The Town participated in the Region's DPW Audit Initiative. By letter dated February 22, 2002, the DPW disclosed numerous RCRA and CWA vioaltions, including that it regularly washed the Town's fleet of vehicles outdoors near an on-site catch basin. This practice resulted in the discharge of vehicle wash water to the Ten Mile River. At no time before February 22, 2002, did the Town have a permit in violation of Section 301 of the Clean Water Act.