CIVIL REFERRAL UNDER THE CLEAN WATER ACT CAROL STREAM, ILLINOIS REFERRED WITH CIVIL LITIGATION REPORTS FOR GENEVA, ILLINOIS, AND SOUTH BEND, INDIANA. CIVIL LITIGATION REPORTS DOCUMENT SERIOUS VIOLATIONS OF THE PRETREATMENT REQUIREMENTS OF THE CLEAN WATER ACT. BACKGROUND: EACH OF THE THREE REPORTS IS SIMILAR IN THE FACTUAL BACKGROUND LEADING TO THE VIOLATIONS. IN EACH CASE, U.S. EPA REGULATIONS REQUIRED THESE MUNICIPALITIES TO SUBMIT APPROVABLE PRETREATMENT PROGRAMS BY JULY 1, 1983. IN EACH CASE, APPLICABLE NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM (NPDES) PERMITS REQUIRED THE SUBMITTALS BY DATES CERTAIN. FINALLY, U.S. EPA ADMINISTRATIVE ORDERS (AO'S) ISSUED UNDER THE CWA REQUIRED THESE CITIES TO SUBMIT PRE- GRAMS BY NO LATER THAN JANUARY 1985. UNFORTUNATELY, IN EACH CASE, NO FULLY APPROVABLE PROGRAMS HAVE BEEN RECEIVED BY U.S. EPA. THESE REFERRALS ARE SUBMITTED IN RESPONSE TO A HEAD- QUARTERS INITIATIVE AGAINST MUNICIPALITIES THAT HAVE FAILED TO SUBMIT, BY THIS LATE DATE, APPROVABLE PROGRAMS. EACH OF THESE REPORTS IS QUITE SPECIFIC IN DETAILING THE DEFICIEN- CIES THAT RENDER THE PROGRAMS UNAPPROVABLE. THIS SPECIFI- CITY WAS INCLUDED AT THE REQUEST OF MEMBERS OF YOUR STAFF AND PERSONNEL FROM THE DEPARTMENT OF