VIOLATIONS UPON WHICH THE ACTION IS BASED: NUMEROUS AND CONTINUOUS VIOLATIONS OF A STATE ISSUED NPDES PERMIT WY-0022357 AND A SUBSEQUENT EPA ADMINISTRATIVE ORDER ISSUED UNDER SECTION 309(A)(3) OF THE ACT, 33 USC 1319(A)(3). PROPOSED RELIEF TO BE SOUGHT, INCLUDING INJUNCTION, AND PROPOSED AMOUNT OF PENALTY TO BE SOUGHT AT SETTLEMENT. INJUNCTIVE RELIEF PLACING ROCK SPRING ON A COURT ENFORCE- ABLE FIXED DATE COMPLIANCE SCHEDULE FOR THE DEVELOPMENT AND IMPLEMENTATION OF AN EFFECTIVE COMPREHENSIVE COMPOSITE CORRECTION PLAN TO BRING ITS WASTEWATER TREATMENT INTO CONTI NOUS COMPLIANCE WITH THE CWA. ADDITIONALLY, WE ARE SEEKING A CIVIL PENALTY FOR PAST NPDES & PRETREATMENT VIOLATIONS.