EPA v. CITY OF CALLAWAY WATER SYSTEM

Case summary

AUGUST 18, 2025 - ADMINISTRATIVE COMPLIANCE ORDER On January 15, 2021, EPA promulgated the Lead and Copper Rule Revisions (�LCRR�). The LCRR included a requirement for water systems to complete initial inventories of lead service lines by October 16, 2024. On October 8, 2024, the EPA finalized the Lead and Copper Rule Improvements (�LCRI�), which built upon the pre-2021 LCR and 2021 LCRR. Relevant to this Order, the LCRI maintained the LCRR compliance date of October 16, 2024, for initial lead service line inventory, notification of service line material, and associated reporting requirements). Until a State, Tribe, or Territory has primary enforcement authority for a new or revised National Primary Drinking Water Regulation (�NPDWR�), such as the LCRR and LCRI, pursuant to SDWA Section 1413, 42 U.S.C. � 300g-2, only the EPA can enforce the NPDWR pursuant to SDWA Section 1414(a)(2), 42 U.S.C. � 300g-3(a)(2). Although the Florida Department of Environmental Protection (FDEP) administers the Public Water Supply Supervision Program in Florida pursuant to SDWA Section 1413 of the SDWA, 42 U.S.C. 300g-2, the State of Florida has not been granted primacy by the EPA for implementation and enforcement of the LCRI and/or LCRR as of the date of this Order. Therefore, the EPA currently has primary enforcement responsibility for the SDWA LCRR and LCRI. Pursuant to 40 C.F.R. � 141.84(a) (service line inventory), a water system must develop a service line inventory that identifies the materials of all service lines connected to the public water distribution system. PWSs were required to develop and submit to the State1 an initial service line inventory by October 16, 2024, pursuant to 40 C.F.R. �� 141.84(a)(1) and 141.90(e)(1). The System failed to develop and submit its required initial service line inventory to the State by the October 16, 2024, deadline. Failure to develop an initial inventory by October 16, 2024, requires Tier 2 Public Notification pursuant to 40 C.F.R. Subpart Q of Part 141. The System failed to provide Tier 2 Public Notification to the persons it serves, as required by 40 C.F.R. Part 141, Subpart Q. Failure to submit an initial inventory to the State by October 16, 2024, requires Tier 3 Public Notification pursuant to 40 C.F.R. Subpart Q of Part 141. Within 30 days of completing its initial service line inventory, a water system must inform all persons served at the service connection of lead, galvanized requiring replacement, or lead status unknown service lines pursuant to 40 C.F.R. � 141.85(e)(1). The System has failed to inform all persons served at the service connection that the service line is known to, or has the potential of, containing lead, or such notification has failed to meet the timing, content, or delivery requirements, as prescribed in 40 C.F.R. � 141.85(e). A water system must make the service line inventory publicly available. The System failed to make the service line materials inventory publicly available, or available online. Failure to make the service line materials inventory publicly available requires Tier 2 Public Notification. The System failed to provide Tier 2 Public Notification to the persons it serves, as required. Beginning October 16, 2024, a water system shall deliver public education materials to persons served by the water system at the service connection with a lead, galvanized requiring replacement, or lead status unknown service line, as prescribed. The System failed to deliver the required public education materials to persons served by the water system at the service connection with a lead, galvanized requiring replacement, or lead status unknown service line in accordance as required by 40 C.F.R. �141.85. Based on the findings above, the EPA alleges that the System violated the SDWA, including violations of the NPDWRs.

Defendants (1)

• CITY OF CALLAWAY WATER SYSTEMNamed in settlement

Facilities (1)

• CALLAWAY, CITY OF WATER SYSTEM

  PANAMA CITY, FL

  Registry ID: 110013191777

Statutes cited

• SDWA 1412/1414 — National Drinking Water Regulations

Enforcement conclusions (1)

• CITY OF CALLAWAY WATER SYSTEMentered 2025-08-18

  Primary law: SDWA

Timeline (2 milestones)

• 2025-08-18Final Order Issued
• 2025-08-28Enforcement Action Data Entered