,IEPAchagrin.epa.ohio.gov/edoc/images/DSWNOV20130416/3PK0003220130411161… · ,IEPA 40 years and moving forward John R. Kasich, Governor Mary Taylor, ft Governor Scott J. Nally,

EPA,I40 years and moving forward

John R. Kasich, Governor

Mary Taylor, ft Governor

Scott J. Nally, Director

April 11, 2013

RE: LAKE COUNTYVILLAGE OF MADISON W\NTPNPDES PERMIT NO. 0H0023515OHIO EPA PERMIT NO, 3PK00032

Mr. Sam Britton, Jr., MayorVillage of Madison126 W. Main StreetMadison, 01-I 44057-0007

Dear Mayor Britton:

On April 9, 2013, this writer conducted a compliance evaluation inspection of the Village ofMadison Wastewater Treatment Plant. The purpose of the inspection was to evaluate thewastewater treatment plant's operation and maintenance condition, and to evaluate the facility'scompliance with the National Pollutant Discharge Elimination System (NPDES) permit. Mr.James Borsi of AKE Laboratories, Operator of Record, and Mr. Dan Gerson, P.E. of URSConsultants, Village Engineer, accompanied this writer during the inspection.

Wastewater Treatment Plant ObservationsAt the time of inspection, operation of the plant was satisfactory. The plant was discharging aneffluent of satisfactory visual quality, free from debris, suspended solids, oil and grease. Generaloperation and maintenance of the grounds, processes and equipment were satisfactory. Sludgecake is disposed via landfilling at the Lake County Solid Waste Facility.

NPDES PermitDischar.ge Monitoring Reports (DMRs)A review of the DMRs covering the period of December 2011 through March 2013 revealed thefollowing effluent limitation violations:

Reporting Reported ViolationCode Parameter. . Urnit ype -Valvp No

001 00530 Total Suspended Solids 30D Conc 16 39,75 12/112011

001 00530 Total Suspended Solids 300 Qty 30.3 119.719 12/1/2011

001 00530 Total Suspended Solids 70 QIy 45.4 65.5183 12/1/2011

001 00610 Nitrogen, Ammonia (NH3 30D Qty 11.0 12.6331 1211/2011

001 80082 CBOD 5day 30D Qty 24.6 24.9516 12/112011

001 00665 Phosphorus, Total (F) 300 Conc 0.73 .93 12/112011

001 00665 Phosphorus, Total (F) 300 Qty 1.4 2.897 12/1/2011

001 50092 Mercury, Total (Low Level) 300 Qty 0.000019 .00003 12/1/2011

001 00530 Total Suspended Solids 70 Cone 24 82. 12/8/2011

001 00530 Total Suspended Solids 7D Qty 45.4 205.911 12/8/2011

001 00530 Total Suspended Solids 70 Cone 24 31.5 12/15/2011

001 00530 Total Suspended Solids 70 Oty 45.4 113.145 12/15/2011

001 00530 Total Suspended Solids 7D Cone 24 30.5 12122/2011

Northeast District Office • 2110 East Aurora Road Twinsburg, OH 44087-1924www.epa.ohio.gov • (330) 963-1200 • (330) 487-0769 (fax)

001001001001001001001001001001001001001001001001001001001001001001001001001001001001001001001001001001001001001001001001001

0053000610006650053000530005300053080082006650053000530005300061080082800520053000530500925009200610006100061000610006100061000610006100061000610006100061000610006100066500530006100061000610006100053000610

VILLAGE OF MADISON WINTPAPRIL 11, 2013PAGE 2 OF 4

Total Suspended SolidsNitrogen, Ammonia (NH3)Phosphorus, Total (P)Total Suspended SolidsTotal Suspended SolidsTotal Suspended SolidsTotal Suspended SolidsCBOD 5 dayPhosphorus, Total (P)Total Suspended SolidsTotal Suspended SolidsTotal Suspended SolidsNitrogen, Ammonia (NH3)CBOD SdayCBOD 5 dayTotal Suspended SolidsTotal Suspended SolidsMercury, Total (Low Level)Mercury, Total (Low Level)Nitrogen, Ammonia (NH3)Nitrogen, Ammonia (NH)Nitrogen, Ammonia (NH3)Nitrogen, Ammonia (NH3)Nitrogen, Ammonia (NH3)Nitrogen, Ammonia (NH3)Nitrogen, Ammonia (NH3)Nitrogen, Ammonia (NH3)Nitrogen, Ammonia (NH3)Nitrogen, Ammonia (NH3)Nitrogen, Ammonia (NH3)Nitrogen, Ammonia (NH3)Nitrogen, Ammonia (NH3)Nitrogen, Ammonia (NH3)Phosphorus, Total (P)Total Suspended SolidsNitrogen, Ammonia (NH3)Nitrogen, Ammonia (NH3)Nitrogen, Ammonia (NH3)Nitrogen, Ammonia (NH3)Total Suspended SolidsNitrogen, Ammonia (NH3)

