Ohiolchagrin.epa.ohio.gov/edoc/images/DSWNOV20120105/1...NPDES Compliance Inspection Report...
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Environmental Ohiol Protection Agency John R. Kasich, Governor Mary Taylor, It. Governor Scott J. Nally, Director December 28, 2011 Mr. Jim Brett Westland Development Limited Corporation 5700 Dry Fork Road Cleves, Ohio 45002 Re: Hamilton County, Dry Fork MHP, Compliance Evaluation Inspection Dear Mr. Brett: On December 9, 2011, I conducted a Compliance Evaluation Inspection at the Dry Fork MHP (NPDES Permit No. 0H0109380; OEPA Permit No. IPY00001*BD). The inspection was also conducted as part of renewing your NPDES Permit. You were representing this facility. A copy of my inspection report is enclosed. The inspection report contains three unsatisfactory areas. The Effluent / Receiving Waters section was rated unsatisfactory as a result of the numerous NPDES Permit violations. The Records / Reports section was rated unsatisfactory as a result of the failure to submit numerous timely Discharge Monitoring Reports, Noncompliance Notifications, and annual sludge disposal reports. The Permit section was rated unsatisfactory as a result of the failure to submit a timely NPDES Permit renewal application. On June 24, 2011, you were notified that your NPDES Permit renewal application had not been submitted as required. In this letter, I indicated that enforcement action would be recommended by this office if the NPDES Permit renewal application was not submitted by July 31, 2011. The renewal application was not submitted until November 15, 2011. As a result, this office has recommended enforcement action be taken pursuant to Ohio Revised Code Chapter 6111. The areas noted in the report summary will require a written response by January 20, 2012. The response should include a description of the actions proposed to correct the violations and the dates anticipated for completion of these actions. Southwest District Office 937 1285 6357 401 East Fifth Street 937 1285 6249 (tax) Dayton, ON 45402-2911 www.epa.ohiogov
Transcript of Ohiolchagrin.epa.ohio.gov/edoc/images/DSWNOV20120105/1...NPDES Compliance Inspection Report...
EnvironmentalOhiol Protection Agency
John R. Kasich, GovernorMary Taylor, It. GovernorScott J. Nally, Director
December 28, 2011
Mr. Jim BrettWestland Development Limited Corporation5700 Dry Fork RoadCleves, Ohio 45002
Re: Hamilton County, Dry Fork MHP, Compliance Evaluation Inspection
Dear Mr. Brett:
On December 9, 2011, I conducted a Compliance Evaluation Inspection at the Dry ForkMHP (NPDES Permit No. 0H0109380; OEPA Permit No. IPY00001*BD). Theinspection was also conducted as part of renewing your NPDES Permit. You wererepresenting this facility. A copy of my inspection report is enclosed.
The inspection report contains three unsatisfactory areas. The Effluent / ReceivingWaters section was rated unsatisfactory as a result of the numerous NPDES Permitviolations. The Records / Reports section was rated unsatisfactory as a result of thefailure to submit numerous timely Discharge Monitoring Reports, NoncomplianceNotifications, and annual sludge disposal reports. The Permit section was ratedunsatisfactory as a result of the failure to submit a timely NPDES Permit renewalapplication.
On June 24, 2011, you were notified that your NPDES Permit renewal application hadnot been submitted as required. In this letter, I indicated that enforcement action wouldbe recommended by this office if the NPDES Permit renewal application was notsubmitted by July 31, 2011. The renewal application was not submitted until November15, 2011. As a result, this office has recommended enforcement action be takenpursuant to Ohio Revised Code Chapter 6111.
The areas noted in the report summary will require a written response by January 20,2012. The response should include a description of the actions proposed to correct theviolations and the dates anticipated for completion of these actions.
Southwest District Office 937 1285 6357401 East Fifth Street 937 1285 6249 (tax)Dayton, ON 45402-2911 www.epa.ohiogov
Mr. Jim BrettDecember 28, 2011Page 2
If you have any questions, please call me at (937) 285-6096.
