THE CITY OF KEVIL OWNS AND OPERATES A WASTEWATER TREATMENT FACILITY SERVING 160 HOUSELHOLDS. SINCE 1977, THE CITY HAS BEEN UNABLE TO MEET THE EFFLUENT LIMITATIONS ON ITS DISCHARGE OF POLLUTANTS TO SURFACE WATERS CONTAINED IN THREE NPDES PERMITS ISSUED BY THE U.S. ENVIRONMENTAL PROTECTION AGENCY AND THE COMMONWEALTH OF KENTUCKY. AS A RESULT, EPA HAS ISSUED FOUR ADMINISTRATIVE ORDERS TO THE CITY, PLACING THEM ON A SCHEDULE TO ACHIEVE PERMIT COMPLIANCE. THE CITY HAS FAILED TO ACHIEVE COMPLIANCE IN ACCORDANCE WITH THESE ORDERS.