Sunoco and USEPA agreed to the settlement of an ESA before the filing of a complaint. On May 18,2015, an EPA representative conducted a compliance inspection of Respondent's facility at River Rouge, Detroit, MI to determine its compliance with the Risk Management Program ( RMP ) and found that Respondent had violated the following regulations: 1. Respondent failed to address the consequence of deviation in the operating procedures; 2. Respondent failed to address the steps required to correct or avoid deviation on the operating limits; 3. Respondent failed to provide refresher training on the operating procedures; and 4 Respondent failed to prepare a training record for each employee that has received the refresher training on the operating procedures. The civil penalty agreed to was $3,600.00