On December 3, 2013, EPA conducted a compliance inspection of Respondent’s facility to determine compliance with the Risk Management Plan (RMP) regulations promulgated at 40 C.F.R. part 68 under section 112(r)(7) of the Act. The EPA found that the Respondent had violated regulations implementing section 112(r)(7) of the Act by failing to comply with the specific requirements outlined in the attached RMP Program Level 3 Process Checklist-Alleged Violations & Penalty Assessment (Checklist and Penalty Assessment). The Checklist and Penalty Assessment is incorporated into this ESA.