1. SECTION 309(A)(3) OF THE CLEAN WATER ACT ( CWA ), 33 U.S.C. SECTION 1319(A)(3). 2. DEWEY A. STRINGER PETRO GUARD COMPANY, INC. ESPIRITU SANTO BAY - ST 216 5858 WESTHEIMER, SUITE 400 HOUSTON, HARRIS COUNTY, TEXAS 77057 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 LIMITATIONS. 4. RELIEF SOUGHT PURSUANT TO SECTION 309(A)(3) OF THE CWA, EPA ISSUED AN ADMINISTRATIVE ORDER (AO) ORDERING THE RE- SPONDENT TO OPERATE AND MAINTAIN THE FACILITIES SO AS TO DISCHARGE EFFLUENT WHICH DOES NOT EXCEED THE EFFLUENT LIMITATIONS.