=> CHRYSLER'S NEWARK ASSEMBLY PLANT ASSEMBLES & STORES AUTOMOBILES PRIOR TO THEIR SHIPMENT TO DEALERS. THE ASSEMBLY PROCESS INCLUDES PHOSPHATING, WHICH IS AN ELECTROPLATING ACTIVITY. CHRYSLER'S NEWARK FACILITY IS AN INTEGRATED PLANT BECAUSE IT COMBINES ITS ELECTROPLATING & NON-ELECTROPLATING PROCESS WASTEWATER PRIOR TO TREATMENT. => CHRYSLER SENDS THE EFFLUENT FROM ITS NEWARK FACILITY TO THE NEWARK, DELAWARE PUBLICLY OWNED COLLECTION SYSTEM. AFTER COLLECTION, THE EFFLUENT IS SENT TO THE WILMINGTON, DE SEWAGE TREATMENT PLANT (STP) FOR TREATMENT & DISCHARGE INTO THE DELAWARE RIVER. HENCE, CHRYSLER'S NEWARK FACILITY IS SUBJECT TO EPA'S ELECTROPLATING PRETREATMENT REQUIREMENTS AT 40 C.F.R. PART 413. => A 09/20/84 LETTER FROM CHRYSLER INDICATES THAT ITS NEWARK DELAWARE PLANT WILL NOT ACHIEVE EPA'S ELECTROPLATING PRETREATMENT REQUIREMENTS FOR LEAD, ZINC, & TOTAL METALS UNTIL 07/15/85. THIS IS 13 MONTHS AFTER THE 06/30/84 DEADLINE REQUIRED BY 40 C.F.R. PART 413. => LEAD & ZINC ARE BOTH TOXIC POLLUTANTS AS DEFINED IN SECT.307(A) OF THE CWA, 33 U.S.C. SECT.1317(A). DISCHARGES OF THESE POLLUTANTS, COUPLED WITH THE POTENTIAL INABILITY OF WILMINGTON'S STP TO REMOVE THESE POLLUTANTS ON A CONSISTENT BASIS, POSES A THREAT TO THE ENVIRONMENT. A MORE DIRECT IMPACT IS THE THREAT POSED TO SLUDGE GENE