The Town violated a previously issued AO which required compliance with all provision of 40 CFR Part 141, Subpart L (Stage 1 Disinfectants and Disinfection Byproducts Rule) including the maximum contaminant level (MCL) for haloacetic acids. The MCL violation triggered the filtration requirement under 40 CFR Part 141, Subpart L (Surface Water Treatment Rule).
The consent decree establishes an enforceable schedule to design, build, and operate a filtration plant. Injunctive relief includes the cost to design and construct a membrane filltration plant. It also includes the cost for the necessary chadwick plant upgrades and the O&M for one year of operation and the cost associated with public notification.