On August 31, 2016, EPA conducted an inspection of the Respondent's Sanitary Sewer System (SSS). As a result of the inspection, EPA identified that the County had not developed written Operation and Maintenance (O & M) procedures for its collection systems. In addition, the County has one (1) constructed sanitary sewer overflow (SSO) upstream of its Wastewater Treatment Plant (WWTP) that is unpermitted. This Administrative Order requires the Town to develop written O & M procedures and either eliminate the SSO or seek SPDES permit coverage.