Respondent was assessed a civil penalty of $55,000 for five violations of the HRM when it offered for transportation in commerce flammable liquid powered vehicles, a Class 9 hazardous material, as an ¿undeclared shipment" in shipping containers that were not accompanied  by a shipping paper describing the shipment as a hazardous material, were not marked with a UN identification number, were not placarded, when no packing certificate was provided to the vessel operator, and when the required warning statement was not affixed to the access doors of the shipping containers (violation No. 1); it offered the above-described  hazardous materials for transportation  as cargo on a vessel in commerce, when the vehicles'  fuel tanks were more than one-fourth  full and when fuel leaked from the vehicles during conditions normally incident to transportation (violation No. 2); it offered Class 2.2 hazardous  materials, UN l 066, Nitrogen, compressed, as an "undeclared" shipment because it was not accompanied by a shipping paper describing the shipment as a hazardous material and placards were not affixed to the shipping containers (violation No. 3); it had not created and retained records of hazmat employee  training (violation No. 4); and it transported flammable liquid powered vehicles, a Class 9 hazardous  material, for transportation by vessel in commerce  when the vehicle's ignition key was in the ignition (violation No. 5).