PRASA violated the Act by discharging from the POTW treated sewage at a location other than the authorized in said permit for at least twelve (12) consecutive days. Although the discharge was of treated sewage, it was sewage from a primary treatment plant. Section 301(h) of the CWA allows the discharge of primary treated effluent into deep waters, as it is the case of the Puerto Nuevo WWTP. A penalty is proposed based on the above findings of violations, and after taking into consideration the statutory factors in Section 309(g) of the Act.