PRASA failed to comply with a May 2, 2002 AO requiring Respondent's San Sebastian public water system to install and operate continuous monitoring turbidimeters by Aug. 30, 2002. Respondent was to have certified to EPA that compliance with the Enhanced Interim Surface Water Treatment Rule was achieved by Sept. 16, 2002,. On Oct. 28, 2002, EPA issued an Administrative Complaint, Finding of Violation, Notice of Proposed Assessment of a Civil Penalty and Notice of Opportunity to Request a Hearing (the Complaint )