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 8/11/2010. Violations include: 1.) failure to annually certify that operating procedures are current and accurate; 2.) failure to keep training records for employees operating the refrigeration system; 3.) failure to perform inspections and tests of the process equipment; and 4.) failure to schedule inspections and tests of equipment consistent with the manufacturer's recommendations and good engineering practices.