IMPACT: ON OCTOBER 28, 1994, THE REGION REFERRED TO HQ AND DOJ VIOLATIONS BY JEFFERSON COUNTY, AL OF PROVISIONS OF THE CLEAN WATER ACT APPLICABLE TO ALL 11 OF ITS WASTEWATER TREATMENT PLANTS. THE REFERRAL SEEKS A CIVIL JUDICIAL PENALTY. BACKGROUND: IN NOVEMBER 1993 AND APRIL 1994, TWO CITIZENS' GROUPS FILED CITIZEN SUIT COMPLAINTS AGAINST JEFFERSON COUNTY IN FEDERAL DISTRICT COURT FOR VIOLATIONS OF THE CWA, INCLUDING EFFLUENT LIMITATION VIOLATIONS, SANITARY SEWER OVERFLOWS AND BYPASSES OCCURRING AT 7 OF THE WWTPS. ALL PARTIES, INCLUDING JEFFERSON COUNTY, HAVE FILED MOTIONS FOR SUMMARY JUDGMENT IN THE CASE WHICH ARE STILL PENDING. ON OCTOBER 7, 1994, DOJ AT REGION IV'S REQUEST, FILED AN AMICUS CURIAE BRIEF WITH THE COURT. THE 10/28/94, REFERRAL ADDRESS 4 CATEGORIES OF CWA VIOLATIONS: (1) EFFLUENT VIOLATIONS AT 10 WWTPS; (2) DISCHARGING AT AN UNPERMITTED SOURCE (BYPASSES) AT 6 WWTPS; (3) DISCHARGING AT AN UNPERMITTED SOURCE (SANITARY SEWER OVERFLOWS); (4) DISCHARGING WITHOUT A VALID NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM (NPDES) PERMIT. THE TOTAL NUMBER OF VIOLATIONS UNDER SECTION 301 AND 402 OF THE CWA IS 14,686. THE CIVIL PENALTY AMOUNT OF $208703,000 IS BASED ON A GRAVITY CALCULATION OF $7,022,000 AND ECONOMIC BENEFIT OF $273,681,000.