SAN DIEGO'S POTW HAS NOT COMPLIED WITH THE SECONDARY TREATMENT EFFLUENT LIMITATIONS IN ITS NPDES PERMIT. IT ALSO HAS A HISTORY OF EXTENSIVE BYPASSES OF RAW SEWAGE RESULTING FROM SPILLS AND OVERFLOWS OF THE COLLECTION AND CONVEYANCE SYSTEM. IT HAS VIOLATED RECEIVING WATER BACTERIOLOGICAL STANDARDS. IT HAS VIOLATED PERMIT REQUIRE- MENTS GOVERNING THE HANDLING OF SLUDGE. AND IT HAS NOT PROPERLY IMPLEMENTED ITS PRETREATMENT PROGRAM. REGION 9 IS SEEKING A SUBSTANTIAL PENALTY AND ORDERS REQUIRING TIMELY COMPLIANCE WITH ALL PROVISIONS OF THE CITY'S NPDES PERMIT. THIS IS A MAJOR CASE BROUGHT PURSUANT TO THE NATIONAL MUNICIPAL POLICY.