Syllabus

U.S. EPA Region VIII ("Region") appeals from an Initial Decision in which the Administrative Law Judge ("ALJ") assessed a civil penalty of $ 3,500 upon Carroll Oil Company ("Carroll Oil"), an inactive gas station located in Cheyenne, Wyoming, for failing to permanently close its underground storage tanks ("USTs") in accordance with regulations at 40 C.F.R. part 280 subpart G ("UST closure regulations").