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Mar 30, 2018
C) 1110 I EnvironmentalProtection AgencyJohn R. Kasich, GovernorMary Taylor, Lt. GovernorScott J. Nally, Director
February 1, 2012
Ms. Marilyn J. ColeBrookville LLC2526 Stafford PlaceColumbus, Ohio 43209
Re: Montgomery County, Brookville Lake Estates Mobile Home Park, ComplianceEvaluation Inspection and Notice of Violation
Dear Ms. Cole:
On January 18, 2012, I conducted a Compliance Evaluation Inspection at BrookvilleLake Estates Mobile Home Park (NPDES Permit No. 0H0040631; OEPA Permit No.1 PV00035*FD). Representing the facility was Mr. Damon Shell of Brookville LakeEstates and Mr. Bob Gomez of Winelco, Inc..
I have included with this letter a copy of the inspection report and General Lab Criteria.This letter also serves as a Notice of Violation. The following findings are listed aseither observation or violations and will require a written response. The findings are asfollows:
1. During the inspection it was discovered that there was not a written StandardOperating Procedures for the analysis of pH in the field. A written StandardOperating Procedure is required for all analysis being performed by the facility oron behalf of the facility.
2. A logbook is not being maintained for the pH meter. A logbook is required to bemaintained so that all maintenance and calibration activities can be documentedas required.
3. During the inspection it was discovered that there was not a written StandardOperating Procedures for the collection of samples. It was also discovered thatthe sample description was not on the sample bottles. A written StandardOperating Procedure is required for the collection of samples and a sampledescription is required to be on the label of the sample bottle.
4. It was determined during the inspection that the thermometer used for monitoringtemperature has not been calibrated using an NIST traceable thermometer. All
Southwest District Office 937 1285 6357401 East Fifth Street 937 1285 6249 (fax)Dayton, OH 45402-2911 wswepa.ohio.gov
Ms. Marilyn J. ColeFebruary 1, 2012Page 2
thermometers used for monitoring either the temperature of the final effluent orused to monitor the temperature during the analysis of a sample a required to becalibrated using an NIST or NIST traceable thermometer.
1. The inspection revealed the bypassing of treatment as described in the attachedinspection report (see pictures in attachment 2). The bypassing of treatment is aviolation of Part III, Item 11 of permit 1PV00035*FD. A written responseregarding this violation is required.
2. It was apparent during the inspection that the surface sand filters had anexcessive amount of solids on them. The excessive amount of solids on thesurface sand filters prevented them from operating properly. The failure tomaintain the treatment works in good working order is a violation of Part Ill, Item3 of permit 1PV00035 tFD. A written response regarding this violation isrequired.
3. As part of the inspection process a compliance scan was performed of the datasubmitted on the Data Monitoring Reports submitted by the facility. Several FinalEffluent Limit violations and Frequency / Monitoring Violations were identified andare listed in Attachment 1 of this inspection report. A written response regardingthis violations is required.
4. During the inspection it was discovered that the facility design has been modifiedin an attempt to alleviate excessive flow spikes entering the treatment process. Itis my understanding the modifications were intended to be a short termexperiment and were not intended to be a permanent modification. Ohio RevisedCode 6111.44 requires the submission of a Permit to Install application and theapproval of said application prior to the modification of treatment works. A Permitto Install application has not been submitted for the aforementionedmodifications.
Please inform this office, in writing, within ten days of receipt of this notification as to thereason for the above referenced violations, as well as a description of the actions takenor proposed to prevent further violations. Your response should include the dates,either actual or proposed, for completion of said actions. Please be advised that failureto comply with the effluent limitations, monitoring, or reporting requirements of yourNPDES Permit may be cause for enforcement action pursuant to the Ohio RevisedCode Chapter 6111.
On January 4, 2012 the Ohio EPA sent you a draft of the NPDES permit for the facility.As you know the draft permit included a Compliance Schedule which is designed toallow time for the Brookville Lake Estates MHP to connect to public sewers. OnJanuary 19 you indicated that you would require an additional 10 days or so to complete
Ms. Marilyn J. ColeFebruary 1, 2012Page 3
your review and provide comments. I look forward to receiving your commentsregarding the draft permit and compliance schedule.
If you have any questions regarding this matter please feel free to contact me at (37)285-6107 or via email at: RobertOstendorfepa.state.oh.us .
j1Bob Ostendorf Jr.Division of Surface WaterPermits Section
cc: Mr. Bob Gomez, Winelco, Inc.
