g hio

n
Environmental
Protection Agency
Mike DeWine, Governor
Jon Husted, Lt. Governor
Laurie A. Stevenson, Director

NOTICE OF VIOLATION

July 15, 2019

Re: NORWOOD CITY PWS

Notice of Violation
Drinking Water Program
Hamilton County
OH3101703
OPCT-1014571

Mr. Joseph C. Geers

1901 Tilden Avenue
Norwood, Ohio 45212

Subject: Sanitary Survey — Facility ID #0H3154756, WS3-1014571-90,

Community PWS

Dear Mr. Geers:

On May 17, 2019, Mary McGuinn and I conducted a sanitary survey for the Norwood
City public water system. The purpose of the inspection was to determine your
compliance with Ohio's drinking water laws as found in Chapter 6109 of the Ohio
Revised Code (ORC) and Chapter 3745 of the Ohio Administrative Code (OAC). Our
inspection included a review of records associated with facility operations.

During the inspection, the Ohio Environmental Protection Agency (Ohio EPA) observed
the following violations of Chapter 6109 of the ORC and Chapter 3745 of the OAC.

VIOLATIONS

1. In accordance with OAC Rule 3745-7-09(B)(1), "A certified operator shall perform
their duties in a responsible and professional manner consistent with standard
operating procedures and best management practices".

a. During the inspection excessive corrosion was noted on the storage tanks,
the tank's access ladder and overflow pipe. The concrete base of one of
the tanks also shows significant deterioration.

Southwest District Office • 401 East Fifth Street • Dayton, OH 45402-2911

epa.ohio.gov • (937) 285-6357 • (937) 285-6249 (fax)
Mr. Joseph Geers, Norwood City PWS
OH3101703 — NOV
July 15, 2019
Page 2 of 5

b. An engineering evaluation performed on May 14, 2014, documented all of

the issues cited above and indicated that the 1.25 MGD tank was severely
deteriorated. The evaluation recommended that replacing the tank was a
far better option than repair due to the age of the tanks and the expense of
continued maintenance. To date, no action has been taken to repair or
replace the storage tanks.

c. For an example of a best management practice, AWWA Standard G200-

15 states, utilities shall have a maintenance program that includes periodic
cleaning and refurbishing of facilities as required, Cleaning of covered
storage shall be based on internal inspections conducted at a minimum of
every five years. External inspections shall be conducted seasonally

d. Please provide any documents you have that indicate maintenance was
performed or repairs were requested.

e. Please provide a written explanation of why actions were not taken and
what actions you intend to take to resolve the above referenced violation.

2. In accordance with OAC Rule 3745-7-09(B)(2), "A certified operator shall

operate and maintain public water systems as not to endanger the health or
safety of persons working in or around the facility, the public at large, or the
environment due to negligence or incompetence".

a. A May 14, 2014 inspection and subsequent engineering report

indicated the 1.25 MGD storage tank was severely deteriorated.
The tank had holes exposing finished drinking water to the
elements and a dead bird was observed in the finished water stored
in the tank. The inspection also indicated that interior and exterior
coatings on the tank were in poor condition.

b. There are no records indicating you took any actions to resolve this
situation.

c. Provide any records you have documenting your response to the

engineering report, your requests for repairs and any other
information pertinent to this situation.

d. Please provide a written explanation of why actions were not taken and
what actions you intend to take to resolve the above referenced violation.
Mr. Joseph Geers, Norwood City PWS
OH3101703 — NOV
July 15, 2019
Page 3 of 5

3. In accordance with OAC Rule 3745-7-09(C)(1) the duties of an operator of

record shall include the responsible and effective onsite management and
supervision of the technical operation of a public water system.

a. Based on the information documented above, you have failed to

maintain the facility, failed to take any action to correct issues noted
in the Dixon engineering report and failed to maintain records
required in accordance with OAC Rule 3745-7-09. These actions
do not represent the responsible and effective onsite management
and supervision of the technical operation of a public water system.

b. Please provide any documents you have that indicate maintenance was
performed or repairs were requested.

c. Please provide a written explanation of why actions were not taken and
what actions you intend to take to resolve the above referenced violation.

