STATUTE - 309 OF THE CLEAN WATER ACT, 33 U.S.C. SECTION 1319. VIOLATIONS - 2 UNPERMITTED OUTFALLS IN VIOLATION OF THE CLEAN WATER ACT. PROPOSED RELIEF - SETTLEMENT IN THE FORM OF A CONSENT DECREE. A MINIMUM CIVIL PENALTY IN THE AMOUNT OF $99,000. SINCE THE COMPANY HAS SUBMITTED A NPDES PERMIT APPLICATION TO COVER THE UNPERMITTED OUTFALLS, NO INJUNCTION RELIEF IS NECESSARY.