VSS International, Inc. (“VSS”) appeals from Chief Administrative Law Judge (“ALJ”) Susan L. Biro’s Initial Decision and Order assessing an administrative civil penalty against VSS for violations of the Oil Pollution Prevention regulations implementing Clean Water Act § 311, as amended by the Oil Pollution Act, 33 U.S.C. § 1321. The violations occurred at VSS’s asphalt emulsion storage facility in West Sacramento, California.