In 1986, Laidlaw Environmental Services purchased a hazardous waste incinerator near South Carolina’s North Tyger River, which required them to receive a permit for the disposal of waste under the Clean Water Act. This permit limited the volume of pollutants the company could discharge into the river from the operation of the incinerator. During the period of operation from 1987 to 1995, the company violated the permit’s allowable amount of discharge 489 times, leading the Friends of the Earth to file suit under the Clean Water Act. Attempting to avoid a costly lawsuit, Laidlaw petitioned the South Carolina Department of Health and Environmental Control to request a state enforcement that would give them a civil penalty and a timeline to address the issues, thus negating the case of the Friends of the Earth.