NATURE OF THE CASE: THE COCA COLA COMPANY (COKE) OWNS AND OPERATES A PROCESSING PLANT IN AUBURNDALE, FLORIDA, INVOLVED IN THE PREPARATION OF CITRUS JUICE, ASSOCIATED BY-PRODUCTS, AND FORMULATED BEVERAGES. ON AUGUST 6, 1979, A NPDES PERMIT #FL0000418 WAS ISSUED. THIS PERMIT, AS WELL AS THE PREVIOUS PERMIT, CONTAINS EFFLU- ENT LIMITATIONS FOR DISCHARGES FROM TWO OUTFALLS AT THE AU- BURNDALE PLANT TO THE LAKE LENA RUN. IN ADDITION, THIS PER- MIT CONTAINS STRINGENT EFFLUENT LIMITATIONS, WHICH BECAME EFFECTIVE 04/01/83, WHICH ARE BASED ON STATE ESTABLISHED WA- TER QUALITY STANDARDS FOR THE LAKE LENA RUN. TO ENSURE THAT COKE MET THESE LIMITS, THE PERMIT CONTAINS A SCHEDULE FOR COMPLIANCE WITH MILESTONE DATES TO ASSIST COKE IN CONSTRUCT- ING THE NECESSARY TREATMENT TECHNOLOGY. COKE HAS BEEN OUT OF COMPLIANCE ON AT LEAST SOME EFFLUENT PARAMETERS EVERY QUARTER SINCE 1978. IN AN ATTEMPT TO MEET ITS PERMIT REQUIREMENTS, COKE, IN 1980, CONSTRUCTED A LARGE SPRAY IRRIGATION SYSTEM TO AID IN TREATMENT. SINCE THAT TIME, COKE HAS ADDED TO ITS SPRAY IRRIGATION SYSTEM AND HAS EXPERIENCED NUMEROUS PROBLEMS WITH THIS SYSTEM INCLUDING RE- SULTING UNPERMITTED DISCHARGES AND FURTHER EFFLUENT VIOLA- TIONS. IN RESPONSE, EPA ISSUED AN ADMINISTRATIVE ORDER TO COKE, REQUIRING A PERMIT APPLICATION FOR THE UNPERMITTED DISCHARGE AS WELL AS ESTABLISHING MONITORING, SAMPLING, AND REPORTING REQUIREMENTS CONSISTENT WITH