EPA ALLEGES THAT RESPONDENT FAILED TO DEMONSTRATE THAT IT HAD: TIMELY SUBMITTED A RISK MANAGEMENT PLAN, LISTED IN THE RISK MANAGEMENT PLAN THE ENVIRONMENTAL RECEPTORS WITHIN A RADIUS DETERMINED BY THE DISTANCE TO THE ENDPOINT OF A RELEASE, MAINTAINED RECORDS OF OFFSITE CONSEQUENCE ANALYSIS, AND CONDUCTED A COMPLIANCE AUDIT OF THEIR RISK MANAGEMENT PROGRAM AT LEAST EVERY THREE YEARS. ALSO, RESPONDENT SELF-DISCLOSED SIMILAR VIOLATIONS AT ITS HOLDEN AND SMOKEHOUSE FACILITIES.