ON APRIL 29, 1994, EPA ISSUED AN ADMINISTRATIVE COMPLAINT PURSUANT TO SECTION 309(G) OF THE CWA, ALLEGING IN 2 COUNTS THAT RESPONDENT VIOLATED THE CWA BY DISCHARGING POLLUTANTS IN EXCESS OF ITS NPDES PERMIT LIMITS FOR ZINC, COPPER, TOTAL SUSPENDED SOLIDS AND PH, INTO THE BLACK RIVER, ON 53 OCCASIONS; CIVIL PENALTY PROPOSED $125,000.