On May 21, 1999, having held for use in its operations at the Alma facility 2,500 lbs. or more of chlorine, Respondent, the City of Alma, exceeded the applicability threshold established by 40 CFR Section 68.130. Respondent's process is subject to Program 3 requirements because the distance to public receptors is less than the distance to the toxic endpoint for a worst-case release assessment under 40 CFR Section 68.25 and because the process is subject to the process safety management standards. Based on the inspection conducted on February 28, 2013, and a review of additional information received by EPA subsequent to that date, EPA identified the following alleged violations by Respondent of the Risk Management Program regulations: a0 Failure to have information pertaining to the technology of the process that included safe upper and lower limit; b) Failure to have information pertaining to the technology of the process that included an evaluation of the consequences of deviation; c) Failure to have information pertaining to the equipment in process that included relief system design and design basis, as required; d) Failure to document that equipment complies with recognized and generally accepted good engineering practices as required; e) failure to perform an initial process hazard analysis; f) Failure to develop and implement written operation procedures that address emergency shutdown; g) Failure to develop and implement written operating procedures that address a star