BUNNELL HAS BEEN VIOLATING ITS NPDES PERMIT LIMITS SINCE APRIL, 1987. THE PERMITS LIMITS ARE WATER QUALITY STANDARD BASED LIMITS AND THE EXISTING WWTP IS NOT CAPABLE OF MEETING THOSE LIMITS WITHOUT CHANGES REQUIRING CONSTRUC- TION. BUNNELL HAS HAD THE FUNDS TO UNDERTAKE THE NEEDED CONSTRUCTION BUT HAS REFUSED TO DO THAT. BUNNELL IS USING THOSE FUNDS TO SHOW CREDIT WORTHINESS FOR A FARMERS HOME ADMINISTRATION GRANT AND LOAN TO EXPAND THE PLANT AND TO CONSTRUCT A NEW DRINKING WATER TREATEMENT FACILITY.