THIS IS A CIVIL ACTION UNDER SECTION 309(B) OF THE CWA FOR APPROPRIATE RELIEF, INCLUDING INJUNCTIVE RELIEF AND THE IM- POSITION OF CIVIL PENALTIES, FOR DEFENDANT'S VIOLATIONS OF ITS NPDES PERMITS CONDITIONS. INDUSTRIAS LA FAMOSA, INC., DEFENDANT, A COMPANY INCORPO- RATED UNDER THE LAWS OF NJ AND DULY LICENSED TO DO BUSINESS IN PR, IS IN THE BUSINESS OF CANNING FRUIT JUICES AND NEC- TARS. DEFENDANT'S PLANT WHICH IS THE SUBJECT OF THIS ACTION IS LOCATED IN BAYAMON, PR. THE PLANT WASTEWATERS PRIMARILY ORIGINATE FROM CLEANING OF THE PRODUCTION AREA, SANITARY WASTEWATERS AND EFFLUENT OF A GREASE TRAP LOCATED IN THE RE- PAIR SHOP, AND ARE DISCHARGED TO THE RIO HONDO. DEFENDANT HAS HAD 1,131 VIOLATIONS OF ITS PERMIT LIMITS SINCE AUGUST 1981 AS EVIDENCED BY ITS DMR'S. ALSO, IN THE COURSE OF PLANT INSPECTIONS CONDUCTED BY THE EPA OR THE PR EQB, THE INSPECTORS REPORTED DEFENDANT'S FAILURE TO COMPILE AND RETAIN RECORDS OF LABORATORY EQUIPMENT CALIBRATION & MAINTENANCE AS REQUIRED IN THE PERMITS. FURTHER, DEFENDANT FAILED TO NOTIFY THE EPA IN THE EVENT OF PERMIT NONCOMPLI- ANCE AS REQUIRED BY PART II(A)(2) OF ITS PERMIT. FINALLY, DEFENDANT FAILED TO OPERATE ITS FACILITY PROPERLY AS RE- QUIRED BY PART II(A)(3) OF ITS PERMIT. RELIEF REQUESTED INCLUDES THE FOLLOWING: ORDER DEFENDANT TO COMPLY WITH ITS PERMIT REQUIREMENTS AND CONDITIONS; IM- POSE A CIVIL PENALTY OF $10,000 FOR EA