VIOLATIONS OF CWA SECTION 502, FAILURE TO FOLLOW PROPER SLUDGE MANAGEMENT GUIDELINES. COMPLAINANT FILED ADMINISTRATIVE COMPLAINT DOCKET NO. 5-CWA- 98-019 ON SEPTEMBER 30, 1998, CITING RESPONDENT FOR VIOLAT- IONS OF THE ACT PURSUANT TO SECTION 405(D) AND (E) AND PROPOSED A FINE FOR $45,000 ALLEGING RESPONDENT VIOLATED SECTION 503.8 (B) BY FAILING TO USE THE METHODS SPECIFIED IN US EPA PUBLICATION SW-846 FOR ANALYSIS OF INORGANIC POLLUTANTS AND FAILURE TO MEET THE POLLUTANT LIMITS SET FORTH IN 503.13 WHEN PREPARING AND APPLING BULK SEWAGE SLUDGE TO AGRICULTURAL LAND ON JULY 1, 1996. THE COMPLAINT FURTHER ALLEGED RESPONDENT VIOLATED 503.17(A)(1) AMD (A)(4) IN 1994. 1995, 1996, AND 1997 BY FAILING TO DEVELOP AND RETAIN FOR FIVE YEARS CERTIFICATION STATEMENTS INDICATING THAT RESPONDENT WAS MEETING CLASS A AND B PATHOGEN AND VECTOR ATTRACTION REDUCTION REQUIREMENTS PURSUANT TO 503.32 AND 503.33. ON MARCH 1, 1999, SETTLEMENT OF THIS ACTION AND AGREEMENT TO SETTLE THIS ACTION THROUGH THE FILING OF CACO DOCKET NO. 5-CWA-019-98 WAS FILED WITH THE REGIONAL HEARING CLERK ASSESSING A FINAL PENALTY AMOUNT OF $6,000.