Respondent is a corporation with place of business in River Rouge, Michigan, and is the owner and operator of an onshore bulk oil storage facility. Operations commenced there in 1992. The Facility has an aggregate aboveground storage capacity of over 1,320 gallons in containers, each with a shell capacity of at least 55 gallons. The facility could reasonably be expected to discharge oil to a navigable water of the United States, and is therefore subject to the SPCC regulations. On March 23 and 24, 2015, EPA inspected the facility and conducted an evaluation of the Integrated Contingency Plan (IPC), which contained the Facility's SPCC plan and FRP, last reviewed in April, 2014. On November 23, 2015, EPA issued a Notice of Violation to Respondent alleging violations of certain SPCC and FRP regulations, as outlined in the CAFO's Factual Allegations and Alleged Violations. The civil penalty deemed to be an appropriate civil penalty to settle this action is $165,000.