1. SECTION 309(G)(2)(A) OF THE CLEAN WATER ACT ( CWA ), 33 U.S.C. SECTION 1319(G)(2)(A). 2. DEL ORO DAIRY, A NEW JERSEY PARTNERSHIP P.O. BOX 1846 ANTHONY, DONA ANA COUNTY, NEW MEXICO 88021 3. RESPONDENT WAS IN VIOLATION OF SECTION 301(A) OF THE CWA BY FAILING TO DEVELOP AND IMPLEMENT A POLLUTION PREVENT- ION PLAN (PPP0 AS REQUIRED BY ITS PERMIT. 4. RELIEF SOUGHT PURSUANT TO SECTION 309(G)(2)(A) OF THE CWA, EPA PROPOSES A CIVIL PENALTY OF $25,000.