Respondent operates and maintains a WWTP and CSO Outfalls that discharge pollutants to the Hudson River authorized by SPDES Permit. EPA issued the Respondent a RFI on October 4, 2011, pursuant to Section 308 of the CWA, requiring submission of information within thirty (30) calendar days of receipt regarding CSO LTCP development and sewer backups. To date, the Respondent has failed to submit the information required by the RFI, in violation of Section 308 of the CWA. The Order requires the Respondent to appear at the EPA Region 2 office to show cause as to why EPA should not file a complaint and therefore, pollutant reductions are not applicable to the complying actions of this Order.