Open investigation · Lima, Ohio

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Every gap we're chasing on this site, in the open. Each lead is unverified inference until a source corroborates it — and every one traces to the corpus-completeness audit or a working hypothesis. Pick one up, answer it, or bring the document that closes it.

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34 open leads · unverified

Signal Unanswered [open] Ohio EPA Public Notice 222503 · data/extracted/oepa/2DP00130.npdes.yaml · eDocument portal sweep 2026-08-22 (data/research/oepa-portal-2dp00130-2026-08-22/)

The comment window on the Bistrozzi "Bosc" indirect-discharge permit closed, and no final permit has issued

Ohio EPA noticed a draft Indirect Discharge Permit (2DP00130*AP, Public Notice 222503, dated 2026-07-01) — BISTROZZI LLC's "Bosc" data center at 4110 N Cole St, Lima, routing domestic waste + non-contact cooling water through a private sanitary main and a temporary lift station to the American–Bath WWTP (a POTW that lacks a State-approved pretreatment program). Monitored parameters are water temperature, pH, and flow rate; the draft expires 2028-12-31. The 30-day window put the close at ~2026-07-31 (inferred from the notice date, not printed on the permit). Checked on 2026-08-22, 22 days after that close: Ohio EPA's eDocument portal serves 23 documents under 2DP00130 and every one of them is the 2026-05-13 application package (APP285104563). There is no approval row, no response-to-comments, and no final permit — a complete, untruncated result set, so the absence is the portal's answer and not a paging artifact. The comparison that makes it legible is the campus's own air permit (0302022054), which shows DRAFT FOR PUBLIC COMMENT (2026-01-29) followed by APPROVAL OR ACKNOWLEDGEMENT (2026-05-28); an issued permit has a shape, and this one does not have it yet. [verified: absence, portal-complete]

Re-swept 2026-08-23 and the negative is unchanged and re-dated: 23 rows, all of them the 2026-05-13 application package, coverage untruncated (1 of 1 pages), still no approval row and no final permit. Those 23 rows have now been READ — 12 of 16 distinct documents are committed under data/documents/oepa/lima/ with a full deferral record (#2089). The permit is filed under entity AMERICAN-BATH WWTP, the receiving POTW, not under BISTROZZI LLC, which is why an applicant-name search does not find it.

Help confirm → OEPA-2DP00130

Signal Under review [open] data/extracted/oepa/lima/2dp00130-surrogate-characterization.yaml · data/documents/oepa/lima/2dp00130-app285104563-manifest.yaml · data/extracted/oepa/lima/edoc-4116201.npdes.yaml

The campus's own discharge characterisation measures a different data center, 90 miles away

Ohio EPA's portal holds 23 documents under 2DP00130, all of them the 2026-05-13 application package APP285104563. Read end to end on 2026-08-23, they are three parallel submissions of one bundle — 16 distinct documents, of which the load-bearing one is the Indirect Discharge Permit Sampling Report for outfall 001 (eDocs 4116204, 4116226). ITS GROUP A RESULTS TABLE IS BLANK ON BOTH COPIES: the nine parameters the form states results MUST be provided for — BOD, COD, TOC, TSS, ammonia, maximum and average temperature, pH, total filterable residue — carry no values, and neither does any results column in Groups B or C. The report's whole affirmative content is a believed-present / believed-absent checklist naming eight analytes (bromide, fluoride, phosphorus, sulfate, aluminium, barium, copper, zinc). [verified] The applicant DISCLOSES the substitution on the face of the application (4116201 p2): "site sampling information is not available at this time as the facility is under construction ... we left the Group A table blank since we do not have actual blowdown WQ data ... Sample data from a similar site has been added for reference until sampling data can be obtained from the Project Bosc site." ⚠️ THE SIMILAR SITE IS NAMED IN THE LAB REPORTS AND IT IS NOT LIMA — "GOOGLE CLB - 1 (C008798), 225 RATHMELL RD, 43137", i.e. Google's Columbus/Lockbourne campus in Franklin County, on the Scioto rather than the Maumee, sampled 2026-04-09 (ChemTreat COA W-260410-016, eDoc 4116202; Alloway lab project 2612060, eDoc 4116205). Every number in the package's one populated table — the two-column summary appended at 4116204 p9 — is that site's water. [verified] THIS IS EASY TO MISREAD AND THAT IS THE POINT OF THE LEAD. The summary table is headed "Lima Project"; the Alloway certificate's cover reads "Project Name: Lima Project"; only the sample IDs (CLB1-City, CLB1-MCP3) and the ChemTreat company line say where the water came from. Taken on its project label alone the package would publish Columbus measurements as Lima's. WHAT THE SURROGATE DATA IS GOOD FOR, tagged [reference] throughout: it is a PAIRED makeup/loop sample, so an operating cycles-of-concentration is computable from it — chloride 3.56, total filterable residue 3.84, conductivity 3.84, potassium 3.89, sodium 4.02, sulfate 4.08, median ~3.9 across six conservative tracers (3.56-4.43 over thirteen species). That is the first disclosed, MEASURED cycles figure connected to this applicant anywhere in the record, and it sits at or just below the bottom of the 4-6 band the corpus's cooling model already cites while assuming 5.0. ⚠️ THE MODEL IS NOT ADJUSTED TO IT AND THE FIGURE IS NOT ADOPTED — it is a self-reported measurement of a different facility, cycles are limited by the LOCAL makeup water's scaling potential and Columbus city water is not Lima's, and it is one grab pair on one day. A self-report never upgrades the source; a self-reported analogue is weaker still. It also carries the only blowdown TEMPERATURE anywhere in the package (85 degF maximum, 65 degF average) — for CLB-1 — which matters because water temperature is one of the three parameters the draft 2DP00130 permit actually monitors. Group A's own temperature rows are blank.

