1. SECTION 311(B)(6)(B)(I) OF THE CLEAN WATER ACT ( CWA ), 33 U.S.C. SECTION 1321(B)(6)(B)(I), AS AMENDED BY THE OIL POLLUTION ACT OF 1990. 2. GLICKENHAUS ENERGY CORPORATION, EAST TEXAS OIL CO. FEE B & C LEASES, RRC ID NO. 21875 VILLAGE MILLS, HARDIN COUNTY, TEXAS 77669 3. RESPONDENT WAS IN VIOLATION OF SECTION 311(J) OF THE CWA BY: 1) NO MANAGEMENT APPROVAL OF PLAN; 2) WRITTEN PROCED- URES AND A RECORD OF INSPECTIONS ARE NOT MAINTAINED FOR THREE YEARS; 3) FIELD DRAINAGE DITCHES, ROAD DITCHES, AND OIL TRAPS, SUMPS, OR SKIMMERS ARE NOT REGULARLY INSPECTED FOR OIL, AND/OR OIL IS NOT REMOVED; 4) SECONDARY CONTAIN- MENT APPEARS TO BE GROSSLY INADEQUATE FOR TANKS AND CEN- TRAL TREATING INSTALLATIONS; 5) BRINE DISPOSAL FACILITIES ARE NOT EXAMINED OFTEN; AND 6) DRAINS FOR THE SECONDARY CONTAINMENT SYSTEMS AT THE BATTERY(IES) AND CENTRAL TREATMENT STATIONS ARE NOT CLOSED AND SEALED AT ALL TIMES EXCEPT WHEN RAINWATER IS BEING DRAINED. 4. RELIEF SOUGHT PURSUANT TO SECTION 311(B)(6)(B)(I) OF THE CWA, EPA ASSESSED THE RESPONDENT A CIVIL PENALTY OF $1,650 FOR THE VIOLATIONS CITED.