This enforcement action was filed in response to violations of CAA 112(r)(7) which were discovered during a Risk Management Plan (RMP) inspection conducted on 9/3/2009. Violations included: failure to establish a system to address findings from the process hazard analysis; failure to update and revalidate the process hazard analysis at least every five years; failure to certify annually that operating procedures are current and accurate; failure to provide refresher training on operating procedures to the employees who are operators of the process.