Does NOT reopen #1479 / H1-DRAW, which closed as modelled on the correct ground that the facility is pre-operational. It sharpens that closure by dating it: the applicant now says so in its own filing and names the event that would change it. The disclosed cooling flow — 52,000 gpd average, 156,000 gpd maximum, batch — reconciles cleanly with the 0.10 MGD combined design average of the Rev. 1 PTI (see BOSC-SANITARY-DESIGN-FLOW), leaving ~0.048 MGD domestic against 155 staff on three shifts. Two defects on the face of the form are recorded and not corrected: it locates the facility at 40.741894/-73.989311 (Manhattan, New York), and it answers NO to "was a Permit to Install obtained?" 28 days after DSWPTI-260294 issued for this site. #2089

Help confirm → BOSC-DISCHARGE-SURROGATE

Open question Unanswered [open] data/extracted/oepa/lima/2dp00130-surrogate-characterization.yaml (treatment_chemicals) · data/documents/oepa/lima/edoc-4116203.pdf · edoc-4116206.pdf · edoc-4116207.pdf · edoc-4116225.pdf

The application says the cooling chemicals' design dosages are attached; they are not in the package

The 2DP00130 application's additional-information block states "See attached SDSs sheets for the anticipated cooling water treatment chemicals AND THEIR DESIGN DOSAGES" (eDoc 4116201 p2). Four safety data sheets are indeed attached and they identify the programme: Garratt-Callahan FORMULA 2310-LT, whose sheet prints its product use as "COOLING WATER TREATMENT" (4116203); Univar hydrochloric acid 15%, for pH control (4116206); sodium bromide, CAS 7647-15-6 (4116207); and Hydrite sodium hypochlorite 12.5%, an EPA-registered pesticide (4116225). The bromide/hypochlorite pair is the standard route to a bromine biocide generated in situ, which is consistent with bromide being one of only eight analytes the sampling report marks believed present. [verified] ⚠️ NO DOSAGE, FEED RATE OR DESIGN CONCENTRATION APPEARS IN ANY OF THE FOUR. All four were read end to end on 2026-08-23; a safety data sheet has no such field. The chemicals are disclosed and the dosages the form represents as filed were never filed. [verified negative] Without them the loading of bromide, phosphate and hypochlorite to the American-Bath POTW cannot be estimated from the public record, and the sampling report that would otherwise bound it is blank. A secondary defect, recorded and not resolved: the sheet filed for sodium bromide is Aldrich product 229881, a laboratory-grade material supplied under the TSCA R&D exemption whose stated identified uses are "Laboratory chemicals, Synthesis of substances". The applicant named its attachment "Sodium Bromide.pdf", so the chemical is identified; the sheet does not describe a bulk cooling-water product. [open]

OWED RECORD — the design dosages are the natural subject of a follow-up request to Ohio EPA against APP285104563, and are the one input that would let the record bound the campus's chemical loading before the facility operates. #2089

Answer this → BOSC-COOLING-DOSAGES-NOT-FILED

Signal Under review [open] data/extracted/permits/4230060.epa.yaml · data/extracted/permits/4230068.sanitary.yaml · data/documents/permits/bistrozzi-permits/filename-map.yaml

The campus discloses a 0.10 MGD sanitary design flow — cut by two thirds from the permit it replaces

Ohio EPA issued PTI DSWPTI-260597 on 2026-08-14 (eDoc 4230060), the Rev. 1 successor to DSWPTI-260294 (4074527, 2026-04-07), for the BOSC-1A Private Sanitary Sewer Improvement Plan at 4110 N Cole St. The approved application (eDoc 4230068, signed 2026-05-27, EMH&T) states the revision in the applicant's own words - "Revision to DSWPTI-260294. Design daily flow reduced from 0.333 to 0.10 MGD. As a result, force main and temporary lift station downsized accordingly." Form B1 section 3 carries the numbers - start-up AND design average daily flow 0.10 MGD, peak hourly 0.36 MGD, sewer hydraulic capacity 0.79 MGD - and the built system is 7,819 LF of 6-24 in PVC gravity, a 6 in PVCO force main, 35 manholes, a flow-split junction and two 10 ft wet wells. All [verified] from the two documents. This matters because 2DP00130 routes the campus's DOMESTIC WASTE PLUS NON-CONTACT COOLING WATER down this same private main, so the corpus now holds an applicant-stated DESIGN BASIS for that pathway where the A3 cycling reconciliation has only a back-solved bracket. ⚠️ 0.10 MGD is a design AVERAGE DAILY flow and is NOT a ceiling on what the main can carry - the same form gives a design peak hourly flow of 0.36 MGD and a sewer hydraulic capacity of 0.79 MGD, so any reconciliation against A3 has to use the figure that matches the quantity it is testing rather than treating the average as a cap. What the record does NOT say is WHY the design fell - whether load was re-estimated, or a cooling stream was moved off this line onto another pathway. That is [open], and the reduction is not by itself evidence of either. Note also that the corpus separately routes a ~2.5 MGD FM-2 industrial stream to the CITY OF LIMA WWTP (network.yaml, bosc-fm2-return); that is a different pipe to a different plant, and nothing here reconciles the two figures with each other.

