The Chief Counsel assessed a civil penalty of $5,670 for three violations of the HMR, including representing, certifying and marking UN standard packaging as being reconditioned and meeting the reconditioning requirements of the HMR when the leakproofness test was not conducted, when the reconditioning markings were incorrect, and while failing to provide hazardous materials training in general awareness, safety, function specific and security awareness in accordance with the requirements of the HMR.  The Chief Counsel did not credit Respondent's claim that it had ceased operations due to Respondent's failure to provide any evidence to support the claim.