On January 10, 2011, EPA approved a Stipulation and Order resolving a civil action for RCRA and CWA claims Eastman Chemical Resins, Inc. (ÂEastmanÂ)for violations of Sections 311(b)(3) and 311(j) of the CWA and 3008 of RCRA. The violations relate to the independent chemical manufacturing operations conducted by Hercules, Eastman and GEO at a shared facility, the Hercules Franklin Plant, located in Courtland, Virginia. Specifically, the Complaint against Eastman, which will be filed simultaneously in the Eastern District of Virginia, alleges that Eastman committed the following violations: 1) Deficient SPCC and FRP Plans in violation of 40 C.F.R. Part 112; 2) the failure to implement the FRP due to inadequate oil spill response drills and exercises in violation of 40 C.F.R. § 112.21(a); 3) the unlawful discharge of oil into the Nottoway River, a navigable water, in violation of Section 311(b)(3) of the CWA; 4) Inadequate oil storage tank secondary containment in violation of 40 C.F.R. § 112.7; 5) Inadequate plant lighting in violation of 40 C.F.R. § 112.77(g)(5)(i); The failure to make a hazardous waste determination for waste oil removed from the FacilityÂs on-site Wastewater Treatment Facility in violation of 40 C.F.R. § 262.11; and the failure to make a Land Disposal Regulation waste determination as required by 40 C.F.R. § 268.7(a). Although EPA initially identified areas of potential injunctive relief, Eastman and the other companies co-located at the Franklin