Document Y9bdYo0JJZyvL7rkMEoB2yy6k

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 United Mobile Homes of Ohio, Inc - Wood Valley MHP, 1493 N. Whetstone River Rd, Caledonia, Ohio, Marion County Jonathan Moody, Environmental Engineer WECAB, Multimedia Section Brooke Furio, Section Supervisor WECAB, Multimedia Section BASIC INFORMATION Facility Name: United Mobile Homes of Ohio, Inc. - Wood Valley MHP Facility Type: Extended aeration treatment plant (privately-owned mobile home park) NPDES Permit Number: OH0111236 Date of Inspection: September 5, 2024 Date of Previous Inspection: May 22, 2024 EPA Inspector(s): 1. Jonathan Moody, Lead Inspector Facility Representative(s): 1. Dee Saunders, UMH Properties 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 Brock McGhee McGhees Technical Water Services, Inc. 22230 James Road Bellville, OH 44813 419-961-6767 Physical Facility Address United Mobile Homes of Ohio, Inc - Wood Valley MHP, 1493 N. Whetstone River Road Caledonia, Ohio 43314 Inspection Type: Compliance Evaluation with Sampling Facility Notification: Unannounced Inspection Announced Inspection Arrival Date and Time: 9/5/24 12:00 PM Departure Date and Time: 9/5/24 12:30 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: Provided CBI notification to facility Background: The Wood Valley property has approximately 161 lots for manufactured homes. At the time of the inspection, the owner estimated between 2.5 and 4 individuals per occupied lot, and there were approximately 33 vacant lots. A list of effluent exceedances is included in Appendix F. Process Description: The treatment facility is an extended aeration basin with an equalization tank, slow sand filters and a UV disinfection system. This report does not contain Confidential Business Information (CBI). Page 2 Staff Interview(s): The operator was not present for this inspection. Maintenance staff unlocked the facility, but departed before the sample was collected. Jonathan Moody talked with Dee Saunders in the Wood Valley Estate's office before leaving the site. FACILITY WALK-THROUGH OCCURRED: Yes Data Collected and Observations: EPA collected a bacteriological sample for E. coli from a sample tap at the end of the UV system. This is the location which was identified during a previous inspection, on May 22, 2024, as the compliance sampling location for Outfall 001. 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. The sand filters were filled with vegetation, algae and other materials as shown in Photos 5 through 13. 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 D. The results of samples collected during the inspection are included in Appendix E. RECORDS REVIEW List of Records Reviewed Onsite: No records were reviewed onsite Page 3 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. OH0111236 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..." At the time of the inspection, five of the six cells in the slow sand filter contained either excessive plant grown, algae and/or dried material resembling dried sludge. One filter cell was in operation. This cell was flooded, holding standing water and covered with bright green algae. 2. NPDES Permit No. OH0111236 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 (geometric mean): 284 Monthly Limit (geometric mean): 126 Result of the E. coli sample taken during the inspection was 866 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. 