Record · Enforcement
correspondence
edoc-3170424
Fields
agency
U.S. EPA / DOJ / Ohio Attorney General
instrument
correspondence
case_no
3:14-CV-02551-JZ
respondent
City of Lima, Ohio
facility
City of Lima Sanitary Sewer System (SSS)
permit_no
—
issued_date
2017-05-26
effective_date
—
supersedes
Consent Decree entered into on January 13, 2015
penalty_usd
—
stipulated_penalties
—
status
—
summary
This is a May 26, 2017 correspondence letter from the City of Lima, Ohio (signed by the Director of Utilities) to U.S. EPA Region 5, DOJ, and the Ohio Attorney General, responding line-by-line to USEPA's April 3, 2017 letter conditionally approving Lima's CMOM Program Plan (a Consent Decree requirement under Case 3:14-CV-02551-JZ, entered January 13, 2015). The letter addresses requested modifications across multiple CMOM sections—including hydrogen sulfide monitoring, emergency preparedness, maintenance scheduling, sewer cleaning/CCTV inspection, capacity evaluation, and rehabilitation—and commits to submitting a revised CMOM Program Plan and all requested reports within 30 days.
note
—
obligations
- requirement Inspect and exercise all air release valves associated with the sanitary force mains on an annual basis (Section 5.3 – Hydrogen Sulfide Monitoring and Control)
- deadline —
- status committed
- requirement Line five manholes in the Bowman Road Area downstream of a force main discharge affected by hydrogen sulfide as part of the 2017 capital improvement budget
- deadline 2017-12-31
- status committed
- requirement Post permanent warning sign at SSO #337 (Lost Creek) within 90 days of letter date
- deadline 2017-08-24
- status committed
- requirement Revise SOERP to describe how Environmental Compliance Manager determines whether temporary warning signs related to SSO discharges are warranted (Section 5.5 – Emergency Preparedness and Response)
- deadline —
- status committed
- requirement Maintain $250,000 contingency line item in annual budget for emergency sanitary needs (Section 5.1 – Maintenance and Budgeting)
- deadline —
- status active
- requirement Revise CMOM Program Plan to reflect a cleaning schedule of the entire SSS at least once every 5 years (Section 6.4/6.5)
- deadline —
- status committed
- requirement Maintain 10-year CCTV inspection schedule (Section 6.4/6.5)
- deadline —
- status committed
- requirement Revise manhole inspection schedule to reflect a 5-year frequency (Section 8.5)
- deadline —
- status committed
- requirement Submit revised CMOM Program Plan and copies of requested reports within 30 days of this correspondence
- deadline 2017-06-25
- status committed
- requirement Revise Table 10-1 to include a schedule for all action items listed (Section 10.0 – CMOM Program Future Performance Goals)
- deadline —
- status committed
- requirement Revise CMOM Program Plan to describe how Lima plans to address the reported budget deficiency (Appendix A – Sewer Asset Risk Scoring); plan includes annual rate increases, grants/0% interest loans, and WPCLF borrowing
- deadline —
- status committed
- requirement Provide copy of Evaluation of Private Property Infiltration and Inflow report (Section 8)
- deadline —
- status committed
- requirement Provide copy of City of Lima Separate Sanitary Sewer System Pump Station Condition Assessment (August 6, 2012) (Section 9.0)
- deadline —
- status committed
- requirement SOERP training: all Supervisors, Operators, Assistant Operators, and Sewer System Technicians to read and sign SOERP annually (Section 5.5)
- deadline —
- status committed
⚠ Gaps in the record
- OCR rendered case number as '3:14-C1t-02S51-.IZ'; verified from image as '3:14-CV-02551-JZ'
- OCR rendered DOJ No. as '90-5-1-1-08433'; verified from image as '90-5-1-1-08433'
- 90-day warning sign deadline calculated from letter date 2017-05-26 yielding approx. 2017-08-24
- Pages appended to the letter (Hydrostatic Discharge Inspection FAQs – Draft Guidance – August 1, 2017) appear to be a separate OEPA internal guidance document unrelated to this enforcement instrument and were not extracted
Where it connects
oepa/lima/edoc-3170424.order.yaml · p.1 · oepa