A SELF-REPORT NEVER UPGRADES THE SOURCE - this is the applicant's statement to the agency, and if it disagrees with the A3 cooling reconciliation the disagreement is the finding, not a licence to adjust the model. Ingested under issue #2088. #2088

Help confirm → BOSC-SANITARY-DESIGN-FLOW

Open question Under review [open] data/extracted/permits/4230068.sanitary.yaml (Form B1 section 4) · data/extracted/oepa/oepa-2PH00007-american-bath-fact-sheet.npdes.yaml

The campus's own filing puts American/Bath WWTP at 72% of design once the campus is connected

Form B1 section 4 of the Rev. 1 PTI application (eDoc 4230068, 2026-05-27) is the applicant's disclosure of the receiving plant's loading - receiving facility "American/Bath WWTP", present average daily flow 0.953 MGD based on 01/25, design average daily flow 1.500 MGD on a 1995 design year, and proposed average daily flow with the new sewer 1.083 MGD. The applicant answers that the plant HAS adequate capacity and that there is NO intent to expand it. The 1.500 MGD design corroborates the figure the corpus already carries from Ohio EPA fact sheet 2PH00007 (used in baseline.scenario.yaml); the 0.953 MGD CURRENT loading is new to the corpus and is the first dated actual-flow figure on this plant from any source. Post-connection utilisation is 1.083 / 1.500 = 72% of a 31-year-old design. [verified] as what the document states. ⚠️ ONE ARITHMETIC GAP, UNRESOLVED - 0.953 present plus the 0.10 MGD design flow of this sewer is 1.053, not the 1.083 stated. The 0.030 MGD difference is not explained anywhere on the form. It may be another committed connection, a rounding or basis difference, or a form error; the record does not say, so it stays [open] rather than being reconciled by assumption.

Distinct from LIMA-WWTP-SHARE, which concerns the City of Lima WWTP (2PE00000, 18.5 MGD) and the FM-2 stream - a different plant and a different pipe. Do not merge the two headroom questions. OWED RECORD - American/Bath's own DMR record would test the 0.953 figure against reported flow; a self-reported plant loading on an applicant's form is not the plant's own submission. #2088

Answer this → AMERICAN-BATH-HEADROOM

Signal Unanswered [open] Reported (uncorroborated) · coordinate + neighbor from the ODNR census (data/reference/ohio-waterwells/allen.csv)

A reportedly dry-and-replaced shallow well sits ~3.7 mi down-gradient of the dewatering field

A shallow domestic well near 40.83613, -84.16757 (about 3.7 mi northwest of the construction-dewatering wellfield centroid) was reported to have run dry and needed replacement. Our Cooper-Jacob screen puts zero [inference] drawdown there — the modeled radius of influence is ~2,000 ft and no defensible homogeneous cone reaches 3.7 mi in this aquifer, so the field's cone AS MODELED is not the mechanism. Two facts keep it a lead rather than a dismissal — the site sits DOWN-gradient of the field (the regional water table falls ~12 ft/mi toward compass ~315 deg, the direction a dewatering field's influence preferentially extends), and the nearest census well is a marginal bedrock well (57 ft deep, 56.5 ft static — only ~0.5 ft of water column) that could fail under drought alone. Distinguishing a preferential (buried-valley) pathway from an independently marginal well needs site hydrogeology the record does not carry.

OWED RECORD — a dewatering pumping-test / drawdown-monitoring record or a buried-valley aquifer map would resolve whether the field reaches this far; absent that it stays open/reported.

Help confirm → DEWATERING-DRYWELL-NW

Signal Under review [open] The Lima News 2026-05-11 · data/extracted/limaohio/lima-news-construction-wave.news.yaml

Ohio EPA is monitoring lime-kiln dust drifting off the data-center construction site

The first construction-phase environmental signal on record. Per an email from Ohio EPA Public Information Officer Anthony Chenault (reported by The Lima News 2026-05-11), inspectors visited the North Cole St site because lime kiln dust and alkaline powder used to dry and stabilize wet soil was being carried off-site by the wind. Ohio EPA "asked the company to reduce and contain the spread of dust"; the construction company's plan adds water trucks and monitors wind conditions during lime-kiln application, and agency staff said they would "visit the site frequently over the next few weeks." A cited Safety Data Sheet notes the dust can irritate eyes, skin, and the respiratory and gastrointestinal tracts. Whether the suppression plan holds — and whether dust reaches residents — is unresolved. Secondary reporting; the underlying Ohio EPA correspondence is not yet in the corpus.

first post-permit construction-impact signal (distinct from the 313 MW backup-genset air permit) #1477

Help confirm → LIMA-LIMEDUST

Signal Unanswered [open] The Lima News 2026-05-15 · data/extracted/limaohio/lima-news-construction-wave.news.yaml

Corridor residents contest the Google-funded roundabout construction and easement takings

At a Port Authority of Allen County open house (2026-05-14, reported by The Lima News 2026-05-15), Sugar Creek Township residents said the North Cole St roundabouts (SR-115 construction from 2026-06-01, Bluelick Rd in August, Beery Rd TBD) benefit Google more than the community. Lynne Focht, ceding a permanent right-of-way easement near the SR-115 intersection, said she "will never own that land again"; David Streeter said "none of it has to do with long-term health to the individuals, to the residents." Their unifying ask was transparency and a Google contact person — still unanswered. The first construction-phase community-reaction signal; extends the PAAC transparency record (paac-board-minutes) into the build. Secondary reporting.

#1477

Help confirm → LIMA-CONSTR-TRAFFIC

Redaction Withheld [open] Allen County PRR · item 4

The project's cost-benefit analysis is withheld

Item 4 of the BOSC public-records request — the projected tax-revenue impact and public-ROI inputs and assumptions — is held by county legal counsel under R.C. 149.43 and the §9.66(D) data-center exemption. Not produced.

the one to watch

Fill the gap → PRR-04

Redaction Withheld [open] OEPA PTI · eDoc 4132514

The per-engine output behind the 313 MW figure is trade-secret-redacted

The final air permit-to-install (eDoc 4132514, 2026-05-28) confirms the generator count and three-hall emission-unit grouping on a primary footing, but the per-engine ekW behind the disclosed 313 MW is redacted as trade secret.

Fill the gap → PTI-313MW

Redaction Withheld [open] Allen SWCD · §149.433 / §1333.61

The site plan sets are withheld twice over

The County withholds the BOSC-1A plan sets; the Soil & Water district shields the same documents again under R.C. 149.433 (infrastructure records) and R.C. 1333.61 (trade secret — “water and wastewater usage for a data center”), a ground that reaches even the plan-share links inside produced emails.

