THE CITY PARTICIPATED IN THE REGION'S DPW AUDIT INITIATIVE. BY LETTER DATED JULY 8,2002, THE CITY DISCLOSED THAT AMONG OTHER ACTIVITIES, IT REGULARLY DISCHARGED VEHICLE WASHWATER FROM THE DEPARTMENT OF PUBLIC WORKS, DEPARTMENT OF PARKS AND RECREATION, WATER DEPARTMENT, AND FIRE DEPARTMENT FACILITIES INTO WATERS OF THE U.S. THROUGH THE CITY STORMWATER SEWER SYSTEM AND/OR INTO THE CITY SANITARY SEWER SYSTEM. AT NO TIME BEFORE JULY 8, 2002, DID THE CITY HAVE A NPDES PERMIT FOR SUCH DISCHARGES OR A CONNECTICUT GENERAL PERMIT FOR THE DISCHARGE OF VEHICLE MAINTENANCE WASTEWATER. THUS, THE CITY WAS DISCHARGING POLLUTANTS WITHOUT AN NPDES PERMIT IN VIOLATION OF SECTION 301 OF THE CLEAN WATER ACT AND IN VIOLATION OF THE STATE PRETREATMENT PROGRAM. IN ADDITION, THE CITY DISCHARGED STORMWATER FROM THE DPW, WATER DEPARTMENT AND PARKS AND RECREATION FACILITIES WITHOUT AN INDIVIDUAL OR GENERAL PERMIT.