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. STARR OPERATING COMPANY 4815 WEST BRAKER LANE, SUITE 502 AUSTIN, TRAVIS COUNTY, TEXAS 78759-5619 FACILITIES: DEWEY BURTON LEASE, RRC 02181, BEXAR COUNTY, TX. JOHN W. NENTWICH LEASE, RRC 06810, BEXAR COUNTY, TX. 3. RESPONDENT WAS IN VIOLATION OF SECTION 311(J) OF THE CWA BY FAILING TO IMPLEMENT A SPILL PREVENTION CONTROL AND COUNTERMEASURES (SPCC) PLAN FOR THE TWO FACILITIES IN BEXAR COUNTY. 4. RELIEF SOUGHT PURSUANT TO SECTION 311(B(6)(B)(I) OF THE CWA, EPA PROPOSES A CIVIL PENALTY OF $3,300 FOR THE BRU- TON LEASE AND $3,750 FOR THE NENTWICH LEASE, FOR A PRO- POSED TOTAL OF $7,050.