Fill the gap → ASWCD-PLANS

Redaction Withheld [open] Allen County PRR · item 16 · contested

The county website's edit history is disclaimed, not absent

Item 16 (the CMS audit trail for the Sanitary Engineering pages) was answered “no records — we don't manage the website,” yet the WordPress /revisions endpoint returns HTTP 401 (gated, not 404). The version history exists; custody sits with the host.

Fill the gap → PRR-16

Open question Under review [open] Allen SWCD · item 3

Wetland determination: “no records” — but a produced inspection says otherwise

The SWCD answered “no records” for the 0.7-acre forested wetland (DSW401251760W), yet a produced site inspection records that “the existing wetland was mitigated.” A produced record contradicts the answer.

Answer this → ASWCD-03

Open question Under review [open] Allen SWCD · item 4

Farm-tile drainage impact: “no records” — yet a failure is photographed

The SWCD answered “no records” on tile / agricultural-drainage impact, but the 2026-06-05 inspection documents an east farm-tile diversion-swale failure (photo captioned “East farm tile bypass”).

Answer this → ASWCD-04

Open question Unanswered [open] Cross-production referral · item 9 · data/extracted/legal/prr-mandamus/prr-production-2026-07-24/hume-road-wpclf-application-2026.award.yaml

Nobody owns the forcemain's MGD design capacity

The Hume / Shawnee forcemain's design capacity (item 9) is disclaimed by every county body — each points to Ohio EPA or the townships. Batch 2 produced the financing and the engineering contract, not the MGD figure. **Batch 3 (2026-07-24) did not close it either:** the item-11 Hume Road WPCLF application was produced in full (all 11 pages read) but is a financial/loan form end to end — no forcemain design-capacity figure, no feasibility study, no engineering attachment anywhere in it (a verified absence from the produced document). [inference] The design capacity would sit in the project's design/feasibility work — Access Engineering is the named consulting engineer on the application — which the county did not produce; the produced records establish neither that work's contents nor who holds it. (Distinct from the City of Lima WWTP's own 18.5 MGD design flow, now in the corpus via the public NPDES permit — see LIMA-WWTP-SHARE.)

Answer this → FORCEMAIN-MGD

Open question Unanswered [open] data/reference/hydrology/thermal-discharge-screen.yaml (EPA ECHO DMR, 2024-05-01..2024-10-31) · data/reference/wqs/ohio-temperature-criteria.yaml · data/extracted/oepa/2DP00130.npdes.yaml

Nothing on the Ottawa corridor holds a thermal limit against the heat already in the river

Ohio's numeric temperature criterion for this reach is a 29.4 degC daily maximum (OAC 3745-1-35 Table 35-11, zone G, Jun 16-30). Two permitted dischargers report peak daily-maximum effluent temperatures at or over it from their own submissions — Lima Refinery (OH0002623) at 32.2 degC and PCS Nitrogen (OH0002615) at 30.0 degC — and neither outfall carrying those reported temperatures has a numeric thermal limit. The refinery's permit does hold an 85 degF ceiling, but on outfall 003; the reported temperature above is outfall 001's, which carries none, so the ceiling does not bind the discharge screened here. All three permits that report a temperature on this reach (adding the City of Lima WWTP, OH0026069) are monitor-only on the reporting outfall. [verified] from the reported ECHO DMR record. What no record shows is any thermal mixing-zone determination, alternative-effluent-limit demonstration, or CWA section 316(a) balanced-indigenous-community study for the corridor — the instrument that would establish whether the reported temperatures are authorized. Separately, the campus's own heat load has no thermal instrument at all — it holds no NPDES permit; its indirect-discharge permit (2DP00130*AP) monitors water temperature at the sewer, which is a POTW pretreatment condition, not a receiving-water limit.

OWED RECORD — a fact sheet, mixing-zone determination, or section 316(a) demonstration for any Ottawa-corridor thermal discharge would resolve it; absent that the authorization basis stays open #1719

Answer this → THERMAL-NO-LIMIT

Open question Unanswered [open] Allen County PRR · item 2 · narrowed

County ⇄ DoD / federal-contractor comms — narrowed to nothing

Item 2 sought County communications with DoD or federal contractors (GDIT, GDLS) about the American Township facility and corridor. The county narrowed the ask and returned “no records.”

Answer this → PRR-02

Open question Unanswered [open] Allen County PRR · item 19 · owed

County ⇄ engineer-of-record (EMH&T) comms not produced

Item 19 sought County communications with EMH&T. None produced as to the Commissioners; the SWCD produced its own EMH&T emails, but the County's are still owed (it may supplement from Sanitary Engineering).

Answer this → PRR-19

Open question Unanswered [open] Ohio EPA GLRI subaward files · owed

The grant instrument behind the $650k Lost Creek project

The funding source is verified — a GLRI subaward through Ohio EPA, OSU portion $327,450, term 2023–2025 — but the signed award instrument (deliverables, match, reporting) on the Maumee-headwater ag-runoff project is still owed.

Answer this → GLRI-INSTRUMENT

Signal Low confidence [open] Allen SWCD capture · untranscribed

The OSU monitoring data quantifying the Maumee-headwater load

Continuous flow and water-quality from three ISCO6712 sites would quantify the actual nutrient / flow reduction on Lost Creek (HUC12 041000070305). The load-reduction table is referenced on the captured SWCD page but not transcribed.

Help confirm → OSU-MONITORING

Open question Unanswered [inference] Hypothesis H2 · defense nexus · data/extracted/lima/federal-authorization-instrument-search.md (#1480 documented negative search)

The campus's federal authorization posture is undisclosed — searched, negative

The Joint Systems Manufacturing Center (Lima Army Tank Plant) is co-located with the campus — documented geography under hypothesis H2 — but the campus's authorization posture (FedRAMP / DoD impact level) is undisclosed, so the causal link to the boom remains an inference. A #1480 search of the primary instrument surfaces came back negative on every path: USASpending/SAM.gov return no recipient or award for Bistrozzi LLC / Bistrozzi Addition LLC; the FedRAMP Marketplace lists Google Cloud service-wide (High), naming no Lima facility; and Google's public-sector posture runs on Assured Workloads — a software-defined community cloud that uses no physical infrastructure distinct from the commercial data centers — so a facility-scoped authorization instrument for Lima cannot exist by construction. The question stays open (the posture is genuinely undisclosed, not merely un-found), but it is now investigated and bounded, not a standing un-run inference.

