COMPLAINT FILED 2/18/98 COMPLAINT ALLEGES: RESPONDENT DISCHARGED FILL MATERIAL INTO NAVIGABLE WATERS OF THE UNITED STATES WITHOUT A COE PERMIT. IN VIOLATION OF CWA SECTION 404 AND 301A. CACO ISSUED 5/11/98 ASSESSING A PENALTY OF $8,000. RESPONDENT SHALL MAKE PAYMENT WITHIN THIRTY DAYS. RESPONDENT ALSO AGREES TO COMPLETE A SEP.