This enforcement action was filed in response to violations discovered during a Risk Management Plan (RMP) compliance inspection conducted on 5/31/2012. Violations of CAA 112(r)(7) include: 1.) failure to review and update the offsite consequences analysis at least once every five years; 2.) failure to conduct process hazard analyses that address stationary source siting and human factors; 3.) failure to annually certify that operating procedures are current and accurate; 4.) failure to establish written operating procedures to maintain the integrity of process equipment such as the crane and the chlorine sensors; 5.) failure to perform inspections and tests on the crane at a frequency consistent with the manufacturer's recommendations and good engineering practices; 6.) failure to determine and document responses to each of the findings in their compliance audit including correction of the deficiencies.