OCTOBER 29, 2025 - ADMINISTRATIVE ORDER ON CONSENT
On October 21, 2024, EPA inspectors, accompanied by a TDEC inspector, conducted a Compliance Evaluation Inspection {CEI) of the City's STP and WCTS. The inspection was conducted to evaluate the City's compliance with the requirements of Section 301 of the CWA, 33 U.S.C. ?? 1311, the regulations promulgated thereunder, and the Permit.
Through the EPA's Integrated Compliance Information System database, inspectors found that the City exceeded permit Sanitary Sewer Overflow (SSO} limitations from January 2024 through December 2024, with 101 wet weather SSOs and four dry weather SSOs.
The City violated Part 1.1.2. of their Permit, Section 301(a} of the CWA, 33 U.S.C. ? 1311(a}, and Section 402 of the CWA, 33 U.S.C. ? 1342, by failing to properly operate and maintain its WCTS resulting in SSOs.
Within sixty (60) days after the City has satisfied the terms of this Order on Consent as set forth in Paragraphs 15-18, the City shall submit for the EPA's review and approval a final report (Final Report) that includes certification that all requirements of this Order and any other actions required of the Order on Consent have by fully completed. If the EPA determines, after review of the Final Report, that all the requirements of this Order on Consent have been complied with, the EPA will provide notice to the City and this Order on Consent shall be deemed terminated.
If the EPA determines that any requirement has not