1. SECTION 309(G) OF THE CLEAN WATER ACT ( CWA ), 33 U.S.C. SECTION 1319(G). 2. SOUTHWEST INDUSTRIAL GASES, INC., A TEXAS CORPORATION 538 SOUTH INDUSTRIAL BOULEVARD DALLAS, DALLAS COUNTY, TEXAS 75207 3. RESPONDENT WAS IN VIOLATION OF SECTION 301 OF THE CWA BY EACH DAY THAT RESPONDENT CONDUCTED THE RELEVANT ACTIVI- TIES AND OPERATED THE FACILITY WITHOUT NPDES PERMIT COVERAGE. 4. RELIEF SOUGHT PURSUANT TO SECTION 309(G) OF THE CWA, EPA PROPOSED A CIVIL PENALTY OF UP TO $27,500 FOR THE VIOLA- TION CITED.