SYNOPSIS: * THE CITY OF MONTICELLO IS LOCATED IN DREW COUNTY, ARK. THE CITY OWNS AND OPERATES TWO WASTEWATER TREATEMENT FACILITIES, THE WEST AND EAST PLANT. THE WEST PLANT CONSISTS OF TWO OXIDATION PONDS AND WAS BUILT IN 1972. THE EAST PLANT CON- SISTS OF TWO OXIDATION PONDS AND TWO AERATED LAGOONS. THE EAST FACILITY HAS BEEN EXISTENCE SINCE 1972. * THE AVG DAILY DESIGN FLOW OF THE WEST PLANT IS 1.7 MGD PER DAY AND 2.91 MGD FOR THE EAST PLANT. THE PLANTS SERVE A TOTAL POPULATION OF APPROX 8,960. BOTH FACILITIES ARE AUTHORIZED BY THEIR RESECTIVE NPDES PERMITS TO DISCHARGE TO THE OUACHITA RIVER. * THE CITY WAS ISSUED NPDES PERMIT ARR0021831 FOR THE EAST PLANT ON JUNE 1, 1984, WHICH EXPIRED ON JUNE 13, 1986. A TIMELY RENEWAL APPLICATION WAS SUBMITTED AND THE PERMIT WAS REISSUED ON JUNE 20, 1986, AND WILL EXPIRE IN 1991. ALL PREVIOUS AND CURRENT PERMITS CONTAINED SECONDARY TREATMENT LIMITS. * THE CITY WAS IN VIOLATION OF ITS PERMITTED EFFLUENT LIMITS AT BOTH THE WEST AND EAST PLANTS IN 1982 AND 1983. IN 1984 EPA ISSUED AOS VI-84-435A AND VI-84-