This enforcement action was filed in response to violations discovered during a CAA 112(r)(7) Risk Management Plan inspection conducted on July 22, 2013. Violations included: 1) failure to conduct a hazard review when a major change in process occurs; 2) failure to ensure that each employee was trained on the processes and procedures that pertain to their duties; 3) failure to implement procedures to maintain the ongoing mechanical integrity of raincaps; 4) failure to perform inspections and tests of emergency safety valves at a frequency consistent with applicable manufacturers' recommendations, industry standards, or good engineering practices; 5) failure to certify every three years that procedures and practices developed under the rule are adequate and being followed; and 6) failure to revise and update their Risk Management Plan within 6 months of a change that requires a revised PHA or hazard review.