Docstoc

708 pages of EPA documents

Document Sample
708 pages of EPA documents Powered By Docstoc
					Issuance Date: Effective Date:

_ _

BEFORE THE OHIO ENVIRONMENTAL PROTECTION AGENCY In the Maller of:

IRG Rubber City, LLC 3623 Brecksville Road Richfield, Ohio 44286 Applicant And Goodyear Tire and Rubber Company 1144 East Market Street Akron, Ohio 44316 Property Owner Respondents

Director's Final Findings and Orders

I. JURISDICTION
These Director's Final Findings and Orders (Orders) are issued to IRG Rubber City, LLC (IRG) and the Goodyear Tire and Rubber Company (Goodyear) and collectively known as Respondents pursuant to the authority vested in the Director of the Ohio Environmental Protection Agency (Ohio EPA) under Ohio Revised Code (ORC) Sections 3734.02(G) and Ohio Administrative Code (OAC) Rule 3745-27-03(B). II. PARTIES BOUND These Orders shall apply to and be binding upon Respondents and their successors in interest liable under Ohio law. No change in ownership of the "Alpha" and "Bela" areas of Summit County Auditor Parcel No. 6756639 [or portions of replalted Blocks 6 and 7J, as hereinafter described, will in any way alter Respondents' responsibilities under these Orders.

000001

Director's Final Findings and Orders IRG Rubber City, LLC Exemption Request Page 2

m. DEFiNITiONS

Unless otherwise stated, all terms used in these Orders shall have the same meaning as defined in ORC Chapter 3734 and the rules promulgated thereunder. IV. FINDINGS OF FACT The Director of Ohio EPA has determined the following findings: 1. ORC Section 3734.02(H) states that "No person shall engage in filling, grading, excavating, building, drilling, or mining on land where a hazardous waste facility, or solid waste facility, was operated without prior authorization from the director [of environmental protection], who shall establish the procedure for granting such authorization by rules adopted in accordance with Chapter 119 of the Revised Code." OAC Rule 3745-27-13(A) states that "No person shall, without authorization from the director, engage in filling, grading, excavating, building, drilling, or mining on land where a hazardous waste facility or solid waste facility was operated. Any person proposing to engage in these activities on land where a hazardous waste facility or solid waste facility was operated shall comply with the requirements of this rule." Respondents IRG and Goodyear are "persons" as that term is defined in aRC Section 3734.01 (G) and in OAC Rule 3745-27-01 (P)(3). Respondent IRG is considering the purchase of several properties currently owned by Respondent Goodyear including several parcels of property adjacent to the former city of Akron Settlement Street Landfill, a closed municipal solid waste disposal landfill located along Kelly Avenue at Tech Way in Akron, Summit County, Ohio. The parcel was formerly identified as Summit County Auditor Parcel No. 6756639 containing 156.6 acres. Respondent Goodyear recently replatted the area, and the parcels located in this general area are now identified as Blocks 6,7,8, and

2.

3.

4.

9.
5. On January 17, 2008, Hull and Associates, Inc. (Hull) submitted to Ohio EPA on behalf of Respondent IRG a request pursuant to OAC Rule 3745-27-13(D)(2) to perform a subsurface investigation on two approximately 9.8-acre areas identified as "Alpha" and "Beta" which together comprise an approximately 19.6-acre portion of the original 156.6-acre Goodyear parcel identified in Finding NO.4. A delineation of the "Alpha" and "Beta" areas is attached as Exhibit 1 to these Orders. A map showing replatted Blocks 6, 7,8 and 9 is attached as Exhibit 2. The original January 17,2008 request is titled "OAC 3745-27-13(0)(2) Authorization Requestto Conduct

000002

Director's Final Findings and Orders IRG Rubber City, LLC Exemption Request Page 3
Geotechnical Exploration Adjacent to the Former Settlement Street Landfill, City of Akron, Summit County." Revisions to the original request, dated February 8,2008, were received by Ohio EPA on February 11,2008, and February 12, 2008.

6.

On February 13, 2008, Ohio EPA issued a concurrence with Respondent IRG's request to conduct the subsurface investigation specified by the January 17, 2008 request, as revised through February 8,2008, pursuant to OAC Rule 3745-27-13. The February 13, 2008 letter reminded Respondent IRG of their certification report obligations pursuant to OAG 3745-27-13(H)(10), "including, but not limited to... deed notation and plat map showing revised waste limits." OAG Rule 3745-27-13(H)(10) requires that the owner or operator "shall provide a certification report within sixty days of completion of the filling, grading, excavating, building, drilling, or mining activities. OAG Rule 3745-27-13(H)(1 0) further states, "This [certification] report shall contain the following: (a) A verification to Ohio EPA that the following activities have been completed: (i) The owner or operator has filed with the board of health having jurisdiction and with Ohio EPA, a plat or revised existing plat for the unit(s) of the solid waste facility or hazardous waste facility and information describing the acreage, exact location, depth, volume, and nature of the waste deposited in the unit(s) ofthe solid waste facility or hazardous waste facility that was impacted by the filling, grading, excavating, building, drilling, or mining activities; If waste still remains on the property, the owner shall update any prior recorded notation on the deed to the property, in accordance with state law, to notify any potential purchaser of the property that the land has been used as a hazardous waste facility or solid waste facility and that its use is restricted. The notation shall describe the acreage impacted by the filling, grading, excavating, building, drilling, or mining activities; and the exact location, depth, volume, and nature of waste disposed of at the site.

7.

8.

(ii)

9.

On April 24, 2008, Hull submitted to Ohio EPA on behalf of Respondents a certification report pursuant to OAG Rule 3745-27-13(H)(10) documenting work completed pursuant to the February 13, 2008 authorization. Hull contends in the April 24, 2008 report that based upon information provided, OAC Rule 3745-27-13

000003

Director's Final Findings and Orders IRG Rubber City, LLC Exemption Request Page 5

16.

The Director further finds that the exemption granted herein in no way releases Respondents from their responsibilities under ORC Chapter 3734 and OAC Chapter 3745-27 as an owner or operator of a property containing hazardous and/or solid waste. V. ORDERS 1. Pursuant to ORC Section 3734.02(G) and OAC Rule 3745-27-03(B), Respondents IRG and Goodyear are hereby exempted from the requirements of OAC Rules 3745-27-13(H)(10)(a)(i) and (ii) to file a plat revision and a deed notation and to provide verification of such filing as part of the certification report associated with the February 13, 2008 authorization for the subsurface investigation ofthe "Alpha" area. Ohio EPA agrees that Respondents have found no evidence of waste disposal on the "Beta" area. The exemption granted herein for the "Alpha" area applies solely to Respondents Goodyear and IRG and is not transferable to future owners of the property or for future certification reports required at this property or any other property. 2. Respondents IRG and Goodyear are not exempted from any other obligations under OAC 3745-27-13 at the "Alpha" and "Beta" areas described herein. Respondents IRG and Goodyear are further advised that in the event that any solid or hazardous waste is encountered during any future activities at the "Alpha" or "Beta" areas, all filling, grading, excavating, building, drilling, or mining shall immediately cease and appropriate authorization shall be obtained pursuant to OAC 3745-27-13 prior to recommencing these activities. VI. OTHER CLAIMS

Nothing in these Orders shall constitute or be construed as a release from any claim, cause of action, or demand in law or equity against any person, firm, partnership, or corporation, not a party to these Orders, for any liability arising from, or related to, Respondents and/or related to the "Alpha" and "Beta" areas as described herein. VII. OTHER APPLICABLE LAWS All actions required to be taken pursuant to these Orders shall be undertaken in accordance with the requirements of all applicable local, state, and federal laws and regulations. These Orders do not waive or compromise the applicability and enforcement of any other statutes or regulations applicable to Respondents and/or the described "Alpha" and "Beta" areas.

000004

Director's Final Findings and Orders IRG Rubber City, LLC Exemption Request Page 6

VIII. NOTICE All documents required to be submitted by Respondents pursuant to these Orders shall be addressed to: Ohio Environmental Protection Agency Northeast District Office Division of Solid and Infectious Waste Management 2110 East Aurora Road Twinsburg, Ohio 44087-1969 Attn: Supervisor, DSIWM or to such persons and addresses as may hereafter be otherwise specified in writing by Ohio EPA. IX. RESERVATION OF RIGHTS Nothing contained herein shall be construed to prevent Ohio EPA from seeking legal or equitable relief to enforce the terms of these Orders or from taking other administrative, legal, or equitable action as deemed appropriate and necessary for noncompliance with these Orders. Nothing contained herein shall be construed to prevent Ohio EPA from exercising its lawful authority to require Respondents to perform additional activities pursuant to ORC Chapter 3734 or any other applicable law in the future. Nothing herein shall restrict the right of Respondents to raise any administrative, legal, or equitable claim or defense with respect to such further actions which Ohio EPA may seek to require of Respondents. Nothing in these Orders shall be construed to limit the authority of Ohio EPA to seek relief for violations which may occur with respect to the "Alpha" or "Beta" areas as described in these Orders.

IT IS SO ORDERED: Ohio Environmental Protection Agency

Chris Korleski, Director

000005

State of Ohio Environmental Protection Agency
STREET ADDRESS: MAILING ADDRESS
TELE: (614) 644-3020 FAX: (614) 644-3184 www.spa.state.oh.us

Lazarus Government Center 50 W. Town St., Suite 700 Columbus, Ohio 43215

P.O. Box 1049 Columbus,OH 43216-1049

February 24, 2009

Re:

Summit County Application No. 702477 ws Akron City PWS - OH7700011 (PWS ID) Detail Plans for Sum - Martha Ave Waterline Extension: Proposed Waterline Extensions about 250 feet of 12-inch pipe in Martha Avenue extending East from Executive Drive and about 150 feet of 12-inch pipe in Martha Avenue extending North from Executive Drive and about 1, 300 feet of 12-inch pipe in Executive Drive extending east from Martha Drive and about 350 feet of 8-inch pipe in an utility easement extending East from Martha Avenue Plans Received February 6, 2009 From City of Akron

Mayor & Council City of Akron 166 South High Street Akron, Ohio 44308 Ladies and Gentlemen: The Ohio Environmental Protection Agency has reviewed the enclosed plans submitted pursuant to Ohio Revised Code Sections 6109.07 et. seq., or accepted the certification of plan review by an authorized professional engineer pursuant to a contract therefore. These plans are approved SUbject to the condition of compliance with all applicable laws, rules, regulations, and standards. The applicant is responsible for obtaining all other necessary approvals, waivers or releases required by state, federal or local law prior to implementing this plan. Further, all construction must be supervised by a registered engineer, if required by law, or expert qualified in such work. This approval shall become void five years from the date of this letter unless the facilities are constructed as proposed by that date. By accepting this approval, the applicant acknowledges that this deadline shall not be considered or construed as extending or having any effect whatsoever on any compliance schedule or deadline set forth in any administrative or court order issued to or binding upon the applicant, and the applicant shall abide by such compliance schedules or deadlines to avoid the initiation of additional legai action by the Ohio Environmental Protection Agency. The Division of Drinking and Ground Waters in the Northeast District Office of the Ohio Environmental Protection Agency shall be notified, in writing, as to a) the construction start date; b) the construction completion date; and c) the date the facilities were placed into operation. This approval shall apply only to those water supply facilities shown on the plans cited above. Any waste handling facilities shown on these plans must have a separate waste handling approval. Lead solder and flux that exceeds 0.2 percent lead content and any pipe or pipe fitting that exceeds an 8 percent lead content shall not be used in the installation of the proposed facilities.
Ted Strickland, Governor Lee Fisher, Lieutenant Governor Chris Korleski, Director

@

Printed on Recycled Paper

Ohio EPA is an Equal Opporlunity Employer

Printed in-r.ouse

000006

City of Akron February 24, 2009 Page 2

The owner shall provide for the proper maintenance and operation of the water supply and distribution system, Necessary measures shali be taken to ensure that there wili be no cross connections between the public water supply and any private water supply, The local health department shali be notified of any private water wells which will no longer be used as sources of potable water and which should be abandoned. The supplier of water shall ensure that no customer at anyone, two or three family dwelling installs a booster pump that is supplied from any pipe connected to the public water supply system unless an air gap separation is provided in accordance with Ohio Administrative Code Rule 3745-95-07(A). The owner shall contactthe appropriate district of the U.S. Army Corps of Engineers regarding each stream or wetland crossing proposed as part of this project. If a 404 permit is determined to be necessary by the Corps of Engineers, the owner shali acquire a Section 404 Permit and 401 Water Quality Certification, before impacting any waters of the state as a part of this project. Any weli, well point, pit, or other device instalied for the purpose of lowering the ground water level to facilitate construction of this project shali be properly abandoned in accordance with the provisions of Rule 3745-9-10 of the Ohio Administrative Code or in accordance with the provisions of this plan or as directed by the director of the Ohio Environmental Protection Agency or his representative. In addition, a well sealing report shali be filed with the Ohio Department of Natural Resources, Division of Water, within 30 days of completion, in accordance with Section 1521.01 of the Ohio Revised Code. Any person instaliing any weli, weli point, pit, or other device used for the purpose of removing ground water from an aquifer shall complete and file a Well Log and Driliing Report form with the Ohio Department of Natural Resources, Division of Water, within 30 days of the weli completion in accordance with the Ohio Revised Code, Section 1521.01 and 1521.05. In addition, any such facility that has a capacity to withdraw waters of the state in an amount greater than 100,000 gallons per day from all sources shali be registered by the owner with the Chief of the Division of Water, Ohio Department of Natural Resources, within three months after the facility is completed in accordance with Section 1521.16 of the Ohio Revised Code. For copies of the necessary well log, drilling report, or registration forms, please contact: Division of Water Ohio Department of Natural Resources Fountain Square Columbus, OH 43224-1387 (614) 265-6717 Air Pollution Control Requirements: Fugitive dust generated by this water line project shall be controlied as specified in OAC 3745-17-08(6). A National Poliutant Discharge Elimination System (NPDES) permit wili be required if the construction project results in a disturbance greater than or equal to one acre. As a requirement of the permit, a Storm Water Poliution Prevention Plan (SWPPP) must be developed before submitting the Notice of Intent (NOI) for coverage under the permit. The NOI must be submitted 45 days prior to beginning construction. To obtain the application form and relevant information, please contact Ohio EPA's stormwater coordinator at (330) 963-1200. The proposed facility may be constructed only in accordance with plans approved by the director of the Ohio Environmental Protection Agency. There may be no deviation from the approved plans without the express, written approval of the agency. Any deviation from the approved plans or the above conditions may lead to sanctions and penalties provided under Ohio law.

000007

City of Akron February 24, 2009 Page 3

Approval of these plans does not constitute an assurance that the proposed facilities will operate in compliance with all Ohio laws and regulations. Additional facilities shall be installed upon orders of the Ohio Environmental Protection Agency if the proposed facilities prove to be inadequate or cannot meet applicable standards. Should there be any questions regarding the requirements, meaning, or interpretation of any of the above which we may clarify, please contact the Division of Drinking and Ground Waters, Northeast District Office, Ohio Environmental Protection Agency. You are hereby notified that this action of the Director is final and may be appealed to the Environmental Review Appeals Commission pursuant to Section 3745.04 of the Ohio Revised Code. The appeal must be in writing and set forth the action complained of and the grounds upon which the appeal is based. The appeal must be filed with the Commission within thirty (30) days after notice of the Director's action. The appeal must be accompanied by a filing fee of $70.00 which the Commission, in its discretion, may reduce if by affidavit you demonstrate that payment of the full amount of the fee would cause extreme hardship. Notice of the filing of the appeal shall be filed with the Director within three (3) days of filing with the Commission. Ohio EPA requests that a copy of the appeal be served upon the Ohio Attothey General's Office, Environmental Enforcement Section. An appeal may be filed with the Environmental Review Appeals Commission at the following address: Environmental Review Appeals Commission 309 South Fourth Street, Room 222 Columbus, OH 43215 Sincerely,

~~
Director CKifs cc: Central Office, DDAGW NEDO, DDAGW Manager Public Utilities Bureau Summit County Board of Health City of Akron Health Department City of Akron Bureau of Engineering

000008

' ••.. c . . . . .: : ..•.

.UNITED STATES ENVIRONMENTAL PROTECTlOIIIAGENCY REGION 5 77 WESt JACKSON BOULEVARD "CHICAGO, IL 60604-3590

'JUl"032008
--.'

." REPLY TO THE ATTENTION OF:

WC-ISJ

CERTIFIED

MAIL

'1001 O~20 Oim6 1454 0625

RETURN RECEIPT REQUESTED
The Honorllble Donala L.l'lusquellic Mayor of Akron Suite 200 Municipal Building 166 S. High Street Akron, Ohio 44308
, . . C •

Subject: City of Ak:t0liFirstA1l1el1dedRequest for IrrfoririaUOl1PutsUllllt to Section 308 of the Clean Water Act (33 U.S.c. 1318) DocketNo.: V-W·08-308~7 Dear Mayor PlusqueUic: I have encI6~e'dthe above-referenced First Ameftded Request rdrIIlformation issued to the City of Akron ("the CitY") putsUllllt to Section308(a) Of the Clean Water Act ("the Act"). TlJis FirsfAmeIided Request wasprepli1"ed fu large part afthe City's request to limit the scope ofthe samplfug requirements fu the Request iSS1ied to Akron on March 12,2008 (March 12th Request). After several months ofnegotiatioI4 the US." Environmental Protection AgeIicyand Akron agreed upon the samplfug points contained in the eIlclosed First Amended RequeSt. In addition, we have modified Sections B and C torefieet the limited information the City provided in response to those sections fu the March 12th request Therefore, for thel1lost part, the City has had knowledge ofthe contentof this requ~stfor at least thieemonths. AccordiIlgly, we expect the City to comply immediately with the requirements of the First Amended Request. Also, please beawarethafthe issuance of Uris lettenmdptovidfug the requested infonnation does notrelieve the City of fui)rresponsibi1ity under the .li..ct for . seeking .and maintai11ing- an:gpplicable Nati.onal Pollutant Discharge Elimination System Pen-nit.

000009

We appreciate yoUr coojJ~ration and prompt attentiontothis matter. Please contact Tom Bramscher at (312) 886·6753 or Jenny Davison at (312) 886-0184 within 48 hours ofreceipt of this First Atnended Request to infoinrhin:iofthe City's intent to comply with this request and to discuss any questions you may have related to the request.

~i~
Acting Director, Water DivisiOn Enclosure

000010

•

UNITED STAT~~ENVmONMENTAL PROTF;Cl'lOl'hGENCY REGIONS

IN THE MATTER. OF:
THE CITY OF AKItON,OH10

)
)

) ) ) )

AMENDED REQuEST PURSUANT TO SECTION 308 OF THE CLEAN WATER ACT 33 U:S.C:SECTIONt318 (a) DOCKF.T NO. V-W-Ol!"308-07

.

.

