Respondent is the owner and operator of a permitted combined sewer system in New Jersey. EPA conducted compliance evaluation inspections of the CSS on August 13 and 14, 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, failure to develop an O&M Plan and failure to develop and maintain an FIAA. This Order establishes a compliance schedule to address all violations identified during the inspections.