Document LpVYNXNazZzomj99Jqvk70Xm3

EPA REGION 5 Enforcement and Compliance Assurance Division INSPECTION REPORT Inspection Entry Date/Time Inspection Exit Date/Time Weather Media Statute(s)/Program(s) Type of Inspection 04/22/2025 09:00 AM (ET) 04/22/2025 11:10 AM (ET) Announced: Yes Access: Granted Water Clean Water Act, NPDES, Wastewater Treatment Plant (WWTP) Compliance Evaluation Inspection (CEI) Permittee Name Facility or Site Name Facility/Site Physical Address City, State, Zip Code County/Borough/Parish Facility GPS Coordinates Mailing Address (If different) City, State, Zip Code Madison County Sewer District #2 WWTP Madison County Sewer District #2 WWTP 2795 Old Columbus Rd London, OH 43140 39.9486, -83.49014 FRS ID 110014326292 Permit Number(s) (If Applicable) OH0130915 SIC and/or NAICS 4952 Lead Inspector: Joseph Forth JOSEPH FORTH EPA REGION 5 Digitally signed by JOSEPH FORTH Date: 2025.06.13 10:47:33 -05'00' Forth.Joseph@epa.gov (312) 886-7275 Supervisor Review: Molly Smith MOLLY SMITH EPA REGION 5 Digitally signed by MOLLY SMITH Date: 2025.06.13 11:13:20 -05'00' Smith.Molly@epa.gov (312) 353-8773 SECTION I - INTRODUCTION Site Entry and Inspection Objectives EPA REGION 5 Lead Inspector, Joseph Forth, arrived at the Madison County Sewer District #2 WWTP (the "site" or "facility"), located at 2795 Old Columbus Rd, London, Ohio 43140, at 09:00 AM ET on April 22, 2025 for an announced inspection. EPA REGION 5 Lead Inspector presented credentials to Gordon Pool and informed the Facility that this was an EPA REGION 5 inspection to investigate elements of the Clean Water Act (CWA) Section 308 and implementing regulations. This report is based on information supplied by 1 of 13 Madison County Sewer District #2 WWTP Inspection Date(s): 04/22/2025 Madison County Sewer District #2 WWTP representatives, direct observations made by the EPA REGION 5 inspectors, records and reports maintained by the permittee and other information including: photographs taken by EPA REGION 5 inspectors, physical evidence collected by the EPA REGION 5 inspectors, measurements taken by EPA REGION 5 inspectors, verbal or written statements made by information supplied by Madison County Sewer District #2 WWTP representatives during or subsequent to the on-site Inspection, and materials, processes, data, photographs, or documents shown, demonstrated, or submitted to the EPA REGION 5 inspectors by Madison County Sewer District #2 WWTP representatives during or subsequent to the on-site Inspection. In addition, information gathered prior to or subsequent to the Inspection from a review of EPA, State, and/or public records may be included in this report. Attendees Organization Attendee Name EPA Region 5 EPA Region 5 Ohio EPA Mid-Ohio Water & Sewer District Mid-Ohio Water & Sewer District Joseph Forth Matthew Schulte Joanna Asuncion Gordon Pool Daniel Fonseca Facility/Site Description Title Lead Inspector Inspector Inspector Field Supervisor/Operator Operations Supervisor Present in Opening Conf. Yes Yes Yes Yes Yes Present in Closing Conf. Yes Yes Yes No Yes EPA REGION 5 lead inspector confirmed the following facility information: The WWTP has a max designed flow of 300,000 gallons per day (gpd). The average daily flow is approximately 100,000 to 130,000 gpd. Flow enters the facility via pumped flow and starts with pre-screening. The flow is then split into 2 extended aeration basins. Each aeration basin has a corresponding clarifier the flow enters. Flow is then combined and enters a tertiary sand filter process. Then the flow goes through ultraviolet (UV) disinfection and a post aeration system. Finally, the flow is lifted via lift station and discharged from Outfall 001 to Deer Creek. The facility also has a 150,000-gallon equalization basin that flow can be diverted to during periods of high flow/storm events. The facility has 10 employees, 3 of which are certified operators. The field supervisor is on-site between 20 and 30 hours per week. All sludge is hauled to London City WWTP (also operated by Mid-Ohio facility) for further treatment. Processed sludge is then utilized in land application. At the time of the inspection, the facility has been storing sludge for 6-8 weeks because of maintenance occurring at London City WWTP. Mid-Ohio takes their