RESPONDENT FAILED TO PROPERLY PREPARE AND FULLY IMPLEMENT AN SPCC PLAN FOR ITS FACILITY IN ACCORDANCE WITH 40 C.F.R. 112.7 AS REQUIRED BY 40 C.F.R. 112.3(A); FAILED TO REVIEW AND CERTIFY RESPONDENT'S SPCC PLAN BY REGISTERED PROFESSIONAL ENGINEER; RESP. DISCHARGED OIL INTO NAVIGABLE WATERS IN QUANTITY DETERMINED TO BE HARMFUL.