Document MJqqGkRrJGQ1Kv4dLnX5exgzy

DATE: SUBJECT: FROM: THRU: UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 5 77 WEST JACKSON BOULEVARD CHICAGO, ILLINOIS 60604 September 30, 2024 CLEAN WATER ACT INSPECTION REPORT Hayden Heights MHP, UMH Central OH, LLC, 5501 Cosgray, Dublin, Ohio, Franklin County Jonathan Moody, Environmental Engineer WECAB, Multimedia Section Brooke Furio, Section Supervisor WECAB, Multimedia Section BASIC INFORMATION Facility Name: Hayden Heights MHP, UMH Central OH, LLC Facility Type: Extended aeration treatment plant (privately-owned mobile home park) NPDES Permit Number: OH0136051 Date of Inspection: September 5, 2024 Date of Previous Inspection: June 5, 2024, closing conference on June 21, 2024 EPA Inspector(s): 1. Jonathan Moody, Lead Inspector Facility Representative(s): 1. Bo Foster, UMH Properties, Inc., Property Manager Contact Email Address: jyorick@umh.com, jsearcy@umh.com Owner Contact Jeffrey V. Yorick, P.E. Executive Vice President for Engineering UMH Properties, Inc. 150 Clay Street, Suite 410 Morgantown, WV 26501 304-291-3380 Operator Contact Contract Operator Eric Britenstine Britenstine Environmental 614-207-9030 Physical Facility Address Hayden Heights MHP 5501 Cosgray Road Dublin, Ohio Inspection Type: Compliance Evaluation with Sampling Facility Notification: Unannounced Inspection Announced Inspection Arrival Date and Time: 9/5/2024 1:30 PM Departure Date and Time: 9/5/24 2:00 PM OPENING CONFERENCE Presented Credentials Stated authority and purpose of inspection Provided Small Business Resource Information Sheet, previously provided Small Business Resource Information Sheet not provided. Reason: N/A Provided CBI notification to facility The following information was obtained verbally from Bo Foster unless otherwise noted. Page 2 Background: The Hayden Heights property is a Manufactured Home Community (MHC) owned by UMH Properties, Inc. The property has approximately 115 lots total for manufactured homes. At the time of the inspection all lots were occupied. A list of effluent exceedances is included in Appendix D. Process Description: The treatment facility is an extended aeration basins with an equalization tank, slow sand filters, and a UV disinfection system. This report does not contain Confidential Business Information (CBI). Staff Interview(s): Bo Foster said the operator had planned to fix the UV system after the end of the summer monitoring season. FACILITY WALK-THROUGH OCCURRED: Yes Data Collected and Observations: EPA collected a bacteriological sample for E. coli from the UV system channel. This is the location which was identified during a previous inspection, on June 5, 2024, as the compliance sampling location for Outfall 001. The inspection on September 5, 2024 was a follow-up to the earlier inspection on June 5, 2024. The sample was collected into a 120mL sterile plastic bottles pre-preserved with sodium thiosulfate provided by Pace Analytical Services. After collecting the sample, Jonathan Moody conducted additional monitoring using an AT-600 wastewater meter. Three of the six lamps were offline at the time of the inspection. Looking at the control panel shown in Photo 1, the bottom lamp on the left bank and both lamps in the center bank were offline. These are the same locations as the lamps which were offline during the June 5, 2024 inspection. Photos and/or Videos: were taken during the inspection. A photolog for the photos taken during the inspection is included in Appendix B. Field Measurements: were taken during this inspection. The results of monitoring conducted while in the field are included in Appendix C. The results of samples collected during the inspection are included in Appendix D. Page 3 RECORDS REVIEW