1. SECTION 309(G) OF THE CLEAN WATER ACT ( CWA ), 33 U.S.C. SECTION 1319(G). 2. COBRE MINING COMPANY, A DELAWARE CORPORATION 3 MILES NORTH OF THE TOWN HANOVER, GRANT COUNTY, NEW MEXICO 79825 3. RESPONDENT WAS IN VIOLATION OF SECTION 301 OF THE CWA BY EACH DAY THE RESPONDENT CONDUCTED THE RELEVANT ACTIVITIES AND OPERATED THE FACILITY WITHOUT NPDES PERMIT COVERAGE. 4. RELIEF SOUGHT PURSUANT TO SECTION 309(G) OF THE CWA, EPA PROPOSED A CIVIL PENALTY OF UP TO $137,500 FOR THE VIOLA- TIONS CITED.