1. SECTION 309(G)(2)(A) OF THE CLEAN WATER ACT ( CWA ), 33 U.S.C. SECTION 1319(G)(2)(A). 2. AIRBORNE FREIGHT CORPORATION, A DELAWARE CORPORATION 10307 WETMORE ROAD SAN ANTONIO, BEXAR COUNTY, TEXAS 78216 3. RESPONDENT WAS IN VIOLATION OF SECTION 301(A) OF THE CWA BY DISCHARGING POLLUTANTS FROM THE FACILITY WITHOUT AN NPDES PERMIT DURING PERIODS OF RAINFALL FROM APPROXIMATE- LY OCT. 1, 1992 THROUGH MAR. 14, 1997. 4. RELIEF SOUGHT PURSUANT TO SECTION 309(G)(2)(A) OF THE CWA EPA PROPOSES A CIVIL PENALTY OF $27,500, WHICH CONSTI- TUTES NO MORE THAN $11,000 PER DAY PER VIOLATION FOR EACH VIOLATION.