SYNOPSIS: STANDARD PLATING CO., INC. OPERATES A PLATING SHOP IN W. SPRINGFIELD, MA. IT DISCHARGES UNTREATRED POLLU- TANTS (ELECTROPATING WASTES) INTO THE CONNECTICUT RIVER. STANDARD HAS NO NPDES PERMIT FOR ITS DISCHARGE, AND HAS NEVER MADE APPLICATION FOR SUCH A PERMIT. THE DISCHARGE IS LESS THAN 30,000 GPD AND CONTAINS HEAVY METALS AND TOXIC POLLUTANTS. STANDARD'S PERMIT APPLICATION IS EXPECTED TO BE FILED SOON. STANDARD WILL NEED TO INSTALL TREATMENT TO COMPLY W/ THE TECHNOLOGY-BASED PERMIT LIMITS APPLICABLE TO THE ELEC- TROPLATING INDUSTRY. SECTION 301(A) OF THE CWA, 33 U.S.C. SECT. 1311(A), PROHIBITS THE DISCHARGE OF POLLUTANTS INTO NAVIGABLE WATERS OF THE U.S., EXCEPT IN COMPLIANCE W/THE TERMS & CONDITIONS OF AN NPDES PERMIT ISSUED PURSUANT TO SECT. 402(A) OF THE ACT, 33 U.S.C. SECT. 1342(A). SECT. 309(D), 33 U.S.C. SECT. 1319(D), AUTHORIZES THE ADMINISTRATOR TO SEEK A CIVIL PENAL- TY, NOT TO EXCEED $10,000/DAY OF VIOLATION OF SECT. 301. A CIVIL ACTION FOR PENALTIES IS NECESSARY, RATHER THAN SIMPLY ISSUING A PERMIT WHICH WOULD REQUIRE STANDARD TO IN- STALL TREATMENT, SO AS TO ESTABLISH THAT THE PERMIT REQUIRE- MENT MUST NOT BE TAKEN LIGHTLY. THE GOVT. SHOULD SEEK THE IMPOSITION OF A CIVIL PENALTY IN THE AMOUNT OF THE COST SAV- INGS ENJOYED BY STANDARD BY REASON OF ITS FAILURE TO INSTALL TREATMENT, PLUS A PUNITIVE AMOUNT.