1. SECTION 309(B) OF THE CLEAN WATER ACT ( CWA ), 33 U.S.C. SECTION 1319(B). 2. S. B. FOOT TANNING CO., A MINNESOTA CORPORATION HIGHWAY 287 CACTUS, MOORE COUNTY, TEXAS 79013 3. S. B. FOOT IS A CATEGORICAL INDUSTRIAL USER IN THE LEA- THER TANNING AND FINISHING POINT SOURCE CATEGORY AND THROUGH-THE-BLUE SUBCATEGORY AND AS SUCH, IS REQUIRED TO COMPLY WITH THE CATEGORICAL PRETREATMENT STANDARDS FOR SULFIDE, TOTAL CHROMIUM AND PH. IN ADDITION, THE FACILITY IS REQUIRED TO COMPLY WITH THE REPORTING REQUIREMENTS ESTABLISHED FOR INDUSTRIAL USERS, INCLUDING THE REQUIRE- MENTS TO SUBMIT A BASELINE REPORT (BMR) WITHIN 180 DAYS OF THE EFFECTIVE DATE OF THE CATEGORICAL PRETREATMENT STANDARDS, A REPORT ON COMPLIANCE WITH THE CATEGROICAL PRETREATMENT STANDARDS WITHIN 90 DAYS OF THE FINAL DATE FOR COMPLIANCE WITH THE CATEGORICAL PRETREATMENT STAND- ARDS, AND PERIODIC REPORTS ON CONTINUED COMPLIANCE IN JUNE AND DECEMBER OF EACH YEAR. S. B. FOOT HAS VIOLATED SECTION 307(D) OF THE CWA BY FAILING TO COMPLY WITH THE CATEGORICAL PRETREATMENT STAN- DARDS FOR SULFIDE, CHROMIUM AND PH. THE RESPONDENT WAS ALSO IN VIOLATION OF SECTION 308(A) OF THE CWA BY FAILING TO SUBMIT A COMPLIANCE REPORT WITHIN 90 DAYS OF NOV. 25, 1985, THE COMPLIANCE DATE OF PRET