Document rMyvLm5d4Z53dKqdmXKkpgnr
BEFORE THE UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
In the Matter of:
DOCKET NO. CWA-10-2025-0044
JOHN CANNON AND NANCY CANNON ADMINISTRATIVE ORDER ON CONSENT
Greenbank, Washington
Respondents.
I. INTRODUCTION 1.1. The U.S. Environmental Protection Agency (EPA) makes the findings set forth in Section IV below and is issuing this Administrative Order on Consent ("Order") to John Cannon and Nancy Cannon ("Respondents") under the authorities in Sections 308 and 309(a) of the Clean Water Act ("CWA"), 33 U.S.C. 1318 and 1319(a). 1.2. This Order is mutually entered into by the EPA and Respondents. 1.3. The EPA alleges that Respondents violated CWA Section 301(a), 33 U.S.C. 1311(a), by discharging a pollutant or pollutants into navigable waters from a point source without authorization by a Department of Army permit issued by the U.S. Army Corps of Engineers ("Corps") pursuant to CWA Section 404, 33 U.S.C. 1344. 1.4. By entering into this Order, Respondents (1) consent to the EPA's authority to issue and enforce this Order; (2) neither admit nor deny the factual allegations as set forth in this Order; (3) agree to undertake all actions required by the terms and conditions of this Order; (4) consent to be bound by the requirements set forth herein; and (5) agree not to contest the authority of the EPA to issue or enforce this Order or the validity of any terms or conditions in this Order.
II. STATUTORY AUTHORITY 2.1. CWA Section 301(a), 33 U.S.C. 1311(a), prohibits the discharge of any pollutant by any person except, inter alia, as authorized by a permit issued by the Corps pursuant to CWA Section 404, 33 U.S.C. 1344. 2.2. CWA Section 309(a), 33 U.S.C. 1319(a), provides that whenever the EPA finds that any person is in violation of any condition or limitation that implements, inter alia, CWA Sections 301(a) and 404, 33 U.S.C. 1311(a) and 1344, the EPA shall issue an order requiring such person to comply with such condition or limitation, and shall specify a time for compliance that the EPA determines to be reasonable taking into account the seriousness of the violation and any good faith efforts to comply with applicable requirements. 2.3. CWA Section 308(a), 33 U.S.C. 1318(a), authorizes the EPA to require the submission of any information required to carry out the objectives of the CWA. 2.4. The authorities in CWA Sections 308 and 309(a), 33 U.S.C. 1318 and 1319(a), have been delegated to the Regional Administrator for EPA Region 10 and have been redelegated to the Region 10 Director of the Enforcement and Compliance Assurance Division ("Director").
III. DEFINITIONS 3.1. All terms used, but not defined, in this Order have the meanings provided to them in the CWA, 33 U.S.C. 1251 et seq., and the EPA regulations promulgated under the CWA. 3.2. "Act" or "CWA" means the Clean Water Act, 33 U.S.C. 1251 et seq. 3.3. "Day" or "days" means a calendar day or calendar days unless expressly stated to be a business day. When computing any period of time under this Order, should the last day fall on a Saturday, Sunday, or federal holiday, the period shall run until the end of the next business day.
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U.S. Environmental Protection Agency 1200 Sixth Avenue, Suite 155, 11-C07 Seattle, Washington 98101
3.4. "Discharge of a pollutant," as defined in CWA Section 502(12), means inter alia,
"any addition of any pollutant to navigable waters from any point source." 33 U.S.C.
1362(12).
3.5. "Discharge of dredged material," as defined in 40 C.F.R. 232.2, means inter
alia, "any addition of dredged material into, including redeposit of dredged material other than
incidental fallback within, the waters of the United States."
3.6. "Discharge of fill material," as defined in 40 C.F.R. 232.2, means inter alia,
"the addition of fill material into waters of the United States."
3.7. "Dredged material," as defined in 40 C.F.R. 232.2, means "material that is
excavated or dredged from waters of the United States."
3.8. "Fill material," defined in 40 C.F.R. 232.2, means inter alia, "material placed in
waters of the United States where the material has the effect of: (i) Replacing any portion of a
water of the United States with dry land; or (ii) Changing the bottom elevation of any portion of
a water of the United States."
3.9. "High tide line," defined in 33 C.F.R. 328.3, means inter alia, "the line of
intersection of the land with the water's surface at the maximum height reached by a rising tide."
