Record · Inspections & compliance reviews
City of Lima WWTP
edoc-591751
Fields
agency
Ohio EPA, Division of Surface Water
district
Northwest District Office
program
Pretreatment
inspection_type
Pretreatment Audit
type_code
Audit
facility
City of Lima WWTP
facility_address
1200 Fort Amanda Road, Lima, OH 45804
permit_no
2PE00000
npdes_id
OH0026069
county
Allen County
inspection_date
2017-02-28
report_date
2017-03-17
entry_time
—
exit_time
—
significant_noncompliance
—
units_in_service
—
summary
On February 28, 2017, Ohio EPA conducted a Pretreatment Audit of the City of Lima WWTP's approved pretreatment program, including file review and inspections of two industrial users (Ford Motor Company and Dana Holding Corporation). Both industrial users were found to be in compliance, and all industrial user inspections and sampling requirements are being carried out. The City's implementation of Lima's approved pretreatment program was found to remain satisfactory.
note
—
inspectors
- Peggy Christie
- Peggy B. Christie
facility_representatives
- David Schnipke, Environmental Compliance Manager
- James R. Bookman, Industrial Monitoring and Laboratory Chief
- Rob Flinn, Industrial Monitoring Technician
observations
- kind finding
- text Ford Motor Company (1155 Bible Road, Lima, Ohio) — Manufacturer of automotive engines. Non-categorical SIU. Average process flow 100,000–120,000 gpd. Industry visited during PCI. Compliance status: In compliance. Sanitary is discharged through a separate line.
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- kind finding
- text Dana Holding Corporation (777 Bible Road, Lima, OH 45801-2025) — Manufactures driveshafts for the automotive industry. Non-SIU. Average total flow 1,300 gpd. Industry visited during PCI. Compliance status: In compliance. This facility used to have a discharge permit with the City, but they now haul all the process wastewater off-site to Valicor for recycling. Currently they only discharge sanitary wastewater to the City. The City inspects this facility once a year and samples them twice a year.
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- kind finding
- text IU File Review — Section I, Part A: Dana is not under permit. They no longer discharge process wastewater to the City. All applicable IU control mechanism contents (duration, nontransferability, effluent limits, local limits, most stringent limit, TTO/TOMP, self-monitoring requirements, reporting, compliance schedules, slug notification, etc.) were evaluated as Y (satisfactory) for Ford Lima Engine Plant and N/A for Dana Driveshaft Manufacturing.
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- kind finding
- text IU File Review — Section I, Part B (CA Compliance Monitoring): Both facilities were inspected and sampled at required frequency. Documentation of inspection activities and slug discharge control plan evaluation confirmed. Sampling activities documented with chain-of-custody/QA/QC; analysis for all regulated parameters and appropriate analytical methods confirmed for both facilities.
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- kind finding
- text IU File Review — Section I, Part C (CA Enforcement Activities): Both facilities are in compliance. Older file reference in Dana's file of notification of SNC and publication in paper, but the facility is in compliance currently.
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- kind finding
- text Section II Interview — CA Pretreatment Program Modifications: No changes pending or completed since last inspection. No needed changes identified.
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- kind finding
- text Section II Interview — Legal Authority: There are contributing jurisdictions discharging wastewater to the POTW (Findlay Road area; drains to the City, metered and billed; all domestic wastewater). No difficulty in implementing legal authority.
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- kind finding
- text Section II Interview — IU Characterization: SIU classification has not changed. New IUs identified through developer contacts and waste characterization forms; changes in flow flagged through industrial monthly billing spreadsheet. Inspections and sampling also used.
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- text Section II Interview — Control Mechanism Evaluation: 0% of SIUs are not covered by an existing, unexpired permit or control mechanism. 0 control mechanisms were not issued within 180 days of expiration. No UST/CERCLA/RCRA corrective action sites discharge to POTW. Lima accepts trucked waste from Allen County WWTP biosolids, septage, EOLM C&DD Landfill, and Bluffton aeration (septage). Waste is not hazardous. Hauled wastes are sampled; pH of grease traps checked; MSDS reviewed.
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- kind finding
- text Section II Interview — Application of Pretreatment Standards: City keeps abreast of regulations via workshops, OTCO, Government Affairs, attorneys, Federal Register, professional journals, and WEF. No pollutants of concern identified beyond current local limits. No new limits since last inspection.
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- kind finding
- text Section II Interview — Compliance Monitoring (January 2016 to January 2017): 0% of SIUs were not sampled or not inspected at least once; 0% not sampled at least once; 0% not inspected at least once (all parameters); 0% in SNC with self-monitoring and not inspected or sampled. All IUs are inspected and sampled every year. Compliance sampling performed by City; analysis by Alloway (metals, cyanide, organics) and City (conventionals). City and Alloway participate in USEPA DMRQA program; City runs duplicates on every test. No problems in sample location, collection, or analysis. City has not had any issues with slug loads in the last 5 years; all SIUs evaluated for slug control plan need.
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- kind finding
- text Section II Interview — Enforcement: No interference, pass through, fires/explosions, corrosive structural damage, flow obstructions, excessive pollutant concentrations, heat problems, O&G interference, toxic fumes, illicit dumping, or worker health/safety concerns since last inspection. Note on excessive flow rates: City will request (batch) IUs to hold wastewater during storm events. No hazardous waste discharges to POTW. Compliance schedules are used and are appropriate. ERP has had no modifications since last inspection; no problems with implementation; ERP is effective.
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- kind finding
- text Section II Interview — Data Management/Public Participation: Confidentiality requests handled on a case-by-case basis with legal involvement if necessary. Files treated as public records; no requests for confidential status from IUs. Data management includes individual files, spreadsheet of all IUs, and Access database (flow data through billing). No records have been purged.
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⚠ Gaps in the record
- TWIN CAPTURE — not the canonical reading. The portal serves this 2017-02-28 pretreatment audit at two docids; edoc-1851472 is the same letter and is canonical for FIDELITY (a scan is read by the vision path alone, with nothing to check itself against). Declared in data/site/document-versions.yaml as a `v2` cluster — the two files are NOT byte-identical. The canonical records more (26 vs 13) and governs.
- Document is a page-image scan with no embedded text layer; all data extracted by OCR interpretation of scanned images.
- The Pretreatment Inspection Report form does not have a 'Sig. Non-Compliance' checkbox filled in; significant_noncompliance left null.
- report_date taken from the transmitting letter date (March 17, 2017); the inspection report itself was signed by inspector on March 9, 2017 and by reviewer on March 16, 2017.
- Inspectors list deduped to Peggy B. Christie (Peggy Christie) — same person listed under two slightly different name forms.
- Facility number OH0026069 recorded as npdes_id as it appears to be the Ohio EPA facility/NPDES number on the inspection form.
Where it connects
oepa/lima/edoc-591751.inspection.yaml · p.1 · oepa