Respondent owns and operates several solvent blending, storage, and distribution facilities located in Iowa and Kansas. On July 17, 2007, a series of fires and explosions occurred at a KS Facility. The cause of the incident was a static charge that ignited Special Naphtholite 66/3 (VM&P), an EHS listed under Section 112(r)(3) of the CAA, while it was being unloaded from a tractor trailer into an above ground storage tank. The initial explosion of this EHS led to further fire and explosions of multiple above ground storage tanks. Debris from exploding tanks was launched through the air causing extensive damage to the Facility, as well as to nearby office buildings and a residential trailer. The fire and explosions also caused the release of several hazardous substances and EHSs stored in the tanks including xylene, ethyl benzene, methanol, acetone, toluene, and methyl isobutyl ketone. These releases continued to fuel the fire and ultimately impacted the soil, water, and air of the Facility and neighboring properties. Run-off containing these substances and fire suppressants from the Facility reached a sanitary sewer drain and was later detected in the sludge at the wastewater treatment plant’s aeration basin. The fire and explosions at the Facility were investigated by the Kansas State Fire Marshall (KSFM). KSFM issued a report on the incident dated July 17, 2007. The Report concluded that several factors may have contributed to the incident including: