ROBERT A. RICE AND PHYLLIS H. RICE DBA INTERMOUNTAIN MINERAL ENGINEERS, INC. (IME) OPERATE THE NABOB MINE NEAR THE NABOB CREEK NEAR PINEHURST, ID IN THE SILVER VALLEY REGION OF NORTHERN IDAHO. THEY LEASE THE NABOB TUNNEL, SITE OF THE ILLEGAL DISCHARGE, FROM THE NABOB SILVER-LEAD CO. OF KELLOGG, ID. THEY OPERATE PORTIONS OF THE NABOB LEAD & ZINC MINE THROUGH SUBSURFACE CLAIM LEASED FROM OTHER PARTIES. THEY ALSO LEASE A NEARBY MILLSITE FROM NABOB SILVER-LEAD TO PROCESS ORE WHICH CONTAINS FACILITIES FOR DISCHARGE WATER TREATMENT. THREE SPECIFIC VIOLATIONS OF THE CLEAN WATER ACT BY ILLEGAL DISCHARGES ARE DOCUMENTED TO DATE. BECAUSE OF THE STATUTE OF LIMITATIONS, TWO OF THESE VIOLATIONS ARE CHARGEABLE IN THE COMPLAINT. SUBSTANTIVE LEGAL REQUIREMENTS ARE CLEAN WATER ACT, SEC 301(A){33 USC, 1311(A)}, SEC 502{33 USC, 1362}, TITLE 40 CFR, SEC 122.2. AVAILABLE REMEDIES ARE CWA, SEC 309(D), 33 USC, 1319(D).