****** PRASA HAS FAILED TO REPORT TO EPA AND EQB THE RAW SEWAGE OVERFLOWS THAT HAVE OCCURRED AT THE ISABELA, AS REQUIRED BY GENERAL CONDITION C.12 OF THE ISABELA WWTP NPDES PERMIT. BASED UPON INFORMATION RECEIVED FROM PRASA (MONTHLY DMRS), PRASA'S BYPASSES REPORTS, AS WELL AS INFORMATION GATHERED BY EPA DURING THE MAY 11, 2001 INSPECTION, EPA FINDS THAT THE ISABELA WWTP IS NOT IN COMPLIANCE WITH ITS NPDES PERMIT. IN ADDITION, THE FACILITY HAS BEEN ADEQUATELY OPERATED AND MAINTAINED AS REQUIRED BY ITS NPDES PERMIT. THEREFORE, ON THE BASIS OF THE FINDINGS CITED IN THE PARAGRAPHS ABOVE, THE PERMITTEE IS IN VIOLATION OF 301 OF THE ACT AND PERMIT CONDITIONS ESTABLISHED PURSUANT TO IT. ****** EPA CONDUCTED COMPLIANCE EVALUATION INSPECTIONS AT THE ISABELA WWTP ON MARCH 17, 2000 AND MAY 11, 2001, DURING WHICH EPA OBSERVED DEFICIENCIES AND THAT THE FACILITY HAD NOT BEEN ADEQUATELY OPERATED AND MAINTAINED AS REQUIRED BY ITS NPDES PERMIT, THEREBY CONCLUDING THAT THE ISABELA WWTP WAS NOT IN COMPLIANCE WITH ITS NPDES PERMIT, THEREBY CONCLUDING THAT THE ISABELA WWTP WAS NOT IN COMPLIANCE WITH ITS NPDES PERMIT. AS A RESULT, EPA ISSUED TWO NON-PENALTY ADMINISTRATIVE ORDERS: (1) ADMINISTRATIVE ORDER, CW