1. SECTION 311(B)(6)(B)(I) OF THE CLEAN WATER ACT ( CWA ), 33 U.S.C. SECTION 1321(B)(6)(B)(I), AS AMENDED BY THE OIL POLLUTION ACT OF 1990. 2. GINCO OPERATING COMPANY 4241 CENTER GATE SAN ANTONIO, BEXAR COUNTY, TEXAS 78217-4802 3. RESPONDENT WAS IN VIOLATION OF SECTION 311(J) OF THE CWA BY FAILING TO IMPLEMENT A SPILL PREVENTION CONTROL AND COUNTERMEASURE (SPCC) PLAN FOR ITS K.L. BECK LEASE, RRC 00541 FACILITY IN BEXAR COUNTY, TEXAS. 4. RELIEF SOUGHT PURSUANT TO SECTION 311(B)(6)(B)(I) OF THE CWA, EA PROPOSES A CIVIL PENALTY OF $4,375.