Sincerely,
..7 ) ()
Ned SarleDivision of Surface WaterPermits Section
Enclosure
C***MState of Ohio Environmental Protection Agency
Southwest District Office
NPDES Compliance Inspection ReportSemi-Public Sewage Disposal Inspection Form
Section B: Facility DataName and Location of Facility Inspected Entry Time 1 Permit Effective Date
Dry Fork MHP 10:00A.M. 11/1/20065700 Dry Fork Road ExitTime PermitExpirationDateCleves, Ohio 45002 12:05 P.M. 10/3112011Name(s)andTitle(s)ofOn-SiteRepresentatives PhoneNumber(s)Jim Brett, Owner (513) 265-7481
Name, Address and Title of Responsible Official PhoneNumberJim Brett, Owner (513) 265-74815700 Dry Fork RoadCleves, Ohio 45002
Section C: Areas Evaluated During Inspection(S _Satisfactory, M= Marginal, U = Unsatisfactory, N _ Not Evaluated)
Permit S FlowMeasurement _N _PretreatmentRecords/Reports S Laboratory _S _Compliance ScheduleOperations&Maintenance U Effluent/ReceivingWaters _S _Self-Monitoring ProgramFacilitySiteReview S SludgeStorage/Disposal _Nj_OtherCollection System
Section D: Summary of Findings (Attach additional sheets If necessary)
See Attached Summary of Findings / Comments.
Inspector Reviewer
xJ_J1- Ned Sarle Date Martyn Burl t DtePermit Section Compliance & Enforcement SupervisorDivision of Surface Water Division of Surface WaterSouthwest District Office Southwest District Office
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Permit #: I PY0000I *BDNPDES#: 0H0109380
Average Daily Design Flow: 31,200 Gallons/DayPlant Serves: 100 unit Mobile Home ParkAverage Daily Flow: 11,000 Gallons/Day(Period of Review): (November 2010 to October 2011)Method of flow monitoring: surface sand filter dosing pump meterType of alarms for plant: High water alarms
Pretreatment
Type of Pretreatment: Trash TrapDoes the Trash Trap need pumped: NoMaintenance of pretreatment components is: Good
Tri State Liauid Waste oums trash traD once ever y month.
Secondary Treatment(Aeration)
Color of sludge: Medium BrownQuality of Sludge: MediumFoam: None presentOdor: No objectionable odor present
Yes I No
Yes I NoAeration is taking placeBlowers are operatingSkimmers are operatinDiffusers are operatingSludoe return is olerati
Plant is septicBlowers are on a timerPlant is floodedGratina is Dresent
Maintenance of aerating equipment is. Good
I
Secondary Treatment(Settling)
Clarity:
ClearCondition of Weir:
CleanWeir is level:
YesEffluent in weir:
Clear
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Permit #: 1 PY0000I*BDNPDES #: 0H0109380
Clarifier walls need scraped: No
Overall maintenance of settling components is: Good
mments/Status:
Tertiary Treatment
Yes I NOSurface sand filters: Slow
Subsurface
Distribution box operating
Beds alternatedAre filters pond ing/floodin Beds rakedSand filters overgrown
Chlorination presentUV present
Dechlorination Dresent
Overall maintenance of components is: Good
mments/Status:
Sludge Handling/Storage Disposal
Hauler name: Tri State Liquid WasteDisposal Site: MSD Mill Creek WWTPSludge wasted from: Secondary ClarifierHow often is sludge wasted: Once every 3 to 4 weeksSludge drying beds: No Sludge holding tank: Yes
Overall maintenance of components is: Good
entslStatus:was recently hauled from the WWTP for the first time in 8
Plant Discharge
Discharge point is a: StreamName of discharge point: Dry Fork of the Whitewater RiverDischarge is visible: Yes Quality of Effluent: Clear
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Permit #: 1PY00001*BDNPDES #: OHO 109380
Summary of Findings I Comments
Areas Requiring a Response
An annual sludge disposal report is required to be submitted by January 31 of eachfollowing year. This is addressed in Part II, Section K of the NPDES Permit. The 2007,2008 and 2010 annual sludge disposal reports were not submitted as required by thepermit.
A review of the Discharge Monitoring Reports (DMRs) for January 2008 throughOctober 2011 indicated numerous effluent violations. These violations are listed onAttachment I. You have failed to report these violations in accordance to the NPDESPermit. Better effort must be taken to prevent future violations. Future violations mustbe reported as required by the NPDES Permit as detailed in Part 111.12 titled"Noncompliance Notification." NPDES Permit violations may also be reported inaccordance to the new Ohio EPA reporting requirements. These reportingrequirements are addressed at the following Ohio EPA website:http://www.epa.state.oh.us/dsw/permits/permits.aspx . Please indicate what actions willbe taken to prevent future violations and to report any violations that do occur.
