THIS ADMINISTRATIVE COMPLAINT AND OPPORTUNITY TO REQUEST HEARING IS ISSUED TO RAIFORD PATTON, OWNER OF ASHER ASSOCIATES FOR FAILING TO PREPARE AND IMPLEMENT A SPILL PREVENTION CONTROL AND COUNTERMEASURE PLAN FOR THE BEAVER HOLE FACILITY, THE BRIGHT FACILITY, THE 22-21 FACILITY AND THE 32-20 INJECTION FACILITY LOCATED IN NIOBARA COUNTY.