THIS IS A CLASS I CLEAN WATER ACT (CWA) ADMINISTRATIVE PENALTY COMPLAINT ISSUED PURSUANT TO SECTION 309(G) OF THE CWA AGAINST PERKINS OIL CO, INC. FOR VIOLATIONS OF SECTION 301(A) OF THE CWA. RESPONDENT HAS VIOLATED SECTION 301(A) OF THE CWA BY DISCHARGING BRINE (PRODUCED WATER) INTO WATERS OF THE U.S. WITHOUT A VALID KPDES OR NPDES PERMIT. THE VIOLATION OCCURRED ON 03/20/90 AND WAS DETECTED BY A KY. STATE INSPECTOR. THE COMPLAINT SEEKS A PENALTY OF $4,000 AND WAS ISSUED 09/20/90. A PRE-NEGOTIATED DRAFT CONSENT AGREEMENT FOR $2,500 WAS SENT SIMULTANEOUSLY TO RESPONDENT FOR SIGNATURE.