The City of Batavia has failed to fully implement its approved Industrial Pretreatment Program (IPP) by failed to inspect each Significant Industrial User (SIU) once per year, by failing to implement its Enforcement Response Plan (ERP), and by failing to make certain inspection records available for review. This APO seeks a monetary penalty. A companion AO (CWA-02-2003-3072 is issued to require the City of Batavia to a) inspect each SIU by 9/30/03 ( (the end of the City's IPP year), to implement its ERP, and to provide evidence that missing inspection records are placed in SIU files.