EPA enforcement against wastewater plants and the largest Clean Water Act penalties
2,667 formal cases at 1,546 plants · $73M in penalties · 886 EPA inspections
- Formal cases at plants
- 2,667
- Since FY2020
- 554
- Penalties at plants
- $73M
- Clean Water Act cases
- 9,187
EPA's civil enforcement records name 1,546 of the 12,448 publicly owned wastewater treatment plants in the Klarifi directory in 2,667 formal cases, with $73.3 million in penalties assessed. Across all facility types, EPA has brought 9,187 cases under the Clean Water Act with $7,453.1 million in penalties. The state table links to each state's enforcement page, and the ranking below lists the largest Clean Water Act penalties on record, wastewater plants and industrial dischargers alike. Every case links to its report on EPA's ECHO site.
Enforcement against wastewater plants by state
| State | Formal cases | Since FY2020 | Plants named | Penalties |
|---|---|---|---|---|
| Texas | 456 | 146 | 275 | $9.6M |
| New York | 301 | 48 | 139 | $2.9M |
| Louisiana | 185 | 24 | 80 | $1.3M |
| New Mexico | 161 | 64 | 24 | $717,007 |
| Ohio | 109 | 30 | 83 | $5.2M |
| Idaho | 104 | 17 | 54 | $1.2M |
| Missouri | 103 | 17 | 77 | $2.6M |
| Pennsylvania | 99 | 16 | 61 | $2.6M |
| Massachusetts | 97 | 12 | 38 | $1.4M |
| New Jersey | 89 | 7 | 38 | $1.9M |
| Indiana | 59 | 4 | 31 | $5.7M |
| New Hampshire | 47 | 8 | 19 | $205,950 |
| Illinois | 46 | 16 | 37 | $10M |
| Michigan | 45 | 3 | 31 | $1M |
| South Carolina | 42 | 3 | 24 | $701,222 |
| Tennessee | 42 | 10 | 30 | $2.4M |
| Oklahoma | 41 | 9 | 30 | $496,890 |
| Alabama | 39 | 0 | 28 | $1.2M |
| Nebraska | 39 | 10 | 30 | $1.1M |
| California | 38 | 6 | 26 | $2.4M |
| Kansas | 38 | 10 | 29 | $177,188 |
| Arkansas | 35 | 5 | 22 | $483,649 |
| Iowa | 35 | 5 | 26 | $88,920 |
| Florida | 34 | 0 | 24 | $2.3M |
| Wisconsin | 33 | 16 | 19 | $297,674 |
| Arizona | 31 | 4 | 21 | $927,000 |
| West Virginia | 30 | 15 | 31 | $864,900 |
| Georgia | 28 | 2 | 19 | $3.8M |
| Montana | 28 | 3 | 16 | $712,825 |
| Washington | 26 | 9 | 21 | $589,438 |
| Kentucky | 23 | 0 | 18 | $1.8M |
| Mississippi | 21 | 11 | 19 | $722,158 |
| Colorado | 20 | 5 | 17 | $50,450 |
| Connecticut | 20 | 0 | 14 | $806,380 |
| Alaska | 16 | 3 | 9 | $331,818 |
| Minnesota | 16 | 7 | 13 | $2.8M |
| Virginia | 15 | 0 | 16 | $226,130 |
| Maryland | 13 | 2 | 7 | $1.1M |
| Rhode Island | 13 | 0 | 9 | $283,000 |
| North Carolina | 10 | 0 | 6 | $7,700 |
| Oregon | 10 | 2 | 9 | $64,520 |
| Maine | 6 | 1 | 5 | $27,500 |
| South Dakota | 6 | 1 | 6 | $5,375 |
| Utah | 5 | 0 | 5 | $10,025 |
| North Dakota | 4 | 0 | 2 | $66,650 |
| Wyoming | 4 | 2 | 3 | $12,500 |
| Hawaii | 3 | 0 | 3 | — |
| Delaware | 1 | 1 | 1 | — |
| Vermont | 1 | 0 | 1 | $10,521 |
Full case histories, milestones, violation types and EPA's complete case summaries for every plant are shown with a free Klarifi account. Create one
The 10 largest Clean Water Act penalties
EPA civil cases with a Clean Water Act count, ranked by the penalty assessed or agreed. Cases may include counts under other statutes; the Deepwater Horizon settlement leads the list. Compliance actions are the value of the fixes and upgrades a case required.
