On August 25-27, 2015, EPA conducted a Municipal Separate Storm Sewer System (MS4) Audit of the Town. As a result of the Audit, EPA identified violations of the NYSDEC SPDES MS4 General Permit as well as other Clean Water Act violations, such as non-stormwater discharges to drains at the Parma Highway Facility to the Village of Hilton's MS4 and Salmon Creek. The non-stormwater discharges from Parma's Highway Facility were addressed under Information Request and Administrative Compliance Order CWA-02-2016-3006, which was issued on October 29, 2015. This Order, CWA-02-2016-3030, is being issued to address the violations of the MS4 General Permit identified at the time of the Audit, including but not limited to the following: failure to implement and update the Stormwater Management Program (SWMP) Plan; failure to map all Town outfalls and conduct/document a outfall reconnaissance inventory (ORI); failure to develop, implement and enforce a construction stormwater runoff control program; failure to maintain an inventory of post-construction management practices and develop and implement a program that ensures adequate long-term O&M of those practices; and failure to develop and implement a pollution prevention / good housekeeping program. CWA-02-2016-3030 requires the Town to comply with the terms and conditions of the NYSDEC MS4 General Permit.