On May 1, 2014, EPA inspected Respondent's facility and conducted an evaluation of the Facility's SPCC plan, last revised in September 2012. At that time, the Facility had not prepared,nor submitted an FRP. On February 4, 2015, EPA issued a Notice of Violation to Respondent alleging violations of certain SPCC and FRP regulations (in the NOV).The regulation requires an owner to prepare an SPCC plan that describes the physical layout of the facility and includes a diagram that identifies the location and contents of all regulated fixed oil storage containers, storage areas where mobile or portable containers are located, transfer stations, and connecting pipes. The Facility's SPCC plan did not completely describe the layout of the Facility including the manufacturing equipment in Building 59, or include a diagram that identifies the location of transfer stations in violation of the regulations. The regulations also require where experience indicates a reasonable potential for equipment failure, the SPCC plan must include a prediction of the direction, rate of flow, and total quantity of oil which could be discharged from the facility as a result of each type of major equipment failure. The Facility's SPCC Plan did not include this in violation of the regulations. The regulations require that the owner any buried metallic storage tank installed on or after January 10, 1974 from corrosion and regularly perform leak tests. The SPCC Plan did not address these requirements in regar