Acuity Specialty Products Group Inc.

submitted to the City of Atlanta.28. On or about April 4, 2000, Employee A knowingly failed to report thedischarge of approximately 10,000 gallons of sludge into the City of Atlanta sewersystem.29. On or about March 23, 200 2, Employee A knowingly failed to report toany authorities that acid product and caustic wastewater had been discharged into aditch at the Seaboard facility, in violation of ASP's Permit.30. From in or about June 2002 until on or about October 1, 2002, the exactdates being unknown, Employee A reported pH data on SMRs submitted to the Cityof Atlanta which was false because the pH probe was not functioning. It is not knownwhether the actual pH of the facility's wastewater exceeded the permit limits.31. On or about November 7, 2002, Employee A caused a garden hose to beused to dilute wastewater pre-treatment plant effluent in the V-Notch weir area of thewastewater pre-treatment plant, in order to prevent City of Atlanta personnel fromobtaining a representative sample of the facility's wastewater while the City personnelwere conducting monitoring at the facility.32. On or about the dates listed below, Defendant ASP, through EmployeeA, knowingly failed to report accurate phosphorus sampling results on the SMRssubmitted to the R.M. Clayton Reclamation Center POTW:9