THE CITY OF DALTON, GA, THROUGH THE BOARD OF WATER, LIGHT AND SINKING FUNDS COMMISSIONERS (THE BOARD ) OPERATES DALTON UTILITIES (THE UTILITY ). THE UTILITY OPERATES, MAINTAINS, AND MANAGES THE ELECTRIC, NATURAL GAS, DRINKING WATER AND SEWAGE SERVICES FOR THE CITY OF DALTON AND THE SURROUNDING AREAS WITHIN WHITFIELD COUNTY. THE UTILITY'S WASTEWATER TREATMENT FACILITIES SERVE A DOMESTIC POPULATION OF APPROXIMATELY 22,000 PERSONS AS WELL A NUMEROUS INDUSTRIES WHICH ARE PRIMARILY CARPET MANUFACTURERS. APPROXIMATELY 90 PERCENT OF THE UTILITY'S INFLUENT WASTEWATER IS FROM INDUSTRIAL SOURCES. THE UTILITY OWNS AND OPERATES THREE BIOLOGICAL WASTEWATER TREATMENT FACILITIES: (1) ABUTMENT ROAD WWTF; (2) RIVERBEND WWTF; (3) LOOPERS BEND WWTF. THESE FACILITIES HAVE A COMBINED DESIGN TREATMENT CAPACITY OF 40 MILLION GALLONS PER DAY (MGD) AND CURRENTLY TREAT APPROXIMATELY 29 MILLION GALLONS OF WASTEWATER ON AN AVERAGE DAILY BASIS. EFFLUENT FROM THE TREATMENT FACILITIES IS SPRAYED ONTO A DEDICATED LAND APPLICATION SYSTEM (LAS). A FULL EVALUATION OF ALL WASTEWATER PROGRAMS (I.E., WASTEWATER TREATMENT FACILITIES, LABORATORY, SLUDGE HANDLING AND DISPOSAL, LAND APPLICATION SYSTEM, PRETREATMENT PROGRAM, AND SANITARY SEWER COLLECTION SYSTEM) COMMENCED AT THE UTILITY IN LATE FEBRUARY 1997. IN THE SPIRIT OF COOPERATION AND PARTNERSHIP, GEROGIA EPD HAS REQUESTED THAT EPA REGION 4 ALLOW THE STATE TO BE A CO-PLAINTIFF IN THIS ACTION. EPA HAS IDENTIFIED A TOTAL OF 445 VIOLATIONS BY TH