The U.S. EUvirotlfuental Protection Agency isiafuendingits March 12.,2008 Reqnest fotlnforrtuition pursuant to Section. 308 ofthfi Clean WaterAct (First Amended Request). This First.An1ended Request supersedes th~Reql1est issued to the City of Akron on March 12~2008.The FirstAtrtended Request is issued pursuant to the Authority vested in the Administrator ofthe EPA by Section 308 (a) ofthe Clean Water Act (eWA), 33 U.S.C § 1318 (a), and dilly re-delegated to the undersigned Acting Director of the EPARegio~5 W'ate~ Division, and requires the City of.Akron to sample discharges relating to its combined sewer overflows; establish and maintain records; and provide infornlation in accordanCe with the attached document. Access to records· and infolinauon described hercin must be pro....1ded notwithstanding the possibility that the records contain information that may be
charactcnze.1 as confidential informatiofior trade secrets~ Should you so request~

however, ai1.Y information (other than public information) which the Adm:inistrator of this Agency detennines to constitute methods, processes, or other business infonnation entitled to trade sectetg;viH 0'> secret. Request for et::.mfi.d.ential freahncl1t ffillst 'be made vilhen irtfortnation 01 access to records is
inic'flT!ation!lot su identified wiH not

accorded this protection by

the Agency,

in an 8,(1rninisttalhi e,¢}vi!, (if trirninal actioTI. signii1cant civil and cnrr.inal penai,ties pursuant to'Section 309 filiiingto res'po>J1d to'requests issued pursuant to ::>e(;uon Ca) in a ,,"'''Iv complete and accurate illftt'jj.er.

/\tA~'~~jJ t~l.ft~-~-#
li~ka f1.Hyde \ ~ p",ctnrg Director~ ¥Tater~Di"o;Jision

",1\

n

/~,

'

j

.->

Region 5

,

000011

DEFINITIONS Unless otherwise defilled herem, fenrts used in these requests shlll1 have the meaning given to those terms in the Clean Water Act, 33 U.S. C. § 1251 et seq.,.and the regulations promulgated thereunder at 40 C.F. R. § 122.
. .

The term "Akron" shall mean theCity of Akron and any agents, employees or contractors or other entities that perfomied work tir acted in any way on behalfofor at the direction of the City of Akron. The term "CombinedSewtir o,ierflow;' or "CSQ" shall mean arty discharge from any outfull identified in Akron's CuttentPetmit, as set forth in Attachment 1. The term "Combim\d8ewer Overflow Olltfall" or "CSO Outfall" slulllltlean the specific point source at a pll.tticularlocationfrom which a eso occurs. The term "Combined Sewer Systefu"shall mean the portion of' Akron's Sewer System designed to convey municipal sewage (domestic, commercial, and industrial wastewaters) and stonnwaterrunoffthroUgh a singlc--pipe system to Akron's Wastewater Treatment Plant or to a combined sewer overflow structure. The term "Infiltratlon;'slla.1lll1el1tl the water entering a sewer system aIld service connections fromtheground'tht0ughmeans inc1uditig, bUt not limited to, defective pipes and sewer walls, pipe and sewer joints, connections, and manhole wans. The terrn "Inflow"shallmean the water dischatged il1toa sewer system, including service
cOEnections,from sources mcluding, hut not limited to, toofleaders,:'ceUars, yard and

area drains, foundation drains, cOoling water discharges, drains from springs and swampy
areas manhole covcrs~ cross con..nections from stonn sewers and combined sewers)' catch
j

The tenn "lflfiltrationffr,fl,Yw"
'T'"i ri l

~ ".. ,.. 1 ....",t: t"rm---- ~L . .,.." - __ -'l~~ or' ~tfi.i~'",r,rd;;;,,,,,k<:il11_,......v, ~'nv"'.3 ""'i".rl';""'g hf 1ftf:oftCna'{l·;c't~ ,~, 1" _e ...>..... T""""llfU ,,,tY..,,J ,":> ~-u;;;;.I rnA'JIll ~ J !.,,=,Cv-,,~i! V-,,- ......-,-,', u l l ,,0g..,n ~.angH)Ie 10rm,

It include3~ but is

ihiLhed

Dotun10;;HLs,

teports~Ietters~mapBy

graphs,

charts, log books, notes, computer printouts and computer data bases.
The ie.Lui "Sanitar! Se\ver System" shaH mean an anortions 6f Akron's SC"ifJeY Svstcm that _ . •

are not part offtJrrcn' s Combined Sc-v.rer System.

The term "Sewer System"or "System" shaH mean the wastewater coliection and
transfliissiolIsj-s1,em cn,vned {,if'Dperated by ..A,JcrOn: designedto coUectah.d convey

ml1uicipa1 se-~vage (domestic, COIJ:h"'TIC1\jial and'ind-nstrial) to Akron's Waste\vater Treaill16u~t Plfu"1t or to a CO!l1bi~ed5ewer Dvcil1o""Nsuucture. HSBv/erSysteln~; includes both the ~4Combined Sewer Systern" and tlu;HSahitar:-Y Se\>:,xer Systew..
j

H

2
000012

The term ''You'' or ''YoUt'' sl1all mean the City of Akron. REQUESTS
A. CSO Slurtpling and Reporting Requirements for the City of Akron
1. Overview.Ambng other things, this Information Request requires that the City of

Akron sample certain CSO discharge points to the (;uyahoga River, tributaries of the Cuyahoga River,the Little Cuyahoga River and the Ohio Canal during overflow events. An "ovefflowevent" is defined as a day in which the specific eso discharge point overflowscontinnously for one or more hours, and would include a subsequent day, ifthe overfl()wiscontinuous. All grab sampleStakenpurSliant to Section A ofthfs request will be analyzed for fecal coliform and e-c6!i in accordance with 4{) C.F.R Part 136. 2. Between Julyl,2008artd October 31, 2008, AkronshaHcollectat least two grab samples from each of the CSO outfalls identified in Attachment L In the event Akron is unable to collect at least two samples from the CSO outfalls identified in Attachment I by Oct~ber 31,2008, Akron shall resume samplingoriMay I, 2009 and continue through October 31, 2009 until each CSOspecified in Attachment 1 has been sampled at least tWo times.
3. J..kron shall perf'orlnsampling and analyses to detennm:theconcentrations of fecal coliform arid e-coli (per 100 milliliters) in thereceivingstreams upstream and downstream of the specific eso outfalls being sampled, at the points listed in Attachment 2. The upstream samples shaH be taken within the first hour 2 hours of any eso discharge. The dmvl1streml1 Slh"'llples shaH be taken within the first 2 to 3 hour of any CSO dischargef(afa time-\vhen flovl from theCSOdischarge 'would be expected to have reached ,he downstream s!LJnpling location).

4. .A.kronshal1 irinl1eiliately sub:rt'..i~ to EP i\ a proposed methodology for detennimng the concentrations of polJutants it discharges in the combined sewer ontfaIls listed r;; the i\ttachment iand theinstream poin.1z listed in:;;~l>ttacfullem AlTon's submission
shaH indude britnot be limited to: (1 )a description ofthe sampling methodologv (including the number of people - to perionilthe-sa1np~iti~theequipmeIrt· needed to perfonn the -samplL"ig~'wn:ethersampling\villoccurby autoll.atic rneans 01'
j

':'IV..

kAUJr.~ltf611<:'''-:<.j--:;HnM~:t,"';r'''111- "''- h.c> ~<""r_6,~"",,,,,,.-i .•c,,'h,;"" ...... ......" ..."".u) _w iii. !' .. ~_fU"''''' ..... ~ ) "'v "'-"...""...."'.... v;,,~ 1'o/.1_....;u.

.,.",;"\, W,11

't.. ..

t}y

conducted
.~,~j

under
and preservative

samplingwili
\'-'lin heused~ etc.).

initiated/triggered; and
.1..... 1.......

{,..y~ a. 1..01."",.:;> JiJ." l,... V~L ·V.i. ·.... h., ............ " _.... "" .~"\P~'c~·,,;'+ir;:...., :i-c-f'fFf~'~nai\r~1·-;,,>al" ...", _"'-"-...........,n.v=.Y {nt'06;;;;"M, 11""4='tht;,;;{r,,t·~ ...... "'-"i.:' ,"'VA """"""".u,

r.. "'><]1':';=+=-"
:::H;i.t",~ __

\.\

f~-!-lc.',,,.A~=_._ ",;"'= __ ",,~!,.n..!!!!~~ .. H'-",

type

sampling tha; ~e ;ro.n~ling~::~le:j.,. The,r~pOtt~ shaH ~¥eciff Cabh outfall. that was sarnpled a.UG t.ne locatloflS '\vlthin the reCe1Vlng stream v.rherD date

.3
000013

of each sample (bothcSO ahd instream), and the concentrations per 100 milliliters of fecal coliform and e-coli determined to be present in each sample (bOth CSO and instream).

B. Illformati6l1 Request Pertaining to Unpernrltted Discharge Points
6. IdentifY (by name, rivet or strell1'n mile location, or arty othernieans of specifically identifying) ahddescribe in detail the locations of aU diScbatges into waters of the United States whichhave occurred since July1,2003, from any portion of Akron's sewer collection sYstem (other than CSO locations identified in the Attachment I). To the extent this information existsm docutnentsotherthan in the monthly operati11g r(jj:lorts submitted to the State ofOhio, provide those documents in response to this request. If you believe. you have previously provided this documentation,·identify the date, author,stibject matter/title of the document and the page number On whiCh the information appears. In addition,if you believe the information has been provided verbally in the past, provide the information in writing . in response to this requ.est. 7. For each 10cati?I1ideritifietlin response to Paragraph 6, indicate on a discharge location by discharge1ocation basis, each date since J~ly 1, 2003, that pollutants were discharged from the particularlocation, the duration and the "olume of the discharge, and the reason for the discharge. If you do not have the measured duration and volume i;jf the discharge, provide the estimated duration and volUll1eof the discharge and provide a detailed explanation of the basis for your estimation. To the extent this information exists indocuments other thall in the monthly operating reports submitted to the State of Ohio, provide those documents in response to this request. If you believe you have preViriuslyprovided this dOC1Ul1el1tatioll~ identify t.~tYdate, author~
the page number on v,rhich t~e information appears. ~]~ addit~,61~ if y~ub~lieve. :he ~fonnati~:nhas ~een provided verbally in the past, prcnrule the rntorrnatlon In "''TIting ~.n respcmsc to thlS request
su~ect matietltjtleof tJ;e dOClL~ent'and

8. For response to 6 id.entify and describe in detail an rneasures\vhich'have'beeh tak,en, ,;r"hich \vere COl1sidered but 1101. ta..l(e!1~ or ftJefoll plarIs to 'ta~e to eliminate the discharge of POllUtfuitS at that lccation~ . To the extent this Ih.forrrta:non in doctunents' other than iti monthlv oneratin v repo!*,s submitted to 4~e State cfOhio,pTQv1de those'df'JC11111.ents in re-Bpol1S~ to' this - ,~' }"'ii,,",,',, you have this docUiinent2lti':'11, ""'OJ"" date, authof,5UbjecttnafterftltIe of the d()'clli"nent the page number 011 ~vllichthe infcr'iTIutic:n appears. In addition, if yon beiie"v~e the--inforrnation has heell provided
1

and

the
~.

provide fueinfcrtnaticTI +n V"TIth1g hi
~n
•

to
g
L -".

Fer

cQmpl~tedJ idelitifyatld destribe in detail (a) the date the measure l;-,,'as cumnlated.> (b) " '" the Pllip05C oftne rneasur6, (c}what the tn.eastH'e achieved~ "c.ih'f'VC" it$ (e)' 1fthe IT"',O"",""

000014

not achieve its purpose. to the extent this infonnation existsmdoeuments other than in the monthly operatirig repomsuhmitted to the State of Ohio, proVide those documents in ~esponse to this request. If you believe you hllvepreviollsIy provided this documentation, identify the date, author, subject matter/title of the document and the page number on ",hich fheinforrnation appears. In addition, if you believe the infonnation has been proVided verbally in the past, provide the information in writing in response to this request. 10. For each meaSure identified mtesponse to Paragraph 8whic!lyOll plan to take to eliminate the discharge ofpollutants,provide (a) a detailed schedule of the steps which will be taken to complete thenieasure, (b) the date the measure will be completed, (c) the eStimated costs of the measure, (d) the steps that hllve been taken to secure funding topayforthemeasure,(e) any steps thatwill betaken to secure funding for the measure, (f) any costs that have already been incurred on the measure, (g) the dates that those steps wilIbe taken, (h) the purposeofthel1leasure and (i) how, if at all, proVisions for these steps have been or are intended to be included in any Capital IlDprovements Plan. you have not taken and do fibt plan to take steps to eliminate or control the discharge ofpollutants from any ~ecific location, explain why you do notintend to do S<l' To t~e extentthis infortnation llxists in documents other than in the monthly operating reports submitted to the State of Ohio, provide those documents ~ tesponse to this request. If you believe you hllvepreViously provided this doc entation, identify the date, author, subject .matter/title of the Ul11 document and the page number on which the information appears.. Irtaddition, if you believe the information has been provided verbally in the past, provide the infonnation in Writing in response to this request.

If

11. Identify anddescribe in detail the locations of all releasesof pOllutants from Akron's sewer col1ectionsysfern other than those locations identified in the Attachment or in response to Paragraph 6 which have occUlted since July I, 2003. Your description should inclUde, bnt not be limited to, a description of releases from manholes, drains fi:dures and collections system failutes. To the extent this information exists in dOCUlDents other than in the monthly operating reports submitted to the State of Ohio, proVide those documents in response to this request. If you believe you have previously pro'vided this documentation, 'id.entify the date, author~

subject matter/title of the docmnent a..YJ.d the page nUmber on 'which the infonnation
appears. In addition,> if you believe the irrforn1ati6nhas been provided verbaUy in the past, provide the information in 'Writing in response to this;request. 12. For each locatlo1fidtntifiedjnre'sponse to Paragraph11, state ort a location by IDcation basis, each date since July 1~2003, thatpDl1utants were released from the particular Iocation~ the'dffi:Ation' an.d the 'voiuJ:n.eoftheteleMe~ a.."1d the reason for the .release. If you d.o not have the lneastited. dunitiQn and v61urru:, of the rele-ase, provide the ... . .. . ... . .dutation and volume ofth~te1ease,~nd pr?vide a detailed eXplfLl10.tion

of the basis for Y01U"0stirllatioTI.To the extent t..1Us info.nnationexists in documents tJ:w,n mo:ntbJy to the State of Ohio, provide those -docurnents intestmmse to this req'u.est. If you believe yonhavepreviotlsly

5
000015

provided this documentatIon,id.entify the date, author, subject matter/title ofthe document and the page numberonwmch the information appears. In addition, if you believe the information has been provided verbally in the past, provide the information in Writing in response to this request. 13. For each releaseiden.tified in response to Paragraph 11, state whether the pollutants thatwere rehiased were discharged into a navigable water of the United States, and the basis for Ybur respon.se as towhy you m.aintainthat the pollutimts were or were not discharged into a navigable water of the United States. To the cxtent this infonnation existSin documents other than in the monthly operating reports submitted to the State ofOmo, provide thoscd.ocuments in response totmsrequest If you believe you have preViouslyproVided this documentation,id~ntify the date, author, subject matter/title ofthe document and the page number on wmch the i1l.formation appears. In addition, if you believe the i1l.formation has been provided verbally in the past, provide the information in writing in response to this request. 14. Identify all docUtl1cntSin youtposscSsion pertaining to Akron.'s operation and maintenance ofitssllparate sanitary sewersystem since July I, 2003. Your response should include, butnot be liniited to, summary reports ofoperation and maintenance activities and documents pertaining to Specific, individUll:l operation and maintenance activities. To the extent this informati6n exists in documents other than in the monthly operating repditS submitted to the State ofOmo,providethose documents in response tothis request. If you believe you have previously provided this documentation, identify the date, author, subject matter/title of the document and the page number on Which the information appears. In additioJ:l, if you believe the information has been provided verbally in the past, provide the in.formation in writing in response to this request..As a first step in responding t? this request, the City may provide year end summaries of the requested data as compiled by the City's Access andiorDataStream 7i databases. 15. Identify all docl.lInelits inyoUr possession generated since.l'uI)t1,2003, pertaining to infiltration and inflow ("Ill") in Akron's separate sanitary sewer system. Your response shouldinclude, but not 1>e liniited to, docun'lents pertai:l1irtgto field surveys for identifying sources ofIll, and efforts to eliminate excessive III (including elimination ofillegal stonnwatet connections). To the extent this information exists in documents other than in the monthly operating reports submitted to the State of Ohio, provide those documents in response to thistequest tf you believeyou have previously provided this documentation, identify the date, author, subject matter/title of the documentffi1d the page uumberon ",hich thein.fotination appears. In addition, if you believe the informationtias been provided yei'bally in the past, provide the inforn'latlon in Writing in response totms request. .
<

.'"

'c"

-.:

16. Akronsl1l1Hptovide to EPAWithin 60 days Ofr~ceiptof this request the inforn'lation identified above under Paragraphs 6 through 15, Section B. The response shall be sent to· the address provided in Paragraph 25 below.

6
000016

C. Other Matters

17. Akron shall provide records ofall back-up events resultingirtdischarges onto public andprivate property from Akron's system from July 1, 2003 through present. Back-upeventsshalHnclude discharges onto streets, yards, parks, playgrounds, residences, buildings, and areas where persons may Come into contact with the discharges. Information pertaining to back-up events shall include iriformation reported by Akron, its citizens, .or other persons or entities. Ab-0nsliall also provide records ofitsfirtdirtgsasto the causes of the back-up events, as well as records of any corrective measures taken byAkronas a result ofthe back-up events. Finally, Akron shall provide ~ copy ofits back-up respons~ plan. In additiou,Ab-0nshall create and provide a list ofall back-up events that Akron bas determined were due to the failure of Akron's sewer system. To. the extent this information exists in documents other than in the monthly operating reports submitted to the State or Ohio, provide those documents in responseto this request. Ifyou believe you have previously provided this documentation, identify the date,anthor; subject matter/title of the d~cument and the page numberou which the informati0tlappears. In addition, ifyo~believe the information has been provided verbally in the past, provide the information in writing in response to this request. 18. AkrOn shall provide records ofall complaints from citizens orotherpersons or entities regarding spills, oVerflow events; receiving strean1 characteristics and/or concerns, .imd back"up events, for the period from July 1,2003 thtoughthe present. Akron shall also provide records ofAkron's findings upon investigation of these complaints, as well as records ofany corrective measures taken by Akron as a result of any complaints. Akron shall also provide estimates of any spill volumes, destinations ofthespills,and CaUses ofspills. Finally, Akt0Ilshallprovide a copy of its spilImitigati0tlplan.To the extent this illformation exists indocuments other than in the monthly operating reportS submittea to the State of Ohio, provide those documents in response to this request.. If you believe you have previously provided this documentation,ideritify the date, author, subjectmatterltitleofthe document and the page number on which the information appears. In addition, if you believe the information has beel1 provided verba1ly in the past, provide the information in writing in response to this request: 19. For the periddfrom July 1,2003 through the preseri~AktortshaUprovide daily (all strip charts)flowmomtori!lg d~ta for each orthe satellite communities which have sewer lines feedIng into Akron's system. Akron shall provide this fnformation in spreadsheet format. To the. eXtent this informatiOn exists in docUI1lents other than in the monthly operating reports submitted to the State ofOhio, provide those documents in r~sponse to this request. If you believe you have previonsly provided this do~umentation, identify the date, author, subject matterltitle of the document and the page numbci' on which the information appears. In addition, if youbelieve the information has been provided verbally in the past, provide the information in writing in response to this request.

