WE ARE REFERRING THIS MATTER TO YOU FOR A PROPOSED CIVIL ACTION UNDER SECTION 309(D) OF THE CLEAN WATER ACT, 33 U.S.C 1319(B). THE SCHLAGE LOCK COMPANY HAS VIOLATED THE METAL FINISHING PRETREATMENT REQUIREMENTS SET FORTH AT 40 C.F.R. 433, CONTINUOUSLY IN 1986. WE EXPECT THESE VIOLATIONS TO CONTINUE THROUGH 1987. THE PROPOSED DEFENDANT OWNS AND OPERATES A LOCK MANUFAC- TURING PLANT NEAR COLORADO SPRINGS, COLORADO. THIS PLANT DISCHARGES WASTEWATERS INTO THE POTW OWNED BY THE SECURITY SANITATION DISTRICT. THE PROPOSED RELIEF TO BE SOUGHT, INCLUDING INJUNCTION, AND PROPOSED AMOUNT OF PENALTY TO BE SOUGHT AT SETTLEMENT, IF APPLICABLE. WE ARE SEEKING PENALTIES AND INJUNCTIVE RELIEF TO REQUIRE COMPLIANCE. THE RECENT CONTACTS WITH THE DEFENDANT(S), INCLUDING ANY PREVIOUS ADMINISTRATIVE ENFORCEMENT ACTIONS TAKEN, AND NEGOTIATIONS, IF ANY. WE HAVE HAD NUMEROUS INFORMAL CONTACTS RECENTLY. WE ISSUED SCHLAGE AN AO ON JULY 31, 1986. DATE OF INSPECTION, INFORMATION RESPONSE, OR RECEIPT OF EVIDENCE OF VIOLATIONS WHICH LED TO DECISION TO INITIATE ENFORCEMENT PROCEEDINGS. THROUGHOUT 1986, WE RECEIVED SELF-MONITORING DATA INDICAT ING SCHLAGE WAS IN VIOLATION OF 40 C.F.