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. DAN REYNOLDS COMPANY 819 LAKEWOOD ROAD CAMDEN, OUACHITA COUNTY, ARKANSAS 71701 FACILITIES: SHIREY LEASE, OUACHITA COUNTY, ARKANSAS MINOR, MEEKINS, MCELROY A AND B LEASE, OUACHITA COUNTY, ARKANSAS 3. RESPONDENT WAS IN VIOLATION OF SECTION 311(J) OF THE CWA FAILING TO IMPLEMENT A SPILL PREVENTION CONTROL AND COUNTERMEASURES (SPCC) PLAN IN THE SHIREY AND MINOR FACI- LITIES IN OUACHITA COUNTY, ARKANSAS. 4. RELIEF SOUGHT PURSUANT TO SECTION 311(B)(6)(B)(I) OF THE CWA, EPA PROPOSES A CIVIL PENALTY OF $7,500 FOR COUNT 1 AND $10,500 FOR COUNT 2, FOR A PROPOSED TOTAL OF $18,000.