Since June 2004, the Town has marginally, but consistently violated its total zinc monthly average and daily maximum concentration limits. The Order requires the Town to summarize its past efforts to reduce total zinc in the FacilityÂs influent and effluent and to submit a scope of work and implementation schedule for further investigations that the Town will conduct as part of its development of recommendations for achieving compliance with the water-quality based effluent limitations contained in the NPDES Permit.