List of Records Reviewed Onsite: No records were reviewed onsite Requested documents: N/A Documents Received From Facility: N/A CLOSING CONFERENCE Provided U.S. EPA point of contact to the facility. Explained Inspection Report Process Confirm CBI status at end of closing conference. No CBI claimed. Discussed Preliminary Area(s) of Concern Areas of Concern: 1. NPDES Permit No. OH0136051 Part III-General Conditions 3.A. - Facility Operation and Quality Control "All wastewater treatment works shall be operated in a manner consistent with the following: A. At all times, the permittee shall maintain in good working order and operate as efficiently as possible all treatment or control facilities or systems installed or used by the permittee necessary to achieve compliance with the terms and conditions of this permit..." Three of the six lamps were offline at the time of the inspection. Looking at the control panel shown in Photo 1, the bottom lamp on the left bank and both lamps in the center bank were offline. These are the same locations as the lamps which were offline during the June 5, 2024 inspection. 1. NPDES Permit No. OH0136051 Part I, A. - Final Effluent Limitations and Monitoring Requirements Final Outfall - 001 - Final Parameter: E. coli - #/100 ml Measuring Frequency: 1/Month during Summer Weekly Limit: 284 Monthly Limit: 126 Page 4 Result of the E. coli sample taken during the inspection was 411 which is higher than the weekly and monthly averages. At the time of writing of this report, the other weekly and monthly values were not known. Appendices A. B. C. D. Aerial Image Digital Image Log Field Measurement Data EPA Sampling Results from Pace Analytical Services Attachments 1. Transmittal of Sample Analysis Results (Laboratory Reports) DIGITAL SIGNATURES Report Author: Jonathan Moody JONATHAN JONATHAN MOODY Digitally signed by Date: 2024.09.30 Report Author Signature:M__O__O_D__Y______1_2:5_9_:43_-_04_'0_0'_____________ Section Supervisor: Brooke Furio BROOKE Digitally signed by BROOKE FURIO Section Supervisor Signature:_F_U_R__IO________D1_4a:t_1e6:_:23_022_-40.4_0'90_.03'_0 ____________ Page 5 Facility Name: Hayden Heights MHP Facility Location: 5501 Cosgray, Dublin, Ohio, Franklin County Date of Inspection: September 5, 2024 APPENDIX A: AERIAL PHOTO FROM GOOGLE MAPS VISITED 08/30/2024 Unused EQ Basin Drying Beds Stormwater Pond Aeration Basin UV Chamber Filters Appendices Page: 1 Facility Name: Hayden Heights MHP Facility Location: 5501 Cosgray, Dublin, Ohio, Franklin County Date of Inspection: September 5, 2024 APPENDIX B: PHOTOLOG CAMERA: COOLPIX W300 Appendices Page 2 Facility Name: Hayden Heights MHP Facility Location: 5501 Cosgray, Dublin, Ohio, Franklin County Date of Inspection: September 5, 2024 1: DSCN2288.JPG Location: Hayden Heights Photographer: Jonathan Moody Date/Time: 9/5/2024 1:44 PM Camera Direction: North Description: At the time of the inspection, three of the six lamps were burned out, or offline. These are the same lamps which were offline during the inspection on June 5, 2024. Appendices Page 3 Facility Name: Hayden Heights MHP Facility Location: 5501 Cosgray, Dublin, Ohio, Franklin County Date of Inspection: September 5, 2024 2: DSCN2289.JPG Location: Hayden Heights Photographer: Jonathan Moody Date/Time: 9/5/2024 1:47 PM Camera Direction: Northeast Description: Sample S04, E. coli sample collected from the UV disinfection channel at the location which was identified by the operator during the June 5, 2024 as the location where compliance samples are collected for Outfall 001. Appendices Page 4 Facility Name: Hayden Heights MHP Facility Location: 5501 Cosgray, Dublin, Ohio, Franklin County Date of Inspection: September 5, 2024 3: DSCN2290.JPG Location: