VIOLATIONS OF THE CITY'S NJPDES PERMIT DUE TO UNPERMITTED DISCHARGES AND IMPROPER OPERATIONS AND MAINTENANCE OF THE COMBINED SEWER SYSTEM. RECOMMEND ACTION BE TAKEN TO SECURE INJUNCTIVE RELIEF REQUIRING PERTH AMBOY TO OPERATE AND MAINTAIN ITS SYSTEM IN ACCORDANCE WITH ITS RESPECTIVE NJPDES PERMITS AND THE CWA, TO MAKE CAPITAL IMPROVEMENTS WHERE NECESSARY TO ENSURE COMPLIANCE AND TO OBTAIN A PENALTY FOR THE VIOLATIONS THAT HAVE OCCURRED.