This is a administrative penalty action for Respondent's failure to submit a Risk Management Plan to EPA prior to facility start-up in January 2009. Respondent had timely submitted a comparable safety program under the state of Nevada's Chemical Accident Prevention Program but had not submitted its RMP to EPA by the time of start-up. Prior to initiation of this action the facility did submit its RMP, at an estimated additional cost of $5000. Respondent has agreed to pay a civil penalty of $8400.