Corporate Misconduct Accountability Project
Leisure Valley, Inc. · EPA Administrative Order
Leisure Valley Inc Skips Water Safety Tests for Years
Nevada corporation operating Wyoming RV park allegedly failed to test drinking water for arsenic, mercury, and other toxins for years, leaving 750 residents in the dark about potential contamination.
CRITICAL SEVERITY
TL;DR
Leisure Valley, Inc., a Nevada corporation, owns and operates the Star Valley RV Park Public Water System in Wyoming, serving approximately 750 people. The EPA found the company failed to test drinking water for dangerous contaminants including arsenic, mercury, cyanide, and radionuclides from 2020 through 2022. When bacterial contamination was detected in September 2022, the company allegedly failed to conduct required safety assessments or notify the public. The EPA issued an administrative order forcing immediate compliance and threatening penalties up to $69,733 per day for continued violations.
This case shows how profit motives can override basic safety when oversight is weak and penalties arrive years late.
750
People exposed to untested water
810
Service connections affected
$69,733
Maximum daily penalty per violation
3 years
Duration of alleged testing failures
0
Required tests completed during compliance period
The Allegations: A Breakdown
Core Allegations
What they did · 8 points
| 01 | Leisure Valley, Inc. failed to monitor the water system for dangerous inorganic contaminants including antimony, arsenic, barium, beryllium, cadmium, chromium, cyanide, fluoride, mercury, nickel, selenium, and thallium during the entire January 1, 2020 to December 31, 2022 compliance period. Federal law requires testing at least once every three years at every entry point to the distribution system. | high |
| 02 | The company failed to test for sodium during the same three-year period, violating requirements under 40 C.F.R. section 141.41. Untreated groundwater from two wells supplied the entire system with no monitoring to verify safety. | medium |
| 03 | Leisure Valley, Inc. failed to monitor for synthetic organic contaminants at every entry point during the 2020-2022 compliance period. The company only collected SOC samples at one location on July 5, 2023, after violations had already occurred. | high |
| 04 | The company failed to test for volatile organic contaminants at the Well #2 and well house spigot sample point during the January 1, 2020 to December 31, 2022 compliance period. VOC samples were finally collected on July 5, 2023, years behind schedule. | high |
| 05 | Leisure Valley, Inc. failed to monitor for radionuclides during the second and fourth quarters of 2022 and the first quarter of 2023, despite federal requirements for quarterly testing. Radioactive contaminants pose significant threats to human health if undetected. | high |
| 06 | After multiple positive total coliform sample results in September 2022, the company failed to conduct a required Level 1 assessment within 30 days. This assessment investigates sanitary defects that could cause bacterial contamination and identifies necessary corrective actions. | high |
| 07 | The company failed to notify the public about the Level 1 assessment violation within the required 30-day Tier 2 timeframe. The EPA found no record that residents were informed or that required certification was submitted to the agency. | high |
| 08 | Leisure Valley, Inc. failed to issue Tier 3 public notices within one year about the monitoring violations for inorganic contaminants, sodium, synthetic organic contaminants, volatile organic contaminants, and radionuclides. Residents had no way of knowing their water was not being tested as required by law. | high |
Regulatory Failures
How oversight broke down · 5 points
| 01 | The EPA sent Leisure Valley, Inc. annual notifications of specific monitoring requirements that apply to the water system. Despite these direct communications, the company allegedly ignored federal testing mandates for multiple years. | high |
| 02 | The company failed to report violations to the EPA within the required 48-hour timeframe. Federal regulations at 40 C.F.R. section 141.31(b) require immediate reporting of any failure to comply with Safe Drinking Water Act requirements. | medium |
| 03 | Violations spanned from January 2020 through at least the first quarter of 2023, suggesting regulatory enforcement was delayed by three years or more. The EPA did not issue its administrative order until February 15, 2024. | high |
| 04 | The administrative order threatens civil penalties of up to $69,733 per day of violation, as adjusted for inflation, but years of alleged noncompliance passed before enforcement action materialized. This penalty structure may be calculated as a cost of doing business rather than a genuine deterrent. | medium |
| 05 | The Safe Drinking Water Act gives the company the right to seek federal judicial review of the EPA order rather than requiring immediate compliance. This built-in delay mechanism allows corporations to continue challenging orders through litigation. | medium |
Public Health and Safety
Risks to residents · 6 points
| 01 | The Star Valley RV Park water system regularly serves approximately 50 year-round residents and approximately 700 individuals who use the system seasonally. All relied on untreated groundwater from two wells with no verification that dangerous contaminants were absent. | high |
