THIS CASE INVOLVES A PREVIOUS CONSENT DECREE AND VIOLATIONS OF THAT DECREE AND THE APPLICABLE KPDES PERMIT. EPA SEEKS APPROPRIATE STIPULATED PENALITIES AND A CONSENT DECREE MODIFICATION TO BRING THE CITY OF BRODHEAD INTO COMPLIANCE WITH ITS FINAL EFFLUENT LIMITATIONS. THE MODIFICATION EPA PROPOSES WILL REQUIRE FROM THE CITY A COMPLETE NEW TREATMENT SYSTEM EVALUATION BY A COMPETENT ENGINEERING FIRM DIFFERENT THAN THE DESIGN ENGINEER.