THIS IS A CWA CLASS I ADMINISTRATIVE PENALTY ACTION FOR DISCHARGE WITHOUT A PERMIT. RESPONDENT RAILSBECK OWNED AND OPERATED A TRAILER PARK, TREATED WASTE FROM TRAILERS IN AN ACTIVATED SLUDGE PACKAGE PLANT WHICH DISCHARGED INTO AN UNNAMED DITCH WHICH FLOWS INTO THE GIN HOUSE CREEK. EPA ISSUED SEVERAL ORDERS TO REQUIRE RESPONDENT TO SUBMIT A PERMIT APPLICATION. EPA ISSUED AN APO ON AUGUST 11, 1994.