1. SECTION 309(G)(1) OF THE CLEAN WATER ACT ( CWA ), 33 U.S.C. SECTION 1319(G)(1). 2. SONAT EXPLORATION GOM INC., A DELAWARE CORPORATION (FORMERLY ZILKHA ENERGY COMPANY) 1201 LOUISIANA STREET, SUITE 3200 HOUSTON, HARRIS COUNTY, TEXAS 77002 3. RESPONDENT WAS IN VIOLATION OF SECTION 301 OF THE CWA BY DISCHARGING POLLUTANTS FROM ITS OFFSHORE FACILITIES THAT EXCEEDED PERMITTED EFFLUENT LIMITATIONS, AS SHOWN IN THE CERTIFIED DMRS FILED WITH EPA. 4. RELIEF SOUGHT PURSUANT TO SECTION 309(G)(1) OF THE CWA, EPA PROPOSED A CIVIL PENALTY OF $27,500 FOR THE VIOLA- TIONS CITED.