This enforcement action was filed in response to CAA 112(r)(7) violations discovered during a Risk Management Plan (RMP) inspection which was conducted on 4/8/2010. Violations included: failure to update and revalidate the process hazard analysis every 5 years; failure to retain the process hazards analyses and documented resolutions of recommendations from the PHA team for the life of the process; failure to annually certify that the operating procedures are current and accurate; failure to provide refresher training on operating procedures to the operators.