ADM COMPLAINT ISSUED 12/14/2000 FOR PERMIT VIOLATIONS INCLUDING EXCEEDANCE OF ONE ACRE ZONE OF DEPOSIT, DISCHARGES OF FOAM AND SCUM AND DISCHARGES OF SEAFOOD WASTE. WE PROPOSE TO W/D THE ADMINISTRATIVE COMPLAINT AND REFER CASE TO DOJ. INJUNCTIVE RELIEF IS NEEDED TO COMPEL THE COMPANY TO ADDRESS THE VIOLATION OF EXCEEDING ONE ACRE ZONE OF DEPOSIT AND INJUNCTIVE RELIEF IS NOT AVAILABLE ADMINISTRATIVELY. FROM PRELIMINARY NEGOTIATIONS, IT DOES NOT APPEAR THE COMPANY WILL REMEDY THE ZONE OF DEPOSIT VIOLATION ON ITS OWN AND IT APPEARS THE ECONOMIC BENEFIT OF NONCOMPLIANCE WAS UNDERESTIMATED.