3.10. "Navigable waters," as defined in CWA Section 502(7), means "the waters of the
United States, including the territorial seas." 33 U.S.C. 1362(7).
3.11. "Parties" means the EPA and Respondents.
3.12. "Person," as defined in CWA Section 502(5), means an "individual, corporation,
partnership, association, State, municipality, commission, or political subdivision of a State, or
any interstate body." 33 U.S.C. 1362(5).
3.13. "Point source," as defined in CWA Section 502(14), means "any discernible,
confined and discrete conveyance . . . from which pollutants are or may be discharged." 33
U.S.C. 1362(14).
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U.S. Environmental Protection Agency 1200 Sixth Avenue, Suite 155, 11-C07 Seattle, Washington 98101
3.14. "Pollutant," as defined in CWA Section 502(6), means "dredged spoil, solid waste, incinerator residue, sewage, garbage, sewage sludge, munitions, chemical wastes, biological materials, radioactive materials, heat, wrecked or discarded equipment, rock, sand, cellar dirt, and industrial, municipal, and agricultural waste discharged into water." 33 U.S.C. 1362(6).
3.15. "Site" means the parcel owned, possessed, and controlled by Respondents at 3700 Oceanside Drive, Lagoon Point, Division 2, Lots 6 and 7, near latitude 48.0755621 N and longitude - 122.6126405 W, in Greenbank, Island County, Washington.
IV. FINDINGS OF FACT AND LAW 4.1. Respondents are individuals. Therefore, each Respondent is a "person" as defined by CWA Section 502(5), 33 U.S.C. 1362(5). 4.2. At all times relevant to this Order, Respondents owned the Site, and retained and directed a contractor to perform work resulting in unauthorized discharges at the Site. 4.3. The Site abuts Admiralty Inlet, in the Puget Sound. Admiralty Inlet and Puget Sound are subject to the ebb and flow of the tide and are traditional navigable waters. As such, Admiralty Inlet and Puget Sound are "navigable waters" within the meaning of CWA Section 502(7), 33 U.S.C. 1362(7). 4.4. In or around March 2023, persons acting on behalf of Respondents used certain heavy mechanical earthmoving equipment, including but not necessarily limited to excavators, loaders, and/or dump trucks to discharge fill material, including boulders and rip rap rock, along approximately 120-linear feet of the Site below the high tide line of Admiralty Inlet and Puget Sound. 4.5. The heavy mechanical earthmoving equipment referenced in Paragraph 4.4 of this Order is a "point source" within the meaning of CWA Section 502(14), 33 U.S.C. 1362(14).
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U.S. Environmental Protection Agency 1200 Sixth Avenue, Suite 155, 11-C07 Seattle, Washington 98101
4.6. The fill material that persons acting as the operator on behalf of Respondents
caused to be discharged, as referenced in Paragraph 4.4 of this Order, include boulder and rip rap
rock, which constitutes "fill material" within the meaning of 40 C.F.R. 232.2, and which
constitutes a "pollutant" within the meaning of CWA Section 502(6), 33 U.S.C. 1362(6).
4.7. By causing such fill material to enter waters of the United States, including
Admiralty Inlet and Puget Sound, Respondents engaged in the "discharge of pollutants" from a
point source within the meaning of CWA Sections 301(a) and 502(12), 33 U.S.C. 1311(a) and
1362(12).
4.8. According to the State of Washington Department of Fish and Wildlife, the fill
material discharged below the high tide line of Admiralty Inlet and Puget Sound altered the
natural intertidal flow and circulation patterns and likely increased the wave energy deflecting
off the face of the boulder rock armoring, which disrupts sediment transport and accretion
processes; increases scouring and erosion of the beach substrate; impacts habitat for migration,
feeding, and rearing during periods of high wave energy, which makes the nearshore
environment inhospitable for forage fish and juvenile salmon.
4.9. Because Respondents are the owners of the Site and directed the operator to
engage in the discharge of pollutants from a point source into navigable waters, Respondents and
the Site have been subject to the CWA at all times relevant to this Order. Thus, any such
discharge has been and is subject to the CWA.
4.10. During all times relevant to this Order, Respondents were not issued a Corps
permit pursuant to CWA Section 404, 33 U.S.C. 1344.
