Based on the findings of a CAA 112(r)(7) Risk Management Plan (RMP) inspection and documents submitted by the Respondent, the EPA has determined that the following RMP violations occurred at the facility: 1.) failure to maintain supporting documentation to analyze worst case and alternate release scenarios; 2.)failure to establish a system to promptly adress the PHA team's findings and recommendations; 3.) failure to adequately develop operating procedures; 4.) failure to provide operators with refresher training; 5.) failure to address the 3/8/2007 compliance audit's findings and recommendations and 6.) failure to conduct a compliance audit at least once every three years.