Record · Permits
Maumee Watershed Nutrient TMDL — Lima loop total-phosphorus wasteload allocations
maumee-tp-wla-lima-loop
Fields
agency
Ohio Environmental Protection Agency
program
TMDL wasteload allocation + NPDES watershed general permit (total phosphorus)
permit_no
OHP000001 (general) / 2PE00000 (individual) / OH0026069 (application)
action
allocation assigned and made enforceable through a watershed general permit
action_date
2023-09-28
expiration_date
2028-10-31
applicant
City of Lima
facility
City of Lima WWTP, NPDES 2PE00000 / OH0026069
project_name
Maumee Watershed Nutrient TMDL — Lima loop total-phosphorus wasteload allocations
affected_resource
Ottawa River → Auglaize River → Maumee River → Lake Erie Western Basin
note
[verified] The Maumee Watershed Nutrient TMDL assigns the City of Lima WWTP a spring-season total-phosphorus wasteload allocation of 4.0 metric tons (4,000 kg), which OHP000001 Part IV.A.1 carries as the plant's enforceable Individual Load Limit, and — separately, in Table A4.3 — an allocation of 0.083 MT for its combined sewer overflows. ⚠️ [open] The two allocations do NOT have the same standing, and an earlier reading of this record said they did. The 4,000 kg figure is in the permit. The CSO figure is the TMDL's allocation only: no condition of OHP000001, and no condition of the plant's own NPDES permit, is held in this corpus that carries it. What instrument makes the 0.083 MT enforceable — and whether any does — is unestablished. Lima's is the third-largest allocation in the 39-facility grouped load, behind Toledo Bay View (27.9) and Lucas County WRRF (4.8); its CSO allocation is the second largest in the basin, behind only Toledo. On the TMDL's own record Lima WWTP exceeded 4.0 MT in one of five reported years (5.0 in 2018; 2.9 / 3.3 / 3.0 / 2.4 in the other four). [verified] Seven Allen County dischargers hold allocations under the same permit, and two of them were over in most or all reported years: American-Bath WWTP (370 kg) reported 590, 390, 620, 520 and 500 kg in 2017-2021 — above its limit in all five — and Elida WWTP (340 kg) reported 860, 890, 910, 990 and 390 kg, also above in all five. Shawnee II WWTP (750 kg) was above in three of five. [open] Whether any of that is a violation depends on the group, not the plant: OHP000001 Part IV.C.3 makes an individual exceedance a violation ONLY when the 39-facility cumulative load also exceeds its cap, and in the one season published (2024) the group reported 43,304 kg against a 64,170 kg limit — 20,866 kg under. [verified] A SECOND TMDL allocates phosphorus to FOUR of these facilities: the Ottawa River Watershed (Lima Area) near-field TMDL, approved by U.S. EPA 2014-04-15 for in-stream aquatic life use, gives Lima WWTP 5.33 kg/day, Shawnee II 2.31, Lima Refinery 1.58 and Cridersville 0.61, and names five dischargers with no far-field allocation, three of which this corpus did not hold under any permit number. It does NOT allocate to American-Bath or Elida — the two plants over their far-field allocation every reported year. See `nearfield_tmdl`. [open] That report itself is NOT in the corpus — only Appendix 5's summary of it. Ohio EPA publishes it; acquiring it is a named gap.
⚠ Gaps in the record
- Table A4.1 and Table A4.5 disagree, and A4.1 is the operative one. A4.5's second column is headed "WLA" but restates several allocations differently from the table that assigns them — Shawnee II reads 0.51 MT against A4.1's 0.75, and Elida reads 0.21 against A4.1's 0.34. The general permit settles it: OHP000001 Part IV.A.1 sets Shawnee II at 750 kg and Elida at 340 kg, matching A4.1. Cite A4.1 (or the permit) for an allocation and A4.5 only for the reported loads beside it. Reading a limit out of A4.5 would understate Shawnee II's by a third.
- Table A4.5's seven numeric columns are, in order, 2008 / WLA / 2017 / 2018 / 2019 / 2020 / 2021. The first column is a 2008 baseline load, not a reported year; reading the row left-to-right as a time series misreports both ends of it.
- The spring-season metric tons and the general permit's kilograms are the SAME allocation in two units, not two allocations. Lima WWTP's 4.0 MT and its 4,000 kg limit are one number.
- The CSO allocation in Table A4.3 is ADDITIONAL to the Table A4.1 allocation for the same permit, and A4.1 says so ("does not include the combined sewage overflows"). Lima WWTP carries both: 4.0 MT for the regular effluent and 0.083 MT for the overflows.
- The most recent per-facility spring load on this record is 2021. No post-2021 figure for any of these plants is asserted here; the annual Season Report required by OHP000001 Part IV.D is the record that would carry one, and none is in the corpus.
Where it connects
maumee-tmdl/maumee-tp-wla-lima-loop.epa.yaml · p.1 · maumee-tmdl