Respondent is the City of Hammond, Indiana Water Works Department (HWWD), a municipal owned utility. USEPA and Respondent agreed to settle the following causes of action through a Consent Agreement and Final Order (CAFO) executed on October 28, 2014. Respondent used, stored, handled, and moved, multiple one ton containers of the regulated substance chlorine at the facility in amounts over the threshold quantity of 2,500 pounds per year. The Facility?s chlorine process did not meet the Program 1 requirements of 40 CFR 68.10(b). Respondent?s chlorine process was subject to the Program 3 Risk Management Program (RMP) requirements. Count 1: Respondent failed to document the names or positions of the individuals responsible for the implementation of the RMP elements, and the lines of authority between them violated 40CFR 68.15(c) and Section 112(r)(7) of the Clean Air Act. Count 2: Respondent failed to analyze and report in its 2011 RMP one worst case scenario that was estimated to create the greatest distance in any direction to a specified endpoint resulting from an accidental release under 40CFR68.25(a)(2)(i). Count 3. Respondent failed to estimate the population potentially affected by a chemical accident at the Facility to two significant digits 40CFR 68.30(d). Count 4. Respondent failed to review and update the offsite consequence analysis for the Facility since it submitted its RMP in 1999, and at least once every five years 40CFR 68.36(a). Count 5. Respondent failed to mai