RESPONDENT FAILED TO DEVELOP A MANAGEMENT SYSTEM TO OVERSEE THE RISK MANAGEMENT PROGRAM ELEMENTS; DID NOT ESTABLISH WRITTEN PROCEDURES TO MAINTAIN THE ON-GOING INTEGRITY OF PROCESS EQUIPMENT; INSPECTIONS AND TESTING PROCEDURES PERFORMED ON MULTIPLE PROCESS VESSELS DID NOT FOLLOW RECOGNIZED AND GENERALLY ACCEPTED GOOD ENGINEERING PRACTICES WHICH VIOLATED PREVENTION OF ACCIDENTAL RELEASES .