Invitation Energy, Inc. (���Invitation���) is a West Virginia corporation with a principal place of business located on Route 2, Shinnston, West Virginia. Invitation is involved in the production of oil and natural gas. It operates a production well off of Route 14 north of the village of Central, Wood County, West Virginia (the ���Well���). Invitation maintains three above-ground storage tanks (���ASTs���) at the Well. In August 2003, EPA discovered that the Well was leaking crude oil into an unnamed tributary of the Briscoe Run. The Briscoe Run is a tributary of the Ohio River. Oil and sheens have been observed in the unnamed tributary and the Briscoe Run. EPA learned that the Well has been leaking oil since March 2003. EPA also discovered that Invitation does not have a SPCC Plan for the ASTs at the Well. Two of the ASTs are situated within a dike system which drains into a ditch running offsite. EPA sent Invitation two requests for information about the Well pursuant to Section 308(a) of the Clean Water Act, as amended (���CWA���), 33 U.S.C. �� 1318(a). Invitation failed to respond to the requests. The ongoing discharge of oil from the Well is a continuing violation of Section 311(b)(3) of the CWA, 33 U.S.C. �� 1321(b)(3). Invitation���s failure to have a SPCC Plan and failure to control drainage from its facility are violations of the regulations promulgated under Section 311(j) of the CWA, 33 U.