* THIS LITIGATION CONCERNS 10 WATER PERMITS (NPDES) * IMPERIAL UTILITIES CORPORATION. THIS IS A CIVIL ACTION AGAINST IMPERIAL UTILITIES CORPORATION, JEFFERSON COUNTY, MISSOURI FOR, AMONG OTHER THINGS, DISCHARGES WITHOUT A PER- MIT, BYPASSING OF RAW SEWAGE, DISCHARGES IN VIOLATION OF NPDES EFFLUENT LIMITS AND FAILURE TO SUBMIT NPDES DISCHARGE MONITORING REPORTS, ALL OF WHICH VIOLATE SEC. 301 OF THE CLEAN WATER ACT, 33 U.S.C. 1311. IMPERIAL UTILITIES CORPORATION IS A PRIVATE SEWER COMPANY, ESTABLISHED IN 1974, WHICH OPERATES NINE SEWAGE TREATMENT FACILITIES (NAMED ABOVE) AND ONE LIFT STATION IN THE ROCK CREEK WATERSHED, JEFFERSON COUNTY, MISSOURI. SEVEN OF THESE FACILITIES DISCHARGE INTO ROCK CREEK OR ITS TRIBUTARIES. ROCK CREEK IS A HIGH QAULITY STREAM USED FOR WHOLE BODY CON- TACT RECREATION AND DESIGNATED FOR USE AS A WILDLIFE AND LIVESTOCK WATERING STREAM AND FOR THE PROTECTION OF WARM WATER AQUATIC LIFE. SINCE 1974, SEVEN OF THESE FACILITIES HAVE DISCHARGED OR ARE NOW DISCHARGING WITHOUT A VALID NPDES PERMIT. IN ADDI- TION, IUC HAS FAILED TO SUBMIT MONITORING REPORTS FOR ANY OF THE PERMITTED FACILITIES AND HAS FAILED TO OPERATE SUCH FACILITIES PROPERLY AS DOCUMENTED BY FREQUENT STATE REPORTS OF RAW SEWAGE OVERFLOWS, DISCHARGES OF BLACK, SEPTIC EF- FLUENT AND BYPASSES. IN TWO INSTANCES THESE DISCHARGES RE- SULTED IN FISH KILLS. SPECIFIC VIOLA