AN INSPECTION REVEALED THAT THE RESPONDENT FAILED TO SUB- MIT A BMR FROM 9/1/83-5/13/93, FAILED TO SUBMIT A 90-DAY COMPLIANCE REPORT FROM 2/28/84-4/28/93, FAILED TO SUBMIT PERIODIC COMPLIANCE REPORTS FROM 6/30/84-4/28/93 AND FAILED TO COMPLY WITH CATEGORICAL PRETREATMENT STANDARDS. A FEDER- AL PENALTY OF $40,000 WAS PROPOSED.