VIOLATIONS UPON WHICH THE ACTION IS BASED: VIOLATIONS OF INTERIM EFFLUENT LIMITS AND VARIOUS OTHER CONDITIONS IN NPDES PERMIT NO. UT-0021709, ISSUED PURSUANT TO SECTION 402 OF THE ACT, 33 U.S.C. 1342. VIOLATIONS OF EPA'S 40 CFR PART 403 REGULATIONS AND ADMINISTRATIVE ORDERS ISSUED PURSUANT TO 309(A) OF THE ACT, 33 U.S.C. 1319(A). THE PROPOSED RELIEF TO BE SOUGHT, INCLUDING INJUNCTION, AND PROPOSED AMOUNT OF PENALTY TO BE SOUGHT AT SETTLE- MENT, IF APPLICABLE. INJUNCTIVE RELIEF TO: (1)REQUIRE CENTRAL VALLEY- COTTONWOOD TO CEASE ITS DISCHARGES TO WATERS OF THE UNITED STATES AS SOON AS POSSIBLE, BUT IN NO EVENT LATER THAN JULY 1, 1988; (2)REQUIRE CENTRAL VALLEY-COTTONWOOD TO ENTER INTO AN AGREEMENT WITH THE REGIONAL TREATMENT FACILITY BOARD WHICH WOULD ALLOW THE BOARD TO VICARIOULSY ENFORCE A PRETREATMENT PROGRAM AGAINST THE INDUSTRIAL USERS OF ITS SYSTEM. 6 A CIVIL PENALTY IN THE AMOUNT OF $289,400 FOR SETTLEMENT FOR PAST PERMIT AND A.O. VIOLATIONS AS DETERMINNED BY THE AGENCY'S PENALTY POLICY.