1. SECTION 309(G)(2) OF THE CLEAN WATER ACT ( CWA ), 33 U.S.C. SEC. 1319(G)(2). 2. THE CROWN CENTRAL PETROLEUM CORP. 111 RED BLUFF ROAD PASADENA, TEXAS NPDES PERMIT NO. TX0004626 3. RESPONDENT WAS IN VIOLATION OF SECTION 301(A) OF THE CWA BY EXCEEDING THE EFFLUENT LIMITATIONS OF PART I.A OF ITS PERMIT IN ITS DISCHARGES INTO THE HOUSTON SHIP CHANNEL. 4. RELIEF SOUGHT PURSUANT TO SECTION 309(G)(2) OF THE CWA, EPA PROPOSES A PENALTY OF $125,000, WHICH CONSTITUTES LESS THAN $10,000 PER VIOLATION CITED IN THE COMPLAINT.