1. SECTION 309(G)(2)(A) OF THE CLEAN WATER ACT ( CWA ), 33 U.S.C. SECTION 1319(G)(2)(A). 2. VRATSINAS CONSTRUCTION COMPANY THE PRUDENTIAL INVESTMENT CORPORATION, D/B/A PRUDENTIAL REALTY GROUP FACILITY: KEYSTONE CONSTRUCTION PROJECT 13929 N. CENTRAL EXPRESSWAY DALLAS, TEXAS 3. RESPONDENTS WERE IN VIOLATION OF SECTION 301(A) OF THE CWA BY DISCHARGING POLLUTANTS WITHOUT A PERMIT. 4. RELIEF SOUGHT PURSUANT TO SECTION 309(G)(2)(A) OF THE CWA, EPA PROPOSES A CIVIL PENALTY OF $10,000 PER VIOLAT- IONS, UP TO A MAXIMUM OF $25,000.