COLUMBIA MANUFACTURING COMPANY, INC. (COLUMBIA) MANUFACTURES BICYCLES AND SCHOOL FURNITURE AT ITS WESTFIELD FACILITY. PURSUANT TO THE CLEAN WATER ACT (CWA), COLUMBIA DISCHARGED APPROXIMATELY 200,000 GALLONS PER DAY (GPD) OF ITS PROCESS AND OTHER WASTEWATER THROUGH A NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM (NPDES) OUTFALL TO THE LITTLE RIVER. INCLUDED IN THIS TOTAL WAS AT LEAST 39,500 GALLONS PER DAY OF NON-CONTACT COOLING WATER, GROUNDWATER AND STORMWATER. THE COMPANY WAS IN CHRONIC VIOLATION OF IT'S PERMIT MONTHLY AVERAGE LIMITATIONS ON HEXAVALENT CHROMIUM CONCENTRATION, AND ITS MAXIMUM DAILY LIMITATIONS ON HEXAVALENT CHROMINIUM AND COPPER CONCENTRATIONS, WITH OCCASIONAL VIOLATIONS OF PERMIT LIMITATIONS ON ZINC, NICKEL, AND OIL AND GREASE. COLUMBIA NOW DISCHARGES APPROXIMATELY 360,000 GALLONS PER DAY OF INDUSTRIAL WASTEWATER TO THE PUBLICLY OWNED TREATMENT WORKS (POTW) OWNED AND OPERATED BY WESTFIELD, MASSACHUSETTS. THE FLOW TO THE POTW IS ESTIMATED BY THE COMPANY SINCE THERE IS NO FLOW MEASURING DEVICE ON THIS DISCHARGE. FEDERAL CATEGORICAL PRETREATMENT REGULATIONS REQUIRE IT TO SAMPLE DISCHARGES TO THE POTW SEMI-ANNUALLY. HOWEVER, COLUMBIA ROUTES THE PROCESS WASTEWATER TO A POINT IN ITS SEWER LINE WHERE THE PROCESS WASTEWATER IS COMBINED WITH THE SANITARY WASTE OF THE PLANT. THUS, THE CONCENTRATION OF POLLUTANTS IN ITS PROCESS WASTEWATER IS DILUTED BY SANITARY WASTE FLOW GENERATED BY ITS EMPLOYEES, IN VIOLA