The Respondent is a permitted Municipal Separate Storm Sewer System (MS4) that received permit coverage from NJDEP on April 4, 2004 and was the subject of an EPA audit from June 14-16, 2011. On November 9, 2011, EPA issued an Administrative Order (CWA-02-2012-3003) for violations observed during the audit. There is no injunctive relief for this show cause order as it was previously calculated under CWA-02-2012-3003. The order requires the City to come to EPA Region 2 and show cause as to why EPA should not file a complaint.