On March 24, 2010, R. E. Pierson Materials Corporation (Pierson) disclosed potential Clean Water Act (CWA) § 311 (failure to prepare a SPCC plan) violations to EPA Regions 2 and 3 for nine of its facilities. Pierson failed to prepare and implement Spill Prevention, Control, and Countermeasure (SPCC) Plans, as required by CWA Section 311(j)(1)(C), 33 U.S.C. § 1321 (j)(1)(C), and 40 C.F.R. §§ 112.3 through 112.7.