7/13/10 - CONSENT AGMT AND FINAL ORDER ISSUED, ASSESSING A PENALTY OF $25,000, DUE WITHIN 60 DAYS. DEFICIENCIES IN RESPONDENT'S SEWERAGE INFRASTRUCTURE MOM PROGRAMS FOUND IN THE SELF-ASSESSMENT LED EPA REGION 4 AND RESPONDENT TO ENTER INTO CONSENT AGMT AND CONSENT ORDER FOR COMPLIANCE ( CONSENT AGMT ), NO. CWA-04-2003-4789, FILED ON MARCH 13, 2003, WHICH REQUIRED RESPONDENT TO DEVELOP AND IMPLEMENT VARIOUS MOM PROGRAMS FOR THE UTILITY'S CTS TO ENSURE ELIMINATION OF SANITARY SEWER OVERFLOWS (SSOs). SSOs ARE ANY DISCHARGE TO WATERS OF THE UNITED STATES FROM THE CTS THRU POINT SOURCES NOT SPECIFIED IN AN NPDES PERMIT, AS WELL AS ANY RELEASE OF WASTEWATER FROM THE CTS TO PUBLIC OR PRIVATE PROPERTY THAT DOES NOT REACH WATERS OF THE U.S., SUCH AS A RELEASE TO A LAND SURFACE OR STRUCTURE THAT DOES NOT REACH WATERS OF THE UNITED STATES. RESPONDENT FAILED TO DEVELOP AND/OR IMPLEMENT, IN WHOLE OR IN PART, THE MOM PROGRAMS AS OUTLINES IN THE CONSENT AGREEMENT AND FAILED TO SUBMIT SEMI-ANNUAL REPORTS AS REQUIRED IN THE CONSENT AGMT. DUE TO RESPONDENT'S FAILURE TO COMPLY WITH THE CONSENT AGMT, EPA ISSUED ADMINISTRATIVE ORDER CWA-04-2009-4813, ON OCT 1, 2009, WHICH SUPERSEDES THE CONSENT AGMT. SINCE THE ISSUANCE OF THE CONSENT AGMT, RESPONDENT'S CTS HAS EXPERIENCED SSOs. EPA ALLEGES THAT RESPONDENT HAS VIOLATED SECTION 301(a) OF THE CWA BY DISCHARGED UNTREATED SANITARY SEWAGE CONTAINING POLLUTANTS TO WATERS OF THE U.S. AT LOCATIONS NOT AUTHORIZED BY AN NPDES PERMIT AND BY FAILING TO PROPE