7
000017

To the extent this inforlnationexistsin documents other than ilithe monthly operating reports submitted to the State ofOhio, provide those documents in response to this request. If you believe you have previously provided this documentation, identify the date, author, subject matter/title of the document and thepage number on which the information appears.•. Inllddition,if you believe the iliformation has been provided verbally in the past, provide theinformation in writing in response to this request. 21. Within ninet)' (90}days of receipt ofthls request, Akt6llsl1aH evalUate the adequacy of its current PumP station backup power and emergency pumping capabilities and provide a report to EPA for its revi~w at the address provided in paragraph 25 below. In the report, Akron shall, for each PumP station, provide detailed information about its PumP station's backup powerandloremergency pumping capability, lightning strike protection eqnipment,anddescribe in detail its history ofpowercloss-related and lightning strike-related overflows and water-inbasement incidCrits during the past 5 years. •The report shall be provided to EPA at the address provided. in Paragraph 25 below. To the extelit thisinfonnation exists in documents other than iii the monthly operating reports sUbmitted to the State of Ohio,. provide those documents iniesponse to this request. If youbelieveyou have previously provided this dOCumentation, identify the date, author, subject matter/title ofthe document and the page number on which the information appears. In addition, . if you believe theinfonnation has been provided vernally in the past, proVide the information in writing in responSe to this request. . 22. Akron shaH provide a Geographic Infonnation System (GIS)sl1ape file identifying the sewer lines in its system, the CSOoutfaUs,the treatment plant, and the tie-in locations of aU ofthe significantilldustrial jIsers (Sms).AkronshaU also provide to EPA the wastewater flow rates from each SRJfrom July' I, 2003 through the present. Finlllly, Akron shill provide to EPA-average daily flow rates for each SID. Ifdaily flow rates are not available; Akron shaH provide monthly flow rates. To the extentthis information exiSts in documents other than in the monthly operating reports submitted to the State of Ohio, ptovidethose documents in response to this request. If YOl1 oelieveyou haVepreviol:\Sly ptovi~edthis documentation,identify the date, author, subject matter/title ofthe document and the page number on which the

8
000018

information appears.. In addition, ifyou believe the information has been provided verbally in the past, provide the information in writing in response to this request. 23. Akron shall ptovide to EPA Within 60 days of receipt Mthis request the information identified above in Paragraphs 17 through 20 and Paragraph 22, Section C. The response shall be sent to EPA at the address provided inParagraph 25 below. 24. If Akron blilieves it can provide the information EPAseeks in afom other than in the reports identified in paragraphs 17 through 22 ofSectionC,Akron shall innnediately inform EPA.ofthis proposal both verbally and in a follow-up letter. If EPA accepts analtemate form, this documentation will be due within the same time frame set out inl'aragraphs 21 and 23 of Section C. 25. Akron shanstibmit~hereportsrequired by this Info ationReqllest to EPA at l1ll the address set forth below, accompanied by the following certification signed by an official or authorizM agent: I certifyurider penalty <>f law that this document and all attachments were preparedurtdet my direction or supervision in accordance with a system designed to asStl1"ethat qualified personnel propetly gather and evaluate the information submitted. Based on my inquiry of the person or persons who manage thesystern, or those persons directly responsible for gathering the information, the information submitted is, to the best of my knowledge and belief; we, accurate and complete. I am aware that there are significant penalties forsublllittingfaise information, inc1ridingthepossibility of fine and imprisonment for knowing violations. The records shalIhe sent to the folloWing address: Acting Director, Wateibivi~ion . United States Environmental Protection Agency - Region.S 77 W. Jackson Blvd. Chicago, lllin6is60604 .. . . ATTN: Jenny Davison, WECA Branch (We-lSI) Facsimile NUII1her (312) 886..()168

This informatiotl request is not sUbject to the Paperwork Reduction Action.

9
000019

Please contact Jenny DaV'isCln ofniy staff at (312)886-Q184,orSusan Perdomo in the Office of Regional Counsel at (312) 886-0557, immediately; if you have any question about this request:

Date'

I

10
000020

ATTACHMENT 1
,
,

No. I. 2. 3. 4. 5. 6. 7. 8. 9. 10.

Station Number 3PFOOOOO046
,
,
'"

'

"

"

,' ..
'

3PFOOOOO047 3PFOOOOO048 3PFOOOOOO49 3PFOOOOO050 3PFOOOOO051
..

..

'

....

3PFOOOOO053 3PFOOOOO054

..

.

,
..C

"

3PF00000055 .
..

3PP00000056 .'
,
.
"

>,.,
'

Descrintibrt South Arlington Street District 2 nd Kelly ave. Combined Sewer Overflows Rack 3 Min Street Combined Sewer Overflow Rack 4 River Street Combined Sewer Overflow Rack 5 Factory St. Combined Sewer Overflow Rack 6 Case Avenue Combined Sewer Rack 7 North Case avenue & Dublin Street Combined Sewer Overflow Rack 8 Case Avenue - NewtonStreet District Combined Sewer OverflowRtick 10 Hazel Street Trunk, District 4, Combined Sewer Overflow Rack 11 Home Avenue District Combined Sewer Overflow Rack 12' Maderia Street Combined Sewer Overflow Rack 13
.

,.

'

.

---c

II. 12.

13.
14. 15. 16. 17. 18. 19. 20. 2I.

Forest Hill District combined Sewer Overflow Rack 15 > 3PFOOOOOO59 WolfLedgesTrunk Combine? Sewer Overflow .. ..."'. Rack16 3PFOOOOO063 West North Street Combined Sewer Overflow Rack 20 3PFOOOOO065 North Hill Trunk Combined SeWer Overflow Rack .. . 22 " .. 3PFOOOOO066 North Maple Street Combined Sewer Overflow . Rack 23 3PFOOOOO067 West Market Street Outlet Combined Sewer ..' .. Overflow Rack 24 3PFOOOOO068 Otto Street Combined Sewer Overflow Rack 25 3PFOOOOO069 Aqueduct Street Out1etCombined Sewer •... ••••• Overflow Rack 26 3PFOOOOO070 I'. Uhler Avenue Combined Sewer Overflow Rack 27 '.- ,. ' 3PFOOOOOOn Uhler AvenuecCarpenterStreet Outlet Combined Sewer Overflow Rack 29 3PFOOOOO073 Cuyahoga Street/Peek Road Combined Sewer Overflow Rack 30
'

3PFOOOOOO58

,.

.

.

.

,

.

.

.

,

.

.

.

.

...

'.

'.

......
"

.'

--c

2I. 22.

3PFOOOOOO75
....

..

3PFOOOOO076

.

Carpertter Heights Distri~t Cornbined Sewer Overflow Rack 32 North Side Intercentor Combined Sewer Overflow

11
000021

...

No. 23. 24. 25. 26. 27. 28.

Station Number·
....

3PFOOOOOO77
.

.........
....

...

·

3PFOOOOOO78 3PFOOOOOO79

...•

.
. ..
.

..
.

...

..

3PFOOOOOO80

...

·

Description Rack 33 Riverside Blvd. District Combined Sewer Overf1dwRack34 Gorge Blvd: District Combined Sewer Overflow .. ···!Qck35 Merriman Road Outlet Combined Sewer Overflow Rack 36 Bowery Street Combined Sewer Overflow Rack
.

.......

I

37

3PFOOOOOO81

.

..

\
.

3PFOOOOOO83
i

...

...... 9,n Avenue at Settlement Street, Combined Sewer Retention Tank Overflow Rack 2NRack 2S Akron Police Pistol Range on Cuyahoga Street, . Overflow RaCl( 40
·

r

12
000022

ATTACHMENT 2
,
,

""

"

,"
'

"

Site Sl S2

','

CSO/ Stream ", "', Cuyahoga River
,
,',

Little Cuyahoga River
• ,

S3 S4 S5 S6 S7

Ohio Canal
,

I

,

,

,',

Ohio Canal
,
'

Cuyahoga River Camp Brook Little Cuyahoga River
,

"

"

,

".

.'

.
"

c'.

i

....

,

S8

Cuyahoga River

~

. "

Downstream of all CSOs Downstream of Ohio Canal and , Little Cuyahoga confluence Lock 15 Monitoring Downstream of Station, North Street Ohio Canal CSOs Cedar Street Upstream ofall Monitol'irigStation CSOs ..; Ohio Canal Front Street Bridge Upstream ofall il1 Ohio Edison Dam CSOs - Cuyahoga ',', Pool River ". Brittian Road UpstteamofCSO Bridge) Rack 12 Camp Brook MassillonRd Upstream ofall Monitotil1gStation· ' CSOs - Little Cuyahoga River ','" Cuyahoga Street ,Downstream of , Bridge Northside CSOs prior to confluence "',' with Little Cuyahoga River
'
"

Location i, Akron Peninsula Rd" Monitol'irig Station Otto Street Monitoring Station

"

.

,0

.

"

I

.'

'.

13
000023

Attachment.

AUTHORlt)'· ANrrCOIIIFIDENTIAUTY PROViSioNS

AuthoritY Information requests afsmllde undetauthorityprovidedbySection30S of the Clean Water Act, 33 U.S.C. 131S.Section30S prollidesthat: "Wh~neverrequiredto carry out the objective of this Act. '" ,the Administr.atorshallrequire thr:l owner or Qperator of any point sources to iii establish and maintain SUCh records, (iiLmakesuch reports. (iiil install. use and maintain such monito~f!'lgequipmentllnd methods(inclOdingWhen~appropriate. biological monitoring methOdsl. Jivlsample such efftuent••• and Iv) provide Sl'("" ~·"",r information as he may reasonably require: andtM Administrator .or his authorized representative, upon presentation of his credentials, shall have arighfrif entry to•.• any premises in which an effluent $ource i.s located orin Whichanyrecord$•••are located, and may at reasonable times nave access to and copy any records...and sample any effluents....
Please be advised that thesubrnlSsidl'lof false Statements issubjilct to federal prosecution under 18 U.S.C. §1001and that !hiedt any other failure to c~mplywitnthilrequirements of Seetion 308 as requeStedbV U.S. EPA maY resUlt inenfdrcementaction under the authority of Section 309 of the Clllllln Water_ Act. which provides for specified civil and/or

criminal penalties.
Confidentiality U.S. EPA regulations concerning cOhftdentiality and treatirient of bUsiness information are contained in 40 CHI Part 2; Subpart ·8. lhformation may not be withheld from the Administrator or his authorized representative because it is viewed as confidential. However, when requested to do so •. the Administrator is required to consider information to be COnfidential ami to . treat it accordingly.if disclo.sure would divulge methods or processes entitled to protection as trade sacrets(33 LJ .S.C.§ 131S(bland 1 U.S,C. §1905J. except.that effluent data las defined in 40 CFl't §2.302(a1l211may not be considered by U.S. EPA as confidential.

a

The regulations provide that one may assert II bUsinesscohfidantiality claim covering part or all of any trade sacretinformation furnished to U.S. EPA at the time such information is provided to the Agency ,The mennerofa$serting such claims Is specified in 40 CFR §2. 2031bl. In tne event that a reqUest is made for -release of information covered by such claim of confidentiality or t~a .i),gencyotherwise decides to make determination as to whether or not such information is enfltled to suen confidential treatment, notice will be provided to the claimant prior to any release of the information. However, if no claim of confidentiality is mad a when i.nfdrmationis furnished to' U.S. EPA; eny information submitted to the AgehcVmay be made available to the public without prior notice.

.This inforrnationft!clllesl: is not subiectl:O the atllJrov~1 requirements of the
.-

.

PapelVJotkReduction Ad of 1995, 44 tB.C. § 3SlHet seq.

000024

Protection of Downstream Uses Nothing new, already required by federal and state regulations

For consideration as part of Ohio Rural Drainage Manual Recommendation that all new petition ditch projects (as well as bottom dipping maintenance of existing projects) determine distance to the nearest high quality water designation: EWH, CWH, Superior High Quality Water, or Outstanding State Water No action needed if distance is more than the specified threshold. Work on projects draining less than 3.1 sq mi can proceed as traditional ditch design. If distance is less than the threshold then: .. Consult with resource agency on selection of appropriate design " Apply "pump around BMP" during bottom excavation to reduce downstream water quality
How many existing and future drainage projects would be affected by the need to consider protection of downstream uses?

Madison, Union & Champaign Counties Little Darby Creek (illustrates pocket of high quality water in ag watershed) 178 square mile watershed 305 miles of stream channel (NHD) _ streams or stream segments have high quality designation
Distance of "Buffer" for Protection of Downstream Use 0.25 miles 0.5 miles 1.0 mile Streams within Watershed Subject to: No Added Added Requirements Requirements Direct Requirements of Imposed by Imposed by High Quality Designation Downstream Use Downstream Use 44 miles, 14 % 154 miles, 51% 106,35% 104,34% 42 miles, 14% 94 miles, 31% 156 miles, 51% 106,35% 106,35%

Protection of downstream use increases number of stream miles "protected" by 15 - 50 percent depending upon the buffer distance chosen. Defiance & Williams Counties Lick Creek (illustrates typical stream in northwest Ohio) 106 square miles watershed 210 miles of stream channel (NHD) o streams or stream segments have high quality designation Protection of downstream use not an issue in much of northwest Ohio (see map).

000025

TMDL Development/Implementation Strategy
JULY 8,2008 10:00 AM - 4:00 PM CONFERENCE RM A Jeff DeShon

General Discussion by Management to evaluate current and future TMDL program
Brian Hall

Dan Dudley, Eric Pineiro, Gail Hesse, George Elmaraghy, Jeff DeShon, Maan Osman, Russ Gibson, Trinka Mount Al RUPPr Dave Stroud, Dave SChuetz, Mike Gallaway, Brian Hall

Agenda topics
MONITORING SCHEDULE EXISTING AND FUTURE Should we slow down the current pace of watershed monitoring and new TMDL development and focus resources on follow-up watershed monitoring and new TMDL implementation needs? Are there scheduling ramification or concerns?

Group agreed

slowing down the number of TMDL produced is a good idea and to allocate more

resources to implementation. Noted that reduction greater than 20% needs Region authorization, will increase number of watersheds With no data

Team formed TM, JD, DS, EP to develop new TMDL monitoring schedule.

TImeframe early November for new schedule

Trinka and Jeff

November

TMDL IMPLEMENTATION AND MARKETING What specific process revisio,ns/'ad,jith)ns are needed in TMDLs to facilitate implementation at local watershed scale? How best can Ohio EPA market watershed TMDls to local stakeholders and move' implementation activities forward? How successful has our TMDl been implemented? Change format ofTMDL (smaller, more specific), Provide to do list of items to be implemented, Should have tracking system for implementation Three verbs describe GEPA's role in implementation - assessing, tracking and facilitating
Kent State developing report comparing OH to WVA TMDLs , report should proVide feedback on Ohio's implementation

Skill sets of staff doing current work might not be best sUited to facilitate implementation planning after TMDl approval

{jn'i'~~'~s'iti~~"a~(i'Coii~g'~'s'ha~e"b~e'n"a'n"aavoca'te":"s~ga'~""Ck"6r:"'Moore;-A'~g!'a"iz'e'didn;t';;'or'k;'sa'~'d~'sky'may't)e"~Or'k~'
ILGARD in

Include implementation Action Plan for each TMDL for management

Trinka (TMDL Coordination

review

Group)

All NewTMDLs

000026

TMDL MODELING NEEDS AND EXISITNG TOOLS

What new TMDL modeHng innovations and approaches need to be de,'eloped to address new issues (e.g. increased assimilative capacity in rural drainage ways)? How can the success of these new approaches be measures (e.g. OSU 319 contract)? What is the effectiveness of the current load allocation modeling? Need to develop modeling tool to forecast assimilative improvements in drainage ditches Complex modeling need higher level of resources, not sure if loa<llng;s.. Are tools modeling/greater resources are needed to determine of TMDL?

Meet with Chief to discuss model(s) selection prior to field data gathering Develop model for drainage ditch management (319 grant to OSU?) TIIIDL DEVELOPMENT AND SOURCE TRADING How

Maan

Annually (usually in May and June)

Maan and Russ

2010

principles can be developed into process as a potential implementation option in appropriate

Need understanding of impact new nutrient rUles will have on implementation.
It would be nice to trade for something other than loadings (e.g. trade overwlde/NCD for treatment plant loading, in QHEI units). Have had discussions with MB! about research into this topic.
Educate staff on how to deal with NPS

Draft memo about planned nutrient WQ standards Draft memo on possible trading and NPS restoration

Dan

July (complete)

Russ

November

000027

12/04/2007

19:03

514-544-0108

OOOD COMMUNICATIONS

PAGE

04/09

Ohio

Department of Development

Summary of Incentiyes for The Goodyear Tire and Rubber Company and the Summit County Port Authority in conjunction with the Goodyear Headquarters Project

Value of Ohio's Commitment: More than $90,000,000
Proposed State IncentIves: Discretionary Grants Roadwork Development (629) Account 166 Direct LQan Ohio Job Retention Tax Credit
~C:.!!le~a!!.JnwO:!.!h'.i.!io~R~e:'y'v!!:!ltailll~iz.:!at~lo,a.n.!.-Fwuwn.u,di..-

)

$17,200,000 $5,000,000 $20,000,000 $46,755,436 __.__.---,---l$2,OOO,OOO

TotalValuQ·Qf State Incentives

Up to $90,955,436

Proleat Assumptions: • The Goodyearmre & Rubber Company (Goodyear) would build Its new headquarter'S the City of Akron. Summit County. • GOodyear would Invest approximately $209 mllllon for its proposed project, including $107.8 million in new building costs. $18,9 million in new furnITure fixtures and equipment. $44 million in parking structures, and $38.3 million in other related project oosts. • Goodyear will ensure that 2.900 persons are employed al the project. • The average hourly wage rate for all new positions at the project site would be approximately $45.00. exclusive of benefits. • The State of Ohio is in competition with the states of Virginia, and North Carolina for Goodyear's proposed project. • In~ntfves may be prOVided to the Summit County Port Authority (Port Authority) to su ppart this project.

This commitment is currant as of November 30, 2007. This commitment will remain in effect until December 31,2007.
000028

12/04/2007

19:03

614-644-0108

ODOD COMMUNICATIONS

PAGE

05/09

Summary of Incentives for The Goodyear Tire and RUbber Company and the Summit County Port Authority in conjunction with The Goodyear Headquarters Project
STATE COMMITMENT ACCEPTANCE REQUIREMENTS

•

the 0000 understands the conftden~al nature of negotiating fmancial incentives for business location and expansion plans. The Department will make a concerted effort to coordinate the release of public information in conjunction with Goodyear's govemmental affairs and communications office. Lack of<:.oordinl!ltion rn fh"J timing of

announcements and required approvals could jeopardize ODOD's ability to deliver the referenced incentives.
• This preliminary commitment of assistance is based upon our understanding of the project as outlined herein. 1'1&<16e address any issues Inconsistent with our understanding of the project. In the event that any of these numbers are reduced, our commitment may be reduced proportionately. PleaSE! note that the use of State funds may require the payment of Ohio's prevailing wage rate as determined by the Ohio Department of Commerce, Wage and Hour Bumau. This commitment is contingent upon final approval by the Ohio Tax Credit Authority, the Development FinanCing AdVisory Council, and the State Controlling Board. The 0000 recognizes Goodyear and the Port Authority may need to proceed with the proposed project prior to receiving final approval for the incentives offered in order to meet schedule requirements. Although you do so at your own risk, the 0000 is confident that this will not jeopardize your application for StatE! assistance. Please continue to work with Eric Neff, Business Development Representative, and Leah Anglin-WalSh, Regional Economic Development Director. Eric will assist the company In gaining the necessary approvals for the assistance described hemin. Eric will m.,d to receive a written response from Goodyear by December 31, 2007, acceptmg this assistance and confirming our understanding of the project. Eric may be reached at (614) 466-5656 or bye-mail ateneff@odod.sta!e.Qh.us. and Leah may be reach$d at (330) 643-3392 or by a-mail at langlln@odod&tGl!lil,oh.Us, should you have any questions.

