THE DEFENDANT IN THE PROPOSED CIVIL ACTION IS SUPERIOR CHROME PLATING COMPANY. SUPERIOR OWNS AND OPERATES AN ELECTR OPLATING FACILITY LOCATED IN COMPTON, CA. THE FACILITY DIS- CHARGES PROCESS WASTEWATER INTO THE JOINT WATER POLLUTION CONTROL PLANT (JWPCP) OWNED AND OPERATED BY THE LOS ANGELES COUNTY SANITATION DISTRICTS (LACSD) WHERE IT IS TREATED PRIOR TO BEING DISCHARGED INTO THE PACIFIC OCEAN. SUPERIOR IS NOT REQUIRED TO OBTAIN AN NPDES (NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM) PERMIT FOR ATHE PLANT BECAUSE IT DISCHARGES INTO A PUBLICLY OWNED TREATMENT WORKS (POTW). AS AN INDUSTRY WHICH DISCHARGES INTO A POTW, SUPERIOR IS REQUIRED TO COMPLY WITH THE PRETREATMENT REQUIREMENTS OF SEC 307 OF THE CWA, 33 U.S.C. 1317. THE BASELINE MONITORING REPORT (BMR) SUPERIOR SUBMITTED TO LACSD INDICATES THAT SUPERIOR IS DISCHARGING HEAVY METALS INTO THE JWPCP IN EXCESS OF THE PRETREATMENT STANDARDS FOR E EXISTING ELECTROPLATING FACILITIES. 40 C.F.R. 413. CHEMI- CAL ANALYSES PERFORMED ON SUPERIOR'S DISCHARGE CONFIRMED THE OCCURRENCE OF EFFLUENT VIOLATIONS FOR CADMIUM, CHROMIUM, ZINC, AND CYANIDE. THE MOST FLAGRANT VIOLATIONS WERE FOR THE DISCHARGE OF CONSISTENTLY HIGH LEVELS OF CADMIUM AND CYANIDE THE DEADLINE FOR ACHIEVING FINAL COMPLIANCE WITH THE PRETREA TMENT STANDARDS WAS 04/27/84. IN ITS BMR, SUPERIOR INITIALLY PROJECTED IT WOULD NOT ACHIEVE FINAL COMPLIANCE UNTIL 04/19 85. AT A 06/21/85 MEETING WITH LACSD, A S