OKOLONA SEWER CONSTRUCTION DISCTICT, OF LOUISVILLE, KY, HAS HAD NUMEROUS VIOLATIONS OF ITS NPDES PERMIT AND HAS VIOLATED AN A.O. ALSO, OKOLONA REFUSES TO NEGOTIATE IN GOOD FAITH ON TERMS OF AN AGREEMENT TO CONNECT TO THE SEWER SSYTEM OF THE LOUISVILLE AND JEFFERSON COUNTY METRO SEWER DISTRICT (MSD). CONNECTION IS REQURIED BY AN EARLIER WRIT- TEN AGREEMENT, AND IS THE BASIS OF AN EPA CONSTRUCTION GRANT TO BUILD A SEWER LINE TO THE AREA. THE SEWER LINE WAS FUND- ED TO PREVENT WATER-QUALITY VIOLATIONS IN THE SMALL STREAMS PRESENTLY RECEIVING DISCHARGES FROM THE OKOLONA PLANT AND SIMILAR SMALL PLANTS. CONNECTION TO MSD IS ECONOMICALLY MORE VIABLE THAN UPGRADING THE PLANT TO MEET WATER-QUALITY STANDARDS. OKOLONA HAS NOT DEMOSTRATED A WILLINGNESS TO MEET FINAL PERMIT LIMITS OF NO DISCHARGE ; WE RECOMMEND JUDICIAL PROCEEDINGS TO OBTAIN INJUNCTIVE RELIEF AND AN ASSESSMENT OF CIVIL PENALTIES.