This enforcement action was filed in response to violations to CAA 112(r)(7) which were discovered during a Risk Management Plan (RMP) compliance inspection conducted on 7/15/2009. A total of 13 violations are listed in the CAFO and relate primarily to a.) determination of risk (Census data, population estimates, identification of environmental receptors, use of USGS maps); b) lack of identification of responsible persons and lines of authority; c.) failure to review and update off-site consequence analysis; d.) failure to establish a system to promptly address findings and recommendations from their Process Hazard Analysis (PHA); e.) failure to update, revalidate and retain documentation from previous PHAs for each process covered; f.) failure to annually certify that operating procedures are current and accurate; and g.) failure to submit a single registration form that includes the correct maximum quantity of each regulated substance in each process.