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. LAMBERT OIL CO. 412 NORTH TATE NORPHLET, UNION COUNTY, ARKANSAS 71759 FACILITY: HAYES LEASE, UNION COUNTY, ARKANSAS 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 HAYES LEASE FACILITY IN UNION COUNTY, ARKANSAS AND SECTION 311(B)(3) OF THE CWA BY THE UNAUTHORIZED DISCHARGE OF AN UNKNOWN QUANTITY OF OIL FROM THE HAYES FACILITY INTO AN UNNAMED MARSH IN UNION 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 $10,000 FOR COUNT 2, FOR A PROPOSED TOTAL OF $17,500.