1. SECTIONS 308(A) AND 309(A) OF THE CLEAN WATER ACT ( CWA ) 33 U.S.C. SECTIONS 1318(A) AND 1319(A). 2. PHILLIPS PETROLEUM COMPANY, A DELAWARE CORPORATION D.B.A. PHILLIPS PETROLEUM COMPANY BORGER REFINERY AND NGL CENTER STATE HIGHWAY 119, 4 MILES NORTHEAST OF BORGER, HUTCHINSON COUNTY, TEXAS 79008 3. RESPONDENT WAS IN VIOLATION OF SECTION 301 OF THE CWA BY DISCHARGING POLLUTANTS FROM ITS FACILITY THAT EXCEEDED PERMITTED EFFLUENT LIMITATIONS, AS SHOWN IN THE CERTIFIED DMRS FILED WITH EPA. 4. RELIEF SOUGHT PURSUANT TO SECTIONS 308(A) AND 309(A) OF THE CWA, EPA ISSUED THE RESPONDENT AN ADMINISTRATIVE ORDER (AO). THE AO ORDERED THE RESPONDENT TO: A) WITHIN 30 DAYS, TAKE WHATEVER CORRECTIVE ACTION IS NECESSARY TO ELIMINATE AND PREVENT RECURRENCE OF THE VIOLATIONS CITED, B) WITHIN 30 DAYS, SUBMIT A WRITTEN REPORT DETAILING THE SPECIFIC ACTIONS TAKEN TO CORRECT THE VIOLATIONS CITED AND EXPLAIN HOW THESE ACTIONS WILL PREVENT RECURRENCE, AND C) IF NOT POSSIBLE TO CORRECT THE VIOLATIONS CITED, WITHIN 30 DAYS, SUBMIT A COMPREHENSIVE PLAN TO DO SO IN THE SHORTEST POSSIBLE TIME.