THE CITY OF BRODHEAD (CITY) OWNS AND OPERATEDS A WASTE- WATER TREATMENT FACILITY (PLANT) SERVING 340 HOUSEHOLDS. SINCE 1972, THE CITY HAS BEEN UNABLE TO MEET THE EFFLUENT LIMITATIONS ON ITS DISCHARGE OF POLLUTANTS TO SURFACE WATERS. THOSE LIMITATIONS ARE CONTAINED IN NATIONAL POLLU- TANT DISCHARGE ELIMINATION SYSTEM (NPDES) PERMITS, THE FIRST PERMITS ISSUED BY THE U.S. ENVIRONMENTAL PROTECTION AGENCY (EPA) AND THE LAST PERMIT ISSUED BY THE COMMONWEALTH OF KENTUCKY. AS A RESULT, EPA HAS ISSUED FOUR ADMINISTRATIVE ORDERS TO THE CITY, PLACING IT ON SCHEDULE TO ACHIEVE PERMIT COMPLIANCE. THE CITY HAS FAILED TO ACHIEVE COMPLIANCE IN ACCORDANCE WITH THESE ORDERS. ON FEBRUARY 25, 1986, EPA HELD A SHOW CAUSE MEETING WITH THE CITY TO DISCUSS THE CITY'S NON-COMPLIANCE AND POSSIBLE EPA ENFORCEMENT ACTION. AT THAT TIME, THE CITY REQUESTED THAT EPA CLOSELY MONITOR THE FACILITY FOR SEVERAL MONTHS TO DOCUMENT THAT MINOR EQUIPMENT REPLACEMENT AND OPERATIONAL CHANGES WOULD BRING THE PLANT INTO COMPLIANCE. THIS EFFORT FAILED TO BRING THE PLANT INTO CONSISTENT COMPLIANCE. BOTH EPA AND KENTUCKY HAVE CONDUCTED MULTIPLE-DAY TECH- NICAL ASSISTANCE VISITS (MARCH, 1987 AND JUNE, 1985, RES- PECTIVELY) IN AN EFFORT TO OPTIMIZE THE PERFORMANCE OF THE PLANT. THE CITY HAS NOT IMPLEMENTED THE MAJOR RECOMMENDA- TIONS OF THE TWO STUDIES SUMMARIZING THOSE VISITS.