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 10/15-16/2012. Violations were related to the following: a.) documentation deficiencies; b.) Process Hazard Analysis (PHA) deficiencies; c.) failure to develop and implement normal shutdown and start-up procedures following a downturn or emergency shutdown; d.) failure to develop and implement procedures which address operating limits, safety and health considerations and safety systems; e.) failure to annually certify that operating procedures are current and accurate; f.) deficiencies in employee training, refresher training and training records; g.) failure to investigate incidents which could have reasonably resulted in a catastrophic release of a regulated substance.