Count 1: On 6/7/2012, EPA inspected this facility and determined that Respondent had failed to adequately prepare, maintain and implement an SPCC plan for the facility.
Count 2: On or about 4/9/2012, Respondent discharged an unknown amount of Chevron Rando HD hydraulic oil from its facility into or upon the Shantee Creek and adjoining shorelines. This discharge of oil caused a sheen upon the surface of the Shantee Creek and therefore was determined to be a quantity that may be harmful under 40 CFR 110.3 of Section 311(b)(3) of the Clean Water Act.