1. SECTIONS 308 AND 309(A) OF THE CLEAN WATER ACT ( CWA ), 33 U.S.C. SECTIONS 1318 AND 1319(A). 2. ENERGY LEASE SEVICES COMPANY, AN OKLAHOMA COMPANY OIL PRODUCTION FACILITY SW/4, SECTION 22, T20 N, R6 E OSAGE, OSAGE COUNTY, OKLAHOMA 74054 3. RESPONDENT WAS IN VIOLATION OF SECTION 301 OF THE CWA BY DISCHARGING POLLUTANTS WITH PRODUCED WATERS TO WATERS OF THE U.S. WITHOUT A NPDES PERMIT ON OR ABOUT JUL. 16, 1999. 4. RELIEF SOUGHT PURSUANT TO SECTIONS 308 AND 309(A) OF THE CWA, EPA ISSUED THE RESPONDENT AN ADMINISTRATIVE ORDER (AO) THAT REQUIRED THE RESPONDENT TO: A) WITHIN 30 DAYS OF THE AO, SUBMIT INFORMATION CONCERNING ANY DISCHARGES OF POLLUTANTS TO WATERS OF THE U.S. WITHIN THE LAST 5 YEARS; B) UPON RECEIPT OF THE AO, CEASE ALL UNPERMITTED DISCHARGES OF POLLUTANTS FROM THE OIL PRODUCTION FACILI- TY; AND C) WITHIN 45 DAYS OF THE AO, ARRANGE TO MEET WITH EPA AND SHOW CAUSE.