COMPLAINT IS ISSUED TO ASSESS PENALTIES FOR VIOLATIONS OF THE NPDES PERMIT RELATED TO MONITORING AND OPERATION AND MAINTENANCE OF DISCHARGE PIPE. IN ADDITION, COMPLAINT CITES VIOLATIONS OF DISCHARGES WITHOUT A PERMIT. THE PARTIES AGREED ON A CASH PENALTY AND THE AGENCY IS ALSO SIMULTANEOUSLY ISSUING AN ORDER ON CONSENT (AOC) TO ADDRESS THE VIOLATIONS CITED IN THE COMPLAINT.