•

•

•

•

)

ThiS commitment is current as of November 30, 2007. This commitment will remain in effect until December 31, 2007.

2

000029

12/04/2007

19:03

514-544-0108

ODOD COMMUNICATIONS

PAGE

05/09

Summary of Incentives for The Goodyear Tire and Rubber Company and the Summit County Port Authority in conjunction with The Goodyear Headquarters Project
GRANTS

DlscretionlllY Grants Estimated Value: More than $17 mm/on
The 0000 is prepared to offer funding from the Rapid Outreach Grant program, the Director's Contingency account. and the Director's Discretionary account for up to $7 million from the fiscal year 2008 DUdget (WhiCh began July 1, 2007), an $5 million from the fiscal year 2009 bUdget (which begins July 1,2008), and $5 million from the fiscal year 2010 budget (Which begins July 1, 2009) to the Port Authority for Its costs associated With the Goodyear Headquarters project. These funds are in addition to the $200,000 already provided to the City of Akron for this project. The grant will be provided on a reimbursement basis to the Port Authority. The use of Stale funds may require the payment of Ohio's prevailing wage rates as determined by the Ohio Department of Commerce, Wage and Hour Bureau. Use of these funds is contingent upon approval by the State Corrtrolllng Board. Ava/lability of 2009 and 2010 funds is contingent upon future appropriation to 1M program by the Ohio General Assembly. .
Roadwork Oawlopment (629) Account

Estimated Value: Up to $5 mt1Hon
The 0000 (s prepared to offer a grant from the Roadwork Development (629) Account for up to $2 million from the fiscal year 2008 budget (Which began July 1, Z007) and $3 million from the fiscal year 2009 budget (Which begins July 1, .2008) for the costs associated with the Goodyear Headquarter project and Akron Rivenvalk project. The grant will be proVided on a reimbursement basis to the Port Authority. The use of these gratlt funds is for public road improvements only and may requira the payment of Ohio's prevalllng wage rates as determined by the Ohio Department of Commerce, Wage and H9ur Bureau. Use. of lhese funds is contingent upon approval by the State Controlling Board.

economic Development Contingency Account EstlmatBd Value: Up to $200,000
The 0000 offered a grant from the Economic Development Contingency Account for up to $200,000 from the fiscal year 2008 budget (whiCh began July 1, 2007) to the City of Akron for its initial environmental assessment costs associated with the Goodyear Headquarter project, The grant will be prOVided on a reimbursement basis to the City of Akron. The use of State funds may require the payment of Ohio's prevailing wage rates as determined by the Ohio Department of Gommerce., Wage and Hour Bureau. Pi ease note: This is not a new commitment of assistance. This grant has already been awarded to the City of Akron and approved by the state Gontrolling Board.

This commitment is current as of November 30, 2007. This commitment will remain in effect until December 31, 2007.

3

000030

12/04/2007

19:03

514-544-0108

ODOD COMMUNICATIONS

PAGE

07/09

Summary of Incentives for The Goodyear Tire and Rubber Company and the Summit County Port Authority in conjunction with The Goodyear Headquarters Project
Clt:<an ohio Revitalization Fund' Potential Value: Up to $2 million

The Clean Ohio Revitalization Fund was developed to provide funding for brownfield clean up activities, which are a key component in brownfield redevelopment. Brownfield redevelopment allows a community to reclaim and improve its lands, making previously developed property Viable for new development. The Clean Ohio ReVitalization fund is part of a $290 million dollar initiative approved by Ohio voters as part of the $400 million Clean Ohio Fund. The Ohio Department of Development, through its Office of Urban Development, Implements the Clean Ohio Revitalization Fund in consultation with the Ohio Environmental Protection Agency (Ohio EPA). • Please Note: The Clean Ohio Fund grants are competitive awards. Given the paramerers of the project and 0000'5 understanding of the environmental Issues associated with the project site, the project is within the parameters of projects that hava been funded preViously, and 0000 expects that an exceptionally competitive application to Clean Ohlo Revitallzllllon Fund can be developed for this project.

FINANCING
I,

156 Direct Loan Loan Amount: Up to $20 million

The 0000 is prepared to provide 166 Direct Loans for eligible fixed-asset costs associated With the Project. subject to lt1e following conditions: Loan amount: Term: Interest rate:
COllateral/SeCUrity:

Up to $16 million Up to 5 years

Fees/Costs:

EqUity requirement:

0.0 percent loan to have a security position acceptable to the Director of the ODOD Application fee of $1 ,500; a .2:5 percent annual servicing fee; and a 2 percent processing and commHment fee for the first $1 million and 1 percent of any additional loan funds (not to exoeed $50,000) 10 percent of the total eligible project costs

Loan amount: Term: interest rate: Collateral/Se.curity:

Up to $5 million Up to 20 years 0.0 percent years 1"10 2.0 percent years 11-2.0 Loan to have e secunry position acceptable to the Director of the 0000

This commitment is current as of November 30, 2007. This oommitment will remain in effect until December 31, 2007.

4

000031

12/04/2007

19:03

614-544-0108

PAGE

08/09

Summary of Incentives for The Goodyear Tire and Rubber Company and the Summit
County Port Authority in conjunction with The Goodyear Headquarters Project Fees/Costs: Application fee of $1,500; a .25 percent annual servicing fee; and a 2 percent processing i;lnd commitment fee for the first $1 million and i percent of any additional loan fundS 10 percent of the total eligible project costs

Eq ulty requirement:

Financing is contingent upon meeting all program guidelines, completion of due diligence, satisfactcry review of the company's flnancial statements, and approval by the Development Financing Advisory Council (DFAC) and State Controlling Board. The use of State funds may require the payment of Ohio's prevailing wage rates, as determined by the Ohio Department of Commerce, Wage and Hour Bureau.

I
This commitment is current as of November 30,2007. This commitment will remain in effuct untit December 31, 2007. 5

000032

12/04/2007

19:03

614-544-61138

ODOD COMMUNICATIONS

PAGE

09/09

Summary of Incentives for The Goodyear Tire and Rubber Company and the Summit County Port Authority in conjunction with The Goodyear Headquarters Project TAX INCENTIVE
Ohio .Job Retention Tax Credit Estimatad Value: Up to $46.7 mit/ion

The Job Retention Tax Credit program allows companies retaining jobs in the State to lllke a corporate franchise or State income tax credit based on the Ohio income tax withheld from eligible retained employees. The credit is non·refundable but may be carried forward for up to three years. 0000 will recommend to the Ohio Tax Credit Authority a tax credit for 15 years based with the following rates: Empioyees
Tax Credit Rate

2,900 2,500 -2,899 2,000 - 2,499
less than 2,000

27 percent 26 percent 25 percent No credit

These recommendations will be contingent upon the company commitllng to an average hourly wage of $45.00. The company's tax credit is calculated based upon the state income tax withholdings for the retained jobs. This credit is contingent upon submittal of an application, meeting all program requirements inclUding adequate local finOlnclal support. This credit is also contingent upon the recommendations of the Directors of the Office of Budgel Management and the Ohio Department of Taxation, and approval by the Ohio Tax Credit Authority. The company must maintain operations at the project site for at least 3l) years, twice the term of the tax credit

This commitment is current as of November 30, 2007. This commitment wilf remain in effect until December 31.2007.

6

000033

(

(

November 19, 1979 Lynn A. Clark, Section Chief Ohio EPA - Northeast District 2110 E. Aurora Road Twinsburg, Ohio 44087

.I

Dear Mr. Clark:The following is submitted for your consideration in reply to your letter of November 7, 1979: The following materials are currently disposed of in the landfill and are derived from basic chemicals: Scrap butadiene/acrylonitrile rubbers - solid 2. 3. Scrap butadiene/ styrene resins - soltd Scrap butadiene/vinyl toluene resins - '1,olid in the pretreatment facility, air-floated and then filtered to separate the solids from the clarified water. The filter cake which is in solid form contain;20... 25%-.solids,. The filter cake is trucked to the landfill area where;;!';3.per, f:J.,y .ash and~.:Cl!!,~d I;'J.l.l>b"r trimmings are mixed in with the latex during covering operations. Latex types include butadiene/styrene. butadiene/acrylonitrile and polybutadiene. 5. 6. Belt trim rubber and plastics Soapstone slurry cleanings, 20-40% solids (Slab - Kote II) Present plans call for disposing of this material at another approved site. The waste, however, 1's not considered a hazardous type material.

4. Waste latex wastes (cleanings) which are mixed, chemically coagulated

'1l

Note:

I hope this meets with your satisfaction.

,-

- .
;
• __ : .' ·t

- -"
r··· / ~

.",

..

.
1

~l~'_
. J S-tone, Section Head Akron Central Engineering Staff
000034

cc:

J

11 S'mergli'a' D C Salze)'
~:.c

-,

000035

000036

~~
vSLJ/Ct)

\

000037

From: To:

Kurt Princic bakuhai@ci.akron.oh.us; Dave Dysle; Frank Markunas; Jennifer Kurko; John Schmidt; Natalie Oryshkewych; Phil Rhodes; Rod Beals; Scott Moegling Date: 1/28/20087:29:02 AM Fwd: OhioEPA Orders on Relevant Properties\Goodyear Project Subject: Greetings, See below. Is anyone aware of any other finding and orders other than the ones for the Eslish\Continental Property as it relates to the Goodyear project.? If so please bring them to Tuesday's meeting. Attached is a map which outlines the proposed project >>> "Norman, Mark A." <MANorman@vorys.com> 1/25/20085:15 PM »> Kurt: Per my voicemail from today, I understand that there is some form of administrative or judicial order in favor of Ohio EPNState of Ohio and regarding the Eslich property. This order reportedly has terms that would govern the transfer of this property. I would like to obtain a copy of this order (or orders if more than one) ASAP. If you could email it on Monday 1/28, that would be great Otherwise, if you could bring it to the 1/29 meeting (or have it sent with another OEPA staff member if you are not going to attend) and give to me, it would be appreciated. I do not know if there are orders on any of the other relevant properties to be redeveloped and would request that you ask your team if such orders exist I am not interested in air/water orders that would expire if the operations closed, but rather orders that might have some obligations to future owners. This would include properties owned by Goodyear, Harwick, and other third parties. I do not have a comprehensive property address or owner list at this point to assist you. However,if your team is able to identify any orders (other than Eslich), that would very important Thanks in advance. Mark

Mark A. Norman Vorys, Sater, Seymour and Pease LLP 221 East Fourth Street, Suite 2000 Cincinnati, OH 45202 Phone 513-723-4006 Fax 513-852-7881 Mobile 513-405-4006 Email manorman@vssp.com Website

From the law offices of Vorys, Sater, Seymour and Pease LLP. IRS CIRCULAR 230 DISCLOSURE: In order to ensure compliance with requirements imposed by the U.S. Internal Revenue Service, we inform you that any federal tax advice contained in this communication (including any attachments) is not intended or written to be used, and it

000038

cannot be used, by any taxpayer for the purpose of (i) avoiding penalties that may be imposed under the U.S. Internal Revenue Code or (ii) promoting, marketing, or recommending to another person, any transaction or other matter addressed herein.

CONFIDENTIALITY NOTICE: This e-mail message is intended only for the person or entity to which it is addressed and may contain confidential and/or priVileged material. Any unauthorized review, use, disclosure or distribution is prohibited. If you are not the intended recipient, please contact the sender by reply e-mail and destroy all copies of the original message. If you are the intended recipient but do not wish to receive communications through this medium, please so advise the sender immediately.

cc:

Kurt Princic; Laura Tobias

000039

UhlO.com - vIsion unvelled tor Hoover raclluy
_______ --""_,,·w.. _

l:'age

j

or L

""""~

Ohio.com
January 29, 2008

Current;43~

IlIImilliII
Editorial
Lifestyle Entertainment Multimedia UPublfsh Classifieds Obltuilries

News

Sports

Business

@1HOm,,"1[): Jobs ~ Cern ~ Shopping

Sear<:h

Choose section(s)

AhoutU, 1 M"k~U.Y~orHom"P"ge I RSSIfJ

(Page I or2) I Si'l~" Pape Vi."

Vision unveiled for Hoover facility
New owner foresees warehouses, eateries, shops, even possible hotel on North Canton campus
By Jim Mackinnon 8ea<:on Journal business writef

North Call1on losl a premier maker of vacuum oleaners, and its largest 'private employar, when ll1e new owne, oill1e Hoover Co. closed the aging headquarters alld factory in 2<l07
But ove, ttle ""xl several yeafs, ij,e small Stark County city might get a new 100·room I'otel in

CM$top~.. Sema'jl.", ofl"d~.trial Com'r<.l,a. ialk~,t a now; oonf,,.,,,,,, on J.n. 26, 2006, about a".• m,ra ,."deoingof. proposed m'<ed·u•• ,.developm.nl olth<> form., Koove, Co, camp"o i~ No'th Canto", Ohio, H. and """" develOp.", bought tl\e propsr" f'om Ko""o". ",w ""'PO",IO

p.,"nt

(Mlk~

CardowlAkmn S••""n Journal)
View m",e photo, "

Hoove(s place. Pius shops, rastaufants, light manufacturing, wafehouses and more, A1llo1d, between 350 and 850 jobs might be emeled whefe as many as 2,400 people worked durmg Hoover's peak years
Ohio OK.
F~nding (0,'

Goodyoa, HQ

Thars the vision of Maple Street Commerce Ltd., ~,e new O\M\ef of the 88·acre Hoover campus in tile heart of North Canton's downtown, The real·estate venture closed on the property Monday morning, buying it f'om TTl Floor Care NOfth America, Hoover's new cOfJlorate parent "Change Is ineVitable," Mayor David Held said In a news cOllrerence announcing the new oWnerShip plans befofe as many as 150 people in the aUditorium of the fOfmer Hoover headquarters bUilding

Poo"3,d witl> t1po agl1o.t

1"""~. i~"umt

knoWTl"' the "White House" The three faces behind Ma pie SlIeet Commerce afe famiilafwith redeveloping aging Northeast Ohio siles: Stuart lichtef, founder and head of California-based Industrial Realty Group, Chris Semarjian of Industrial
C<lmmer~e

OhKl S"pr~ma C""rt Ak,on ;.wy~,

<w,p~nd,

Ltd. and Cleveland real·eslate finn NflJ Daus, and Realtor aob DeHoff of North Canton',

DeHoff Developmenl Co Lichter and Sema,jian a,e the developers
Pat'~ e~s,do b~hind

the $900 miilion Goodyear headquarters project In

'h& Point

Akron- and other large indust,;al properties in ttle region. DeHoff, meanwhile, ooonts emong his projects

tl'" new Hilton Garden Inn at the Galeway Co,porate

Pa,k off Interstate 77 near Akron"Canion AifJl0rt. The Hoover oomplex Is ouldated and inefficient for large manufactufing opefations, bui its space lends itself to smail companies, DeHoff said, Small and midsize companies in Northeast Ohio are ttl. ones adding jobs, he said "Two years from now lhe build;ng w111 be teeming with employees,' DeHoff said. Semarjian said that while the developers have a vision for the sile, markellorcas ultimatety will determine what kind 01 businesses move In One tenant, still unnamed, has signed to use warellouse "paCe, he "aid, By May, there w111 be fou, tenants using the property, Semarjlan said. Hotel idea studied Maple Street Commerce is a "very spewlative"
awai~ng

JmSlogs:
Ak,,,,,,,n;nc:
Raw Umber ali heist THEFT, a poem
by Madeleine Mysko

Ihe ,esults in the ne>rt 90 days of a .tudy It commissione<J to see
~e,cent,

whether" iOO-unlt hotel is feasibie, he said, He put the chances of a hotel aljust 30
~fOposai

calling It

All Oa King'S Men;

Dear Democraw Akron Zips'
Hoban safely eommits to lip.

The ,efallen; U,ey want to bring in will be aimed al .ervi~g the local community and w111 not be "big box" types, Semarjian said

Bala"Ged Ledger:
Tom Brady?

Page 1 12 - Next>
Stor~

Blog of Mnss
FISA Fame

Oe~t",ct;on:

'001.

BokBluster:
Bill and Ted's Big Adventure

Cleveland Brow,,", Talks begin with Ande,son, Lewis
Ct"vaf",,<l Caval;e"" Le8ron beals Kobe again .. ,betle, late Read 0115 comments»

000040

http://www.ohio.com/news/top_storiesll4628742.html

1/29/2008

unlo.cUIIl - v lSlUn

unveueu lur noover laCl1llY

rage

~

Ul L

!han never Ohio Travels with Bolly:
I/Iihen is the big RV show in Toledo?

Type in your oomm.nts to p051 to the forum

Nama (appears on
your post)

Olympic DrMms· Running: Socks,., For Y(>ur Elbows
Sound Check: Cocaine 1$ a helluva drug.,jusl ask Ike Turner Thl> Heldenfill>s: More "Judge Judy"

CQmroonts

Th<! Sports B1~l: BCS Championship Game: The
Infamous DVD

Varsity L"!l(,rs:
Hudson pail choose Young Pfofessionals Loop: YP Lo~ Newsletter: February, 2008

Type Ihe numbers you see in the image on
the fight

JI"~

Of. po.ting I. In <ompllon"" wi!~ sur;}) 1m"" s. pollt•. In.pprop~.r.pOOl. m.y 4. r.mo\"d i>y r~. mo<klf8lor.

