1. SECTION 311 OF THE CLEAN WATER ACT ( CWA ), 33 U.S.C. SECTION 1321. 2. AMOCO PIPELINE COMPANY 5201 EMMETT F. LOWERY EXPRESSWAY TEXAS CITY, GALVESTON COUNTY, TEXAS 77591 FACILITY: GENOA METERING STATION, 1-45 AND ALEMDA-GENOA ROAD 3. ON OR ABOUT NOV. 10, 1997, AMOCO DISCHARGED APPROXIMATELY 5,400 BARRELS OF OIL FROM ITS GENOA METERING STATION INTO OR UPON THE NAVIGABLE WATERS OF THE U.S. OR ADJOINING SHORELINES IN SUCH QUANTITIES THAT HAVE BEEN DETERMINED MAY BE HARMFUL TO THE PUBLIC HEALTH OR WELFARE OR EN- VIRONMENT OF THE U.S. 4. RELIEF SOUGHT PURSUANT TO SECTION 311 OF THE CWA, EPA SUBMITTED THIS DIRECT REFERRAL REQUESTING DOJ INITIATEA CIVIL ENFORCEMENT ACTION FOR CIVIL PENALTIES AGAINST THE VIOLATOR NAMED IN THE REFERRAL. THIS ACTION SEEKS A CIVIL PENALTY FOR THE DISCHARGE OF OIL INTO OR UPON THE NAVIG- ABLE WATERS OR ADJOINING SHORELINES. THE BOTTOM LINE SETTLEMENT AMOUNT IS $891,000, PROPOSED IS $5,940,000. 5. ENVIRONMENTAL JUSTICE ISSUES: AN ENVIRONMENTAL JUSTICE COMPUTER ANALYSIS WAS MADE FOR THE I SQUARE MILE AREA A- ROUND THE SPILL SITE. THE ANALYSIS SHOWED THAT THE MINOR- ITY POPULATION OF THE AREA IS 41.3% COMPARED TO THE STATE AVERAGE OF 39.4%. THE PERCENT ECO