PRASA failed to comply with an April 17, 2002 AO requiring Respondent's Las Marias public water system to install and operate continuous monitoring turbidimeters by July 30, 2002. Respondent was to have certified to EPA that compliance with the Enhanced Interim Surface Water Treatment Rule was achieved by August 14, 2002. On Oct. 28, 2002, EPA issued and Administrative Compliant, Findings of Violation, Notice of Proposed Assessment of a Civil Penalty and Notice of Opportunity to Request a Heraing (the Complaint ).