Corporate Misconduct Accountability Project
Hill MHP, LLC · Administrative Order for Compliance on Consent
Virginia Mobile Home Park Repeatedly Dumped Untreated Sewage Into Bay
Hill MHP LLC violated the Clean Water Act 72 times in eight months, discharging dangerous levels of sewage pollutants into tributaries flowing to the Chesapeake Bay while operating with an outdated treatment plant and ignoring maintenance requirements.
CRITICAL SEVERITY
TL;DR
Hill MHP LLC, owner of a mobile home park sewage treatment plant in Bowling Green, Virginia, repeatedly violated its Clean Water Act discharge permit from August 2022 through March 2023, recording 72 exceedances of allowable pollution limits. The company discharged excessive levels of total suspended solids, biochemical oxygen demand, nitrogen, and E. coli bacteria into an unnamed tributary flowing to Maracossic Creek, the York River, and ultimately the Chesapeake Bay. EPA inspectors observed visible light-brown solids floating in the receiving water and found that the facility failed to maintain required equipment, operated without backup power, and ignored its own operations manual.
This case shows how even small operators can cause systemic environmental harm when profit takes priority over compliance.
72
Permit violations in 8 months
8122%
Highest exceedance above permitted limit
0
Backup power systems at facility
The Allegations: A Breakdown
Core Allegations
What they did · 8 points
| 01 | The facility recorded 72 separate violations of effluent discharge limits between August 1, 2022 and March 31, 2023. These exceedances included total suspended solids measurements as high as 8122% above the permitted limit, with one reading showing 1,233.3 mg/L when the maximum allowed was only 15 mg/L. | high |
| 02 | EPA inspectors observed light-brown solids discharged directly under Outfall 001 and accumulating 40 to 50 feet downstream in the receiving water. The solids appeared different from natural creek bed material, indicating direct discharge of untreated wastewater components. | high |
| 03 | The company violated its permit by failing to maintain adequate facilities and systems of treatment and control. Turbidity and cloudiness were observed in the effluent holding tank and post-aeration chamber, showing that treatment systems were not functioning properly. | high |
| 04 | The facility operated without any backup or auxiliary power source. According to facility representatives, during a prolonged power outage, wastewater would be held in the collection tank until capacity was exceeded, at which point it would overflow. A previous operator attributed an August 2019 exceedance to a power failure that prevented the Sequencing Batch Reactor from resetting. | high |
| 05 | Hill MHP LLC failed to follow its own Operations and Maintenance Manual. The manual showed influent entering the anaerobic chamber at the east end of the Sequencing Batch Reactor, but in reality, influent was pumped directly into the Surge Anoxic Mix tank while the anaerobic chamber was repurposed to store wasted solids. | high |
| 06 | The company used an improvised method to calculate discharge flow, totaling the number of 381-gallon batches from the Sequencing Batch Reactor instead of using water supply flow meters as required by the Operations and Maintenance Manual. This substitution violated permit requirements for accurate flow measurement. | medium |
| 07 | The facility discharged excessive levels of Kjeldahl nitrogen up to 350% above permitted limits, including readings of 18.8 mg/L when the maximum allowed was 4.5 mg/L. Excess nitrogen fuels harmful algal blooms that deplete oxygen in water and create dead zones where marine life cannot survive. | high |
| 08 | The facility exceeded E. coli limits in December 2022, with a geometric mean of 178 colony-forming units per 100 mL when the limit was 126. E. coli presence signals fecal contamination that poses health risks if ingested or contacted during recreational water activities. | medium |
Regulatory Failures
How oversight broke down · 5 points
| 01 | EPA conducted a site inspection on October 29, 2020 and sent its inspection report identifying violations to the previous owner on December 23, 2020. Hill MHP LLC purchased the facility on August 31, 2021, but EPA did not send a Notice of Potential Violations until May 31, 2022, allowing violations to continue for over 18 months after the initial inspection. | high |
| 02 | The facility operated under a state-issued NPDES permit administered by the Virginia Department of Environmental Quality, yet VADEQ failed to catch or correct the 72 exceedances that occurred over an eight-month period. EPA only intervened after consultation with VADEQ regarding this enforcement action. | high |
| 03 | The Administrative Order on Consent was not issued until June 4, 2024, nearly four years after EPA’s initial inspection and nearly two years after Hill MHP LLC received the NOPVOC. During this extended delay, the facility continued discharging pollutants above permitted levels into tributaries flowing to the Chesapeake Bay. | high |
