THE HAVERSTRAW JOINT REGIONAL SEWERAGE BOARD (HJRSB), WEST HAVERSTRAW, NY, HAS VIOLATED ITS NPDES PERMIT BY FAILING TO PROPERLY IMPLEMENT ITS INDUSTRIAL PRETREATMENT PROGRAM AS REQUIRED BY SECTION 307 OF THE CLEAN WATER ACT. HJRSB OPERATES AN EIGHT MILLION GALLON PER DAY CONVENTION- AL ACTIVATED SLUDGE WASTEWATER TREATMENT PLANT IN WEST HAVERSTRAW, NY. IN AUGUST 1985, THE NYSDEC ISSUED HJRSB A NPDES PERMIT, EFFECTIVE 10/1/85, CONTAINING A REQUIREMENT TO IMPLEMENT ITS PRETREATMENT PROGRAM. IN DECEMBER OF 1985, EPA CONDUCTED AN AUDIT OF HJRSB'S PRETREATMENT PROGRAM AND CONCLUDED THAT HJRSB'S PROGRAM HAD NOT PROGRESSED BECAUSE OF A LACK OF INITIATIVEON THE PART OF HJRSB. IN DECEMBER OF 1986, EPA CONDUCTED AN INSPECTION OF THE PROGRAM AND CONCLU- DED THAT HJRSB WAS STILL NOT PROPERLY IMPLEMENTING ITS PRO- GRAM. HJRSB HAS ALSO FAILED TO SUBMIT THE SEMI-ANNUAL RE- PORTS ON PRETREATMENT PROGRAM IMPLEMENTATION TO THE NYSDEC. THESE REPORTS WERE DUE ON 4/29/86 & 10/29/86 & WERE REQUIRED BY HJRSB'S NPDES PERMIT. THE RELIEF SOUGHT INCLUDES A CIVIL PENALTY OF $57,000 AND EXPEDITIOUS IMPLEMENTATION OF THE PRETREATMENT PROGRAM. THE CIVIL PENALTY REQUESTED REFLECTS A DETERMINATION OF THE ECONOMIC SAVINGS DERIVED BY THE BOARD BY DELAYING ITS COM- PLIANCE AND A DETERMINATION ON THE GRAVITY OF THE VIOLATION. THIS CASE IS IMPORTANT BECAUSE IT IS PART OF A LARGER EFFO ISSUES: THIS CASE IS IMPORTANT BECAUS