This enforcement action was filed in response to violations discovered during a CAA 112(r)(7) (Risk Management Plan) inspection conducted on 7/28/2011. Respondent's Risk Management Program, prepared on 9/14/2010, failed to include numerous elements required by the RMP regulation. Respondent's failure to develop and implement a complete Risk Management Program at this facility is a violation of the requirements of 40 CFR 68.12(c).