* THIS LITIGATION INVOLVES WATER PERMITS (1) KY0044504 * * (2) KY0045896 (3) KY0045900 (4) KY0051543 * PLASTICS UNIVERSAL CORPORATION (HEREAFTER 'PLASTICS' OR 'THE COMPANY'), A SUBSIDIARY OF ADAMS RESOURCES AND ENERGY, INC., OPERATES SURFACE COAL MINING OPERATIONS IN BELL AND KNOX COUNTIES, KENTUCKY. IN MARCH 1980, PLASTICS PURCHASED BLUE GEM COAL AND LAND CORPORATION. NPDES PERMIT KY0044504 (ATTACHMENT A-1) WAS ISSUED TO PLASTICS EFFECTIVE JANUARY 30, 1978. NPDES PERMITS KY0045896, KY0045900, AND KY0051543 WERE ISSUED TO BLUE GEM COAL AND LAND CORPORATION EFFECTIVE DATES SEPTEMBER 28, 1978, SEPTEMBER 28, 1978 AND APRIL 28, IT WAS AGREED THAT CERTAIN DELAYS IN THE CONSTRUCTION OF A LIFT STATION (A SYSTEM OF PUMPS FOR THE MOVEMENT OF WASTE- WATER TO THE TREATMENT FACILITY) DUE TO THE INABILITY TO SECURE DELIVERY OF TIMELY PURCHASED EQUIPMENT WAS EXCUSABLE AND THE U.S. WOULD NOT OBJECT TO A MOTION BY THE DEFENDANTS FOR MODIFICATION OF DELAYS IN CONSTRUCTION OF A GRIT CHAM- BER (A MECHANICAL DEVICE FOR THE REMOVAL OF HEAVY SETTLE- ABLE SOLIDS FROM THE WASTEWATER), THE U.S. REITERATED ITS POSITION THAT MORE DELAY IN OBTAINING FEDERAL GRANT FUNDING WAS AN INSUFFICIENT JUSTIFICATION TO VOID LIABILITY FOR FAILURE TO MEET THE NEGOTIATED DECREE SCHEDULE. IN 12/81 DOJ WAS NOTIFIED BY RMUA THAT IT HAD FAILED TO MEET THE DEADLINE DATES ESTABLISHED FOR CONSTRUCTION OF THE LIFT STATION AND GRIT CHAMBER AND HAD