THIS ACTION AGAINST THE CITY OF WATERBURY, CT INVOLVES VIOLATIONS OF SECTION 301 OF THE CLEAN WATER ACT, 33 U.S.C. SECTION 1311, SECTION 608 OF THE CLEAN AIR ACT, 42 U.S.C. SECTION 7671, AND EPA'S STRATOSPHERIC OZONE PROTECTION REGULATIONS. THE CLEAN WATER ACT CASE INVOLVES UNAUTHORIZED DISCHARGES FOR THE CITY'S SEWAGE COLLECTION SYSTEM. ON AT LEAST 57 OCCASIONS IN THE PAST FIVE YEARS, THE CITY'S COLLECTION SYSTEM HAS OVERFLOWED INTO NAVIGABLE WATERS. MOST OF THESE EVENTS OCURRED BECAUSE OF INADEQUATE COLLECTION SYSTEM MAINTENANCE BY THE CITY. THE CIY ALSO FAILED TO REPORT SEVERAL OF THESE INCIDENTS WITHIN THE 72 HOUR PERIOD REQUIRED BY THE CITY'S NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM PERMIT. THE CLEAN AIR ACT CASE ARISES FROM THE CITY'S IMPROPER DISPOSAL OF HOUSEHOLD APPLIANCES CONTAINING OZONE-DAMAGING REFRIGERANTS. THE CITY HAS COLLECTED REFRIGERATORS AND AIR CONDITIONERS FROM CITY RESIDENTS AND CRUSHED THESE APPLICANCES WITHOUT RECOVERING THE REFRIGERANTS. AS A RESULT REFRIGERANTS HAVE BEEN RELEASED INTO THE ATMOSPHERE IN VIOLATION OF THE CLEAN AIR ACT AND EPA'S STRATOSPHERIC OZONE PROTECTION REGULATIONS.