THE PROPOSED COMPLAINT FILED WITH THIS LITIGATION REPORT SEEKS COMMENCEMENT OF A CIVIL ACTION AGAINST J.T. BAKER CHEM COMPANY, A SPECIALTY MANUFACTURER OF RELATIVELY SMALL LOTS OF OVER 450 INORGANIC CHEMICALS, FOR CONTINUED VIOLATION OF A NUMBER OF EFFLUENT CHARACTERISTICS LIMITED IN ITS NPDES PERMIT. IN ITS ACTION EPA SEEKS IMPOSITION OF CIVIL PENAL- TIES FOR VIOLATION OF NPDES PERMIT ISSUED TO BAKER AS PERMITTEE PURSUANT TO THE FEDERAL WATER POLLUTION CONTROL ACT AMENDMENTS OF 1972, 33 USC SECTION 1251 ET SEQ., NOW THE CLEAN WATER ACT. THE GOV'T ALSO SEEKS TO OBTAIN EQUITABLE RELIEF AGAINST BAKER WITH A GOAL OF TERMINATING WHAT HAS BEEN THE ESSENTIALLY CONTINUAL VIOLATIONS OF THE TERMS AND CONDITIONS OF ITS PERMIT SINCE THE EFFECTIVE DATE, 7/31/74. THE MAJOR PERMIT VIOLATION WHICH THE INJUNCTION SOUGHT HEREIN ADDRESSES IS VIOLATION OF EFFLUENT LIMITATIONS CON- TAINED IN BAKER'S PERMIT WHICH LIMIT AVERAGE AND MAXIMUM DISCHARGE QUANTITIES OF CERTAIN CHARACTERISTICS OF THE EF- FLUENT, INCLUDING BOD-5, TSS, AND AMMONIA NITROGEN. AS A RESULT OF AN ADMINISTRATIVE ACTION COMMENCED BY EPA ON MAY 29 1981 PURSUANT TO 33 USC SECTION 1319, ADDITIONAL VIOLA- TIONS INVOLVING CHIEFLY LEAD, BUT TO A SMALLER EXTENT COPPER AND MERCURY AS WELL, WERE SUBSEQUENTLY EFFECTIVELY CURED BY BAKER. BECAUSE A CONSENT DECREE (CD) HAS ALREADY BEEN FILED AND APPROVED BY THE COURT, EPA SUBMITS HER