EXCEL VIOLATED FEDERAL PRETREATMENT PROHIBITIONS UNDER 40 CFR 403 IN THAT EXCEL HAS DISCHARGED, AT NUMEROUS TIMES, EFFLUENT WITH A PH OF LESS THAT 5.0 STANDARD UNITS AND HAS CAUSED INTERFERENCE AND PASS THROUGH OF THE CITY OF FORT MORGAN'S WASTEWATER TREATMENT PLANT. IN ADDITION, EXCEL HAS VIOLATED ITS CONTROL MECHANISM WITH THE CITY. EXCEL OWNS AND OPERATES A SLAUGHTERHOUSE LOCATED IN FORT MORGAN AND IS AN INDUSTRIAL USER FOR THE CITY'S PUBLICALLY OWNED TREATMENT WORKS.