1. SECTION 309(G) OF THE CLEAN WATER ACT ( CWA ), 33 U.S.C. SECTION 1319(G). 2. CHEVRON PHILLIPS CHEMICAL COMPANY L.P., A DELAWARE LIMTED PARTNERSHIP STATE SPUR 119 NORTH BORGER, HUTCHINSON COUNTY, TEXAS 79008-0968 3. RESPONDENT WAS IN VIOLATION OF SECTION 301 OF THE CWA BY EACH DAY RESPONDENT CONDUCTED THE RELEVANT ACTIVITIES AND OPERATED THE FACILITY WITHOUT NPDES PERMIT COVERAGE. 4. RELIEF SOUGHT PURSUANT TO SECTION 309(G) OF THE CWA, EPA PROPOSED A CIVL PENALTY OF UP TO $27,500 FOR THE VIOLA- TION CITED.