EPA issued an Adiminstrative Order (AO) to Farmington to address violations of the total phosphorus, total recoverable copper, E. coli, biochemical oxygen demand, total suspended solids, and the whole effluent toxicity (WET) limits contained in its NPDES permit. The AO requires the Town to determine within 6 months whether year-round or seasonal land application is feasible and propose an implementation schedule to achieve full permit compliance by June 30, 2012. If year-round land application is not feasible, then, within one year of receipt of the AO, the Town must submit a wastewater treatment facility (WWTF) upgrade facilities plan with recomendations and a proposed schedule to achieve full permit compliance by June 30, 2012. The design and construction schedule for the selected alternative will be incorporated into the AO. The AO includes interim limits for specific parameters that are in effect from the date of the Town's receipt of the AO until the earliest of: (1) the facilities plans improvements are fully operational; or (2) EPA determines that the Town has not complied with the interim AO milestones. The AO also requires the Town to prepare and submit a phosphorus optimization plan assessing the cost and feasibility of implementing interim process control and chemical addition alternatives, and alternatives to minimize influent phosphorus levels at the WWTF. If year-round land application is infeasible: (1) the Town must prepare a copper optimization engineering r