WETLAND AND WATERS OF THE U.S. ON THE PROPERTY OWNED BY SIMRELL WERE FILLED BY MILLER, A CONTRACTOR TO SIMRELL, TO CREATE AN IMPOUNDMENT FOR RECREATIONAL PURPOSES. THE RESPONDENTS HAVE PRIOR KNOWLEDGE OF THE NEED TO OBTAIN A CWA SECTION 404 PERMIT FOR WORK DISCHARGES INTO WATERS OF THE U.S. AND WETLANDS. ACCORDINGLY, THIS IS A KNOWING, WILLFUL, AND FLAGRANT VIOLATION OF THE CWA. EPA IS SEEKING AN ADMINISTRATIVE PENALTY FOR PUNITIVE AND DETERRENT PURPOSES.