This enforcement action was filed in response to violations of CAA 114(r)(7) which were discovered on 9/1/2010 during a Risk Management Program (RMP) compliance inspection. Violations include: 1.) Failure to assure that the facility's 2009 process hazard analysis (PHA) recommendations were resolved in a timely manner and 2.) Failure to certify at least once every three years that the facility's developed procedures and practices are adequate and in compliance with the provisions of the Risk Management Program.