4.11. Respondents are each a person whose activities caused the discharge of
pollutant(s) from point source(s) into navigable waters, without a permit pursuant to the CWA
Section 404, 33 U.S.C. 1344. Accordingly, each instance in which Respondents discharged
pollutant(s) to navigable waters, is a violation of CWA Section 301, 33 U.S.C. 1311.
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U.S. Environmental Protection Agency 1200 Sixth Avenue, Suite 155, 11-C07 Seattle, Washington 98101
4.12. Each day that the fill material remains in place without the required permit constitutes a violation of CWA Section 301(a), 33 U.S.C. 1311(a).
4.13. Taking into account the seriousness of these violations and any good faith efforts to comply with applicable requirements, the parties acknowledge and agree that the schedule for compliance contained in Section V of this Order is reasonable and appropriate.
V. COMPLIANCE MEASURES Based upon the foregoing findings and the authority granted to the undersigned Director, it is hereby ordered and agreed to in accordance with CWA Sections 308 and 309(a), 33 U.S.C. 1318 and 1319(a), that Respondents comply with the following actions: 5.1. Prohibition of Discharge: Respondents shall not discharge any additional pollutants into any waters of the United States at the Site except in compliance with this Order or a permit issued pursuant to the CWA. 5.2. Rock Removal: No later than February 15, 2025, Respondents shall have completely removed all boulder and rip rap rock discharged in front of the existing bulkhead and below the high tide line of Admiralty Inlet and Puget Sound at the Site. That boulder and rip rock removal shall comply with the following terms and conditions:
5.2.1. Respondents shall not perform boulder and rip rap rock removal activities or operate heavy mechanical earthmoving equipment within the work area during periods of tidal inundation;
5.2.2. Respondents shall maintain only one access point to the beach work area for ingress and egress of heavy mechanical earthmoving equipment;
5.2.3. Respondents shall maintain the work area and the use of heavy mechanical earthmoving equipment on the beach to a maximum 25-foot wide work corridor waterward of the existing bulkhead;
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U.S. Environmental Protection Agency 1200 Sixth Avenue, Suite 155, 11-C07 Seattle, Washington 98101
5.2.4. Prior to commencement of boulder and rip rap rock removal activities, highly visible marking flags shall be staked on the beach and removed at the end of the workday prior to tidal inundation of the beach in order to visibly highlight and delineate the limits of the work corridor for the operator established by Paragraph 5.2.3 of this Order;
5.2.5. Heavy mechanical equipment operations and/or staging, and construction material(s) shall not extend waterward on the beach area outside the limits of the work corridor established by Paragraph 5.2.3 of this Order;
5.2.6. Respondents shall place rubber mats or other types of ground protective construction matting along the beach work corridor established by Paragraph 5.2.3 of this Order for heavy mechanical equipment access and operations to minimize impacts to the beach substrate;
5.2.7. Respondents shall check equipment daily for leaks and complete any required repairs before operating the equipment in the work corridor on the beach established by Paragraph 5.2.3 of this Order or near Admiralty Inlet and/or Puget Sound;
5.2.8. Respondents shall use lubricants composed of biodegradable base oils such as vegetable oils, synthetic esters, and polyalkylene glycols for use in equipment operated in or near water;
5.2.9. Respondents shall prevent contaminants such as petroleum products, hydraulic fluid, fresh concrete, sediments, sediment-laden water, chemicals, or any other toxic or harmful materials, from entering or leaching into Admiralty Inlet and/or Puget Sound;
5.2.10. Respondents shall maintain oil spill clean-up materials (e.g., absorbent socks, pads, mats, etc.) and containment materials (floating plastic foam or
In the Matter of: John Cannon and Nancy Cannon Docket Number: CWA-10-2025-0044 Administrative Order on Consent Page 7 of 15
U.S. Environmental Protection Agency 1200 Sixth Avenue, Suite 155, 11-C07 Seattle, Washington 98101
fiber booms, etc.) on Site in order to respond to accidental releases and spills of
petroleum products into Admiralty Inlet and/or Puget Sound;
5.2.11. Respondents shall not stockpile excavated boulders and rip rap
rock and other materials on the beach waterward of the high tide line of Admiralty Inlet
and/or Puget Sound;
5.2.12. If heavy surface flow or precipitation conditions arises that will
result in erosion or sediments potentially entering Admiralty Inlet and/or Puget Sound,
Respondents shall cease all heavy mechanical equipment operations and boulder and rip
rap rock removal activities, except those needed to control erosion and sedimentation;
5.2.13. Other than the boulder and rip rap rock discharged at the Site,
Respondents shall not remove from the Site any native beach sand or gravel, large woody
logs and stumps or other natural habitat features during the boulder and rip rap rock
removal activities;
5.2.14. Respondents shall remove any construction debris that may have
broken off on the beach during the removal process (e.g. concrete chunks, angular rock
pieces) and shall transport and dispose of this debris material to an upland location where
it will not contact waters of the United States;
5.2.15. Upon project completion, Respondents shall reshape and grade the
beach substrate where depressions and trenches have formed during project work
activities to its approximate pre-disturbance elevations and contours;
5.2.16. Following removal of all boulder and rip rap rock and any
construction debris, Respondents shall dispose of materials at an off-Site upland location
approved by the Island County Planning and Community Development Department;
5.2.17. Respondents shall comply with all other federal, state, and local
authorizations and permits.
