Respondent is the owner and operator of a permitted combined sewer system in New Jersey. EPA conducted compliance evaluation inspections of the CSS on March 26-27, 2007 and August 2, 2011. Based on the inspection findings, the Respondent failed to comply with the conditions of its NJPDES permit including failure to develop an adequate O&M Manual, 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.