City of Corpus Christi, Texas Clean Water Act Settlement

(Washington, D.C. – September 25, 2020) - Today, the U.S. Environmental Protection Agency (EPA) announced a settlement with the City of Corpus Christi to improve its sewer system, which, with more than 1,100 miles of sewer lines and more than 100 lift stations, is one of the largest sewer systems in Texas.

• Overview
• Violations
• Injunctive Relief
• Pollutant Reduction
• Health Effects and Environmental Benefits
• Civil Penalty
• Comment Period
• Contact

Overview of Sewer Authority and Facilities

The city of Corpus Christi (the City) owns and operates one of the largest separate sewer systems in Texas, consisting of 6 wastewater treatment plants (WWTPs) and a wastewater collection system with more than 1,250 miles of sewer pipe and 100 lift stations

Violations

The United States alleges that the city of Corpus Christi violated Section 301 of the Clean Water Act and terms and conditions of its National Pollutant Discharge Elimination System permits, which set limits for how much of a certain pollutant an entity is allowed to discharge into a waterbody. The City’s alleged violations include effluent limit exceedances, frequent discharges of raw sewage to waters of the United States and failure to prevent sanitary sewer overflows (SSOs) through proper operation and maintenance of its system.

Injunctive Relief

The proposed settlement includes specific requirements to address WWTP exceedances of permitted pollutant limits and SSOs, unintentional discharges of raw sewage from municipal sanitary sewers. The City will conduct a comprehensive assessment of its sanitary sewer system to identify defective sewer pipes and lift stations in poor condition.  The assessment results will be used to prioritize rehabilitation efforts aimed to prevent the occurrence of future SSOs.  During the first four years of implementation of this settlement, the City will focus its efforts on assessing and rehabilitating portions of the city that have historically experienced SSOs, covering roughly 450 miles of sewer. The City will conduct a system-wide capacity assessment and address areas where SSOs have occurred or are predicted to occur, especially during large rain events. The City of Corpus Christi will implement a capacity, management, operation, and maintenance program which includes comprehensive system cleaning and a grease control program to minimize SSOs caused by sewer blockages.  The program also includes measures the City will take to quickly respond to and clean up further sewage releases.  The total cost of implementing these measures is estimated to be approximately $600 million over the 15-year period to complete the injunctive relief. 

Pollutant Reduction

Through the implementation of the proposed Decree, the following estimated annual pollutant reductions will result:

• 489 pounds of total suspended solids;
• 468 pounds of biochemical oxygen demand;
• 76 pounds of total nitrogen; and
• 11 pounds of total phosphorus.

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.
• Biological 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

Civil Penalty

The City of Corpus Christi will pay a civil penalty of $1,136,000 which will be split equally between the United States and the State of Texas.

Comment Period

The proposed settlement, lodged in the U.S. District Court for the Southern District of Texas, Corpus Christi Division, is subject to a 30-day public comment period and final court approval. Information on submitting comment is available at Department of Justice.

Contact for Further Information

James Zimny, Environmental Scientist
Municipal Enforcement Branch
Water Enforcement Division
Office of Enforcement and Compliance Assurance
U.S. EPA
1200 Pennsylvania Ave., NW
Washington, DC  20460
Phone: (202) 564-6551
zimny.james@epa.gov