On or about July 25. 2012. EPA inspected the Facility and determined that Respondent failed to prepare and or implement a facility SPCC plan in violation of 40 C.F.R. § 112.3 in accordance Wth 40 C.F.R. §§ 112.7. 112.8 and 112.20.23. During the inspection described in paragraph 22, above. EPA delivered a l\:otice of Inspection And list of deficiencies to Respondent which included failure to prepare an SPCC ptan in violation of40 C.F.R. § 112.3 and numerous implementation violations of40 C.F.R. §§ 112.7. 112.8. and 112.20.24. On or about August 23.2012. EPA received a copy of Respondent's SPCC plan. 25. On or about January 24, 2013, EPA sent a Notice of Potential Violations Jetter to Respondent describing deficiencies with Respondent's SPCC Plan and continuing violations. 26. On or about March 18. 2013. Respondent submitted a revised SPCC plan and a signed statement of correction.
27. On or about April I 0. 2013. EPA determined that Respondent had corrected the violations identified in the July 25. 2012 inspection.