DEFENDANT OWNS AND OPERATES A PUBLICLY OWNED TREAT- MENT WORKS WHICH HAS HAD BOD5, TSS, WH3, ASN0 PARAMATERS IN VIOLATION OF ITS NPDES PERMIT. MONITORING OF THE FACILITY INDICATES THAT THE PLANT MAY HAVE HAD VIOLATIONS OCCURRING WHICH WERE UNREPORTED BECAUSE OF POOR SAMPLING METHODOLOGY. EPA SEEKS CIVIL PENALTIES AND STIPULATED PENALTIES FOR NONCOMPLIANCE WITH EXISTING CONSENT DECREE UNDER THE CLEAN WATER ACT SECTIONS 311, 319, AND 342.