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U.S. Environmental Protection Agency 1200 Sixth Avenue, Suite 155, 11-C07 Seattle, Washington 98101
5.3. Notification Prior to Work Activities: At least three (3) days prior to commencing
the work activities on the Site required by Paragraph 5.2 of this Order, Respondents shall provide
written notification to the EPA contacts identified in Paragraph 6.1 of this Order and include: (1)
Respondents' names; (2) work location address; (3) the dates certain when the boulder and rip
rap rock removal activities on the Site will commence and conclude; (4) the name(s) and contact
information (e.g., cell phone, email, etc.) of all individuals operating on the Site; and (4) a list of
heavy mechanical equipment performing the work activities on the Site as required by Paragraph
5.2 of this Order.
5.4. Notification Following Completion of Work Activities: No more than seven (7)
days after completing the work activities on the Site required by Paragraph 5.2 of this Order,
Respondents shall provide written notification to the EPA contacts identified in Paragraph 6.1 of
this Order and include: (1) Respondents' names; (2) work location address; (3) the dates certain
when the boulder and rip rap rock removal activities on the Site concluded; (4) the name(s) and
contact information (e.g., cell phone, email, etc.) of all individuals operating on the Site; and (5)
a list of heavy mechanical equipment that performed the work activities on the Site as required
by Paragraph 5.2 of this Order.
5.5. Completion Report: Within thirty (30) days of completing the activities on the
Site required by Paragraph 5.2 of this Order, Respondents shall provide the EPA contacts
identified in Paragraph 6.1 of this Order with a Completion Report, which shall include digital
photographs of the Site conditions before and after completion of the work activities required by
Paragraph 5.2 of this Order and a narrative summary of Respondents' compliance with all of the
requirements of Paragraph 5.2 of this Order. The Completion Report shall comply with the
requirements of Section VI of this Order, including but not limited to the requirements of
Paragraph 6.3 of this Order. The EPA will review and, if appropriate, approve the Completion
Report after receipt of Respondents' written notification. The EPA may request a Site visit to
In the Matter of: John Cannon and Nancy Cannon Docket Number: CWA-10-2025-0044 Administrative Order on Consent Page 9 of 15
U.S. Environmental Protection Agency 1200 Sixth Avenue, Suite 155, 11-C07 Seattle, Washington 98101
inspect the completion of work activities prior to approving the Completion Report. If the EPA
does not approve the Completion Report, Respondents shall be notified of the actions necessary
to obtain the EPA's approval.
5.6. Site Access: Until termination of this Order, Respondents shall, commencing on
the Effective Date, provide or otherwise obtain for the EPA, reasonable access to the areas of the
Site owned by Respondent and exert their best efforts to obtain reasonable access to any off-Site
areas to which access is necessary to implement this Order. Respondents shall provide access to
all records and documentation reasonably related to the conditions at the Site and the restoration
activities conducted pursuant to this Order. Such access shall be provided to EPA employees
and its designated representatives. These individuals shall be permitted to move freely at the Site
and, if access is granted thereto, appropriate off-Site areas in order to conduct actions which the
EPA determines to be necessary, so long as they do not unreasonably interfere with any of
Respondents' activities at the Site.
VI. DOCUMENTATION AND SUBMISSIONS
6.1. All reports, notifications, documentation, submissions, and other correspondence
required to be submitted by this Order shall be submitted to the EPA electronically, to the extent
possible.
6.1.1. Electronic submissions shall be sent to the following addresses:
R10enforcement@epa.gov, jen.mark@epa.gov, and johnson.patrick@epa.gov.
