THE EPA PROPOSED THE FILING OF A CIVIL ACTION FOR VIOLATION OF THE CWA SECTION 307D. SHEYENNE TOOLING HAS DISCHARGED ZINC TO THE CITY'S WASTEWATER TREATMENT SYSTEM IN VIOLATION OF THE NATIONAL CATEGORICAL PRETREATMENT STANDARDS ON 13 SEPARATE OCCASIONS, FAILED TO REPORT THREE OF THE ABOVE VIOLATIONS TO EPA WITIN 24 HRS, FAILED FOR A PERIOD OF APPROXIMATELY 5 YEARS TO SUBMIT ITS BASELINE MONITORING REPORT AND FAILED FOR A PERIOD OF 5 YEARS TO SAMPLE ITS DISCHARGE AND SUBMIT PERIODIC COMPLIANCE REPORTS. EPA PROPOSED A MINIMUM SETTLEMENT OF $300,000. THE REGION PROPOSED THAT SOME FLEXIBILITY BE WORKED INTO THE SETTLEMENT FOR THE POSSIBILITY OF SHEYENNE TOOLING TO ENGAGE IN SEPS TO OFFSET FOR GRAVITY.