This enforcement action was filed in response to violations to CAA 112(r)(7) discovered during a Risk Management Plan (RMP) compliance inspection which was conducted on July 24-25, 2012. Violations include: a.) failure to establish a system to promptly address the Process Hazard Analysis (PHA) team's findings and recommendations; b.) failure to annually certify that operating procedures are current and complete; and c.) failure to establish written operating procedures to maintain the ongoing integrity of the process equipment.