Respondent violated their Clean Water Act NPDES permit by having sanitary sewer overflows from their collection system and by having effluent violations of Biochemical Oxygen Demand (5-day) (BOD) and Total Suspended Solids. The primary effluent violations are the 7 months of BOD monthly average violations from Jan. 2001 to Jan. 2003. Permittee is being Ordered to develop a schedule to bring BOD discharges within effluent limits and to develop a plan to minimize sanitary sewer overflows.