SUIT ALLEGES AN EPA ADMINISTRATIVE ORDER ISSUED AGAINST PLAINTIFFS WAS IMPROPERLY ISSUED AND VIOLATES THEIR CONSTI- TUTIONAL RIGHTS. ORDER WAS ISSUED TO REDRESS VIOLATIONS OF SECTION 404 OF CWA, 33 U.S.C. 1344. PROPOSED COUNTERCLAIM WILL SEEK ENFORCEMENT OF THE ADMINISTRATIVE ORDER, INJUNC- TION RELIEF AND THE IMPOSITION OF CIVIL PENALTIES FOR VIOLA- TIONS OF BOTH THE ORDER AND THE CLEAN WATER ACT.