Answer this → H2-AUTH

Claim Low confidence [inference] docs/HYDROLOGY.md §"Cooling water demand" and §"The supply side" · hypothesis H1 · water & power

The consumptive cooling draw is closed as modelled, and the 7Q10 is no longer the binding constraint

The Ottawa's design low flow is about 0.2 cfs (cited), and the campus's consumptive cooling loss is the keystone of hypothesis H1. What the record can carry today is a modelled draw, and it does: two independent methods bracket the consumptive demand at 3.14-3.84 MGD, and buildout adds 4.85 cfs of net consumptive draw — 24.3x that cited annual 7Q10, or 3x the cited summer 30Q10 of 1.6 cfs in the MAY-OCT window when reference ET already exceeds rainfall. A *measured* draw does not exist to be found: the facility is pre-operational, so no monitored flow has been reported. Two things keep this a lead rather than a finding. The figures are [inference: derived] and [inference: assumption] throughout — a modelled bracket, never a measurement. And the ratio itself is a screening bound, not the operating mechanism: Lima does not withdraw at the 7Q10 at all, drawing instead from ~14.4 billion gallons of off-stream reservoir storage filled by high-flow pumping, so the constraint that actually binds is reservoir drawdown (a 199-day cut to the zero-refill drought reserve), not intake depletion. The 24.3x multiple is the honest headline only if it is read as what it is.

A measured draw becomes obtainable only once 2DP00130 issues and the facility operates and reports its monitored flow rate — see the OEPA-2DP00130 lead.

Corroborate → H1-DRAW

Signal Unanswered [open] watermark-directory/the-watermark-directory#34

Acquire the GLRI / Ohio EPA Lost Creek grant instruments (subaward, design, load-reduction table, monitoring)

The corpus holds a **secondary** Allen SWCD summary of a \$650,000 ag-runoff retention/treatment grant (Project `ALLENSWCD-FDFARM22`) on **Lost Creek HUC12 041000070305** (a Maumee headwater 2.7 mi east of I-75) — baseline nutrient-burden context for the hydrology axis. The funding source is verified (GLRI subaward via Ohio EPA, OSU portion \$327,450, 2023-2025), but the primary instruments are not in hand. ### Scope — documents still owed (see audit §2 table) - **Grant agreement / award instrument** — the signed GLRI / Ohio EPA subaward (deliverables, match, reporting). Source: Ohio EPA GLRI files; Allen SWCD; PRR. - **OSU application & conceptual design** — engineering basis for the BMPs (berm/wetland/forebay/pump-vault; saturated buffer). Source: OSU FABE (Dr. V. Shedekar). - **Load-reduction estimate table** — referenced on the captured page ("table below") but **not transcribed** in `data/extracted/watershed/osu-lima-ag-runoff-treatment.capture.yaml`. Re-capture the full page / SWCD project file. - **OSU monitoring data** — continuous flow + water quality (3 sites, ISCO6712 samplers). ### Acceptance - Primary instrument(s) committed under `data/documents/watershed/` (or the load-reduction table transcribed into the existing capture YAML), with the audit §2 rows flipped to "in hand". Source: `data/extracted/legal/corpus-completeness-audit.md` §2; `docs/HYDROLOGY.md`.

#34

Help confirm → GH-34

Signal Withheld [open] watermark-directory/the-watermark-directory#35

Pursue outstanding PRR records: item 4 cost-benefit + items 5-15 county wastewater universe

Two outstanding clusters from the county PRR production tracker (cover letter 2026-06-05). Production is rolling ("every Friday"); these are the items to watch in subsequent batches. This is an external-dependency tracking issue, not an engineering task. ### Item 4 — Project BOSC cost-benefit analysis (WITHHELD) Cost-benefit analysis / projected tax-revenue impact / public-ROI inputs & assumptions — withheld "being reviewed by our legal counsel for compliance with R.C. 149.43 and R.C. 9.66." Watch for release in later productions. ### Items 5-15 — county wastewater works (DEFERRED to the Sanitary Engineer) BOSC pump-station/forcemain **RFP + bids**; permits **DSWPTI-260294** & **DSW-6756**; **Shawnee II Phase 2** (the request text characterizes this as 12.6 MGD; the produced batch-2 records — Res #220-24, 2026-06-12 — document the receiving plant's influent pump-station **firm** capacity expanding **15 → 25 MGD**) design; **MS Consultants forcemain feasibility** (Res #113-26 / #136-26); **1996 CWA consent decree**; **Cridersville WWTP** records. The largest, most case-relevant hole. Note the internal contradiction already documented: Res #113-26 / #136-26 sit in the Commissioners own minutes (`M021926.pdf:3`, `M022626.pdf:3`). Consider a fresh PRR directed to the Allen County Sanitary Engineer. ### Acceptance - Track each Friday production; as records land, ingest them (NPDES/EPA/plan kinds) and update `corpus-completeness-audit.md` §1. ### Batch 3 (2026-07-24) — the Sanitary Engineer's per-item production The county produced native per-item file trees for items **9/11/13/14/15** (1,610 files; ingested + extracted — see `bosc-prr-production-2026-07-24.response-index.yaml` and the `.analysis.md`). This grounds the SSO/DFFO enforcement chain (1997→2028), the OWDA Loan 6718 Phase-1 financing ($15.36M), the Cridersville treatment agreement + its Section-16 termination mechanism, and the Hume Road WPCLF application. **Two responsiveness gaps remain outstanding:** (a) **item 13** — the county answered the 2024→ MS Consultants / BOSC pump-station+forcemain ask with an empty "13 - See 9" folder, but the item-9 tree is Phase-1-era (2008-2016) with no 2024-onward MS Consultants records; and (b) the still-withheld **item 4** cost-benefit. Item 9's literal ask — a record referencing the **12.6 MGD peak** figure — was **not** produced (0 of 1,245 machine-readable files reference it). Source: `data/extracted/legal/corpus-completeness-audit.md` §1; `prr-mandamus/bosc-prr-production-2026-06-05.response-index.yaml`; `prr-mandamus/bosc-prr-production-2026-07-24.response-index.yaml`.

