1. SECTION 309(G)(2)(A) OF THE CLEAN WATER ACT ( CWA ), 33 U.S.C. SEC. 1319(G)(2)(A). 2. UNION PACIFIC RESOURCES P.O. BOX 7, MS-2807 FORT WORTH, TEXAS 76101-0007 NPDES PERMIT NO. GMG290033 LOCATION OF FACILITIES: GULF OF MEXICO 3. RESPONDENT WAS IN VIOLATION OF SECTION 301(A) OF THE CWA BY EXCEEDING THE EFFLUENT LIMITATIONS OF ITS PERMIT AND BY DISCHARGING POLLUTANTS WITHOUT NPDES PERMIT COVERAGE FOR THOSE DISCHARGES. 4. RELIEF SOUGHT PURSUANT TO SECTION 309(G)(2)(A) OF THE CWA EPA PROPOSES A PENALTY OF $25,000.