What the $20,000 Fine Doesn’t Pay For

Williams, South Carolina sits in Williamsburg County, a rural stretch of the state where the median household income hovers well below the national average and where environmental enforcement is not a given. The people who live and work nearest to 189 Supply Road didn’t get a vote on whether Warren and Griffin, Inc. would operate without a stormwater permit. They didn’t get a notice in their mailbox. They didn’t get a seat at the table when the EPA calculated its $20,000 penalty using its 2016 Supplemental Guidance framework.

What they got was a company running industrial operations and releasing stormwater into the surrounding environment without the legally required safeguards. Industrial stormwater runoff isn’t just rain. It carries with it whatever has touched the ground at that facility: oils, heavy metals, sediment, chemical residues, and process-related contaminants that vary by industry. A permit requires a facility to characterize what’s in that runoff, install controls to reduce it, monitor it, and report it. Without a permit, none of those obligations exist. Without those obligations, the water downstream absorbs the consequences.

The people in rural South Carolina who drink from wells, fish from local waterways, or let their kids play near drainage ditches don’t have the resources to test their water every time an industrial facility nearby decides compliance paperwork is inconvenient. They trust that the regulatory system is doing that for them. This case is a document of what happens when a company decides, for however long, that the system can be ignored without consequence. The EPA inspection on August 8, 2023, happened because inspectors showed up. Not because Warren and Griffin self-reported. Not because they applied for a permit they knew they needed. Because someone came to look.

The settlement agreement states that violations “have been corrected.” That may be true on paper. The harm that occurred between the start of unpermitted operations and August 8, 2023, is over, and whatever entered the water during that window is already downstream. A $20,000 check to the federal government does not filter it back out.

Straight From the Document: What They Signed

Every quote below comes verbatim from the Expedited Settlement Agreement and Final Order filed with the EPA Region 4 Regional Hearing Clerk on March 27, 2025. Docket No. CWA-04-2024-1000(b).

“Respondent, who is the owner and operator of the Site, discharged industrial stormwater from the Site without authorization by any permit issued pursuant to the Clean Water Act (Act) in violation of Section 301(a) of the Act, 33 U.S.C. § 1311(a).”

“Respondent neither admits nor denies the factual allegations alleged in the Alleged Violations Form or otherwise stated herein.”

“Respondent consents to the assessment of this penalty and waives the right to: (1) contest the alleged violations specified in the Alleged Violations Form; (2) a hearing pursuant to Section 309(g)(2) of the Act; (3) appeal the Final Order; and (4) judicial review pursuant to CWA § 309(g)(8).”

“This Agreement does not affect the right of the EPA or the United States to pursue appropriate injunctive or other equitable relief or criminal sanctions for any violations of law or to issue an administrative compliance order, e.g., for any uncorrected violations listed in the Alleged Violations Form.”

Who Pays When Industrial Runoff Goes Unchecked

Environmental Degradation

Industrial stormwater runoff is a documented pathway for pollution entering waterways, soil, and groundwater. Without a permit, there are no controls and no monitoring.

• Industrial stormwater can carry heavy metals, petroleum hydrocarbons, sediment, and process chemicals from the facility’s ground surface directly into drainage systems and connected waterways. Without an NPDES permit, no baseline characterization of these pollutants was required, meaning the specific contaminants discharged at 189 Supply Road were never formally identified or tracked.
• Williams, South Carolina sits within a watershed that feeds into the larger Santee River Basin. Unpermitted industrial discharges in this region contribute cumulative pollutant loads to waterways that serve agricultural, recreational, and drinking water purposes downstream.
• The Alleged Violations Form, incorporated by reference into the settlement agreement, contains the specific inspection observations. That document details the on-the-ground environmental conditions observed by EPA inspectors on August 8, 2023, but is not reproduced in full in the public-facing settlement. The absence of that detail from the public record is itself a feature of the expedited process, not a bug.

Public Health

Rural South Carolina communities face compounding environmental health risks. Unpermitted industrial discharge adds to a baseline of elevated exposure.

• Williamsburg County, where Williams is located, is a majority-Black, low-income rural county where access to clean municipal water and environmental health monitoring resources is limited. Residents relying on private wells are most exposed to groundwater contamination from industrial sources with no permit-based monitoring requirements.
• Industrial stormwater contaminated with heavy metals or hydrocarbons poses documented risks to human health including neurological damage, kidney dysfunction, and elevated cancer risk through dermal contact, ingestion, or inhalation of contaminated water vapor. None of these pathways were studied or monitored during the period Warren and Griffin operated without a permit.
• The EPA’s expedited settlement process resolves the administrative case without requiring public disclosure of what specific contaminants were present in the discharge. The community affected by the violation received notice through the mandated public comment period under CWA § 309(g)(4), but only after the penalty was already negotiated.

Economic Inequality

The cost structure of Clean Water Act enforcement creates a system where low-income, rural communities bear the environmental risk while corporations calculate whether compliance costs more than getting caught.

