OKLAHOMA ORDNANCE WORKS AUTHORITY (OOWA) IS A PUBLIC TRUST WHICH OPERATES A PUBLICLY OWNED TREATMENT WORKS (POTW) LOCATED IN AN INDUSTRIAL PARK COMMONLY KNOWN AS THE MID-AMERICA INDUSTRIAL DISTRICT IN PRYOR, OKLAHOMA. THIS ACTION IS BROUGHT AGAINST OOWA FOR EFFLUENT VIOLATIONS FROM JANUARY 1986 TO MARCH 1991; FAILURE TO SUBMIT A PERMIT APPLICATION 180 DAYS PRIOR TO THE EXPIRATION DATE OFO THE EFFECTIVE PERMIT; FAILURE TO DEVELOP AND COMPLETE IMPLEMENTATION OF A PRETREATMENT PROGRA; AND, FAILURE TO COMPLETE REVISION AND ISSUANCE OF INDUSTRIAL USER CONTRACTS AS REQUIRED. DEFENDANT'S EFFLUENT VIOLATIONS INCLUDE THE POLLUTANTS EXCEEDANCE OF THE PARAMETERS FOR BIOCHEMICAL OXYGEN DEMAND AND TOTAL SUSPENDED SOLIDS. DURING NOVEMBER 1990, THE EPA RECEIVED A CITIZEN COMPLAINT CONCERNING THE DISCHARGE OF TOXIC ORGANICS AND METALS INTO THE CHOUTEAU CREEK AND NEOSHO RIVER FROM THE OOWA WASTEWATER TREATMENT PLANTS. ON DECEMBER 12, 1990, EPA PERFORMED A JOINT COMPLIANCE INSPECTION, ALL AREAS EVALUATED WERE UNSATISFACTORY (PERMIT, RECORDS/REPORTS, FACILITY SITE REVIEW, FLOW MEASUREMENT, LABORATORY, EFFLUENT, COMPLIANCE SCHEDULE, SELF-MONITORING, O&M, AND SLUDGE). IN ADDITION, IT WAS DISCOVERED THAT THE DEFENDANT FAILED TO DEVELOP AND IMPLEMENT AN INDUSTRIAL PRETREATMENT PROGRAM, AND ISSUE REVISED INDUSTRIAL USER CONTRACT