SYNOPSIS: THE CITY OF MIDDLESBORO (HEREINAFTER THE CITY) OPERATES A WASTEWATER TREATMENT PLANT IN MIDDLESBORO, KENTUCKY. NPDES PERMIT NUMBER KY0027235 WAS INITIALLY ISSUED ON JULY 17, 1975, RE-ISSUED ON JULY 1, 1977, AND RE-ISSUED AGAIN ON DECEMBER 10, 1982, FOR THE OPERATION OF THE WASTEWATER TREATMENT SYSTEM SERVING THE CITY (ATTACHMENT 1). ON NOV- EMBER 23, 1982, AN ADMINISTRATIVE ORDER (ORDER) WAS ISSUED SETTING SCHEDULES FOR COMPLYING WITH NPDES LIMITS AND SET- TING SCHEDULES FOR COMPLYING WITH NPDES LIMITS AND SETTING INTERIM EFFLUENT LIMITS. THE ORDER ALSO REQUIRED THE CITY TO INSTALL A COLOR REMOVAL SYSTEM BY APRIL 1, 1983 AND CON- STRUCT A NEW WASTEWATER TREATMENT PLANT BY OCTOBER 1985 (ATTACHMENT 2). THE CITY'S WASTEWATER TREATNMENT FACILITY HAS BEEN UN- ABLE TO COMPLY WITH THE EFFLUENT LIMITATIONS IN ITS NPDES PERMIT AND THE ADMINISTRATIVE ORDER IMPOSED BY EPA. SPECI- FICALLY, THE CITY HAS EXCEEDED EFFLUENT LIMITATIONS FOR TOTAL SUSPENDED SOLIDS (TSS), TOTAL CHROMIUM, FREE CYANIDE TOTAL MERCURY, TOTAL PHENOLS, DISSOLVED OXYGEN, FECAL COLI- FORM, AND TOTAL COLOR. IN ADDITION, THE CITY HAS FAILED TO REMOVE AT LEAST 85% OF THE INFLUENT BOD AND TSS AS REQUIRED BY THE PERMIT. ALSO, THE CITY HAS FAILED TO: 1) TAKE RE- PRESENTATIVE SAMPLES; 2) FOLLOW REQUIRED TEST PROCEDURES; 3) RECORD REQUIRED ANALYTICAL DATA; AN