CITY PUMPED RAW AND COMBINED SEWAGE FROM PRISON FACILI- TIES INTO STORM DRAINS LEADING TO PENNYPACK CREEK WITHOUT AN NPDES PERMIT THUS VIOLATING SECTION 301 OF CWA. HOUSE OF CORRECTIONS ALSO HAS FREQUENT OVERFLOWS OF COMBINED SEW- AGE INTO PENNYPACK CREEK THROUGH INTERCONNECTION OF SANITARY AND STORM SEWERS.