This enforcement action was filed in response to violations to CAA 112(r)(7) which were discovered during a Risk Management Plan (RMP) compliance inspection conducted on 3/17/2010. Violations included 1.) failure to compile and maintain process safety information before conducting any process hazard analysis (PHA); 2.) failure to update and revalidate the PHA every five years; 3.) failure to implement written procedures to maintain the ongoing integrity of their process equipment; 4.) failure to ensure that the frequency of inspections and tests of their process equipment is consistent with the manufacturers' recommendations and good engineering practices; 5.) failure to correct equipment deficiencies that were outside acceptable limits in a safe and timely manner.