THE PLYMOUTH WATER AND SEWAGE DISTRICT IN PLYMOUTH, NEW HAMPSHIRE, HAS BEEN ISSUED THREE NATIONAL POLLUTANT DIS- CHARGE ELIMINATION SYSTEM PERMITS BY EPA. THE FIRST PERMIT WAS ISSUED ON 10/19/74, AND THE SECOND ON 05/31/77. PLYMOUTH'S CURRENT PERMIT WAS ISSUED ON 09/17/84 AND WILL EXPIRE ON 09/17/89. THE LATTER TWO PERMITS REQUIRED PLYMOUTH TO ACHIEVE SECONDARY TREATMENT BY 07/01/77. PLYMOUTH'S PRESENT WASTEWATER SYSTEM CONSISTS OF A PRIMARY TREATMENT PLANT. AS A RESULT, THIS COMMUNITY HAS CONTINUOUS- LY VIOLATED EFFLUENT LIMITATIONS SINCE 07/01/77. THEREFORE, THIS CASE IS BEING ADDRESSED AS PART OF EPA'S NATIONAL MUNICIAL POLICY EFFORT. IN SEPTEMBER 1986, EPA ISSUED AN ADMINISTRATIVE ORDER TO PLYMOUTH. THE ORDER WAS BASED UPON PLYMOUTH'S INABILITY TO MEET THE EFFLUENT LIMITATIONS IN ITS PERMIT. THE ORDER CON- TAINED INTERIM EFFLUENT LIMITATIONS AND A CONSTRUCTION SCHEDULE REQUIRING COMPLETION OF CONSTRUCTION AND PERMIT COMPLIANCE BY 07/01/88. BECAUSE OF PROBLEMS ENCOUNTERED IN FINANCING THE TREATMENT PLANT ( THE IMPROVEMENTS WERE TO BE FINANCED PRIVATELY), PLYMOUTH FAILED TO MEET THE MILESTONE DATES IN THE ORDER. ON 03/24/88, A MEETING WAS HELD WITH REPRESENTATIVES OF THE TOWN. AT THAT TIME, EPA WAS TOLD THAT FINANCING FOR THE PLANT HAD RECENTLY BEEN APPROVED BY THE STATE OF NEW HAMPSHIRE UNDER SPECIAL LEGISLATION AND THAT PLYMOUTH WAS READY TO MOVE FORWARD TO