THE TEXAS MUNICIPAL POWER AUTHORITY ( TMPA ) WAS CREATED BY THE TEXAS LEGISLATURE. TMPA PROVIDES ELECTRIC POWER TO THE TEXAS CITIES OF GARLAND, DENTON, GREENVILLE AND BRYAN. IT OWNS AND OPERATES A STEAM ELECTRIC POWER PLANT (GIBBONS CREEK STEAM ELECTRIC STATION GCSES ) IN GRIMES COUNTY, TX. GCSES OPERATES UNDER NPDES PERMIT NO. TX0074438 WHICH WAS ISSUED IN JANUARY OF 1979 BY EPA AND WAS REISSUED IN APRIL 1984. ONE OUTFALL AT THE PLANT (301) HAS VIOLATED LIMITS ESTABLISHED FOR BOD, TSS ON A CONSISTENT BASIS SINCE NOVEMBER, 1982. THAT OUTFALL IS THE SANITARY SEWAGE OUTFALL AND ACCOMODATES A 6,000 GALLON PER DAY PACKAGE SEWAGE TREAT- MENT PLANT. IN ADDITION, LIMITS FOR PH MINIMUM WERE VIOLA- TED IN NOVEMBER AND DECEMBER 1982, AND JANUARY, MARCH AND APRIL 1983. TMPA IS CURRENTLY MODIFYING THE FACILITY, AND STATES THAT IT WILL BE IN COMPLIANCE BY MARCH OF 1985. DUE TO THE PAST HISTORY OF THE AUTHORITY, THE REGION HAS LEGITIMATE REASONS TO DOUBT THIS ASSERTION. ON MAY 18, 1983, THE REGION ISSUED AN ADMINISTRATIVE ORDER TO TMPA WHICH REQUIRED THEM TO SUBMIT A CRITICAL PATH SCHEDULE FOR COMPLIANCE. THE SCHEDULE WAS SUBMITTED AND INDICATED THAT COMPLIANCE WOULD BE REACHED BY JANUARY 15, 1984. IT WAS NOT. THE PROBLEMS WITH THE PLANT STEM FROM DESIGN DEFICIENCIES, NON-OPERATIONAL PORTIONS OF THE SEWAGE TREAT- MENT SYSTEM AND INCORRECTLY ROUTED D