THE CASE INVOLVES DISCHARGES OF PRODUCED WATER AND OIL IN FIELDS LEASED BY MOBIL, AN INTERNATIONAL OIL COMPANY, ON NAVAJO LANDS IN UTAH. MOBIL DOES NOT HAVE A CWA PERMIT FOR THESE DISCHARGES AND IS THEREFORE IN VIOLATION OF SECTION 301(A) OF THE ACT. THE UNAUTHORIZED DISCHARGES ARE TO NUMEROUS DRY WASHES AND OTHER TRIBUTARIES OF THE SAN JUAN RIVER. THE DISCHARGES OF OIL MAY ALSO BE VIOLATIONS OF SECTION 311 OF THE CWA. IN ADDITION, MOBIL HAS FAILED TO FULLY IMPLEMENT AN ADEQUATE SPILL PREVENTION CONTROL AND COUNTER MEASURES ( SPCC ) PLAN AT THE OIL FIELDS. THIS ACTION SEEKS INJUCTIVE RELIEF TO INSURE MOBIL'S EFFORTS TO PROPERLY OPERATE AND MAINTAIN ITS PIPING SYSTEMS TO PREVENT DISCHARGES. IT ALSO SEEKS CIVIL PENALTIES FOR PAST VIOLATIONS. THIS CASE MAY RAISE ISSUES OF WHETHER DRY WASHES ARE WATERS OF THE U.S. UNDER THE CWA.