Based on information obtained during an EPA inspection of the Respondent's Sanitary Sewer System (SSS), between January 9, 2009 and December 20, 2013, the Respondent experienced 173 unpermitted discharges of sanitary sewage from its SSS to the Atlantic City Municipal Separate Storm Sewer System (MS4) and receiving water bodies. The discharges were documented and reported by the Respondent to the NJDEP. The Information Request and Administrative Compliance Order requires the Respondent to cease and desist unauthorized discharges of sanitary sewage and requires preparation and submission to the EPA an itemized list of Sanitary Sewer System problem areas regarding oil and grease, surcharging, infiltration, inflow, backups, roots, solids buildup etc. This list shall include a description of actions to be taken to evaluate and remedy each of the identified problem areas, along with a prioritized schedule for the completion of each rehabilitation measure and/or corrective action. In particular, an enhanced Fats, Oils and Grease education program shall be included in the prioritized schedule.