THIS IS AN ACTION BROUGHT PURSUANT TO SECTIONS 309(B), AND 309(D) OF THE CLEAN WATER ACT (CWA), FOR VIOLATIONS OF THE TERMS AND CONDITIONS OF THE NPDES PERMIT ISSUED TO THE ROBESONIA-WERNERSVILLE MUNICIPAL AUTHORITY FOR OPERATION OF ITS PUBLICLY OWNED TREATMENT WORKS. THE FACILITY IS LOCATED IN HEIDELBERG TOWNSHIP, BERKS COUNTY, PENNSYLVANIA. DEFENDANT SERVES AND ACTS THROUGH AND IN COOPERATION WITH THE BOROUGHS OF ROBESONIA & WERNERSVILLE AND THE TOWNSHIPS OF HEIDELBERG, LOWER HEIDELBERG AND SOUTH HEIDELBERG. THE DEFENDANT DISCHARGES POLLUTANTS INTO SPRING CREEK. DEFENDANT WAS ISSUED AN NPDES PERMIT ON JULY 8, 1980. THE PERMIT EXPIRED AND HAS BEEN RENEWED. THE ORIGINAL PERMIT ISSUED TO ROBESONIA-WERNERSVILLE, CONTAINED EFFLUENT LIMITS FOR BIOCHEMICAL OXYGEN DEMAND (BOD), AND FOR TOTAL SUSPENDED SOLIDS (SS). THE RENEWED PERMIT CONTAINED THESE EFFLUENT LIMITATIONS AND ALSO CONTAINED EFFLUENT LIMITATIONS FOR BOD, SS AND NEW LIMITS FOR AMONIA-NITRIGEN AND PHOSPHOROUS. DEFENDANT HAS BEEN IN CONTINUOUS NONCOMPLIANCE WITH THE EFFLUENT LIMITATIONS SPECIFIED IN ITS NPDES PERMIT FOR BOD, SS, AMMONIA-NITROGEN, AND PHOSPHOROUS, AS INDICATED BY DATA CONTAINED IN ITS DMR'S. DEFENDANT HAS COMMITTED 'AT LEAST' 4,551 VIOLATIONS OVER A PERIOD OF 53 MONTHS. SECTION 309(D) OF THE CLEAN WATER ACT PROVIDES THAT ANY PERSON WHO VIOLATES ANY CONDITION OR LIMI