THIS IS CIVIL JUDICIAL REFERRAL PURSUANT TO SECTIONS 301(A) AND 309 OF THE CLEAN WATER ACT [33 U.S.C. 1311(A) AND 1319] REGARDING DEFENDANT SAFEWAY, INC. THE VIOLATION HERE IS DISCHARGE OF POLLUTANTS TO WATERS OF THE UNITED STATES WITHOUT A VALID NPDES PERMIT AT 24 SEPARATE LOCATIONS (LARGE QUANTITIES OF MILK WERE DISPOSED BY POURING INTO SANITARY SEWERS).THIS REFERRAL SEEKS A CIVIL PENALTY OF $200,000 IN ORDER TO RECOVER THE ECONOMIC BENEFIT GAINED BY NON-COMPLIANCE, TAKING INTO ACCOUNT THE RELATIVE GRAVITY OF THE VIOLATIONS.