#35

Help confirm → GH-35

Claim Under review [inference] watermark-directory/the-watermark-directory#144

Follow up on Allen SWCD request items 3 & 4 (wetland determinations + tile drainage)

**Context.** In the Allen SWCD PRR production (merged in #142) the District answered **item 3** (wetland / floodplain / water-resource determinations) and **item 4** (tile / field-tile / agricultural-drainage system affected by construction) with *"no responsive records"* — each qualified *"unless your request also implicates the previously identified sets of plans"* (which it withheld). **Worth a second look.** The inspection forms the SWCD *did* produce speak directly to both subjects: - **Item 3 (wetland).** Inspections from **2025-12-08** onward record *"the existing wetland was mitigated."* The on-site isolated-wetland 401 permit **DSW401251760W** (issued 2025-08-12) and its **2025-08-18 Mitigation Purchase Agreement** are already in-corpus (`permits/3788677.epa.yaml`, `permits/3796349.epa.yaml`). - **Item 4 (tile drainage).** The **2026-06-05** inspection documents an **east farm-tile diversion swale** failure — *"the tile is no longer exposed and only bubbling up through soil"* — with a labeled photo (*"East farm tile bypass,"* bundle p9). **Follow-ups.** 1. Pin down the scope of the "no records" answers — do they exclude the produced inspection forms and/or the withheld plan sets? (The qualifier suggests the determinations may have been folded into the withheld plans.) 2. Pursue the determination record sets elsewhere: Ohio EPA's 401 / Isolated Wetland Permit file for **DSW401251760W** and pending **DSW401252260W** (applied 2025-12-09); Army Corps if a federal nexus exists; and the County Engineer / Sanitary tile-drainage & as-built records for item 4. 3. Roll the breached-tile + creek-west-of-site dewatering finding into the hydrology/discharge axis. **Refs.** - `data/extracted/legal/prr-mandamus/bosc-prr-production-2026-06-12-aswcd.response-index.yaml` — items 3 & 4 + findings `wetland-mitigated-vs-no-records`, `farm-tile-impact-vs-no-records` - `data/extracted/legal/corpus-completeness-audit.md` §1 (Allen SWCD production) - Outstanding-records trackin…

#144

Corroborate → GH-144

Open question Unanswered [open] watermark-directory/the-watermark-directory#155

Track the disposition of the Level-2 wetland permit DSW401252260W (incomplete 2025-12-23)

## Context Open question surfaced by the permit-vs-disturbance sequence reconstruction (#150 / #153), observation **`level2-401-after-clearing`** in [`bosc-site-permit-sequence.yaml`](../blob/main/data/extracted/legal/prr-mandamus/bosc-site-permit-sequence.yaml). ## The question Was the broader **Level-2** isolated-wetland fill at the BOSC site authorized before the fill area was disturbed — and what is its current disposition? ## What the records show - The narrow **Category-1** isolated wetlands (0.33 ac) *were* authorized first: DSW401251760W, granted **2025-08-12** (before disturbance) — in-corpus (`permits/3788677`, `/3796349`). - The **Level-2** application (DSW401252260W) was received **2025-12-09** — the day after the first inspection records clearing/grubbing underway — and Ohio EPA declared it **INCOMPLETE** on **2025-12-23** (no practicable on-site alternatives analysis "for the entire site"; the delineation covers ~358 ac). In-corpus: `permits/3949585`. - **The corpus contains no later disposition** of DSW401252260W (a grep finds only the 2025-12-23 incompleteness letter). ## Deliverable Acquire the subsequent Ohio EPA 401/Wetlands/Mitigation correspondence for **DSW401252260W**: was a revised application submitted, and was it **granted or denied** — when, and at what fill scope? Add the disposition event(s) to the chronology in `bosc-site-permit-sequence.yaml` and ingest the record under `data/extracted/permits/`. ## Source Ohio EPA DSW 401/Wetlands/Mitigation Section (the same Joe Loucek / Heather Allamon / Rachel Secrest contacts on the in-corpus letters); or the Bistrozzi-permits production set. Content-verify the date; no source bytes altered. Analysis, not a legal conclusion.

#155

Answer this → GH-155

Signal Withheld [open] watermark-directory/the-watermark-directory#160

Acquire the architectural footprint sheets / emission-unit plot plan to re-ground compute Method 3

**Refines #33.** The issued PTI **P0138965** confirms the emission-unit **grouping** (P001–P114 in three groups of 38 + 36 cooling towers in three groups of 12 → **≈ three data halls**) but carries **no plot-plan attachment and no floor area**. So compute **Method 3** (`docs/COMPUTE.md`) stays the flagged-weak **land-area envelope**, not real floor area. **To get.** The **architectural site-plan sheets** (CI Design / WSP / EMH&T) showing the data-hall building footprints, or the permit's plot-plan attachment if one exists. The committed plan set is a single grading & storm sheet (`1A-C-3104`) showing only ancillary SSS/GPS buildings on piers — the data-hall footprints sit on sheets not in hand. **Acceptance.** - Data-hall floor area documented from a primary source; Method 3 re-grounded from land-area envelope to floor area in `docs/COMPUTE.md` + `watermark.facility`. **Refs.** `corpus-completeness-audit.md` §4; `docs/COMPUTE.md`; #33.

