ON AT LEAST 17 OCCASIONS, RESPONDENT DISCHARGED PRODUCTION WATER INTO PHILLIPS CANYON DRAINAGE, ROCK CREEK, LOS PINOS RIVER, DRY CREEK, SALT CREEK AS WELL AS ADJACENT WETLANDS, IRRIGATION DITCHES AND STOCK PONDS. THE SPILLS OCCURRED AT INJECTION WELLS, DRIP TANKS AND PIPELINE BREAKS AND ARE POINT SOURCES. THESE DISCHARGES HAVE NEVER BEEN AUTHORIZED BY A PERMIT ISSUED UNDER THE CWA. THE PROPOSED PENALTY FOR THESE VIOLATIONS IS $65,000.