This enforcement action has been filed in response to violations discovered during a CAA 112(r)(7) (Risk Management Plan) inspection which was conducted on 07/08/2008. Violations included: 1.) failure to annually certify that operating procedures are current and accurate; 2.) failure to document training records for each employee involved in an operating process; 3.) failure to provide refresher training at least every three years to each employee involved in an operating process; 4.) failure to establish and implement written procedures for the maintenance of process equipment; 5.) failure to ensure the frequency of inspections and tests of process equipment according to the manufacturer's recommendations and good engineering practices; 6.) failure to document the inspections and tests which have been done on process equipment.