1. SECTION 311(B)(6)(A)(1) OF THE CLEAN WATER ACT ( CWA ), 33 U.S.C. SECTION 1321(B)(6)(A)(1), AS AMENDED BY THE OIL POLLUTION ACT OF 1990 ( OPA ). 2. COMMERCIAL LUBRICANTS CORPORATION 6061 VAN HISE DRIVE DALLAS, DALLAS COUNTY, TEXAS 75212 3. RESPONDENT WAS IN VIOLATION OF SECTION 311 BY 1) SPCC PLAN NOT CERTIFIED BY A PROFESSIONAL ENGINEER, AND 2) IN- ADEQUATE SECONDARY CONTAINMENT. 4. RELIEF SOUGHT PURSUANT TO 311(B)(6)(A)(1) OF THE CWA, EPA PROPOSES A CIVIL PENALTY OF $600 AND ISSUED A COMPLIANCE ORDER REQUIRING THE RESPONDENT TO CORRECT THE VIOLATIONS CITED.