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