THE RESPONDENTS OPERATED A DAIRY AND EGG-LAYING OPERATIONS AT THE FACILITY, WHICH WAS OWNED BY MELVIN PETERSHEIM. CONDUCTED AN INSPECTION OF THE FACILITY ON APRIL 1, 2010, AND OBSERVED THE DISCHARG EO FPOLLUTANTS (MANURE AND MILK-HOUSE WASTES) FROM THE FACILITY INTO WATERS OF HTE UNITED STATES. EPA DETERMINED, BASED ON OBSERVATIONS MADE AT THE FACILITY AS WELL AS STATEMENTS MADE BY THE RESPONDENTS, THE FACILITY QUALIFIED AS A LARGE CAFO. EPA ALSO DETERMINED THAT THE RESPONDENTS LACKED AN NPDES PERMIT. AS A RESULT, EPA DETERMINED THAT THE RESPONDENTS VIOLATED THE CWA PROHIBITION AGAINST DISCHARGING POLLUTANTS INTO WATERS OF THE UNITED STATES WITHOUT A NPDES PERMIT.