THIS ADMINISTRATIVE PENALTY COMPLAINT ALLEGES VIOLATIONS OF ALTOONA CITY AUTHORITY'S NPDES PERMIT NO. PA 0027014 FOR THE EASTERLY WWTP, INCLUDING FAILURE TO SUBMIT TO EPA FOR APPROVAL THE AUTHORITY'S SAMPLING PLAN, USED TO PERFORM CALCULATIONS INVOLVED 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 TO ASSESS PENALTIES FOR NONCOMPLIANCE.