THIS IS A CIVIL ACTION AGAINST THE MDC, FOR VIOLATION OF SEC. 301(A) OF THE ACT. DEFENDANT IS AN AGENCY OF THE COMMONWEALTH OF MASSACHUSETTS, CREATED BY STATUTE. DEFEN- DANT'S STATUTORY RESPONSIBILITIES INCLUDE THE OPERATION AND MAINTENANCE OF THE BOSTON SEWAGE TREATMENT AND DISPOSAL SYS- TEM. THE COMPLAINT REQUESTS INJUNCTIVE RELIEF AS WELL AS CIVIL PENALTIES FOR PAST VIOLATIONS. THE REGION PROPOSES A REQUEST FOR INJUNCTIVE RELIEF TO REQUIRE DEFENDANT TO COMPLY WITH SPECIAL CONDITION C2 OF ITS NPDES PERMIT--MONITORING AND RECORDING REQUIREMENTS FOR THE NUT ISLAND TREATMENT PLANT, QUINCY, MASSACHUSETTS--AND CIVIL PENALTIES FOR PAST NON-COMPLIANCE. THE MDC'S NPDES PERMIT WAS ISSUED JOINTLY BY EPA AND THE STATE IN 1976. REGION I ISSUED AN ADMINISTRATIVE ORDER TO THE MDC ON AUGUST 8, 1980, REQUIRING INTERIM LIMITATIONS. ON JULY 1, 1982, THE REGION ISSUED A SECOND ADMINISTRATIVE ORDER TO THE MDC REQUIRING OPERATION AND MAINTENANCE IM- PROVEMENTS. THE MONITORING REPORTS FOR SEPTEMBER 1982 THROUGH JANU- ARY 1983 WERE NOT SUBMITTED TO EPA UNTIL MARCH 7, 1983. SINCE THE MDC HAS HISTORICALLY BEEN LATE IN SUBMITTING THESE REPORTS, THE REGION DID NOT AT FIRST REALIZE THAT THERE WAS A MORE SERIOUS PROBLEM. HOWEVER, MDC PERSONNEL WERE CON- TACTED ON NUMEROUS OCCASIONS (INCLUDING DURING THE WEEKS OF NOVEMBER 22, 1982, DECEMBER 27, 1982, JAN