FAILURE TO IMPLEMENT AN APPROVED PRETREATMENT PROGRAM. 3 PROPOSED DEFENDANTS.
Suffolk failed to implement its pretreatment program as approved by failing to: 1) identify categorical industrial users, 2) issue adeqaute control mechanisms, 3) verify compliance with applicable pretreatment standards, and 4) have adequate resource for carrying program activities. Suffolk will be required to correct the pretreatment program violations by, among other things, conducting required sampling and inspections, issuing appropriate control mechanisms and develop appropriate local limits for its POTWs.