BETWEEN 2007 AND 2010, THE CITY REPORTED 468 WET WEATHER OVERFLOWS FROM ITS COMBINED SEWER COLLECTION SYSTEM. DURING THIS SAME PERIOD, THE CITY DID NOT HAVE AN APPROVAL LTCP AND FAILED TO COMPLY WITH THE NINE MINIMUM CONTROL REQUIREMENTS. ALSO, BETWEEN 2005 AND 2010, THE CITY VIOLATED ITS NPDES PERMIT EFFLUENT LIMITS ON 1,266 DAYS.