own NPDES permit samples. The bottles with pre-filled preservatives are provided by Masi Labs. Parameters analyzed on-site are pH, disolved oxygen (DO), and temperature. During review on the inspection, the time of sample collection and sample analysis were not currently being recorded for pH, DO, and temperature. Daniel Fonseca stated that there are plans to begin construction on infrastructure to pump sewage from the 2 of 13 Madison County Sewer District #2 WWTP Inspection Date(s): 04/22/2025 facility to a new wastewater treatment plant that is expected to be built in approximately 5 years. The facility shared that the operator that is usually on-site at Madison County Sewer District #2, Tim Patterson, was not available the day of the inspection, as he splits his time between plants #1 and #2. Tim Patterson was at plant #1 on the day of the inspection. At the time of inspection, the tertiary sand filter system was non-operational. Daniel Fonseca stated that the sand filter system has been non-operational for over a year. According to the Facility, the Mid-Ohio Water and Sewer District Director will be visiting the WWTP to evaluate the sand filter status and begin the process of replacement. Daniel Fonseca stated that "ideally" the sand filter would be replaced within a month of the date of inspection (April 22, 2025). According to the Facility, the collection system has not experienced any Sanitary Sewer Overflows (SSOs), but occasionally a customer will have their basement back up if they do not have check valves installed. Daniel Fonseca stated that the WWTP does not perform any water softening. He stated that most, if not all, homes in the area have some form of water softening system. This softened water leaches copper from the pipes in homes and the collection system. Daniel Fonseca states this is the cause for the facility's copper exceedances. According to the facility, the past ammonia issues have been related to a clarifier becoming clogged with debris and not being able to properly operate. When this occurs, the clarifier is shut down and manually cleaned. According to the facility, the 2024 E.coli issues at the facility were related to only one grab sample that had a high exceedance. When the sample was averaged with the second weekly grab sample, the facility was within the weekly limit. Facility/Site Information Location(s) Location/Area/Sub-area Outfall 001 Treatment Plant Description All equipment and processes associated with the wastewater treatment process. SECTION II - OBSERVATIONS Location: Treatment Plant Observation #: JF1-OB-001 Date: 04/22/2025 During the inspection, there appeared to be a large build-up of sludge/debris on the baffle walls of the clarifiers (See Photo # 6). Daniel Fonseca stated that the baffle walls for the clarifiers are currently cleaned once per year. Samples are taken at the post aeration system. 3 of 13 Madison County Sewer District #2 WWTP Inspection Date(s): 04/22/2025 Photo(s) 1. IMG_0453.JPG 2. IMG_0454.JPG 3. IMG_0455.JPG 4. IMG_0448.JPG 5. IMG_0456.JPG 6. IMG_0449.JPG 7. IMG_0451.JPG 8. IMG_0452.JPG 9. IMG_0450.JPG 10. IMG_0447.JPG Location: Outfall 001 Observation #: JF1-OB-002 Outfall 001 had proper signage. Photo(s) 1. IMG_0457.JPG Date: 04/22/2025 SECTION III - RECORDS REVIEW Records may not be in sequential order. Record: Discharge Monitoring Reports (DMR) Reports Ref #: JF1-RR-001 Reviewed By: Joseph Forth Are of Concern (AOC): No Reviewed Date: 04/29/2025 EPA requested E.coli sampling results for the period where the Facility had reported exceedances. Daniel Fonseca provided the documents to EPA on April 29, 2025. Document(s) 1. 2024 Ecoli Season Results.xlsx SECTION IV - SAMPLING ACTIVITIES AND ANALYTICAL RESULTS No sampling was conducted. SECTION V - AREA OF CONCERN Areas of Concern may not be in sequential order. 