THIS IS A CIVIL ACTION AGAINST THE CITY OF EUCLID, OHIO FOR CONTINUOUSLY VIOLATING THE EFFLUENT LIMITS FOR BOD,TSS, CHLORINE, AND PHOSPHORUS IN ITS NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM (NPDES) PERMIT, SINCE ITS ISSUANCE IN SEP TEMBER 1977. THE EUCLID WASTEWATER TREATMENT SYSTEM TREATS FLOWS FROM RESIDENTIAL, COMMERCIAL AND INDUSTRIAL SOURCES IN THE CITY OF EUCLID AND DISCHARGES DIRECTLY TO LAKE ERIE. THE CITY HAS RECEIVED APPROXIMATELY $15,221,725 IN FEDERAL MONIES TO UPGRADE AND CONSTRUCT THIS FACILITY. IT IS AN ACTIVATED SLUDGE PLANT WITH PHOSPHORUS AND TERTIARY TREATMENT CAPABIL- ITIES. ALTHOUGH THE PLANT HAS THE CAPACITY TO MEET ADVANCED WASTEWATER TREATMENT LIMITS AND ITS PERMIT REQUIRES IT TO DO SO, IN ACCORDANCE WITH THE WATER QUALITY STANDARDS FOR LAKE ERIE, EUCLID HAS CONSISTENTLY FAILED TO OPERATE AND MAINTAIN ITS FACILITIES TO MEET THESE STANDARDS.