MAY 23, 2022 - AMENDED ADMINISTRATIVE ORDER ON CONSENT:
On October 6, 2021, the City executed an AOC that required the City, among other requirements, to complete all work under the ICAP no later than January 1, 2022, and submit a proposed Groundwater Control Plan, a Temporary Treatment Plan, and a structural engineering report on the condition of the concrete and structural integrity of each clarifier at the WWTP. The City timely submitted the Temporary Treatment Plan on November 15, 2021, the structural engineering report on December 15, 2021, the proposed Groundwater Control Plan on January 13, 2022, and a supplemental concrete testing repo1i on February 28, 2022.
From June 2019 through December 2021, the City continued to discharge billions of gallons of partially treated wastewater into the Mississippi River in violation of the Permit effluent limits for BODs, BODs percent removal, TSS, TSS percent removal, and fecal coliform.
As of January 2022, the City began treating the daily average dry weather flow of wastewater from the WWTP to comply with the Permit effluent limits. As such, implementation of the approved Temporary Treatment Plan was not necessary. During March 2022 the City failed to comply with the Permit effluent limits for percent removal of total suspended solids due to diluted influent from rainfall, but otherwise complied with the Permit effluent limits. This violation of the Permit effluent limit did not violate the AOC because this Permit