STATUTORY BASIS THE STATUTES AND REGULATIONS WHICH ARE THE BASIS FOR THE PROPOSED ACTION ARE 33 U.S.C. SECTIONS 1317 AND 1319 AND 40 C.F.R. PARTS 403, 413, AND 433. DEFENDANT LTV STEEL TUBULAR PRODUCTS COMPANY 965 WANDA AVENUE FERNDALE, MICHIGAN 48220 VIOLATIONS 33 U.S.C. SECTION 1317 AND 40 C.F.R. SECTIONS 413 AND 433, DISCHARGING TO A PUBLICLY OWNED TREATMENT WORKS (POTW) IN VIOLATION OF THE PRETREATMENT LIMITS FOR ZINC. 33 U.S.C. SECTION 1317 AND 40 C.F.R. SECTION 403.12(B) (7), FAILURE TO SUBMIT A COMPLIANCE SCHEDULE. RELIEF SOUGHT U.S. EPA, REGION V, SEEKS INJUNCTIVE RELIEF WHICH WOULD PROVIDE FOR EXPEDITIOUS ATTAINMENT OF THE PRETREATMENT LIMITS FOR ZINC. IN ADDITION, THE RELIEF SOUGHT INCLUDES A PENALTY OF $10,000 PER DAY FOR THE NON-COMPLYING DISCHARGE. CONTACTS WITH THE DEFENDANT U.S. EPA HAS MET WITH LTV STEEL TUBULAR PRODUCTS COMPANY REPRESENTATIVES TO DISCUSS THE CONCEPTUAL ISSUES OF A CONSENT DECREE. THE LAST MEETING WAS ON JAN. 23, 1986. PRECEDENT NONE.