EPA v. CJT GROUP, LLC

Case summary

MAY 28, 2025 - ADMINISTRATIVE ORDER ON CONSENT On June 27, 2024, representatives of EPA conducted an inspection of the Systems, pursuant to its authority under Section 1445(b)(1) of the SDWA, 42 U.S.C. ? 300j-4(b)(1). GA EPD representatives participated alongside EPA. On July 29, 2024, GA EPD submitted a written request for EPA to assist with addressing the Systems? SDWA noncompliance. On August 28, 2024, EPA issued an Emergency Administrative Order (?Emergency Order?) to Respondent, to address the conditions at the Systems that presented an imminent and substantial endangerment to the persons served by the Systems. Such conditions included lack of adequate chlorination at the Systems and holes in the sanitary seals of the wells supplying the Systems. On September 12, 2024, EPA issued a Notice of Noncompliance (?NONC?) and Information Request Letter (?IRL?) to Respondent, to allow Respondent time to review their potential noncompliance and submit documentation of any actions that Respondent has taken to address each instance of noncompliance alleged. On September 30, 2024, Respondent submitted a response to the IRL. The response did not contain any documentation of corrective actions taken, such as photographs, scopes of work, or receipts of purchase; however, Respondent provided narrative responses to the noncompliance and areas of concern alleged. On October 29, 2024, representatives of EPA conducted an inspection of the Systems. Representatives from EPA Region 4 Laboratory Services and Applied Science Division (?LSASD?) were also present to perform chlorine residual and bacteriological sampling at each System. GA EPD representatives participated alongside EPA. On January 2, 2025, EPA issued another NONC and IRL to Respondent, to allow Respondent time to review their potential noncompliance and submit documentation of any actions that Respondent has taken to address each instance of noncompliance alleged. On February 6, 2025, Respondent submitted a response to the IRL. The response did not contain any documentation of corrective actions taken, such as photographs, scopes of work, or receipts of purchase; however, Respondent provided narrative responses to the noncompliance and areas of concern alleged. As of the Effective Date of this AOC, the Respondent has still not provided EPA appropriate documentation of the Systems? compliance with the SDWA, NPDWR, and GaPDWR. The specific noncompliance and the allegations are detailed in the Notices of Noncompliance sent on September 12, 2024, and January 2, 2025. At the time of the Inspections, the Monthly Operation Reports at the Systems were not being completed and submitted to GA EPD as required. A Notice of Violation was issued from GA EPD on February 1, 2024, for failure to provide monthly water operation reports to GA EPD for August 2023 through December 2023. Therefore, the Arlington Terrace, Koinonia Forest Park, and Koinonia Village PWSs are in noncompliance for failure to report to the State the results of measurements and analyses within the first 10 days following the end of the month. At the time of the June 2024 Inspection, the Systems did not adhere to the required retention policy for records. Missing records include, but are not limited to, Stage 2 disinfection byproduct sampling plan, Stage 2 disinfection byproduct monitoring results, Consumer Confidence Reports, and bacteriological sample siting plan. Therefore, the Arlington Terrace, Koinonia Forest Park, and Koinonia Village PWSs are in noncompliance. Based on the foregoing FINDINGS, and pursuant to the authority of Section 1414(g) of the SDWA, EPA is issuing this AOC to place Respondent on an enforceable schedule to comply with 40 C.F.R. Part 141 and the GaPDWRs. The requirements of the August 27, 2024, Emergency Administrative Order shall be superseded by this AOC as of the Effective Date of this Agreement.

Defendants (1)

• CJT GROUP, LLCNamed in settlement

Facilities (1)

• ARLINGTON TERRACE MHP

  AMERICUS, GA

  Registry ID: 110013129630

Statutes cited

• SDWA 1412 — Nat'l Drinking Water Compliance Schedule - Effective Date

Enforcement conclusions (1)

• CJT GROUP, LLCentered 2025-05-28

  Primary law: SDWA

Timeline (3 milestones)

• 2025-05-28Final Order Issued
• 2025-06-11Enforcement Action Data Entered
• 2026-05-19Enforcement Action Closed