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E-IO I I I I I I I I I I I I I I I I I I I - 10 - d. The above violations total 5 in number. 8. The detection limit for TRC is 0.05 mg/l using the amperometric titration method. ~9. Metro has discharged detectable amounts of TRC to the South Platte River on each day from January 1, 1982 to the present. 10. Metro has discharged more than 0.05 mg/l TRC, as measured by a single grab sample, on each day from January 1, 1982 to the present. 11. Metro's facility is and was from January 1, 1982 to the present incapable of discharging effluent with 0.05 mg/l TRC or less while simultaneously meeting the fecal coliform limit set forth in the 1979 permit. 12. Metro's discharge of more than 0,05 mg/l TRC, as measured by a grab sample, exceeds the 0.05 mg/l instantaneous maximum TRC parameter set forth in the 1979 permit. 13. Metro has never achieved the 1.5 mg/l limit set forth in the 1979 permit, measured as both 30-day and 7-day averages, for NH3-N, 14. Metro has consistently violated the NH3-N 1.5 mg/l 30 day average and the 1.5 mg/l 7 day average parameters set forth in the 1979 permit on each day from July 1, 1983 to the present. 15. Metro was required by the federal pretreatment regulations codified at S 40 C,F.R. 403(b) to have obtained approval of Metro's pretreatment program by July 1, 1983. 16. Metro did not submit its pretreatment program to EPA for approval until September 30, 1985. 17. Metro did not attain approval of its Pretreatment Program until August 1, 1986. 18. Metro was in violation of 40 C.F.R. S 403.8(b) on each day from July 1, 1983 through July 31, 1986. 19. Metro was in violation of its permit requirements for pretreatment on each day from June 30, 1983 through July 31, 1986. 20. Metro has periodically discharged pollutants to the Burlington Ditch from March 20, 1986 to the present.