THIS IS A PROPOSED ACTION UNDER SECTION 309 OF THE CWA AGAINST LOUISIANA PACIFIC (LP) AND SIMPSON PAPER COMPANY (SIMPSON). LPAND SIMPSON OPERATE PULP MILLS ON THE NORTH SPIT OF HUMBOLDT BAY IN FAIRHAVEN, CALIFORNIA, NEAR EUREKA. LP AND SIMPSON DISCHARGE WASTE WATER PURSUANT TO NPDES PERMITS INTO THE PACIFIC OCEAN. EPA REGION 9 IS SEEKING INJUNCTIVE RELIEF TO REQUIRE PROMPT COMPLIANCE WITH THE TOXICITY LIMITS, AND AN APPROPRIATE CIVIL PENALTY. THE SURFRIDER FOUNDATION HAS FILED A NOTICE OF CITIZEN SUIT ALSO SEEKING TO BRING AN ENFORCEMENT ACTION CONCERNING THESE VIOLATIONS. NOTE: BOTH SIMPSON AND LOUISIANA PACIFIC HAVE PULP MILLS THAT ARE LOCATED RIGHT NEXT TO EACH OTHER. BOTH ARE CAUSING POLLUTION TO THE PACIFIC OCEAN. BOTH ARE BENIFICIARIES OF CWA 301(M).