VIOLATIONS OF EFFLUENT LIMITATIONS AND OTHER CONDITIONS IN THE CITY'S NPDES PERMIT, INCLUDING THE FAILURE TO MAINTAIN AND OPERATE THE CITY'S PUBLICLY OWNED TREATMENT WORKS ( POTW ) WHICH RESULTED IN SANITARY SEWER OVERFLOWS AND UNAUTHORIZED DISCHARGES OF WASTEWATERS TO WATERS OF THE UNITED STATES WITH EXCEEDANCES OF EFFLUENT LIMITATIONS FOR TOTAL ZINCE; AND A FAILURE TO DEVELOP APPROPRIATE LOCAL LIMITS FOR INDUSTRIES THAT DISCHARGE TO THE POTW.