Hayden Heights Photographer: Jonathan Moody Date/Time: 9/5/2024 1:52 PM Camera Direction: North Description: Visual grab sample collected form the UV channel at Outfall 001. Appendices Page 5 Facility Name: Hayden Heights MHP Facility Location: 5501 Cosgray, Dublin, Ohio, Franklin County Date of Inspection: September 5, 2024 4: DSCN2291.JPG Location: Hayden Heights Photographer: Jonathan Moody Date/Time: 9/5/2024 1:52 PM Camera Direction: Down Description: Visual grab sample collected form the UV channel at Outfall 001. Appendices Page 6 Facility Name: Hayden Heights MHP Facility Location: 5501 Cosgray, Dublin, Ohio, Franklin County Date of Inspection: September 5, 2024 Appendices Page 7 Facility Name: Hayden Heights MHP Facility Location: 5501 Cosgray, Dublin, Ohio, Franklin County Date of Inspection: September 5, 2024 APPENDIX C: FIELD MEASUREMENT DATA AND SAMPLING Jonathan Moody conducted field monitoring using an In-Situ AquaTroll 600 (AT600), Serial Number 1079129. The AT600 was equipped with a temperature/conductivity sensor, pH sensor, Rugged Dissolved Oxygen (RDO) sensor and a turbidity sensor. The chart below shows the results of the monitoring. The AT600 was calibrated September 4, 2024 using a 3-point pH calibration and the In-Situ "Quick Cal" solution for specific conductivity. The RDO sensor was calibrated using the 100% saturation method on September 5, 2024, just before starting the field monitoring. Date/Time Ref. # Location 9/5/2024 1:53 PM MP-07 UV channel, compliance monitoring point for Outfall 001. Using a grab jar. Cond pH (SU) (ug/cm) RDO (mg/l) 1922 8.23 8.99 Turbidity (NTU) equivalent 0 Appendices Page 8 Facility Name: Hayden Heights MHP Facility Location: 5501 Cosgray, Dublin, Ohio, Franklin County Date of Inspection: September 5, 2024 APPENDIX D: EPA SAMPLING RESULTS FROM PACE ANALYTICAL SERVICES One grab sample was collected during this inspection. A complete copy of the laboratory report is included in Attachment 1. A summary of the results is shown in the table below: Date/Time Ref. # Location E. Coli MPN 100 ml 9/5/2024 4092775- Effluent 1:45 PM 02 Outfall 411 001 Method: Colilert - Most Probable Number (MPN) Appendices Page 9 Facility Name: Hayden Heights MHP Facility Location: 5501 Cosgray, Dublin, Ohio, Franklin County Date of Inspection: September 5, 2024 ATTACHMENT 1 : LABORATORY REPORTS Pace Analytical Services, LLC P.O. Box 907 Madisonville, KY 42431 270.821.7375 www.pacelabs.com Jonathan Moody (ERG) Eastern Research Group, Inc 14555 Avion ParkwaySuite 200 Chantilly, VA 20151 Certificate of Analysis 4092775 Customer ID: Report Printed: 44-103012 09/10/2024 18:35 Project Name: UMH E.Coli Sampling Workorder: Dear Jonathan Moody Enclosed are the analytical results for samples received by the laboratory 09/05/2024 15:16. The results relate to the samples included in this report. Results reported herein conform to the applicable TNI/NELAC Standards and the laboratory's Quality Manual, where applicable, unless otherwise noted in the body of the report. 4092775 The test results provided in this final report were generated by each of the following laboratories within the Pace Network: - Pace Analytical Services LLC Kentucky - Englewood If you have any questions concerning this report, please feel free to contact me. #460210 Madisonville, KY #460291 Pikeville, KY #E871136 Englewood, OH This page is included as part of the Analytical Report and must be retained as a permanent record thereof. Alicia Barnes, Project Manager V.P.1020.0 Printed on 9/10/2024 at 6:35:35PM Page 1 of 6 Pace Analytical Services, LLC P.O. Box 907 Madisonville, KY 42431 270.821.7375 www.pacelabs.com Lab ID 4092775-01 4092775-02 Client Sample ID/Alias E.Coli/S03 Wood Valley E.Coli/S04 