| # | Case | State | Date | Type | Penalty | Compliance actions | Source |
|---|---|---|---|---|---|---|---|
| 1 | BP EXPLORATION/MOEX/TRANSOCEAN DEEPWATER/TRITON/GULF OF MEXICO OIL SPILL/DEEPWATER HORIZON (NC) | TX | Apr 2016 FY2010 | Judicial case | $3,367M | $1,944M | ECHO 04-2010-9036 |
EPA's description: “5/9/2011 - COMPLAINT ALLEGES DEFENDANTS VIOLATED CWA SECTIONS 311 AND 301/402. THE VIOLATIONS AROSE FROM OIL DISCHARGES FROM THE MOBILE OFFSHORE DRILLING UNIT, DEEPWATER HORIZON, IN THE GULF OF…” | |||||||
| 2 | ATP Oil & Gas Corp. | TX | Dec 2015 FY2013 | Judicial case | $39M | $5,000 | ECHO 06-2013-1792 |
EPA's description: “Complaint alleging the unlawful discharges of oil and an unpermitted chemical dispersant from the offshore oil and gas production platform, known as the ATP Innovator, into the Gulf of Mexico. A…” | |||||||
| 3 | BP EXPLORATION (ALASKA) INC (BPXA) | AK | Nov 2015 FY2006 | Judicial case | $25M | $61M | ECHO 10-2006-0316 |
EPA's description: “U.S. District Court for the District of Alaska Enters Consent Decree for BP Exploration Alaska (BPXA) Violations of Clean Water Act, Clean Air Act, and Federal Pipeline Safety Laws. On July 13, 2011,…” | |||||||
| 4 | DISTRICT OF COLUMBIA (BLUE PLAINS | DC | Aug 1996 FY1996 | Judicial case | $20M | $110M | ECHO 03-1996-0072 |
| 5 | KOCH INDUSTRIES, INC. | KS | Jul 2009 FY1995 | Judicial case | $15M | — | ECHO 06-1995-0015 |
| 6 | MASSEY ENERGY COMPANY, ET. AL.(NATIONAL CASE)(LEAD) | WV | Apr 2008 FY2005 | Judicial case | $13M | $7.1M | ECHO 03-2005-0380 |
| 7 | SMITHFIELD FOODS, INC. | VA | Feb 2001 FY1996 | Judicial case | $13M | — | ECHO 03-1996-0278 |
| 8 | MOTIVA ENTERPRISES, LLC , ET AL | DE | Jan 2006 FY2001 | Judicial case | $12M | $10M | ECHO 03-2001-0334 |
| 9 | MORTON INTERNATIONAL, INC. (NATIONAL CASE) (LEAD) | MS | Nov 2005 FY1998 | Judicial case | $10M | $42M | ECHO 04-1998-0459 |
| 10 | DOE RUN RESOURCES CORPORATION | MO | Dec 2011 FY2007 | Judicial case | $7M | $66M | ECHO 07-2007-0275 |
Cases by fiscal year
| Fiscal year | At wastewater plants | Penalties at plants | All Clean Water Act cases | Penalties, all CWA |
|---|---|---|---|---|
| FY2018 | 68 | $199,080 | 211 | $4.6M |
| FY2019 | 68 | $162,468 | 230 | $8.9M |
| FY2020 | 58 | $35,100 | 210 | $7.6M |
| FY2021 | 49 | $126,000 | 232 | $4.6M |
| FY2022 | 74 | $851,394 | 247 | $9.2M |
| FY2023 | 87 | $265,940 | 277 | $3.6M |
| FY2024 | 111 | $87,975 | 332 | $5.1M |
| FY2025 | 85 | $219,953 | 253 | $2.3M |
| FY2026 | 89 | $33,234 | 215 | $2.2M |
| FY2027 | 1 | — | 3 | — |
EPA fiscal years run from 1 October to 30 September. The current year is partial.
EPA wastewater enforcement: questions
What is the largest Clean Water Act penalty ever assessed?
BP EXPLORATION/MOEX/TRANSOCEAN DEEPWATER/TRITON/GULF OF MEXICO OIL SPILL/DEEPWATER HORIZON (NC): $3,367.3 million in fiscal year 2010, with $1,943.8 million in required compliance actions. Penalties are the amounts EPA records as assessed or agreed, which can differ from what was collected.
Which state has the most EPA enforcement actions against wastewater plants?
Texas, with 456 formal cases naming 275 plants, 146 of the cases since fiscal year 2020. Counts reflect federal cases in EPA's ICIS system; state-led enforcement is recorded separately by each state.
What is the difference between an administrative and a judicial enforcement case?
Administrative cases are handled by EPA itself, usually as orders under section 309 of the Clean Water Act that require a plant to correct permit violations, sometimes with a penalty. Judicial cases are referred to the Department of Justice and filed in court; they typically end in a consent decree that sets a multi-year capital programme, which is why the largest compliance-action values sit with judicial cases.
Enforcement data: EPA ICIS-FE&C civil enforcement cases and ICIS compliance inspections, via ECHO. Penalties are the amounts assessed or agreed in each case as EPA records them, not necessarily collected.
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