This AO was developed as a result of an inspection. EPA identified that the City was not complying with the best management practices (BMPs) for its combined sewer system, in accordance with its SPDES Permit. This Administrative Order requires the City to develop and implement written maintenance and inspection procedures for its collection system, in accordance with the BMPs of its SPDES Permit. As such there is no pollutant loading reductions. Injunctive relief focuses on the development of written maintenance and inspection procedures. For purposes of this AO, it is assumed that an overall cost of $3,000 is required to develop such procedures.