THE CITY OF MONTICELLO (CITY) OWNS AND OPERATES A WASTE- WATER TREATMENT FACILITY (PLANT) SERVING A POPULATION OF APPROXIMATELY 3225 PERSONS. IN JULY OF 1977, THE U.S. ENVIRONMENTAL PROTECTION AGENCY (EPA) ISSUED A NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM (NPDES) PERMIT SPECIFYING NO DISCHARGE. ON JUNE 30, 1982, EPA DENIED THE CITY'S REAPPLICATION FOR AN NPDES PERMIT. BETWEEN JULY OF 1977 AND JUNE 30, 1982, THE CITY FAILED TO MEET THE TERMS AND CONDITIONS OF ITS PERMIT. SINCE JUNE 30, 1982, THE CITY HAS DISCHARGED WITHOUT AN NPDES PERMIT.