DURING THE PEROID FROM APRIL 27, 1995, THROUGH OCTOBER 15, 1998, THE CITY LAND APPLIED SEWAGE SLUDGE TO VARIOUS PROPER- TIES IN OR NEAR DETROIT LAKES, MINNESOTA, WHICH FAILED TO MEET THE PATHOGEN REDUCTION STANDARDS AS SET FORTH IN 40 CFR SECTION 503.32(B)(2). FURTHER, THE CITY DURING FEBRUARY 1997, FAILED TO CERTIFY COMPLIANCE WITH THE SEWAGE SLUDGE REQUIREMENTS LISTED IN 40 CFR SECTIONS 503.2 AND 503.17, INCLUDING BUT NOT LIMITED TO CERTIFICATION OF SITE RESTRIC- TIONS, MANAGEMENT PRACTICES, CLASSIFICATION OF SLUDGE AS CLASS A OR CLASS B, REDUCTION OF CLASS A OR CLASS B PATHOGEN S, AND REDUCTION OF VECTOR ATTRATION.