MAY 9, 2025 - ADMINISTRATIVE ORDER ON CONSENT
On August 13, 2024, the EPA and MDEQ conducted a Compliance Evaluation Inspection (CEI) at the Facility to evaluate the Facility'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 2019 NPDES Permit. The CEI identified several violations of the CWA and the 2019 NPDES Permit, including
exceedances of effluent limits established in the 2019 NPDES Permit. In addition, the CEI found that the Town violated the Operations and Maintenance Requirements Section of the 2019 NPDES Permit by having inoperable aeration in Lagoon Cell No. #1 and an inoperable rotating biological contactor ( RBC ) in Lagoon Cell No.3. The EPA's findings and recommendations were summarized in a CEI Report
dated October 3, 2024.
On January 17, 2025, the EPA sent the Town a Notice of Violation (NOV)/Show Cause letter outlining the effluent limit and operation and maintenance violations of the 2019 NPDES Permit. Specifically, from October 2021 through September 2024, the Town exceeded the effluent limitations for Ammonia-Nitrogen (Weekly Average) (4 of the last 12 quarters); and E. Coli.
On February 12, 2025, the EPA and the Town held a Show Cause meeting during which the Town outlined its potential plans to place a staff gauge at the outfall; repair
and place in service the aerators in Lagoon Cell No.1, repair and place in service the rotating