SYNOPSIS: THIS CIVIL ACTION WAS INITIATED TO OBTAIN INJUNCTIVE RELIEF & PENALTIES UNDER SECT 309(B) & (D) OF THE CWA, 33 U.S.C. SECT. 1319(B),(D), AGAINST DEF FOR VIOLATIONS OF PRE- TREATMENT STDS TO WHICH THE CORP. IS SUBJ AS AN INDUSTRIAL USER OF A POTW. LFE OPERATES AN ELECTROPLATING FACILITY IN CLINTON, MA. APPROX. 20,000 GPD OF INDUSTRIAL WSTEWTRS ARE DISCHARGED FROM LFE'S FACILITY INTO PUBLIC SEWERS LEADING INTO THE POTW IN CLINTON, MA AND OPERATED BY THE WATER DIVISION OF THE MDC. MDC-CLINTON OPERATES UNDER AN NPDES PERMIT. HIGH CONCENTRATIONS OF CU & PB IN LFE'S DISCHARGE VIO- LATE THE ELECTROPLATING NAT'L CATEGORICAL STDS TO WHICH LFE IS SUBJ UNDER THE ACT. THE LOW PH OF THE DISCHARGE VIOLATES THE SPECIFIC PROHIBITIONS OF THE NATIONAL PROHIBITED DISCH. STDS. IN ADDN, LFE HAS FAILED TO COMPLY W/THE MONITORING & REPORTING REQUIREMENTS OF THE GENERAL PRETREATMENT REGS. REG I BELIEVES THAT A CIVIL ACTION IS APPROPRIATE BOTH TO ENSURE THAT LFE COMES INTO COMPLIANCE W/PRETREATMENT STDS BY INSTALLING ADEQUATE TRMT ON A RAPID SCHEDULE & TO EMPHA- SIZE THE SERIOUSNESS W/WHICH EPA VIEWS SUCH VIOLATIONS SO THAT OTHER COMPANIES WILL BE ENCOURAGED TO COMPLY W/PRETRMT REGS. DEFENDANT: LFE CORPORATION IS A PUBLIC CORP