1. SECTION 309(G)(2)(A) OF THE CLEAN WATER ACT ( CWA ), 33 U.S.C. SEC. 1319(G)(2)(A). 2. JAMES A. BECK SENECA RESOURCES CORPORATION 333 CLAY STREET, SUITE 4150 HOUSTON, TEXAS 77002 LOCATION OF FACILITY: OFFSHORE, GULF OF MEXICO NPDES PERMIT NO. GMG290123 3. RESPONDENT WAS IN VIOLATION OF SECTION 301(A) OF THE CWA BY DISCHARGING DRILL MUD FROM THE FACILITY INTO THE GULF OF MEXICO THAT HAD NOT BEEN SUBJECTED TO THE REQUIRED ONCE/MONTH AND ONCE/END OF WELL TOXICITY TESTING. 4. RELIEF SOUGHT PURSUANT TO SECTION 309(G)(2)(A) OF THE CWA EPA PROPOSES A CIVIL PENALTY OF OF $10,000 PER VIOLATION UP TO A MAXIMUM OF $25,000.