1. SECTION 309(A)(3) OF THE CLEAN WATER ACT ( CWA ), 33 U.S.C. SECTION 1319(A)(3). 2. API OPERATING COMPANY KLEBERG COUNTY - DEL GRULLO BAYOU P.O. BOX 57-0536 HOUSTON, TEXAS 77257 3. RESPONDENT WAS IN VIOLATION OF SECTION 301(A) OF THE CWA BY FAILING TO COMPLY WITH PART I.2.C.A. OF ITS PERMIT AND CONTINUING TO DISCHARGE PRODUCED WATER OR PRODUCED SAND TO WATERS OF THE U.S. 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 LIMITS OF THE AO, COMPLY WITH THE MONITORING AND REPORT- ING REQUIREMENTS OF THE AO, COMPLY WITH THE GENERAL CON- DITIONS SCHEDULE OF THE AO, PROVIDE WRITTEN REPORTS OF ANY NON-COMPLIANCE OF THE AO, AND COMPLY WITH THE NO DIS- CHARGE REQUIREMENTS OF ITS PERMIT.