THE DEFENDANT HAS VIOLATED ITS NEW JERSEY POLLUTANT DIS- CHARGE ELIMINATION SYSTEMS (NJPDES) PERMIT BY FAILING TO PROPERLY IMPLEMENT ITS INDUSTRIAL PRETREATMENT PROGRAM. PROPOSED RELIEF TO BE SOUGHT: A JUDICIAL ORDER DIRECTING ELSA TO COMPLY WITH ITS PERMIT REQUIREMENTS AND CONDITIONS, AND THE IMPLEMENTATION OF A CIVIL PENALTY. THIS CASE IS IMPORTANT BECAUSE IT IS PART OF A LARGER EFFORT BY THE EPA TO ENFORCE IMPLEMENTATION OF INDUSTRIAL PRETREATMENT PROGRAMS BY POTWS.