From August 13-15, 2019, an authorized representative of the EPA conducted a compliance inspection of the Respondent facility to determine compliance with the Risk Management Plan (RMP) regulations promulgated at 40 C.F.R. Part 68 under Section 112(r) of the Act, 42 U.S.C. 7412(r). EPA found that required trainings did not occur within the time interval deadline specified by Respondent. This is a violation of the three-year refresher training requirement in 40 C.F.R. 68.71(6). In one Management of Change (MOC), training of employees associated with the process was not completed prior to start-up after the changes were implemented. This is a violation of he training requirement in 40 C.F.R. 68.75(c). A report for an incident on July 19, 2017, did not include the date the investigation began. Additionally, documentation listing all personnel whose job tasks are relevant to the incident findings did not include contract employees. This is a violation of the incident investigation requirements of 40 C.F.R. 68.81.