ON OCTOBER 12, 2005, EPA INSPECTED THE FACILITY AND FOUND A VIOLATION OF THE SPCC REGULATIONS, 40 CFR PART 112 REQUIRING THAT THE FACILITY PREPARE AND IMPLEMENT AN SPCC (SPILL PREVENTION, CONTROL AND COUNTERMEASURE) PLAN. ON FEBRUARY 13 2006 EPA SENT THE FACILITY AN EXPEDITED SETTLEMENT OFFER WHICH WAS SIGNED AND RETURNED BY THE FACILITY ON MARCH 8, 2006.