NO SPCC PLAN. COMPANY FAILED TO DEVELOP PROCEDURES, METHODS AND REQUIREMENTS FOR PREVENTING THE DISCHARGE OF OIL. COMPANY ALSO HAD AN OIL SPILL LAST WINTER. ALLEGEDLY, THE SPILL RESULTED FROM VANDALISM (A CONTROL VALVE TURNED ON AND LEFT UNATTENDED). THE SPILL REACHED A SMALL CREEK IN THE AREA. IF COMPANY HAD HAD AN SPCC PLAN AND CONTROL PROCEDURES IN PLACE (RESTRICTED ACCESS, SECONDARY CONTAINMENT), THE SPILL COULD PROBABLY HAVE BEEN PREVENTED OR AT LEAST CONTAINED WITH NO ENVIRONMENTAL HARM. AEP