VIOLATIONS UPON WHICH THE ACTION IS BASED: VIOLATION OF EPA'S 40 CR PART 403 REGULATIONS AND ADMINIS ADMINISTRATIVE ORDER, DOCKET NO. 85-15. PROPOSED RELIEF TO BE SOUGHT, INCLUDING INJUNCTION, AND PROPOSED AMOUNT OF PENALTY TO BE SOUGHT AT SETTLE- MENT, IF APPLICABLE: INJUNCTIVE RELIEF PLACING GRANGER-HUNTER ON A COURT- ENFORCEABLE FIXED DATE SCHEDULE TO ACHIEVE NO DISCHARGE AS SOON AS POSSIBLE, BUT IN NO EVENT LATER THAN THE JULY 1, 1988, STATUTORY DATE. STIPULATED PENALTIES SHOULD BE IMPOSED ON GRANGER-HUNTER FOR EACH DAY AFTER JULY 1, 1988 THAT THE PLANT IS STILL DISCHARGING. ADDITIONALLY, WE PROPOSE A CIVIL PENALTY FOR SETTLEMENT OF $198,000 FOR PAST PERMIT AND AO VIOLATIONS, AS DETERMINED BY THE AGENCY'S CIVIL PENALTY POLICY.