The United States Environmental Protection Agency (EPA), Region IX and K Oue, Limited (Respondent) (collectively the Parties) agree to settle this matter and consent to the entry of this Consent Agreement and Final Order (CA/FO). This CA/FO commences and concludes this proceeding in accordance with 40 C.F.R. Sections 22.13(b), 22.18(b)(2) and 22.45(b). Respondent agrees to the assessment of a civil penalty in the amount of $88,545 for the violations.