This is a Complaint pursuant to MPRSA Sections 102 and 105, issued to Manson Construction Company. The violation involved 24 instances of discharge of dredged material from significantly leaking barges, during transport through the Gulf of the Farallones National Marine Sanctuary en route to the San Francisco Deep Ocean Disposal Site (SF-DODS). Twenty of the 24 leaking trips occurred with the same barge. These discharges occurred between February and April, 1998, while Manson was under contract with the San Francisco District U.S. Army Corps of Engineers on the Port of Richmond Deepening Project (part of a joint venture with Great Lakes Dredge & Dock Co., see separate CA/FO in Super Docket), and totalled approximately 30,000 cubic yards of dredged material. NOTE: This Complaint was issued because Manson failed to sign a Consent Agreement by the September 26, 2003 deadline established under a Tolling Agreement. Also, there were approximately twice as many instances of substantially leaking Manson barges during this project than are included in the charges named in this Complaint. Thus the real volume of dredged material discharged was approximately twice what is covered in this complaint. However, the statute of limitations restricted the number of counts EPA could pursue.