A CIVIL ACTION IS PROPOSED AGAINST RICO DEVELOPMENT CORPORATION ALLEGING THAT RDC VIOLATED ITS NPDES PERMIT FOR THE DISCHARGE OF PROCESS WASTEWATERS CONSISTING OF MINE DRAINAGE FROM ITS INACTIVE LEAD, ZINC AND SILVER MINE. NPDES PERMIT #CO-002973 IS THE PERMIT PERTAINING TO THIS SITE. THIS ACTION UNDER SECTION 309A IS FOR VIOLATIONS OF THE NPDES PERMIT. THIS ACTION UNDER SECTION 301A IS FOR DISCHARGING WITHOUT AN NPDES PERMIT FROM THE BLAINE TUNNEL. THE PROPOSED PENALTY IS $1,750,000.