ON APRIL 28, 2003, REGION 7 SIGNED A PACKAGE INCLUDING THREE REFERRALS FOR CWA PRETREATMENT VIOLATIONS PERTAINING TO THE CITY OF POSTVILLE, IOWA AND ITS TWO INDUSTRIAL CONTRIBUTORS, AGRIPROCESSORS, INC., AND IOWA TURKEY PRODUCTS. INC. � BOTH MEAT PROCESSING PLANTS. THE REFERRAL FOR AGRIPROCESSORS ALSO CONTAINS INFORMATION REGARDING VIOLATIONS OF EPCRA AND THE CAA FOR FAILURE TO PROVIDE LOCAL AND STATE AUTHORITIES WITH INFORMATION REGARDING THE USE OF ANHYDROUS AMMONIA AT THEIR FACILITY AND FOR FAILURE TO DEVELOP AND IMPLEMENT A RISK MANAGEMENT PLAN FOR ANHYDROUS AMMONIA. ON APRIL 28TH, REGION 7 ALSO RECEIVED A 60-DAY CITIZEN SUIT NOTICE LETTER FROM MIDWEST ENVIRONMENTAL ADVOCATES � ON BEHALF OF NORTHWEST IOWA CITIZENS FOR CLEAN WATER � INDICATING THAT IT INTENDS TO SUE THE CITY OF POSTVILLE AND AGRIPROCESSORS FOR CWA VIOLATIONS (SUBSTANTIALLY SIMILAR TO THE ONES IDENTIFIED IN EPA'S REFERRAL) AND FOR VIOLATIONS OF RCRA AND IOWA STATE LAW REGARDING IMPROPER LAND DISPOSAL OF PAUNCH WASTE. EPA INITIATED REVIEW OF THESE ENTITIES AFTER A RELEASE FROM THE CITY'S WASTEWATER TREATMENT LAGOONS RESULTED IN A FISH KILL. ACTIONS BY THE STATE SUBSEQUENT TO THAT EVENT HAD BEEN LARGELY INEFFECTIVE IN BRINGING THE TWO INDUSTRIES INTO COMPLIANCE WITH APPLICABLE PRETREATMENT STANDARDS OR IN FORCING THE CITY TO EFFECTIVELY ENFORCE THE PRETREATMENT STANDARDS AGAINST THE INDUSTRIES. THE REGION'S REFERRALS SEEK SIGNIFICANT PENALTIES TO DETER NONCOMPLIANCE AND RECAPTURE ECONOMIC BENEFIT.