Respondent is the owner and operator of a permitted combined sewer system in New Jersey. EPA conducted compliance evaluation inspections of the CSS on March 26-27, 2007 and August 2, 2011. Based on the inspection findings, the Respondent failed to comply with the conditions of its NJPDES permit including failure to develop an adequate O&M Manual, failure to implement a proper O&M program and failure to prevent unauthorized overflows of sewage. EPA issued an amended Order in 2014 to amend the 2013 Order and establish a compliance schedule for the Respondent to both develop an approved O & M Plan and to implement a series of collection system improvement projects, The Respondent has been unable to comply with the approved prioritized combined sewer system project schedule due to significant financial hardship but proposed a new schedule which eliminates a very costly project, modifies certain dates and includes a new project which will eliminate one of the Respondent's CSO points. EPA is satisfied with the proposal and this Administrative Order on Consent (AOC) serves to memorialize this project schedule modification.