U.S. EPA, REGION V RECOMMENDS THE FILLING OF A CIVIL ACTION AGAINST THE WHITEHALL LEATHER COMPANY (WLC) SEEKING THE IMPOSITION OF A SUITABLE CIVIL PENALTY AND INJUNCTIVE RELIEF FOR THE INTRODUCTION OF POLLUTANTS TO A PUBLICLY OWNED TREATMENT WORKS (POTW) OPERATED BY THE MUSKEGON COUNTY WASTEWATER MANAGEMENT SYSTEM (MUSKEGON COUNTY WWMS), IN EXCESS OF THAT ALLOWED UNDER APPLICABLE PRETREATMENT STANDARDS, IN VIOLATION OF THE CLEAN WATER ACT (THE ACT). SECTION 307 (D) OF THE ACT, 33 U.S.C. 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 UNITED STATES FROM ADVERSE IMPACTS THAT MAY OCCUR WHEN NON-DOMESTIC POLLUTANTS ARE DISCHARGED INTO A SEWAGE SYSTEM. AS EXPLAINED IN GREATER DETAIL WITHIN, WLC OPERATES A LEATHER TANNING AND FINISHING PLANT IN WHITEHALL. MICHIGAN. WLC IS IN VIOLATION OF THE APPLICABEL CATEGORICAL LIMITATIONS FOR THE LEATHER TANNING INDUSTRY, SPECIFIED AT 40 CFR 425. AS AN EXISTING INDUSTRIAL USER, THE CATEGORICAL LIMITATIONS APPLICABLE TO WLC ARE SULFIDE, TOTAL CHROMIUM, AND PH (40 CFR 425.15). THIS REFERRAL DOES NOT SEEK THE ENFORCEMENT OF ANY LOCAL LIMITS, SINCE THE