THIS ACTION IS BASED ON THE CWA SECTION 301, 309, & 402, AND 40 CFR PARTS 122, 123, 124, & 125. KLEER KAST, INC. HAS VIOLATIONS OF NPDES PERMIT NO. NJ0031313 AND UNAUTHOR- IZED DISCHARGE IN VIOLATION OF SECTION 301(A) OF THE CWA. PROPOSED RELIEF SOUGHT INCLUDES INJUNCTIVE RELIEF TO RE- QUIRE PERMIT COMPLIANCE AND TREATMENT STUDIES, AND SETTLE- MENT PENALTIES FROM $200,000 TO $350,000.