CRIME WATCH
PUbllshed January 27th

BOOKS

HOME & GARDEN

Read the weekly police bloller for Summit. Stark, Medina, Portage and Wayne counties,

Pr~ve"lif]g tr~[1d

Qfhsbito'; bel"» born \<>0 eBrly

TIred of being cO<lp&d lJp? Can'lwei\ unt~ ~,,'Ing? "Sna~

KiTlq pir:\urer, cr"~py Florida

Ranch style

la,"~5

buyer;;

-------~~------------------

Ohi&:roiii

000041

http://www.ohio.com/news/top_stories/14628742.html

1/29/2008

From: To: Settles Date: Subject:
Greetings -

John Schmidt Bill Skowronski; Caroline Markworth; Keith Riley; Kurt Princic; Lynn Sowers; Mike 1/29/20087:53:46 AM WKSU and Akron Beacon Journal News Stories - Goodyear Project

On the drive in this morning, WKSU had a blurb about ODoD's $2 million "grant" to Akron from roadway/lights/ signfl!~,fl!Jb-'",Qqodyear Project Also referenced that the same developer is doing the HoolieTcCiiTijjTeXTri'l\jorth Canton, Ilranshortly after 6 AM as part of the local news portion of Morning Edition, This morning's edition of the Akron Beacon Journal references $33,9 million for construction of roadway and parking deck, The news article can be found at www.ohio.com. The $2 million grant article may get pUblished at the website as an audio file, not there yet Website is wwwwksu,org, Follow the link for news, Food for thoughtJohn M. Schmidt, RS" P.E. Ohio EPA, Division of Solid & Infectious Waste Management Northeast District Office (330) 963-1175 Fax (330) 487-0769 Phone (330) 963-1175 Fax (330) 487-0769 email John.Schmidt@epa.state.oh.us

cc:

Harry Courtright; John Palmer; Natalie Oryshkewych; Rod Beals; Scott Moegling

000042

t:.
.
A

crtrtTC a t ion

I ':"\J v, lazar d GUS W as t e

C" ~

"+r-:::::l' :.~

Untl('d SHqC'~ EnVllonnll.'nlnl PrOll'C Agency

V,I i1 sh'lnglon DC 7NG

PJeasetype or print in ink. If you need required by Section 103(c) of the Com preadditlonaf space, use separate sheets of h ensive Environmental Response, Compen~ paper. Indicate the letter of ths. item . ;~alion, and Liability Actoi 1980 and must which applies. b () \1e mailed by June 9, 1 9 8 1 . . : : ; t I ~ .
ThiS initial notification 'information is

0-1()

Y

Person Required to Notify: ,-~ / D £7 1Nam, I Le l700 yea1r l i r e ~ TI t/pber0 Enter the name and address of the p e r s o n ,-,=='-"--'--"-'--'=--'--'---'-'-"'-",-=:-",-,--=-=,_-or organization required to notify, AA CI -..L- ..\.4 // r---IS""'T, I - C1?;7 I tLQrQC .:::::> I '

OJ! ~/C;

d

OHi-OQO- GOr - 1:2)
--r:-

C

II

f

B

Site Location:
Enter the common name (If known) and actual location of the site.

Nam, 01 Si"

Gooc{Veqy - 5e i be rl!!!t3'freei !1!l11:lfi, s"",EmstoE f/4f1& 2..Ji::; Epder f/It"u l~p;f1 Ave.

C',y

A ((t"o f2
;;;"1 {" -

County'SU

111 m ; T

Slat,

0 If

Z,p Cod,

-f -f 3/(p
V

•
E

....

c

Person to Contact:

Enter the name, title (if applicable), and business telephone number of the person

Nam, Ie""
Phon,

F,,,, ,ndTitl'lLtdJ't;;zfl

j

B.A. Ivff!r. /j (c{?/..s ~e

v;ce~

to contact regarding information
submitted on this form.

'79t, - 30 9q

D ' Dates of Waste Handling:
Enie'fThe years that you estimate waste treatment, storage, or disposal began and ended at the site.
C;-.

F:c,.::o"'m"IY:.:'::':c'I--'-_I.!..C::o-:::::>::-

/0sr

y T"oc:l.:.:::":.''-1.!-~~.!-

/ q 71
- - - - -

_

_

.taste Type: Choose the option you prefer to complete

Option t: Select general waste tYpes and source categories. If you do not know the general waste types or sources, you are encouraged to describe the she in Item I-Description of Site.
General Type of Waste:' Place an Xin the appropriate boxes. The categories listed overlap. Check each applicable category.
Source of Waste: Piace an X in the appropriate boxes,

Option 2: This option is available to persons familiar with the Resource Conservation and Recovery Act (RCRAl Section 300 regulations 140 CFR Part 261).

r

1.

~

Organics

2.. f.i1j Inorganics
3. Ji[ Soluents A. 0 Pesticides
III 0 0 0 10. 0 11. 0 5. 6. 7. 8. 9.

,RJ Heavy metals
Acids Bases PCBs Mixed Municipal Waste Unknown Other (Specify)

1. 0 Mining 2. 0 Construction 3. 0 Textiles 4. 0 FertHizer 5. 0 Paper/Printing 6. 0 Leather Tanning 7. 0 Iron/Steel Foundry 8. % Chemical. General 9, 0 Plating/PoJ',shing 10. 0 Military/Ammunition 11. 0 Electrical Conductors 12, 0 Transformers 13. 0 Utility Companies 14. 0 Sanitary/Refuse 15. 0 Photofinish 16. 0 Lab/Hospital 17. 0 Unknown
1

Specific Type of Waste: EPA has assigned a four-digit number 10 each hazardous was listed in the regulations under Sec1ion 3001 of RCRAJEnter tl appropriate four~digit number in the boxes provided. A copy a the fist of hazardous wastes and codes can be obtained by contacting the EPA Region serving the Stale in·which the site located. .'"

o0 0 2 9,.

J":! -8 81

{./t2;~e;,.(s ;~J)i{ds Me ql "

Form Approved
nM'RN..,
'''''(1(\

'''''0

000043

,

- : £ ; 1 HBzard ous VVast

~
,
•

__ '19'"

.

=-:1--

.~~~---~(
Facility Type

Sidelwo

owa.nt1t¥.

_",t" )< In the appropriate boxes to pillet an he 1aClIl'ty types found at the sl1e

,. 0 Piles

h waste ,,.,t-"te. e "~total facilitycom b'Ineamount". space d quantity. the estimate d

"d1C81e t

Lme) of hazardous wastes at the 51te
usr~g cubic feet or gallons.

2. 0 land Treat menl 3. )S Landfill 4. 0 Tanks
5, 6. 7. 8. 0 Impoundment 0 Underground Injection 0 Drums, Above Ground ~ Drums, Below Ground

~
square leel

\

In the "lotal facility area" space. give the estimated area size which the facilities

occupy using square feet or acres.

9. 0 Other (SpecifYI
Known, Suspected Or Likely Releases to the Environment:
Place an X in the appropriate boxes to indicate any known, suspected. or likely releases of wastes to the environment.

o

Known

0 Suspected

~

Likely

0 None

Note: Items Hand.' are optional. Completi.ng thes.e items will assi~t EPA and State and local governments in locating and assessing hazardous waste srtes. Although completmg the Items is not requIred, you are encouraged to do so.

Sketch Map of Site Location: (Optional) Sketch a map showing streets, highways, routes or other prominent landmarks near the site. Place an X on the map to indicate : . the site location. Draw an arrow showing , . . the direction north. You may substitute a publishing map showing the site location.

See Area{ g
HCl}£6iraou5

...
were used

Description of Site: (Optional)

r

Describe the history and present conditions of the site. Give directions to the site and describe any nearby wells, springs, lakes, or housing. Include such information as haw waste was disposed and where the waste came from. Provide any other information or comments which may help describe the site conditions.

ihe.

Wot5 U5'ed -Eor- iVl c!u 5 f!r,c. { '5';fe w a"ifes -f'r0 fYl prodtl. c f/Of1 o f f/.& bbercJ

J me+c::r I prr ducf5, or:r6'l~"c C hef11:Ca (5, S yl1 fhef/c ru bbers ~ n::"5',nS.
4/{I'odl.icfs

Nofe ; S;J1ce / q 77, pdlrt or
STreet- 161f7d -A' II /16(5 pee/1
(JUS

t Ae
U 5' e

Geodyetflp- 5'eiPerf,'r!1

d

-for

/10/1- /; tI;/:4"hJI-

,puf

wcrsfe (Trds4} tt5e C i fy wale f".

f!Of1/feS

6%re

neUlV'" -{he

!61flld~(1

Signature and Title: ) person or authorized representative .)'Ch as plant managers, superintendents. trustees or attorneys} of persons required to notify must sign the form and provide a mailing address (if diHerent than address in item A). For other persons providing notification! the signature is optional. Check the boxes which best describe the

Jij Owner, Pi csent

Xl Owner, Past
EJ Transporter
~

J< Operator, 000044

o

Operator, Present Past Other

f
I

I

f ,
t

\--.

.. .;.

~.

". .'-" !.. '.•~

."'- a '.'
;;0

C'"'

