THIS IS A CLASS I CLEAN WATER ACT (CWA) ADMINISTRATIVE PENALTY COMPLAINT ISSUED PURSUANT TO SECTION 309(G) OF THE CWA AGAINST THE HARRIS CORPORATION, GOVERNMENT SYSTEMS SECTOR FOR VIOLATIONS OF SECTION 301(A) OF THE CWA. RESPONDENT HAS VIOLATED SECTION 301(A) OF THE CWA BY EXCEEDING THE NPDES PERMIT LIMITS FOR TRICHLOROETHENE; 1,1-DICHLOROETHENE; 1,2-CIS-DICHLOROETHENE; 1,2-TRANSDICH- LOROETHENE; VINYLCHLORIDE; 1,1-DICHLOROETHANE FOR INCIDENTS OCCURING FROM NOVEMBER 1985 TO DECEMBER 1989. RESPONDENT ALSO VIOLATED SECTION 301(A) BY HAVING AN UNPERMITTED DISCHARGE OF UNTREATED GROUNDWATER ON SEPTEMBER 4, 1987. DISHCARGE MONITORING REPORTS AND CORRESPONDENCE SUBMITTED TO THE EPA BY THE RESPONDENT EVIDENCE THESE VIOLATIONS. THE COMPLAINT SEEKS A PENALTY OF $25,000 AND WAS ISSUED ON SEPTEMBER 28, 1990.