70 Qty70 Qty7D Qty30D Conc70 Cone30D Qty70 Qty300 Qty300 Qty7D Oty7D Cone70 Qty70 Qty70 Cone7D Qty7D Conc70 Qty300 Cone300 Qty300 Cone300 Qty7D Conc70 Qty70 Cone70 Qty70 Cone7D Qty300 Cone70 Cone30D Qty70 Qty70 Cone70 Oly300 Cone30D Qty30D Cone30D Qty70 Cone70 Qty7D Qty30D Qty

45.416.52.1162430.345.424.61.445.42445.416.519.536.92445.410,10.0000191.73.22.64.92.64.92.64.91,72.63.24,92.64.90.7330.31.73.222.64.9345.511

94.301318.24442.89721.2528.60.085466.116329.23251.702850.811735.113.07317,798220,570.264730.53061911.6.000035.0786. 869 113.8256.405017.8510.17404.7656.575723.11256.383.921488.070964.6156. 14302.7935.74421.914.198765.2259.6364253.504711,7758

12/22/201112122/201112/22/20111/1/20121/1120121/1/2012111/20121/1/20121/1/20121/15/20121/22/20121/22/20121/22120121/22/20121/22/20122/22/20122/22/20123/1/20123/1/20125/1/20125/1/20125/8/20125/8120125/15/20125/15/20125/22/20125/22/20126/1/20126/1/20126/1/20126/1/20126/8/20126/8/20127111201210/1/201210/1/20121011/201210/8/201210/8/201211/1/201212/1/2012

The Data Substitution Code "AH" was used numerous times during the months of July 2012 andAugust 2012, citing in the comment section "unaware that the new permit became effective'.This is a misuse of the data substitution codes and is considered a violation of the NPDESpermit. This agency expects the village and its operator to be aware of the requirements of theNPDES and to conduct the required monitoring and reporting of data as required by the NPDESpermit.

VILLAGE OF MADISON WWTPAPRIL 11, 2013PAGE 3 OF 4

Part II, Item U of the existing NPDES permit requires Total Kjeldahl Nitrogen, Total Nitrite plusNitrate, and Total Phosphorus at Outfalls 001 and 901 to be monitored on the same day. Duringthe inspection, Mr. Borsi stated that he collects the samples for these pollutants on the sameday, as required. However, a review of the DMRs shows that monitoring for Total Nitrite plusNitrate and Total Phosphorus during the months of August 2012 and December 2012 were notperformed on the same days. If this is a clerical error, the error must be corrected in the DMRsystem.

A review of the DMRs also shows a Sanitary Sewer Overflow was reported on October 29, 2012for Station 300. Sanitary Sewer Overflow Occurrences at Station 300 are for overflows thatoccur in the collection system only. The overflow that was reported on October 29, 2012occurred at the wastewater treatment plant. The occurrence was reported on the form for Non-Compliance Notification for Bypasses and Upsets (Form 4498) as required, but should not bereported at Station 300 of the DMR system. Please make the necessary corrections to the DMRsystem.

Other Reporting RequirementsPart II, Item 0 (1) (g) of the existing NPDES permit requires the submittal of an annual PollutantMinimization Plan report to meet the general mercury variance requirements. The annual reportis due by March l of each year. To date, this office has not received the required reports to besubmitted for 2012 and 2013. Be advised that failure to submit these reports in a timely manneris a violation of the NPDES permit and may result in replacing the general mercury variancewith a water quality based mercury effluent limitation of 1.3 ng/l. If the annual reports have beensubmitted to the DSW Central Office, please provide this office with copies.

The Sewage Sludge Disposal Annual Report for 2012 was submitted on January 28, 2013;however, this office does not have record of receipt of the Sewage Sludge Disposal AnnualReport for 2011 which was to have been submitted by January 31, 2012- Failure to submit therequired report is a violation of the NPDES permit. Please immediately submit the requiredreport.

Be advised that failure to comply with the effluent limitations or to satisfy the monitoring orreporting and compliance scheduling requirements of your NPDES permit may be cause forenforcement pursuant to Ohio Revised Code Chapter 6111.

Sanitary Sewer Long Term Maintenance PlanThe Sanitary Sewer Long Term Maintenance Plan was submitted and accepted by this office onJanuary 14, 2013. The Village will meet with Ohio EPA on July 1 s' of each year to discuss theprogress made and status of the sanitary sewer collection system. During this meeting, theVillage will provide this office with a written summary of the street location of workperformed/completed each year and the street location of work anticipated to be performed forthe following year.

Actions to be Taken by PermitteeWithin 10 days of the date of this letter, you are directed to notify this office, in writing, outliningthe corrective action, either actual or proposed, that will be taken to eliminate the abovehighlighted deficiencies.

VILLAGE OF MADISON VW/TPAPRIL 11, 2013PAGE 4 OF 4

Should you have any questions regarding this letter, please contact the undersigned at(330)963-1183.

Sincerely,

VIA ^t4L/," A,Marie Underwood, P.E.Environmental EngineerDivision of Surface Water

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