1. SECTIONS 309(G)(1) AND 309(G)(2) OF THE CLEAN WATER ACT, 33 U.S.C. SECTIONS 1319(G)(1) AND 1319(G)(2), ( CWA ). 2. DIXIE CHEMICAL COMPANY 10701 BAY AREA BOULEVARD PASADENA, HARRIS COUNTY, TEXAS 77507 3. RESPONDENT WAS IN VIOLATION OF SECTION 301(A) OF THE CWA BY NOT HAVING A COMPLETED POLLUTION PREVENTION PLAN (PPP) IMPLEMENTED, INADEQUATE RECORDKEEPING, AND FAILING TO MONITOR STORMWATER DISCHARGES. 4. RELIEF SOUGHT PURSUANT TO SECTION 309(G)(2)(A) OF THE CWA EPA PROPOSES A CIVIL PENALTY OF $10,000 PER VIOLATION, UP TO A MAXIMUM OF $25,000.