On November 20, 2019, an authorized representative of the EPA conducted an inspection of Respondent's facility located in Cotulla, Texas, to determine compliance with the Risk Management Program (RMP) regulations promulgated at 40 CFR Part 68 under Section 112(r) of the CAA, 42 USC 7412(r). Violation of 40 CFR 68.67(e) Process Hazard Analysis (PHA) - The owner or operator failed to promptly address six of the thirty-seven team findings and recommendations in a timely manner for the PHA dated March 13, 2017.