EPA v. THE CITY OF RAYMOND RAYMOND, MISSISSIPPI

Case summary

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 during the inspection, stirred up solids in some areas of the lagoon due to the depth of the sludge, and (4) and only two feet of clear water in some areas of the lagoon due to the amount of settled solids. Additionally, the NOV explained that on November 9, 2020, MDEQ gave the City an informal compliance schedule (ICS) for suspected fraudulent sampling and reporting of effluent discharges. On December 14, 2021, the City submitted an ICS report to MDEQ. On August 20, 2024, the EPA and the City held a Show Cause meeting whereby the City outlined its plans to ultimately pump the influent of the Facility to a new regional wastewater treatment plant. The City has violated the Effluent Limitations and Monitoring Requirements Section of the 2021 NPDES Permit, issued pursuant to Section 402 of the CWA, 33 U.S.C.? 1342, by discharging pollutants into an unnamed tributary of Snake Creek in excess of the limitations established in its 2021 NPDES Permit for BODs, BODs % removal, Total Copper, E. Coli, Ammonia-Nitrogen, TSS, and TSS % removal. In addition, the City has violated its 2021 NPDES Permit by failing to properly operate and maintain all facilities and systems of treatment and control which are installed or used by the Facility to achieve compliance with the conditions of the permit. Based on the above, the EPA finds that the City is in violation of Section 301(a) of the CWA, 33 U.S.C. ? 1311(a), and the above referenced provisions of its 2021 NPDES Permit. Based on the foregoing EPA FINDINGS and pursuant to the authority of Section 309{a) of the CWA, 33 U.S.C. ? 1319(a), IT IS HEREBY ORDERED AND AGREED TO that the City comply with the following requirements, which are divided into requirements related to the City's existing Facility, and requirements related to the City's construction of a new pump station to a new regional wastewater treatment plant (WWTP) that will replace the existing Facility, which will then be decommissioned.

Defendants (2)

• RAYMOND, MISSISSIPPINamed in settlement
• THE CITY OF RAYMONDNamed in settlement

Facilities (1)

• RAYMOND POTW, EAST

  HINDS BLVD, RAYMOND, MS, 39154

  Registry ID: 110011056007

Statutes cited

• CWA 301 — NPDES Discharge without a Permit
• CWA 301/402 — NPDES Permit Violations

Enforcement conclusions (1)

• THE CITY OF RAYMOND RAYMOND, MISSISSIPPIentered 2025-05-09

  Primary law: CWA

Timeline (2 milestones)

• 2025-05-09Final Order Issued
• 2025-06-04Enforcement Action Data Entered