BAY-HOUSTON, THROUGH ITS MICHIGAN PEAT DIVISION, DISCHARGED PROCESS WASTEWATER AND DREDGED AND FILL MATERIAL INTO WET- LANDS AND OTHER WATERS OF THE UNITED STATES WITHOUT OBTAIN- ING CWA SECTIONS 402 AND 404 PERMITS. EPA ISSUED A CWA SECTION 309(A) ORDER TO BAY-HOUSTON ON FEBRUARY 9, 1998, DIRECTING BAY-HOUSTON TO CEASE ITS UNLAW- FUL DISCHARGRS EXCEPT IN COMPLIANCE WITH A CWA 404 PERMIT. BAY-HOUSTON SUBMITTED A PERMIT APPLICATION TO MDEQ ON JUNE 2, 1998, WHICH WAS ULTIMATELY DENIED ON JAN. 7, 1999. U.S. DOJ FILED A COMPLAINT AGAINST BAY-HOUSTON IN AUGUST 1999. THE CASE HAS BEEN STAYED PENDING RESOLUTION OF A COMPLETION CASE.