• The $20,000 penalty is calculated under EPA’s 2016 Supplemental Guidance to the 1995 Interim Clean Water Act Settlement Penalty Policy for Industrial Stormwater Requirements. That framework is designed for expedited resolution of first-offense, corrected violations. It does not account for the duration of the violation or the economic benefit the company derived from avoiding permit costs.
• Obtaining an NPDES industrial stormwater permit typically involves filing fees, engineering assessments, stormwater pollution prevention plan development, and ongoing monitoring costs. By operating without one, Warren and Griffin avoided all of these expenses for an unknown period. The $20,000 penalty may or may not exceed that avoided cost.
• The settlement explicitly states that Warren and Griffin will bear its own attorney’s fees. The affected residents of Williamsburg County have no equivalent legal representation in this process. Their interests are represented only through the EPA’s enforcement discretion and the state consultation process, neither of which gives them a direct voice in the penalty amount.
• Environmental justice data from the EPA’s own EJScreen tool consistently ranks rural South Carolina communities near the top of cumulative environmental burden indexes. Enforcement actions that resolve quickly and quietly with moderate fines do not change that underlying burden.

What $20,000 Actually Means

• The EPA’s expedited settlement process under CWA § 309(g)(2)(A) is designed for smaller violations that have been corrected. The maximum penalty under this provision is $25,000 per day per violation, but expedited settlements are structured to resolve quickly at far lower amounts when a company corrects the violation and cooperates.
• There is no public record in this settlement of how long Warren and Griffin operated without a permit. If the company avoided permit costs for even one full year, the savings from avoided compliance expenses could easily equal or exceed the $20,000 penalty, making non-compliance a financially rational decision.
• The settlement agreement explicitly states Warren and Griffin cannot deduct the penalty for federal tax purposes under Section 162(f)(1) of the Internal Revenue Code. That clause exists because Congress recognized that allowing penalty deductions would reduce the deterrent effect to near zero.

Who to Watch and How to Push Back

The settlement is final and the civil penalty liability is resolved, but the EPA retains enforcement authority over this site, and the community around Williams, South Carolina retains the right to organize, monitor, and demand transparency.

People Named in This Document

• Keriema S. Newman, Director, Enforcement and Compliance Assurance Division, EPA Region 4. Signed the Final Order on February 6, 2025. She is the senior enforcement official who authorized this settlement amount.
• Tanya Floyd, Regional Judicial Officer, EPA Region 4. Issued the Final Order on March 27, 2025. Her office is responsible for the judicial function of administrative enforcement cases.
• Lonnie Dom, Enforcement Officer, EPA Region 4. The officer who conducted the enforcement action. Contact: Dom.Lonnie@epa.gov, 706-355-8683.
• Andrew Teodorescu, Attorney-Advisor, EPA Region 4. The attorney who handled the legal side of this settlement. Contact: Teodorescu.andrew@epa.gov, 404-562-8309.
• Gary Headden, identified as Site Manager for Warren and Griffin, Inc. His email address (headdeng@musc.edu) contains the musc.edu domain, which is the Medical University of South Carolina. That connection between a medical institution and an industrial stormwater violator is a thread the source document does not explain.

Watchlist: Regulatory Bodies With Jurisdiction

• EPA Region 4 (Atlanta): Primary federal enforcer. They can pursue criminal sanctions, injunctive relief, and additional administrative compliance orders if violations resurface or remain uncorrected. Public docket access at EPA’s ECHO database.
• South Carolina Department of Environmental Services (SCDES): The state agency consulted per CWA § 309(g)(1). South Carolina has the authority to pursue separate state-level enforcement actions independent of the federal settlement.
• U.S. Department of Justice (DOJ), Environment and Natural Resources Division: Retains authority to pursue criminal charges under the Clean Water Act if violations are found to be knowing or willful. The federal settlement does not provide criminal immunity.
• EPA Office of Inspector General: Accepts complaints about inadequate enforcement actions, including concerns that penalties are too low to deter future violations.

What You Can Do

• Submit a public comment: The EPA is required to provide a public comment period before the Final Order is issued under CWA § 309(g)(4). If you live near this facility or are concerned about future operations, contact EPA Region 4’s Enforcement and Compliance Assurance Division directly to request to be notified of future actions at this site.
• Use EPA’s ECHO database: The Enforcement and Compliance History Online (ECHO) tool at echo.epa.gov allows anyone to look up a facility’s permit status, inspection history, and violation record. Search for Warren and Griffin, Inc. at 189 Supply Road, Williams, SC 29493 to track any future violations or permit applications.
• Connect with local environmental justice organizations: Groups like the South Carolina Environmental Law Project and the Coastal Conservation League work directly on industrial water pollution issues in South Carolina. Rural communities facing environmental enforcement gaps need legal and organizing support, not just individual complaints.
• File a FOIA request for the Alleged Violations Form: The specific inspection findings (Enclosure A in the settlement) are not reproduced in the public document. File a Freedom of Information Act request with EPA Region 4 to obtain the full Alleged Violations Form and learn exactly what inspectors found on August 8, 2023.
• Monitor the MUSC connection: Gary Headden’s contact email uses the Medical University of South Carolina domain. If Warren and Griffin, Inc. has any operational or contractual relationship with a state medical institution, that relationship warrants public scrutiny. Request records from MUSC under South Carolina’s Freedom of Information Act if you believe a public institution is involved.