This Complaint proposes a penalty for failing to implement its approved pretreatment program in multiple areas. Violations addressed by the Consent Order include: violations of the City?s manganese limit in its NPDES permit, pass through, failure to submit a complete annual pretreatment report, failure to maintain a list of SIUs, failure to control indirect discharges from SIUs, failure to include all required elements in permits issued to other SIUs, failure to create required sampling records, failure to develop and implement procedures to evaluate significant noncompliance by industrial users, failure to implement procedures to investigate noncompliance, failure to analyze SIU reports, failure to implements the City?s updated pretreatment ordinance, and failure to enforce against industrial users. Violations were observed during the July 11 and 12, 2013 EPA inspection. An Administrative Order on Consent (CWA-08-2014-0014) requiring the City address these violations was entered into on March 7, 2014.
The EPA alleges that the City violated the NPDES permit�s manganese effluent limit as a result of pass through from two City-owned drinking water treatment plants and failed to implement various aspects of its EPA approved pretreatment program. The City and EPA entered into an Administrative Order on Consent on 3/7/14 to address the violations. The City has agreed to pay a civil administrative penalty of $25,000 to resolve its civil penalty liability for these violation