THE CITY'S WWTP HAD UNAUTHORIZED DISCHARGES OF SLUDGE RESULTING IN APPROXIMATELY 90 DRY TONS OF ACTIVATED SLUDGE ENTERING THE RECEIVING STREAM OVER THE LAST THREE YEARS; THE CITY FAILED TO PROPERLY OPERATE AND MAINTAIN THE FACILITY, RESULTING IN A SANITARY SEWER OVERFLOW OF APPROXIMATELY 3,000 GALLONS AND A FAILURE TO IMPLEMENT THE CMOM PLAN; THE CITY HAD A PROHIBITED BYPASS OF 0.537 MILLION GALLONS OF UNTREATED WASTEWATER; AND THE CITY FAILED TO COMPLY WITH EFFLUENT LIMITATIONS FOR AMMONIA AND TSS.