This enforcement action was filed in response to violations of CAA 112(r)(7) which were discovered during a Risk Management Program inspection conducted on 9/9/2008. Either the Respondent or Respondent's predecessor failed to do the following: 1.) Compile and maintain safety information on the anhydrous ammonia tanks and dissociators; 2.) Conduct a process hazard analysis; 3.) Develop written emergency shutdown procedures; 4.) Provide refresher training to the operators; 5.) Prepare and implement procedures to maintain the on-going mechanical integrity of the equipment related to the storage and use of ammonia; 6.) Conduct inspections and tests on the process equipment; 7.) Establish written change management procedures; 8.) Conduct compliance audits and 9.) Evaluate contractors' safety performance records and programs prior to selecting the contractor who performs maintenance on their processes.