THIS COMPLAINT ALLEGES THAT A.M.R. COMBS HAS VIOLATED CERTAIN PROVISIONS OF THE CLEAN WATER ACT BY DISCHARGING POLLUTANTS TO WATERS OF THE UNITED STATES WITHOUT AN AUTHORIZING NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM (NPDES) PERMIT. A.M.R. COMBS-DENVER OPERATES A JET FUEL TANK FARM NEAR STAPLETON AIRPORT ON BEHALF OF UNITED AIRLINES. ON NOVEMBER 25, 1990, A FIRE OCCURED AT THE TANK FARM, BURNING FOR THREE DAYS BEFORE IT WAS FINALLY EXTINGUISHED BY OTHER ENTITIES. ON THIS DATE, SAND CREEK BEGAN RECEIVING CHEMICALS AND OTHER POLLUTANTS, GENERATED AND RELEASED AS A RESULT OF THE FIRE.