THIS CWA REFERRAL IS BASED ON NOR-AM CHEMICAL'S COMPANY'S VIOLATIONS OF THE APPLICABLE PRETREATMENT DISCHARGE LIMITS FOR TOLUENE AND CHLOROFORM. SECTION 307(D) OF THE ACT, 33 USC SECTION 1317(D), PROVIDES THAT IT SHALL BE UNLAWFUL FOR ANY OWNER OR OPERATOR OF ANY SOURCE TO OPERATE IN VIOLATION OF ANY PRETREATMENT STANDARD AFTER THE COMPLIANCE DATE OF THE STANDARD. PRETREATMENT PROGRAMS ARE DESIGNED TO PROTECT MUNICIPAL WASTEWATER TREATMENT PLANTS, THEIR COLLECTION SYSTEMS, AND THE WATERS OF THE U.S. FROM ADVERSE IMPACTS THAT MAY OCCUR WHEN NON-DOMESTIC POLLUTANTS ARE DISCHARED INTO A SEWAGE SYSTEM. - NOR-AM OWNS AND OPERATES A MANUFACTURING FACILITY IN MUSKEON, MI WHERE IT PRODUCES PYROGALLOL, 2,2-DIMETHOXYPROPANE, AND 2,3-ISOPROPYLIDENEDIOXYPHENOL (NC-7312) WHICH ARE ULTIMATELY USED IN THE PRODUCTION OF PESTICIDE BASED PRODUCTS. THE PYROGALLOL PRODUCTION PROCESS PRODUCES NOR-AM'S REGULATED WASTESTREAM. NOR-AM DISCHARGES ITS PRETREATED AND NON-PRETREATED INDUSTRIAL WASTES AND PROCESS WASTEWATER TO A PUBLICLY OWNED TREATMENT WORKS (POTW), THE MUSKEGON COUNTY WASTEWATER MANAGEMENT SYSTEM I (MCWMS). - THE PRETREATMENT STANDARDS FOR THE 2 POLLUTANTS AT ISS ARE CONTAINED IN THE CATEGORICAL PRETREA