| 04 | The facility’s compliance history shows that it had a pattern of non-compliance even before Hill MHP LLC purchased it. The Order notes the facility had a history of non-compliance, yet state and federal regulators allowed ownership to transfer without requiring infrastructure improvements or enhanced oversight. | medium |
| 05 | EPA based its findings on Discharge Monitoring Reports submitted by Hill MHP LLC itself, revealing that regulatory oversight depended entirely on self-reported data. The company submitted monthly reports documenting its own violations without triggering immediate enforcement action. | medium |
Profit Over People
Cost-cutting that endangered communities · 5 points
| 01 | The company failed to install backup power equipment despite knowing that power failures would cause the Sequencing Batch Reactor to malfunction and compromise treatment effectiveness. This decision saved upfront equipment costs while transferring environmental risk to the surrounding community. | high |
| 02 | Facility representatives told EPA inspectors they were unsure what was causing the observed turbidity in the effluent but guessed it related to chlorine tablets not dissolving fully. This statement reveals a lack of investment in proper diagnostics or process control that would identify and correct treatment problems. | medium |
| 03 | The company continued operating a treatment plant that consistently failed to meet permit limits rather than making the capital investments needed to achieve compliance. The facility’s ongoing exceedances demonstrate that Hill MHP LLC prioritized continued operation over environmental protection. | high |
| 04 | The Administrative Order gives Hill MHP LLC the option to cease all operations at the mobile home park if constructing a replacement plant proves infeasible due to cost estimates. This provision allows the company to abandon the facility rather than invest in proper wastewater treatment, leaving residents to find alternative housing. | high |
| 05 | The facility began pump-and-haul services for its effluent only on April 6, 2023, after more than eight months of documented violations. The company waited until faced with formal enforcement action to stop discharging pollutants, showing that compliance came only when legally compelled. | high |
Public Health and Safety
Environmental and community harm · 6 points
| 01 | The facility discharged pollutants into an unnamed tributary to Maracossic Creek, which flows to the York River and ultimately the Chesapeake Bay. These are waters of the United States that people use for recreation, fishing, and as sources of drinking water. | high |
| 02 | Total suspended solids clog aquatic habitats and disrupt the life cycles of fish and benthic organisms. Turbid waters receive less sunlight, hampering photosynthesis in aquatic vegetation and degrading the entire food chain. | high |
| 03 | Excess nitrogen fuels the growth of harmful algal blooms, which deplete oxygen in the water when algae die and decompose. These hypoxic or low-oxygen conditions create dead zones where most marine life struggles to survive. | high |
| 04 | High biochemical oxygen demand means microorganisms in the water consume large amounts of oxygen to break down organic matter. This leads to oxygen-depleted conditions that are detrimental to fish, shellfish, and other aquatic fauna. | high |
| 05 | The presence of E. coli signals fecal contamination that can pose health risks for humans and animals if ingested or if it contaminates local recreational waters. Children, immunocompromised individuals, and older adults are particularly vulnerable to gastrointestinal illnesses from contact with contaminated water. | medium |
| 06 | The Chesapeake Bay is already struggling with nutrient pollution from various industrial, agricultural, and municipal sources. Each additional violator contributes to the collective assault on a delicate aquatic ecosystem, which reverberates back onto community health and well-being. | high |
Community Impact
How residents bear the burden · 6 points
| 01 | Mobile home park residents live directly adjacent to the failing sewage treatment plant and face the most immediate exposure to any overflow events or odor problems. These residents, often economically vulnerable, have fewer options to relocate away from the environmental hazard. | high |
| 02 | If Hill MHP LLC decides not to construct a compliant facility because the expense is too high, the entire mobile home park could close. This would displace residents who often have limited housing options and financial resources to find alternative affordable housing. | high |
| 03 | Property values in or near the mobile home park may decline if prospective residents learn that the sewage treatment plant has repeatedly violated pollution limits. Existing residents face economic losses through no fault of their own. | medium |
| 04 | Local residents who rely on nearby creeks for recreation, fishing, or irrigation must now weigh the risks of encountering contaminated water. The company’s violations have effectively denied community members safe access to local waterways. | high |
| 05 | The Administrative Order provides no direct compensation or assistance to local residents who suffered exposure to pollutants during the eight-month violation period. The community bears the health and economic costs while the company negotiates the most cost-effective compliance path. | medium |
