DATE OPEN: 2/88; DATE VIOLATION DETERMINED: 12/01/84; DATE DOCUMENTS RECEIVED BY ORC: 03/24/88. THE COUNCIL AND COMMISSION OPERATE THE BLUE LAKE & SENECA WASTEWATER TREATMENT FACILITIES IN THE MINNEAPOLIS-ST. PAUL METROPOLITAN AREA. THEY RECEIVED THEIR CURRENT PER- MITS TO DISCHARGE INTO THE MINNESOTA RIVER IN 1987. THESE PERMITS SPECIFIED THAT THE COUNCIL AND COMMISSION WERE PERMITTED TO OPERATE UNDER INTERIM EFFLUENT LIMITATIONS, BY LAW, BECOME EFFECTIVE. THE COMMISSION AND COUNCIL WILL NOT MEET THEIR FINAL EFFLUENT LIMITATIONS ON JULY 1, 1988, AND NOT INTEND TO ACHIEVE COMPLIANCE UNTIL 1992. THE GENESIS OF U.S.EPA'S INTEREST IN THE MATTER WAS THE COUNCIL'S AND COMMISSION'S LONGSTANDING DISPUTE WITH ITS WATER QUALITY RELATED FINAL EFFLUENT LIMITATIONS. THIS DISPUTE RESULTED IN THE LAPSING OF THEIR 1977 PERMITS IN 1982. WHILE RESEARCHING THE HISTORY OF THIS MATTER, OTHER VIOLATIONS, INCLUDING BYPASS, FAILURE TO TIMELY NOTIFY OF BYPASS, TSS EFFLUENT LIMITATION VIOLATIONS, AND MITIGATION VIOLATIONS WERE DISCOVERED. THESE LATTER VIOLATIONS RE- LATE TO THE 1977 PERMITS AND HAVE BEEN INCORPORATED INTO THIS REFERRAL. THE STATE OF MINNESOTA ENTERED INTO A CONSENT DECREE WITH THE COUNCIL AND COMMISSION UNDER THE JURISDICTION OF THE RAMSEY COUNTY DISTRICT COURT ON FEBRUARY 16, 1988, AS DE- TAILED IN THE LITIGATION REPORT. WE