THIS IS A PROPOSED CIVIL ACTION UNDER SECTIONS 301, 308, 309 AND 402 OF THE CLEAN WATER ACT AGAINST MOBIL EXPLORAT- ION & PRODUCING U.S., INC. ( MOBIL ), FOR DISCHARGING POL- LUTANTS IN VIOLATION OF EFFLUENT LIMITATIONS IN GENERAL NPDES PERMIT FOR OFFSHORE OIL AND GAS PLATFORMS IN THE GULF OF MEXICO. MOBIL IS RESPONSIBLE FOR AT LEAST FIFTY-TWO (52) DOCUMENTED DISCHARGES WITH OIL AND GREASE CONCENTRATIONS IN EXCESS OF THE MAXIMUM LIMIT OF 72 MG/1 OF THE MONTHLY AVERAGE LIMIT OF 48 MG/1. ALL THESE VIOLATIONS OCCURRED AT A SINGLE PLATFORM, GRAND ISLE 2OA. AFTER VIOLATIONS CONTI- NUED FOR FIVE CONSECTIVE MONTHS, MOBIL CORRECTED THE PROBLEM BY INSTALLING AN AIR FLOTATION UNIT. AT NO TIME DID MOBIL SHUT-IN THIS WELL TO PREVENT FUTURE VIOLATIOS, AS OTHER OFFSHORE PRODUCERS HAVE DONE AND MOBIL COULD HAVE DONE.