THIS IS A PROPOSED ACTION AGAINST ZERO CORPORATION UNDER SECTION 307 OF CLEAN WATER ACT FOR VIOLATIONS OF EPA'S PRETREATMENT STANDARDS AND FOR VIOLATIONS OF EPA'S REPORTING REQUIREMENTS. ZERO OPERATES A MANUFACTURING BUSINESS IN BURBANK, CALIF. WHERE IT MAKES PROTECTIVE CASING FOR MILITARY EQUIPMENT. AT THIS FACILITY, ZERO ENGAGES IN METAL FINISHING OPERATIONS ZERO DISCHARGES ITS INDUSTRIAL WASTEWATER TO THE BURBANK AND LOS ANGELES SEWAGE SYSTEMS, AND SO IS SUBJECT TO THE METAL FINISHING PRETREATMENT STANDARDS SET OUT AT 40 C.F.R 433.15. ZERO HAS CONSISTENTLY VIOLATED THESE PRETREATMENT STANDARDS SINCE AUGUST 1986. ZERO HAS ALSO VIOLATED REGULATIONS REQUIRING IT TO MONITOR AND REPORT THE CHARACTER OF ITS WASTEWATER. EPA CONDUCTED A COMPLIANCE INSPECTION OF ZERO IN FEBRUARY, 1990. ON JUNE 1, 1990, EPA ISSUED ZERO AN ADMINISTRATIVE ORDER REQUIRING ZERO TO COMPLY WITH APPLICABLE PRETREATMENT REQUIREMENTS. ZERO IS CURRENTLY IN COMPLIANCE WITH PRETREATMENT REQUIREMENTS ACCORDING TO ITS REPORTS. THIS ACTION IS PROPOSED TO COLLECT AN APPROPRIATE CIVIL PENALTY FOR ZERO'S PAST VIOLATIONS, AND TO ENSURE ZERO CONTINUES TO COMPLY.