CERRO COPPER PRODUCTS CO. ( CERRO ) OF EAST ST. LOUIS, IL, OPERATES A COPPER PROCESSING FACILITY IN SAUGET, IL. THE FACILITY DISCHARGES APPROXIMATELY ONE MILLION GALLONS OF WASTEWATER PER DAY TO THE SAUGET PHYSICAL/CHEMICAL PLANT ( P/C PLANT ), A PUBLICLY OWNED TREATMENT WORKS ( POTW ). SECTION 307 OF THE CLEAN WATER ACT ( CWA ), 42 USC S1317, IS DESIGNED TO PREVENT INDIRECT DISCHARGES, SUCH AS CERRO, FROM DISCHARGING TOXIC POLLUTANTS INTO A POTW IF SUCH POLLU- TANTS WILL EITHER INTERFERE WITH THE PROPER FUNCTIONING OF, OR PASS THROUGH, THE POTW. PURSUANT TO SECT 307 OF THE CWA, THE ADMINISTRATOR PROMULGATED THE GENERAL PRETREATMENT REGU- LATIONS WHICH, INTER ALIA, IMPOSE REPORTING REQUIREMENTS ON SUBJECT FACILITIES. THE ADMINISTRATOR ALSO PROMULGATED THE NAT'L CATEGORICAL PRETREATMENT STANDARDS ( NCPSS ), WHICH SET EFFLUENT LIMITATIONS FOR CATEGORIES OF INDUSTRIES WHICH DISCHARGE INTO A POTW. CERRO HAS VIOLATED BOTH SETS OF REGULATIONS, AS WELL AS AN ADMINISTRATIVE ORDER WHICH REQUIRED COMPLIANCE WITH THE GENE RAL PRETREATMENT REGULATIONS. FIRST, CERRO FAILED TO PRO- VIDE THE USEPA WITH TIMELY AND COMPLETE INFORMATION, AS RE- QUIRED BY THE GENERAL PRETREATMENT REGULATIONS; MOST NOTABLY CERRO HAS NOT, YET, SUBMITTED A COMPLIANCE SCHEDULE. IN ADDITION, CERRO HAS VIOLATED AN ADMINISTRATIVE ORDER WHICH REQUIRED CERRO TO SUBMIT THE INFORMATION REQUIRED BY THE GE- NERAL PRETREATMENT REGULATIONS. FINAL