1. SECTION 309(G) OF THE CLEAN WATER ACT ( CWA ), 33 U.S.C. SECTION 1319(G). 2. PROGRESSIVE, INC., A TEXAS CORPORATION 1030 COMMERCIAL BOULEVARD NORTH ARLINGTON, TARRANT COUNTY, TEXAS 76017 3. RESPONDENT WAS IN VIOLATION OF 301 OF THE CWA BY DIS- CHARGING POLLUTANTS TO WATERS OF THE U.S DURING PERIODS OF RAINFALL WITHOUT A NPDES PERMIT FROM APPROXIMATELY OCT. 1, 1992 TO JAN. 9, 1998. 4. RELIEF SOUGHT PURSUANT TO SECTION 309(G)(1) OF THE CWA, EPA PROPOSES A CIVIL PENALTY OF $27,500 FOR THE VIOLATION CITED.