This enforcement action was filed in response to multiple violations to CAA 112(r)(7) discovered during a Risk Management Plan (RMP) inspection conducted on 2/3/2010. Violations include 1.) failure to review and update the offsite consequence analyses once every five years; 2.) failure to ensure that problems identified in hazard reviews were resolved in a timely manner; 3.) failure to ensure that employees presently operating or newly assigned to covered processes had been trained and tested competent in the operating procedures for those processes; 4.) failure to provide refresher training at least every three years; 5.) failure to train each employee involved in the ongoing mechanical integrity associated with each process; 6.) failure to investigate each incident which resulted in or could have resulted in a catastrophic chemical release; 7.) failure to compile, revise and update their Risk Management Plan within five years of its initial submission or most recent update.