THE CITY OF ROCK SPRINGS, WYOMING FAILED IN 1991 TO SUPPLY SUFFICIENT QUALIFIED PERSONNEL FOR IMPLEMENTATION AND ENFORCEMENT OF THE PRETREATMENT PROGRAM AS REPORTED BY THE CITY IN ITS ANNUAL REPORT. THE INSPECTION CONDUCTED ON JANUARY 28 AND 29, 1992 REVEALED THAT THE CITY HAS FAILED TO PROPERLY IMPLEMENT THE INDUSTRIAL PRETREATMENT REQUIREMENTS BY: FAILING TO ISSUE VALID PERMITS TO ITS SIGNIFICANT INDUSTRIAL USERS. THE PERMITS LACK A STATEMENT OF NON-TRANSFERABILITY, SPECIFIC SAMPLING LOCATIONS, APPROPRIATE REPORTING REQUIREMENTS, RIGHT OF ENTRY, RECORD RETENTION, CIVIL AND CRIMINAL PROVISIONS, REVOCATION OF PERMIT CLAUSES, AND STATEMENT OF DURATION. THE PH LIMITS IN THE PERMITS ARE LESS STRINGENT THAN THOSE ALLOWED BY THE LOCAL LEGAL AUTHORITY. THE CITY HAS FAILED TO ISSUE PERMITS CONSISTENT WITH THE LOADINGS OR CONCENTRATION AND FLOW SO THAT THEY CAN DETERMINE COMPLIANCE. FAILURE TO SAMPLE AND INSPECT EACH SIU AT LEAST ONCE PER YEAR. FAILED TO ADEQUATELY DETERMINE THE COMPLIANCE STATUS OF SIU'S THROUGH INDUSTRIAL WASTE SURVEYS. FAILURE TO REQUIRE SELF MONITORING REPORTS WHICH INCLUDE ANALYTICAL RESULTS FOR ALL PERMITTED PARAMETERS. THE CITY HAS FAILED TO REVIEW THE COMPLIANCE STATUS OF SIU'S PERIODICALLY. IN ALL THERE ARE 12 POINTS OF FAILURE BY THE CITY OF ROCK SPRINGS TO MONITOR AND ADMINISTER THEIR POTW. THE PROPOSED CIVIL PENALTY FOR THIS COMPLAINT IS $125,0