THE CITY OF ADRIAN VIOLATED ITS PERMIT LIMITS FROM JANUARY 1989 THROUGH APRIL 1989 AND FROM 8/89 THROUGH 2/91 BY EX- CEEDING ITS PERMIT LIMITATIONS FOR TRC, NH3N, FECAL, CD, P, CU, AND ZINC. THE CITY ALSO VIOLATED ITS REPORTING REQUIRE- MENTS BY FAILING TO REPORT FRO SEVERAL PARAMETERS. DURING MAY, JUNE & JULY OF 1989 NUMEROUS VIOLATIONS OCCURRED DUE TO A SINGLE OPERATIONAL UPSET WHICH RESULTED FROM A CYANIDE SPILL BY AN INDUSTRIAL USER. AS THE CITY TOOK IMMEDIATE AC- TION AGAINST THE USER, WE HAVE NOT INCLUDED THESE VIOLATIONS IN OUR COMPLAINT. NOTE, HOWEVER, THAT THE CITY MAY ARGUE THAT THE UPSET WAS ALSO RESPONSIBLE FOR START UP PROBLEMS WITH A NEW FINE BUBBLE AERATION SYSTEM WHICH IT INSTALLED IN 8/89 RESULTING IN ADDITIONAL VIOLATIONS WHICH ARE INCLUDED IN OUR COMPLAINT.