RESPONDENT IS CHANGED WITH EFFLUENT LIMITATION VIOLATIONS. IT IS ALLEGED TO HAVE VIOLATED LIMITS SET IN ITS NPDES PERMIT, ISSUED 9/12/90, FOR PH AND TOTAL CYANIDE DURING THE PERIOD OCTOBER 1990 TO APRIL 1991, ON 160 DIFFERENT OCCASIONS. THE ALLEGED VIOLATOR DISCHARGES INTO LAKE ERIE.