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 amends the 2013 AO and establishes a compliance schedule for the City to both develop an approved O & M Plan and to implement a series of collection system improvement projects.