Petitioner, City of Moscow, (“Petitioner” or “Moscow”) operates a publicly owned treatment works (“POTW”) in Moscow, Idaho, adjacent to Paradise Creek near the Washington border. Moscow filed a Petition for Review (“Petition”) seeking revision of several permit conditions in a final Clean Water Act (“CWA”) National Pollutant Discharge Elimination System (“NPDES”) permit decision issued by U.S. Environmental Protection Agency, Region X (“Region”), for the discharge of treated waters into Paradise Creek.