For respondent, at all times relevant to this CAFO, the Facility had a total oil storage of 8,000 gallons, and there was a potential discharge pathway from the storm drains at the Facility driveway several yards to the north of the oil tank, and Cheeney Creek flows through sensitive areas including the Ritchey Nature Preserve, and the oil that Respondent stored, handled refined and/or processed at the Facility could reasonable have been expected to discharge to Cheeney Creek and the White River, and Cheeney Creek is a tributary of and flows into the White River and is therefore a navigable water of the United States, and the White River is an interstate river that is used by interstate travelers for recreational or other purposes, and at all times relevant to this CAFO, Respondent was subject to the oil pollution prevention regulations, and was therefore required to prepare and implement a SPCC Plan in accordance with regulations, and at all times relevant to this CAFO, a secondary containment system surrounded the oil tank, and on March 13, 2015, EPA On-Scene Coordinator Jason Sewell arrived at the Facility in connection with responding to an oil discharge to Cheeney Creek and the White River, and on March 13, 2015 OSC requested a copy of Respondent's SPCC Plan for the facility, and on that day Respondent provided OSC Sewell a copy of their SPCC Plan for the facility, a copy of a four-page undated document titled Spill Containment Plan . On March 18, 2015 authorized repres