THIS IS A CLASS I ADMINISTRATIVE PENALTY COMPLAINT ISSUED AGAINST WESTERN CRUDE RESERVES, INC. UNDER SECTION 309(G) OF THE CLEAN WATER ACT. THE COMPLAINT ALLEGES THAT RESPONDENT DISCHARGED POLLUTANTS WITHOUT A VALID KPDES OR NPDES PERMIT AT 2 OIL/BRINE SEPARATOR FACILITIES IN ESTILL COUNTY IN MARCH & NOV. 1988. THE PROPOSED PENALTY IS $15,000. A CONSENT AGREEMENT & ORDER WAS PRE-NEGOTIATED WITH RESPONDENT FOR $10,800 AND MAILED CONCURRENTLY WITH THE COMPLAINT ON 06/21/89.