4. In accordance with OAC Rule 3745-7-09(C)(2) an operator of record shall

immediately notify the permittee or owner of a public water system and
ensure the agency is notified of items that require notification in accordance
with section 6109 of the Ohio Revised Code and the rules adopted
thereunder. OAC Rule 3745-83-01(1)(4) requires the owner or operator of a
public water system to report to the appropriate district office as soon as
possible, but within twenty-four hours, the discovery of any serious plant or
distribution system breakdown or condition causing or likely to cause any
discharge of water not in accordance with Chapter 6109 of the revised code
or any hazard for employees, consumers or the public.

a. There are no records indicating you notified Ohio EPA or your

employer of the significance of the items you were dealing with or
the findings of the storage tank inspection conducted in May 2014.

b. The discovery of holes in the roof of the 1.25 MGD storage tank,
the dead bird in the finished water and the poor condition of internal
and external protective coatings are significant issues which should
have been reported to Ohio EPA in accordance with OAC Rule
3745-83-01( I )(4)(c).

c. Please provide any documents you have that indicate the facility owner or
Ohio EPA were notified of the severity of the situation with the storage
tank.
Mr. Joseph Geers, Norwood City PWS
OH3101703 — NOV
July 15, 2019
Page 4 of 5

d. Please provide a written explanation of why actions were not taken and
what actions you intend to take to resolve the above referenced violation.

5. In accordance with OAC 3745-7-09(A)(3)(e), public water system

operation and maintenance records shall include documentation of
preventative maintenance and repairs or requests for repair of equipment
that affect or have the potential to affect the quality or quantity of water
conveyed or produced.

a. A review of the records did not indicate the performance of any

maintenance or any requests for repair to correct deficiencies noted
in the storage tank inspection discussed above or the items
documented in the Notice of Violation issued on June 3, 2019.

b. Please provide any documents you have that indicate maintenance was
performed or repairs were requested.

c. Please provide a written explanation of why actions were not taken and
what actions you intend to take to resolve the above referenced violation.

If you have already resolved the violations listed above, thank you, and please provide
documentation supporting compliance. If you have not yet addressed the violations,
please submit a compliance plan on how you plan to correct the violations cited above.
Please provide the required written responses within 15 days of the date of this
letter. Documentation of steps taken to return to compliance includes written
correspondence, updated policies, and photographs, as appropriate, and may be
submitted via the postal service or electronically to Mariano.Haensel@epa.ohio.gov.

Failure to comply with Chapter 6109 of the Ohio Revised Code and rules promulgated
thereunder may result in an administrative or civil penalty, and potential administrative
action on your certificate. If circumstances delay resolution of violations, submit written
correspondence describing the steps that will be taken and dates when compliance will
be achieved.

Please note that the submission of any requested information to respond to this letter
does not constitute waiver of the Ohio EPA's authority to seek administrative or civil
penalties as provided in Section 6109.23 and 6109.33 of the Ohio Revised Code.
Mr. Joseph Geers, Norwood City PWS
OH3101703 — NOV
July 15, 2019
Page 5of5

If you hav any questions regarding this letter, or any other matter involving your water
system, ease feel free to contact me by email at_Mariano.Haensel@epa.ohio.gov or
by pho e at (937) 285 6113.

Si

io Ha nsel
nm tal Specialist
n Drinking and Ground Waters
D~nking Water Group

J(sff Davidson, Manager, DDAGW - SWDO

Dan Stine, DDAGW — SWDO
Mary McGuinn — DDAGW - SWDO
Jeff Stark, District Office Compliance Coordinator, Ohio EPA, DDAGW, SWDO
Andrew Barienbrock, Ohio EPA, DDAGW - CO
John McDaniel, DDAGW - SWDO
Norwood Health Department
Hamilton County Health Department

cc: Mayor Thomas F. Williams, City of Norwood

MH/bp