THIS MATTERS IS AN ADMINISTRATIVE COMPLAINT, FINDING VIOLA- TIONS, NOTICE OF PROPOSED ASSESSMENT OF CIVIL PENALTY AND NOTICE OF OPPORTUNITY TO REQUEST A HEARING, FILED BY USEPA PURSUANT TO SECTION 309(G)(2) OF THE CLEAN WATER ACT, 33 USC SECTION 1319(G)(2). SPECIFICALLY, THE DEFENDANT VIOLATED SECTION 301 AND SECTION 402 OF THE CWA 33 USC SECTION 1311, 1342, BY DISCHARGING POLLUTANTS INTO A NAVIGABLE WATER IN NONCOMPLIANCE WITH THE TERMS AND CONDITIONS OF A NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM (NPDES) PERMIT.