Respondent is the owner and operator of a permitted combined sewer system in New Jersey. EPA conducted compliance evaluation inspections of the CSS on September 10-12, 2008 and August 3, 2011. Based on the inspection findings, the Respondent failed to comply with the conditions of its NJPDES permit including failure to implement a proper O&M program and failure to prevent unauthorized overflows of sewage. This Order establishes a compliance schedule to address all violations identified during the inspections.