STATUTE AND REGULATIONS CLEAN WATER ACT SECTIONS 307 AND 309, 33 U.S.C. SECTION 1317 AND SECTION 1319 40 C.F.R. SECTIONS 403.12, 413.64 AND 433.15. DEFENDANT MODINE MANUFACTURING COMPANY 415 BIERLEY ROAD PEMBERVILLE, OH 43450 VIOLATIONS DISCHARGING TOXIC POLLUTANTS IN EXCESS OF STANDARDS SET FORTH IN 40 C.F.R. SECTIONS 413.64 AND 433.15, THEREBY, VIOLATING SECTION 307(B) OF THE CLEAN WATER ACT, 33 U.S.C. SECTION 1317(B). PROPOSED RELIEF (A) JUDICIALLY ENFORCEABLE COMPLIANCE SCHEDULE WITH MILESTONE DEADLINES FOR STEPS REQUIRED TO UPGRADE OR REPLACE EXISTING WASTESTREAM TREATMENT TO COME INTO COMPLIANCE WITH THE APPLICABLE PRETREATMENT STANDARDS (B) A CIVIL PENALTY OF $500,000. CONTACTS WITH DEFENDANT NOVEMBER 8, 1985, CONFERENCE AT EPA HEADQUARTERS, DECEMBER 31, 1985, SECTION 308 REQUEST FOR INFORMATION AND JANUARY 30, 1986, MODINE SECTION 308 RESPONSE. PRECEDENTIAL LEGAL ISSUES EARLY ENFORCEMENT CASES UNDER FEB