1. SECTION 309(G) OF THE CLEAN WATER ACT ( CWA ), 33 U.S.C. SEC. 1319(G). 2. CITY OF SHREVEPORT (LUCAS PLANT) 11301 E. KING HIGHWAY SHREVEPORT, LOUISIANA 71115 NPDES PERMIT NO. LA0041394 3. RESPONDENT HAS VIOLATED SECTION 301(A) OF THE CWA BY DIS- CHARGING POLLUTANTS INTO NAVIGABLE WATERS IN EXCESS OF ITS PERMIT LIMITATIONS. 4. RELIEF SOUGHT PURSUANT TO SECTION 309(G) OF THE CWA, EPA PROPOSES A CIVIL PENALTY OF $125,000. 5. FACILITY ID NO. LA41394.