1. SECTIONS 308 AND 309(A) OF THE CLEAN WATER ACT ( CWA ), 33 U.S.C. SECTIONS 1318 AND 1319(A). 2. BUCK CREEK ASSOCIATES, AN OKLAHOMA COMPANY FACILITY: OIL PRODUCTION LINE LONG. 95*, 51.47' NORTH, LAT. 36*, 48.02' WEST T27 N, R 14 E BARTLESVILLE, WASHINGTON COUNTY, OKLAHOMA 74003 3. RESPONDENT WAS IN VIOLATION OF SECTION 301 OF THE CWA BY DISCHARGING POLLUTANTS WITH PRODUCED WATERS TO WATERS OF THE U.S. WITHOUT A NPDES PERMIT ON OR ABOUT MAY 12, 1999. 4. RELIEF SOUGHT PURSUANT TO SECTIONS 308 AND 309(A) OF THE CWA, EPA ISSUED THE RESPONDENT AN ADMINISTRATIVE ORDER (AO) THAT ORDERED THE RESPONDENT TO: A) WITHIN 60 DAYS, REPLACE OLD TANKS WITH NEW TANKS; B) CONSTRUCT SECONDARY CONTAINMENT AROUND THE NEW TANK(S) CAPABLE OF CONTAINING ANY ACCIDENTAL RELEASE; C) INSTALL AN AUTOMATIC CUTOFF SYSTEM IN THE EVENT THE TANK(S) ARE OVER FILLED; AND 4) INSTALL A AUTOMATICALLY ACTIVITATED SUMP PUMP IN THE BERN TO PUMP RELEASES INTO THE STORAGE TANKS.