PVS failed to conduct a complete process hazard analysis, control open-ended valves or lines, develop written procedures for alarm response, inspect and test toxic gas detection alarms, establish and implement mechanical integrity procedures for in-service piping systems, and include rail tank car storage as a covered process in its Risk Management Plan filing. This CAFO requires PVS to pay a penalty of $174,000 and resolves the FOV issued to PVS on December 3, 2024.