CAFO issued 2/13/2003, assessing a penalty of $41,992.50. Respondent agrees to complete a SEP. Respondent did not have a management system to oversee implementation of the risk management programs; Respondent had not compiled all written information pertaining to the the technology of the process and the equipment in the process; Respondent had not performed a process hazard analysis or did not maintain documentation which showed that it had performed a process hazard analysis; Respondent had not developed and implemented writtten operating procedures to ensure safe performance of process related activities; Respondent did not have training documentation; Respondent had not corrected equipment deficiencies