THE CITY OF CLEARWATER, FL. OWNS AND OPERATES THE MARSHALL STREET POLLUTION CONTROL FACILITY. THIS FACILITY PROVIDES WASTEWATER SERVICE TO APPROXIMATELY 50,000 PEOPLE. ON AUGUST 12, 1974, THE USEAP ISSUED TO THE CITY ITS FIRST NPDES PERMIT. THIS PERMIT, AS WELL AS SUBSEQUENT PERMIT ISSUED ON APRIL 18, 1980, ESTABLISHED EFFLUENT LIMITATIONS FOR THE CITY'S DISCHARGE. SINCE 1977, THE MARSHALL STREET PCF HAS BEEN UNABLE TO MEET THE EFFLUENT LIMITATIONS CONTAINED IN ITS PERMITS. THE PRIMARY REASON FOR THE CITY'S NONCOMPLIANCE IS THAT THE TREATMENT PLANT IS UNDERDESIGNED FOR ADVANCED WASTEWATER TREATMENT. MARSHALL STREET FPC WAS NEVER DESIGNED TO TREAT THE NITROGEN AND PHOSPHORUS COMPONENTS IN ITS EFFLUENT. THE CITY OF CLEARWATER, FLORIDA OWNS AND OPERATES THE EAST POLLUTION CONTROL FACILITY (EAST PCF) AND THE NORTHEAST POLLUTION CONTROL FACILITY (NORTHEAST PCF), PROVIDING WASTEWATER SERVICE TO APPROXIMATELY 70,000 PEOPLE. THE EAST PCF WAS ISSUED A NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM PERMIT NO. FL0021865 ON MAY 18, 1977, REQUIRING THE FACILITY TO ACHIEVE NO DISCHARGE TO SURFACE WATER BY JULY 1, 1977. BECAUSE THERE WAS NO PRATICAL WAY TO IMMEDIATELY CEASE ITS DISCHARGE TO OLD TAMPA BAY, AN ENFORCEMENT COMPLIANCE SCHEDULE LETTER WAS ISSUED ON JULY 28, 1977, SETTING INTERIM LIMITATIONS AND ESTABLISHING A COMPLIANCE SCHEDULE REQUIRING THE CI