On or about 7/12/2010, Hubbard Feeds discharged an estimated 3,927 gallons of soybean oil via a storm sewer into Loramie Creek which is a tributary of the Ohio River and therefore considered a navigable water of the United States. This facility submitted its most current SPCC Plan to the EPA on 11/30/2012. Upon review of the plan, EPA determined that Respondent had failed to adequately prepare, maintain and implement such an SPCC Plan for the facility.