1. SECTION 309(G)(2)(A) OF THE CLEAN WATER ACT ( CWA ), 33 U.S.C. SEC. 1319(G)(2)(A). 2. INTERNATIONAL PAPER COMPANY R.R. 4 BOX 1002 MINDEN, LOUISIANA 71055 NPDES PERMIT NO. LA0065218 3. RESPONDENT WAS IN VIOLATION OF SECTION 301(A) OF THE CWA BY DISCHARGING HIGH BIOCHEMICAL OXYGEN DEMAND (BOD) WASTE WATER FROM ITS FACILITY INTO BOONE CREEK WITHOUT AN NPDES PERMIT RENEWAL OR NEW PERMIT FOR THE DISCHARGE OF A POLL- UTANT FROM THE FACILITY. 4. RELIEF SOUGHT PURSUANT TO SECTION 309(G)(2)(A) OF THE CWA EPA PROPOSES TO ASSESS ADMINISTRATIVE PENALTIES IN THE A- MOUNT OF $10,000 PER VIOLATION, UP TO A MAXIMUM OF $25,000.