00NICIPAL WWTP LAND APPLICATION OF SEWAGE SLUDGE WITH EXCESSIVE CADMIUM CONCENTRATIONS, PLUS ANALYTICAL AND CERTIFICATION VIOLATIONS. BACKGROUND: ON SEPTEMBER 30, 1997, REGION 5 FILED A COM- PLAINT AGAINST PIQUA ALLEGING VIOLATIONS OF SECTION 504 OF THE CWA, 33 U.S.C. 1345, AND THE CWA SLUDGE REGULATIONS AT 40 C.F.R. PART 503. THE REGION SOUGHT A TOTAL CIVIL PENALTY OF $36,000 FOR THE ALLEGED VIOLATIONS. IN THE FOUR-COUNT COMPLAINT, U.S. EPA ALLEGED THAT PIQUA VIOLATED THE ACT BY FAILING TO: MEET CEILING CONCENTRATION LIMITATIONS FOR CADMIUM IN LAND-APPLIED SEWAGE SLUDGE, 40 C.F.R. 503.13(A) (1); SUBMIT CERTIFICATION STATEMENTS FOR CALENDAR YEARS 1994 AND 1995 TO U.S. EPA 40 C.F.R. 503.18; AND UTILIZE U.S. EPA-APPROVED TEST METHODS TO ANALYZE ITS SLUDGE FOR INORGANIC POLLUTANTS, 40 C.F.R. 503.8. ON APRIL 21, 1998, PIQUA SUBMITTED THE REQUIRED CERTIFICATION STATEMENT TO COMPLY WITH CERTIFICATION STATEMENT REQUIREMENT (40 CFR 503.18).