| 06 | Trust in local authorities and regulators erodes when residents learn that a facility operated for years with known violations before enforcement action was taken. This breakdown in public confidence undermines the social contract between communities and their government. | medium |
Corporate Accountability Failures
Why enforcement came too late · 6 points
| 01 | The company was made aware of violations during discussions following receipt of the Notice of Potential Violations from EPA and in subsequent discussions with EPA and VADEQ, yet continued operating the facility with known deficiencies. This shows that informal warnings failed to compel compliance. | high |
| 02 | The Administrative Order on Consent requires the company to submit a Corrective Action Plan within 90 days of the effective date, but sets no deadline for actually completing construction of a new treatment plant. This open-ended timeline allows further delay in achieving full compliance. | medium |
| 03 | The Order allows Hill MHP LLC to avoid building a replacement plant entirely if the company determines it is infeasible due to cost estimates, exceeding budget, or other unforeseen contingencies. This escape clause prioritizes corporate financial concerns over environmental restoration. | high |
| 04 | EPA reserves the right to institute further actions if it obtains evidence that information provided by Hill MHP LLC was knowingly false or materially inaccurate, but the Order includes no automatic penalties for past violations. The company faces no specified financial penalty for the 72 documented exceedances. | high |
| 05 | The certification requirement allows a company representative to certify compliance based on inquiry of persons who manage the system, creating a self-verification loop that previously failed to prevent violations. The Order relies on the same internal reporting structure that allowed the original violations to occur. | medium |
| 06 | Respondent waives any and all remedies, claims for relief, and rights to judicial or administrative review. This provision means Hill MHP LLC cannot challenge EPA’s findings in court, but it also means the company avoids a public trial that might reveal additional misconduct or impose stricter penalties. | medium |
The Bottom Line
What this case reveals · 4 points
| 01 | Hill MHP LLC’s 72 violations in eight months demonstrate that even small wastewater treatment facilities can cause systemic environmental harm when operators prioritize cost savings over compliance. The company’s discharges contributed to the degradation of waterways flowing into the already-stressed Chesapeake Bay ecosystem. | high |
| 02 | The multi-year gap between EPA’s initial inspection and the issuance of this Administrative Order shows how slowly enforcement mechanisms respond to ongoing pollution. During this delay, local communities continued to be exposed to contaminated water while the facility operated outside permit limits. | high |
| 03 | The Order’s provision allowing the company to cease operations rather than invest in a compliant facility reveals the power imbalance between corporations and communities. Hill MHP LLC can walk away from the problem, but residents face displacement and lasting environmental damage. | high |
| 04 | This case illustrates how regulatory systems that rely on self-reporting and reactive enforcement allow violations to persist. The company submitted monthly Discharge Monitoring Reports documenting its own exceedances without triggering immediate corrective action, revealing fundamental weaknesses in oversight mechanisms. | high |
Timeline of Events
October 2020
EPA representatives inspect the Hill Mobile Home Park Sewage Treatment Plant and identify violations of the permit and Clean Water Act.
December 2020
EPA sends its Site Inspection Report to the facility’s previous owner, documenting violations observed during the October inspection.
August 2021
Hill MHP LLC purchases the facility and takes over operational control of the sewage treatment plant from the previous owner.
May 2022
EPA sends Hill MHP LLC a Notice of Potential Violations and Opportunity to Confer, listing the violations identified in the inspection report.
August 2022
A new NPDES permit is issued to Hill MHP LLC, making the company the official permittee. The facility begins recording the violations that would total 72 over the next eight months.
August-December 2022
The facility records its most extreme violations, including total suspended solids readings of 1,233.3 mg/L (8,122% above the 15 mg/L limit) in October.
January-March 2023
Violations continue with consistent exceedances of TSS, BOD, and nitrogen limits every month, bringing the total count to 72 separate violations.
April 2023
Hill MHP LLC begins pump-and-haul services for the facility’s effluent, stopping direct discharge into the unnamed tributary after more than eight months of documented violations.
June 2024
EPA issues the Administrative Order for Compliance on Consent, requiring Hill MHP LLC to either construct a new sewage treatment plant or cease all operations at the mobile home park.
