Defendant Summary
Sentencings
Plea Agreements
Indictments/
informations
Environmental Crimes
Case Bulletin
U.S. Environmental Protection Agency
Office of Criminal Enforcement, Forensics and Training
in This Edition:
AAA Pest Protection Inc., William Robles—Region 4
Joseph V. Chernis, IV—Region 5
Sea World Management & Trading Inc., Edmond Fajardo—Region 6
Tyson Poultry Inc.—Region 7
OE Construction Corporation—Region 8
James Philip Lucero—Region 9
Charles Ray Mundy—Region 9
Dyno-Nobel, Inc.—Region 10
Andre Bernard—Region 10
This bulletin summarizes publicized investigative activity and adjudicated cases
conducted by OCEFT Criminal investigation Division special agents, forensic specialists,
and legal support staff. To subscribe to this monthly bulletin you may sign up for
email alerts on our publications page. Unless otherwise noted, all photos are provided
by EPA-CID.
February—March 2018
&EPA
United States
Environmental Protection
Agency
EPA Pub. 310-N-15-007

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Defendant Summary
Region
Defendants
Case Type/Status
4
AAA Pest Protection Inc. d/b/a AAA Pest Control,
Inc. (AAA Pest) and William Robles
Sentencing
5
Joseph J. Chernis, IV
Sentencing
6
Sea World Management & Trading Inc.
Edmond Fajardo
Plea Agreement
7
Tyson Poultry Inc.
Sentencing
8
OE Construction Corporation
Sentencing
9	James Philip Lucero	Indictment
9	Charles Ray Mundy	Sentencing
10
Dyno-Nobel, Inc.
Plea Agreement
10
Andre Bernard
Sentencing
I
© ft ®
Page 2
EPA Bulletin- Feb/Mar 2018

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Sentencings
New York Man Sentenced to 87 Months for Multi-State Biodiesel Fraud Scheme
Andre Bernard, 65, of Mount Kisco, NY was sentenced on February 6, 2018, to 87 months in federal prison
for conspiracy to commit wire fraud, making false statements related to the Clean Air Act, and his participa-
tion in a multi-state scheme to defraud biodiesel buyers and U.S. taxpayers by fraudulently selling biodiesel
credits and fraudulently claiming tax credits. As part of his sentence, the court also entered a money judg-
ment in the amount of $10.5 million, the amount of proceeds of the charged criminal conduct that the de-
fendant personally received. Two accounts already seized from the defendant worth more than $1.5 million
will be credited against the money judgment. Bernard was found guilty on August 2, 2017.
According to court documents, Bernard and his co-conspirators operated entities that purported to purchase
renewable fuel, on which credits had been claimed and therefore was ineligible for additional credits, pro-
duced by their co-conspirators at Gen-X Energy Group (Gen-X), headquartered in Pasco, Washington, and its
subsidiary, Southern Resources and Commodities (SRC), located in Dublin, Georgia. They then used a series
of false transactions to transform the fuel back into feedstock needed for the production of renewable fuel,
and sold it back to Gen-X or SRC, allowing credits to be claimed again. This cycle was repeated multiple
times.
"Today's sentencing shows that the Department of Justice will continue to vigorously prosecute those who
defraud the federal government and the American taxpayer through unlawful schemes," said Acting Assistant
Attorney General Wood. "We applaud the work of DOJ, EPA, and our other federal law enforcement part-
ners that sought and obtained justice in this case."
"We will not tolerate environmental fraud in the Renewable Fuels Program, or anywhere else." said EPA Ad-
ministrator Scott Pruitt. "This case highlights EPA's resolve in working with partners, nationally, to hold bad
actors accountable."
"The successful prosecution of these fraudsters is a testament to our commitment to combat crime at every
level," said U.S. Attorney Chapa Lopez. "We will continue to support our investigative partners in dismantling
such criminal schemes."
"Fraud against the United States and its citizens will continue to be targeted by the Secret Service," said Resi-
dent Agent in Charge Jeff Kelly with the U.S. Secret Service. "These complex investigations are only success-
fully accomplished with the dedication and partnership of our partner agencies and the U.S. Attorney Office
in bringing accountability."
From March 2013 to March 2014, the co-conspirators, including Bernard, generated at least 60 million cred-
its that were based on fuel that was either never produced or was merely re-processed at the Gen-X or SRC
facilities. The co-conspirators received at least $42 million from the sale of these fraudulent credits to third
parties. In addition, Gen-X received approximately $4.3 million in false tax credits for this fuel.
This case was investigated by EPA's Criminal Investigation Division, the U.S. Secret Service, and the IRS. The
case was prosecuted by DOJ.
Page 3
EPA Bulletin- Feb/Mar 2018

