EPA v. EDMODSON COUNTY WATER DISTRICT

Case summary

AUGUST 26, 2025 - ADMINISTRATIVE COMPLIANCE ORDER On October 23, 2018, the SDWA was amended in accordance with the America's Water Infrastructure Act (AWIA) of 2018 (Public Law 115-270). In relevant part, AWIA amended 1433's CWS risk and resilience provisions, 42 U.S.C. 300i-2. On March 12 - 13, 2025, the EPA completed an onsite inspection of Respondent's public water system. During the inspection, the EPA inspection team requested that the Respondent produce its RRA and ERP, which it is required to maintain onsite pursuant to Section 1433(d) of the SDWA. The Respondent produced the System's RRA and ERP for EPA review. During the review of the RRA, the EPA inspection team determined that the document did not assess all of the required elements of 1433(a) of the SDWA. Specifically, the document failed to include the risks to the System from malevolent acts and natural hazards; the resilience of the pipes and constructed conveyances, physical barriers, distribution facilities, electronic, computer, and other automated systems which are used by the System; monitoring practices of the System; financial infrastructure of the System, the use, storage, and handling of various chemicals by the System; and the operation and maintenance of the System, as required by Section 1433(a)(1) of the SDWA. During the review of the ERP, the EPA inspection team determined that the document did not assess all of the required elements of 1433(b) of the SDWA. Specifically, the document failed to include strategies and resources to improve the resilience of the system, including the physical security and cybersecurity of the system; plans and procedures that can be implemented, and identification of equipment that can be utilized, in the event of a malevolent act that threatens the ability of the community water system to deliver safe drinking water; actions, procedures, and equipment which can obviate or significantly lessen the impact of a malevolent act on the public health and the safety and supply of drinking water provided to communities and individuals; and strategies that can be used to aid in the detection of malevolent acts or natural hazards that threaten the security or resilience of the System, as required by Section 1433(b) of the SDWA. Therefore, the EPA alleges that Respondent failed to comply with Section 1433(a) of the SDWA, 42 U.S.C. 300i-2(a) and Section 1433(b) of the SDWA, 42 U.S.C. 300i-2(b), by certifying an incomplete RRA and ERP to the EPA. Furthermore, the Respondent has not provided a complete RRA or ERP to the EPA to date. EPA is issuing this Order to address the violations enumerated above and to place the Respondent on an enforceable schedule to comply with the requirements of Section 1433 of the SDWA.

Defendants (1)

• EDMODSON COUNTY WATER DISTRICTNamed in settlement

Facilities (1)

• EDMONSON CO WATER DISTRICT-WAX WTP

  PO BOX 208, BROWNSVILLE, KY, 42201

  Registry ID: 110013027278

Statutes cited

• SDWA 1433 — Intentional Acts

Enforcement conclusions (1)

• EDMODSON COUNTY WATER DISTRICTentered 2025-08-26

  Primary law: SDWA

Timeline (3 milestones)

• 2025-08-26Final Order Issued
• 2025-08-28Enforcement Action Data Entered
• 2025-10-24Enforcement Action Closed