1. SECTION 309(A) OF THE CLEAN WATER ACT ( CWA ), 33 U.S.C. SECTION 1319(A). 2. PENNZOIL EXPLORATION AND PRODUCTION COMPANY, A DELAWARE CORPORATION P.O. BOX 51843 LAFAYETTE, LAFAYETTE PARISH, LOUISIANA 70505 FACILITIES: OFFSHORE FACILITIES IN THE OUTER CONTINENTAL SHELF WATERS OF THE WESTERN GULF OF MEXICO 3. RESPONDENT WAS IN VIOLATION OF SECTION 301 OF THE CWA BY DISCHARGING POLLUTANTS FROM ITS OFFSHORE FACILITIES IN EXCESS OF PERMITTED EFFLUENT LIMITATIONS. 4. RELIEF SOUGHT PURSUANT TO SECTION 309(A) OF THE CWA, EPA ISSUED AN ADMINISTRATIVE ORDER (AO) TO THE RESPONDENT. THE AO REQUIRES THE RESPONDENT TO, WITHIN 30 DAYS: A) TAKE WHATEVER CORRECTIVE ACTION IS NECESSARY TO ELIMINATE AND PREVENT RECURRENCE OF THE VIOLATIONS, B) SUBMIT WRIT- TEN REPORT DETAILING THE SPECIFIC ACTIONS TAKEN TO COR- RECT THE VIOLATIONS AND WHY THEY WILL PREVENT RECURRENCE, C) IF NOT POSSIBLE TO CORRECT WITHIN 30 DAYS, SUBMIT A PLAN TO DO SO IN THE SHORTEST TIME POSSIBLE, AND D) MEET WITH EPA AND SHOW CAUSE.