This enforcement was filed in response to violations of CAA 112(r)(7), which were discovered during a risk management plan compliance inspection conducted on 9/1/2011. Violations include: 1) failure to develop a management system to oversee the implementation of the risk management plan, including documentation, scheduling and maintenance of process operations; 2) failure to update and evaluate the process hazard analysis every five years; 3) deficiencies in written procedures as well as employee training; 4) failure to follow the frequency of inspections of process equipment along with the correction of any such deficiencies in this equipment; 5) problems in responding to and documenting incidents as well as acting on recommendations resulting from incident investigations; 6) failure to submit corrected emergency contact information within one month of change.