SEPTEMBER 3, 2024 - ADMINISTRATIVE ORDER ON CONSENT
On May 9, 2023, the EPA contractors conducted a Compliance Evaluation Inspection (CEI) to assess the overall operation of the Facility. The CEI identified deficiencies related to the operation and maintenance of facilities and systems for collection and treatment including effluent violations of the Permit?s limits and the Permit?s requirements to conduct effluent monitoring and submit discharge monitoring reports (DMRs) conveying the results of effluent monitoring. The EPA?s findings and recommendations were summarized in the CEI Report dated June 28, 2023.
The CEI showed that MBCI was in violation of the Operation and Maintenance Section of the Permit, Part III.B.1.
On February 9, 2024, the EPA sent a Notice of Violations (NOV) letter to MBCI for the violations identified during the CEI as well as its review of ICIS. The NOV noted failure to submit discharge monitoring reports (DMRs) on the scheduled date, for the past 12 quarters, effluent limitation violations of the Permit, failure to sample, lapse in the whole effluent toxicity testing, and failure to properly operate and maintain the facility.
On March 28, 2024, EPA and representatives of MBCI Department of Utilities held a conference call to discuss the Permit violations. MBCI confirmed the Permit violations and drafted a report dated April 12, 2024, explaining the violations and detailing corrective actions to address them.
MBCI has violated the Effl