THE DEFENDANT HAS VIOLATED ITS NPDES PERMITS AND FAILED TO PROPERLY IMPLEMENT ITS INDUSTRIAL PRETREATMENT PROGRAM. THE PROPOSED RELIEF SOUGHT INCLUDES A CIVIL PENALTY & ORDER REQUIRING DEFENDANT TO ACTIVELY IMPLEMENT & ENFORCE ITS PRETREATMENT PROGRAM. THIS CASE IS PART OF A LARGER EFFORT BY EPA TO ENFORCE IMPLEMENTATION OF INDUSTRIAL PRE- TREATMENT PROGRAMS BY POTWS.