On November 5, 2018, EPA Region IX inspected the Lanai Facility to evaluate compliance with the requirements of 40 C.F.R. Part 112. Based on that inspection and the review of documentation provided by the Respondent, EPA determined that the Respondent had not prepared an adequate SPCC Plan or implemented all requirements of 40 C.F.R. Part 112. For instance, Respondent failed to conduct a review and evaluation of the SPCC plan at least once every five (5) years, conduct integrity testing of the aboveground storage tanks (ASTs), and properly permanently close out of service ASTs. Respondent entered into an Administrative Order on Consent (EPA Docket No. OPA-311-09-2020-001) with EPA, effective May 15, 2020, to come into full compliance with the Oil Pollution Prevention Regulations at this Facility. This Consent Agreement and Final Order issued pursuant to 40 C.F.R. Sections 22.13 and 22.18 (CA/FO) simultaneously commences and concludes this proceeding, wherein EPA alleges that the Respondent violated Section 311(j)(1)(C) of the CWA, 33 U.S.C. Section 1321(j)(1)(C), and its implementing regulations.