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� <br /> � • <br /> 33. Any overflow point or other discrete fissure in Respondent's Separate Sanitary Sewer <br /> Collection System from which sewage has been or may be discharged to the waters of the <br /> United States constitutes a"point source,"pursuant to Section 5�2(14}of the CWA, <br /> 33 U.S.C. § 1362(14). <br /> 34. Sanitary sewage is a"pollutant,"pursuant to Section 502(6)of the CWA,33 U.S.C. <br /> § 1362(b). <br /> 35. Respondent has identified 19 Sanitary Sewer Discharges that have occurred since 2Q10. <br /> 36.The table attached to this Order as Attachment B provides a summary of the Sanitary <br /> Sevver Discharge events since 2010, including the date of the event,the location,the <br /> estimated volume discharged,the cause of the event,the weather conditions during the <br /> event,the final disposition of the Sanitary Sewer Discharges,the affected waterway, any <br /> mitigating actions taken by the Respondent,whether the SSO was reported to the Illinois <br /> Environmental Protection Agency(IEPA),and whether there was any observed <br /> discernible environmental harm. <br /> 37. The Sanitary Sewer Discharges detailed in Atta.chment B are"discharges of a pollutant" <br /> from a"point source"to a"navigable water,"as those terms are defined at Section <br /> 542(7), (12) and(I4)of the CWA,33 U.S.C. § 1362(7), (12)and(14), and 40 C.F.R. <br /> § l 22.2. <br /> 38. Respondent has identifted Property Backups that occuned within Respondent's Separate <br /> Sanitary Sewer Collection System and Respondent's Combined Sewer Systetn. <br /> 39. The table attached to this Order as Attachment C provides the number of Property <br /> Backups that occurred due to a hlockage within the private lateral,the number of <br /> Property Backups that occurred due to a blockage within the public main sewer line, and <br /> Property Backups that occurred due to heavy rainfall. <br /> 40. Respondent did not provide the number af Property Backups that occurred within the <br /> Separate Sanitary Sewer System portion or the number of Property Backups that occurred <br /> within the Combined Sewer System portion of the Respondent's collection system. <br /> 41. Respondent does not have a NPDES permit which allows Sanitary Sewer Discharges or , <br /> Unauthorized Combined Sewer Discharges. Respondent's discharges of sewage or other '� <br /> pollutants into any waters of the United St�tes without a NPDES permit, as identified in <br /> either Attachment B or C, are violations of Section 301(a)of the CWA, 33 U.S.C. li <br /> § 1311(a). <br /> COMPLIANCE REQUIREMENTS <br /> Fursuant to Sections 308(a)and 309{a}(3)of the CWA, 33 U.S.C. §§ 1318{a)and 1319(a}(3), <br /> EPA orders that: <br /> 5 <br />