1. SECTIONS 311(B)(6)(A)(II) AND 311(B)(6)(B)(I) OF THE CLEAN WATER ACT ( CWA ), 33 U.S.C. SECTIONS 1321(B)(6)(A) (II) AND 311(B)(6)(B)(I), AS AMENDED BY THE OIL POLLUTION ACT OF 1990. 2. GDDC, INC., A TEXAS COMPANY OIL FIELD WASTE TREATMENT AND DISPOSAL FACILITY 12 MILES WEST OF BAY CITY, TEXAS ON FM 1468 CLEMVILLE, MATAGORDA COUNTY, TEXAS 77414 3. RESPONDENT WAS IN VIOLATION OF SECTION 311(J) OF THE CWA BY FAILING TO IMPLEMENT AN SPPC PLAN FOR ITS FACILITY AS REQUIRED. 4. RELIEF SOUGHT PURSUANT TO SECTIONS 311(B)(6)(A)(II) AND 311(B)(6)(B)(I) OF THE CWA, EPA PROPOSED A CIVIL PENALTY OF $27,500 FOR THE VIOLATIONS CITED.