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. JACK L. TURNER 800 EASTRIDGE DRIVE EL DORADO, UNION COUNTY, ARKANSAS 71730 FACILITY: SOUTHERN COMPANY D LEASE , UNION COUNTY, AR. 3. RESPONDENT WAS IN VIOLATION OF SECTION 311(J) OF THE CWA BY A FAILING TO IMPLEMENT A SPILL PREVENTION CONTROL AND COUNTERMEASURES (SPCC) PLAN FOR THE SOUTHERN FACILITY, AND SECTION 311(B)(3) OF THE CWA BY UNAUTHORIZED DIS- CHARGE OF AN UNKNOWN QUANTITY OF OIL FROM THE SOUTHERN FACILITY INTO AN UNNAMED POND AND ADJOINING SHORELINES IN UNION OUNTY, ARKANSAS. 4. RELIEF SOUGHT PURSUANT TO SECTION 311(B)(6)(B)(I) OF THE CWA, EPA PROPOSE A CIVIL PENALTY OF $9,800 FOR COUNT 1, AND $10,000 FOR COUNT, FOR A PROPOSED TOTAL OF $19,800.