THIS ACTION IS BASED UPON THE VIOLATIONS OF EFFLUENT LIMITATIONS AND CONDITIONS IN SECTION 402 NPDES PERMIT AS EVIDENCED BY DISCHARGE MONITORING REPORTS (DMRS) SUBMITTED BY SYNTEX. VIOLATIONS OF TERMS AND CONDITIONS (INTERIM EFFLUENT LIMITS) IN SECTION 309(A) ADMINISTRATIVE ORDER ISSUED TO SYNTEX. THE PROPOSED INJUNCTIVE RELIEF SOUGHT IS AN INJUNCTION DIRECTING SYNTEX TO EITHER DIVERT PROCESS WATER DISCHARGE TO POTW, OR TO MAINTAIN 'GOOD HOUSEKEEPING PRACTICES' AND INSTALL THE NECESSARY TREATMENT EQUIPMENT REFLECTING 'BEST CONVENTIONAL CONTROL TECHNOLOGY' TO MEET EFFLUENT LIMITS IN ITS NPDES PERMIT. PROPOSED AMOUNT OF SETTLEMENT PENALTY: $308,000.