ON MARCH 16, 2011, THE BANKRUPTCY TRUSTEE IN THE IN RE FREBO, INC ISSUED TO EPA A PENALTY, WHICH SETTLES EPA'S CLAIM AGAINST AVON FUEL AND SUPPLY CO. ( AVON ) AND FREBRO, INC ( FREBO ) FOR THEIR FAILURE TO HAVE A FACILITY RESPONSE PLAN ( FRP ) FOR THEIR FUEL OIL STORAGE FACILITY IN AVONDALE, CHESTER COUNTY, PENNSYLVANIA IN VIOLATION OF SECTION 311(j) OF THE CLEAN WATER ACT, AND THE REGULATIONS CODIFIED AT 40 C.F.R. SECTION 112.20.