This Complaint and Settlement Agreement is issued to Chevron USA for violations at their Wilson Creek facility, Hiawatha Oil and Gas Field facility, both in Colorado; and LaBarge Field facility, located in Wyoming. These violations include an oil spill on 5/18/2002 and one on 11/10/2003 from the Wilson Creek facility. On 6/16/2002 a spill of 3.5 barrels occurred at the Hiawatha facility. The Respondent also failed to prepare and implement an adequate SPCC plan for these three facilities.