THIS REFERRAL IS A CIVIL JUDICIAL ACTION IN THE U S DISTRICT COURT FOR THE DISTRICT OF ALASKA AGAINST KETCHIKAN PULP COMPANY (KPC), WHICH OWNS AND OPERATES A PULP MILL IN KETCHIKAN, AK. THE SUIT SEEKS INJUNCTIVE RELIEF AND CIVIL PENALTIES UNDER SECTION 309 OF THE CWA, 33 USC, 1251 ET SEQ, FOR VIOLATIONS OF SECTION 301 OF THE ACT. KPC HAS VIOLATED BOTH THE TERMS OF AN NPDES PERMIT INCORPORATING NATIONAL EFFLUENT GUIDELINES FOR THE PULP INDUSTRY AND THE TERMS OF AN ADMINISTRATIVE CONSENT ORDER. EPA IS SEEKING CIVIL PENALTIES FOR KPC'S PAST VIOLATIONS IN AN AMOUNT EQUAL TO THE BENEFITS OF DELAYED COMPLIANCE. EPA ALSO SEEKS TO HAVE THE COURT ISSUE A CONSENT DECREE TO KPC WHICH WOULD ESTABLISH A REVISED COMPLIANCE SCHEDULE AND STIPULATED PENALTIES FOR FUTURE VIOLATIONS.