ON FEBRUARY 3, 2014, EPA SENT A SHOW CAUSE LETTER TO SEABOARD ASPHALT PRODUCTS COMPANY ( SEABOARD OR RESPONDENT ) REGARDING EPA'S ALLEGATION THAT RESPONDENT VIOLATED SECTION 311(j) OF THE CWA, 33 U.S.C. SECTION 1321(j), FOR FAILURE TO COMPLY WITH THE OIL POLLUTION PREVENTION REGULATIONS OF 40 C.F.R. PART 112. SPECIFICALLY, EPA ALLEGED THAT SEABOARD FAILED TO PREPARE AND IMPLEMENT A SPILL PREVENTION, CONTROL AND COUNTERMEASURE ( SPCC ) PLAN FOR ITS FACILITY AND FAILED TO MEET THE REQUIREMENTS FOR SPECIFIC DISCHARGE PREVENTION AND CONTAINMENT PROCEDURES.