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Sentencings
Fumigation Company Sentenced, Owner Imprisoned After Illegal Pesticide Applications
AAA Pest Protection Inc. d/b/a AAA Pest Control, Inc. (AAA Pest), and owner William Robles, 59, of Fort
Lauderdale, Florida were sentenced on March 9, 2018 in federal court in connection with the illegal applica-
tion of pesticides to treat homes and other buildings for termites over several years.
AAA Pest was sentenced to five years of probation, ordered to implement and enforce a comprehensive envi-
ronmental compliance and employee training plan, and ordered to pay a $35,000 criminal fine. AAA Pest was
also ordered to pay restitution to the victims of the crimes. Robles was sentenced to the statutory maximum
term of imprisonment of one year and ordered to pay a criminal fine of $30,000. In a related matter, Pierce
Long, 53, of Oakland Park, Florida was previously sentenced to a year in prison.
AAA Pest, Robles, and Long previously pled guilty to knowing violations of federal law stemming from their
illegal applications of the restricted use pesticide, sulfuryl fluoride, contrary to the label's safety require-
ments.
According to court documents and statements, the Federal Insecticide, Fungicide and Rodenticide Act (FIFRA)
regulates the use of pesticides, including those designated for restricted use due to their potential adverse
effects, including serious injury or death. Application of these pesticides is limited to certified applicators or
those under the direct supervision of certified applicators. Sulfuryl fluoride, a commonly used antimicrobial
agent in structural fumigations for termites, is one such restricted use pesticide, registered with the EPA. At
the heart of the safe use of such pesticides is compliance with the product label, which includes written,
printed, or graphic matter associated with the pesticides that dictates the safe application, aeration, testing,
and clearance of the fumigant gas through the use of a properly functioning, maintained, and calibrated low-
level fumigant detection device.
The investigation revealed that on two separate occasions in 2016, AAA Pest
and Long completed structural fumigations without providing residents with the
proper warnings prior to introduction of the fumigant gases, did not use person-
al protective equipment for employees, failed to properly aerate the fumigated
spaces, failed to post required hazard warnings, and failed to conduct clearance
by ensuring that the fumigated space was free of the toxic gas before residents
re-entered. In addition, Robles admitted that between March 21, 2013, and
April 17, 2015, he failed to have the required, operable, and properly calibrated
fumigant detection device for approximately 580 fumigations.
"Today's sentencing sends an important message to companies, business own-
ers, and employees that knowing violations of federal environmental laws will
not be tolerated. Those who engage in such dangerous and reckless conduct
will be prosecuted to the fullest extent of the law in light of the serious conse-
quences for the consumer public," said Benjamin G. Greenberg. "The Southern
District of Florida values its partnership with the EPA, Criminal Investigation Di-
vision and the Florida Department of Agriculture and Consumer Services and is
committed to working together to investigate and prosecute these crimes to protect the public and ensure
ii
I
t is critical for
the health
and safety of building
inhabitants that pest
control companies
follow manufacturer
instructions when ap-
plying pesticides in-
doors"
-Susan Bodine
Page 4
EPA Bulletin- Feb/Mar 2018

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Sentencings
that companies who comply with the law are not placed at a competitive disadvantage."
"It is critical for the health and safety of building inhabitants that pest control companies follow manufactur-
er instructions when applying pesticides indoors," said Susan Bodine, Assistant Administrator of EPA's Office
of Enforcement and Compliance Assurance. "This case demonstrates that EPA and its law enforcement part-
ners are committed to making sure that businesses apply pesticides legally and safely."
The sentencing includes the fourth individual defendant to be sentenced to the statutory maximum term of
imprisonment in the District's ongoing effort to address pesticide crimes. It is estimated that there were
more than 25,000 structural fumigations in Miami-Dade and Broward counties in 2017. The Court noted that
these companies and individuals hold themselves out to the community as specially trained and skilled ex-
perts, and that families put their trust - and their lives - in the fumigators hands and should be able to return
to such "safe spaces" as one's home, without concern about whether the device used to measure if toxic gas
remained in the fumigated space, was working and maintained as required by law.
The case was investigated by EPA and the Florida Department of Agriculture and Consumer Services. The
case was prosecuted by DOJ.
Page 5
EPA Bulletin- Feb/Mar 2018

