1. SECTION 309(B) OF THE CLEAN WATER ACT ( CWA ), 33 U.S.C. SECTION 1319(B). 2. CITY OF MANDEVILLE, A LOUISIANA MUNICIPALITY 3101 EAST CAUSEWAY APPROACH MANDEVILLE, ST. TAMMANY PARISH, LOUISIANA 70448 3. RESPONDENT WAS IN VIOLATION OF SECTION 301(A) OF THE CWA BY DISCHARGING POLLUTANTS FROM ITS FACILITY REPEATEDILY ON OCASSIONS THAT EXCEED PERMITTED EFFLUENT LIMITATIONS. 4. RELIEF SOUGHT PURSUANT TO SECTION 309(B) OF THE CWA, EPA REFERRED THIS DIRECT REFERRAL TO DOJ REQUESTING THE INI- TIATION OF A CIVIL ENFORCEMENT ACTION. EPA IS SEEKING IN- JUNCTIVE RELIEF AND AN UNDETERMINED CIVIL PENALTY AGAINST THE RESPONDENT FOR THE NUMEROUS AND REPEATED VIOLATION OF THE NPDES PERMIT REQUIREMENTS FOR THE CITY'S PUBLICILY- OWNED SEWAGE TREATMENT PLANT OVER A PERIOD OF 9 YEARS.