Direct Quotes from the Legal Record
QUOTE 1
Scale of violations
allegations
“The Facility has a history of non-compliance and from August 1, 2022 through March 31, 2023 the facility had 72 exceedance violations over an 8-month period.”
💡 This shows the facility violated its permit an average of nine times per month for eight consecutive months.
QUOTE 2
Visible pollution in waterway
allegations
“At the time of the Site Inspection, the inspector observed light brown solids discharged directly under Outfall 001 and 40-50 ft downstream in the receiving water. The solids observed appeared different than the natural material in the creek bed.”
💡 EPA inspectors personally witnessed untreated sewage solids floating in the creek, providing direct evidence of pollution.
QUOTE 3
Extreme exceedances
allegations
“Solids, total suspended WKLY MAX 1233.3 15 mg/L 8122”
💡 The facility discharged solids at more than 82 times the permitted maximum, showing complete failure of the treatment system.
QUOTE 4
No backup power
profit
“At the time of the Site Inspection, Facility representatives stated that there was no backup or auxiliary power source for the STP. In the event of a prolonged power outage, wastewater would be held in the wastewater collection tank and collection system and would overflow once capacity was exceeded.”
💡 The company operated without basic safety equipment, prioritizing cost savings over preventing sewage overflows.
QUOTE 5
Ignoring operations manual
allegations
“The Facility’s O&M Manual shows influent coming into the SBR in the anaerobic chamber at the east end of the system. The O&M Manual also describes the anaerobic chamber as a location where solids can settle during the SBR process. However, at the time of the Site Inspection, influent was being pumped from the wastewater collection tank over the anaerobic chamber, directly into the Surge Anoxic Mix (SAM) tank. The anaerobic chamber was being used to store wasted solids at the time of the Site Inspection.”
💡 The facility completely disregarded its required operating procedures, showing systemic non-compliance.
QUOTE 6
Improvised flow measurement
allegations
“At the time of the Site Inspection, Facility representatives stated that flow was actually calculated by totaling the number of 381-gallon batches discharged from the SBR instead of using the flow meter information.”
💡 The company substituted an improvised method for required measurements, making accurate monitoring impossible.
QUOTE 7
Regulatory delay
regulatory
“On or about August 31, 2021, Respondent purchased and took over operational control of the Facility. On May 31, 2022, EPA sent Respondent a Notice of Potential Violations and Opportunity to Confer (NOPVOC) with the list of violations.”
💡 EPA waited nine months after Hill MHP LLC purchased the facility to send formal notice, allowing violations to continue.
QUOTE 8
Escape clause for company
accountability
“Notwithstanding the foregoing, in the event that Respondent determines that the replacement plant is infeasible, either due to cost estimates, including fines or penalties resulting from any noncompliance with the Permit or the CWA, exceeding budget or other unforeseen contingencies, the CAP may simply call for ceasing all operations at the Hill Mobile Home Park.”
💡 The Order allows the company to avoid building a compliant facility if costs are too high, leaving residents to find new housing.
QUOTE 9
Community displacement risk
community
“In the event that Respondent ceases all operations at the Hill Mobile Home Park, the AOC shall be deemed completed.”
💡 The company can walk away from its pollution problem by closing the park, displacing vulnerable residents.
QUOTE 10
No financial penalty specified
accountability
“Respondent shall bear its own costs and attorney’s fees in connection with this proceeding and associated with the implementation or enforcement of this AOC, including any costs related to resolution of any dispute arising regarding this AOC.”
💡 The Order contains no specified fine for 72 violations, allowing the company to avoid direct financial penalty for past misconduct.
QUOTE 11
Wastewater ended up in Chesapeake Bay
health
“The unnamed tributary to Maracossic Creek, Maracossic Creek, the York River, and the Chesapeake Bay are waters of the United States within the meaning of Section 502(7) of the Act, 33 U.S.C. § 1362(7).”
💡 The facility’s violations polluted waterways that ultimately flow into the ecologically critical and already-stressed Chesapeake Bay.
QUOTE 12
Nitrogen pollution harm
health
“Excess nitrogen can fuel the growth of harmful algal blooms, which deplete oxygen in the water when algae die and decompose, creating dead zones where most marine life struggles to survive.”
💡 The facility discharged nitrogen at levels up to 350% above permit limits, contributing to oxygen depletion that kills fish and other aquatic life.
