THE CITY OF NEPTUNE BEACH OWNS AND OPERATES A WASTEWATER TREATMENT FACILITY WHICH CURRENTLY DISCHARGES INTO THE INTERCOASTAL WATERWAY AND SERVES A POPULATION OF APPROXI- MATELY 6100. FOR THAT DISCHARGE, THE U.S. ENVIRONMENTAL PROTECTION AGENCY (EPA) ISSUED NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM (NPDES) PERMIT NO. FL00020427, EFFECTIVE JANUARY 30, 1975 AND EXPIRING JUNE 30, 1977. EPA REISSUED THAT PERMIT EFFECTIVE JULY 1, 1977, WITH AN EXPIRATION DATE OF JUNE 30, 1982 AND CONCURRENTLY ISSUED THE CITY AN ENFORCEMENT COMPLIANCE SCHEDULE LETTER (ECSL). THE ECSL CONTAINED INTERIM EFFLUENT LIMITATIONS AND A SCHEDULE REQUI- RING COMPLIANCE BY JULY 1, 1980. THE CITY FAILED TO MEET THE DEADLINE, AND THE ECSL BECAME NULL AND VOID IN AUGUST, 1980. THE CITY FILED AN APPLICATION FOR REISSUANCE OF ITS PERMIT ON JANUARY 13, 1983, SIX MONTHS AFTER THE PERMIT HAD EXPIRED. ACCORDINGLY, NOTWITHSTANDING THE SUBSEQUENT ADMIN- ISTRATIVE ORDER ISSUED IN 1983 AND AMENDED IN 1985, THE CITY HAS BEEN DISCHARGING WITHOUT A PERMIT SINCE JUNE 30, 1982. EPA ISSUED A PERMIT TO DISCHARGE TO THE ST. JOHN'S RIVER EFFECTIVE SEPTEMBER 28, 1984 AND WHICH WILL EXPIRE ON SEPTEMBER 30, 1989.