THE COMPLAINT ALLEGES THAT RESPONDENT VIOLATED THE TERMS OF ITS NPDES PERMIT SECTION 301(A) BY FAILING TO SUBMIT A BEST MANAGEMENT PRACTICES PLAN PRIOR TO BEGINNING TO PROCESS FINFISH IN APRIL 1991, TO SUBMIT THE STICKWATER RECOVERY PLAN, TO COLLECT 24 HOUR COMPOSITE SAMPLES OF TSS FOR APRIL 22 THROUGH SEPTEMBER 7, 1991, TO COLLECT SEPARATE FISH MEAL AND STICK WATER SAMPLES AS REQUIRED BY PART I.F.1. OF THE PERMIT, TO TIMELY SUBMIT DMRS, TO PREVENT OIL SLICKS ON THE WATER, TO REPORT UNANTICIPATED BYPASSES OF ITS WASTEWATER TREATMENT EQUIPMENT, TO CONDUCT SHORELINE INSPECTIONS, TO CHART THE EXTENT OF THE WASTE PILE NEAR ITS OUTFALL, AND TO REPORT STICK WATER RECYCLING.