# City of Helena Pretreatment
> **Administrative - Formal** · FY2021 · — · Final Order With Penalty
## Case
- **Activity ID:** `3602864246`
- **Case Number:** 08-2021-0211
- **Type:** Administrative - Formal
- **Lead:** EPA
- **Outcome:** Final Order With Penalty
- **Penalty assessed:** —
- **Cost recovery:** —
- **Compliance action $:** —
- **Multimedia (multi-env):** —
## Defendants
- City of Helena (complaint) (settlement)
## Summary

The Pretreatment Regulations apply to publicly owned treatment works (POTWs) and to industrial users discharging pollutants to POTWs from non-domestic sources. The Pretreatment Regulations prohibit any discharge to a POTW that causes a violation of the POTW�s NPDES permit or disrupts the POTW�s treatment process. With limited exceptions, POTWs that receive industrial waste are required to develop pretreatment programs. These programs must include mechanisms to ensure that industrial users comply with pretreatment standards and requirements, which include enforcement if necessary. EPA has direct implementation authority for the pretreatment program in Montana, which means EPA directly oversees the implementation of pretreatment programs in Montana. The City of Helena (City) POTW has an EPA approved pretreatment program and is considered a control authority with regard to the Pretreatment Regulations in their service area.

EPA inspectors conducted a pretreatment compliance audit (PCA) at the City of Helena on September 11-13, 2017. Several deficiencies and associated corrective actions were noted. Among those deficiencies were the recurring failures to implement the City�s approved pretreatment program. On May 14, 2020, The EPA sent a Letter of Violation to the City of Helena. On September 2, 2021, the EPA issued an Administrative Order for Compliance (AO) to the City of Helena
The AO requires the City to comply with all requirements of its NPDES permit and 40 C.F.R. 

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*Source: [EPA ECHO](https://echo.epa.gov/) · AI Analytics · CC0 1.0*