On or around 11/25/2005, there was a release of at least 103,000 gallons of gasoline from Delta Fuel's Tank #3 in its bulk storage facility in Toledo, OH. On or about 8/22/2011, Delta Fuels reported a release of 10,800 gallons of denatured ethanol from Tank #2 at the same facility into a secondary containment area which was saturated with water at the time of the spill. EPA sought penalties against Delta Fuels for 1.) failing to properly maintain and implement its SPCC Plan and 2.) failing to prepare and submit in a timely manner the Tier II forms for its hazardous chemicals on site for calendar years 2003, 2004, 2006 and 2007. The Coast Guard also sought reimbursement of $4,354,273 in costs spent from the Oil Spill Liability Trust Fund in connection with EPA's cleanup and oversight activities for the spills. EPA also sought to make sure Delta Fuels completed its evaluation of the integrity of its containment system for controlling spills and repaired any flaws in that system. EPA estimated that this work would cost between $250,000 and $500,000.