1. SECTION 309(G)(2)(A) OF THE CLEAN WATER ACT ( CWA ), 33 U.S.C. SEC. 1319(G)(2)(A). 2. CITY OF SAPULPA P.O. BOX 1130 SAPULPA, OKLAHOMA 74067 FACILITY: CREEK COUNTY, OKLAHOMA NPDES PERMIT NO. OK0025992 3. RESPONDENT VIOLATED SECTION 308 OF THE CWA BY FAILING TO SUBMIT PRETREATMENT MODIFICATIONS BY MAY 10, 1993, AS RE- QUIRED BY THE NPDES PERMIT. THE MODIFICATIONS WERE SUB- MITTED IN JUL. 1994. 4. RELIEF SOUGHT PURSUANT TO SECTION 309(G)(2)(A) OF THE CWA EPA PROPOSES A PENALTY NOT TO EXCEED $25,000.00.