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Enforcement

Total Environmental Solutions, Inc. (TESI) Consent Decree Modification

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Overview of Company

Total Environmental Solutions, Inc. (TESI) owns and operates 161 individual sewage treatment plants and the connection collection system in Louisiana. 

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Violations

On December 21, 2000, the Court entered a consent decree between the U.S. EPA and the Louisiana Department of Environmental Quality (LDEQ) and TESI for:

  • discharges of pollutants into navigable waters of the United States in violation of Section 301 of the Clean Water Act (CWA) and, 
  • violations of terms, conditions and limitations of its Louisiana Pollutant Discharge Elimination System (“LPDES”) permits.

While under the December 21, 2000 consent decree, violations continued and the parties found that facility-specific problems existed.

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Injunctive Relief

This modification includes both short-term and long-term remedial measures for the collection system and sewage treatment plants (STPs).

The remedial measures include:

  • Conducting and submitting comprehensive diagnostic evaluation reports for all pond STPs. A pond STP utilizes a large holding or detention pond or lagoon, usually constructed with earthen dikes, to contain wastewater while sedimentation and biological oxidation occur.
  • Developing and implementing operations and maintenance plans for all mechanical and pond STPs. A mechanical STP utilizes mechanical means to aerate a mix of wastewater and activated sludge so that organic components within the wastewater are decomposed by biological processes.
  • Developing and implementing specific operations and maintenance programs for managing the collection system associated with each STP.
  • Developing and implementing long-term, site-specific control plans for each STP.
  • Developing and implementing utility-wide measures to ensure proper implementation of LPDES permit requirements, including: sampling of effluent, employee safety, and staff training.
  • Required submitting of reports for review and approval by EPA and LDEQ.
  • Specifying procedures for TESI to submit final STP reports to EPA and LDEQ requesting approval. Upon approval of the long-term, site-specific control plans, the individual STP will be terminated from the modified consent decree. 

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Health and Environmental Benefits

In the last five years, more than 2,739 effluent limitation violations have occurred, impacting the surrounding environment and the receiving waters of the United States. 

Pollutant Total in last 5 years
Biological Oxygen Demand 639
Chlorine, total residual 20
Coliform, fecal general 192
Nitrogen, ammonia total [as N] 403
Oxygen, dissolved [DO] 60
pH 95
Solids, total suspended 1330

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State Partners

The State of Louisiana is a co-plaintiff.

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Comment Period

The proposed settlement, lodged in the U.S. District Court for the Northern District of Iowa, is subject to a 45-day public comment period and final court approval.  Information on submitting comments is available at the Department of Justice website.

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For More Information, Contact:

Dane A. Wilson
Water Enforcement Division
1200 Pennsylvania Ave, NW (Mail Code 2243A)
Washington, DC 20460
(202)564-0544
wilson.dane@epa.gov

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