THIS ADMINISTRATIVE PENALTY ORDER IS ISSUED TO BRUCE'S SHAMROCK FOR A SPILL THAT OCCURRED ON 4/15/2000 AND FOR FAILURE TO PREPARE AND IMPLEMENT AN SPCC PLAN FOR BRUCE'S SHAMROCK. THIS ACTION IS SUBJECT TO THE 22 RULE WHICH IS ENTERED INTO BY THE PARTIES FOR THE PUPOSE OF SIMULTANEOUSLY COMMENCING AND CONCLUDING THIS MATTER. THE ASSESSED PENALTY FOR THESE VIOLATIONS IS $6,000.