On August 14, 2014, EPA issued an Administrative Compliance Order to the City after determining, through a compliance audit conducted by EPA in August of 2013, that the City, at its combined sewer system (CSS), is in violation of several conditions and limitations of its NJPDES permit. Violations include: failure to develop an adequate operation and maintenance (O & M) plan and manual; failure to properly operate and maintain its CSS; failure to prevent intrusion of receiving water into its CSS; failure to develop a Facility Inventory and Assessment Analysis; and failure to discontinue discharges not covered by its permit or apply for the appropriate NJDPES permit for discharges not covered by its permit. The ACO requires the City to submit to EPA, and implement, an itemized list of and schedule for completion of all rehabilitation measures and/or corrective actions necessary to achieve and maintain compliance with its permit, including actions to address violations found during EPAÂs audit; develop, submit to EPA and implement an adequate O & M plan and manual; and develop and submit to EPA quarterly reports documenting compliance with the ordered provisions of the ACO.