MAY 9, 2025 - ADMINISTRATIVE ORDER ON CONSENT
On January 30-31 and February 3, 2023, the EPA and MDEQ conducted a Compliance Evaluation Inspection (CEI) at the Facility to evaluate the City's compliance with the requirements of Sections 301(a) and 402 of the CWA, 33 U.S.C. ?? 1311{a) and 1342, the regulations promulgated thereunder, and the 2021 NPDES Permit. The CEI identified potential violations, including exceedances of effluent limits in the 2021 NPDES Permit, potential operations and maintenance violations, and potential Bypass violations. The EPA's findings and recommendations were summarized in a CEI Report dated June 8, 2023.
On August 6, 2024, the EPA sent the City a Notice of Violation (NOV)/Show Cause letter outlining the effluent limit exceedances and the proper operations and maintenance violations of the 2021 NPDES Permit. Specifically, from April 2021 through March 2024, the City exceeded the effluent limitations for Biochemical Oxygen Demand, 5- day (BODs) {9 violations); BODs % removal {6
violations); Total Copper (6 violations); f. Coli. (1 violation); Ammonia-Nitrogen (3 violations);Total Suspended Solids (TSS) (4 violations); and TSS % removal (5 violations). The August 6, 2024, NOV also outlined the following operations and maintenance violations identified during the inspection: (1) the float system for the existing lagoon baffle system was failing, (2) the baffle
system was in disrepair, (3) five functioning aerators, which were in use