Haden Heights SAMPLE SUMMARY Matrix Date Collected Water Water 09/05/2024 12:12 09/05/2024 13:45 Date Received Sampled By 09/05/2024 15:16 Client 09/05/2024 15:16 Client Lab Sample ID: 4092775-01 Description: E.Coli S03 Wood Valley ANALYTICAL RESULTS Sample Collection Date Time: 09/05/2024 12:12 Sample Received Date Time: 09/05/2024 15:16 Conventional Chemistry Analyses Englewood Analyte E. Coli Result Flag 866 Units MPN/100m L MRL 1 MDL Method 1 Colilert - MPN Prepared 09/05/2024 15:50 Analyzed 09/06/2024 17:28 Analyst EKWW Lab Sample ID: 4092775-02 Description: E.Coli S04 Haden Heights ANALYTICAL RESULTS Sample Collection Date Time: 09/05/2024 13:45 Sample Received Date Time: 09/05/2024 15:16 Conventional Chemistry Analyses Englewood Analyte E. Coli Result Flag 411 Units MPN/100m L MRL 1 MDL Method 1 Colilert - MPN Prepared 09/05/2024 15:50 Analyzed 09/06/2024 17:28 Analyst EKWW Page 2 of 6 Pace Analytical Services, LLC P.O. Box 907 Madisonville, KY 42431 270.821.7375 www.pacelabs.com Notes for work order 4092775 - Samples collected by PACE personnel are done so in accordance with procedures set forth in PACE field services SOPs . - Results contained in this report are only representative of the samples received. - PACE does not provide interpretation of these results unless otherwise stated . - All Waste Water analyses comply with methodology requirements of 40 CFR Part 136. - All Drinking Water analyses comply with methodology requirements of 40 CFR Part 141. - Unless otherwise noted, all quantitative results for soils are reported on a dry weight basis. - The Chain of Custody document is included as part of this report. - All Library Search analytes should be regarded as tentative identification based on the presumptive evidence of the mass spectra. Concentrations reported are estimated values. Qualifiers U Target analyte was analyzed for, but was below detection limit (the value associated with the qualifier is the laboratory method detection limit in our LIMS system). Standard Qualifiers/Acronyms MDL Method Detection Limit MRL Minimum Reporting Limit ND Not Detected LCS Laboratory Control Sample MS Matrix Spike MSD Matrix Spike Duplicate DUP Sample Duplicate % Rec Percent Recovery RPD Relative Percent Difference > Greater than < Less than Page 3 of 6 Pace Analytical Services, LLC P.O. Box 907 Madisonville, KY 42431 270.821.7375 www.pacelabs.com Conventional Chemistry Analyses Englewood - Quality Control Analyte Result Batch BDI0449 - Default Prep Micro 7 Blank (BDI0449-BLK1) Prepared: 9/5/2024 15:50, Analyzed: 9/6/2024 17:28 E. Coli ND Reporting Limit Units Spike Level Source Result %REC %REC Limits 1 MPN/100mL RPD RPD Limit Notes U Page 4 of 6 Pace Analytical Services, LLC P.O. Box 907 Madisonville, KY 42431 270.821.7375 www.pacelabs.com Conventional Chemistry Analyses Englewood - Quality Control Analyte Result Reporting Limit Units Spike Level Source Result Batch BDI0449 - Default Prep Micro 7 LCS (BDI0449-BS1) Prepared: 9/5/2024 15:50, Analyzed: 9/6/2024 17:28 E. Coli 2420 Certified Analyses included in this Report Analyte Certifications 1 MPN/100mL 2420 Colilert - MPN in Water E. Coli KY Drinking Water Mdv (00030) KY Wastewater Mdv (00030) %REC 100 %REC Limits 0-200 RPD RPD Limit Notes Shipped By: Client Sample Acceptance Checklist for Work Order 4092775 Temperature: 5.90 Celcius Condition Check if Custody Seals are Present/Intact Check if Custody Signatures are Present Check if Collector Signature Present Check if bottles are intact Check if bottles are correct Check if bottles have sufficient volume Check if samples received on ice Check if VOA headspace is acceptable Check if samples received in holding time. Check if samples are preserved properly Page 5 of 6 Page 6 of 6