1. SECTION 309 OF THE CLEAN WATER ACT ( CWA ), 33 U.S.C. SECTION 1319. 2. THE GHK COMPANY, L.L.C., AN OKLAHOMA ORPORATION 6305 WATERFORD BOULEVARD, OKLAHOMA CITY, OKLAHOMA COUNTY, OKLAHOMA 73100ES, OK.
SITES IN LATIMER AND PUSHMATAHA COUNTIES, OK. 3. RESPONDENT WAS IN VIOLATION OF SECTIONS 301 , 404 AND 308 OF THE CWA BY: 1) FAILING TO APPLY FOR AND RECEIVE AN NPDES PERMIT BEFORE DISCHARGING AND FAILING TO DEVELOP AND DEVELOP A SWPPP; 2) FAILING TO APPLY FOR A 404 PERMIT FOR THE DISCHARGE OF DEDGED OR FILL MATERIAL; AND 3)FAILING TO RESPOND FULLY TO ASECTION 308 INFORMATION REQUEST.
4. RELIEF SOUGHT PURSUANT TO SECTION 309 OF THE CWA, EPA SUBMITTED A DIRECT REFERRAL REQUESTING THAT DOJ INITIATE A CIVIL ENFORCEMENT ACTION FOR INJUNCTIVE AND OTHER RELIEF AGAINST THE RESPONDENT.