| 02 | Arsenic exposure from drinking water can cause cancer, cardiovascular disease, and neurological damage. Mercury can harm the nervous system, kidneys, and developing fetuses. Cyanide interferes with oxygen use by cells and can be fatal. None of these substances were tested for during the compliance period. | high |
| 03 | Multiple positive total coliform samples in September 2022 indicated bacterial contamination in the water supply. Total coliform bacteria can signal the presence of disease-causing organisms that cause gastrointestinal illness, particularly dangerous for children, elderly residents, and immunocompromised individuals. | high |
| 04 | Radionuclides present significant health threats including increased cancer risk from long-term exposure. The company failed to test for these radioactive contaminants in three separate quarters spanning 2022 and 2023. | high |
| 05 | At least 15 of the 810 service connections serve year-round residents who consumed this untested water daily for cooking, drinking, and bathing. Families had no way to protect themselves because the company never notified them of testing failures. | high |
| 06 | Volatile organic contaminants include industrial solvents and fuel components that can cause liver damage, kidney problems, and cancer. Synthetic organic contaminants include pesticides and other chemicals linked to reproductive harm and developmental effects. Neither category was monitored during the required compliance period. | high |
Profit Over People
The cost-cutting calculation · 5 points
| 01 | Comprehensive laboratory testing for inorganic contaminants, volatile organic contaminants, synthetic organic contaminants, and radionuclides requires significant expenditure with no immediate revenue return. The company allegedly avoided these costs entirely for three years. | high |
| 02 | Level 1 assessments require hiring qualified professionals to investigate sanitary defects, develop corrective action plans, and implement fixes. By failing to conduct this assessment after positive coliform results, the company avoided immediate remediation costs. | high |
| 03 | Public notification requires printing, distribution, and documentation that consumes staff time and resources. The company allegedly skipped both Tier 2 and Tier 3 public notices, saving money while leaving residents uninformed of health risks. | medium |
| 04 | The water supplied by the system is untreated groundwater from two wells. Installing treatment systems to address any contaminants found through testing would require capital investment. By not testing, the company avoided discovering problems that would mandate expensive treatment infrastructure. | high |
| 05 | Leisure Valley, Inc. is a Nevada corporation operating a public water system in Wyoming, suggesting a corporate structure potentially designed to operate across state lines with minimal local accountability. The company serves a transient RV park population less likely to organize sustained resistance than permanent community residents. | medium |
Community Impact
Who bears the cost · 5 points
| 01 | The Star Valley RV Park likely serves working-class families, retirees on fixed incomes, and seasonal workers who choose RV living for affordability. These residents lack the resources to independently test water quality or relocate when safety is compromised. | high |
| 02 | Year-round residents at the park had no warning that their drinking water was not being tested as federal law requires. Parents could not make informed decisions about whether to use bottled water for infant formula or children’s consumption. | high |
| 03 | The failure to notify the public about positive coliform results in September 2022 meant residents continued using potentially contaminated water for drinking, cooking, and bathing without knowledge of bacterial contamination. Vulnerable populations including elderly residents faced heightened risk of gastrointestinal illness. | high |
| 04 | Even if testing eventually reveals no dangerous contaminant levels, three years of uncertainty has already inflicted psychological harm. Residents must now wonder whether undetected exposure to arsenic, mercury, or other toxins during that period will cause health problems years later. | medium |
| 05 | Lincoln County, Wyoming, where the system is located, has a population under 20,000 people. Small rural communities often lack the political power and resources to hold corporate water system operators accountable, leaving residents dependent on distant federal enforcement. | medium |
Corporate Accountability Failures
The accountability gap · 6 points
| 01 | The EPA administrative order was filed on February 15, 2024, for violations beginning in January 2020. This four-year gap between the start of alleged noncompliance and enforcement action gave the company years of cost savings with minimal consequence. | high |
| 02 | The order requires the company to comply with monitoring requirements within 30 days of receiving the order, but this deadline comes years after the original compliance period expired. Residents were exposed to unknown risks during the entire delay. | high |
| 03 | Federal law allows the company to seek judicial review of the EPA order under section 1448(a) of the Safe Drinking Water Act. This appeals process can drag on for additional years while compliance remains contested. | medium |
| 04 | The order states it does not constitute a waiver, suspension, or modification of any Safe Drinking Water Act requirement and that issuance is not an election by the EPA to forgo civil or criminal action. However, it remains unclear whether the agency will pursue additional penalties beyond the compliance order. | medium |
