Respondent , as the owner of an SPCC-regulated facility, is subject to the SPCC regulations. Respondent began operating the facility prior to 1984. On June 21 and June 22, 2010 EPA representatives inspected the facility and advised the Respondent of the requirement to prepare and maintain an SPCC Plan. In a Request for Information dated May 14, 2012, EPA requested a copy of Respondent's SPCC plan. In reviewing Respondent's Response, EPA determined that Respondent had failed to prepare and maintain an adequate SPCC plan for the facility. The parties settled on a $9,000 civil penalty. Respondent also agreed to perform a supplemental environmental project (SEP) costing at least $298,000, completing the SEP no later than November 1, 2016.