USEPA and OGM, Ltd d/b/a Clean Water Ltd. agreed to settle various causes of action, including that Respondent is the owner of a bulk oil onshore facility and has a total oil storage capacity of greater than or equal to one million gallons; that the Opossum Creek flows into the Great Miami River, which is a navigable river; that Respondent's facility is located such that a discharge from the facility could cause injury to fish and wildlife and sensitive environments; that said facility is an FRP-regulated facility ; that until August 19, 2013, the facility did not have secondary containment for each aboveground storage area and this constitutes a violation; that an FRP should have been submitted to the EPA Regional Administrator no later than August 30, 1994; that Respondent purchased the facility from Perma-Fix of Dayton in March 2008; that Respondent has not submitted an FRP as required, and that said failure to submit an FRP is a violation. USEPA determined that an appropriate civil penalty to settle the violation alleged in this Consent Agreement Final Order (CAFO) is $30.000.00. USEPA considered the seriousness of violation, economic benefit to the violator, history of prior violations and the CWA Penalty Policy, and Respondent's agreement to perform a supplemental environmental project (SEP) costing at least $30,550.00, and it was agreed that Respondent would pay a civil penalty of $14,725.00 within 30 days of the effective date of the CAFO. The Respondent also agreed