This enforcement action was filed in response to violations discovered during a Risk Management Plan (RMP/CAA 112(r)(7)) inspection which was conducted on 8/18/2009. Violations included failure to develop and implement written operating procedures, failure to train employees involved in operating a process, failure to establish written procedures to maintain the ongoing integrity of the process equipment, failure to document tests and inspections performed on process equipment, failure to conduct an audit of the prevention program within three years.