Document gbpR76nyMGNEk6yKbznNOa2aN

DATE: SUBJECT: FROM: THRU: UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 5 77 WEST JACKSON BOULEVARD CHICAGO, ILLINOIS 60604 September 24, 2024 CLEAN WATER ACT INSPECTION REPORT United Mobile Homes of Ohio, Inc - Lake Sherman Village MHC., 7227 Beth Avenue SW, Navarre, Ohio, Stark 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. - Lake Sherman Village MHC Facility Type: Extended aeration treatment plant (privately-owned mobile home park) NPDES Permit Number: OH0045683 Date of Inspection: September 5, 2024 Date of Previous Inspection: May 30, 2024 EPA Inspector(s): 1. Jonathan Moody, Lead Inspector Facility Representative(s): 1. Ron Miller, UMH Properties, Inc. - Operator Contact Email Address: jyorick@umh.com, jsearcy@umh.com Owner Contact Operator Contact Physical Facility Address Jeffrey V. Yorick, P.E. Executive Vice President for Engineering UMH Properties, Inc. 150 Clay Street, Suite 410 Morgantown, WV 26501 304-291-3380 Ron Miller UMH Properties, Inc. (330) 484-4767 Lake Sherman Village MHC 7227 Beth Avenue SW, Navarre, Ohio 44662 Stark County (330) 484-4767 Inspection Type: Compliance Evaluation with Sampling Facility Notification: Unannounced Inspection Announced Inspection Arrival Date and Time: 9/5/24 8:15 AM Departure Date and Time: 9/5/24 9:00 AM 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 (previously provided) The following information was obtained verbally from Ron Miller unless otherwise noted. Page 2 Background: The Lake Sherman Village is a Manufactured Home Community (MHC) owned by UMH Properties, Inc. The property has approximately 254 lots total for manufactured homes. At the time of the inspection there were approximately 251 occupied lots. Process Description: The treatment facility is an extended aeration basins with an equalization tank, slow sand filters and a chlorine contact chamber. This report does not contain Confidential Business Information (CBI). Staff Interview(s): Ron Miller is the operator in charge of the sewer plant and is employed by UMH Properties, Inc. Ron Miller is onsite every day. Ron Miller has been an operator for 34 years. Sometime between Tuesday (9/3/24) morning and Wednesday (9/4/24) morning the pumps in the dosing chamber, which pumps to the sand filters, became inoperable. When Ron arrived at the site on Wednesday morning, water had begun to backup in the plant and was overflowing from the south aeration basin onto the ground in between the south and middle aeration basins. See photos 4 through 6. The ground in that area slopes toward a receiving stream to the south of the treatment plant in the direction shown in photo 5. FACILITY WALK-THROUGH OCCURRED: No Data Collected and Observations: EPA collected a bacteriological sample for E. coli from the end of the chlorine contact chamber just upstream of a flow measurement weir. Per Ron Miller, this is the same location where samples are collected for routine E. coli compliance purposes. The sample was collected into a 120mL sterile plastic bottles pre-preserved with sodium thiosulfate provided by Pace Analytical Services. The bottle was dipped into the water matrix with gloved hand with a single motion. After collecting the sample, Jonathan Moody conducted additional monitoring using an AT-600 wastewater meter and a Hach SL1000 for residual chlorine, and free ammonia field measurements. 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. Page 3 The results of monitoring conducted while in the field are included in Appendix C. The results of the field sampling are included in Appendix D. 