CAFO issued 9/14/2004, assessing a penalty of $14,700. Respondent failed to adequately implement a provision of 40 C.F.R. Section 68.67(e) when: The Respondent's process hazard analyses did not address engineering and administrative controls, consequences or failure of engineering and administrative controls, stationary source siting and human factors; The Respondent did not properly document a written schedule for when process hazard analyses recommendations were to be completed; and The Respondent did not update and re-validage the process hazard analyses for acrylonitrile within the required five year period