1. SECTION 309(A)(3) OF THE CLEAN WATER ACT ( CWA ), 33 U.S.C. SECTION 1319(A)(3). 2. ZINN PETROLEUM COMPANY 1200 SMITH, SUITE 2910 HOUSTON, HARRIS COUNTY, TEXAS 77002 FACILITY: LAT. 28*49'55'N, LONG. 95*29'59 W, BRAZORIA COUNTY, TEXAS 3. RESPONDENT WAS IN VIOLATION OF SECTION 301(A) OF THE CWA BY DISCHARGING PRODUCED WATER OR SAND INTO WATERS OF THE U.S. IN VIOLATION OF PART I.2.C.A. OF ITS PERMIT. 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 FACILITY SO AS TO DISCHARGE EFFLUENT WHICH DOES NOT EXCEED THE EFFLUENT LIMITATIONS OF THE AO, COMPLY WITH THE MONITORING AND RE- PORTING REQUIREMENTS OF THE AO, COMPLY WITH THE GENERAL CONDITIONS SCHEDULE IN THE AO, REPORT ANY NON-COMPLIANCE OF THE AO, AND COMPLY WITH THE NO DISCHARGE REQUIREMENTS OF ITS PERMIT.