#160

Help confirm → GH-160

Signal Unanswered [open] watermark-directory/the-watermark-directory#161

Acquire the corridor environmental records (forcemain + Shawnee II Ph2 NPDES/SWPPP/ESC; item-9 MGD) — the #151 referral

Surfaced by the cross-production referral map (**#151**, `legal/prr-mandamus/cross-production-referral-map.yaml`). With three producing bodies now on the record, the **corridor-level environmental** records are owned by **no county body** — each disclaims and points to the next: - **ASWCD item 6** — BOSC-1A forcemain NPDES / SWPPP / ESC → "Ohio EPA / Sanitary Eng" - **ASWCD item 8** — Shawnee II Phase 2 stormwater / ESC → "Ohio EPA / Sanitary Eng" - **ASWCD item 9** — Hume/Shawnee forcemain **MGD design capacity** → "Ohio EPA / Sanitary Eng" - **ASWCD item 7** — forcemain drainage / tile / wetland → "Sanitary Eng / **townships**" Batch 2 produced the **procurement / financing / resolution** layer of these projects but **not** their environmental-permit layer. **To get.** Ohio EPA Division of Surface Water (NPDES construction-stormwater / SWPPP / ESC for the forcemain corridors + Shawnee II Phase 2; the item-9 MGD design capacity). The **townships** (American / Shawnee) are **not yet a requested custodian** — a candidate next PRR target. **Refs.** `legal/prr-mandamus/cross-production-referral-map.yaml`; `corpus-completeness-audit.md` §1; #35.

#161

Help confirm → GH-161

Signal Withheld [inference] watermark-directory/the-watermark-directory#162

Pursue the item-16 CMS / WordPress revision history (county Sanitary pages) at the web host

PRR **item 16** asked for the CMS audit trail / edit history of the county **Sanitary Engineering** pages (2025-01-01→). The Commissioners answered "**No records… do not manage the county website**" — **contested**: - The Sanitary pages' WordPress `modified` dates fall **inside** the requested window. - The `/wp-json/wp/v2/.../revisions` endpoint returns **HTTP 401 (gated, not 404)** — the version history **exists**; custody simply sits with the **host** (AhelioTech / CorpComm-built site). **To get.** The page revision history from the **host** (or via a custody-directed request), and/or document the 401-gated-but-present finding as the standing rebuttal to the "no records" disclaimer. **Refs.** `legal/web-vendor-audit/allen-county-web-vendor-audit.md`, `allen-county-level-sites.md`; `corpus-completeness-audit.md` §1 (item 16).

#162

Help confirm → GH-162

Signal Unanswered [open] watermark-directory/the-watermark-directory#752

gap(extraction): extract the LACRPC CAC agenda .jpg — first use of the #703 image path

**Follow-up to #703** (the raw image-source extraction path), now on `main`. #703 built the `.png/.jpg/.tif` read path but ran **no** live extraction — the path ships, nothing uses it yet. This is its first real use. ## Target `data/documents/lacrpc/meetings/20260120 CAC Agenda and Meeting Notice.jpg` — the one image-only source in the corpus (a Lima–Allen County Regional Planning Commission Citizens Advisory Committee agenda / meeting notice). Currently reference-only; the #703 path can now read it straight into the vision extractor (single image, no OCR hint). ## Scope - Run the live image extraction (`extract_document(doc, kind=…)` over the `.jpg`, via the new `_read_doc` image branch) → a reviewed artifact under `data/extracted/lacrpc/`. - **Open question — which kind/model.** This is a meeting agenda, not one of the six current doc kinds (deed/npdes/sos/epa/wetland/engineering). Decide before extracting: - map it to the LACRPC meetings/timeline layer (cf. `data/extracted/lacrpc/meetings/meeting-summaries.yaml`), or - add a light generic agenda/notice kind+model, or - capture it as a dated `TimelineEvent` source only. Prefer the smallest change that keeps the figure/text honest. - **Chain of custody:** the `.jpg` is immutable evidence — don't rename/alter the source byte. Record the canonical name + a content-verified date in the collection's alias manifest if one applies. - Validate the new extraction against `watermark.models` (`test_extracted_yaml_valid.py` must stay green). ## Why it's separate It runs the API (cost) and lands a **reviewed corpus artifact** — a deliberate, gated decision distinct from shipping the code path. Tag claims `[verified]` only against the extracted artifact once committed. ## Done when The LACRPC CAC agenda is a committed, schema-valid extraction under `data/extracted/lacrpc/`, sourced through the #703 image path, and (if it carries a date/parties) wired into the timeline/meetings layer.

#752

Help confirm → GH-752

Signal Unanswered [open] AEP Ohio Lyka Transmission Project fact sheet (captured 2026-07-11) · data/extracted/grid/aep-lyka-transmission-2026.project.yaml

AEP Ohio's Lyka 345kV substation/line has no OPSB case yet — filing expected early 2027, final route undetermined

AEP Ohio's own project fact sheet (captured 2026-07-11, dated 2026-04-08) schedules the Ohio Power Siting Board (OPSB) regulatory filing for "Early 2027" and an anticipated OPSB decision for "Spring 2027" — as of this writing no OPSB case number has been assigned or filed (confirmed by direct search of opsb.ohio.gov and AEP's own regulatory-filings index). The Lyka Substation site (a customer-owned parcel between N West St and N Cole St, Sugar Creek Township) is fixed, but the ~4-mile 345kV line route is not — AEP's own map shows 45 numbered "study segments" still under consideration, and the company selects a final route only after public input and field surveys, which run through fall 2026. A separate, unrelated Ohio History Connection/SHPO review track (OHPO project ID 2026ALL68059, "Lyka Station STATCOM Project," received 2026-04-08) should not be conflated with the OPSB siting case itself. Secondary reporting (LimaOhio.com, 2026-04-21) states the substation is sited "on Google's under-construction property" — AEP's own materials never name a customer ("a commercial customer's facility"); the Google/Bistrozzi attribution stays [inference] until an OPSB filing names the load.