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Sentencings
llllinois Man Sentenced to Three Years in Prison for Violating Clean Air Act Related to
Asbestos Removal at Former Pillsbury Plant
On February 5, 2018, Joseph J. Chernis, IV was sentenced to serve 37 months in federal prison for failure to
adequately remove and dispose of asbestos material, violations of the Clean Air Act, at the former Pillsbury
Mills facility in Springfield. Following his prison term, Chernis, 35, was ordered to remain on supervised re-
lease for a period of three years, Chernis was ordered to self-report to prison when directed by the Bureau of
Prisons.
Chernis pled guilty on April 7, 2017, to three counts of violating
the Clean Air Act. Chernis admitted that he hired an untrained
worker to illegally remove dry asbestos pipe insulation from the
Pillsbury Mills facility. From October 2014 to August 2015, dry
asbestos-containing insulation was cut and stripped from pipes
inside four buildings at the facility, including the structure
known as the Dryer building.
"The defendant's illegal and reckless acts endangered the
health of those performing the asbestos removal and others,"
stated U.S. Attorney John E. Childress, "and caused the U.S. EPA to assume clean-up efforts at a cost of mil-
lions of dollars."
"Asbestos can cause cancer and other serious respiratory dis-
eases, so it is important that it be handled legally," said Brad
Ostendorf, Assistant Special Agent in Charge of EPA's criminal
enforcement program in Illinois. "The defendant knew the rules
regarding the legal removal of asbestos containing materials,
but ignored them. In this way, he threatened not only the envi-
ronment but the safety of his untrained workers and the gen-
eral public. This case demonstrates that EPA and its partner
agencies will not abide those who try to make money by break-
ing the law."
Under provisions of the Clean Air Act, the EPA has promulgated rules, regulations and requirements to con-
trol the removal, handling and disposal of asbestos, a hazardous air pollutant. Any owner or operator of a
renovation or demolition activity which involves removal of specified amounts of asbestos-containing materi-
al must comply with the EPA regulations.
The case was investigated by EPA's Criminal Investigation and prosecuted by EPA and DOJ attorneys.
Page 6
EPA Bulletin- Feb/Mar 2018

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Sentencings
Tyson Poultry Fined $2 Million for Violating the Clean Water Act
Tyson Poultry Inc. was sentenced in federal court in Springfield, Missouri, on February 27, 2018 to pay a $2
million criminal fine, serve two years of probation, and pay $500,000 to directly remedy harm caused when it
violated the Clean Water Act. The charges stemmed from discharges at Tyson's slaughter and processing fa-
cility in Monett, Missouri that led to a major fish kill event.
Tyson Poultry, the nation's largest chicken producer, is headquartered in Springdale, Arkansas, and is a sub-
sidiary of Tyson Foods Inc. According to court records, Tyson Poultry's conviction arose out of a spill at its
feed mill in Aurora, Missouri, where it mixed ingredients to produce chicken feed. One ingredient was a liquid
food supplement called "Alimet," which is a very strong acid with a pH of less than one. In May 2014, the
tank which was used to store Alimet at the Aurora feed mill sprang a leak. Tyson had the spilled substance
transported to its Monett plant where it was then discharged into the sewers and flowed into the City of
Monett municipal waste water treatment plant. The Alimet killed bacteria used to reduce ammonia in dis-
charges from the treatment plant. As a result, more ammonia was released from the plant into Clear Creek,
and approximately 108,000 fish were killed.
Under the terms of the plea agreement, Tyson Poultry also agreed to retain an independent, third-party audi-
tor to examine environmental compliance at Tyson Poultry facilities across the country; conduct specialized
environmental training at all of its poultry processing plants, hatcheries, feed mills, rendering plants, and
waste water treatment plants; and implement improved policies and procedures to address the circumstanc-
es that gave rise to these violations.
"Good corporate practices are vital to protecting public health and our nation's natural resources," said
Acting Assistant Attorney General Jeffrey H. Wood for the Environment & Natural Resources Division. "When
corporate misconduct disregards human safety or the environment in violation of federal laws, the Depart-
ment of Justice and EPA stand ready to pursue all necessary legal relief, including criminal penalties, to en-
sure that these acts do not go unpunished. We hope that the outcome of this case will be a lesson for all
companies that deal with dangerous wastes."
"Today's sentence not only remedies the harm Tyson Poultry caused locally, but puts safeguards in place to
prevent similar occurrences at Tyson Poultry facilities across the country," said U.S. Attorney Timothy A. Gar-
rison for the Western District of Missouri. "Tyson's $2.5 million fine and restitution payment reflects the seri-
ousness of this offense and our commitment to protect Missouri's natural resources."
"Today's sentencing not only holds Tyson Poultry accountable for their illegal actions, it includes important
requirements for the company to improve compliance with the law to prevent future violations," said Assis-
tant Administrator Susan Bodine for EPA's Office of Enforcement and Compliance Assurance. "This case ex-
emplifies EPA's commitment to protect clean water by pursuing the most egregious violations."
The case was investigated by EPA's Criminal Investigation Division. The case was prosecuted by DOJ ENRD
and Western District of Missouri litigation team.
Page 7
EPA Bulletin- Feb/Mar 2018

