The EPA alleges in the Consent Agreement, that Kennecott failed to provide environmental receptors in their RMP; revise and update their RMP within five years; provide an accurate five-year accident history in the RMP executive summary; properly document a resolution to recommendations from a process hazard analysis; annually certify an operating procedure was current and correct; conduct 33 inspections on temperature and pressure transmitters; document each inspection and test has been performed on process equipment; and inspect and test self-contained breathing apparatus equipment.