This enforcement action was filed in response to Risk Management Plan violations discovered during a CAA 112(r)(7) compliance inspection which was conducted on 7/14/2011. Violations include: 1.) Failure to use most recent Census data to estimate the population potentially affected; 2.) Failure to maintain supporting documentation used to analyze the alternate release scenario; 3.) Failure to include in its the operating procedures the procedures used when chlorine is delivered on site; 4.) Failure to include emergency shutdown procedures in the operating procedures; 5.) Failure to annually certify that the operating procedures are current and accurate; 6.) Failure to provide the operators with refresher training on the operating procedures; and 7.) Failure to conduct a compliance audit.