NATURE OF CASE CAREFREE HOMES, INC. AND ROBERT DE ROSE, ITS PRESIDENT, THE PROPOSED DEFENDANTS, HAVE REPEATEDLY VIOLATED THE SAFE DRINKING WATER ACT, 42 U.S.C. SECTION 300F ET SEQ., AND EPA'S NATIONAL INTERIM PRIMARY DRINKING WATER REGULATIONS PROMULGATED THEREUNDER, 40 C.F.R. PART 141.}i CAUSE OF ACTION THE DRINKING WATER SUPPLIED BY CAREFREE HOMES, INC. FOR USE AT THE CAREFREE HOMES MOBILE HOME PARK HAS REPEATEDLY BEEN FOUND TO EXCEED MAXIMUM CONTAMINANT LEVELS (MCL) FOR COLIFORM BACTERIA, WHICH ARE CODIFIED AT 40 C.F.R. SECTION 141.14. THIS BACTERIOLOGICAL CONTAMINATION PRESENTS A POTENTIAL HEALTH RISK TO USERS OF THE SYSTEM. CAREFREE AND DE ROSE HAVE FAILED TO SAMPLE THEIR WATER AND REPORT ANALYTICAL RESULTS TO EPA, IN VIOLATION OF 40 C.F.R. SECTION 141.21 AND 141.31. CAREFREE AND DE ROSE HAVE ALSO FAILED TO NOTIFY USERS OF THE SYSTEM OF EXCEEDANCES OF THE MCL OR OTHER VIOLATIONS OF THE REGULATIONS IN VIOLATION OF 40 C.F.R. SECTION 141.32. THESE VIOLATIONS HAVE CONTINUED DESPITE A NUMBER OF EPA TELEPHONE, WRITTEN AND PERSONAL CONTACTS WITH CAREFREE HOMES, INC. AND DE ROSE BEGINNING IN EARLY 1980 IN AN ATTEMPT TO OBTAIN COMPLIANCE INFORMALLY. AFTER REPEATED CONTACTS BY EPA EMPLOYEES WERE UNSUCCESSFUL, AN ADMINISTRATIVE FINDINGS AND ORDER LETTER WAS SENT TO MR. DE ROSE ON AUGUST 1, 1983.