PIMA COUNTY OPERATES A PUBLICLY OWNED TREATMENT WORKS, KNOWN AS THE INA ROAD WASTEWATER TREATMENT PLANT, IN TUCSON, ARIZONA. THE INA ROAD PLANT OPERATES UNDER AN NPDES PERMIT ISSUED BY THE UNITED STATES ENVIRONMENTAL PROTECTION AGENCY, REGION IX PURSUANT TO THE CLEAN WATER ACT. UNDER THE PER- MIT, PIMA COUNTY IS AUTHORIZED TO DISCHARGE TREATED WASTE- WATER FROM THE INA ROAD FACILITY TO THE SANTA CRUZ RIVER IN ACCORDANCE WITH SPECIFIED EFFLUENT LIMITATIONS, MONITORING REQUIREMENTS, AND OTHER CONDITIONS. THE PROPOSED CIVIL ACTION WHICH IS THE SUBJECT OF THE LITIGATION REPORT INVOLVES THE FOLLOWING VIOLATIONS BY PIMA COUNTY OF SECTIONS 301 AND 402 OF THE CLEAN WATER ACT BEETWEEN AUGUST 1, 1978 AND MARCH 1, 1983. 1. ELEVEN MONITORING REQUIREMENTS VIOLATIONS ARISING FROM THE FAILURE TO OPERATE THE AUTOMATIC EFFLUENT SAMPLER NECESSARY FOR PERMIT COMPLIANCE; AND 2. EIGHTY-SIX EFFLUENT LIMITATIONS VIOLATIONS. THE FAILURE OF PIMA COUNTY TO OPERATE THE INA ROAD PLANT'S EFFLUENT SAMPLER WAS ORIGINALLY DISCOVERED DURING A ROUTINE EPA INSPECTION IN EARLY 1982. THEREAFTER, A CRIMI- NAL INVESTIGATION WAS UNDERTAKEN BY THE OFFICE OF THE INSPECTOR GENERAL WHICH REVEALED THAT THE INCIDENT WAS REPRESENTATIVE OF A WIDESPREAD PRACTICE OF SEVERAL YEARS DURATION. SAMPLING WAS OFTEN SKIPPED WHEN THE EFFLUENT WAS OBSERVED TO BE OF POOR QUALITY AND THEREF