REPSONDENT FAILED TO COMPLY WITH PERMIT REQUIREMENTS WHICH REQIRE IT TO DEVELOP SPECIFIC LOCAL LIMITS IN ACCORDANCE WITH 40 CFR 403.5. APO ISSUED, ASSESSING A PENALTY OF $80,000 AGAINST PRASA, FOR VIOLATING THE INDUSTRIAL PRETREATMENT PROGRAM (IPP) IMPLEMENTATION REQUIREMENTS BY FAILING TO COMPLETE A TECHNICAL EVALUATION OF LOCAL LIMITS AND TO HAVE IN PLACE IN INDUSTRIAL USER FINAL PERMITS TECHNICALLY SOUND AND DEFENSIBLE LOCAL LIMITS BY THE REQUIRED DEADLINES FOR THE SEVEN FACILITIES. PRASA IS RESPONSIBLE FOR THE DEVELOPMENT OF LOCAL LIMITS TO ENSURE THAT INDUSTRIAL DISCHARES WILL NOT CAUSE PASS THROUGH OR INTERFERENCE. IN ACCRDANCE WITH 40 CFR 122.21(J)(4), LOCAL LIMITS MUST BE RE-EVALUATED DUR- ING THE NPDES PERMIT RENEWAL PROCESSES. PRASA HAS FAILED TO DO SO FOR THE SEVEN FACILITIES.