NATURE OF THE CASE THE CITY OF GUYMON OWNS AND OPERATES TWO WASTEWATER TREAT- MENT PLANTS, THE NORTH PLANT & THE NORTHEAST PLANT, WHICH ARE SUBJECT TO THE REQUIREMENTS OF THE CAA, SECTIONS 301 & 402. SIPCO DISCHARGES EFFLUENT INTO THE NORTHEAST PLANT. CAUSE OF ACTION A. THE NORTH PLANT -- THE NORTH PLANT IS A MINOR FACILITY THAT WAS ISSUED A NPDES PERMIT WHICH EXPIRED ON 9/30/79. THE CITY FAILED TO MAKE TIMELY REAPPLICATION FOR A NEW PERMIT SO THE FACILITY IS CURRENTLY DISHCARGING WITHOUT A PERMIT. THE CITY ALSO FAILED TO SUBMIT TIMELY DISCHARGE MONITORING RPTS AND NONCOMPLIANCE REPORTS TO EPA. B. THE NORTHEAST PLANT -- THE NORTHEAST PLANT IS A MAJOR FACILITY THAT WAS ISSUED AN NPDES PERMIT ON 7/31/81. THIS PERMIT, AS WELL AS A PREVIOUS PERMIT, CONTAIN FINAL EFFLUENT LIMITATIONS FROM DISCHARGES FROM THE NORTHEAST PLANT. AT THE SAME TIME THIS PERMIT WAS ISSUED, GUYMON RECEIVED AN AO PURSUANT TO SECTION 309(A)(5)(A) OF THE CAA. THIS ORDER ESTABLISHED INTERIM EFFLUENT LIMITATIONS. GUYMON HAS BEEN UNABLE TO COMPLY WITH EITHER THE INTERIM OR FINAL EFFLUENT LIMITATIONS. BECAUSE IT WAS APPARENT THAT THE NORTHEAST PLANT WOULD NOT BE ABLE TO MEET THE REQUIRED LIMITS, GUYMON, IN 1977, APPLIED FOR A STEP 1 GRANT TO CONSTRUCT ADDITIONAL TREATMENT FACILITIES. AS OF THE DATE OF REFERRAL, STEP 1 HAS YET TO BE FINALIZED. IN ADDITION, GU