THIS CASE INVOLVES VIOLATIONS OF THE PRETRMT REQUIRE- MENTS OF THE CWA BY INDEPENDENT PLATING CO, INC, AN ELECTRO- PLATER IN WORCESTER, MA. INDEPENDENT DISCHARGES APPROX 40,000 TO 100,000 GPD OF INDUSTRIAL WASTEWATER INTO THE UPPER BLACKSTONE WATER POLLU- TION ABATEMENT DISTRICT (UBWPAD) POTW AT MILLBURY, MA. THE HIGH CONCENTRATIONS OF TOT CN, TOT CR, TOT NI, TOT ZN, & TOT METALS VIOLATE THE ELECTROPLATING NATIONAL CATEGORICAL STDS AT 40 CFR PART 413. INDEPENDENT ALSO FAILED TO COMPLY W/THE MONITORING & REPORTING REQUIREMENTS OF THE GENERAL PRETRMT REGS AT 40 CFR SECT 403.12. THE DEF OPERATES AN ELECTROPLATING FACILITY IN WHICH A LARGE PORTION OF THE PRODUCTS PLATED ARE PARTS FOR METAL FURNITURE MFG. THE COMPANY USES 5 PLATING LINES WHOSE RINS- ES & OVERFLOWS ARE COLLECTED & DISCHARGED THRU 2 OUTFALLS TO THE SANITARY SEWER SYSTEM WHERE, AFTER TRMT, THE EFFLUENT FLOWS INTO THE BLACKSTONE RIVER. INDEPENDENT DOES NOT PRETREAT ANY OF ITS WASTEWATERS PRIOR TO DISCHARGE TO THE SEWER. AVAILABLE DATA SHOW CONSISTENT VIOLATIONS OF APPLI- CABLE LIMITS. THE UBWPAD DOES NOT YET HAVE AN APPROVED PRETRMT PGM; THEREFORE EPA IS THE LEAD ENFORCEMENT AUTHORITY TO BRING SUIT. VIOLATIONS: INDEPENDENT IS AN EXISTING, 'NON-INT