This Administrative Complaint (Complaint) seeks the assessment of civil penalties pursuant to the authority vested in the Administrator of the Environmental Protection Agency (EPA) by Section 309(g) of the Clean Water Act (CWA), 33 U.S.C. Section 1319(g).
The Director of the EPA Region 9 Enforcement and Compliance Assurance Division (Complainant) has been delegated the authority to issue this Complaint. The rules for this proceeding are the Consolidated Rules of Practice Governing the Administrative Assessment of Civil Penalties and the Revocation/Termination or Suspension of Permits (Rules of Practice), 40 Code of Federal Regulation (C.F.R.) Part 22, a copy of which is enclosed. See, specifically 40 C.F.R. Section 22.1(a)(9). Pursuant to the Rules of Practice, 40 C.F.R. Section 22.13(a), this Complaint conforms to the prehearing procedures at 40 C.F.R. Section 22.14 governing administrative complaints.