EPA v. THE CITY OF MANCHESTER, TENNESSEE

Case summary

OCTOBER 29, 2025 - ADMINISTRATIVE ORDER ON CONSENT On October 21, 2024, EPA inspectors, accompanied by a TDEC inspector, conducted a Compliance Evaluation Inspection {CEI) of the City's STP and WCTS. The inspection was conducted to evaluate the City's compliance with the requirements of Section 301 of the CWA, 33 U.S.C. ?? 1311, the regulations promulgated thereunder, and the Permit. Through the EPA's Integrated Compliance Information System database, inspectors found that the City exceeded permit Sanitary Sewer Overflow (SSO} limitations from January 2024 through December 2024, with 101 wet weather SSOs and four dry weather SSOs. The City violated Part 1.1.2. of their Permit, Section 301(a} of the CWA, 33 U.S.C. ? 1311(a}, and Section 402 of the CWA, 33 U.S.C. ? 1342, by failing to properly operate and maintain its WCTS resulting in SSOs. Within sixty (60) days after the City has satisfied the terms of this Order on Consent as set forth in Paragraphs 15-18, the City shall submit for the EPA's review and approval a final report (Final Report) that includes certification that all requirements of this Order and any other actions required of the Order on Consent have by fully completed. If the EPA determines, after review of the Final Report, that all the requirements of this Order on Consent have been complied with, the EPA will provide notice to the City and this Order on Consent shall be deemed terminated. If the EPA determines that any requirement has not been established or successfully been in place, the EPA will notify the City, provide a list of the deficiencies, and may require the City to address such deficiencies. If so required, the City shall address the list of deficiencies and shall submit a modified Final Report in accordance with the EPA notice. Failure by the City to address the deficiencies shall be a violation of this Order on Consent. Alternatively, the EPA can terminate the Order on Consent upon written notice to the City.

Defendants (1)

• THE CITY OF MANCHESTER, TENNESSEENamed in settlement

Facilities (1)

• MANCHESTER WATER AND SEWER DEPARTMENT

  736 WEST HIGH STREET, MANCHESTER, TN, 37355

  Registry ID: 110009789568

Statutes cited

• CWA 301/307 — Effluent Limitations - NPDES Toxic & Pretreatment Effluent Standards
• CWA 301/402 — NPDES Permit Violations

Enforcement conclusions (1)

• THE CITY OF MANCHESTER, TENNESSEEentered 2025-10-29

  Primary law: CWA

Timeline (2 milestones)

• 2025-10-29Final Order Issued
• 2025-11-18Enforcement Action Data Entered