1. SECTION 309(G)(2) OF THE CLEAN WATER ACT ( CWA ), 33 U.S.C. SECTION 1319(G)(1). 2. MILLENNIUM PETROCHEMICALS, INC., A VIRGINIA CORPORATION 11603 STRANG ROAD LA PORTE, HARRIS COUNTY, TEXAS 77571 3. RESPONDENT WAS IN VIOLATION OF SECTION 301 OF THE CWA BY DISCHARGING POLLUTANTS FROM THE FACILITY THAT EXCEEDED PERMITTED EFFLUENT LIMITATIONS, AS SHOWN IN THE CERTIFIED DMRS FILED WITH EPA. 4. RELIEF SOUGHT PURSUANT TO SECTION 309(G)(2) OF THE CWA, EPA PROPOSES A CIVIL PENALTY OF $125,000.