DESCRIPTION OF THE FACILITY: THE MAIN SEWAGE TREATMENT PLANT (STP) IS A 4.5 MGD FA- CILITY THAT PROVIDES PRIMARY TREATMENT PRIOR TO DISCHARGING TO THE MISSISSIPPI RIVER. SPECIFICALLY, THE FACILITY CON- SISTS OF HEADWORKS AND CLARIFIERS. SLUDGE IS TREATED BY WET AIR OXIDATION (ZIMPRO PROCESS) PRIOR TO APPLICATION TO SLUDGE DRYING BEDS. BASIS OF ALLEGED VIOLATION: FACTUAL BASIS: THE WEST MEMPHIS UTILITY COMMISSION RECEIVED A STEP 1 GRANT AWARD TO DEVELOP A FACILITIES PLAN IN JUNE OF 1975. DURING THE NEXT FOUR YEARS THE COMMISSION ONLY COMPLETED AN INFLOW AND INFILTRATION ANALYSIS AND A SEWER SYSTEM EVALUA- TION SURVEY. THEY DID NOT BEGIN DEVELOPING FACILITIES PLAN- NING DOCUMENTATION UNTIL EPA ISSUED AN ADMINISTRATIVE ORDER (DOCKET NO. VI-79-100) ON DECEMBER 17, 1979. THE ORDER RE- QUIRED THE COMMISSION TO SUBMIT ADEQUATE FACILITIES PLANNING DOCUMENTS TO THE ARKANSAS DEPT. OF POLLUTION CONTROL AND ECOLOGY (ADPCE) BY MAY 31, 1980. THE COMMISSION SUBMITTED DOCUMENTS TO THE ADPCE ON MAY 30, 1980; HOWEVER THE DOCU- MENTS SUBMITTED WERE DEFICIENT IN A VARIETY OF WAYS. EPA EXTENDED THE SUBMITTAL DEADLINE UNTIL AUGUST 31, 1981, THROUGH AN ADMINISTRATIVE ORDER (DOCKET NO. VI-81-741) IS- SUED MARCH 30, 1981. THE COMMISSION WAS STILL UNABLE TO SUBMIT ACCEPTABLE FACILITIES PLANNIN