THE CITY OF LOWELL IS IN VIOLATION OF ITS CURRENT NPDES PER- MIT AND ITS PREVIOUS PERMIT IN THE FOLLOWING RESPECTS: EFFLUENT LIMITATION VIOLATIONS - SINCE MAY, 1984, THE CITY OF LOWELL HAS FREQUENTLY VIOLATED THE EFFLUENT LIMITATIONS FOR TOTAL SUSPENDED SOLIDS (TSS) AND BIOCHEMICAL OXYGEN DE- MAND (BOD). THEY HAVE OCCASIONALLY VIOLATED EFFLUENT LIMIT- ATIONS FOR SETTLEABLE SOLIDS AND MAXIMUM FECAL COLIFORM; OPERATION, MAINTENANCE, AND STAFFING VIOLATIONS - 2 OF 4 IN- FLUENT SCREW PUMPS, 3 OF 4 MECHANICAL AERATORS, 1 OF 3 SLUDGE THICKENERS, AND 1 OF 2 ZIMPRO SLUDGE TREATMENT UNITS WERE FOUND TO BE INOPERABLE AT AN INSPECTION BY EPA ON MAY 23, 1986. SIMILAR PROBLEMS FOUND AT INSPECTION IN FEB, 1985 IN ADDITION, THE FACILITY SUFFERS FROM HIGH STAFF TURNOVER AND A LACK OF SUPERVISORY CONTROL; BYPASS VIOLATIONS - THE CITY CONSISTENTLY BYPASSES WASTEWATER DURING STORM EVENTS AT FLOWS SIGNIFICANTLY BELOW THE DESIGN CAPACITY OF THE PLANT. THE BYPASSED FLOW IS DIVERTED INTO THE MERRIMACK RIVER. 22 ADMITTED BYPASSES HAVE OCCURRED OVER THE PAST 2 YEARS;PRE- TREATMENT VIOLATIONS - THE CITY HAS FAILED TO SUBMIT AN AP- PROVABLE PRETREATMENT PROGRAM TO EPA.