THIS IS A CLASS I CLEAN WATER ACT (CWA) ADMINISTRATIVE PENALTY COMPLAINT ISSUED PURSUANT TO SECTION 309(G) OF THE CWA AGAINST JIM DAUGHERTY FOR VIOLATIONS OF SECTION 301(A) OF THE CWA. RESPONDENT HAS VIOLATED SECTION 301(A) OF THE CWA BY DISCHARGING POLLUTANTS (CHLORIDE) WITHOUT A PERMIT. THE VIOLATIONS WERE OBSERVED ON AUGUST 21, 1989 AND JULY 24, 1990. THE COMPLAINT SEEKS A PENALTY OF $20,000 AND WAS ISSUED ON SEPTEMBER 25, 1990.