STATUTORY DEMAND FOR ADMINISTRATIVE ACTION
DATE: July 3, 2026
TO: Office of the Regional Administrator
U.S. EPA Region 6
1201 Elm Street, Suite 500
Dallas, TX 75270
CC: EPA Office of Inspector General (OIG); EPA Criminal Investigation Division (CID)
FROM: Matthew Andrew Duffy, INACTIVE Licensed Water Treatment Operator AAAAC #103850
CASE REFERENCE: Oklahoma City Water Utilities Trust (Hefner, Overholser, and Draper Plants)
NOTICE TYPE: Formal Escalation Demanding Technical Review
1. PURPOSE & MANDATE FOR ESCALATION
This letter constitutes a formal demand for administrative escalation regarding ongoing violations at Oklahoma City (OKC) Water. Previous intake communications have failed to engage personnel with the mandatory technical competency to evaluate engineering fraud.
This case involves complex chemical manipulation, public health risks, and market-impacting procurement fraud that cannot be processed by administrative call-screeners. I am formally demanding that this file be immediately reassigned to a Senior Enforcing Officer, Technical Engineer, or CID Special Agent.
2. SUBSTANTIVE TECHNICAL VIOLATIONS REQUIRING SENIOR REVIEW
Administrative intake staff lack the statutory training to evaluate the evidence currently being withheld from senior engineers. A high-level investigator is required immediately to audit the following:
Chemical Procurement Fraud: Evidence demonstrating an estimated $44,000,000 variance in calcium hydroxide (lime) applications since 1960. This volume violates standard stoichiometric treatment parameters and points to data manipulation benefiting a publicly traded corporate supplier, United States Lime Minerals (USLM). Other chemicals involved: Oxygen, Ferric Sulfate, C02, Fluoride, Chlorine, Ammonia Phosphate & Polymer. TOTALING AN ESTIMATED ~$60 – 70 MILLION USD. STOCK COMPANIES AIRGAS-AIR LIQUIDE, AIR PRODUCTS & BRENNTAG.
Federal Drinking Water Violations: Systemic manipulation of chemical feed rates directly compromises the system's Langelier Saturation Index (LSI), destabilizing distribution piping and contributing to severe compliance risks under the Lead and Copper Rule (40 CFR § 141.80–141.91).
Suppression of Public Health Data: The deliberate masking of approximately 70 environmental and labor violations previously logged with the Oklahoma Department of Environmental Quality (DEQ).
https://www.change.org/p/is-okc-water-illegal/u/33413608
3. FORMAL DEMAND FOR REPLY
Under federal agency guidelines governing whistleblower disclosures and public safety threats, administrative silence or low-level screening is unacceptable.
Please accept this document as an official demand to issue a formal written response within 30 days detailing:
1. The name, title, and contact information of the Senior Technical Engineer or CID Special Agent assigned to audit these chemical logs.
2.The official federal tracking number under which this case is being reviewed.
“ILLEGAL OKC WATER PETITION” AT CHANGE DOT ORG
https://www.change.org/p/is-okc-water-illegal
MATTHEW ANDREW DUFFY
622 N 10TH ST THOMAS OK 73669
(580) 922-1004
BS ENVIRONMENTAL ENGINEERING TECHNOLOGY
INACTIVE WATER LICENSE #103850 AAAAC