Central Site Development, LLC, (Central Site) seeks an award of attorney fees and expenses in accordance with the Equal Access to Justice Act, 5 U.S.C. § 504 (EAJA), and the Commission’s Rules Implementing EAJA, 29 C.F.R. §§ 2204.101-.311, for costs incurred in litigating two items cited by the Secretary in a Citation and Notification of Penalty, issued April 4, 2016.