1. SECTION 309(A)(3) OF THE CLEAN WATER ACT ( CWA ), 33 U.S.C. SECTION 1319(A)(3). 2. DAVID SPOONER PI ENERGY CORPORATION CORPUS CHRISTI BAY 333 CLAY STREET, SUITE 4310 HOUSTON, HARRIS COUNTY, TEXAS 77002 3. RESPONDENT WAS IN VIOLATION OF SECTION 301 OF THE CWA BY DISCHARGING PRODUCED WATER AND SAND INTO WATERS OF THE U.S. THAT EXCEED THE EFFLUENT LIMITS. 4. RELIEF SOUGHT PURSUANT TO SECTION 309(A)(3) OF THE CWA, EPA ISSUED AN ADMINSTRATIVE ORDER (AO) ORDERING THE RE- SPONDENT TO OPERATE AND MAINTAIN THE FACILITIES SO AS TO DISCHARGE EFFLUENT WHICH DOES NOT EXCEED THE EFFLUENT LIMITATIONS.