The Respondent owns and operates the NJPDES permitted combined sewer systems (CSS) located in the Townships of North Bergen and Guttenberg, New Jersey. EPA and EPA contractors conducted compliance evaluation inspections of the CSS on August 21, 2014. Based on the inspection findings, the Respondent failed to comply with the conditions of its NJPDES permit including failure to prevent dry weather overflows, failure to adequately identify, document, investigate and report DWOs, and failure to properly operate and maintain assets of the CSS. This Order establishes a compliance schedule to address all violations identified during the inspection. The pollutant reductions and cost estimates in the CCDS were estimated for the elimination of DWOs. Additional costs and pollutant reductions are unknown at this time and will be determined as projects are developed in response to this AO.