1. SECTION 311 OF THE CLEAN WATER ACT ( CWA ), AS AMENDED BY THE OIL POLLUTION ACT OF 1990 ( OPA ). 2. KOCH GATHERING SYSTEMS INC. 4111 E. 37TH ST. N WICHITA, KS. 67220 (316) 832-5500 KOCH INDUSTRIES, INC. 4111 E. 37TH ST. N WICHITA, KS. 67220 (316) 832-5500 REGISTERED AGENT FOR SERVICE: H. ALLAN CALDWELL 4111 E. 37TH ST. WICHITA, KS. 67220 3. KOCH WAS IN VIOLATION OF SECTION 311 OF THE CWA AND OPA BY DISCHARGING A TOTAL AMOUNT OF APPROXIMATELY 16,001 BARRELS OF OIL IN 160 DISCHARGES. THIS AMOUNT WAS DERIV- ED FROM 149 SELF-REPORTED DISCHARGES TO THE NATIONAL RE- SPONSE CENTER (NRC) PLUS 11 EPA SITES MONITORED FOR WHICH ON-SCENE- MONITORING REPORTS WERE COMPLETED. THE DISCHAR- GES WERE FROM ONSHORE PIPELINES LOCATED IN OKLAHOMA AND TEXAS. ALL WATERS AFFECTED BY THE DISCHARGES WERE ALSO LOCATED IN OKLAHOMA AND TEXAS. 4. PROPOSED RELIEF SOUGHT PURSUANT TO SECTION 311 OF THE CWA, EPA IS SEEKING INJUNCTIVE RE