3. NPDES Permit No. OH0111236 Part I, A. - Final Effluent Limitations and Monitoring Requirements Final Outfall - 001 - Final Parameter: Dissolved Oxygen - mg/L Page 4 Measuring Frequency: 1/week, grab, all months Minimum: 5.0 mg/L Part III, 1. Definitions: "Absolute Limitations" Compliance with limitations having descriptions of "shall not be less than," "nor greater than," "shall not exceed," "minimum," or "maximum" shall be determined from any single value for effluent samples and/or measurements collected." Field monitoring conducted during the inspection showed dissolved oxygen less than the permit limitation. This was observed at the NPDES compliance sampling tap where the measurements were 4.61 mg/L, and 4.78 mg/L and also from a sample taken from the end of the discharge pipe where the value was 3.93 mg/L. The instream concentration in the tributary to the Olentangy River, immediately downstream of the confluence with the effluent from the Outfall 001 was 3.69 mg/L and below the permit limit. Appendices and Attachments A. Aerial Image B. Digital Image Log C. Field Measurement Data D. EPA Sampling Results from Pace Analytical Services Attachments 1. Transmittal of Sample Analysis Results (Laboratory Reports) Page 5 DIGITAL SIGNATURES Report Author: Jonathan Moody Digitally signed by JONATHAN JONATHAN MOODY Date: 2024.09.30 Report Author Signature:_M__O__O_D__Y______13_:0_2:_22_-_04_'00_' ____________ Section Supervisor: Brooke Furio BROOKE Digitally signed by BROOKE FURIO Section Supervisor Signature:_F_U_R__IO________D1_4a:_t1e7:_:23_062_-40._40'90_.03'_0 ____________ Page 6 Facility Name: Wood Valley MHP Facility Location: 1493 N. Whetstone River Rd, Caledonia Date of Inspection: September 5, 2024 APPENDIX A: AERIAL PHOTO FROM PICTOMETRY ONLINE PHOTO TAKEN 03/21/2024 Appendices Page: 1 Facility Name: Wood Valley MHP Facility Location: 1493 N. Whetstone River Rd, Caledonia Date of Inspection: September 5, 2024 1: DSCN2266.JPG Location: Wood Valley Estates Photographer: Jonathan Moody Date/Time: 9/5/2024 11:57 AM Camera Direction: North Description: Outlet from the discharge pipe to the small tributary to the Olentangy River. End of discharge pipe is marked with a red arrow. Appendices Page 2 Facility Name: Wood Valley MHP Facility Location: 1493 N. Whetstone River Rd, Caledonia Date of Inspection: September 5, 2024 2: DSCN2267.JPG Location: Wood Valley Estates Photographer: Jonathan Moody Date/Time: 9/5/2024 11:57 AM Camera Direction: North Description: Outlet from the discharge pipe to the small tributary to the Olentangy River. End of discharge pipe is marked with a red arrow. Appendices Page 3 Facility Name: Wood Valley MHP Facility Location: 1493 N. Whetstone River Rd, Caledonia Date of Inspection: September 5, 2024 3: DSCN2268.JPG Location: Wood Valley Estates Photographer: Jonathan Moody Date/Time: 9/5/2024 11:57 AM Camera Direction: Northwest Description: Outlet from the discharge pipe to the small tributary to the Olentangy River. End of discharge pipe is marked with a red arrow. Appendices Page 4 Facility Name: Wood Valley MHP Facility Location: 1493 N. Whetstone River Rd, Caledonia Date of Inspection: September 5, 2024 4: DSCN2269.JPG Location: Wood Valley Estates Photographer: Jonathan Moody Date/Time: 9/5/2024 12:01 PM Camera Direction: Down Description: Outlet from the discharge pipe to the small tributary to the Olentangy River. Location where field monitoring was conducted. Appendices Page 5 Facility Name: Wood Valley MHP Facility Location: 1493 N. Whetstone River Rd, Caledonia Date of Inspection: September 5, 2024 5: DSCN2270.JPG Location: Wood Valley Estates Photographer: Jonathan Moody Date/Time: 9/5/2024 12:03 PM Camera Direction: West Description: Filter cell at the southwest corner of the filters. At the time of the inspection the surface of the filter was covered with dried, non-sand, material resembling dried sludge. Appendices Page 6 Facility Name: Wood Valley MHP Facility Location: 1493 N. Whetstone River Rd, Caledonia Date of Inspection: September 5, 2024 6: DSCN2271.JPG Location: Wood Valley Estates Photographer: Jonathan Moody Date/Time: 9/5/2024 12:03 PM Camera Direction: North Description: Filter cell at the southeast corner of the filters. At the time of the inspection the surface of the filter was covered with water and a layer of green algae. Appendices Page 7 Facility Name: Wood Valley MHP Facility