The Chief Counsel assessed a civil penalty of $3,500 for three violations of the HMR: representing, marking, and certifying DOT specification compressed gas cylinders as having been requalified in accordance with the HMR, when it (1) failed to calibrate its test equipment at a pressure within 500 pai of the test pressure at which one cylinder was retested and its calibrated cylinder showed permanent expansion on several other occasions; (2) its records of cylinder requalification failed to identify the actual test operator; and (3) it failed to notify the Associate Administrator in writing of a change in personnel performing cylinder requalification testing. The penalty assessed in the order reflected reductions for corrective actions (already taken in the notice of probable violation) and additional reductions for dismissal of parts of violations Nos. 1 and 2 and the overlapping nature of violations Nos. 2 and 3 (which were combined for purposes of determining an appropriate penalty).