EPA conducted and RMP inspection and subsequent review of the Respondent facility on January 29, 2020. The Respondent violated: 40 CFR 68.67(e) by failing to resolve in a timely manner PHA findings and recommendations; 40 CFR 68.69(d) by failing to develop and implement a written operating procedure that provided clear instruction for safely conducting activities involved in a covered process; 40 CFR 68.69(c) by failing to annually certify that operating procedures were current and accurate; and, 40 CFR 68.71(b) by failing to conduct refresher training at least every three years to employees involved in operating a process.