RESPONDENT IS A CORPORATION ORGANIZED UNDER THE LAWS OF THE STATE OF OHIO, WITH A PLACE OF BUSINESS LOCATED AT OR ABOUT THE NE 1/4, NW 1/4, SECTION 19, T46N, R98W, HOT SPRINGS COUNTY, WYOMING. RESPONDENT OWNS AND OPERATES A WATER INJECTION PLANT (# 2), WHICH IS AND WAS AT RELEVANT TIMES A POINT SOURCE . ON 09/13/91, RESPONDENT DISCHARGED, FROM ITS FACILITY, APPROXIMATELY 21,000 GALLONS OF PRODUCED WATER AND 0.3 GALLONS OF CRUDE OIL INTO GRASS CREEK, A TRIBUTARY TO THE BIG HORN RIVER. PRODUCED WATER AND CRUDE OIL ARE POLLUTANTS. AT NO TIME DID THE RESPONDENTS HAVE AN NPDES PERMIT FOR THE DISCHARGES. THE PROPOSED CIVIL PENALTY FOR THIS VIOLATION IS $7,000.