| 05 | The order binds Leisure Valley, Inc., its successors, assigns, and any person acting in concert with the company. However, if the company sells the water system or declares bankruptcy, enforcement becomes more complex and residents may never see meaningful accountability. | medium |
| 06 | The order requires the company to provide copies to any lessee, purchaser, or contractor if the system changes hands, but the original company remains obligated to comply. This provision acknowledges the risk that corporate ownership changes could be used to evade enforcement. | medium |
Exploiting Delay
How time works for corporations · 5 points
| 01 | Leisure Valley, Inc. only collected synthetic organic contaminant samples on July 5, 2023, after the compliance period had already expired. This reactive compliance came only after violations were documented, not as part of proactive safety management. | medium |
| 02 | The order gives the company 15 days to conduct the Level 1 assessment that was due within 30 days of the September 2022 positive coliform results. This extended timeline means the required investigation will occur more than a year and a half after the contamination was detected. | high |
| 03 | The company must now monitor for synthetic organic contaminants at a location it previously neglected, but is not required to sample that location again until January 1, 2026 through December 31, 2028. The order builds in additional multi-year gaps between required testing. | medium |
| 04 | Similarly, the company must monitor for volatile organic contaminants but the order states they are not required to sample again until January 1, 2026 through December 31, 2028. This three-year window perpetuates the same inadequate monitoring frequency that created the original violations. | medium |
| 05 | The order requires public notification within 30 days for past violations, but also requires quarterly notices as long as the Level 1 assessment violation persists. The longer the company delays completing corrective actions, the longer it must issue notices, but this ongoing notification requirement does nothing to accelerate actual remediation. | low |
The Bottom Line
What this case reveals · 5 points
| 01 | This case demonstrates how essential public health protections become optional when enforcement is slow and penalties are delayed. Leisure Valley, Inc. allegedly skipped legally required water testing for years while serving hundreds of residents, and faced no immediate consequences until 2024. | high |
| 02 | The Safe Drinking Water Act created a comprehensive testing regime to protect Americans from dangerous contaminants in drinking water. When a corporation ignores these requirements, the regulatory system has failed its core mission of preventing harm before it occurs. | high |
| 03 | Rural and working-class communities bear disproportionate risk when corporate water system operators cut corners. Star Valley RV Park residents lacked the political power and resources to detect or challenge the testing failures on their own, leaving them entirely dependent on federal enforcement that came years late. | high |
| 04 | The cost-benefit calculation that may have driven these alleged violations treats public health as negotiable. Laboratory testing costs money with no revenue return, creating a structural incentive for profit-driven operators to minimize or skip compliance unless enforcement is swift and certain. | high |
| 05 | Even if subsequent testing reveals no dangerous contaminant levels, the damage is already done. Residents consumed untested water for years, faced potential bacterial contamination in 2022 without warning, and now must live with uncertainty about whether undetected exposures will cause future health problems. | medium |
Timeline of Events
January 2020
Compliance period begins for three-year inorganic contaminant, sodium, synthetic organic contaminant, and volatile organic contaminant testing requirements
2020-2022
Leisure Valley, Inc. allegedly fails to conduct any required testing for inorganic contaminants, sodium, synthetic organic contaminants, or volatile organic contaminants during entire compliance period
Q2 2022
Company fails to monitor water system for radionuclides during second quarter as required by quarterly testing mandate
September 2022
Water system tests positive for total coliform bacteria multiple times within the same month, indicating potential contamination
October 2022
Deadline passes for required Level 1 assessment following multiple positive coliform results; company allegedly fails to conduct assessment
Q4 2022
Company fails to monitor for radionuclides during fourth quarter, compounding earlier testing failures
December 31, 2022
Three-year compliance period expires with no testing completed for multiple required contaminant categories
Q1 2023
Company fails to monitor for radionuclides during first quarter of 2023, extending pattern of noncompliance into new year
July 5, 2023
Company finally collects some synthetic organic contaminant and volatile organic contaminant samples at selected locations, more than six months after compliance period ended
February 15, 2024
EPA issues Administrative Order against Leisure Valley, Inc., documenting multiple violations and requiring immediate compliance with monitoring requirements
Direct Quotes from the Legal Record
QUOTE 1
Untreated groundwater served to hundreds
allegations
“The System is supplied by a groundwater source accessed via two wells. The water is untreated.”
