PRASA OWNS AND OPERATOES SIXTY WATER TREATMENT PLANTS ( WTPS ). THE LA PLATA AIBONITO FILTER PLANT, PROVIDES POTABLE WATER IN THE LA PLATA COUNTY AREA. THIS ACTION IS BASED ON VIOLATIONS OF THE EFFLUENT LIMITS IN ITS PERMIT FOR MANY PARAMETERS. THERE ARE DEFICIENCIES IN THE DIS- CHARGE MONITORING REPORTS THEMSELVES. THEY FAIL TO REPORT CERTAIN EFFLUENT DATA REQUIRED BY THE PERMIT. IN ADDITION, THE DMRS HAVE BEEN SUBMITTED LATE ON AT LEAST 42 OCCASSIONS AND HAVE NOT BEEN SUBMITTED ON AT LEAST 5 OCCASIONS. THE PROPOSED RELIEF TO BE SOUGHT IS A JUDICIAL ORDER DIRECTING PRASA TO COMPLY WITH ITS PERMIT REQUIREMENTS AND CONDITIONS AND THE IMPLEMENTATION OF A CIVIL PENALTY. AN ADMINISTRATIVE ORDER WAS ISSUED ON 9/27/84. FROM 1983 THROUGH 1988, EPA, EQB AND PRASA EXCHANGED CORRESPON- DENCE AND TOOK PART IN NEGOTIATIONS REGARDING COMPLIANCE SCHEDULES FOR THIS FACILITY AND PRASA'S OTHER WATER FILTRATION FACILITIES. VARIOUS LETTERS OF DEFICIENCY WERE SENT TO PRASA DURING THAT TIME PERIOD. ON 9/28/88, EPA ISSUED AN ADMIN. ORDER TO PRASA. THIS ORDER CITED FINDINGS OF EFFLUENT VIOLATIONS AND FAILURE TO COMPLY WITH ITS PER- MIT. THE ORDER ALSO CONTAINED INTERIM EFFLUENT LIMITS FOR FOUR OF THE PERMIT PARAMETERS. ON 3/29/89 EPA ISSUED ANOTHER ORDER TO PRASA REQUIRING COMPLIANCE AND QUARTERLY REPORTING OF COMPLIANCE MEASURES TAKEN. ON 6/15/89 EPA ISSUED A MODIFIED ORDER IN RESPONSE TO