1. SECTION 309(G)(2)(A) OF THE CLEAN WATER ACT ( CWA ), 33 U.S.C. SEC. 1319(G)(2)(A). 2. K-T GALVANIZING P.O. BOX 72 KATY, TEXAS 77492-0072 FACILITY NO. TXP000065 3. RESPONDENT VIOLATED SECTION 308(A) OF THE CWA BY FAILING TO SUBMIT A FINAL COMPLIANCE REPORT AND SEMI-ANNUAL COM- PLIANCE REPORTS, FAILING TO SUBMIT A BMR, AND VIOLATING AN ADMINISTRATIVE ORDER BY NOT HAVING AN APPROVED PRE- TREATMENT PROGRAM. 4. RELIEF SOUGHT PURSUANT TO SECTION 309(G)(2)(A) OF THE CWA EPA PROPOSES A PENALTY NOT TO EXCEED $25,000.00.