THIS IS A PROPOSED ACTION AGAINST THE DELAWARE COUNTY REGIONAL WATER CONTROL AUTHORITY ( DELCORA ) UNDER SECTION 309 OF THE CLEAN WATER ACT ( THE ACT ), 333 U.S.C. 1319, TO COMPEL COMPLIANCE WITH DELCORA'S NPDES PERMIT AT ITS WES- TERN REGIONAL TREATMENT PLANT ( PLANT ). THE NPDES PERMIT VIOLATIONS AT THE PLANT INCLUDE THE FOLLOWING: 1. VIOLATION OF NPDES PERMIT EFFLUENT LIMITATIONS FROM APRIL 1985 TO THE PRESENT. DELCORA HAS JUST BEEN LISTED ON THE QUARTERLY NONCOMPLIANCE REPORT AS BE- ING IN SIGNIFICANT NONCOMPLIANCE FOR ITS DISCHARGES IN TO THE DELAWARE RIVER. 2. VIOLATIONS OF NPDES SAMPLING AND REPORTING REQUIRE- MENTS. THE REMEDY SOUGHT BY THE REGION INCLUDES THE OPERATION OF THE TREATMENT EQUIPMENT THAT HAS BEEN TURNED OFF AND THE IMPROVEMENT OF ITS SAMPLING METHODOLOGY IN ORDER TO ACCUR- ATELY CHARACTERIZE THE PLANT'S INFLUENT AND EFFLUENT. THE REGION ALSO SEEKS A SUBSTANTIAL CIVIL PENALTY.