1. SECTION 311(B)(6)(B)(I) OF THE CLEAN WATER ACT ( CWA ), 33 U.S.C. SECTION 1321(B)(6)(B)(I). 2. ARCADIA EXPLORATION & PRODUCTION COMPANY 3838 OAK LAWN AVE., SUITE 650 DALLAS, DALLAS COUNTY, TEXAS 75219 FACILITY: SMITH L LEASE NO. 2, RRC LEASE ID NO. 108840 3. RESPONDENT WAS IN VIOLATION OF SECTION 31 OF THE CWA BY 1) NO EVIDENCE OF THREE YEAR REVIEW OF PLAN BY OWNER/OP- ERATOR; 2) NO AMENDMENT(S) IF FACILITY HAS HAD CHANGE IN DESIGN, CONSTRUTION, OPERATION, OR MAINTENANCE WHICH MA- TERIALLY AFFECTS THE FACILITY'S DISCHARGE POTENTIAL; 3) AMENDMENT(S) NOT CERTIFIED BY A PROFESSIONAL ENGINEER; 4) PLAN DOES NOT DISCUSS APPROPRIATE CONTAINMENT/DIVERSION- ARY/STRUCTURES/EQUIPMENT; 5) INSPECTIONS REQUIRED BY 40 CFR PART 112 ARE NOT IN ACCORDANCE WITH WRITTEN PROCED- URES DEVELOPED FOR THE FACILITY; 6) WRITTEN PROCEDURES AND A RECORD OF INSPECTIONS ARE NOT SIGNED BY SUPERVISOR; 7) WRITTEN PROCEDURES AND A RECORD OF INSPECTIONS ARE NOT MAINTAINED FOR THREE YEARS; 8) NO DESIGNATED PERSON AC- COUNTABLE FOR SPILL PREVENTION; AND 9) INADEQUATE OR NO FLOWLINE MAINTENANCE PROGRAM HAS BEEN ESTABLISHED (IN- CLUDES EXAMINATION, CORROSION, PROTECTION, AND FLOWLINE REPLACEMENT). 4. RELIEF SOUGHT PURSUANT TO SECTION 311(B)(6)(B)(I) OF THE CWA, EPA PROPOSES A CIVIL PENALTY