THE VIOLATIONS UPON WHICH THE ACTION IS BASED. THE DEF HAS VIOLATED THE CATEGORICAL PRETREATMENT STANDARDS SET FORTH AT 40 C.F.R. PART 412 & 433 & PRASA'S LOCAL LIMITS, AS ESTABLISHED UNDER ITS APPROVED PRETMT PROGRAM, BY FAIL- ING TO INSTALL & PROPERLY OPERATE PRETMT EQUIPMENT NECESSARY TO OBTAIN CONSISTENT COMPLIANCE. THE DEFENDANT HAS FAILED TO COMPLY WITH GENERAL PRETMT STANDARDS BY FAILING TO SUBMIT REQUIRED REPORTS, OR BY SUBMITTING INCOMPLETE REPORTS. THE REGION SEEKS A CIVIL PENALTY FOR PAST VIOLATIONS OF THE ACT AND A JUDICIAL ORDER THAT IMPOSES A COMPLIANCE SCHEDULE, THAT REQUIRES DIGITAL TO SUBMIT REQUIRED REPORTS AND ALSO PROVIDES FOR STIPULATED PENALTIES FOR FUTURE FAILURE TO COMPLY WITH THIS SCHEDULE. THE REGION MET WITH DIGITAL REPRESENTATIVES ON 01/21/88. DIGITAL PRESENTED A COMPLIANCE PLAN THAT ANTICIPATED FINAL COMPLIANCE BY 07/88. THE REGION INFORMED DIGITAL ITS INTENT TO INSTITUTE A CIVIL REFERRAL. PREVIOUSLY, ON 07/01/87, EPA HAD ISSUED AN ADMINISTRATIVE COMPLIANCE ORDER TO DIGITAL. AT THE PRESENT TIME, THERE IS NO REASON TO BELIEVE THERE ARE ANY ISSUES OF LEGAL OR FACTUAL SIGNIFICANCE. EPA REVIEWED SAMPLE ANALYSES AND RESULTS IN PERIODIC REPORTS SUBMITTED BY DIGITAL DURING 85-87, AND RESULTS IN MONITORING REPORTS SUBMITTED PURSUANT TO THE ORDER ISSUED IN JULY, 1987. THE RESULTS SHOWED CON- SISTENT VIOLATIONS OF THE CATEGORICAL PRETREATMENT STANDARDS AND LOCAL LIMITS. THIS CASE IS SIGN