THIS CASE IS A DIRECT REFERRAL OF AL-CAM ENTERPRISES, INC. TO THE DEPARTMENT OF JUSTICE FOR LITIGATION UNDER THE CLEAN WATER ACT AND THE REFUSE ACT, REQUESTING THAT THE DOJ INITI- ATE A CIVIL ACTION PURSUANT TO SECTION 309(B) AND 311 OF THE CWA, 33 USC 1319(B) AND 1321, & THE REFUSE ACT, 33 USC 407. THIS CASE IS BEING REFERRED AS A DIRECT REFERRAL PURSUANT TO THE LETTER AGREEMENT DATED 9/29/83, BETWEEN EPA AND THE DOJ, WHICH DESIGNATED CASES INVOLVING UNAUTHORIZED DISCHAR- GES BY INDUSTRIAL DISCHARGERS AS CANDIDATES FOR REFERRAL DIRECTLY FROM THE REGIONAL OFFICES TO DOJ. THE U.S. ATTOR- NEY'S OFFICE FOR THE S.D.N.Y. HAS REFERRED THIS CASE TO EPA FOLLOWING SUBSTANTIAL INVESTIGATION AND DEVELOPMENT, INCLU- DING DRAFTING OF A COMPLAINT, AND WOULD LIKE TO FILE ASAP. THE VIOLATIONS UPON WHICH THIS ACTION IS BASED ARE: UNAUTHORIZED DISCHARGE IN VIOLATION OF CWA/301(A); DISCHARGE OF OIL IN VIOLATION OF CWA/311; AND DISCHARGE OF REFUSE IN VIOLATION OF THE REFUSE ACT. PROPOSED RELIEF SOUGHT INCLUDES: INJUNCTIVE RELIEF TO RE- QUIRE CESSATION OF UNAUTHORIZED DISCHARGE AND MITIGATION OF ENVIRONMENTAL HARM; AND INITIAL SETTLEMENT PENALTIES OF $70,000 TO $100,000. * FACILITY ADDRESS: