1. SECTION 311(B)(6)(B)(I) OF THE CLEAN WATER ACT ( CWA ), 33 U.S.C. SECTION 1321(B)(6)(B)(I), AS AMENDED BY THE OIL POLLUTION ACT OF 1990. 2. SUN PIPE LINE COMPANY, A CORPORATION ORGANIZED UNDER THE LAWS OF PENNSYLVANIA, OPERATING FACILITIES IN TEXAS AND OKLAHOMA 1801 MARKET STREET PHILADELPHIA, PA. 19103 3. RESPONDENT WAS IN VIOLATION OF SECTION 311(B)(3) BY 1) DISCHARGING APPROXIMATELY 30 BARRELS OF OIL FROM ITS PON- TOTOC COUNTY, OK. FACILITY INTO AN UNAMED CREEK ON FEB. 20, 1997, 2) DISCHARGING APPROXIMATELY 35 BARRELS OF OIL FROM ITS SEMINOLE COUNTY, OK. FACILITY INTO AN UNAMED CREEK ON MAR. 19, 1997, AND 3) DISCHARGING APPROXIMATELY 30 BARRELS OF OIL FROM ITS GREEG COUNTY, TX. FACILITY IN- TO AN UNAMED CREEK ON OCT. 28, 1996. 4. RELIEF SOUGHT PURSUANT TO SECTION 311(B)(6)(B)(I) OF THE CWA, EPA PROPOSES A CIVIL PENALTY OF $19,000.