1. SECTION 309 OF THE CLEAN WATER ACT ( CWA ), 33 U.S.C. SECTION 1319. 2. CITY OF CARTHAGE, A TEXAS MUNICIPALITY 1.5 MILES EAST OF THE INTERSECTION OF U.S. HIGHWAY 59 AND 79 CARTHAGE, PANOLA COUNTY, TEXAS 75633 3. RESPONDENT WAS IN VIOLATION OF SECTION 301(A) OF THE CWA BY: 1) EFFLUENT VIOLATIONS - EXCEEDING THE PERMITTED EF- FLUENT LIMITS REPEATEDLY; 2) NON-SUBMITTAL OR LATE-SUB- MITTAL OF DMRS; AND 3) INSPECTION VIOLATIONS - IMPROPER CALIBRATIONS AND POOR OPERATING CONDITIONS. 4. RELIEF SOUGHT PURSUANT TO SECTION 309 OF THE CWA, EPA SUBMITTED A DIRECT REFERRAL REQUESTING DOJ TO INITIATE A CIVIL ENFORCEMENT ACTION FOR INJUNCTIVE AND OTHER RELIEF AGAINST THE RESPONDENT. THE BOTTOM-LINE CASH SETTLEMENT PENALTY IS $284,500.