PRASA violated Section 301 of the Act, 33 U.S.C. §1311, by discharging pollutants at a location other than the discharge point authorized by the Permit, and that Respondent violated its Permit by failing to provide Operation and Maintenance to the Facility appurtenances. PRASA is found to have, at a minimum, violated the Act on 661 instances from March 17, 2004 through February 6, 2006. EPA, Region 2, hereby proposes to issue a Final Order Assessing Administrative Penalties to PRASA assessing a penalty of $157,500.00.