(D':,,'.
ir

t i "~ '"
.t:

~~~~~i::'f': ;- .,

.::-

... .-:.,

....

~

lI~;~&%i .
~

, ,;
"

<

'

, .. -;:~ .... ~: , " ,.
~.

';.

[
I

,

,

f~ ~.

!
:

,

l0

< , •

i,

--. • " <- , • -.
>

000045

Urban Setting Designation Fact Sheet
Number 8
February 1998, revised August 2004

Introduction
Amended Substitute Senate Bill 221 created the Ohio Voluntary Action Program (VAP), whereby a person can perform a voluntary action at a property and receive a release from cleanup liability from the State of Ohio. A volunteer may evaluate the environmental conditions at a property and remediate the property, if necessary, by employing the services of either a certified professional or other qualified persons. If the property meets the applicable cleanup standards for the use of that property, a certified professional prepares a No Further Action Letter (NFA) for the property. The volunteer or certified professional must employ the services of a certified laboratory to perform analyses that form the basis of the NFA. Upon favorable review of a complete NFA submitted to the Agency, the Ohio EPA director will issue a covenant not to sue releasing the person who undertook the voluntary action from liability for additional cleanup. This covenant is transferable to subsequent property owners. Ohio EPA's ground water protection requirements for voluntary cleanups are designed to address risks to residents and the environment posed by contaminated ground water. While cleanups that bring the underground water supply quickly back to pristine conditions are lofty goals, they can be very costly without improving health and safety, and may often mean the difference between a brownfield being cleaned up and redeveloped or remaining an abandoned scar on the urban landscape. When developing the VAP regulations, Ohio EPA recognized that many brownfield properties are located in highly urbanized areas which rely on community water systems to supply residents with safe drinking water. In those areas, ground water that contains chemicals from prior industrial/commercial activities poses no appreciable risk to the community because the ground water is not being used and will not be used for drinking water purposes in the foreseeable future. In these situations, an Urban Setting Designation (USD) may be appropriate. A USD recognizes that cleaning up the ground water to drinking water standards is not necessary because no one will be drinking the ground water. Other possible exposures to contaminated ground water (such as exposures to wildlife or streams in the area) still must be addressed even when a USD is granted for an area. USDs can be granted only by the Ohio EPA director. A written submittal to the director requesting a USD must be made by a certified professional. The request must successfully demonstrate the property (or properties) meets all the criteria of a USD as specified in Ohio Administrative Code (OAC) rule 3745-300-10(D) before such a designation can be granted. All USD requests must be submitted and approved by the

000046

mailings are conducted within a few weeks after a USD request has been received. Information about the USD is also announced to the public through news releases issued by Ohio EPA to the media and known citizen groups in the area. If significant interest is shown or concerns are raised by residents or interested parties, Ohio EPA, along with the USD applicant, will hold a public meeting.

Approval Criteria
Before a USD can be approved by the director, the written request must successfully demonstrate that: • ali threshold criteria have been met; • the USD is not likely to have an adverse environmental impact on surrounding jurisdictions; • the USD is not likely to adversely impact regional water resource needs and water resource obligations; and • the USD is not likely to expose people in the region to contaminated ground water (by evaluation, among other things, of current and future regional use of ground water) now and in the futu re.

Questions?
If you have any questions regarding the Urban Setting Designation approval process orthe Voluntary Action Program in general, please contact the Voluntary Action Program staff at (614) 644-2924. In addition, information is available on the VAP web page at http://www.epa.state.oh.us/derr/voluntlvolunt.htrnl .

Urban Setting Designation Fact Sheet

3

Number 8, February 1998, rev. August 2004

000047

From: Kurt Princic To: bakuhai@cLakron.oh.us; Bill Skowronski; brownjb@cLakron.oh.us; Dave Dysle; Ed Wilk; Erika Jackson; Frank Markunas; Harry Courtright; Jennifer Kurko; Jim Veres; John Palmer; John Schmidt; Keith Riley; Kelvin Rogers; Laurie Stevenson; Lynn Sowers; Marty Cooper; Natalie Oryshkewych; Phil Rhodes; Rod Beals; Scott Hester; Scott Moegling; Steve Tuckerman Date: 1/25/2008 1:01:45 PM Subject: Meeting re: Goodyear.

Greetings, There has been a change of venue. We will be in the Mayor's conference room at the following address. 166 S. High Street, Akron. This is just up the street from the previous location. Park at the same garage identified below. Here is the tentative agenda. As it gets refined I will update 1. Developer's Intentions\Project Overview. 2. Status of Investigatory Rule 13's when are they coming in. -Goodyear -Joy Park 3. Rule 13 requirements for development\excavation of Goodyear Landfill 4. Development on Eschlich\Continental Tire Property 5. Little Cuyahoga relocation issues 6. As necessary address questions\concerns provided to Akron on January 8th.

Previous E-mail from 1/16 Greetings, After checking everyones schedule and talking with Brad the best day for the meeting is January 29th at 10:00. The meeting will be held at the City Center 5th Floor Conference Room. (All of NEDO's conference rooms were booked). The address is 146 S. High Street. There is a parking garage on the opposite side of the City Center Building. You can take the skywalk or just enter City Center from the street. Take elevator to 5th floor. There is not a set agenda at this time, but the focus will be on the Goodyear Landfill, Eschlisch Property and the Harwick and Micropoise properties off of Englewood Ave. Relocation of the Little Cuyahoga will also be discussed. If you have any questions feel free to give me a buzz or e-mail. Thanks KP

Previous E-mail from KP

000048

Please let me know your availability the week of January 21st and 28th for a follow up meeting regarding the Goodyear project. FYI, their preference is the week of 21st. Thanks

KP

cc:

Laura Tobias

)

000049

000050

RICHARD A. MEROLLA Service Director VALERIE STRAW Executive Assistant DONALD l. PLUSQUELUC

JEFF FUSCO Deputy Director JOHN W. VALLE Deputy Director

Mayor

DEPARTMENT OF PUBLIC SERVICE
166 S. High St.. Room 201 Akron, OH 44308 Phone: (330) 375·2270 FAX: (330) 375·2100

August 2, 2007

Mr. Paul Novak, Manager Permits and Compliance Section Ohio EPA P.O. Box 1049 Columhus, Ohio 43216-1049

Re: Akron, Ohio WPCS Stress Test Permit Waiver NPDES No. 3PFOOOOO*LD
Dear Mr. Novak, The City of Akron (the "City") plans to conduct stress testing of the Akron Water Pollution Control Station ("WPCS") in accordance with the enclosed Scope of Work. The City of Akron has discussed this Scope of Work with U.S. EPA, and has received U.S. EPA's provisional approval. As a result, the City respectfully requests that the Ohio EPA grant the City a waiver from meeting the WPCS NPDES permit requirements during proposed stress testing and the subsequent recovery period. The testing is scheduled for 2007 but is weather dependent and may continue in 200g. In additiOn, the final testing is currently scheduled for May/June 2008. As you are aware from our March 20, 2007 teleconference, the City is planning to perform a stress test of the WPCS secondary treatment system to determine if effluent permit parameters can be met at the higher peak flow rate of 120 MGD (versus the current 110 MGD maximum flow rate). Up to five, real-time, wet weather stress test trials are planned, assuming that actual weather conditions occur that support these tests. Depending upon the results of certain evaluations, it is possible that the fifth test will be done to determine if effluent parameters can be met at flows above 120 MGD. Each test will run for up to 30 hours and may result in the degradation of effluent quality for several days following the test.

1461102 v.OI \ 016756.0003

000051

State of Ohio Environmental Protection Agency

STREET ADDRESS:
Lazarus Government Center 50 W. Town St., Suite 700 Columbus, Ohio 43215
TELE: (614) 644·3020 FAX: (614) 644-3184 www.epa.stele.oh.us

MAILING ADDRESS:

P.O. Box 1049 Columbus,OH 43216-1049

August 7,2007 Richard Merolla, Service Director City of Akron 203 Municipal Building 146 South High Street Akron, OH 44308 Dear Mr. Merolla Based on our discussions with U.S. EPA we understand that you will be performing 5 stress tests of the entire Akron Wastewater Treatment Plant between now and mid-2008. Ohio EPA acknowledges that some violations of permit limits may occur during the stress testing as the limits of operation are determined, We will consider these factors in our data tracking and use appropriate discretion in reviewing the plant's compliance status. The stress test must be conducted to maintain sufficient solids and effective biomass in the treatment plant so that the plant returns to its normal operating status as soon as possible after the completion of each test event. Please notify the Northeast District Office as soon as possible in advance of the beginning and end of each stress test event. Sincerely,

b,i"-f- f!-/J1? C,r

1 j-

George Elmaraghy, PE" Chief Division of Surface Water
GE/EN

cc:

Sandy Cappotto, NEDO/DSW Paul Novak Margaret Malone, AGO

Ted Strickland, Governor Lee Fisher, Lieutenant Governor Chris Korleski, Director

000052

@

Printed on Recycled Paper

Ohio EPA is an Equal Opportunity Employer

Akron WPCS Activated Treatment Process Model and 2007 Stress Test Project Approach (Revised July 26, 2007; revisions shown in bold) Background Pursuant to the recommendations of the 2006 Stress Test Report, additional stress testing is proposed to be performed in 2007 to repeat selected protocol from the 2006 test under full-scale and real-time, wet weather conditions. A process model of the secondary treatment system is also proposed for development in advance of, and during the stress testing, to help define stress test alternative operating conditions and predict effluent quality for additional alternative operating scenarios. The proposed approaches and scope of services for these projects follows. Process Model - Approach ARCADIS proposes to utilize BioWin, a MS Windows-based simulator used world-wide in the analysis and design of wastewater treatment plants, to model the Akron WPCS secondary treatment system. The model will be used to: 1. Aid in identifying possible process modifications to optimize the biological process to sustain nitrification levels during hydraulic events of 120 MGD. Predict the combined effluent quality from two parallel processes, the existing secondary treatment system and the proposed Enhanced High Rate Clarification (EHRC) system treating secondary bypass flows.

2.

The model will be developed and calibrated using historical operating data. Additional operating data will be gathered during the first one or two 2007 Stress Test events and used to further calibrate the model for flows of approximately 120 MGD. The model may then be utilized to evaluate different process variables that may be altered in the full scale process to yield improved performance and results. Operational scenarios shown by the model to improve (better sustain) nitrification will be tested in one or more treatment trains during subsequent stress test events (up to a total of five). Depending on the results, additional stress tests for improved Total Phosphorus removal operational scenarios may be needed, but are not included at this time. The process model will recognize the three, individual final settling tanks, and associated depths, serving each process train and provide a general performance evaluation with respect to vertical physical properties, e.g. surface overflow rate, sludge settling velocities. The primary settling tanks will not be represented in the model because the BioWin software only considers total suspended solids removal on a static basis. This output would be inferior to the real-time primary effluent data proposed to be used to calibrate the model for the secondary treatment process evaluation. Process Model - Scope of Services ARCADIS will commit the necessary resources to develop a process model and coordinate with stress testing efforts. The process model development will include the following steps: Part I 1. Prepare and present an overview of BioWin capabilities and the overall modeling approach to City Engineering Bureau and WPCS representatives. Meet with City Project Team representatives to kick off the project (it is planned for this

2.

Page 1 of 6

000053

2007 Stress Test - Approach Additional stress testing will be performed in 2007 to repeat selected protocol from the 2006 test under full-scale and real-time, wet weather conditions. The 2006 stress tests revealed a stable sludge blanket in the final settling tanks for simulated hydraulic flows of 120 MGD (plus about 16% RAS), but a significant degradation of nitrification. CBOD5 and TSS concentrations were maintained within permit limits. Subsequently, it appears that nitrification is the limiting factor to processing up to 120 MGD through the Akron WPCS Secondary Treatment system. Critical seasonal periods to be further evaluated include 1) early summer, when water and air temperatures may be cool but "summer" nitrification limits are in effect; and 2) mid to late summer, with high temperatures and humidity, when the blowers are strained to provide sufficient air to the aeration tanks. The 2007 Stress Test protocol will focus on process parameters associated with the nitrification process within the activated sludge process (aeration basins). The stress test goal is to determine if adequate nitrification can be sustained under actual wet weather conditions with secondary influent flows of 120 MGD. Testing will be performed beginning in May, and may extend into September, on wet weather days that contribute sufficient wastewater flows to provide a 120 MGD rate through the secondary treatment process. The number of test events will ultimately depend on the number of weather events that result in test periods of 24 hours duration or more at 120 MGD. Five test events are anticipated at this time (refer to Item 6). If at any time during the test the activated system has complete failure by virtue of losing containment of biological solids in the final settling tanks, the test will be terminated. This will be defined as a turbidity measurement of 20 ntu on three or more of the TT effluent samples. (A correlation between effluent suspended solids concentration and turbidity was developed during the 2006 Stress test.) It is anticipated that a waiver will be obtained for final effluent violations that may occur during this testing. 2007 Stress Test - Scope of Services ARCADIS will provide the necessary staff to assist the City of Akron in performing a Stress Test of the Activated Treatment System at the Water Pollution Control Station. The following Scope of Services is proposed. 1. 2. Meet with City representatives to finalize the Stress Test Protocol. Coordinate with City representatives to transmit a variance request for a time period covering the 2007 Stress Testing. Assist the City in performing a Stress Test. ARCADIS personnel will be provided to perform any sampling and testing not normally performed by WPCS staff. A State of Ohio licensed laboratory analyst/operator and other technicians will be staffed at the WPCS during the duration of the tests. The technicians will perform laboratory testing in the WPCS laboratory, as needed, when space and time permit. A local contract laboratory will be utilized for supplemental testing. The following protocol will be followed: Stress Test Protocol 1) All Treatment Trains (Aeration Basins and associated final settling tanks) will be in service during the tests, except one select FST will be out of service to represent a typical condition (17 of 18 FSTs in service). This is intended to: • Most accurately represent actual conditions with multiple trains in service and dampen the effect of any errors or results that may be unique to one treatment train.

3.

Page 3 of 6

000054

from each TT will be taken and tested for CBOD and ammonia to evaluate recovery of any nitrification degradation, v, Set aside a volume of each CBOD5sampie for subsequent testing, as determined necessary upon completion of ammonia testing, Similarly, TSS testing will only be performed on samples corresponding to elevated turbidity measurements, Ammonia tests will be performed for all samples taken, vI. Upon observance of stress test failure, will identify the CBOD5, TSS and ammonia samples taken over the two hours preceding failure, and four hours after the failure, and test • The City will: I. Provide laboratory bench top space for ARCADIS personnel to perform testing of collected samples, iL Provide coolers and consumable laboratory supplies for the necessary testing, iiI. Perform all process operations, make process changes using existing controls upon request by ARCADIS (and following consultation with WPCS management) and share observations of process control issues during testing, iv, Through the duration of each stress test WPCS will monitor and record the following real-time data for later reference, Dick Anderson will set these trends in the DCS system, • TT effluent flow rate • All available Aeration Basin DO data and final effluent DO • Wastewater temperature

6) Test Schedule: Based generally on the flow statistics summarized in the NFA Report, approximately 6 events exceeding a total day flow of 120 MGD may be expected in a "typical" year from May to September, Therefore, it is reasonable to plan stress testing on 5 events. • Events 1 and 2 - Steady state test of 20 MGD/TT (peak total flow of 120 MGD) with all standard operating practices in effect Data from these tests will be input into the Process Model to evaluate possible process modifications to optimize, or at least sustain, nitrification levels to meet "summer" permit conditions, Events 3 through 5 - Steady state test conditions for at least two TTs, while up to four TTs are each operated with a different (variable) operating condition, These variable conditions may include: I. iL Increase RAS rate from 15% to 30% Set up a portable pump to pump a portion of the secondary influent directly to the head of the second pass (a simulated step feed) iiI. Increase total airflow to TT (aeration basin) iv, Feed caustic to TT (aeration basin)

•

It is necessary to perform all five test events during a warm weather period as defined in the Approach. Four of the five test events will be performed in 2007 !I a sufficient number of significant wet weather events occur. Test Event 5 will be planned for late May, early June 2008 regardless of the available wet weather in August and September 2007. Depending on the resuits and conclusions from the modeling, and Events 3 and 4, Event 5 will be planned to validate an alternative operating condition at 120 MGD, or possibly a higher flow rate.

Page 5 of 6

000055

Akron WPCS Activated Treatment Process Model and 2007 Stress Test Project Approach
(Revised July 26, 2007; revisions shown in bold)

Background Pursuant to the recommendations of the 2006 Stress Test Report, additional stress testing is proposed to be performed in 2007 to repeat selected protocol from the 2006 test under full-scale and real-time, wet weather conditions. A process model of the secondary treatment system Is also proposed for development in advance of, and during the stress testing, to help define stress test alternative operating conditions and predict effluent quality for additional alternative operating scenarios. The proposed approaches and scope of services for these projects follows. Process Model - Approach ARCADIS proposes to utilize BIoWIn, a MS Windows-based simulator used world-wide in the analysis and design of wastewater treatment plants, to model the Akron WPCS secondary treatment system. The model will be used to: 1. Aid In identifying possible process modifications to optimize the biological process to sustain nitrification levels during hydraulic events of 120 MGD. Predict the combined effluent quality from two parallel processes, the existing secondary treatment system and the proposed Enhanced High Rate Clarification (EHRC) system treating secondary bypass flows.

2.

The model will be developed and calibrated using historical operating data. Additional operating data will be gathered during the first one or two 2007 Stress Test events and used to further calibrate the model for flows of approximately 120 MGD. The model may then be utilized to evaluate different process variables that may be altered in the full scale process to yield improved performance and results. Operational scenarios shown by the model to improve (better sustain) nitrification will be tested in one or more treatment trains during subsequent stress test events (up to a total of five). Depending on the results, additional stress tests for Improved Total Phosphorus removal operational scenarios may be needed, but are not included at this time. The process model will recognize the three, Individual final settling tanks, and associated depths, serving each process train and provide a general performance evaluation with respect to vertical physical properties, e.g. surface overflow rate, sludge settling velocities. The primary settling tanks will not be represented in the model because the BIoWIn software only considers total suspended solids removal on a static basis. This output would be Inferior to the real-time primary effluent data proposed to be used to calibrate the model for the secondary treatment process evaluation. Process Model - Scope of Services ARCADIS will commit the necessary resources to develop a process model and coordinate with stress testing efforts. The process model development will Include the following steps:

Part I
1. Prepare and present an overview of BIoWIn capabilities and the overall modeling approach to City Engineering Bureau and WPCS representatives. Meet with City Project Team representatives to kick off the project (It is planned for this

2.

Page 1 of 6

000056

meeting to occur on the BioWin presentation day), Review and confirm the project scope and goals, ARCADIS will provide a list of requested data to the City, Given the anticipated project schedule, it will be important to obtain this data within a short time frame, Discuss and confirm with the City alterations made to the aeration basin air diffuser grids, 3,
4,

Order and deliver to the WPCS a portable sampler. Retrieve archived design and operating data for the aeration basin air diffuser system, Program the model to generally represent the existing process tankage and air diffuser system operating parameters, Review data provided by the city, including the previously completed stress test reports, Begin defining process operations by inputting operating data, Calibrate the model using available data, Review and input 2006 Stress Test data, if deemed appropriate, Obtain 2007 stress test data (refer to 2007 Stress Test scope tasks); evaluate test results using the modeL Run model simulations considering changes in process operations such as altering air supply, RAS rate, pH/alkalinity, etc, Identify process variations that appear to yield sustained nitrification levels, As part of the 2007 Stress Test, run a full-scale test of the process variations to support the modeL Compare actual results to modeL Run model simulations for flows greater than 120 MGD and consider the process operations altemative(s) shown most successful in previous model runs and Stress Test Events 3 and 4. Provide a summary of the model results. Provide recommendations regarding process modifications and/or improvements necessary to consistently operate the secondary treatment system at flows up to 120 MGD, or higher, while maintaining effluent ammonia nitrogen concentrations within permit limits, Recommendations will include a narrative description of improvements and an opinion of probable construction costs, as appropriate. If supported by the model and stress test results, a plan for additional stress testing in 2008 at flows above 120 MGD will also be presented.

5,

6,

7,

8.

9.

Part II 1, Review the Akron WPCS pilot test data associated with EHRC technology, An average of the operating efficiency for the ACTIFLO and Densadeg pilot units will be considered in the modeL Develop a second process model that considers an EHRC process, rated at 100 MGD, operating in parallel with the existing secondary treatment system at 120 MGD, Run the process model for various, appropriate scenarios and seasonal conditions to predict combined effluent quality of parallel processes, Provide observations and a final recommendation in regard to this current recommended element of the CSS-LTCP/NFA effort Develop report narrative sections to detail the model development, data used, various process alternatives considered and recommendations associated with Part I and Part IL

2,

3,

4.

Page 2 of 6

000057

