EPA conducted an inspection and records review on April 9-11, 2019. Respondent violated: 40 CFR 68.67(e) by failing to timely address Action items according to the timeframe set in Respondent's PHA Procedure; 40 CFR 68.69(a) by failing to fully develop the operating procedures for emergency shutdown and startup following a turnaround or emergency shutdown; 40 CFR 68.7l(b) by failing to conduct refresher trainings for certain employees within three years; 40 CFR 68.73(e) by failing to document equipment deficiencies identified from mechanical integrity inspections; 40 CFR 68.75 by failing to conduct Management of Change properly on two occasions; and, 40 CFR
68.85(b) by failing to document all the requirements of Hot Work Permits on two occasions.