THE FACILITY WAS INSPECTED ON OCTOBER 8, 2014 FOR COMPLIANCE WITH THE RISK MANAGEMENT PROGRAM REGULATIONS 40 C.F.R. PART 68. EPA ALLEGES THAT RESPONDENT DID NOT (1) PROVIDE REFERSHER TRAINING AT LEAST EVERY 3 YEARS TO ITS EMPLOYEES [68.54(b)], (2) PREPARE AND IMPLEMENT PROCEDURES TO MAINTAIN PRODCESS EQUIPMENT [68.56(a)]; AND (3) CERTIFY COMPLIANCE AUDITS [68.58(a)]. AN EXPEDITED PENALTY ACTION AND CONSENT AGREEMENT WAS ISSUED TO THE COMPANY FOR THE VIOLATIONS.