1. SECTION 309(G) OF THE CLEAN WATER ACT ( CWA ), 33 U.S.C. SECTION 1319(G). 2. CITY OF GALVESTON,A TEXAS MUNICIPALITY CORNER OF 52ND STREET AND PORT INDUSTRIAL GALVESTON, GALVESTON COUNTY, TEXAS 77550 3. RESPONDENT WAS IN VIOLATION OF SECTION 301 OF THE CWA BY VIOLATING THE CONDITIONS OF ITS PRETREATMENT PROGRAM, AND THE TERMS AND CONDITIONS OF ITS NPDES PERMIT. 4. RELIEF SOUGHT PURSUANT TO SECTION 309(G) OF THE CWA, EPA PROPOSED A CIVIL PENALTY OF UP TO $137,500 FOR THE VIOLA- TIONS CITED.