1. SECTION 309(G) OF THE CLEAN WATER ACT ( CWA ), 33 U.S.C. SEC. 1319(G). 2. PHIBRO ENERGY USA, INC. HOUSTON, TEXAS 77262-5038 PERMIT NO. TX0002976 3. PHIBRO VIOLATED SECTION 301(A) OF THE CWA BY VIOLATING CONDITIONS OF PART I.A. OF ITS PERMIT BY DISCHARGING POL- LUTANTS TO THE WATERS OF THE U.S. IN AMOUNTS OR CONCEN- TRATIONS WHICH EXCEED PERMITTED EFFLUENT LIMITATIONS AND VIOLATING PART III.A.4. OF THE PERMIT BY FAILING TO SUB- MIT AN APPLICATION FOR RE-ISSUANCE OF ITS PERMIT AT LEAST 180 DAYS PRIOR TO THE EXPIRATION DATE CONTAINED IN THE PERMIT. 4. RELIEF SOUGHT PURSUANT TO SECTION 309(G) OF THE CWA, EPA PROPOSES A CIVIL PENALTY OF $125,000.00.