Pursuant to Section 309(a) of the Clean Water Act, EPA Region 10 has issued a compliance order to the City of Culdesac, Idaho (City) for violations of the CityÂs NPDES permit (Permit Number ID0024490). The Permit contains water quality based effluent limits for total residual chlorine (TRC) that are not quantifiable using EPA approved analytical methods. The permit states that the permittee will be in compliance if TRC is at or below the compliance evaluation level of 0.1 mg/l. The corresponding loading limits for TRC are based on the water quality based limits, not 0.1 mg/l. From September 2011 through December 2011, the City had 96 violations of its effluent loading limits for TRC. The compliance order specifies interim effluent loading limits based on 0.1 mg/l for TRC and requires the City to report the monitoring results on the monthly discharge monitoring reports.