Ohio EPA (Thomas Poffenbarger, P.E., Water Quality Engineer/Unit Supervisor, DSW Northwest District Office)

extension response letter (correspondence on a draft revised DFFO)

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Allen County Sanitary Engineer (Brad T. Niemeyer, P.E., 3230 North Cole Street, Lima) — "Re: Shawnee II WWTP / DFFO / Correspondence / NPDES / 2PK00002 / Allen County"

Shawnee II WWTP

2PK00002

2023-02-02

responds to the county's 2022-10-26 letter proposing amendments to the 2014-01-06 DFFO via the draft revised DFFOs dated 2019-05-03

correspondence on a not-yet-journalized revision (as of the letter)

OEPA's response to the county's requested amendments to the draft 2019 revised DFFOs. It recites the whole slippage arc in the agency's own words: the 1997-05-01 General Plan promised all SSOs eliminated by 2003-05-01; the 2005 DFFOs (with a $49,226 civil penalty) extended elimination to 2015-12-31; the 2014 modified DFFOs to 2020-12-31; and the county's proposal moves construction completion to 2028-12-31 — "25 years after the original proposal." OEPA agrees to the 2028 date but refuses to drop stipulated penalties, keeps SSO-elimination language while entertaining removal of the "bypass" label the county disputes (the county: the EQ overflow "was always part of the design, stemming back to the OEPA agreed upon 2009 SECAP"), and commits to post-construction monitoring of whether the EQ overflow can be eliminated. cc list spans NWDO + Central Office incl. William Fischbein (Attorney 5, Legal).

[verified] quotes from the letter text layer. Read against the 2014 instrument: the same overflow OEPA is now asked to stop calling a "bypass" was ordered eliminated by 2020-12-31 as a "temporary equalization basin overflow" (2014 Order 1.A.vii).