QUOTE 13
Self-reporting failure
regulatory
“Per Table 1 information, which is from Discharge Monitoring Reports submitted by Respondent, the Facility had 72 exceedances for the period of 8/1/2022 to 03/31/2023.”
💡 The company documented its own violations in monthly reports without triggering immediate enforcement, showing how self-reporting systems can fail.
QUOTE 14
Uncertainty about treatment problems
profit
“Facility representatives stated they were unsure of what was causing the turbidity but guessed it was related to the chlorine tablets not dissolving fully.”
💡 The company operated without understanding or addressing fundamental treatment failures, showing lack of investment in proper diagnostics.
QUOTE 15
Years of known problems
regulatory
“The Facility has a history of non-compliance and from August 1, 2022 through March 31, 2023 the facility had 72 exceedance violations over an 8-month period.”
💡 The facility had compliance problems even before Hill MHP LLC purchased it, yet regulators allowed the transfer without requiring upgrades.
Frequently Asked Questions
What did Hill MHP LLC do wrong?
Hill MHP LLC violated its Clean Water Act discharge permit 72 times in eight months by releasing sewage pollutants far above allowed limits. The company discharged total suspended solids, nitrogen, biochemical oxygen demand, and E. coli bacteria into a creek flowing to the Chesapeake Bay. EPA inspectors observed visible sewage solids floating in the water downstream from the facility’s discharge pipe.
How bad were the pollution levels?
Some violations were extreme. In October 2022, the facility discharged total suspended solids at 1,233.3 mg/L when the maximum allowed was 15 mg/L, which is 8,122% over the limit. Many other months showed exceedances of 500% to 3,000% above permitted levels. These levels indicate the treatment plant was barely functioning.
Who was harmed by these violations?
Residents of the mobile home park and people living downstream were exposed to contaminated water. The pollution degraded local creek ecosystems, harmed fish and aquatic life, and contributed to the ongoing decline of the Chesapeake Bay. People who use the waterways for fishing, recreation, or as a drinking water source faced increased health risks.
Why did the violations continue for so long?
EPA first inspected the facility in October 2020 but did not issue this enforcement order until June 2024, nearly four years later. During that time, the facility continued operating with known deficiencies. The regulatory system relied on the company’s self-reported data and failed to compel immediate corrective action despite monthly reports documenting violations.
What happens to the mobile home park residents now?
Hill MHP LLC must either build a new compliant sewage treatment plant or cease all operations at the mobile home park. If the company decides building a new plant is too expensive, the park will close and residents will have to find new housing. The enforcement order provides no assistance or compensation for displaced residents.
Did the company face any fines?
The Administrative Order on Consent does not specify any monetary penalty for the 72 violations. The company must pay for constructing a new treatment plant or for pump-and-haul services, but the order contains no separate fine for the past pollution. The company avoids direct financial penalty for dumping contaminated wastewater for eight months.
What pollutants did the facility discharge?
The facility exceeded limits for total suspended solids (particles that make water cloudy and smother aquatic habitat), biochemical oxygen demand (organic matter that depletes oxygen in water), Kjeldahl nitrogen (which fuels harmful algal blooms), and E. coli bacteria (indicating fecal contamination). All of these pollutants harm aquatic ecosystems and can pose risks to human health.
Was the company operating properly?
No. EPA found that the facility ignored its own Operations and Maintenance Manual, operated without backup power equipment, and used improvised methods to measure discharge volumes. The treatment plant lacked proper maintenance, and facility staff told inspectors they were unsure what was causing visible pollution in the discharge.
What can people do if they live near this facility?
Residents can request copies of the facility’s discharge monitoring reports through public records requests. They can test local water quality independently through partnerships with environmental organizations. Community members can also organize to demand stronger enforcement, attend public meetings about the facility’s compliance plan, and contact elected officials to push for accountability.
Does this violate federal law?
Yes. The Clean Water Act prohibits discharging pollutants above permitted limits. Section 301 of the Act makes it illegal to discharge any pollutant into waters of the United States except in compliance with a permit. Hill MHP LLC’s 72 exceedances constitute 72 separate violations of federal environmental law.
You can read about this wastewater pollution by visiting the EPA’s website: https://yosemite.epa.gov/oa/rhc/epaadmin.nsf/Filings/452C432A344513D585258B35005D8130/$File/Hill%20MHP%20LLC_CWA%20AOC_June%204%202024.pdf
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