4 of 13 Madison County Sewer District #2 WWTP Inspection Date(s): 04/22/2025 The presentation of Areas of Concern does not constitute a formal compliance determination or violation. AOC Reference #: JF1-OC-FD AOC: Time of sample collection and sample analysis were not currently being recorded for pH, DO, and temperature. AOC Reference #: JF1-OC-NT AOC: At the time of inspection, the tertiary sand filter system was non-operational. Daniel Fonseca stated that the sand filter system has been non-operational for over a year. AOC Reference #: JF1-OC-NT AOC: Daniel Fonseca stated that the WWTP does not perform any water softening. He stated that most, if not all, homes in the area have some form of water softening system. This softened water leaches copper from the pipes in homes and the collection system. The facility believes this is the cause for the facility's copper exceedances, according to Daniel Fonseca. AOC Reference #: JF1-OB-001 AOC: Location: Treatment Plant During the inspection, there appeared to be a large build-up of sludge/debris on the baffle walls of the clarifiers (See Photo # 6). Daniel Fonseca stated that the baffle walls for the clarifiers are currently cleaned once per year. SECTION VI - CLOSING CONFERENCE AND FOLLOW UP Closing Conference EPA Staff conducted Cyber Security questionnaire at 10:53 AM ET. The EPA REGION 5 Lead Inspector held a closing conference with Facility personnel at 11:10 AM ET on April 22, 2025, for the inspection. During the closing conference, EPA REGION 5 Lead Inspector discussed the observations and Areas of Concern identified during the inspection. Areas of concern are as follows: intermittent copper NPDES permit effluent limit exceedances, the sand filter being non-operational for over a year, cleaning and regular maintenance frequency, Facility not currently recording times for sample taken and analyzed. Observations and Areas of Concern have not yet been evaluated for a formal compliance determination. Follow Up On May 27, 2025, via email, Daniel Fonseca stated that the new estimated date for having the sand filter operational again is July 31, 2025. 5 of 13 Madison County Sewer District #2 WWTP Inspection Date(s): Communication Log E.coli sampling data received by EPA REGION 5 after exiting the Facility on April 29, 2025. SECTION VII - LIST OF APPENDICES 1. Photo Log 2. Document Log 04/22/2025 6 of 13 Madison County Sewer District #2 WWTP Inspection Date(s): APPENDIX 1: PHOTO LOG - CANON PC1587 - Serial No. 30203400928 NOTE: Camera clock was set to Central Time, not Eastern Time that the inspection was conducted in. 04/22/2025 Photo 1 04/22/2025 09:23 AM No CBI Treatment Plant Photo of influent screening process. No PII IMG_0447.JPG Photographer: Joseph Forth West 7 of 13 Madison County Sewer District #2 WWTP Inspection Date(s): 04/22/2025 Photo 2 04/22/2025 09:24 AM No CBI Treatment Plant Photo of equalization basin. No PII IMG_0448.JPG Photographer: Joseph Forth East Photo 3 04/22/2025 09:25 AM No CBI Treatment Plant Photo of aeration system, side 1. No PII IMG_0449.JPG Photographer: Joseph Forth North 8 of 13 Madison County Sewer District #2 WWTP Inspection Date(s): 04/22/2025 Photo 4 04/22/2025 09:26 AM No CBI Treatment Plant Photo of sludge wasting tank #2. No PII IMG_0450.JPG Photographer: Joseph Forth North Photo 5 04/22/2025 09:26 AM Treatment Plant Photo of clarifier #2. No CBI No PII IMG_0451.JPG Photographer: Joseph Forth South 9 of 13 Madison County Sewer District #2 WWTP Inspection Date(s): 04/22/2025 Photo 6 04/22/2025 09:27 AM No CBI Treatment Plant Photo of baffle wall before clarifier #1. No PII IMG_0452.JPG Photographer: Joseph Forth Down Photo 7 04/22/2025 09:31 AM No CBI Treatment Plant Photo of sand filter process. No PII IMG_0453.JPG Photographer: Joseph Forth Down 10 of 13 Madison County Sewer District #2 WWTP Inspection Date(s): 04/22/2025 Photo 8 04/22/2025 09:32 AM Treatment Plant Photo of UV system. No CBI No PII IMG_0454.JPG Photographer: Joseph Forth Down Photo 9 04/22/2025 09:33 AM Treatment Plant Photo of UV system. No CBI No PII IMG_0455.JPG Photographer: Joseph Forth Down 11 of 13 Madison County Sewer District #2 WWTP Inspection Date(s): 04/22/2025 Photo 10 04/22/2025 09:36 AM No CBI No PII Treatment Plant Photo of post aeration system and sampling point. IMG_0456.JPG Photographer: Joseph Forth Down Photo 11 04/22/2025 09:48 AM No CBI Outfall 001 Photo of Outfall 001 and outfall signage. No PII IMG_0457.JPG Photographer: Joseph Forth South 12 of 13 Madison County Sewer District #2 WWTP Inspection Date(s): APPENDIX 2: DOCUMENT LOG Document Type Document Name DMR Reports 2024 Ecoli Season Results.xlsx Contains Contains Uploaded By CBI PII No No Joseph Forth 04/22/2025 Date Received 04/29/2025 13 of 13