San Antonio Water System (SAWS) Settlement

Overview of Company and Facility Location

The San Antonio Water System (SAWS) provides sewage treatment and wastewater services to San Antonio, Texas.

Violations

The Complaint alleges violations of the Clean Water Act (CWA) in the form of discharges of untreated sewage from SAWS sewage collection system, including sanitary sewer overflows (SSOs), to waters of the United States.  SAWS violated Section 301 of the Clean Water Act and terms and conditions of its National Pollutant Discharge Elimination System (NPSDES) permits.  SAWS alleged violations include over 2,200 SSOs and more than 800 effluent limit violations.

Injunctive Relief

The settlement will address these illegal discharges from SAWS’ publicly-owned treatment works, which includes three waste water treatment plants (WWTPs) and associated collection system. The proposed consent decree will require SAWS to implement comprehensive injunctive relief within 10 years, with a limited exception for certain work to be done in up to 12 years.

The remedial measures include:

• Early action projects to address worst problems within SAWS wastewater collection and treatment system (WCTS);
• Evaluation and rehabilitation of SAWS WCTS;
• Evaluation of WCTS capacity and associated capacity improvement projects; implementation of a Capacity, Management, Operation and Maintenance (“CMOM”) Program to guide how SAWS manages its system in a more proactive manner and identify and address operation and maintenance deficiencies prior to SSOs occurring; and
• Water quality monitoring to identify potential human sources of bacterial contamination in the Upper San Antonio River.

Pollutant Reduction

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

• 8,021 pounds of total suspended solids;
• 7,678 pounds of biological oxygen demand;
• 1,246 pounds of total nitrogen; and
• 178 pounds of total phosphorus.

Health and Environmental Effects

• 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

SAWS will pay a civil penalty of $2.6 million for its Clean Water Act violations, split between the United States and the State of Texas.

State Partners

The State of Texas is a co-plaintiff.

Comment Period

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

For additional information, contact

Joanna Citron Day
Water Enforcement Division
1200 Pennsylvania Avenue, NW
Washington, DC 20460
(202) 564-5568
Joanna Citron Day (day.joanna@epa.gov)