Location: 1493 N. Whetstone River Rd, Caledonia Date of Inspection: September 5, 2024 7: DSCN2272.JPG Location: Wood Valley Estates Photographer: Jonathan Moody Date/Time: 9/5/2024 12:04 PM Camera Direction: East Description: Filter cell at the middle west side of the filters. surface of the filter was covered with vegetation. At the time of the inspection the Appendices Page 8 Facility Name: Wood Valley MHP Facility Location: 1493 N. Whetstone River Rd, Caledonia Date of Inspection: September 5, 2024 8: DSCN2273.JPG Location: Wood Valley Estates Photographer: Jonathan Moody Date/Time: 9/5/2024 12:04 PM Camera Direction: East Description: Filter cell at the northwest corner of the filters. At the time of the inspection the surface of the filter was covered with vegetation and dried material that resembled dried sludge. Appendices Page 9 Facility Name: Wood Valley MHP Facility Location: 1493 N. Whetstone River Rd, Caledonia Date of Inspection: September 5, 2024 9: DSCN2274.JPG Location: Wood Valley Estates Photographer: Jonathan Moody Date/Time: 9/5/2024 12:04 PM Camera Direction: Description:Mistaken photo Appendices Page 10 Facility Name: Wood Valley MHP Facility Location: 1493 N. Whetstone River Rd, Caledonia Date of Inspection: September 5, 2024 10: DSCN2275.JPG Location: Wood Valley Estates Photographer: Jonathan Moody Date/Time: 9/5/2024 12:04 PM Camera Direction: East Description: Filter cell at the northwest corner of the filters. At the time of the inspection the surface of the filter was covered with vegetation and dried material that resembled dried sludge. Appendices Page 11 Facility Name: Wood Valley MHP Facility Location: 1493 N. Whetstone River Rd, Caledonia Date of Inspection: September 5, 2024 11: DSCN2276.JPG Location: Wood Valley Estates Photographer: Jonathan Moody Date/Time: 9/5/2024 12:04 PM Camera Direction: South Description: Filter cell at the northeast corner of the filters. At the time of the inspection the surface of the filter was covered with vegetation and dried material that resembled dried sludge. Appendices Page 12 Facility Name: Wood Valley MHP Facility Location: 1493 N. Whetstone River Rd, Caledonia Date of Inspection: September 5, 2024 12: DSCN2277.JPG Location: Wood Valley Estates Photographer: Jonathan Moody Date/Time: 9/5/2024 12:05 PM Camera Direction: South Description: Filter cell at the northeast corner of the filters. At the time of the inspection the surface of the filter was covered with vegetation and dried material that resembled dried sludge. Appendices Page 13 Facility Name: Wood Valley MHP Facility Location: 1493 N. Whetstone River Rd, Caledonia Date of Inspection: September 5, 2024 13: DSCN2278.JPG Location: Wood Valley Estates Photographer: Jonathan Moody Date/Time: 9/5/2024 12:05 PM Camera Direction: Description: Filter cell at the middle east side of the filters. At the time of the inspection the surface of the filter was covered with vegetation and debris. Appendices Page 14 Facility Name: Wood Valley MHP Facility Location: 1493 N. Whetstone River Rd, Caledonia Date of Inspection: September 5, 2024 14: DSCN2279.JPG Location: Wood Valley Estates Photographer: Jonathan Moody Date/Time: 9/5/2024 12:05 PM Camera Direction: Inside Description: Looking into the room with the UV system and the compliance sampling tap. Appendices Page 15 Facility Name: Wood Valley MHP Facility Location: 1493 N. Whetstone River Rd, Caledonia Date of Inspection: September 5, 2024 15: DSCN2280.JPG Location: Wood Valley Estates Photographer: Jonathan Moody Date/Time: 9/5/2024 12:06 PM Camera Direction: Inside Description: The Sanitron UV treatment system. was on and the lamp was illuminated. At the time of the inspection, the system Appendices Page 16 Facility Name: Wood Valley MHP Facility Location: 1493 N. Whetstone River Rd, Caledonia Date of Inspection: September 5, 2024 16: DSCN2281.JPG Location: Wood Valley Estates Photographer: