ON SEPTEMBER 27, 2000, EPA, REGION III FILED A CLASS II ADMINISTRATIVE COMPLAINT AGAINST PARKER OIL CO., INC., A BULK OIL STORAGE FACILITY IN KEYSVILLE, VIRGINIA. IN ITS COMPLAINT EPA ALLEGES THAT PARKER OIL CO., INC. VIOLATED 40 C.F.R. PART 112 DUE TO SEVERAL OMISSIONS OR INADEQUACIES IN ITS SPILL PREVENTION CONTROL AND COUNTERMEASURE (SPCC) PLAN AND FAILURE TO COMPLETE AND MAINTAIN A FACILITY RESPONSE PLAN CERTIFICATION FORM. THESE VIOLATIONS SUBJECT PARKER OIL CO., INC. TO PENALTIES UNDER SECTION 311(B)(6) OF THE CLEAN WATER ACT, AS AMENDED 33 U.S.C. SECTION 1321(B)(6). THE ADMINISTRATIVE COMPLAINT PROPOSES TO ASSESS A PENALTY OF $52,272.68.