PRASA failed to comply with an April 17, 2002 AO requiring Respondent's Anasco public water system to install and operate continuous monitoring turbidimeters by July 31, 2002. Respondent was to have certified to EPA that compliance with the Enhanced Interim Surface Water Treatment Rule was achieved by Aug. 15, 2002. On Oct. 28, 2002, EPA issued an Administrative complaint, Findings of Violation, Notice of Proposed Assessment of a Civil Penalty and Notice of Opportunity to Request a Hearing (the Complaint ).