1. SECTION 309(G)(1) OF THE CLEAN WATER ACT ( CWA ), 33 U.S.C. SECTION 1319(G)(1). 2. PENNZOIL EXPLORATION AND PRODUCTION COMPANY, A DELAWARE CORPORATION 1319 WEST PINHOOK ROAD LAFAYETTE, LAFAYETTE PARISH, LOUISIANA 70503 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 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.