THE CITY OF HINDMAN OWNS AND OPERATES A WASTEWATER TREAT- MENT FACILITY (PLANT) SERVING A POPULATION OF 876 (233 USERS). HINDMAN HAS BEEN ISSUED TWO NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM (NPDES) PERMITS BY THE U.S. ENVIRONMENTAL PROTECTION AGENCY (EPA) AND ONE KENTUCKY POLLUTANT DISCHARGE ELIMINATION SYSTEM (KPDES) PERMIT BY THE COMMONWEALTH OF KENTUCKY. AS A RESULT OF EFFLUENT LIMIT VIOLATIONS, THE CITY HAS BEEN ISSUED THREE ADMINISTRA- TIVE ORDERS AND ONE ENFORCEMENT COMPLIANCE SCHEDULE LETTER (ECSL). THE LATEST A.O. WAS ISSUED NOVEMBER 20, 1984, AND REQUIRED THE CITY TO SUBMIT A MUNICIPAL COMPLIANCE PLAN (MCP). THE CITY FAILED TO COMPLY WITH THIS ORDER BUT DID SUBMIT AN MCP ELEVEN MONTHS AFTER THE A.O. SCHEDULE DATE. DURING THE PERIODS OF BOTH OF THE NPDES PERMITS AND UNTIL 1985, THE CITY HAD NO DISCHARGE FROM THEIR PERMITTED OUTFALL AS ALL NINE LIFT STATIONS WERE INOPERATIVE AND NO WASTEWATER COULD REACH THE TREATMENT PLANT. DURING THIS PERIOD, THE CITY HAS NINE SEPARATE, UNPERMITTED DISCHARGE POINTS ALLOWING UNTREATED WASTEWATER TO ENTER TROBLESOM CREEK. IN LATE 1985, THE CITY REPLACED THE NINE LIFT STATIONS THEREBY ALLOWING THE WASTEWATER TO REACH THE TREATMENT PLANT. HOW- EVER, SINCE A TIMELY RENEWAL APPLICATION WAS NOT RECEIVED BY EPA, THE TREATMENT PLANT DISCHARGE IS NOT COVERED BY AN NPDES PERMIT.