NATURE OF THE CASE: THE CITY OF VICCO, KY, OWNS AND OPER- ATES A WWTP WHICH DISCHARGES TO CARRS FORK IN PERRY COUNTY, KY. . THE CITY HAS A POPULATION OF ABOUT 700, OF WHICH APPROXIMATELY 200 ARE SERVED BY THE WWTP. SINCE THE CITY OP- ERATES A WASTEWATER TREATMENT FACILITY WHICH DISCHARGES INTO A WATER OF THE U.S., THE CITY WAS CONTACTED BY REGION IV OF THE USEPA IN A LETTER OF JANUARY 7, 1977, AND REQUESTED TO APPLY FOR A NPDES PERMIT. A SECOND REQUEST FOR APPLICATION WAS MADE TO THE CITY ON AUGUST 30, 1978. AN ADMINISTRATIVE ORDER (NO. 78-280) WAS ISSUED ON DECEMBER 26, 1978, AFTER THE CITY HAD FAILED TO RETURN A COMPLETED NPDES PERMIT APP- LICATION. A NOTICE OF VIOLATION WAS SENT TO THE CITY ON JUNE 2, 1980, AFTER THE CITY FAILED TO COMPLY WITH ADMINIS- TRATIVE ORDER NO. 78-280. ON JANUARY 15, 1981, ANOTHER AD- MINISTRATIVE ORDER (NO. 81-82) WAS ISSUED BECAUSE THE CITY STILL HAD NOT APPLIED FOR A NPDES PERMIT FOR ITS WWTP. IN FEBRUARY, 1981, THE CITY SUBMITTED AN APPLICATION FOR A NPDES PERMIT. UPON RECEIPT OF THE APPLICATION, ADMINISTRA- TIVE ORDERS NO. 81-82 AND 78-280 WERE INACTIVATED. RECOMMENDED ACTION: BECAUSE THE CITY HAS FAILED TO MEET ITS OBLIGATIONS UNDER THE CWA BY NOT CORRECTING THE OPERA- TION AND MAINTENANCE PROBLEMS AT ITS TREATMENT FACILITY, & BECAUSE PREVIOUS EFFORTS BY EPA TO GET THE CITY TO COMPLY WITH ITS NPDES PERMIT CONDITIONS HAVE FAILED, THE ONLY AL- TERNATIVE LEFT TO BRING ABOUT COMPLIAN