1. SECTION 309(G)(1) OF THE CLEAN WATER ACT ( CWA ), 33 U.S.C. SECTION 1319(G)(1). 2. TORCH OPERATING COMPANY, A TEXAS CORPORATION 1221 LAMAR STREET, SUITE 1600 HOUSTON, HARRIS COUNTY, TEXAS 77010 FACILITIES: OUTER CONTINENTAL SHELF OF THE WESTERN GULF OF MEXICO 3. RESPONDENT WAS IN VIOLATION OF SECTION 301 OF THE CWA BY DISCHARGING POLLUTANTS FROM ITS OFFSHORE FACILITIES THAT EXCEEDED PERMITED 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.