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Sentencings
Colorado Company Sentenced for Violating the Clean Air Act
Ori March 27, 2018, OE Construction Corporation, a Golden-based excavation and underground utility compa-
ny, pled guilty to being an accessory after the fact to violating the Clean Air Act, OE was sentenced to pay a
$15,000 fine and up to $55,000 in restitution to companies that purchased modified trucks from OE, The
company was also sentenced to three years of supervised probation, during which time the government will
closely monitor OE's trucks to ensure that their emissions systems are in compliance with state and federal
law.
According to the plea agreement, an employee at OE worked with a Canadian
company called J-Ball Electronics to falsify the monitoring devices required by
the Clean Air Act on at least six OE Construction-owned vehicles. The OE Con-
struction employee purchased kits from J-Ball that allowed him to alter the
vehicles' emission control systems. The effect of these modifications was to
dramatically increase the release of dangerous pollutants from these vehicles,
including particulate matter, NOx (mono-nitrogen oxides), and hydrocarbons.
When contacted by the government concerning these Clean Air Act violations, OE Construction admitted that
four vehicles had been modified, and assured the government that only the four vehicles had been tampered
with and that it had repaired the four vehicles. However, OE Construction did not reveal that J-Ball and OE's
employee had modified at least two other vehicles that OE Construction intended to put up for auction. In
this way, OE attempted to avoid detection, prosecution, and punishment for the additional vehicles that the
OE employee had modified.
"We take seriously our job of protecting the environment in Colorado, and we won't hesitate to prosecute
corporations or individuals committing environmental crimes," said U.S. Attorney Bob Troyer.
"Emission control devices for vehicles are required to ensure public health and safety," said Jeffrey Martinez,
special agent in charge of EPA's criminal enforcement program in Colorado. "The illegal actions in this case
were not isolated incidents or mistakes; they were deliberately and carefully planned. Today's sentencing
shows that EPA and its law enforcement partners will hold responsible those who violate laws designed to
protect the health of our communities."
This case was investigated by the EPA's Criminal Investigation Division. The prosecution was handled by DOJ
Assistant U.S. Attorneys.
Page 8
EPA Bulletin- Feb/Mar 2018