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. OH0045683 Part III-General Conditions 2. GENERAL EFFLUENT LIMITATIONS "The effluent shall, at all times, be free of substances: A. In amounts that will settle to form putrescent, or otherwise objectionable, sludge deposits; or that will adversely affect aquatic life or water fowl; B. Of an oily, greasy, or surface-active nature, and of other floating debris, in amounts that will form noticeable accumulations of scum, foam or sheen; C. In amounts that will alter the natural color or odor of the receiving water to such degree as to create a nuisance; At the time of the inspection the filters were being bypassed. The effluent had a cloudy or discolored appearance as shown in Photos 2 and 3. The turbidity of the discharge was 7.3 NTU equivalents. During a prior inspection conducted on May 30, 2024 the filters were in service and the effluent turbidity was 0 NTU equivalents. 2. NPDES Permit No. OH0045683 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 Page 4 used by the permittee necessary to achieve compliance with the terms and conditions of this permit..." a) The pumps in the dosing chamber were offline and the slow sand filters and chlorine feeder were being bypassed. Temporary pumps were in place to pump water from the dosing chamber into the chlorine contact chamber and chlorine pucks were placed directly into the chlorine chamber. b) Chlorine residual in the contact chamber was below detection for free chlorine and 2.22 mg/L for Total Chlorine. These values are below the state recommended standard in the Ohio EPA manual Design Standards: Wastewater Treatment Plants & Collection Systems 100,000 gpd, Version 2013 -Section 8.72 Chlorination, Page 55: "... C) The chlorine dose usually ranges from 5 to 20 milligrams per liter (mg/L). and D) Hypochlorite is the only acceptable type of chlorine for disinfection. Chlorinated isocyanurates (swimming pool disinfection products) are not to be used in disinfection of wastewater treatment. ..." At the time of the inspection, the chlorine dosing could not be determined, however the chlorine dosing was not enough to maintain an effective free chlorine residual. The concentration of ammonia in the discharge was high enough to fully react with all available free chlorine, eliminating the free chlorine from the hypochlorite disinfectant. 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 JONATHAN JONATHAN MOODY Digitally signed by Date: 2024.09.25 Report Author Signature:_M_O__O__D_Y______0_7:_41_:2_8_-0_4'0_0_' ____________ Section Supervisor: Brooke Furio BROOKE Digitally signed by BROOKE FURIO Section Supervisor Signature:F__U_R__IO________D08_a:t0_e3:_:2104_2-4_0.40_'90._02'5_____________ Page 6 Facility Name: Lake Sherman Village MHC Facility Location: 7227 Beth Avenue SW, Navarre, Ohio Date of Inspection: September 5, 2024 APPENDIX A: AERIAL PHOTO FROM GOOGLE MAPS VISITED 07/24/2024 Sand Filters Drying Beds EQ Basin Chlorine Contact Chamber North Aeration Mid Aeration South Aeration Appendices Page: 1 Facility Name: Lake Sherman Village MHC Facility Location: 7227 Beth Avenue SW, Navarre, Ohio Date of Inspection: September 5, 2024 APPENDIX B: PHOTOLOG CAMERA: COOLPIX W300 Appendices Page: 2 Facility Name: Lake Sherman Village MHC Facility Location: 7227 Beth Avenue SW, Navarre, Ohio Date of Inspection: September 5, 2024 1: DSCN2254.JPG Location: Lake Sherman Village Photographer: Jonathan Moody Date/Time: 9/5/2024 8:35 AM Camera Direction: Down, North Description: Sample S01 taken from the end of the chlorine contact chamber, just upstream of the flow measurement weir. Appendices Page: 3 Facility Name: Lake Sherman Village MHC Facility Location: 7227 Beth Avenue SW, Navarre, Ohio Date of Inspection: September 5, 2024 2: DSCN2255.JPG Location: Lake Sherman Village Photographer: Jonathan Moody Date/Time: 9/5/2024 8:44 AM Camera Direction: Northeast Description: Visual grab of the effluent. and discolored. At the time of the inspection the effluent was cloudy Appendices Page: 4 Facility Name: Lake Sherman Village MHC Facility Location: 7227 Beth Avenue SW, Navarre, Ohio Date of Inspection: September 5, 2024 3: DSCN2256.JPG Location: Lake Sherman Village Photographer: Jonathan Moody Date/Time: 9/5/2024 8:45 AM Camera Direction: Down Description: Visual grab of the effluent. and discolored. At the time of the inspection the effluent was cloudy Appendices Page: 5 Facility Name: Lake Sherman Village MHC Facility Location: 7227 Beth Avenue