SEPTEMBER 3, 2024 - ADMINISTRATIVE ORDER ON CONSENT
to assess the overall operation of the Facility. The CEI identified violations of the Permit, including a failure to properly operate and maintain facilities and systems for collection and treatment, violations of the Permit?s effluent limits, and violations of the Permit?s requirements to conduct effluent monitoring and submit DMRs reporting 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. Specific Operations and Maintenance violations are listed starting on page 9 of the report, Attachment B.
On February 9, 2024, the EPA sent a Notice of Violations (NOV) letter to MBCI regarding violations identified during the CEI as well as its review of ICIS. The NOV noted failure to submit DMRs on the schedule dates, , 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, the 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 Effluent Limitations and Monitoring Re