THIS IS A CLASS I ADMINISTRATIVE PENALTY COMPLAINT ISSUED AGAINST PHAR OIL CO., INC. UNDER SECTION 309(G) OF THE CLEAN WATER ACT. THE ADMINISTRATIVE COMPLAINT ALLEGES THAT RESPONDENT DISCHARGED BRINE ( A POLLUTANT) VIA 4 LEASES INTO WATERS OF THE U.S. WITHOUT A VALID KPDES OR NPDES PERMIT ON DEC. 1, 1988. THE PROPOSED PENALTY IS $10,000. A CONSENT AGREEMENT & ORDER WAS PRE-NEGOTIATED WITH RESPONDENT AND ATTACHED TO THE ADMINISTRATIVE COMPLAINT. THE PROPOSED CONSENT AGREEMENT IS FOR $6,000.