THIS ADMINISTRATIVE PENALTY COMPLAINT ALLEGES VIOLATIONS OF ALTOONA CITY AUTHORITY'S NPDES PERMIT NO. PA 027022 FOR THE WESTERLY WWTP, INCLUDING FAILURE TO SUBMIT TO EPA FOR APPROVAL THE AUTHORITY'S SAMPLING PLAN USED TO PERFORM CALCULATIONS IN DEVELOPING LOCAL LIMITS WITHIN THREE MONTHS OF PERMIT ISSUANCE, AND FAILURE TO SUBMIT LOCAL LIMITS BASED ON A HEADWORKS ANALYSIS OF ITS WWTP WITHIN ONE YEAR OF PERMIT ISSUANCE. THE PURPOSE OF THE COMPLAINT IS TO REQUIRE THE AUTHORITY TO SUBMIT THE REQUIRED ELEMENTS OF ITS PRETREATMENT PROGRAM AS DESCRIBED IN ITS PERMIT AND THE ASSESS PENALTIES FOR NONCOMPLIANCE.