6.1.2. The email subject line shall include the docket number of this
Order and subject of the deliverable.
6.1.3. All materials must be in final and text-searchable format, such as
Portable Document Format (PDF) with Optical Character Recognition (OCR) applied.
6.2. If electronic submittal is not possible, the submissions must be made by certified
mail (return receipt requested). Mailed submissions must be sent to the following addresses:
In the Matter of: John Cannon and Nancy Cannon Docket Number: CWA-10-2025-0044 Administrative Order on Consent Page 10 of 15
U.S. Environmental Protection Agency 1200 Sixth Avenue, Suite 155, 11-C07 Seattle, Washington 98101
Attn: Mark Jen U.S. Environmental Protection Agency Region 10, Alaska Operations Office 222 West Seventh Avenue, No. 19 Anchorage, Alaska 99513
Attn: Patrick Johnson U.S. Environmental Protection Agency Region 10, Alaska Operations Office 222 West Seventh Avenue, No. 19 Anchorage, Alaska 99513
6.3. All reports, notifications, documentation, and submissions required by this Order
must be signed by Respondents and/or a duly authorized representative as specified by 40 C.F.R.
122.22(b) and (d) and must include the following statement:
"I certify under penalty of law that this document and all attachments were prepared under my direction or supervision in accordance with a system designed to assure that qualified personnel properly gather and evaluate the information submitted. Based on my inquiry of the person or persons who manage the system, or those persons directly responsible for gathering the information, the information submitted is, to the best of my knowledge and belief, true, accurate, and complete. I am aware that there are significant penalties for submitting false information, including the possibility of fine and imprisonment for knowing violations."
6.4. Respondents may not withhold information based on a claim that it is confidential. However, pursuant to 40 C.F.R. Part 2, Subpart B, Respondents may assert a claim of business confidentiality regarding any portion of the information submitted in response to this Order. The manner of asserting such claims is specified in 40 C.F.R. 2.203(b). Information subject to a business confidentiality claim is available to the public only to the extent, and by means of the procedures, set forth in 40 C.F.R. Part 2, Subpart B. If Respondents do not assert a claim of business confidentiality when it submits the information, the EPA may make the information available to the public without further notice. 40 C.F.R. 2.203(c).
6.5. If Respondents find at any time after submitting information that any portion of that information is false or incorrect, the signatory must notify the EPA immediately. Knowingly submitting false information to the EPA in response to this Order may subject
In the Matter of: John Cannon and Nancy Cannon Docket Number: CWA-10-2025-0044 Administrative Order on Consent Page 11 of 15
U.S. Environmental Protection Agency 1200 Sixth Avenue, Suite 155, 11-C07 Seattle, Washington 98101
Respondents to criminal prosecution under CWA Section 309(c), 33 U.S.C. 1319(c), as well as
18 U.S.C. 1001 and 1341.
6.6. Submissions by Respondents are incorporated and enforceable as part of this
Order. In case of inconsistency between any submission by Respondents and this Order and its
subsequent modifications, this Order and its subsequent modifications shall control.
6.7. The EPA may use any information submitted in response to this Order in support
of an administrative, civil, or criminal action against Respondents.
6.8. The information required to be submitted pursuant to this Order is not subject to
the approval requirements of the Paperwork Reduction Act of 1995, 44 U.S.C. 3501 et seq.
6.9. Respondents shall preserve and retain, and shall instruct its consultant, contractor,
and other persons acting on their behalf in connection with this Order, to preserve and retain all
records and documents relating in any manner to this Order until the EPA has issued a written
notice pursuant to Paragraph 12.3 of this Order. If the EPA asks Respondents for any copies of
any records or documents related to the activities conducted pursuant to this Order, Respondents
shall, at no cost to the EPA, provide the EPA the original or copies of the records or documents
within thirty (30) days of the EPA's request.
VII. GENERAL PROVISIONS
7.1. Respondents have had the opportunity to confer with and submit information to
the EPA concerning the validity and provisions of this Order.
7.2. This Order does not affect Respondents' responsibility to comply with the CWA
and other local, state, and federal laws and regulations.
7.3. The undersigned signatory for each party has the authority to bind each respective
party to the terms and conditions of this Order.
7.4. Respondents agree to accept service of the Order and other EPA correspondences
by electronic mail to nbcmiles@gmail.com.
