A SPILL PREVENTION, CONTROL AND COUNTERMEASURE (SPCC) FACILITY RESPONSE PLAN (FRP) INSPECTION WAS CONDUCTED ON FEBRUARY 7,2013. EPA IS ALLEGING A VIOLATION AT THE SCHUYLKILL TERMINAL FOR THE FAILURE TO IMPLEMENT A FACILITY RESPONSE DRILL AND EXERCISE PROGRAM IN ACCORDANCE WITH THE NATIONAL PREPAREDNESS FOR RESPONSE EXERCISE PROGRAM GUIDELINES OR ANOTHER APPROVED PROGRAM.