2007 Stress Test - Approach Additional stress testing will be performed in 2007 to repeat selected protocol from the 2006 test under full-scale and real-time, wet weather conditions. The 2006 stress tests revealed a stable sludge blanket in the final settling tanks for simulated hydraulic flows of 120 MGD (plus about 16% RAS), but a significant degradation of nitrification. CBOD5 and TSS concentrations were maintained within permit limits. Subsequently, it appears that nitrification is the limiting factor to processing up to 120 MGD through the Akron WPCS Secondary Treatment system. Critical seasonal periods to be further evaluated include 1) early summer, when water and air temperatures may be cool but "summer" nitrification limits are in effect; and 2) mid to late summer, with high temperatures and humidity, when the blowers are strained to provide sufficient air to the aeration tanks. The 2007 Stress Test protocol will focus on process parameters associated with the nitrification process within the activated sludge process (aeration basins). The stress test goal is to determine if adequate nitrification can be sustained under actual wet weather conditions with secondary influent flows of 120 MGD. Testing will be performed beginning In May, and may extend into September, on wet weather days that contribute sufficient wastewater flows to provide a 120 MGD rate through the secondary treatment process. The number of test events will ultimately depend on the number of weather events that result In test periods of 24 hours duration or more at 120 MGD. Five test events are anticipated at this time (refer to Item 6). If at any time during the test the activated system has complete failure by virtue of losing containment of biological solids in the final settling tanks, the test will be terminated. This will be defined as a turbidity measurement of 20 ntu on three or more of the TT effluent samples. (A correlation between effluent suspended solids concentration and turbidity was developed during the 2006 Stress test.) It is anticipated that a waiver will be obtained for final effluent violations that may occur during this testing. 2007 Stress Test - Scope of Services ARCADIS will provide the necessary staff to assist the City of Akron in performing a Stress Test of the Activated Treatment System at the Water Pollution Control Station. The following Scope of Services is proposed. 1. 2. Meet with City representatives to finalize the Stress Test Protocol. Coordinate with City representatives to transmit a variance request for a time period covering the 2007 Stress Testing. Assist the City in performing a Stress Test. ARCADIS personnel will be provided to perform any sampling and testing not normally performed by WPCS staff. A State of Ohio licensed laboratory analyst/operator and other technicians will be staffed at the WPCS during the duration of the tests. The technicians will perform laboratory testing in the WPCS laboratory, as needed, when space and time permit. A local contract laboratory will be utilized for supplemental testing. The following protocol will be followed: Stress Test Protocol 1) All Treatment Trains (Aeration Basins and associated final settling tanks) will be in service during the tests, except one select FST will be out of service to represent a typical condition (17 of 18 FSTs in service). This is intended to: • Most accurately represent actual conditions with multiple trains in service and dampen the effect of any errors or results that may be unique to one treatment train.

3.

Page 3 of 6

000058

•

Reduce the complexity of flow balancing to select TTs during the test.

2) In preparation for the stress test, the City will check and adjust any hydraulic control structures/features that serve to control flow to the six (6) TTs, i.e. confirm all gates are in their normal position. Any isolation and control valves on the RAS will be in comparable position and the RAS rate will be set in the DCS to be equivalent. If all (18) FSTs are in service one will be selected and taken out of service by closing its distribution chamber isolation sluice gate. 3) In further preparation for each test, and within four hours before the flow rate increases to approximately 120 MGD, i.e. just before a stress test begins, the City will sample and test, or check online instrumentation and record values, for the following: • Current biological/operational characteristics of all six (6) treatment trains. This should include: MLSS, SVI, F/M ratio and RAS rate set-point. Parameters listed in Table 1 - Akron WPCS 2007 Stress Test SamplinglTesting Summary Dissolved oxygen levels at existing DO probe locations in aeration basins.

•

•

4) The Stress Test will proceed as follows: • The City will assess the current, total influent flow rates and forecasted weather to predict whether sufficient wet weather flows may be expected. ARCADIS representatives will then be contacted to respond. If total influent flows exceed 100 MGD, and are predicted to be sustained based on the forecasted rainfall, monitoring/recording and sampling as defined in Step 3 shall commence. ARCADIS will proVide a team to monitor and sample aeration basin and final effluent operating conditions at/near 120 MGD throughout the duration of the flow event, which goal is a 24-hour period at test conditions. During the test period, the City will monitor the TT 1 through 6 effluent flow rates and throttle sluice gates toward a closed position, as necessary, to limit flow to each TT to approximately 20 to 22 MGD as measured at each TT effluent meter.

•

5) Testing and monitoring during the stress test will be conducted to determine when the TTs (basins) under test have begun to "fall". The two basic parameters that will be utilized as indicators of treatment failure are the concentrations of suspended solids and ammonia in the final settling tank effluent. The presence of other contaminants such as CBOD5 and phosphorous require testing that does not produce real time results, but should be tested for later comparison during the analysis phase. The following will occur during the stress test: • ARCADIS will: Take grab samples following Table 1 Sampling/Testing Summary. Provide and operate a portable turbidity meter for real time determination of the presence of suspended solids in each TT effluent. Measure turbidity every 120 minutes to generally assess the process condition and compare to TSS values once received from the City lab. iii. Monitor the sludge blanket of selected FSTs at random intervals using a sludge judge prOVided by the city. iv. For four hours after the conclusion of any test event, an effluent grab sample i. ii.

Page 40f6

000059

from each TT will be taken and tested for CBOD and ammonia to evaluate recovery of any nitrification degradation. v. Set aside a volume of each CBOD5sampie for subsequent testing, as determined necessary upon completion of ammonia testing. Similariy, TSS testing will only be performed on samples corresponding to elevated turbidity measurements. Ammonia tests will be performed for all samples taken. vi. Upon observance of stress test failure, will identify the CBOD5, TSS and ammonia samples taken over the two hours preceding failure, and four hours after the failure, and test. • The City will:

i.

Provide laboratory bench top space for ARCADIS personnel to perform testing of collected samples. ii. Provide coolers and consumable laboratory supplies for the necessary testing. iii. Perform all process operations, make process changes using existing controls upon request by ARCADIS (and following consultation with WPCS management) and share observations of process control issues during testing. iv. Through the duration of each stress test WPCS will monitor and record the following real-time data for later reference. Dick Anderson will set these trends in the DCS system. • TT effluent flow rate • All available Aeration Basin DO data and final effluent DO • Wastewater temperature

6) Test Schedule: Based generally on the flow statistics summarized in the NFA Report, approximately 6 events exceeding a total day flow of 120 MGD may be expected in a "typical" year from May to Septem ber. Therefore, it is reasonable to plan stress testing on 5 events. • Events 1 and 2 - Steady state test of 20 MGDITT (peak total flow of 120 MGD) with all standard operating practices in effect. Data from these tests will be input into the Process Model to evaluate possible process modifications to optimize, or at least sustain, nitrification levels to meet "summer" permit conditions. Events 3 through 5 - Steady state test conditions for at least two TTs, while up to four TTs are each operated with a different (variable) operating condition. These variable conditions may include:

•

i. Ii.

Increase RAS rate from 15% to 30% Set up a portable pump to pump a portion of the secondary influent directly to the head of the second pass (a simulated step feed) iii. Increase total airflow to TT (aeration basin) iv. Feed caustic to TT (aeration basin)

It is necessary to perform all five test events during a warm weather period as defined in the Approach. Four of the five test events will be performed in 2007 if a sufficient number of significant wet weather events occur. Test Event 5 will be planned for late May, early June 2008 regardless of the available wet weather in August and September 2007. Depending on the results and conclusions from the modeling, and Events 3 and 4, Event 5 will be planned to validate an alternative operating condition at 120 MGD, or possibly a higher flow rate.

Page 5 of 6

000060

Following each Test Event ARCADIS and City representatives will meet to debrief, discuss preliminary test results and make any necessary adjustments and preparations for the next test. Copies of meeting minutes will be distributed to City, Ohio EPA and USEPA. Teleconferences with USEPA representatives will occur following debrief meeting minute distribution. 7) Site Egress and Safety Information • Primary Akron WPCS contact for the Stress Test is Mark Harshbarger; he can be reached by phone @ 330-928-1164, ext 439; or by radio at 439. Vince Zampelli is the secondary contact. Emergency contact - At anytime the On-duty operator at the Administration Building control console can be contacted at 330-928-1164, ext 416. The operator on duty at the North Blower Building is available by radio at 440. ARCADIS contacts: I. il. iiI. iv. • Jim Cooper - 330-441-1777 Nate Foote - 330-819-6718 Dave Frank - 330-603-2608 Mark Stoffan - 419-344-2627

•

•

Site Egress - After hours egress is possible through north gate; stop and contact on-duty operator from call box. Advise of name and business. A personal checkin at Administration Building is not required.

4.

Collect data from the City and compile into a report format. Review and evaluate data to proVide observations regarding the results of the stress test. Input data into the Process Model. Submit a draft 2007 Stress Test Report, which incorporates the Process Model evaluation, for City review. Meet with City representatives to review the draft report, receive comments and make revisions to the report. Finalize report in a structure suitable to stand as a separate report from the Akron WPCS NFA Report.

5.

6.

7.

8. Complete revisions to the Akron WPCS NFA Report, including the 2007 Stress Test Report as an added Appendix. If Stress Test Events 1 through 4 are completed by September 30, 2007 (weather dependent), the revised NFA Report and 2007 Stress Test Report will be ready for submission to the EPA by December 31, 2007. It is anticipated that recommendations presented at that time will be contingent on the results of Stress Test Event 5 to be performed in May/June 2008.

Page 6 of 6

000061

RICHARD A. MEROlLA Service Director VALERIE STRAW Executive Assistant

JEFF FUSCO
Deputy Director
jOHNWVALLE Deputy Director

DONALD L PLUSQUELUC Mayor

DEPARTMENT OF PUBLIC SERVICE
166 S. High St., Room 201 Akron, OH 44308 Phone: (330) 375-2270 FAX: (330) 375-2100

August 2, 2007

Mr. Paul Novak, Manager Permits and Compliance Section
Ohio EPA P.O. Box 1049 Columbus, Ohio 43216-1049

Re: Akron, Ohio WPCS Stress Test Permit Waiver NPDES No. 3PFOOOOO*LD
Dear Mr. Novak, The City of Aleron (the "City") plans to conduct stress testing of the Akron Water Pollution Control Station ("WPCS") in accordance with the enclosed Scope ofWor1c. The City ofAkron has discussed this Scope of Work with U.S. EPA, and has received U.S. EPA's provisional approval. As a result, the City respectfully requests that the Ohio EPA grant the City a waiver from meeting the WPCS NPDES permit requirements during proposed stress testing and the subsequent recovery period.. The testing is scheduled for 2007 but is weather dependent and may continue in 2008. In addition, the final testing is currently scheduled for May/June 2008. As you are aware from our March 20, 2007 teleconference, the City is planning to perform a stress test of the WPCS secondary treatment system to determine if effluent permit parameters can be met at the higher peak flow rate of 120 MGD (versus the current 110 MGD maximum flow rate). Up to five, real-time, wet weather stress test trials are planned, assuming that actual weather conditions occur that support these tests_ Depending upon the results of certain evaluations, it is possible that the fifth test will be done to determine if effluent parameters can be met at flows above 120 MGD. Each test will run for up to 30 hours and may result in the degradation of effluent quality for several days following the test.

1461102 v_Ol \ 016756,0003

000062

Please cOI1Bider this request at your earliest opportunity. We are :finalizing the test protocol at this time so that we are prepared for the next significant rainfall event. Please contact Brian Gresser at 330-928-1164X430 if there are any questions. !tcereIY ,

\~Vv~
Richard Merolla, Service Director City of Akron Cc: Sandy Cappotto, Ohio EPA-NEDO Ron Bell, Ohio EPA-NEDO

1461102v_OI \016756.0003

000063

Akron WPCS Activated Treatment Process Model and 2007 Stress Test Project Approach

(Revised July 26, 2007; revisions shown in bold)
Background Pursuant to the recommendations of the 2006 Stress Test Report, additional stress testing is proposed to be performed in 2007 to repeat selected protocol from the 2006 test under full-scale and real-time, wet weather conditions. A process model of the secondary treatment system is also proposed for development in advance of, and during the stress testing, to help define stress test alternative operating conditions and predict effluent quality for additional alternative operating scenarios. The proposed approaches and scope of services for these projects follows. Process Model· Approach ARCADIS proposes to utilize BioWin, a MS Windows-based simulator used world-wide in the analysis and design of wastewater treatment plants, to model the Akron WPCS secondary treatment system. The model will be used to: 1. Aid in identifying possible process modifications to optimize the biological process to sustain nitrification levels during hydraulic events of 120 MGD. Predict the combined effluent quality from two parallel processes, the existing secondary treatment system and the proposed Enhanced High Rate Clarification (EHRC) system treating secondary bypass flows.

2.

The model will be developed and calibrated using historical operating data. Additional operating data will be gathered during the first one or two 2007 Stress Test events and used to further calibrate the model for flows of approximately 120 MGD. The model may then be utilized to evaluate different process variables that may be altered in the full scale process to yield improved performance and results. Operational scenarios shown by the model to improve (better sustain) nitrification will be tested in one or more treatment trains during subsequent stress test events (up to a total of five). Depending on the results, additional stress tests for improved Total Phosphorus removal operational scenarios may be needed, but are not included at this time. The process model will recognize the three, individual final settling tanks, and associated depths, serving each process train and provide a general performance evaluation with respect to vertical physical properties, e.g. surface overflow rate, sludge settling velocities. The primary settling tanks will not be represented in the model because the BioWin sofitware only considers total suspended solids removal on a static basis. This output would ba inferior to the real-time primary effluent data proposed to be used to calibrate the model for the secondary treatment process evaluation. Process Model· Scope of Services ARCADIS will commit the necessary resources to develop a process model and coordinate with stress testing efforts. The process model development will include the following steps: Part I 1. Prepare and present an overview of BioWin capabilities and the overall modeling approach to City Engineering Bureau and WPCS representatives. Meet with City Project Team representatives to kick off the project (it is planned for this

2.

Page 1 of 6

000064

meeting to occur on the BioWin presentation day). Review and confirm the project scope and goals. ARCADIS will provide a list of requested data to the City. Given the anticipated project schedule, it will be important to obtain this data within a short time frame. Discuss and confirm with the City alterations made to the aeration basin air diffuser grids. 3. 4. Order and deliver to the WPCS a portable sampler. Retrieve archived design and operating data for the aeration basin air diffuser system. Program the model to generally represent the existing process tankage and air diffuser system operating parameters. Review data provided by the city, including the previously completed stress test reports. Begin defining process operations by inputting operating data. Calibrate the model. using available data. Review and input 2006 Stress Test data, if deemed appropriate. Obtain 2007 stress test data (refer to 2007 Stress Test scope tasks); evaluate test results using the model. Run model simulations considering changes in process operations such as altering air supply, RAS rate, pH/alkalinity, etc. Identify process variations that appear to yield sustained nitrification levels. As part of the 2007 Stress Test, run a full-scale test of the process variations to support the model. Compare actual results to model. Run model simulations for flows greater than 120 MGD and consider the process operations alternative(s) shown most successful in previous model runs and Stress Test Events 3 and 4. Provide a summary of the model results. Provide recommendations regarding process modifications and/or improvements necessary to consistently operate the secondary treatment system at flows up to 120 MGD, or higher, while maintaining effluent ammonia nitrogen concentrations within permit limits. Recommendations will include a narrative description of improvements and an opinion of probable construction costs, as appropriate. If supported by the model and stress test results, a plan for additional stress testing in 2008 at flows above 120 MGD will also be presented.

5.

6.

7. 8.

9.

Part II

1.

Review the Akron WPCS pilot test data associated with EHRC technology. An average of the operating efficiency for the ACTIFLO and Densadeg pilot units will be considered in the model. Develop a second process model that considers an EHRC process, rated at 100 MGD, operating in parallel with the existing secondary treatment system at 120 MGD. Run the process model for various, appropriate scenarios and seasonal conditions to predict combined effluent quality of parallel processes. Provide observations and a final recommendation in regard to this current recommended element of the CSS·LTCP/NFA effort. Develop report narrative sections to detail the model development, data used, various process altematives considered and recommendations associated with Part I and Part II.

2. 3.

4.

Page 2 of6

000065

2007 Stress Test - Approach
Additional stress testing will be performed in 2007 to repeat selected protocol from the 2006 test under full-scale and real-time, wet weather conditions. The 2006 stress tests revealed a stable sludge blanket in the final settling tanks for simulated hydraulic flows of 120 MGD (plus about 16% RAS), but a significant degradation of nitrification. CBOD5 and TSS concentrations were maintained within permit limits. Subsequently, it appears that nitrification is the limiting factor to processing up to 120 MGD through the Akron WPCS Secondary Treatment system. Critical seasonal periods to be further evaluated include 1) early summer, when water and air temperatures may be cool but "summer" nitrification limits are in effect; and 2) mid to late summer, with high temperatures and humidity, when the blowers are strained to provide sufficient air to the aeration tanks. The 2007 Stress Test protocol will focus on process parameters associated with the nitrification process within the activated sludge process (aeration basins). The stress test goal is to determine if adequate nitrification can be sustained under actual wet weather conditions with secondary influent flows of 120 MGD. Testing will be performed beginning in May, and may extend into September, on wet weather days that contribute sufficient wastewater flows to provide a 120 MGD rate through the secondary treatment process. The number of test events will ultimately depend on the number of weather events that result in test periods of 24 hours duration or more at 120 MGD. Five test events are anticipated at this time (refer to ttem 6). If at any time during the test the activated system has complete failure by virtue of losing containment of biological solids in the final settling tanks, the test will be terminated. This will be defined as a turbidity measurement of 20 ntu on three or more of the IT effluent samples. (A correlation between effluent suspended solids concentration and turbidity was developed during the 2006 Stress test.) It is anticipated that a waiver will be obtained for final effluent violations that may occur during this testing.

2007 Stress Test - Scope of Services
ARCADIS will provide the necessary staff to assist the City of Akron in performing a Stress Test of the Activated Treatment System at the Water Pollution Control Station. The following Scope of Services is proposed. 1. 2. Meet with City representatives to finalize the Stress Test Protocol. Coordinate with City representatives to transmit a variance request for a time period covering the 2007 Stress Testing. Assist the City in performing a Stress Test. ARCADIS personnel will be provided to perform any sampling and testing not normally performed by WPCS staff. A State of Ohio licensed laboratory analysUoperator and other technicians will be staffed at the WPCS during the duration of the tests. The technicians will perform laboratory testing in the WPCS laboratory, as needed, when space and time permit. A local contract laboratory will be utilized for supplemental testing. The following protocol will be followed: Stress Test Protocol 1) All Treatment Trains (Aeration Basins and associated final settling tanks) wili be in service during the tests, except one select FST will be out of service to represent a typical condition (17 of 18 FSTs in service). This is intended to: • Most accurately represent actual conditions with multiple trains in service and dampen the effect of any errors or results that may be unique to one treatment train.

3.

Page 30f6

000066

• 2)

Reduce the complexity of flow balancing to select TIs during the test.

In preparation for the stress test, the City will check and adjust any hydraulic control structures/features that serve to control flow to the six (6) TIs, i.e. confirm all gates are in their normal position. Any isolation and control valves on the RAS will be in comparable position and the RAS rate will be set in the DCS to be equivalent. If all (18) FSTs are in service one will be selected and taken out of service by closing its distribution chamber isolation sluice gate.

3)

In further preparation for each test, and within four hours before the flow rate increases to approximately 120 MGD, I.e. just before a stress test begins, the City will sample and test, or check online instrumentation and record values, for the following: • Current biological/operational characteristics of all six (6) treatment trains. This should include: MlSS, SVI, F/M ratio and RAS rate set-point. Parameters listed in Table 1 - Akron WPCS 2007 Stress Test SamplingfTesting Summary Dissolved oxygen levels at existing DO probe locations in aeration basins.

•

•

4) The Stress Test will proceed as follows: • The City will assess the current, total influent flow rates and forecasted weather to predict whether sufficient wet weather flows may be expected. ARCADIS representatives will then be contacted to respond. If total influent flows exceed 100 MGD, and are predicted to be sustained based on the forecasted rainfall, monitoring/recording and sampling as defined in Step 3 shall commence. ARCADIS will provide a team to monitor and sample aeration basin and final effluent operating conditions at/near 120 MGD throughout the duration of the flow event, which goal is a 24-hour period at test conditions. During the test period, the City will monitor the TI 1 through 6 effluent flow rates and throttle sluice gates toward a closed position, as necessary, to limit flow to each TI to approximately 20 to 22 MGD as measured at each TI effluent meter.

•

5) Testing and monitoring during the stress test will be conducted to determine when the TIs (basins) under test have begun to "fail". The two basic parameters that will be utilized as indicators of treatment failure are the concentrations of suspended solids and ammonia in the final settling tank effluent. The presence of other contaminants such as CBOD5 and phosphorous require testing that does not produce real time results, but should be tested for later comparison during the analysis phase. The following will occur during the stress test: • ARCADIS will: I. il. Take grab samples following Table 1 SamplinglTesting Summary. Provide and operate a portable turbidity meter for real time determination of the presence of suspended solids in each TI effluent. Measure turbidity every 120 minutes to generally assess the process condition and compare to TSS values once received from the City lab. iii. Monitor the sludge blanket of selected FSTs at random intervals using a sludge judge provided by the city. iv. For four hours after the conclusion of any test event, an effluent grab sample

Page 4 of6

000067

from each IT will be taken and tested for CBOD and ammonia to evaluate recovery of any nitrification degradation. v. Set aside a volume of each CBOD5sampie for subsequent testing, as determined necessary upon completion of ammonia testing. Similarly, TSS testing will only be performed on samples corresponding to elevated turbidity measurements. Ammonia tests will be performed for all samples taken. vi. Upon observance of stress test failure, will identify the CBOD5, TSS and ammonia samples taken over the two hours preceding failure, and four hours after the failure, and test. • The City will: Provide laboratory bench top space for ARCADIS personnel to perform testing of collected samples. ii. Provide coolers and consumable laboratory supplies for the necessary testing. iii. Perform all process operations, make process changes using existing controls upon request by ARCADIS (and following consultation with WPCS management) and share observations of process control issues during testing. iv. Through the duration of each stress test WPCS will monitor and record the following real-time data for later reference. Dick Anderson will set these trends in the DCS system. • IT effluent flow rate • All available Aeration Basin DO data and final effluent DO • Wastewater temperature 6) Test Schedule: Based generally on the flow statistics summarized in the NFA Report, approximately 6 events exceeding a total day flow of 120 MGD may be expected in a "typical" year from May to September. Therefore, it is reasonable to plan stress testing on 5 events. • Events 1 and 2 - Steady state test of 20 MGDm (peak total flow of 120 MGD) with all standard operating practices in effect. Data from these tests will be input into the Process Model to evaluate possible process modifications to optimize, or at least sustain, nitrification levels to meet "summer" permit conditions. Events 3 through 5 - Steady state test conditions for at least two ITs, while up to four ITs are each operated with a different (variable) operating condition. These variable conditions may include: Increase RAS rate from 15% to 30% Set up a portable pump to pump a portion of the secondary influent directly to the head of the second pass (a simulated step feed) iii. Increase total airflow to IT (aeration basin) iv. Feed caustic to IT (aeration basin) i. ii. i.