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U.S. Environmental Protection Agency 1200 Sixth Avenue, Suite 155, 11-C07 Seattle, Washington 98101
7.5. This Order shall be binding on Respondents and their agents, employees, successors, and assigns, and on all persons, contractors, and consultants acting in concert with or under the direction of Respondents or of this Order.
7.6. Respondents shall provide a copy of this Order to all operators, contractors, and/or consultants retained to perform any of the work described in this Order at least 48 hours prior to the initiation of such work.
7.7. Until such time as all tasks required under this Order are completed, Respondents shall provide a copy of this Order to any successor in ownership, control, or operation in all or any portion of the real property at issue at least thirty (30) days prior to the transfer and shall simultaneously notify the EPA in writing that such notice has been given. No transfer or contract shall in any way affect Respondents' obligation to comply fully with all the terms and conditions of this Order.
7.8. This Order does not restrict the EPA's authority to enforce any section of the CWA or its implementing regulations.
7.9. For purposes of the identification requirement of Section 162(f)(2)(A)(ii) of the Internal Revenue Code, 26 U.S.C. 162(f)(2)(A)(ii), and 26 C.F.R. 1.162-21(b)(2), performance of Section V of this Order, is restitution, remediation, or required to come into compliance with law.
7.10. The EPA reserves all rights and remedies, legal and equitable, available to address any violation cited in this Order and any other violation of the CWA, and to enforce this Order. Neither issuance of this Order by the EPA nor compliance with its terms precludes further enforcement action pursuant to CWA Section 309, 33 U.S.C. 1319, for the violations cited in this Order, for any other violations of the CWA committed by Respondents, or to enforce this Order.
In the Matter of: John Cannon and Nancy Cannon Docket Number: CWA-10-2025-0044 Administrative Order on Consent Page 13 of 15
U.S. Environmental Protection Agency 1200 Sixth Avenue, Suite 155, 11-C07 Seattle, Washington 98101
VIII. SANCTIONS
8.1. Failure to comply with the terms of this Order may subject Respondents to civil
penalties under CWA Section 309(d), 33 U.S.C. 1319(d), as modified by 40 C.F.R. Part 19.
Should the EPA commence an action seeking penalties for violations of this Order, a United
States district court has the authority, after notice and opportunity for a hearing, to impose
separate civil penalties for violation of the CWA as well as for violation of this Order.
IX. MODIFICATION OF ORDER
9.1. The deadlines set forth in this Order may be modified upon written approval by
the EPA. Any other modification of this Order shall be by agreement of all Parties and in
writing and shall not take effect until the written agreement is signed by all Parties.
X. JUDICIAL REVIEW
10.1. Respondents waive any and all remedies, claims for relief, and otherwise
available rights to judicial or administrative review that Respondents may have with respect to
any issue of fact or law set forth in this Order, including, but not limited to, any right of judicial
review of this Order under the Administrative Procedure Act, 5 U.S.C. 701-708.
XI. EFFECTIVE DATE
11.1. This Order shall become effective upon the execution of the Order by both parties
and will remain in effect until Respondents have demonstrated compliance and the EPA has
notified Respondents pursuant to Section XII of this Order.
XII. FINAL REPORT AND TERMINATION
12.1. The EPA may terminate this Order at any time by written notice to Respondents.
12.2. Absent the notice described in Paragraph 12.1 of this Order, upon the EPA's
approval of the Completion Report pursuant to Paragraph 5.5 of this Order, the EPA will notify
Respondents whether they have satisfied all requirements of this Order under the procedures set
forth in Section VI of this Order. If the EPA concludes that Respondents have failed to satisfy
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U.S. Environmental Protection Agency 1200 Sixth Avenue, Suite 155, 11-C07 Seattle, Washington 98101
the r quirements fthi Order, the EPA ma require further actions a set forth under thi s Order or it may pursue administrative or civil judicial actions. lf the EPA concludes that Respondents ha e satisfied all requirements of this Order this Order shall be terminated. 1T IS SO STIPULATED AND AGREED. FOR RESPO DENT JOHN CANNON:
FOR RE PO DE TNAN Y CAN 0
TT rs so ORDERED AND AGREED.
FOR COMPLAINANT:
EDWARD KOWALSKI
Digitally signed by EDWARD KOWALSKI Date: 2025.01.22 08:56:05 -08'00'
Ed-v ard J. Km alski , Director Enforcement and Compli ance Assurance Division EPA Region 10
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