EPA Region III filed a signed Consent Agreement and Final Order ( CAFO ) resolving an action against George Mason University for suspected violations of Section 311(b)(3) and (j) of the Clean Water Act, in connection with its fuel storage and use facility in Fairfax, Virginia. Specifically, EPA alleged that Respondent discharged oil or a hazardous substance into or upon the navigable waters of the United States or adjoining shorelines in such quantities that may be harmful to the public health in violation of Section 311(b)(3) of the CWA. EPA also alleged that Respondent failed to prepare and implement an SPCC Plan for the Facility as follows: failed to comply with 40 C.F.R. 112.3(d) because its SPCC plan was not properly certified by a registered professional engineer; failed to comply with 40 C.F.R. 112.7 because the SPCC plan did not follow the sequence specified by the SPCC rule or, in the alternative, did not include a cross reference identifying the location of each item; failed to comply with 40 C.F.R. 112.7(a)(3) because the Facility diagram in the SPCC plan omitted certain tanks present at the Facility; failed to comply with 40 C.F.R. 112.7(b) because the SPCC plan did not discuss consequences resulting from any type of major equipment failure; failed to comply with 40 C.F.R. 112.7(f) because the SPCC plan did not discuss discharge prevention briefings; failed to comply with 40 C.F.R. 112.8 (c)(1) because the SPCC plan did not discuss whether the container materia