Respondent failed to comply with certain requirements of Section 405 of the CWA, Disposal or Use of Sewage Sludge, and regulations promulgated there under at 40 C.F.R. Part 503. Specifically, the EPA alleges Respondent land applied sewage sludge in 2016 and 2017 to six
agricultural fields at a sludge application rate exceeding agronomic loading rates, in violation of 40 C.F.R. ? 503.14(d). In addition, in 2017, Respondent land applied sewage sludge on at least four occasions that failed to achieve the required volatile solids reduction percentage, in violation of 40 C.F.R. ?503.15(d).