THIS CASE IS A DIRECT REFERRAL OF AMERICAN FELT AND FILTER CO., INC. TO THE DEPARTMENT OF JUSTICE FOR LITIGATION UNDER THE CLEAN WATER ACT AND THE REFUSE ACT, REQUESTING THAT THE DOJ INITIATE A CIVIL ACTION PURSUANT TO SECTION 309(B) OF THE CWA, 33 USC 1319(B), AND THE REFUSE ACT, 33 USC 407 FOR VARIOUS VIOLATIONS. THIS CASE IS BEING REFERRED AS A DIRECT REFERRAL PURSUANT TO THE LETTER AGREEMENT DATED 9/29/83, BETWEEN EPA & DOJ, WHICH DESIGNATED CASES INVOLVING UNAUTHORIZED DISCHARGES BY INDUSTRIAL DISCHARGERS AS CANDIDATES FOR REFERRAL DIRECTLY FROM THE REGIONAL OFFICES TO DOJ. THE U.S. ATTORNEY'S OF- FICE FOR THE S.D.N.Y. HAS REFERRED THIS CASE TO EPA FOLLOW- ING SUBSTANTIAL INVESTIGATION AND DEVELOPMENT, INCLUDING DRAFTING OF A COMPLAINT, AND WOULD LIKE TO FILE ASAP. THE VIOLATIONS UPON WHICH THE ACTION IS BASED ARE: UNAUTHORIZED DISCHARGE IN VIOLATION OF THE CWA/301(A); DIS- CHARGE OF REFUSE IN VIOLATION OF THE REFUSE ACT; & VIOLA- TIONS OF TERMS & CONDITIONS OF SPDES PERMIT NO. NY0004421. PROPOSED RELIEF SOUGHT INCLUDES: INJUNCTIVE RELIEF UNDER THE CWA AND RA TO REQUIRE CESSATION OF UNAUTHORIZED DIS- CHARGE, COMPLIANCE WITH ALL TERMS & CONDITIONS OF PERMIT AND MITIGATION OF ENVIRONMENTAL HARM; CIVIL PENALTIES OF $10,000 PER DAY PER VIOLATION UNDER CWA/309; AND INITIAL SETTLEMENT PENALTIES OF $880,000. **************************************