This complaint was issued following the 6/17/04 AO, which was issued because of violations of EPA's lead and copper rule. In January 2005, DCWASA and EPA entered into a supplemental Administrative Order, for a seperate violation of the lead and copper rule.
This complaint alleges that DCWASA failed to comply with the testing/sampling requirements of 40 CFR subsection 141.80 et al. DC WASA also failed to report annuall to EPA, based on 40 CFR subsection 141.90 et al. DC WAASA did not submit a consistent plan.
WASA is incurring a penalty for failure to fully implement an Administrative Order on consent that required improvements in data management and quality assurance procedures. Improvements are designed to ensure that the Lead and Copper Rule tap sampling pool consists of appropriate locations and to maintain an accurate inventory of service line materials.