PRAC IS THE OWNER OF THE THREE FACILITIES LISTED. EACH OF THESE FACILITIES HAS A NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM (NPDES) PERMIT. DISCHARGE MONITORING REPORTS(DMRS), PERIODIC REPORTS OF TEST RESULTS ON THE EFFLUENT OF THE FACILITY REQUIRED BY THE PERMIT, FILED BY PRAC, HAVE REVEALED VIOLATIONS OF THE EFFLUENT LIMITS IN THEIR PERMITS FOR MANY PARAMETERS. ADDITIONALLY, THERE ARE DEFICIENCIES IN THE DMRS THEMSELVES. THEY FAIL TO REPORT CERTAIN EFFLUENT DATA REQUIRED BY THE PERMITS AND THEY REVEAL A FREQUENCY OF MONITORING FOR CERTAIN PARAMETERS WHICH FAILS TO MEET THE PERMIT REQUIREMENTS. ADDITIONALLY, PRAC HAS OFTEN FAILED TO SUBMIT THEIR REQUIRED QUARTERLY DMRS. A JUDICIAL ORDER DIRECTING PRAC TO COMPLY WITH ITS PERMIT REQUIREMENTS AND CONDITIONS AND THE IMPOSITION OF A CIVIL PENALTY ARE SOUGHT.