SUMMARY GMC OWNS AND OPERATES THIS AUTOMOBILE MANUFATURING PLANT, WHICH IS INVOLVED IN ELECTROPLATING AND METAL FINISHING AS PART OF THE MANUFACTURING PROCESS. THE FACILITY DISCHARGES INTO A POTW AND IS THEREFORE REQUIRED TO MEET ALL PRETREAT- MENT STANDARDS OF SECT. 307 OF THE CLEAN WATER ACT. GMC NOTIFIED REGION VI THROUGH BASELINE MONITORING REPORTS THAT IT WOULD NOT COMPLY WITH THE ELECTROPLATING CATEGORICAL PRE- TREATMENT STANDARDS BY JULY 1,1984. IT ANTICIPATES COMPLIAN CE IN APPROX. 14 MONTHS, DURING WHICH TIME THE COMPANY IN- TENDS TO CONSTRUCT EXTENSIVE PRETREATMENT FACILITIES. HAD GMC INITIATED ITS COMPLIANCE PROGRAM IN JULY 1982 WHEN THE THIRD CIRCUIT MADE ITS RULING, AND HAD IT EARNESTLY PURSUED A COMPLIANCE SCHEDULE, IT WOULD HAVE BEEN ABLE TO MEET THE JULY 1984 DEADLINE FOR ELECTROPLATING STANDARDS. EPA REG. 6 RECORDS INDICATE THAT GMC DID NOT BEGIN PRELIMINARY ENGIN- EERING WORK UNTIL 10/83. DUE TO THE COMPANY'S DELAYED COMP- LIANCE, IT IS ANTICIPATED THAT THE LEAD, NICKLE, ZINC AND AND TOTAL TOXIC PARAMETERS OF THE ELECTROPLATING AND METAL FINISHING STANDARDS WILL BE VIOLATED. THIS REFERRAL IS RECOMMENDED AS A CLASS 1 ACTION. THE CASE IS OF NATIONAL SIGNIFICANCE SINCE IT IS BUT ONE OF 18 GMC PLANTS ACROSS THE COUNTRY THAT WILL FAIL TO MEET PRETREATMEN T STANDARDS BY 7/1/84. THE REGION IS RECOMMENDING A CONSENT DECREE ASSESSING A CIVIL PENALTY IN TH