7/2/13 - ADMINISTRATIVE ORDER ON CONSENT ISSUED.
ALLEGATIONS:
ON AUG 29, 2012, EPA CONDUCTED A COMPLIANCE EVALUATION INSPECTION (CEI) OF THE WWTP TO EVALUATE MOSHEIM'S COMPLIANCE WITH THE PERMIT AND THE CWA. THE CEI IDENTIFIED DEFICIENCIES RELATED TO THE OPERATION AND MAINTENANCE OF FACILITIES AND SYSTEMS FOR COLLECTION AND TREATMENT, INCLUDING EXCESSIVE ALGAE GROWN ON THE FINAL CLARIFIERS, IMPROPERLY PRESERVED INFLUENT COMPOSITE SAMPLES AND INOPERABLE SAND FILTERS.
ON DEC 12, 2012, EPA SENT A NOV LETTER, TO MOSHEIM REGARDING THE DEFICIENCIES IDENTIFIED DURING THE INSPECTION. THE NOV ALSO ADDRESSED EFFLUENT LIMITS EXCEEDED FOR pH, TOTAL SUSPENDED SOLIDS, TOTAL NITROGEN AND E. COLI FOR THE PERIOD COVERING JAN 1, 2009 THRU SEPT 30, 2012. THE NOV REQUESTED INFO ON CORRECTIVE ACTIONS PLANNED OR TAKEN TO ADDERESS THE DEFICIENCIES AND EFFLUENT LIMIT EXCEEDANCES.
ON DEC 21, 2012, MOSHEIM PROVIDED A RESPONSE TO THE NOV. THE RESPONSE ADDRESSED ALL OF THE DEFICIENCIES EXCEPT THE INOPERABLE SAND FILTERS, WHICH HAVE BEEN OUT OF SERVICE FOR OVER 4 YEARS.
THEREFORE, MOSHEIM HAS FAILED TO PROPERLY OPERATE AND MAINTAIN THE WWTP IN ACCORDANCE WITH THE PERMIT, FAILED TO COMPLY WITH THE EFFLUENT LIMITS OF ITS PERMIT FOR pH, TOTAL SUSPENDED SOLIDS, TOTAL NITROGEN AND E. COLI AND FAILED TO PROVIDE NOTIFICATION OF A PHISICAL ALTERATION THAT SIGNIFICANTLY CHANGED THE NATURE OR INCREASED THE QUANTITY OF THE POLLUTANTS DISCHARGED WHEN THE SAND FILTERS WERE REMOVED FROM THE WASTEWATER TR