On July 23, 2014, an EPA representative conducted a compliance inspection of Respondent's facility, located in Ludington, Michigan to determine its compliance with the RMP regulations, and based on that inspection EPA determined that Respondent violated the following regulations: 1. 40 CFR Sec. 68.67(e) - Respondent failed to establish a system to promptly address the 2012 Process Hazard Analysis findings and recommendations; 2. 40 CFR Sec. 68.73(e) Respondent failed to document deficiencies in equipment that is outside acceptable limits before further use; 3. 40 CFR Sec. 68.79(d) Respondent failed to promptly determine and document an appropriate response to each of the findings of the 2013 compliance audit and document that those deficiencies have been corrected. USEPA and Respondent agreed to an Expedited Settlement account under CAA 112(r)(7) with a civil penalty of $2,700, within 45 days of receipt of the ESA.