1. SECTION 309(G) OF THE CLEAN WATER ACT, 33 U.S.C. SEC. 1319(G). 2. PELTO OIL COMPANY ONE ALLEN CENTER, SUITE 1800 500 DALLAS STREET HOUSTON, TX. 77002 PERMIT NO. GMG280000 3. PELTO VIOLATED SECTION 301(A) OF THE CWA IN TWO OFFSHORE FACILITIES BY FAILING TO PROPERLY OPERATE AND MAINTAIN FACILITIES AND SYSTEMS OF TREATMENT AND CONTROL WHICH WERE INSTALLED AND USED BY THE PERMITEE TO ACHIEVE COM- PLIANCE WITH NPDES PERMIT AT ITS MAIN PASS 209 A PLAT- FORM ON MAR. 20-21, 1990 AND BY DISCHARGING PRODUCED WA- TER IN EXCESS OF OIL AND GREASE LIMITATIONS ON NOV. 6, 1989 AT ITS MAIN PASS 95 A PLATFORM. 4. RELIEF PROPOSED PURSUANT TO SECTION 309(G) OF THE CWA, EPA PROPOSES TO ISSUE A FINAL ORDER ASSESSING ADMINISTRA- TIVE PENALTIES TO THE RESPONDENT ASSESSING A PENALTY OF $25,000.00.