THE CASE INVOLVES DISCHARGES OF PRODUCED WATER AND OIL FROM THE OIL FIELDS LEASED BY TEXACO, AN INTERNATIONAL OIL COMPANY, ON NAVAJO LANDS IN UTAH. TEXACO DOES NOT HAVE A CWA PERMIT FOR THESE DISCHARGES AND IS THEREFORE IN VIOLATION OF SECTION 301(A) OF THE ACT. THE UNAUTHORIZED DISCHARGES ARE TO NUMEROUS DRY WASHES AND OTHER TRIBUTORIES TO THE SAN JUAN RIVER. THE DISCHARGES OF OIL MAY ALSO BE VIOLATIONS OF SECTION 311 OF THE CWA. IN ADDITION, TEXACO HAS FAILED TO FULLY IMPLEMENT AN ADEQUATE SPILL PREVENTION CONTROL AND COUNTERMEASURES ( SPCC ) PLAN AT THE OIL FIELDS. THE CIVIL ACTION SEEKS IMMEDIATE RELIEF TO INCREASE TEXACO'S EFFORTS TO PROPERLY OPERATE AND MAINTAIN ITS PIPING SYSTEMS TO PREVENT DISCHARGES. IT ALSO SEEKS CIVIL PENALTIES FOR PAST VIOLATIONS. THIS CASE MAY RAISE ISSUES OF WHETHER DRY WASHES ARE WATERS OF THE U.S. UNDER THE CWA.