1. SECTION 309(G) OF THE CLEAN WATER ACT ( CWA ), 33 U.S.C. SEC. 1319(G). 2. CITY OF SAPULPA P.O. BOX 1130 SAPULPA, CREEK COUNTY, OKLAHOMA 74067 NPDES PERMIT NOS. OK0025992 AND OK0026000 3. RESPONDENT VIOLATED SECTION 301(A) OF THE CWA BY FAILING TO SUBMIT PRETREATMENT PROGRAM MODIFICATIONS AND TECHNI- CALLY BASED LOCAL LIMITS REQUIRED TO COME INTO COMPLIANCE WITH THE REQUIREMENTS OF 40 C.F.R. PART 403, FAILING TO COMPLY WITH FINAL EFFLUENT LIMITATIONS SPECIFIED FOR CAD- MIUM, CHROMIUM, LEAD, SILVER, AND TOTAL PCBS, AND BY DIS- CHARGING POLLUTANTS IN AMOUNTS AND/OR CONCENTRATIONS IN EXCESS OF ITS PERMITTED LIMITATIONS. 4. RELIEF SOUGHT PURSUANT TO SECTION 309(G) OF THE CWA, EPA PROPOSES A CIVIL PENALTY OF $125,000. 5. FACILITY ID NO. OK0025992.