NATURE OF THE CASE: THE CONFEDERATE ACRES SANITARY SEWER & DRAINAGE SYSTEM, INC. ( CONFEDERATE ACRES ) OWNS AND OPER- ATES A STP KNOWN AS THE CONFEDERATE ACRES WWTP IN LOUISVILLE KY. THE CONFEDERATE ACRES PLANT WAS BUILT IN 1964 AND DESIGN ED TO PROVIDE SECONDARY WASTE TREATMENT. ITS DESIGN CAPACITY IS 295,000 GPD ITS ACTUAL FLOW IS ABOUT 140,000 GPD. ON OCTOBER 28, 1982, THE NPDES PERMIT FOR THE PLANT EXPIRED, AND IT HAS BEEN DISCHARGING WITHOUT A PERMIT SINCE THEN. RELIEF REQUESTED: A. OBTAIN CONSENT DECREE SETTING EXPEDI TIOUS SCHEDULE FOR CONNECTING TO MSD SYSTEM. B. ENJOIN UNPERMITTED DISCHARGE VIOLATIONS. C. IMPOSE CIVIL PENALITIES AS NECESSARY.