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. SEAGULLOPERATING CO.,INC. 1215 MID-SOUTH TOWER 416 TRAVIS STREET SHREVEPORT, LOUISIANA 71101 FACILITIES: BEXAR COUNTY, TEXAS 1. KURZ C LEASE, RRC 11240 2. HEICKMAN A LEASE, RRC 10840 3. W. F. HEICKMAN LEASE, RRC 04079 4. DOWNIE LEASE, RRC 11234 5. HENLEY LEASE, RRC 11220 6. CARTER LEASE, RRC 11224 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 THE 6 FACILITIES IN BEXAR COUNTY. 4. RELIEF SOUGHT PURSUANT TO SECTION 311(B)(6)(B)(I) OF THE CWA, EPA PROPOSES A TOTAL CIVIL PENALTY OF $19,550 (COUNT 1 - $3,450, COUNT 2 - $3,450, COUNT 3 - $3,450, COUNT 4 - $3,450, COUNT 5 - $3,450, AND COUNT 6 - $2,300).