In letters dated February 27 and July 9, 2009, Interstate disclosed violations to EPCRA 313 and CWA 311/SPCC (failure to prepare and/or implement a Spill Prevention, Control and Countermeasures Plan). EPA has determined that it will not seek any penalties against Interstate for these violations because the company appears to have met the conditions for a 100% reduction in gravity-based penalties pursuant to the Small Business Compliance Policy.