ON NUMEROUS OCCASIONS BETWEEN MARCH 31, 1994, AND MAY 31, 1998, SUN CHEMICAL'S DISCHARGES OF PROCESS WASTEWATER TO THE MUSKEGON OUNTY WASTEWATER MANAGEMENT SYSTEM (MUSKEGON POTW) VIOLATED THE ALTERNATIVE OCPSF CATEGORICAL LIMITS (40 CFR PART 414), INCLUDING THE LIMITS FOR THE FOLLOWING TOXIC POLLUTANTS: BENZENE, CHLOROBENZENE, CHLOROFORM, DI-N-BUTYL PHTHALATE, METHYLENE CLORIDE, AND TOLUENE. SUN CHEMICAL VIOLATED AN INFORMATION REQUEST ISSUED TO SUN ON FEBRUARY 17, 1997, PURSUANT TO SECTION 308 OF THE CWA BY (I) FAILING TO PROVIDE WATER BALANCE INFORMATION REQUIRED IN ITEM 2 OF THE 1997 SECTION 308 REQUEST FOR 16 MONTHS AFTER SUN CHEMICAL RECEIVED THE REQUEST, AND (II) FAILING TO PROVIDE SUFFICIENT SAMPLING AND ANALYSIS DATA (SELF-MONITOR- ING DATA), AS REQUIRED BY ITEM 8 OF THE 1997 SECTION 308 REQUEST, TO DEMONSTRATE COMPLIANCE WITH THE ALTERNATIVE OCPSF CATEGORICAL LIMITS FOR CYANIDE AND SOMETIMES OTHER POLLUTANTS IN EACH MONTHLY REPORTING PERIOD FROM APRIL 1997 THROUGH JUNE 1998. EPA SEEKS INJUNCTIVE RELIEF TO REQUIRE SUN CHEMICAL TO (I) INSTALL APPROPRIATE TREATMENT SYSTEMS, UPGRADE EXISTING TREATMENT SYSTEMS, OR TAKE OTHER STEPS TO ACHIEVE COMPLIANCE WITH THE APPLICABLE ALTERNATIVE OCPSF CATEGORICAL LIMITS, (II) DEMONSTRATE CONSISTENT COMPLIANCE FOR A REASONABLE PERIOD, AND (III) FULLY COMPLY WITH THE REQUIREMENT OF SELF- MONITORING IN ITEM 8 OF THE 1997 SEC