THIS ACTION IS BASED ON THE CWA SECTION 307 AND 40 CFR PARTS 403 & 413. THE DEFENDANT HAS VIOLATED NATIONAL PRE- TREATMENT STANDARDS & REPORTING REQUIREMENTS. PROPOSED RELIEF SOUGHT INCLUDES: INJUNCTIVE RELIEF TO IN- SURE COMPLIANCE WITH PRETREATMENT STDS BY THE END OF 1987 OR SOONER, DEPENDING WHETHER DEFENDANT OPTS TO JOIN A CENTRAL RESOURCE RECOVERY FACILITY OR INSTALL PRETREATMENT ON ITS OWN; INJUNCTIVE RELIEF TO COMPEL COMPLIANCE WITH PRETREAT- MENT REPORTING REQUIREMENTS; CIVIL PENALTIES TO BE BASED ON A BEN AND GRAVITY-OF-VIOLATION ANALYSIS.