CAFO issued 2/11/2005, assessing a penalty of $21,700. Respondent did not develop a management system to oversee the implementation of the RMP elements (40 C.F.R. Section 68.15(a)). Respondent did not assign a qualified person or position that has the overall responsibility for the development, implementaion and integration of the RMP elements (40 C.F.R. Section 68.15(b)). Respondent did not document other persons responsible for implementing individual requirements of the RMP and defined the lines for authority through an organization chart or similar doucment (40 C.F.R. Section 68.15(c)). Respondent did not compile and maintain the following up-to-dte RMP safety information pertaining to: Technology of the Process, Process Equipment. Respondent did not perform and document an intitial process hazard analysis (40 C.F.R. Section 68.67(a)). Respondent did not develop and implement written operating procdures that provide instructions or steps for conducting activities associated with each covered process 40 C.F.R. Section 68.69(a)). Respondent did not annually certify that the operating procedures are current and accurate, and that procedures have been reviewed as often as necessary (40 C.F.R. Section 68.69(c)). Respondent did not ascertain and document in a record that each employee involved in operating the process has received and understood required training (40 C.F.R. Section 68.71(c)). Respondent did not establish and implement written procedures to maintain the