The Town is in violation of stringent, WQ-based effluent limits for ammonia nitrogen, copper, and nickel. The Order requires the Town to complete a study to evaluate the feasibility of only discharging during portions of the tidal cycle when there is significant dilution in the receiving stream, which would allow the limits to increased. The completed study will include an evaluation of the measures needed to accomplish the tidal discharge program and a proposed implementation schedule If the tidal discharge is not feasible, the study will determine what measures are needed to meet the existing limits, and propose a schedule to implement them.