THE PERMITTEE, CITY OF DUNKIRK HAS VIOLATED THE TERMS OF ITS NPDES PERMIT REQUIRING THE ATTAINMENT OF SECONDARY TREATMENT. THE CITY OF DUNKIRK HAS ALSO FAILED TO IMPLE- MENT AND ENFORCE ITS PRETREATMENT PROGRAM APPROVED BY EPA IN AUGUST 1984. DEFENDANT AL TECH IS A MANUFACTURING FACILITY WITH OPERAT- IONS IN THE IRON AND STEEL MANUFACTURING AND METAL FINISHING CATOGORIES. AL TECH HAS CONTINUALLY DISCHARGED WASTES INTO THE DUNKIRK POTW WHICH ARE HIGH IN NITROGEN COMPOUNDS. THESE COMPOUNDS HAVE INTERFERED WITH POTW OPERATIONS AND ARE A CAUSE OF PERMIT VIOLATION. THE REGION SEEKS INJUNCTIVE RELIEF AGAINST DUNKIRK TO CEASE VIOLATIONS OF ITS NPDES PERMIT BY TAKING ALL ACTIONS NECESSARY TO ENFORCE ITS PRETREATMENT PROGRAM AS WELL AS TO ENHANCE OPERATION AND MAINTENANCE OR INSTALL ADDITIONAL EQUIPMENT TO IMPROVE PERFORMANCE AT ITS POTW. THE REGION FURTHER SEEKS AN IMMEDIATE SEWER CONNECTION BAN TO PREVENT FURTHER ENVIRONMENTAL DEGRADATION PENDING DUNKIRK'S ATTAIN- MENT OF COMPLIANCE WITH ITS NPDES PERMIT. INJUNCTIVE RELIEF IS SOUGHT AGAINST AL TECH TO COMPEL TERMINATION OF DISCHARGE OF WASTES WHICH INTERFERE WITH POTW PROCESSES. CIVIL PENALTIES ARE SOUGHT AGAINST BOTH DUNKIRK AND ALTECH WITH BOTTOM LINE SETTLEMENT FIGURE PROPOSALS OF $150,000 $115,000, RESPECTIVELY. THE REGION ISSUED AN ADMINISTRATIVE