REFERRAL FOR PENALTIES AND INJUNCTIVE RELIEF WITH RESPECT TO VIOLATIONS OF THE CITY'S NPDES PERMIT CONDITIONS AND SECTION S 301 AND 401 OF THE CLEAN WATER ACT. SPECIFICALLY, THE CITY IS ALLEGED TO HAVE ALLOWED DISCHARGES OF SEWAGE IN EXCESS OF EFFLUENT LIMITS, COMBINED SEWER OVERFLOWS IN A MANNER INCONSISTENT WITH THE NINE MINIMUM CONTROLS, AND SANITARY SEWER OVERFLOWS IN VIOLATION OF PERMIT PROHIBITIONS AGAINST SSOS. ADDITIONALLY, THE CITY IS ALLEGED TO BE IN VIOLATION OF PERMIT CONDITIONS RELATING TO THE FACILITY'S TREATMENT CAPACITY. EPA SEEKS PRIMARILY INJUNCTIVE RELIEF; THE CITY MAY HAVE INABILITY TO PAY ISSUES WITH RESPECT TO PENALTIES. $64,800 CIVIL PENALTY EFF. LMTS VIOLS: TSS, BYPASSES AND CSOS CITY WILL CONDUCT A LTCP FOR CSOS, PERFORM STORMWATER MANAGEMENT SEP