time-sensitive — monitor opsb.ohio.gov for the case filing, expected Early 2027; the line route is not final until then (issue

Help confirm → AEP-LYKA-OPSB

Open question Unanswered [open] src/watermark/hydrology/assimilative.py · src/watermark/hydrology/toxics.py

The municipal-WWTP dilution check is hydraulic only — no per-parameter assimilative capacity on record

The industrial toxic screen now reads each RSEI water discharger's per-chemical load against its own Ohio water-quality criterion (WS-07, issue 1607; data/reference/wqs/). The parallel check for the three municipal WWTPs (hydrology/assimilative.py) is still a purely HYDRAULIC dilution ratio (7Q10 / effluent flow) — a true per-parameter assimilative-capacity screen (ammonia, CBOD, total residual chlorine, metals against their WQBEL-driving criteria) needs each plant's reported effluent CONCENTRATIONS by parameter, which the corpus does not yet hold. The Ohio EPA NPDES DMR record (effluent monitoring) is the missing input; ingesting it via the ECHO DMR connector would let the municipal check screen per parameter the same way the industrial one now does, rather than asserting a rigor the flow-only data can't support.

WS-07 companion — extend the per-chemical criterion screen to the municipal WWTPs once DMR effluent chemistry is ingested (issue 1607). ⚠️ NOT ADVANCED BY #2089, and worth recording why: the 2DP00130 package is an INDIRECT discharger's characterisation of what it sends TO a POTW, which is upstream of plant effluent chemistry and is not a substitute for it. In any case that characterisation is blank — see BOSC-DISCHARGE-SURROGATE. American-Bath's own DMR record remains the missing input for this plant.

Answer this → WWTP-PARAM-ASSIM

Signal Unanswered [open] data/extracted/oepa/lima/edoc-1840393.npdes.yaml (application, Section II.G.1) · data/extracted/oepa/lima/edoc-412983.order.yaml (decree, Appendix A Table A.1)

The 2022 permit application tells Ohio EPA that four SSO basins are built to a 25-year storm; the consent decree sizes them to a 5-year storm

Two agency-filed documents describe the same seven SSO basin projects and disagree on exactly one column. Appendix A, Table A.1 of the 2015 federal consent decree (Case 3:14 CV 2551) puts Lima's basins in TWO protection tiers - Allentown, West Street and Koop sized to convey a 25-year, 6-hour design storm, and Lost Creek, COLE ST., Findlay Road and Fifteenth St. sized to a 5-YEAR, 6-hour storm, with performance criteria "Control SSOs in this basin up to 5-Year, 6-hour design event flow rates". The 2022 NPDES renewal application (EPA Form 3510-1, Application ID 256207483, filed 2022-06-09, Section II.G.1) lists ALL SEVEN as "upgrades sized to convey 25 year, 6 hour storm". Every DATE in the application matches the decree exactly - Simmons Field 2024-08-30 through Fifteenth St. 2038-04-01 - so the application is transcribing the schedule faithfully and uniformly overstating the design storm on the four lower-tier basins. [verified] on both texts; the decree's Table A.1 was read from the page image at 200 DPI because that table is a rotated scan. What it MEANS is open. Whether the as-built design follows the decree or the application, and whether Ohio EPA relied on the 25-year statement when it issued 2PE00000*OD in 2023, are not answerable from these two documents. A copy-down of the first row's language is the obvious explanation and is [inference], not established.

Relevant to #1760 because Cole St. is one of the four. It is NOT evidence about the Bosc campus - a basin named for a street says nothing about which parcels drain to it. The application does supply the geometry handle that question needs: a full SSO outfall inventory with coordinates per point, and CSO outfall 037 "North Sore [sic] @ Cole" at 40.744167, -84.137778. Note the Cole St. BASIN is an SSO basin while 037 is a CSO point; they are not the same thing. UPDATE 2026-08-23 (issue #2088): The Rev. 1 sanitary PTI application (eDoc 4230068, section 5 f/g) puts the APPLICANT'S OWN answer on this question for the first time. Asked "Are there any overflows or bypasses UPSTREAM of the point of connection that may be impacted by the flows from the new sewer?" it answers NO, and asked "Are there any sanitary overflows or bypasses or combined sewer overflows DOWNSTREAM of the point of connection?" it answers NO. Section 9 names the installation inspector and section 10 the sewer-use enforcement authority as the ALLEN COUNTY SANITARY ENGINEERING DEPARTMENT (3230 N. Cole St.), and section 4 names the receiving plant as American/Bath WWTP - i.e. the campus's private sanitary ties into the COUNTY system tributary to American/Bath, not into a City of Lima basin. ⚠️ THIS DOES NOT RESOLVE THE COLE ST. QUESTION AND MUST NOT BE READ AS RESOLVING IT. It is an applicant's checkbox answer on its own application, unaccompanied by a tributary-area analysis, and a self-report never upgrades the source. It is also not a statement about the Cole St. SSO basin by name. What it does is raise the cost of the affirmative: the applicant has told the agency there is no downstream SSO or CSO from its point of connection, and it named a receiving plant that is not the City's. #2090 still needs the geometry from the plan sets (4230061 / 4230062) to test it, and a negative there remains a good and publishable outcome.

Help confirm → SSO-DESIGN-STORM

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Recently closed sourced

NPDES construction-stormwater coverage located — 2GC08468*AG, effective 2025-11-10 closes #143 + #154 · sourced 2026-06-16
County wastewater universe (PRR items 5–15) produced PRR batch 2 · sourced 2026-06-12
GLRI funding source resolved — OSU $327,450, 2023–2025 Shedekar CV · sourced 2026-06-06