THIS IS A PROPOSED CIVIL ACTION TO OBTAIN PENALTIES OF $1,830,209.00 FOR ALPHA'S PAST VIOLATIONS OF ITS NPDES PER- MIT AND THE CLEAN WATER ACT. FROM NOVEMBER 1988 THRU OCTOBER 1990, ALPHA VIOLATED SECTION 301(A) OF THE CLEAN WATER ACT, 33 U.S.C. 1311(A), BY EXCEEDING EFFLUENT LIMITATIONS FOR BIO CHEMICAL OXYGEN DEMAND (BOD), TOTAL SUSPENDED SOLIDS (TSS), AMMONIA, PH AND FLOW AS SET IN ITS NPDES PERMIT.