THIS IS A CLASS I CLEAN WATER ACT (CWA) ADMINISTRATIVE PENALTY COMPLAINT ISSUED PURSUANT TO SECTION 309(G) OF THE CWA AGAINST DEMETREE ENTERPRISES FOR VIOLATIONS OF SECTION 301(A) OF THE CWA. RESPONDENT HAS VIOLATED SECTION 301(A) OF THE CWA BY FAILING TO ATTAIN OPERATIONAL LEVEL OF THE FINAL EFFLUENT LIMITATION FOR TOTAL RESIDUAL CHLORIDE (TRC) BY THE TIME PERIOD, JULY 1, 1990 SET FORTH IN THE NPDES PERMIT AND BY EXCEEDING THE LIMITS FOR TRC DURING JULY 1990. THE RESPONDENT ALSO FAILED TO SUBMIT PROGRESS REPORTS TO THE EPA REQUIRED BY THE PERMIT. THE DISCHARGE MONITORING REPORTS SUBMITTED BY RESPONDENT TO EPA EVIDENCED THE TRC VIOLATIONS. THE COMPLAINT SEEKS A PENALTY OF $12,500 AND WAS ISSUED ON SEPTEMBER 28, 1990.