EPA FILED AN INITIAL ENFORCEMENT ACTION AGAINST THE PUERTO RICO AQUEDUCT AND SEWER AUTHORITY (PRASA) FOR VIOLATIONS OF THE CWA AND NPDES PERMITS AT 92 WASTEWATER TREATMENT PLANTS OWNED AND OPERATED BY PRASA ON 1/12/78 (DOCKET NO. 78-0038). A CONSENT DECREE RESOLVING THAT ACTION WAS FILED AND ENTERED ON 2/27/78. (PRASA I) THE 2/27/78 DECREE WAS FURTHER AMENDED AND MODIFIED ON 10/30/78, 5/16/80, 2/3/81, 12/9/81, AND 7/9/82. BY JULY, 1982, THE CONSENT DECREE COVERED 84 WWTP'S. PRASA VIOLATED THAT 7/9/82 DECREE. ON 1/18/83, EPA FILED A SECOND, SEPARATE ACTION AGAINST PRASA ALLEGING VIOLATIONS OF THE CWA AND NPDES PERMITS AT AN ADDITIONAL 16 WWTP'S. (DOCKET NO. 83-0105) (PRASA II) ON 4/27/84, EPA MOVED THE COURT TO FIND PRASA IN VIOLATION OF THE 7/9/82 CONSENT DECREE AND TO IMPOSE PENALTIES THERE- UNDER FOR SUCH VIOLATIONS. BOTH THE 1/18/83 COMPLAINT AND THE 4/27/84 MOTION TO EN- FORCE WERE RESOLVED WITH THE NEGOTIATION AND ENTRY OF A MODIFIED FINAL JUDGMENT ON 2/22/85. THE 2/22/85 ORDER COVERS 92 WWTP'S. (PRASA III) DURING THE SPRING AND SUMMER OF 1985, IT BECAME APPARENT TO REGION II THAT PRASA WAS IN SUBSTANTIAL NON-COMPLIANCE WITH THE 2/22/85 ORDER. CONSEQUENTLY, ON 11/15/85, EPA FILED A MOTION TO ENFORCE THE 2/22/85 ORDER. THE MOTION TO ENFORCE SOUGHT THE ENTRY OF AN INTERIM