Jonathan Moody Date/Time: 9/5/2024 12:06 PM Camera Direction: Description: The Sanitron UV treatment system. was on and the lamp was illuminated. At the time of the inspection, the system Appendices Page 17 Facility Name: Wood Valley MHP Facility Location: 1493 N. Whetstone River Rd, Caledonia Date of Inspection: September 5, 2024 17: DSCN2282.JPG Location: Wood Valley Estates Photographer: Jonathan Moody Date/Time: 9/5/2024 12:07 PM Camera Direction: North Description: During the inspection, the dosing pump for the filters activated. Flow was observed into the cell at the southeast corner of the filter cells. This was the only cell that appeared to be in use. Appendices Page 18 Facility Name: Wood Valley MHP Facility Location: 1493 N. Whetstone River Rd, Caledonia Date of Inspection: September 5, 2024 18: DSCN2283.JPG Location: Wood Valley Estates Photographer: Jonathan Moody Date/Time: 9/5/2024 12:07 PM Camera Direction: East Description: During the inspection, the dosing pump for the filters activated. Flow was observed into the cell at the southeast corner of the filter cells. This was the only cell that appeared to be in use. Appendices Page 19 Facility Name: Wood Valley MHP Facility Location: 1493 N. Whetstone River Rd, Caledonia Date of Inspection: September 5, 2024 19: DSCN2284.JPG Location: Wood Valley Estates Photographer: Jonathan Moody Date/Time: 9/5/2024 12:08 PM Camera Direction: East Description: Looking at the four filter cells on the north end of the filters. while water was flowing into the cell at the southeast corner. Photo was taken Appendices Page 20 Facility Name: Wood Valley MHP Facility Location: 1493 N. Whetstone River Rd, Caledonia Date of Inspection: September 5, 2024 20: DSCN2285.JPG Location: Wood Valley Estates Photographer: Jonathan Moody Date/Time: 9/5/2024 12:13 PM Camera Direction: Inside Description: Sample tap and sample S03 at the compliance monitoring location for Outfall 001. Appendices Page 21 Facility Name: Wood Valley MHP Facility Location: 1493 N. Whetstone River Rd, Caledonia Date of Inspection: September 5, 2024 21: DSCN2286.JPG Location: Wood Valley Estates Photographer: Jonathan Moody Date/Time: 9/5/2024 12:19 PM Camera Direction: East Description: Visual grab of the water from the tap used for compliance sampling at Outfall 001. Appendices Page 22 Facility Name: Wood Valley MHP Facility Location: 1493 N. Whetstone River Rd, Caledonia Date of Inspection: September 5, 2024 22: DSCN2287.JPG Location: Wood Valley Estates Photographer: Jonathan Moody Date/Time: 9/5/2024 12:19 PM Camera Direction: Down Description: Visual grab of the water from the tap used for compliance sampling at Outfall 001. Appendices Page 23 Facility Name: Wood Valley MHP Facility Location: 1493 N. Whetstone River Rd, Caledonia 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. # 9/5/2024 12:00 9/5/2024 12:15 9/5/2024 12:21 MP-03 MP-04 MP-05 9/5/2024 12:29 MP-06 Location Cond pH (SU) (ug/cm) End of pipe on the discharge line from Outfall 001, in stream measurement, see Photo 4 873 6.53 Measurement from the Outfall 001 compliance monitoring tap, grab jar used. 1110 6.56 Repeat measurement from the Outfall 001 compliance monitoring tap, grab jar used. 1108 6.63 In the tributary to the Olentangy River downstream of the discharge pipe from Outfall 001, upstream of the first culvert. 1099 6.51 RDO (mg/l) 3.93 4.61 4.78 3.69 Turbidity (NTU) equivalent 0.5 0 98.1 0 Shaded cells exceed one of the values from the NPDES permit limitations. Appendices Page 24 Facility Name: Wood Valley MHP Facility Location: 1493 N. Whetstone River Rd, Caledonia 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 4092714- Effluent 8:34 01 Outfall 866 001 Method: Colilert - Most Probable Number (MPN) Appendices Page 25 Facility Name: Wood Valley MHP Facility Location: 1493 N. Whetstone River Rd, Caledonia 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