REQUEST FOR CIVIL LITIGATION PURSUANT TO SECTION 309 OF THE CWA AGAINST THE PRASA; AND THE COMONWEALTH OF PR. PRASA OWNS AND OPERATES SIXTY WTP'S. THE SERGIO CUEVAS FILTER PLANT, LOCATED IN TRUJILLO ALTO, PR, IS ONE SUCH PLANT. IT PROVIDES POTABLE WATER TO A PORTION OF THE SAN JUAN METROPOLITAN AREA. A NPDES PERMIT, NO. PR0022411, WAS ISSUED TO PRASA FOR THE FACILITY. PRASA HAS BEEN, AND REMAINS, IN SUBSTANTIAL AND CONTINUOUS NONCOMPLIANCE W/PERMIT LIMITS AT THE SERGIO CUEVAS FACILITY. EVIDENCE OF THIS NONCOMPLIANCE IS BASED PRIMARILY ON ADMISS- IONS FILED BY PRASA IN THE FORM OF SELF-REPORTING DISCHARGE MONITORING REPORTS, WHICH WERE SUBMITTED UNDER THE TERMS OF THE PERMIT. WE RECOMMEND THE INITIATION OF A CIVIL ACTION FOR INJUNC- TIVE RELIEF AND FOR ASSESSMENT OF CIVIL PENALTIES, BECAUSE PRASA HAS NOT BEEN RESPONSIVE TO ADMINISTRATIVE EFFORTS OF THIS AGENCY TO SECURE COMPLIANCE, INCLUDING THE ISSUANCE OF ADMINISTRATIVE ORDERS. WE SEEK A JUDICIAL ORDER DIRECTING PRASA TO COMPLY WITH THE PERMIT. WE ALSO SEEK A CIVIL PENALTY. THE REFERRAL OF THIS MATTER IS THE LATEST IN A SERIES OF REFERRALS FOR CIVIL LITIGATION PREPARED BY THE REGION AGAINST PRASA FOR LONG-STANDING CWA VIOLATIONS AT ITS WTPS. COMMENCING IN LATE DEC. 1990, REGION II HAS REFERRED 4 WPTS TO THE DEPT. FOR THE INITIATION OF CIV