EPA alleges that on September 19-20, 2019, the Two Shields Butte 9-8-7 Well Pad had a produced water spill of approximately 962 barrels, which was reported to the National Response Center (NRC) on September 20, 2019, Incident No. 1258852. EPA also alleges that on September28-30, 2019, the Moccasin Creek 8-26 Well Pad had a produced water spill of approximately 3,917 barrels, which was reported to the NRC on September 30, 2019, Incident No. 1259799. EPA alleges that both spills violate CWA section 301, 33 U.S.C. ? 1311. Arrow has agreed to pay a civil administrative penalty of $106,500.00 to resolve its civil penalty liability for these alleged violations.