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. ARCADIA EXPLORATION AND PRODUCTION CO. 3838 OAK LAWN AVE., SUITE 650 DALLAS, DALLAS COUNTY, TEXAS 75219 FACILTY: SMITH L LEASE NO. 2, RRC LEASE ID NO. 108840, PORTLAND, SAN PATRICIO COUNTY, TEXAS 3. RESPONDENT WAS IN VIOLATION OF SECTION 311 OF THE CWA BY (1) NO EVIDENCE OF THREE YEAR REVIEW OF PLAN BY OWNER/ OPERATOR; (2) SPCC PLAN DOES NOT DISCUSS APPROPRIATE CON- TAINMENT/DIVISIONARY STRUCTURES/EQUIPMENT; (3) INSPECT- IONS REQUIRED BY 40 CFR PART 112 ARE NOT IN ACCORDANCE WITH WRITTEN PROCEDURES DEVELOPED FOR THE FACILITY; (4) WRITTEN PROCEDURES AND A RECORD OF INSPECTIONS ARE NOT SIGNED BY FACILITY SUPERVISOR; (5) WRITTEN PROCEDURES AND A RECORD OF INSPECTIONS ARE NOT MAINTAINED FOR THREE YEARS; (6) NO DESIGNATED PERSON RESPONSIBLE FOR SPILL PREVENTION; AND (7) INADEQUATE OR NO FLOWLINE MAINTENANCE PROGRAM. 4. RELIEF SOUGHT PURSUANT TO SECTION 311(B)(6)(B)(I) OF THE CWA, EPA ASSESSED THE RESPONDENT A CIVIL PENALTY OF $650 FOR THE VIOLATIONS CITED AND ISSUED A COMPLIANCE ORDER REQUIRING THE RESPONDENT TO CORRECT THE VIOLATIONS.