State of Ohio Environmental Protection AgencySouthwest District Office
NPDES Compliance Inspection ReportSemi-Public Sewage Disposal Inspection Form
Section B: Facility DataName and Location of Facility Inspected Entry Time Permit Effective Date
Brookville Lake Estates MHP 2:00 October 1, 2006
8588 Francie Drive Exit Time Permit Expiration DateBrookville, OH 45309
3:30 September 30, 2011
Name(s) and Title(s) of On-Site Representatives Phone Number(s)Mr. Damon Shell, Park Manager 937-829-5005Mr. Bob Gomez, Operator (Winelco, Inc.) 513-755-8050
Name(s), Address and Title(s) of Operator of Record Phone Number(s)
Robert Armstrong (WW1 -1015880-98) 513-755-8050Robert Gomez (WW1-1065576-05) 513-755-8050Andrew Griner (WWI -1010126-94) 513-755-8050Greg Ross (WW3-1013587-96) 513-755-8050Mike Ullman (WW3-1007257-83) 513-755-8050
Name, Address and Title of Responsible Official Phone NumberMs. Marilyn J. ColeBrookville Lake Estates 614-404-04458588 Francie DriveBrookville, OH 45309
Ohio EPA Inspector Ohio EPA Reviewer
Bob Ostendorf Jr. Date Martyn Burt DateDivision of Surface Water Compliance & Enforcement SupervisorSouthwest District Office Division of Surface Water
Southwest District Office
Permit #: 1 PV00035*FDN.JPDES #: 0H0040631
Average Daily Design Flow: 21,000 Gallons/DayPlant Serves: Mobile Home ParkAverage Daily Flow: 17,013 Gallons/Day(Period of Review): (May 1, 2011 January 1, 2012)Method of flow monitoring: Elapsed time meterType of alarms for plant: None
Type of Pretreatment: OtherDoes the Trash Trap need pumped: N/AMaintenance of pretreatment components is: Fair
;ommentsitatus:The facility is not equipped with a trash trap. Per the operators logbook the facility routinely removesdebris from the pumps.
Color of sludge: Light BrownQuality of Sludge: MediumFoam: None presentOdor: No objectionable odor present
Yes I No
Yes I NoAeration is taking placeBlowers are operatingSkimmers are operatingDiffusers are operatingSludae return is ooeratin
Plant is septicBlowers are on a timerPlant is floodedGratinci is Dresent
Maintenance of aerating equipment is. Fair
;ommentsitatus:Small alterations to the design of the plant have taken place to attempt to address the excessive flowreceived at the plant during rain events. It was discussed during the inspection that these alterationsshould be submitted on a Permit to Install application, It appears that during the alterations to the designof the plant inadequate pumping contributed to the overflow of MLSS out of the aeration tank and ontothe wound (see p ictures included with this insDection reoort).
Permit #: 1 PV00035*FDNFDES #: 0H0040631
Clarity:Condition of Weir:Weir is level:Effluent in weir:Clarifier walls need scraped
Overall maintenance of settling components is: Good
Yes I No
Yes I NoSurface sand Filters: Slow
Distribution box operating
Beds alternatedAre filters pond ing/flood ing
Sand filters overgrown
Chlorination presentUV present
Overall maintenance of components is: Poor
Comments/Status-Due to the hydraulic loadings on the facility excessive solids have entered the surface sand filters. Theexcessive solids have effectively blinded the filters causing ponding. There was also evidence that thesurface sand filters had overflowed onto the ground recently (see pictures included with this inspection
Sludge Handling/Storage Disposal
Hauler name: N/ADisposal Site: N/ASludge wasted from:How often is sludge wasted: N/ASludge drying beds: No Sludge holding tank: No
Overall maintenance of components is: N/A
Comments/Status:Wasting from the facility was discussed during the inspection. I directed them to OEPA technicalassistance website.
Permit #: 1 PV00035*FDNPDES : 0H0040631
Record Keeping! Operator of Record
(a) Wastewater Treatment Works classification (OAC 3745-7)..........(b) Operator of Record holds unexpired license of class required by
Permit..............................................................................(c) Copy of certificate of Operator of Record displayed on-site..........(d) Has the Operator of Record submitted an ORC Notification form..(e) Minimum