THIS CIVIL ACTION SEEKS INJUNCTIVE RELIEF AND PENALTIES UNDER SECTION 309(B) AND (D) OF THE CWA, 33 U.S.C. SECTION 1319(B) & (D), AGAINST THE DEFENDANT FOR VIOLATIONS OF THE FEDERAL PRETREATMENT STANDARDS. VIOLATIONS: DEF DISCHARGES BETWEEN 35,000-57,000 GPD OF INDUSTRIAL WSTWTR FROM ELECTROPLATING FACILITY IN WORCESTER, MA. TO THE UPPER BLACKSTONE WATER POLLUTION ABATEMENT DIST (UBWPAD) POTW AT MILLBURY, MA. AFTER TRMT THERE, IT EVENTUALLY EN- TERS THE BLACKSTONE RIVER. CURRENTLY, PARKER METAL DOES NOT PRETREAT ANY OF ITS PROCESS WASTES PRIOR TO DISCHARGE TO THE SEWER. AS A RESULT, THE DISCHARGE IS IN VIOLATION OF THE DISCHARGE LIMITS IN THE ELECTROPLATING CATEGORICAL STDS. THERE HAVE BEEN CONSISTENT VIOL'S OF LIMITS FOR CN, CU, CR, NI, ZN, & TOT METALS IN THE ELECTROPLATING OF COMMON METALS SUBCAT, 40 CFR SECT 413.14(C), & SECT 307(D) OF CWA. THE COMPLIANCE DATE FOR EXISTING NON-INTEGRATED ELECTROPLATERS, TO WHICH PARKER METAL IS SUBJECT, WAS APR. 27, 1984. PARKER METAL WAS REQUIRED BY 40 CFR 403.12(B) TO SUBMIT A BASELINE MONITORING REPORT ON TOT TOXIC ORGANICS (TTO) BY FEB 24, 1984, BUT TO DATE THERE IS NO RECORD OF EPA HAVING REC'D SUCH A REPORT. IN ADDITION, DEF FAILED TO SUBMIT A COMPLIANCE REPORT BY THE DEADLINE OF JULY 26, 1984, FOR CN & METAL STDS, & FAILED TO SUBMIT PERIODIC COMPLIANCE REPORTS IN JUNE OR DEC 1984, OR JUNE 1985, IN VIO