Count 1 - there was an oil discharge from Palmer Wellbore #1H beginning on 5/4/2014 into a navigable water of the U.S. which violated applicable water standards and/or caused a sheen on the surface of the water.
Count 2 - there was an insufficient amount of catchment basins or diversion structures onsite of Palmer Wellbore #1H to intercept and contain the discharge of oily drilling fluids emitting from the wellbore
Therefore, Respondent violated Section 311(j) of the CWA