This enforcement action was filed in response to violations discovered during a CAA 112(r)(7) (Risk Management Plan) inspection conducted on 9/15/2010. Violations include: 1.) failure to develop procedures for the storage of chlorine, sulfur dioxide and aqua ammonia; 2.) failure to develop emergency shutdown and operations procedures; 3.) failure to provide refresher training on operating procedures; 4.) failure to develop a compliance audit report.