SESD HAS VIOLATED THE SECONDARY EFFLUENT LIMITATIONS ESTABLISHED IN ITS NPDES PERMIT SINCE 1977. SESD PURSUED A SECTION 301(H) WAIVER UNDER THE CLEAN WATER ACT, AND AFTER BEING DENIED A WAIVER IN 1985 REAPPLIED FOR A WAIVER IN 1986. IN 1983, REGION I FILED A CIVIL ACTION AGAINST SESD FOR VIOLATIONS OF THE CWA IN CONNECTION WITH SESD'S DIS- CHARGING OF SLUDGE INTO SALEM HARBOR. SESD CEASED SUCH DISCHARGES IN JULY, 1984.