SW, Navarre, Ohio Date of Inspection: September 5, 2024 4: DSCN2257.JPG Location: Lake Sherman Village Photographer: Jonathan Moody Date/Time: 9/5/2024 8:47 AM Camera Direction: South Description: Looking at the south aeration basin. Per Ron Miller, this basin had overflowed onto the ground shown in the foreground of this photo. Appendices Page: 6 Facility Name: Lake Sherman Village MHC Facility Location: 7227 Beth Avenue SW, Navarre, Ohio Date of Inspection: September 5, 2024 5: DSCN2258.JPG Location: Lake Sherman Village Photographer: Jonathan Moody Date/Time: 9/5/2024 8:47 AM Camera Direction: South Description: Looking at the south aeration basin. Per Ron Miller, this basin had overflowed onto the ground shown in the foreground of this photo. Appendices Page: 7 Facility Name: Lake Sherman Village MHC Facility Location: 7227 Beth Avenue SW, Navarre, Ohio Date of Inspection: September 5, 2024 6: DSCN2259.JPG Location: Lake Sherman Village Photographer: Jonathan Moody Date/Time: 9/5/2024 8:47 AM Camera Direction: East Description: Looking at the south aeration basin. Per Ron Miller, this basin had overflowed onto the ground shown in the foreground of this photo. Appendices Page: 8 Facility Name: Lake Sherman Village MHC Facility Location: 7227 Beth Avenue SW, Navarre, Ohio Date of Inspection: September 5, 2024 7: DSCN2260.JPG Location: Lake Sherman Village Photographer: Jonathan Moody Date/Time: 9/5/2024 8:51 AM Camera Direction: Down Description:Result of the monitoring conducted by EPA at the end of the chlorine contact chamber using a Hach SL1000. Appendices Page: 9 Facility Name: Lake Sherman Village MHC Facility Location: 7227 Beth Avenue SW, Navarre, Ohio 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 8:39 MP-01 Outfall 001 Cond pH (SU) (ug/cm) RDO (mg/l) 782 7.98 9.70 Turbidity (NTU) equivalent 7.3 Date/Time Location 9/5/2024 8:50 Inside the chlorine contact chamber at the flow monitoring weir T. Chlorine (mg/L)1 2.22 F. Chlorine (mg/L)2 0.00 (under range) Free Ammonia (mg/L)3 > 0.60 Notes 1. USEPA DPD Method, Hach Method 10260 range (0.04 to 4.00) 2. USEPA DPD Method, Hach Method 10260 range (0.04 to 4.00) 3. Indophenol Method, Hach Method 10269 range (0.05 to 0.50) Monochloramine (mg/L) 2.00 Appendices Page: 10 Facility Name: Lake Sherman Village MHC Facility Location: 7227 Beth Avenue SW, Navarre, Ohio 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 8 001 Method: Colilert - Most Probable Number (MPN) Appendices Page: 11 Facility Name: Lake Sherman Village MHC Facility Location: 7227 Beth Avenue SW, Navarre, Ohio Date of Inspection: September 5, 2024 ATTACHMENT 1 : LABORATORY REPORTS Attachment 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 4092714 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 13:21. 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. 4092714 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 6:35:08PM Page 1 of 6 Pace Analytical Services, LLC P.O. Box 907 Madisonville, KY 42431 270.821.7375 www.pacelabs.com Lab ID 4092714-01 4092714-02 Client Sample ID/Alias E.Coli/S01 - Lake Sherman E.Coli/S02 - Fohl Village SAMPLE SUMMARY Matrix Date Collected Water Water 09/05/2024 08:34 09/05/2024 09:20 Date Received Sampled By 09/05/2024 13:21 Jonathan Moody 09/05/2024 13:21 Jonathan Moody Lab Sample ID: 4092714-01 Description: E.Coli S01 - Lake Sherman ANALYTICAL RESULTS Sample Collection Date Time: 09/05/2024 08:34 Sample Received Date Time: 09/05/2024 13:21 Conventional Chemistry Analyses Englewood Analyte E. Coli Result Flag 8 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: 4092714-02 Description: E.Coli S02 - Fohl Village ANALYTICAL RESULTS Sample Collection Date Time: 09/05/2024 09:20 Sample Received Date Time: 09/05/2024 13:21 Conventional Chemistry Analyses Englewood Analyte E. Coli Result Flag 2708 Units MPN/100m L MRL 20 MDL Method 20 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 4092714 - 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 4092714 Temperature: 4.50 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