REFERRAL FOR PENALTIES AND INJUNCTIVE RELIEF WITH RESPECT TO VIOLATIONS OF THE CITY'S NPDES PERMIT CONDITIONS AND SECTION 301 AND 402 OF THE CLEAN WATER ACT. SPECIFICALLY, THE CITY IS ALLEGED TO HAVE ALLOWED DISCHARGES IN EXCESS OF EFFLUENT LIMITS, FAILED TO MONITOR THE FLOW OF THE RECEIVING STREAM AND THE LOAD LIMIT, BYPASSED THE PLANT WITHOUT MAXIMIZING FLOW TO THE WWTP, AND FAILED TO REPORT THE DURATION OF OVER- FLOWS. EPA SEEKS INJUNCTIVE RELIEF AND PENALTIES.