This enforcement action was filed in response to violations detected during a Risk Management Plan (RMP) inspection which was conducted on 6/10/2010. There were 13 violations to CAA 112(r)(7) cited in the court document which include failure to properly estimate populations potentially affected, failure to use appropriate USGS maps, failure to maintain records, failure to annually certify operating procedures, failure to establish and implement written procedures, failure to inspect and test process equipment, failure to obtain and evaluate contract operator's safety programs/performance and failure to identify the facility's correct program level in its Risk Management Plan.