Dry Fork MHP collects the WWTP effluent samples. The temperature, dissolvedoxygen, chlorine residual and pH are tested on-site. The TSS, Ammonia, FecalColiform and CBOD5 wastewater samples are analyzed by Dennis Feichtner. StandardOperating Procedures (SOPs) for the tests conducted by the Dry Fork MHP must bedeveloped. An SOP for the wastewater sample collection and handling must also bedeveloped. Dry Fork MHP does not have any written SOPs. These written SOPs mustbe completed by May 31, 2012. Once completed, please provide the Ohio EPA with acopy of these SOPs. A General Lab Criteria checklist was provided during theinspection. We will be using this check list during future inspections.
The TSS, ammonia and CBOD5 wastewater samples are taken as grab samples. TheNPDES Permit requires that these samples be taken as composites. The compositesampling requirements are addressed in Part II, Section E of the NPDES Permit.
You were sent Notice of Violation letters dated September 8, 2008; April 21, 2011 andJune 24, 2011. In addition, you were sent Compliance Evaluation Inspection reportsdated November 20, 2008 and September 21, 2009. Dry Fork MHP was required tosubmit responses for each of these correspondences. However, you did not addressany of them.
Area Not Requiring a Response
The NPDES Permit expired on October 31, 2011. The permit required that a renewalapplication be submitted 180 days prior or by April 30, 2011. Dry Fork MHP failed tosubmit this renewal application until November 15, 2011.
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Permit #: 1 PY00001 *BDNPDES #: 0H0109380
The DMRs are required to be submitted by the 201h of the following month. Thisrequirement is addressed in NPDES Permit in Part Iii, Section 4 titled "Reporting."Numerous reports have been submitted late. These late reports are addressed onAttachment II.
The WWTP consists of a trash trap, a flow equalization tank, two aeration tank, twosecondary clarifiers, two surface sand filters, a chlorine contact tank and adechlorination tank with post aeration. An aerated sludge holding tank is also provided.The surface sand filters both appear to need additional sand.
The WWTP is designed for an average daily flow rate of 31,200 gpd and a peak dailyflow rate of 107,522 gpd. For November 2010 through October 2011 the average dailyflow rate was 11,000 gpd, and the peak daily flow rate was 19,000 gpd.
The park has a permitted capacity of 100 mobile homes. Currently, only 89 spaces areoccupied.
The WWTP is required to be under the supervision of a Class I wastewater operator.Jim Brett is currently a Class I wastewater operator. The required Operator of Recordform was submitted on January 31, 2011. The required operator log book is maintainedat the WWTP.
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Permit #: 1PY00001*BDNPDES #: OHOI 09380
Attachment I
Dry Fork MHP
Effluent Limit Violations for January 2008 through October 2011
Limit Permit ReportedReporting Period Parameter Type Units Limit Value
January 2008January2008January 2008January 2008May 2008May 2008May 2008May 2008May 2008June 2008June 2008July 2008July 2008July 2008July 2008July 2008July 2008July 2008July 2008September 2008September 2008May 2009May 2009May 2009May 2009May 2009May 2009May 2009June 2009June 2009June 2009June 2009June 2009June 2009June 2009July 2009July 2009
AmmoniaAmmoniaAmmoniaAmmoniaAmmoniaAmmoniaAmmoniaAmmoniaAmmoniaAmmoniaAmmoniaFecal ColiformAmmoniaAmmoniaAmmoniaAmmoniaFecal ColiformAmmoniaFecal ColiformAmmoniaAmmoniaFecal ColiformFecal ColiformFecal ColiformAmmoniaAmmoniaAmmoniaFecal ColiformCBOD5AmmoniaAmmoniaAmmoniaAmmoniaAmmoniaAmmoniaAmmoniaAmmonia
