THIS IS A PROPOSED CLASS I ADMINISTRATIVE PENALTY ACTION UNDER SECTION 309(G) OF THE CWA AGAINST RESPONDENT TO RECOVER A PENALTY IN THE AMOUNT OF $16,500. THIS CASE INVOLVES OIL AND GAS FACILITIES LOCATED IN OHIO COUNTY, KENTUCKY WHICH DISCHARGES BRINE FROM OIL/BRINE SEPARATES WHICH ARE POINT SOURCES AND DISCHARGE POLLUTANTS INTO AN UNNARMED TRIBUTARY OF ROUGH RIVER. THE FACILITIES ARE OWNED BY RESPONDENT AND DISCHARGE WITHOUT A PERMIT ON MARCH 10TH, 17TH, 1987 AND JANUARY 28, 1988 AND FEBRUARY 19, 1988.