1. SECTION 309 OF THE CLEAN WATER ACT ( CWA ), 33 U.S.C. SECTION 1319. 2. CITY OF NEW IBERIA WASTEWATER TREATMENT PLANT 2400' SOUTHEAST OF THE INTERSECTION OF ADMIRAL DOYLE DRIVE AND CENTER STREET (STATE HIGHWAY 14) NEW IBERIA, IBERIA PARISH, LOUISIANA 70560 3. RESPONDENT WAS IN VIOLATION OF SECTION 301 OF THE CWA BY: 1) OVER 1,996 VIOLATIONS OF ALLOWING UNTREATED AND/OR PARTIALLY TREATED WASTEWATER TO BE DISCHARGED INTO WATERS OF THE U.S.; AND 2) FAILING TO PROPERLY OPERATE AND MAIN- TAIN ITS TREATMENT UNITS WHICH RESULTED IN THE EXCESSIVE DISCHARGE OF POLLUTANTS FROM THE FACILITY. 4. RELIEF SOUGHT PURSUANT TO SECTION 309 OF THE CWA, EPA RE- FERRED A DIRECT REFERRAL TO DOJ REQUESTING THE INITIATION OF A CIVIL ENFORCEMENT ACTION AGAINST THE RESPONDENT FOR THE VIOLATIONS OF SECTION 301 OF THE CWA AT ITS TREATMENT UNITS. EPA IS SEEKING INJUNCTIVE RELIEF AND OTHER RELIEF.