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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 502(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(6). <br /> 35. Respondent has identified 19 Sanitary Sewer Discharges that have occurred since 2010. <br /> 36. The table attached to this Order as Attachznent B provides a summary of the Sanitary <br /> Sewer 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 Attachment B are "discharges of a pollutant" <br /> from a"point souxce"to a"navigable water,"as those terms are defined at Section <br /> 502(7), (12) and(14) of the CWA, 33 U.S.C. § 1362(7), (12) and(14), and 40 C.F.R. <br /> § 1222. <br /> 38. Respondent has identified Property Backups that occurred within Respondent's Separate <br /> Sanitary Sewer Collection System and Respondent's Combined Sewer System. <br /> 39. The table attached to this Order as Attachment C provides the number of Property <br /> Backups that occurred due to a blockage within the private lateral, the number of <br /> Property Bacicups 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 of 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 States 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. <br /> § 1311(a). <br /> COMPLIANCE REQUIREMENTS <br /> Pursuant 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 />