1. SECTION 309(G)(2)(A) OF THE CLEAN WATER ACT ( CWA ), 33 U.S.C. 1319(G)(2)(A). 2. MOBIL CHEMICAL COMPANY POLYETHYLENE PLANT P.O. BOX 2295 BEAUMONT, TEXAS 77704 NPDES PERMIT NO. TX0068934 3. RESPONDENT VIOLATED SECTION 301(A) OF THE CWA BY VIOLAT- ING THE BYPASS PROVISION OF ITS NPDES PERMIT BY DISCHARG- ING 30,000 GALLONS OF UNTREATED DOMESTIC SEWAGE TO THE FACILITY'S STORMWATER DRAINAGE SYSTEM. 4. RELIEF SOUGHT PURSUANT TO SECTION 309(G)(2)(A) OF THE CWA A PENALTY OF $25,000.00 IS PROPOSED.