EPA v. CITY OF STARKVILLE
Unilateral Administrative Order Without Adjudication
Case summary
SEPTEMBER 30, 2025 - ADMINISTRATIVE COMPLIANCE ORDER This Administrative Compliance Order (Order) is issued to City of Starkville Public Water System (Respondent) pursuant to the authority vested in the Administrator of the United States Environmental Protection Agency (EPA) by Section 1414(g) of the Safe Drinking Water Act (SDWA), 42 U.S.C 300g-3(g). The Administrator has delegated this authority to the Regional Administrator of EPA Region 4, who has, in turn, delegated this authority to the Director of the Enforcement Compliance and Assurance Division. Respondent owns and/or operates the City of Starkville public water system (PWS), located in Starkville, Oktibbeha County, Mississippi, as defined by Section 1401(4) of the SDWA, 42 U.S.C. 300f(4), and 40 C.F.R. 141.2. Respondent's ownership and/or operation of the System makes it a supplier of water within the meaning of Section 1401(5) of the SDWA, 42 U.S.C. 300f(5), and 40 C.F.R. 141.2. Respondent's PWS provides piped water for human consumption and regularly serves at least 15 service connections and/or at least 25 residents and is therefore a community water system (CWS) as defined by Section 1401(15) of the SDWA, 42 U.S.C. 300f(15), and 40 C.F.R. 141.2.Section 1433(a)(1)(A) of the SDWA requires CWSs serving more than 3,300 persons to conduct a Risk and Resilience Assessment (RRA) of its system. A CWS serving a population of more than 3,300 but less than 50,000 was required to certify to the EPA that it had complete and/or revised its ERP no later than December 31, 2021. See 42 U.S.C. 300i-2(b). A CWS serving a population of more than 3,300 persons is required to maintain copies of its RRA and ERP (including any revisions thereto) for five years after the date on which the certification(s) of such RRA and/or ERP was submitted to the EPA. See Section 1433(d) of the SDWA, 42 U.S.C. 300i-2(d). Respondent's CWS serves a population between 3,301 and 49,999 people. On June 2 - 3, 2025, 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 is required to maintain onsite pursuant to Section 1433(d) of the SDWA. During the review of the ERP, the EPA inspection team determined that the ERP did not contain strategies and resources to improve the resilience of the system, including the physical security and cybersecurity of the system. Therefore, the EPA alleges that Respondent failed to comply with Section 1433(b) of the SDWA, 42 U.S.C. 300i-2(b), for certifying an incomplete ERP to the EPA. Based on the FINDINGS, and pursuant to the authority of Section 1414(g) of the SDWA, 42 U.S.C. 300g-3(g), the EPA is issuing this Order, to place the Respondent on an enforceable schedule to comply with Section 1433 of the SDWA, 42 U.S.C. 300i-2. The EPA hereby ORDERS: By January 31, 2026, Respondent shall develop an ERP which includes all of the requirements of this Order.
Defendants (1)
- CITY OF STARKVILLENamed in settlement
Facilities (1)
STARKVILLE WASTEWATER TREATMENT FACILITY
305 SAND ROAD, STARKVILLE, MS, 39759
Registry ID: 110002307343
Statutes cited
- SDWA 1433 — Intentional Acts
Enforcement conclusions (1)
CITY OF STARKVILLEentered 2025-09-30
Primary law: SDWA
Timeline (2 milestones)
- 2025-09-30Final Order Issued
- 2025-09-30Enforcement Action Data Entered
Case metadata
- EPA activity ID
- 3604560871
- Case number
- 04-2025-5082
- Lead agency
- EPA
- EPA region
- 04
- Voluntary self-disclosure
- No
- Primary statute
- Intentional Acts
Sourced verbatim from EPA ECHO Enforcement Case Report for case 04-2025-5082 . Bulk data: ICIS-FEC download summary.
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