This enforcement action was filed in response to violations of CAA 112(r)(7), which were discovered during a Risk Management Plan compliance inspection conducted on 7/27/2011. Violations include: (1) failure to document information pertaining to personnel responsibilities, to the technology and equipment in the process related to construction materials, electricial classification, relief system design and design basis; (2) failure to perform process hazard analyses that addressed potential for catastrophic consequences of previous incidents, stationary source siting, and human factors; (3) failure to certify that operating procedures are current and accurate; (4) failure to provide refresher training at least every three years to each employee involved in the process, as well as failure to maintain emmployee training records; (5) failure to establish written procedures to maintain the integrity of the process including employee training on the maintenance of the equipment, failure to ensure the frequency of inspections and tests of the process equipment and failure to document each inspection and test done on the process equipment; (6) failure to perform appropriate checks and inspections to ensure the equipment was installed properly; (7) failure to periodically evaluate the performance of the contractor owner operator in fulfilling its obligations.