💡 The company provided drinking water to 750 people from untreated wells without testing to verify safety.
QUOTE 2
Three years of testing failures for arsenic and mercury
allegations
“Respondent is required to monitor the System’s water for certain inorganic contaminants (IOCs), i.e., antimony, arsenic, barium, beryllium, cadmium, chromium, cyanide, fluoride, mercury, nickel, selenium, and thallium, at every entry point to the distribution System which is representative of each well after treatment at least once every three years. Respondent failed to monitor the System’s water for IOCs during the January 1, 2020, to December 31, 2022 compliance period and therefore violated this requirement.”
💡 Dangerous heavy metals and toxins went untested for three full years despite federal safety requirements.
QUOTE 3
Bacterial contamination covered up
health
“Respondent is required to conduct a Level 1 assessment and submit it to the EPA within 30 calendar days of learning of the monitoring results. Respondent failed to conduct a Level 1 assessment following multiple positive total coliform sample results in the month of September 2022 and therefore violated this requirement.”
💡 When bacterial contamination was detected, the company failed to investigate the cause or fix the problem.
QUOTE 4
Residents kept in the dark
community
“The EPA’s records reflect that the Respondent failed to notify the public of the violation cited in paragraph 12, above, and failed to submit a copy of the public notice and certification to the EPA and therefore violated this requirement.”
💡 The company never told residents their water was contaminated or that required testing had not been done.
QUOTE 5
Years of violations hidden from public
accountability
“The EPA’s records reflect that the Respondent failed to notify the public of the violations cited in 7 through 11, above, and failed to submit a copy of the public notice and certification to the EPA and therefore, violated this requirement.”
💡 Multiple testing failures spanning three years were concealed from the community that relied on this water.
QUOTE 6
Never reported to regulators
regulatory
“Respondent is required to report any failure to comply with any Part 141 to the EPA within 48 hours (except where Part 141 specifies a different time period). Respondent failed to report the violations cited in paragraphs 7 through 12, above, to the EPA and therefore, violated this requirement.”
💡 The company broke the law by not telling the EPA about compliance failures within the required 48 hours.
QUOTE 7
Scope of population at risk
community
“The System has approximately 810 service connections, at least 15 of which are used by year-round residents, and regularly serves an average of approximately 50 year-round residents and approximately 700 individuals who do not use the System year-round.”
💡 Hundreds of people, including vulnerable year-round residents, depended on water that went untested.
QUOTE 8
Radionuclides left unchecked
health
“Respondent is required to monitor the System’s water for radionuclides each quarter. Respondent failed to monitor the System’s water for radionuclides during the second and fourth quarters of 2022 and the first quarter of 2023, and therefore violated this requirement.”
💡 Radioactive contaminants pose cancer risks but were not monitored during three separate quarters.
QUOTE 9
EPA had repeatedly notified the company
regulatory
“Part 141 includes monitoring requirements. The EPA has sent Respondent annual notifications of the specific monitoring requirements that apply to the System.”
💡 The company could not claim ignorance because EPA directly informed them of their testing obligations every year.
QUOTE 10
Penalties up to $69,733 per day
accountability
“Violation of any part of this Order, the Act, or Part 141 may subject Respondent to a civil penalty of up to $69,733 (as adjusted for inflation) per day of violation, a court injunction ordering compliance, or both.”
💡 Despite high daily penalties, violations continued for years before the EPA took enforcement action.
QUOTE 11
Synthetic organics finally tested after deadline
delay_tactics
“Respondent failed to monitor the System’s water for SOCs during the January 1, 2020, to December 31, 2022 compliance period and therefore violated this requirement. Respondent collected SOC samples at the Well #2 and well house spigot sample point (WL02/SP02) on July 5, 2023.”
