THIS IS A CLASS I ADMINISTRATIVE PENALTY COMPLAINT ISSUED AGAINST HARRY ROBERTS D/B/A ROBERTS & JENKINS UNDER SECTION 309(G) OF THE CLEAN WATER ACT. THE COMPLAINT ALLEGES PERMIT EFFLUENT LIMIT VIOLATIONS AT RESPONDENTS' OIL/BRINE SEPARATOR FACILITIES FOR NUMEROUS MONTHS IN 1988. THE PROPOSED PENALTY IS $6,000. A CONSENT AGREEMENT & ORDER WAS PRE-NEGOTIATED FOR $3,500 & MAILED CONCURRENTLY WITH ADMINISTRATIVE COMPLAINT ON 06/21/89.