PERTAINING TO THE CWA VIOLATIONS: TURTLE MOUNTAIN MANUFACTURING'S VIOLATIONS INCLUDE NUMEROUS EFFLUENT VIOLATIONS OF PRETREATMENT STANDARDS FOR EXISTING SOURCES. SPECIFIC VIOLATIONS ALLEGED IN THIS REFERRAL ARE EXCEEDING MONTHLY AVERAGE LIMITS FOR CADMIUM, CHROMIUM, LEAD AND ZINC. TMMC FAILED TO COLLECT SAMPLES FOR ALL THE REQUIRED PARAMETERS IN THE PRETREATMENT REGULATIONS, SPECIFICALLY OMITTING TOTAL TOXIC ORGANICS AND PH. THE PROPOSED PENALTY FOR THE CWA PORTION OF THIS REFERRAL IS $396,000. -- THE RCRA VIOLATIONS ALLEGED IN THIS REFERRAL CONSIST OF: TMMC FAILED TO PROPERLY CHARACTERIZE WASTE GENERATED AT THE FACILITY, STORED HAZARDOUS WASTE IN EXCESS OF REGULATORY TIME LIMITS, FAILED TO PROPERLY MANAGE HAZARDOUS WASTE STORAGE CONTAINERS, FAILED TO PROPERLY COMPLETE MANIFESTS AND LAND DISPOSAL RESTRICTION CERTIFICATIONS, FAILED TO IMPLEMENT REQUIRED HAZARDOUS WASTE MANAGEMENT WORKER TRAINING, AND FAILED TO COMPLETE REQUIRED CONTINGENCY AND PREPAREDNESS PLANS. THE PENALTY FOR THE RCRA PORTION OF THE REFERRAL IS: $533,705. TOTAL PENALTY ASSESSED: $929,705.