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 ( OPA ). 2. COLUMBIA OIL COMPANY 15221 HIGHWAY 98 MAGNOLIA, COLUMBIA COUNTY, ARKANSAS 71753 FACILITY: J. .M. TALLEY NO. 1, SWD, PERMIT NO. 2553-WR-2, COLUMBIA 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 TALLEY FACILITY, AND SECTION 311(B)(3) OF THE CWA BY UNAUTHORIZED DISCHARGE OF AN UNKNOWN QUANTITY OF OIL FROM THE TALLEY FACILITY INTO AN UNNAMED MARSH IN COLUMBIA COUNTY, ARKANSAS. 4. RELIEF SOUGHT PURSUANT TO SECTION 311(B)(6)(B)(I) OF THE CWA, EPA PROPOSES A CIVIL PENALTY OF $4,200 FOR COUNT 1 AND $10,000 FOR COUNT 2, FOR A PROPOSED TOTAL OF $14,200.