The Middlesex School in Concord, Massachusetts owns and operates a wastewater treatment facility subject to an EPA-issued NPDES permit that includes effluent limits for copper, aluminum, BOD, seasonal phosphorus and ammonia nitrogen. In 2016, based on the school's violations of certain limits, EPA issued an administrative order requiring the school to submit an engineering evaluation to identify sources of copper in its wastewater, opportunities for source reduction, possible operational modifications of its treatment plant to reduce the quantity of copper, aluminum and phosphorus discharged, and if necessary additional treatment processes to achieve compliance with its permit limits along with a compliance schedule. The school failed to submit the information, and EPA initiated a penalty action. On December 13, 2018, EPA filed a consent agreement and final order. The school has agreed to pay a $5,000 penalty. EPA also issued a separate administrative order establishing a new schedule and additional requirements.