VIOLATIONS UPON WHICH THE ACTION IS BASED: VIOLATION OF INTERIM EFFLUENT LIMITS AND VARIOUS OTHER CONDITIONS OF NPDES PERMIT UT-0020826. VIOLATION OF EPA'S 40 CFR PART 403 REGULATIONS AND ADMINISTRATIVE ORDERS (AOS) ISSUED MARCH 20, 1984 AND JANUARY 4, 1985 REQUIRING ADOPTION AND IMPLEMENTATION OF A PRETREATMENT PROGRAM. PROPOSED RELIEF TO BE SOUGHT, INCLUDING INJUNCTION, AND PROPOSED AMOUNT OF PENALTY TO BE SOUGHT AT SETTLE- MENT, IF APPLICABLE. WE SEEK INJUNCTIVE RELIEF TO (1) REQUIRE SOUTH SALT LAKE TO CEASE ITS DISCHARGES TO WATERS OF THE UNITED STATES, AS SOON AS POSSIBLE, BUT IN ANY EVENT, NO LATER THAN JULY 1, 1988; (2)REQUIRE SOUTH SALT LAKE TO ENTER INTO AN AGREEMENT WITH THE CENTRAL VALLEY BOARD WHICH WOULD ALLOW THE BOARD TO ENFORCE A PRETREATMENT PROGRAM AGAINST THE INDUSTRIAL USERS ON THEIR SYSTEM. WE PROPOSE A CIVIL PENALTY AT SETTLEMENT FOR PAST PERMIT AND AO VIOLATIONS OF $12,780 AS DETERMINED BY EPA'S CIVIL PENALTY POLICY.