MonthlyMonthlyWeeklyWeeklyMonthlyMonthlyWeeklyWeeklyWeeklyMonthlyWeeklyMonthlyMonthlyMonthlyWeeklyWeeklyWeeklyWeeklyWeeklyMonthlyWeeklyMonthlyWeeklyWeeklyMonthlyWeeklyWeeklyWeeklyMonthlyMonthlyMonthlyWeeklyWeeklyWeeklyWeeklyMonthlyMonthly
mg/Ikg/daymg/Img/Img/Ikg/daymg/Ikg/daymg/Img/Img/I#/lOOmImg/Ikg/daymg/Ikg/day#/1 OOmlmg/I#/1 OOmlmg/Img/I#/1 OOmI#11 OOml#/lOOmIkg/daymg/Ikg/day#/ lOOm Img/Img/Ikg/daymg/Ikg/daymg/Ikg/daymg/Ikg/day
3.00.354.54.51.00.121.50.181.51.01.510001.00.121.50.1820001.520001.01.51000200020000.121.50.182000101.00.121.50.181.50.181.00.12
9.10.509.19.23.50.194.90.302.09.19.131114.7
0.188.50.3322005.044001.73.345822100100000.61190.611000011100.53140.755.80.316.50.23
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Permit #: 1 PY00001 *BDNPDES#: 0H0109380
Attachment
Dry Fork MHP
Effluent Limit Violations for January 2008 through October 2011
Limit Permit ReportedReporting Period Parameter Type Units Limit Value
July 2009July 2009August 2009August 2009February 2010May 2010May 2010July 2010May 2011May 2011
AmmoniaAmmoniaFecal ColiformFecal ColiformCBOD5AmmoniaAmmoniaAmmoniaAmmoniaAmmonia
WeeklyWeeklyMonthlyWeeklyWeeklyMonthlyWeeklyWeeklyMonthlyWeekly
mg/Ikg/day#11 OOnil#/lOOmlkg/daymg/Im gilmg/Img/Img/I
1.50.18100020001.81.01.51.51.01.5
130.45380038002.31.11.81.61.53.1
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Permit #: IPY0000I*BDNPDES#: 0H0109380
Attachment Ii
Dry Fork MHP
Late Discharge Monitoring Reports
Required DMR DMRs SubmittedFacility Station Report Period Received Late
Dry Fork MHP IDry Fork MHP 1Dry Fork MHP 1Dry Fork MHP 1Dry Fork MHP 1Dry Fork MHP 1Dry Fork MHP 1Dry Fork MHP 1Dry Fork MHP IDry Fork MHP IDry Fork MHP 1Dry Fork MHP 1Dry Fork MHP 1Dry Fork MHP 1Dry Fork MHP 1Dry Fork MHP 1Dry Fork MHP 1Dry Fork MHP IDry Fork MHP IDry Fork MHP IDry Fork MHP 1Dry Fork MHP 1Dry Fork MHP 1Dry Fork MHP 1Dry Fork MHP 1Dry Fork MHP 1Dry Fork MHP IDry Fork MHP IDry Fork MHP 1Dry Fork MHP 1Dry Fork MHP 1Dry Fork MHP 1Dry Fork MHP 1Dry Fork MHP IDry Fork MHP 1Dry Fork MHP 1Dry Fork MHP 1
1/1/20082/1/20083/1/20083/1/20084/1/20085/1/20086/1/20087/1/20088/1/20089/1/200810/1/200811/1/200812/1/20081/1/20092/1/20093/1/20094/1/20095/1/20096/1/20097/1/20098/1/20099/1/200910/1/200911/1/200912/1/20091/1 /20 102/l/20103/l/20104/1/20105/l/20106/l/20107/1/20108/1/20109/1/201010/l/201011/1/201012/l/2010
7/22/20087/22/20087/22/20087/22/2008
7/22/20087/22/20088/22/200810/24/200810/24/20082/21/20099/15/20099/15/20099/15/20099/15/20099/15/20099/15/20099/15/20099/15/20099/15/20099/15/200910/19/200911/23/200912/17/20091/18/20102/19/20103/17/20104/20/20105/17/20106/17/20107/26/20108/18/20109/13/201010/18/201011/17/201012/14/20101/12/2011
YesYesYesYesMissing ReportYesYesYesYesYesYesYesYesYesYesYesYesYesYesYesNoNoYesNoNoNoNoNoNoNoYesNoNoNoNoNoNo
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Permit #: 1 PY0000I*BDNPDES #: 0H0109380
Attachment II
Dry Fork MHP
Late Discharge Monitoring Reports
RequiredFacilityStation Recort Period
Dry Fork MHP 1Dry Fork MHP 1Dry Fork MHP 1Dry Fork MHP 1Dry Fork MHP 1Dry Fork MHP IDry Fork MHP 1Dry Fork MHP 1Dry Fork MHP 1Dry Fork MHP 1Dry Fork MHP 1
1/1/20112/1/20113/l/20114/1/20115/1/20115/1/20116/1/20117/1/20118/1/20119/l/201110/1/2011
DMR DMRs SubmittedReceived Late
2/9/2011 No3/18/2011 No4/6/2011 No5/9/2011 No6/20/2011 No7/18/2011 Yes7/18/2011 No8/18/2011 No9/14/2011 No10/20/2011 No11/17/2011 No
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