Mid-Atlantice Cooperative Solutions, Inc., d/b/a/ Aero Energy ( Aero ) is engaged in the heating oil and propane business in teh Mid-Atlantic Region. Aero operates a bulk oil storage facility located at 1751 Pulaski Highway, Havre de Grace, Harford County, MD 21078 ( Facility ). The Facility has an above-ground oil storage capacity exceeding 1 million gallons. In 2006, EPA discovered that the Facility failed to submit changes toits Facility Resonse Plan to EPA, as required by 40 C.F.R sub section 112.20(d)(2), and failed to imlement an adequate training and drill/exercise program, required by 40 C.F.R. sub section 112.21. The Part 112 regulatoins were promulgated by EPA under the authority of Section 311(j) of the Clean WAter Act, 33 U.S. C. sub section 1321(j), ( CWA ). The enclosed admistrative Complaint proposes a Class II penalty in the amount of $132,284 against Aero.