BACKGROUND: THE LITIGATION REPORT DOCUMENTS KOPPERS' VIOLATIONS OF THE PRETREATMENT REQUIREMENTS FOR IRON AND STEEL MANUFAC- TURERS. IN PARTICULAR, KOPPERS HAS SUBSTANTIALLY EXCEEDED THE DISCHARGE LIMITS TO THE LOCAL PUBLICLY OWNED TREATMENT WORKS FOR AMMONIA, PHENOL, AND CYANIDE SINCE JULY 10, 1985, FINAL COMPLIANCE DATE. 40 CFR SECTION 420.15(A). AGGRES- SIVE ENFORCEMENT OF PRETREATMENT VIOLATIONS IS PART OF THE NATIONAL PROGRAM'S STATED STRATEGY. REGION V RECOMMENDS THE FILING OF A CIVIL ACTION AGAINST KOPPERS SEEKING BOTH INJUNCTIVE RELIEF AND THE ASSESSMENT OF CIVIL PENALTIES. ************************************************************ ************ THIS CASE SHOULD BE FILED AS A CIVIL CONTEMPT ACTION. TOLEDO COKE CORPORATION HAS VIOLATED THE CWA CONSENT DECREE ENTERED BY THE U.S. DISTRICT COURT FOR THE NORTHERN DISTRICT OF OHIO ON 3/28/90. SPECIFICALLY, TOLEDO COKE WAS REQUIRED TO COMPLY WITH CERTAIN EFFLUENT LIMITATIONS. TOLEDO COKE VIOLATED VARIOUS POLLUTANT EFFLUENT LIMITATIONS FROM THE TIME THE DECREE WAS ENTERED AND THUS HAS INCURRED STIPULATED PENALTIES. THE U.S. SHOULD SEEK AN ORDER OF THE COURT, REQUIRING TOLEDO COKE TO COMPLY WITH THE TERM SOF THE CONSENT DECREE AND THE PAYMENT OF STIPULATED PENALTIE