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Sentencings
Former Santa Clara Waste Water Vice President of Environmental Compliance Sentenced
On March 14, 2018, Charles Ray Mundy was sentenced to serve two years in the Ventura County jail for his
role in causing a 2014 explosion at Santa Clara Waste Water Company ("SCWWC"). Mundy previously76yyyik
pled guilty to felony offenses of knowing failure to warn of a serious concealed danger, disposal of hazardous
waste, filing a forged instrument, and reckless disregard for handling hazardous waste causing unreasonable
risk. Mundy also pled no contest to the felony offense of causing great bodily injury by emitting an air con-
taminant, and to the misdemeanor offenses of repeated violation of labor safety standards, and failure to up-
date a business plan. This case was jointly prosecuted by the Ventura County District Attorney's Office and the
California Attorney General's Office.
On November 18, 2014, an explosion occurred at 815 Mission Rock Road, Santa Paula, a wastewater treat-
ment facility owned and operated by SCWWC. Mundy was the former vice president of Environmental Com-
pliance and Facilities Operations at SCWWC. The explosion was caused by the reckless disposal of hazardous
chemicals with incompatible materials in a vacuum truck. Numerous employees and first responders were
injured either by the initial explosion or by inhaling toxic fumes,
While employed by SCWWC, Mundy was instru-
mental in obtaining 255 gallons of the chemical
sodium chlorite, a regulated hazardous material.
SCWWC was required to report the presence of
sodium chlorite in their Hazardous Materials Busi-
ness Plan (HMBP). Mundy failed to report that
sodium chlorite was present at the Santa Paula
location. Further, Mundy failed to disclose the
presence of sodium chlorite to first responders
immediately after the explosion. In addition,
Mundy provided false HMBP submissions by not
reporting 5,500 gallons of Petromax, a hazardous
hemical.
While executing search warrants in November 2014, police recovered forged analytical results in Mundy's
SCWWC office and later confirmed he prepared these forged results and submitted them to the City of
Oxnard, Mundy also failed to provide adequate training and personal protective equipment to employees
working on site.
In addition to the jail sentence, Mundy was ordered to pay victim restitution and will be placed on formal pro-
bation for three years. As a term of probation, Mundy is prohibited from employment in any capacity in the
waste water treatment industry.
The case was investigated by EPA's Criminal Investigation and prosecuted by the Ventura County District
Attorney's Office.
Photo Courtesy—Ventura County Fire Department
Page 9
EPA Bulletin- Feb/Mar 2018

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Plea Agreements
Tank Vessel Operator and Master Convicted for Oil and Garbage Offenses
Sea World Management & Trading Inc. and Edmon Fajardo were convicted on February 26, 2018 for main-
taining false and incomplete records relating to the discharge of oil and garbage from an oil tanker that was
operating off the coast of Texas.
Sea World Management & Trading Inc. is a tank vessel operating company, and Fajardo is the master of the
tank vessel Sea Faith. Both admitted that oil cargo residues and machinery space bilge water were illegally
dumped from the Sea Faith directly into the ocean while the vessel was transiting to Corpus Christi without
the use of required pollution prevention equipment. They also admitted that these discharges were not rec-
orded in the vessel's Oil Record Book as required. Specifically, on five different occasions between March 10,
2017, and March 18, 2017, Fajardo ordered crew members to illegally discharge oily waste from various loca-
tions of the vessel's cargo/deck spaces. These oily waste discharges bypassed the use of the vessel's required
oil discharge monitoring equipment and were done while the vessel was in the Caribbean Sea and the Gulf of
Mexico.
Sea World Management & Trading Inc. and Fajardo further admitted that on
March 10, 2017, and March 15, 2017, Fajardo ordered crew members to throw
plastics, empty steel drums, oily rags, batteries and empty paint cans directly
overboard into the ocean. None of these garbage discharges were recorded as
required in the vessel's Garbage Record Book.
Sea World Management & Trading Inc. and Fajardo pleaded guilty to two felo-
ny violations of the Act to Prevent Pollution from Ships for failing to accurately
maintain the Sea Faith's Oil Record Book and Garbage Record Book. Under the
terms of the plea agreement, the company will pay a total fine of $2.25 million
and serve a three-year term of probation during which all vessels the company
operated and calling on U.S. ports will be required to implement a robust Envi-
ronmental Compliance Plan. Fajardo was also sentenced to six months in prison
to be followed by two years of supervised release. He was also ordered to pay a $2,000 fine.
The case was investigated by the U.S. Coast Guard Corpus Christi Sector, U.S. Coast Guard Investigative Ser-
vice and EPA's Criminal Investigation Division. The case was prosecuted by DOJ's Environmental Crimes Sec-
tion litigation team.
Fajardo
ordered crew
members to
throw plastics, empty
steel drums, oily rags,
batteries and empty
paint cans directly
overboard into the
ocean.
Page 10
EPA Bulletin- Feb/Mar 2018