💡 Testing only happened after the compliance deadline, showing reactive rather than proactive safety management.
QUOTE 12
Order binding on corporate successors
accountability
“This Order is binding on Respondent, its successors and assigns, and any person (e.g., employee, contractor, or other agent) acting in concert with Respondent.”
💡 The order anticipates the company might try to evade responsibility through ownership changes.
QUOTE 13
No waiver of further enforcement
accountability
“This Order does not constitute a waiver, suspension, or modification of any requirement of the Act or Part 141. Issuance of this Order is not an election by the EPA to forgo any civil or criminal action.”
💡 The EPA preserved its right to pursue additional penalties beyond this compliance order.
QUOTE 14
Multi-year gaps built into future testing
delay_tactics
“Respondent is next required to sample for SOCs at the well #2 and well house spigot sample point (WL02/SP02) between January 1, 2026, and December 31, 2028.”
💡 Even after violations, the order allows the same three-year testing gaps that enabled noncompliance.
QUOTE 15
Order issued February 2024 for 2020 violations
regulatory
“Issued: February 15, 2024.”
💡 Four years passed between the start of alleged violations and EPA enforcement, leaving residents at risk throughout the delay.
Frequently Asked Questions
What is Leisure Valley, Inc. accused of doing wrong?
The EPA found Leisure Valley, Inc. failed to test drinking water at its Wyoming RV park for dangerous contaminants including arsenic, mercury, cyanide, radionuclides, and bacteria for three years from 2020 to 2022. When bacterial contamination was detected in September 2022, the company allegedly failed to investigate the cause or notify residents.
How many people were affected by the untested water?
Approximately 750 people relied on the Star Valley RV Park water system, including about 50 year-round residents and roughly 700 seasonal users. The system has 810 service connections, at least 15 of which serve permanent residents.
What dangerous contaminants were not tested for?
The company failed to test for inorganic contaminants including arsenic, mercury, cadmium, chromium, cyanide, beryllium, and selenium. It also skipped testing for synthetic organic contaminants, volatile organic contaminants, sodium, and radionuclides. These substances can cause cancer, organ damage, neurological harm, and other serious health problems.
Did the water actually contain dangerous contamination?
The water tested positive for total coliform bacteria multiple times in September 2022, indicating contamination. For other contaminants, there is no way to know because required testing was never done during the compliance period. The absence of testing means residents consumed water of unknown safety for three years.
Why did the company allegedly skip these tests?
The EPA administrative order does not state the company’s motivation, but comprehensive laboratory testing costs money with no revenue return. Corporate operators may view compliance costs as reducing profits, creating incentive to minimize testing unless enforcement is swift and certain.
Were residents told their water was not being tested?
No. The EPA found the company failed to issue required public notices about the testing failures or the bacterial contamination. Residents had no way of knowing their water supply was not being monitored as federal law requires.
What penalties does the company face?
The Safe Drinking Water Act allows civil penalties up to $69,733 per day for each violation. The EPA order requires immediate compliance but does not specify what penalties will actually be imposed. The order states EPA has not waived its right to pursue civil or criminal action.
How long did violations continue before enforcement?
Alleged violations began in January 2020 and continued through at least the first quarter of 2023. The EPA did not issue its administrative order until February 15, 2024, meaning years passed before formal enforcement action.
What must the company do now?
The EPA order requires Leisure Valley, Inc. to conduct all overdue testing within 30 days, complete the Level 1 assessment for bacterial contamination within 15 days, notify the public about past violations within 30 days, and report all results to the EPA within specified timeframes.
What can residents and concerned citizens do?
Residents should demand copies of all testing results and public notices. They can file complaints with the EPA if they believe the company is not complying with the order. Community members can organize to monitor compliance, request independent water testing, and push for stronger local oversight. Anyone concerned about similar issues at other water systems can check their public water system’s compliance record through EPA databases or state health departments.
You can read the consent decree by visiting the EPA’s website: https://yosemite.epa.gov/OA/RHC/EPAAdmin.nsf/Filings/F8C3DE8B6B809A0E85258B8700687C0D/$File/SDWA-08-2024-0004%20Leisure%20Valley%20Consent%20Agreement.pdf
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