EPA v. CITY OF BOZEMAN, MONTANA

Case summary

EPA NPDES inspectors conducted a pretreatment compliance inspection (PCI) at the Bozeman Wastewater Treatment Plant on September 8-9, 2014. Several deficiencies and associated corrective actions were noted. Among those deficiencies were the recurring failures to implement the City?s approved pretreatment program, summarized below. Many of these findings have been identified in previous PCIs and pretreatment audits as well as other communications with the City. Failure to Identify and Locate All Possible IUs Subject to Pretreatment Program and to Characterize IUs? Waste Failure to Prepare, Maintain, and Submit a List of SIUs Inadequate Legal Authority Failure to Update Local Limits Failure to Enforce Local Limits Failure to Control SIUs Through Permit, Order, or Similar Means Failure to Operate Consistent with Respondent?s Legal Authority Failure to Include All Required Elements in SIU Permits Failure to Evaluate SIUs for the Need to Develop a Slug Plan or Other Slug Controls Failure to Conduct Inspections with Sufficient Care to Produce Admissible Evidence Failure to Sample SIUs at Least Annually Failure to Conduct Sampling and Analyses Using Required Methods and Techniques Failure to Create and Maintain Records Failure to Enforce According to the Respondent?s Enforcement Response Plan Failure to Develop and Implement Accurate SNC Procedure Failure to Have Adequate Resources to Implement the Pretreatment Program The Order requires the City to take several actions to address the above failures.

Defendants (1)

• CITY OF BOZEMAN, MONTANANamed in complaintNamed in settlement

Facilities (1)

• CITY OF BOZEMAN WWTP

  255 MOSS BRIDGE ROAD, BOZEMAN, MT, 59718

  Registry ID: 110063101520

Statutes cited

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

Enforcement conclusions (1)

• CITY OF BOZEMAN, MONTANAentered 2015-10-27

  Primary law: CWA

Timeline (4 milestones)

• 2015-10-27Final Order Issued
• 2015-11-05Enforcement Action Data Entered
• 2021-06-08NPDES Closed
• 2021-06-08Enforcement Action Closed