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Plea Agreements
Dyno-Nobel, Inc. Pleads Guilty for Failing to Notify Federal Authorities of Anhydrous Dis-
charges Near St. Helens
Ori February 23, 2018, Dyrio Nobel, Inc., pleaded guilty to one count of violating the Comprehensive Environ-
mental Response, Compensation, and Liability Act (CERCLA), following a series of large-scale ammonia dis-
charges from a urea-manufacturing plant outside St, Helens, Oregon, in July and August 2015.
"Many of the nation's environmental laws exist specifically to minimize the dangers essential industries pose
to surrounding communities," noted Billy J. Williams, U.S. Attorney for the District of Oregon, "and this crimi-
nal conviction will serve as an important reminder that the EPA and the United States Attorney's Office will
work together to ensure that violations of those laws do not go unpunished."
"Not only did this defendant release over six tons of anhydrous ammonia, impacting the neighboring commu-
nity, they impeded response actions by failing to report the release," said Jeanne Proctor, EPA's special agent
in charge of the Criminal Investigation Division in Seattle. "EPA will not tolerate this blatant disregard for pub-
lic safety."
According to Dyno Nobel's plea agreement with the govern-
ment, the company's St. Helens plant discharged more than six
tons of anhydrous ammonia vapor—a hazardous substance—
into the air over the course of a three-day period starting on
July 30, 2015. A subsequent investigation revealed that several
failed attempts to restart the urea plant had caused a series of
massive discharges from the facility, triggering numerous com-
plaints of foul odors, eye irritation, and difficulty breathing from
citizens of nearby Columbia City, Oregon.
Although Dyno Nobel personnel knew that excessive ammonia emissions were occurring, no effort was made
to alert the authorities at the National Response Center until August 7, 2015—more than a week after the
first discharge. Federal law requires such reports to be made "immediately."
Dyno Nobel, Inc. is a Delaware corporation and wholly owned subsidiary of IPL Group. The plea agreement
proposes a stipulated criminal sentence of two years' probation, requiring remedial steps to better measure
and detect future emissions, and a $250,000 criminal fine. Ultimately, however, the Court may reject the par-
ties' stipulation and impose a different sentence.
This case was investigated by EPA's Criminal Investigation Division and prosecuted by DOJ.
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EPA Bulletin- Feb/Mar 2018

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Indictments/Information
Missouri Man Indicted on Mail Fraud Charges
On January 10, 2018, Dale Johansen was indicted by a federal grand on four felony counts of mail fraud as
part of a scheme to defraud residents of Rogue Creek in Potosi, Missouri.
According to the Indictment, Johansen owned Johansen Consulting Services LLC and was appointed as the
receiver for Rogue Creek Utilities, Inc. which provided all sewer, water services and management to Rouge
Creek. Rouge Creek was a vacation community containing three lakes located in Potosi and composed of ap-
proximately 90 active connections to the drinking water and sewer systems. Johansen's duties as receiver
was to collect samples and provide proper operation at Rogue Creek, including the oversight and mainte-
nance of the water softener system
On March 9, 2016, the Missouri Department of Natural Resources (MDNR ) learned that the water softener
system at Rogue Creek was not operational and thus for at least six months, the residents were receiving well
water that was not treated for lead removal. On March 10, 2016, the water softener system was brought
back on-line so that the water was again being treated to remove lead. On March 11, 2016, the MDNR per-
formed testing on the drinking water which resulted three of five samples testing high for lead.
Johansen issued invoices to customers for water services and falsely represented to residents of Rogue Creek
that their well water was clean, disinfected and safe for human consumption. He also issued monthly invoic-
es for water services, including the removal of lead in their well water, with the knowledge that the well wa-
ter was not being treated for lead removal.
"EPA's Criminal Investigation Division takes any allegations involving a public drinking water system very seri-
ously," said Justin Oesterreich, Assistant Special Agent in Charge of EPA's criminal enforcement program in
Missouri. "We will continue to aggressively investigate and seek prosecution of those whose actions put pub-
lic health at risk."
If convicted, Johansen faces up to 20 years' imprisonment, a fine of $250,000 or both on each count. Restitu-
tion to the victim is also mandatory. In determining the actual sentences, a Judge is required to consider the
U.S. Sentencing Guidelines, which provide recommended sentencing ranges.
This case was investigated by the U.S. Environmental Protection Agency. Assistant United States Attorney
Dianna Collins is handling the case for the U.S. Attorney's Office.
An indictment merely alleges that crimes have been committed. The defendants are presumed innocent un-
til proven guilty beyond a reasonable doubt.
Page 12	EPA Bulletin—Feb/Mar 2018
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