EPA BEGAN ITS INVESTIGATION IN THIS CASE WHEN A FORMER EMPLOYEE REPORTED THAT TURBOCOMBUSTER TECHNOLOGY, INC. (TCT) WAS ILLEGALLY DISCHARGING LOW PH (ACIDIC) WASTEWATER INTO A PRESSURIZED SEWER MAIN LEADING TO MARTIN COUNTY'S PUBLICLY OWNED TREATMENT WORKS (POTW). TCT IS A WHOLLY-OWNED SUBSIDIARY OF CHROMALLY GAS TURBINE CORPORATION (CGTC) WHICH FABRICATES AND REWORKS AIRCRAFT AND ENGINE PARTS. PURSUANT TO THE SETTLEMENT IN PRINCIPLE, TCT HAS AGREED TO PAY THE MAXIMUM CIVIL PENALTY FOR EACH OF THE ALLEGED 9 PH VIOATIONS RECORDED BY THE ENVIRONMENTAL SERVICES DIVISION. TCT HAS AGREED TO PAY THE STATUTORY MAXIMUM PENALTY OF $200,000. THE USA INDICATES IN HIS REPORT THAT THIS $200,000 FIGURE IS SUBSTANTIALLY HIGHER THAN THE PENALTY CALCULATED AT $24,000 - $73,000 BASED ON THE EPA INTERIM CWA SETTLEMENT PENALTY POLICY. THE USA ALSO INDICATES THAT HTE COMPANY HAS ALREADY EXPENDED ABOUT $375,000 IN ENVIRONMENTAL AUDITS AND REMEMDIAL EQUIPMENT MEASURES. IN ADDITION, THE USA'S REPORT INDICATES THAT CONTINUING AUDIT, TRAINING AND REPORTING REQUIREMENTS OVER THE TERM OF THE SETTLEMENT IN PRINCIPLE WILL COST THE COMPANY AN ADDITIONAL $150,000 OVER A PERIOD OF THREE YEARS. THE REGION HAS BEEN PROVIDED LIMITED INFORMATION REGARDING THE VIOLATIONS AND THE SUBSEQUENT REMEDIAL MEASURES WHICH DOES NOT ALLOW FOR AN INDEPENDENT ASSESSMENT OF THE APPROPRIATENESS OF THE PENALTY AMOUNT. HOWEVER, BOTH WMD AND ORC A