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Enforcement

The City Of Meridian, Mississippi Clean Water Act Settlement Information Sheet

(Washington, DC - August 6, 2019) The City of Meridian, MS (City or Meridian) owns and operates approximately 330 miles of sewer pipes that convey wastewater and other pollutants to the City’s two wastewater treatment plants (WWTPs). The collection system includes “sanitary sewers” (i.e., pipes that are designed to carry sewage only). The system’s service population is approximately 40,800.

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Overview of Company 

The City of Meridian, MS (City or Meridian) owns and operates approximately 330 miles of sewer pipes that convey wastewater and other pollutants to the City’s two wastewater treatment plants (WWTPs). The collection system includes “sanitary sewers” (i.e., pipes that are designed to carry sewage only). The system’s service population is approximately 40,800.

The City’s WWTPs discharge to Sowashee Creek, which is a major tributary of the Pascagoula River. Sowashee Creek is listed on Mississippi's 2010 and 2012 Clean Water Act (CWA) Section 303(d) list as impaired for nitrogen and phosphorus, and Mississippi Department of Environmental Quality (MDEQ) has developed Total Maximum Daily Loads (TMDLs) for Sowashee Creek to address previous Section 303(d) listed impairments; including a sedimentation TMDL and an organic enrichment/low dissolved oxygen TMDL.

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Violations

The Complaint seeks injunctive relief and civil penalties and alleges three claims under the CWA and Mississippi State Law.  These claims are: (1) unauthorized discharges from wastewater collection and transmission system, (2) failure to comply with permit condition - proper operation and maintenance, and (3) failure to comply with permit condition - failure to report SSOs.

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Injuntice Relief

The evaluation and rehabilitation of the City’s Wastewater Collection and Transmission System (WCTS) will consist of a multi-phased program, which will result in a prioritized analysis and evaluation of the City's WCTS, the identification of deficiencies, and the correction of deficiencies. Under the Consent Decree (CD), the City will first develop and implement a plan to address the Highway 80 Trunk Line Sanitary Sewer Overflows (SSOs), then the City will prioritize and assess the WCTS to identify areas lacking sufficient capacity and establish Sewer Group priorities for further evaluation and rehabilitation

Early Action Projects (Highway 80 Trunk Line)

The Highway 80 remedial measures will be completed within eight years of the CD. The City will develop and implement a Highway 80 Trunk Line Work Plan and a Highway 80 Trunk Line Rehabilitation Plan pursuant to which the City will conduct sewage flow monitoring and inspections to identify and remediate structural deficiencies in the Highway 80 Trunk Line. The Highway 80 Trunk Line is identified and described in Appendix B of the CD.

Sanitary Sewer Evaluation and Rehabilitation (SSER)

Sewer basins in the City’s WCTS will be prioritized into three groups, numbered 1 through 3, for evaluation and rehabilitation. When developing the three Sewer Groups, the CD requires the City to take into consideration the nature and extent of customer complaints; flow monitoring; the location and cause of SSOs; any remedial measures already undertaken; field crew work orders; any preliminary sewer assessments; and any other relevant information. In addition to the foregoing factors, in determining the Sewer Group priorities, the City shall give priority to the areas near surface waters that have been included on MDEQ’s CWA Section 303(d) list of impaired waters for pathogens and to areas that have been identified by MDEQ as potentially having environmental justice issues (minority and/or low-income neighborhoods).

Rehabilitative needs and corrective actions for Sewer Group 1 will be completed on or before 144 months after the effective date of the CD. All proposed measures for Sewer Group 2 shall be completed within 216 months after the effective date of the CD. The Sewerbasins in Sewer Group 3 will be addressed by the CMOM program required under the CD.

Capacity, Management, Operations, and Maintenance (CMOM) Programs

The CD requires the City to develop and implement the following CMOM programs to address SSOs: Sewer Overflow Response Plan; Emergency Response Plan; Sewer Mapping Program; Information Management System Program; Gravity Sewer System Operations and Maintenance Program; Pump Station and Force Main Operations and Preventative Maintenance Program; Fats, Oils and Grease Control Program; Financing & Cost Analysis Program; and a Legal Support Program.

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Advanced Technology

The CD requires the City to develop and implement an SSO advance remote monitoring program. The City will develop a list and designate chronic SSO locations where it will install and maintain manhole surcharge detecting remote monitoring devices. The remote monitoring devices shall monitor sewer surcharge levels and be designed to send the City real-time alerts of a likely SSO event(s) when the thresholds specified by the City are attained and/or exceeded, thereby improving the City’s sewer operations and responsiveness to SSOs, with the goal of preventing SSOs from occurring at these SSO locations.

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Pollutant Reductions

Through the implementation of the CD, the following estimated annual pollutant reductions will result, based on an annual average of 500,000 gallons of SSOs discharged to waters of the U.S.:

  • 780 pounds of total suspended solids;
  • 746 pounds of biochemical oxygen demand;
  • 1,867 pounds of chemical oxygen demand;
  • 121 pounds of total nitrogen; and
  • 17 pounds of total phosphorus.

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Health Effects and Environmental Benefits

Total suspended solids (TSS) – TSS indicates the measure of suspended solids in wastewater, effluent or water bodies. High levels of TSS in a water body can diminish the amount of light that penetrates the water column and reduce photosynthesis and the production of oxygen. 

Biochemical oxygen demand (BOD) – BOD is an indirect measure of the biologically degradable material present in organic wastes. High BOD means there is an abundance of biologically degradable material that will consume oxygen from the water during the degradation process. It may take away oxygen that is needed for aquatic organisms to survive. 

Nutrients - Excess levels of nitrogen and phosphorus in waters can produce harmful algal blooms. These blooms contribute to the creation of hypoxia or “dead zones” in water bodies where dissolved oxygen levels are so low that most aquatic life cannot survive.

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Civil Penalty

The City will pay a civil penalty in the amount of $276,000 to the United States and the State for its violations of the CWA, to be split evenly.

State Partner

The State, acting through MDEQ, has joined as a co‑plaintiff and brings its own parallel claims under Mississippi State Law, the Mississippi Air and Water Pollution Control Law, Miss. Code Ann. § 49-17-1 et seq. (MAWPCL).  

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For more information, contact:

Sarah Rae
Attorney-Adviser
Water Enforcement Division
U.S. Environmental Protection Agency
1200 Pennsylvania Ave., NW (Mail Code 2243A)
Washington, DC, 20460
(202) 564-2841
rae.sarah@epa.gov

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