NATURE OF THE CASE: THE CITY OWNS AND OPERATES FOUR TREAT- MENT PLANTS; HOWEVER, ONLY VIOLATIONS OCCURRING AT TWO OF THE PLANTS, EAST AND WEST VINCE BAYOU PLANTS, ARE INCLUDED IN THIS REFERRAL. THE DEEPWATER AND GOLDEN ACRES PLANTS ARE CURRENTLY UNDER ADMINISTRATIVE ORDERS. THE CITY HAS CONSISTENTLY FAILED TO COMPLY WITH ITS NPDES PERMITS AND VARIOUS ADMINISTRATIVE ORDERS.