A. P. GREEN OWNS AND OPERATES A CERAMIC FIBER MANU- FACTURING FACILITY LOCATED AT THE MID-AMERICA INDUSTRIAL PARK IN PRYOR, OKLAHOMA. IT IS ALLEGED THAT A. P. GREEN, FROM AUGUST 1980 THROUGH APRIL 14, 1992, DISCHARGED INDUSTRIAL PROCESS WATER AND STORM WATER FROM THE PRYOR FACILITY VIA OUTFALL 001 TO AN UNNAMED DITCH LEADING TO PRYOR CREEK AND THE NEOSHO RIVER. IT IS FURTHER ALLEGED THAT A. P. GREEN, FROM AUGUST 1980 THROUGH OCTOBER 1991, DISCHARGED PROCESS WATER AND STORM WATER FROM THE PRYOR FACILITY'S OUTFALL 002 TO THE AFORE-MENTIONED UNNAMED DITCH. AT NO TIME DID A. P. GREEN HAVE A NPDES PERMIT AUTHORIZING SUCH DISCHARGES. BY DISCHARGING WITHOUT A NPDES PERMIT, A. P. GREEN VIOLATED SECTION 301(A) OF THE CLEAN WATER ACT.