THIS ADMINISTRATIVE PENALTY ORDER IS ISSUED TO THE CITY OF FORT LUPTON AND OPERATIONS MANAGEMENT INTERNATIONAL FOR FAILURE TO CONDUCT ANALYSES TO DETERMINE IF SEWAGE SLUDGE THAT WAS GIVEN TO CITY RESIDENTS MET THE CEILING CONCENTRATION FOR POLLUTANTS OR MET THE CLASS A PATHOGEN REQUIREMENTS. ALSO THE RESIDENTS WHO RECEIVED THE SLUDGE IN 1999 AND 2000 DID NOT RECEIVE A LABEL OR INFORMATION SHEET IN ACCORDANCE WITH FEDERAL REGULATIONS. THIS ORDER IS SUBJECT TO THE 22 RULE WHICH IS ENTERED INTO BY THE PARTIES FOR THE PURPOSE OF SIMULTANEOUSLY COMMENCING AND CONCLUDING THIS MATTER. THE PENALTY ASSESSED FOR THESE VIOLATIONS IS $50,000.