MEMORANDUM OPINION
SUSAN WEBBER WRIGHT, District Judge.
The United States seeks civil penalties and injunctive relief against CPS Chemical Company, Inc. (CPS) for persistent discharge of pollutants into navigable waters in violation of Sections 301 and 402 of the Clean Water Act, 33 U.S.C. §§ 1311 and 1342, the conditions and limitations of the
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