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. CROTTY PRODUCTION 412 NORTH TATE NORPHLET, UNION COUNTY, ARKANSAS 71759 FACILITY: EDWARDS 1, 2, 3, 4, 5 LEASES, UNION COUNTY, AR. 3. RESPONDENT WAS IN VIOLATION OF SECTION 311(J) BY FAILING TO IMPLEMENT A SPILL PREVENTION CONTROL AND COUNTERMEAS- URES (SPCC) PLAN FOR THE EDWARDS FACILITY IN UNION COUNTY AND SECTION 311(B)(3) BY AN UNAUTHORIZED DISCHARGE OF OIL FROM ITS EDWARS FACILITY INTO AN UNAMED MARSH IN UNION COUNTY, AR. 4. RELIEF SOUGHT PURSUANT TO SECTION 311(B)(6)(B)(I) OF THE CWA, EPA PROPOSES A CIVIL PENALTY OF $7,000 FOR COUNT 1 AND $10,000 FOR COUNT 2, FOR A PROPOSED TOTAL OF $17,000.