PERMITTEE FAILED TO MEET ALL PERMIT REQUIREMENTS. On May 5, 2017, EPA Region III filed a CAFO with Antrim Township, Pennsylvania (Antrim) resolving alleged Clean Water Act (CWA) violations of the pretreatment requirements of its National Pollutant Discharge Elimination System (NPDES) Permit No. 0080519. Pretreatment regulations prevent the introduction of pollutants into the collection and treatment system which could interfere with the operation of the system, contaminate the resulting sludge, or pass through into the receiving waters or the atmosphere. Pennsylvania has not been delegated the pretreatment program. The violations were discovered as part of an EPA July 2014 audit of Antrim�s pretreatment program and through information provided by Antrim in response to a March 2016 CWA Section 308 Information Requirement. The audit identified numerous deficiencies in Antrim�s pretreatment program implementation, including, but not limited to, failures to: 1) correctly issue permits to users; 2) issue permits that abide by all federal regulations and that are consistent with local limits; 3) conduct all required compliance sampling at SIUs; 4) conduct all required compliance inspections at SIUs; 5) adequately review all SIU self-monitoring reports and compliance monitoring reports; 6) implement an Enforcement Response Plan; and, 7) maintain all required documentation. The CAFO, which simultaneously commences and resolves the administrative action, in accordance with 40 C