•

It is necessary to perform alf five test events during a warm weather period as defined in the Approach. Four of the five test events wiff be performed in 2007 if. a sufficient number of significant wet weather events occur. T~st Event 5 wiff be planned for late May, early June 2008 regardless of the available wet weather in August and September 2007. Depending on the results and conclusions from the modeling, and Events 3 and 4, Event 5 wiff be planned to validate an alternative operating condition at 120 MGD, or possibly a higher flow rate.

Page 5 of6

000068

Following each Test Event ARCADIS and City representatives will meet to debrief, discuss preliminary test results and make any necessary adjustments and preparations for the next test. Copies of meeting minutes will be distributed to City, Ohio EPA and USEPA. Teleconferences with USEPA representatives will occur following debrief meeting minute distribution.
7) Site Egress and Safety Information • Primary Akron WPCS contact for the Stress Test is Mark Harshbarger; he can be reached by phone @ 330-928-1164, ext 439; or by radio at 439. Vince Zampelli is the secondary contact. Emergency contact - At anytime the On-duty operator at the Administration Building control console can be contacted at 330-928-1164, ext 416. The operator on duty at the North Blower Building is available by radio at 440. ARCADIS contacts: i. ii. iii. iv. • Jim Cooper-330-441-1777 Nate Foote - 330-819-6718 Dave Frank - 330-603-2608 Mark Stoffan - 419-344-2627

•

•

Site Egress - After hours egress is possible through north gate; stop and contact on-duty operator from call box. Advise of name and business. A personai checkin at Administration Building is not required.

4.

Collect data from the City and compile into a report format. Review and evaluate data to provide observations regarding the results of the stress test. Input data into the Process Model. Submit a draft 2007 Stress Test Report, which incorporates the Process Model evaluation, for City review. Meet with City representatives to review the draft report, receive comments and make revisions to the report. Finalize report in a structure suitable to stand as a separate report from the Akron WPCS NFA Report.

5.

6.

7.

8. Complete revisions to the Akron WPCS NFA Report, including the 2007 Stress Test Report as an added Appendix. If Stress Test Events 1 through 4 are completed by September 30, 2007 (weather dependenQ, the revised NFA Report and 2007 Stress Test Report will be ready for submission to the EPA by December 31, 2007. It is anticipated that recommendations presented at that time will be contingent on the results of Stress Test Event 5 to be performed in May/June 2008.

Page 6 of6

000069

DEPARTMENT Of PUBLIC SERVICE AKRON ENGINEERING BUREAU
166 SOUTH HIGH STREET, ROOM 701 AKRON, OHIO 44308-1652 Phone: (330) 375-2355, Fax: (330) 375-2288
E-mail: AkronEngineering@ci.akron.oh.us

DAVID J. CEllK, P.E. CITY ENGINEER

Donald L Plusquellic
Mayor

December 29,2006

United States Environmental Protection Agency Attn: Jenny Davison Water Enforcement and Compliance Assurance Branch Water Division, WC-15J 77 West Jackson Blvd. Chicago, IL 60604

Re:

In the Matter of the City of Akron, Ohio Docket No. V-W-07-308-02

Dear Ms. Davison: Enclosed please find the following two reports: 1) Akron Water Pollution Control Station No Feasible Alternative (NFA) , dated December 29, 2006; and 2) Akron Financial Assessment and Affordability Analysis for the GSO LrGP, dated December 29, 2006. Enclosed with each report is a compact disc that contains an electronic version of the respective report. These reports contain information that is responsive to the above-referenced Section 308 Information Request (the "Information Request"). The City of Akron intends to submit formal objections and requests for clarification in the near future. The City of Akron aiso intends to submit a formal response to the Information Request within the timeframes specified within the Information Request. The submission of the enclosed reports at this time is subject to the City of Akron's subsequent submissions. Finally, consistent with the City of Akron's agreement with U.S. EPA and the Department of Justice, the Akron Financial Assessment and Affardability Analysis far the GSa LrGP is being submitted in two parts. The enclosed document contains Sections 1, 2 and 3, which is Part One of the report. The City of Akron intends to submit Section 4, which is Part Two of the report, by January 22, 2007. As set forth in the enclosed report, the financial assessment is comprised of both Part One and Part Two and, thus, a proper evaluation can only be made upon review of both Part One and Part Two.

000070

Sincerely,

{ Iui~{
cc: Paul Novak, DSW/OHIO EPA ~
1394807.016756.0003

~AKRON

Patrick D. Gsellman

iltr-

000071

Sep 08 06 09148

Akron Water - Admin

330-375-2072
JEFF FUSCO
Deputy Director

p1

GERALD HOLLAND Service Dfrector

VALERIE STRAW
Executive Assistant

JOHN W. VALLE Deputy Director

DONALD L. PLUSQUELLlC Mayor DEPARTMENT OF PUBLIC SERVICE 166 S. High St., Room 201

Akron,OH 44308 Phone: (330) 375-2270
Fax: (330) 375-2100

September 7, 2006

VIA FACSIMILE @ (614) 644-2745 & REGULAR U,S. MAIL Mr. Paul Novak Manager, Permits Programs Division of Surface Water Ohio Environmental Protection Agency Lazarus Government Center P.O. Box 1049 Columbus, OH 43216-1049 Re: Ohio EPA Draft Permit No.: 3PFOOOOO'LD Ohio EPA Public Notice No.: 06-08-066

Dear Mr. Novak: On August 28, 2006, the Ohio EPA issued the referenced public notice, along with a fact sheet and a draft NPDES permit for the City of Akron's Water Pollution Control Station ("WPCS") and sewage collection system. The public notice provides for a 3D-day comment period which is insufficient time for us to review the draft permit and the associated materials, retain consultants, review the issues and prepare written comments. For the reasons set forth below, Akron requests a 90-day extension to the comment deadline, until December 28, 2006. The draft permit contains several new and complicated terms, conditions and limitations. There is a significant financial cost associated with these new terms, conditions and limitations. As a result, Akron needs more time in order to fully evaluate and comprehend the requirements of the draft permit and prepare a comprehensive set of comments. In addition, the draft permit contains several conditions and references relating to Akron's combined sewer overflow ("CSO") long-term control plan ("LTCP"). As recognized within Ohio EPA's fact sheet, Akron submitted its csa LTCP in 1998, along with updates in

000072

Sep 08 06 09148

Akmn Water - Admin

330-375-2072

p2

Mr. P. Novak September 7, 2006 Page 2 September 2000 and May 2002. As further recognized in Ohio EPA's fact sheet, Akron is in the process of negotiating the approval of the LTCP with U.S. EPA and the Department of Justice. Despite the fact that Akron is still awaiting U.S. EPA's approval of its CSO LTCP, the draft permit requires the implementation of CSO controls, including but not limited to, the construction of a 20 million gallon storage basin at the WPCS and the construction of a high rate sedimentation system. Akron is concerned that the conditions within the draft permit may be inconsistent with the LTCP, once approved by U.S. EPA. Ps a result, Akron needs additional time to evaluate these conditions in conjunction with its ongoing negotiations.

esa

Finally, it should be noted that Akron's application has been pending for apprOXimately eight years. We anticipate that several of the conditions that were included in the application have changed since the application was submitted. The original application needs to be reviewed to determine if the changed conditions have a significant impact on assumptions used to prepare this draft. The Ohio EPA's timely consideration of this request is appreciated. In the event you have any questions or need any further information, please contact Randall Monteith, P.E., Pilots Administrator, at 330-375-2627. Sincerely,

/J.,.JiD.~
Gerald O. Holland, Director Department of Public Service GOH:pt c: Mayor Donald L Plusquellic Michael L. McGlinchy, Akron Public Utilities Bureau Manager William Skrowronski, Chief, NEDO Patty L. Smith, Permit Processing Unit, DSW/CO Ron Bell, DSWINEDO

000073

ENGINEERS. ARCHITECTS. SCIENTISTS PLANNERS. SURVEYORS

DLZ
TECHNICAL MEMORANDUM
Geary A. Visca, P.E. January 25, 2005

To: From: Date:

Brad Beckert, P.E., P.S., Project Manager

SUbject: Racks 29-30 aud Northside Interceptor Tunnel

Racks 29 aud 30 When the City of Akron Long-Term Control Plan was submitted in April of 2000, the CSO Rack 4031 Basin (Basin) was to be located on the west side of the Little Cuyahoga River. The Preliminary Design Report for the Basin concluded that it was not feasible to construct it at this location. The Preliminary Design Report instead recommended that the Basin be constructed on the east side of the Little Cuyahoga River on the site of the original City of Akron WWTP. Due to this change in location, it became apparent that the overflow from Rack 30 should be taken to the Basin since its overflow is less than 20 feet from the outside wall of the Basin. In the City of Akron Long-Term Control Plan, the selected control measure for Rack 30 was to separate its system As shown on the implementation schedule, this was one of the last projects to be completed. The primary purpose of this Technical Memorandum is to show that connecting the oyerflow from Rack 30 to the Basin will not impact its operation, and that implementing this solution is feasible and logical. The secondary purposc of this Technical Memorandum is to examine the feasibility of diverting the overflow from Rack 29 to the Basin. Rack 29 is located on Cuyahoga Street just south of Rack 30. In the City of Akron Long-Term Control Plan, the selected control measure for Rack 29 was to divert the overflow from Rack 29 and 27 to a treatment basin. Rack 29 would contribute 60% of the overflow volume to this treatment basin. In the City of Akron Long-Term Control Plan, Section 2, Table 2-5, there are flow values for each one of the racks for the existing system. These values were developed from the model simulation of the City of Akron's collection system for the year 1994. These flow values include the peak overflow rate and volume being discharged by each rack. Also included in this table is the number of overflow events. The table is attached to this memorandum. The following values were listed for Racks 29 and 30:

Rack 29 30

Peak Flow (MGD) 18.0 7.9

Overflow Volume (MG)
11.5 4.1

Volume per Nnmber of Overflow Event Overflow Events
(MG)

45 25

0.256 0.164

2162 Front Street. Cuyahoga Falls. OH 44221-3288 • Telephone (330) 923-0401 • Fax (330) 928-1029 With Offices Throughout The Midwest www.dlzcorp.com 000074

ENGINEERS. ARCHITECTS. SCIENTISTS PLANNERS. SURVEYORS

DLZ

The Basin has 10.000 MG of storage. The City of Akron Long-Term Control Plan recommended a design volume of 9.500 MG for the Basin. This additional 0.500 MG of storage was considered reserve storage, but it is sufficient to handle the average overflow volume per event of 0.420 MG from Racks 29 and 30. The 36-inch overflow line from Rack 30, which has a 2.00% slope and a capacity of 60.9 MGD, is more than sufficient to convey the peak overflow rate from Racks 29 and 30 of25.9 MGD to the Basin. Controlling the overflows from Racks 29 and 30 in the interim can only benefit the water quality of the Little Cuyahoga River. These racks would have been included in the design for the Basin except that the original location for this Basin was on the west side of the Little Cuyahoga River, which made any connections cost prohibitive and hydraulically impossible. Now that the Basin is located on the east side of the Little Cuyahoga River and the overflow from Rack 30 is less than 20 feet from the outside wall of the Basin, it is now very feasible and logical to discharge the overflow from Racks 29 and 30 to this Basin as a short-term solution, and quite possibly as a long-term solution. As outlined in the City of Akron Long-Term Control Plan, the operation and performance of the Basin will be monitored once it is placed into operation. If it is found that the Basin is not performing as expected due to the additional overflow volume from Racks 29 and 30, there is still sufficient time to make adjustments in the City of Akron Long-Term Control Plan implementation. These adjustments could include partially separating the Rack 30 system or diverting a portion of the flow from Rack 29 to the planned Rack 29-27 treatment basin. Implementing this plan maintains the integrity of the City of Akron Long-Term Control Plan while reducing the volume of overflow that is currently being discharged to the Little Cuyahoga River from Racks 29 and 30.

Northside Interceptor Tunnel Another item that needs to be considered in the design of the new sewer line that is to convey the overflow from Racks 29 and 30 to the Basin is the overflow from the Northside Interceptor Tunnel. In reviewing the City of Akron Loug-Term Control Plan, Ohio EPA requested that several alternatives be evaluated. One of the alternatives was to provide additional treatment to the overflows from the Basin and Northside Interceptor Tunnel using ballasted flocculation. To address this issue, an addendum to the City of Akron Long-Term Control Plan was prepared in 2002. (Note: For this alternative, the peak flow rate from the Northside Interceptor Tunnel overflow was modeled at 48 MGD.) The selected alternative consisted of routing the overflow from the Northside Interceptor Tunnel to the Basin and treating both overflows at a single treatment unit. To meet the requirements of this alternative, the new sewer line that will be constructed to convey the overflow from Racks 29 and 30 into the Basin would need to be upsized from a 36-inch to a 42-inch. The 42-inch sewer line @ 1.30% would be capable of conveying the peak overflow rate of73.9 MGD (48 MGD plus 25.7 MGD).

2162 Front Street. Cuyahoga Falls, OH 44221-3288. Telephone (330) 923-0401. Fax (330) 928-1029 With Offices Throughout The Midwest 000075 www.dlzcorp.com

DEPARTMENT OF PUBLIC SERVICE AKRON ENGINEERING BUREAU
166 SOUTH HIGH STREET, ROOM 701 AKRON, OHIO 44308-1652
Phone: (330) 375-2355, Fax: (330),;l;;;~fil(lsz.1 E-mail: AkronEngineering@ci.akroMc41.lQ};l°
DAVID I. CElIK, P.E.

M1 g: 1;'3

CITY ENGINEER

Donald L Plusquellic
Mayor

August 22, 2002

Mr. Paul Novak Division of Surface Water Ohio Environmental Protection Agency Lazarus BUilding 122 South Front Street P.O. Box 1049 Columbus, Ohio 43216-1049 Re: Ohio Canal and the City of Akron's LTCP

Dear Mr. Novak: During our May 30, 2002 meeting concerning the City of Akron's Long Term Control Plan ("LTCP"), you expressed a concern about the timing for implementing controls for specific CSO's that discharge into the Ohio Canal. Your concern was based upon observations made during the Ohio EPA's July 19, 2001 site visit of the City of Akron's sewer system and wastewater treatment plant. In order to address this concern, we agreed to review records regarding the condition of the Ohio Canal on July 19, 2001. As we discussed during our May 30, 2002 meeting, and as confirmed by the documents enclosed with this letter, the condition of the Ohio Canal on July 19, 2001 was the result of a short, but intense rain event that ended immediately prior to the site visit. During the July 19, 2001 site visit, the Ohio Canal did have a grayish color, and it contained a noticeable amount of trash and floatables. As you may recall, this observation was made from the point that the Ohio Canal exits the enclosure behind the former Ohio Edison steam plant and continuing downstream just south of the North Street Bridge. Since this is not the typical condition of the Ohio Canal, Dave Crandell contacted the Sewer Maintenance Department to determine whether or not there was a recent CSO event. Due to the fact that his call was made during a shift change, Dave was only able to speak with a temporary employee who was unable to confirm that there was a recent CSO event. Dave may have conveyed this information to you and Ron during the site visit. After the site visit, Dave made a second contact with the Sewer Maintenance Department and obtained more accurate information. As set forth in the enclosed records, a short duration, intense storm event occurred at scattered locations in the

000076

Mr. Paul Novak August20,2002 Page 2 Akron area, with the heaviest rain falling in West Akron. The storm event resulted in up to 0.57 inches of rain falling in certain areas and combined sewer overflows on the Ohio Canal at Racks #4, #16, #17, #18, #19, #20 and #37. 1 It should be further noted that there was no significant rainfall during the preceding two months. Therefore, the grayish water and trash was most likely caused by a first flush of accumulated deposits within the combined sewer. Moreover, I returned to this same area the following day. At that time the Ohio Canal appeared to be clear, and the grayish color was no longer present. Thus, the condition of the Ohio Canal during the July 19, 2001 site visit was the result of an intense, short duration storm event that flushed deposits from the combined sewer shortly before the visit. Moreover, as represented during our May 30, 2002 meeting, the City of Akron has recently inspected the sewer in the vicinity of the Ohio Canal. As a result, it was determined that the sewer is in good condition. Therefore, in light of all of the priorities involved with implementing the LTCP, the timing for implementing CSO controls for the Ohio Canal, as set forth in the current implementation schedule, is appropriate and consistent with the federal and Ohio CSO policies. In the event you need any additional information or care to further discuss this issue, please do not hesitate to give me a call at (330) 375-2357.

~6etL
PDG/JB/rc Attachments cc:
2002~08-22

Patrick D. Gsellman, P.E. Environmental Division Manager

J. Kidder, M. McGlinchy, Ron Bell (Ohio EPA), File F-04, Env. Div. File
ohio canal pdgjb rc

1 Racks #13, #14 and #24 overflowed to the Little Cuyahoga River during the July 19, 2001 storm event. The infiuent fiow at the WPCS peaked at 140 MGD. and there was no discharge from the secondary bypass.

000077

DATE
07/19/2001

TOTAL DAILY OVERFLOWS # HOURS MGAL

11
#

5.42

0.281

SITE

HOURS MGAL

R04 R13 R14 R16 R17 R18 R19 R20 R24 R37

1 1 1 1 1 2 1 1 1 1

0.64 0.48 0.48 1.73 0.36 0.08 0.02 0.76 0.71 0.16

0.061 0.041 0.018 0.030 0.007 0.010 0.000 0.081 0.029 0.004

000078

July 19th, 2001 Rainfall Summary
G1 G2 G3 G4 85 G6 G7 G8 G9 G10 Gil G12 813

Tolal

0

0.57

I

0

0.08

i

0.21

0,2

0

0

0,08

I

0

0.02

I

0.03

i

0.16

000079

IO~EPH P. KIDDER
Service Director

LUNZY O. ARMSTRONG
Deputy Director

VALERIE STRAW
Executive Assistant

JEFF FUSCO
Deputy Director

DONALD L PLUSQUElliC
Mayor

DEPARTMENT OF PUBLIC SERVICE
1665. High 5t., Room 201 Akron, OH 44308 Phone: (330) 375-2270 FAX: (330) 375-2100

May 28, 2002

Mr. Paul Novak, P.E.
Manager Permits & Compliance Section Division of Surface Water, Ohio EPA Lazarus Government Center 122 S. Front Street Columbus, Ohio 43215-1099
Re: City of Akron CSO Long Term Control Plan (LTCP)

Dear Mr. Novak: As previously discussed, the City of Akron believes its submitted CSO LTCP complies with all applicable state and federal guidance and policy documents. At the request of Ohio EPA, Akron agreed to (l) conduct a further evaluation of express sewers for the major separate sewer areas upstream of combined sewer areas, (2) evaluate additional treatment at the proposed CSO facility for the Ohio Canal Tunnel, CSO Rack 40, Northside Tunnel and WPCS Secondary By-pass and (3) evaluate the proposed schedule based on the staging requirements of the various projects, constructability, water quality improvements and City of Akron sewer user rate financial analysis. Please fmd attached the following proposed additions to the City of Akron Long Term Control Plan dated April 7, 2000 (modified September 5, 2000).
1.

2. 3. 4.

2002 Long Term Control Plan, Additional Evaluations (Proposed Integrated Alternative #2). a. Express Sewers b. Enhanced High Rate Clarification (EHRC) c. Additional Treatment at WPCS City of Akron LTCP - 30 Year Implementation Schedule with Additional Treatment (Yearly Increases Scenario) City of Akron LTCP - 30 Year Implementation Schedule with Additional Treatment (Five Year Increases Scenario) New Section 5.4

000080

Mr. Paul Novak, P.E. May 28, 2002 Page 2 My staff looks forward to meeting with you on May 30, 2002 to discuss the enclosed revised pages. In the meantime, should you have any questions or need further information in advance of the meeting, please do not hesitate to call Patrick Gsellman at 330-375-2357.

'ihKP~
Joseph P. Kidder, Director Department of Public Service JPK/rc Enclosures c: Mayor Plusquellic R. Bell w/enclosure S. Cappotto D. Celik M. McGlinchy P. Gsellman J. Bronowski G. Bozeka File F-04 Environmental Division File

000081

5.4

2002 Long Term Control Plan (LTCP), Additional Evaluation

The City of Akron believes that its LTCP meets the requirements of the presumptive approach as demonstrated in Chapter 4 of tbis report. However, the Ohio EPA requested that the City of Akron conduct additional evaluations. These evaluations included (I) a further evaluation of express sewers for the major separate sewer areas upstream of combined sewer areas, (2) evaluate additional treatment at the proposed CSO facility for the Ohio Canal Tunnel, CSO Rack 40, Northside Tunnel and WPCS Secondary By-pass and (3) evaluate the proposed schedule based on the staging requirements of the various projects, constructability, water quality improvements and City of Akron sewer user rate financial analysis. Express Sewers The express sewer alternative had been evaluated and eliminated for further evaluation in the original long term control plan because the screening level evaluation suggested that negligible benefit would be received at a considerable expense. The express sewer alternative was re-evaluated at the request of Ohio EPA to consider intercepting upstream flow from separate sanitary sewer drainage areas from combined sewer drainage areas II and 12, 18, 35 and Main and Babb master meters. CSO Rack 40 was also included in the evaluation. All express sewers considered in this evaluation were modeled and sized for a 5-year design stonn and tunnels were modeled and sized for a 6-month design stonn. The estimated planning cost for this alternative is $489 million (2002 capital). Moreover, Express sewers were shown by the model to increase secondary bypass at the Akron WPCS. Water quality model results indicate that express sewers would increase the CBOD load in Akron's system by almost 1% more that the recommended Integrated Alternative 2 at a cost of 2.5 times greater than Alternative 2. The express sewer tunnel alternative was also evaluated for a 10-year stonn. The estimated planning cost for this alternative is $579 million (2002 capital). The Express Sewer alternative is not warranted due to lack of water quality benefit at an excessive cost. The detailed evaluation can be found in the Long Term Control Plan Additional Evaluations dated May 2002 (referred herein as "Technical Report"). Enhanced High Rate Clarification (EHRC) Based on the discussions and recommendations of tbe Ohio EPA, the City evaluated EHRC technology at CSO Rack 40 and the overflows to the proposed tunnels within Alternative 2, Given the close proximity of the proposed CSO Rack 40 basin to the proposed NSI Tunnel overflow, combining these facilities in two phases was appropriate for evaluation purposes.

000082

The evaluation of these two alternatives was based on a size sufficient to capture and treat all storms from the average model year used to develop the Facilities Plan evaluation. These alternatives were incorporated into the existing hydraulic model with all proposed Alternative 2 improvements to measure the additional amount of CBOD capture. The estimated planning cost of the EHRC to CSO Rack 40INS TUlliel is $12 million (2002 capital) for Phase 2 and $13 million (2002 capital) for Phase 3. The estimated planning cost of the EHRC to the ocr is $52 million (2002 capital). EHRC (or some other type of additional treatment) were shown in the model to provide increased removal of CBOD without increasing secondary by-pass at the WPCS. It may be shown during post construction monitoring that additional treatment is warranted. Due to the potential benefit, the City will add treatability/pilot phases to the LTCP and incorporate the possibility of additional treatment phases into the schedule. The detailed evaluation can be found in the Teclmical Report. Additional Treatment at WPCS The treatment provided during wet weather at the WPCS includes primary treatment of wet weather flow and blending with secondary treated effluent. At the request of Ohio EPA, EHRC was evaluated as a means of providing additional CBOD removal from the blended effluent. The addition of parallel wet weather treatment system was evaluated usingEHRC. The estimated planning cost of the EHRC at the WPCS is $11 million (2002 capital) for Phase 1a and $11 million (2002 capital) for Phase 2a. EHRC (or some other type of additional treatment) were shown in the model to provide increased removal of CBOD. It may be shown during post construction monitoring that additional treatment is warranted. Due to the potential benefit, the City will add treatability/pilot phases to the LTCP and incorporate the possibility of additional treatment phases into the schedule. The detailed evaluation can be found in the Technical Report. Implementation Plan and Schedule As stated in Section 5.1, after each group of projects is completed a post construction monitoring program will be performed to detennine the effectiveness of the improvements. Each type of improvement will be addressed to determine if modifications are needed in order to improve their operation and effectiveness. These opportunities will be enhanced with the additions of treatability/pilot and specific post construction monitoring as shown on Table 5-2 and discussed in the preceding sections. Based on an evaluation of the actual CSO quantity and quality, additional phases may be added to the

000083

LTCP. This evaluation will be based on a benefit-effective reduction of pollutants based on receiving stream water quality concerns and Section 5.1, lrnplementation Plan and Schedule. The treatability/pilot projects will examine treatment technologies, including but not limited to, EHRC. The EHRC technology appears to have a high operation and maintenance cost especially for a potentially remote site. This technology also has very limited actual operation and experience in the States. A majority of the EHRC installations are on potable water supply and storm water applications in Europe. Also, the type and size of an additional treatment unit can not be determined until post constrnction monitoring is completed on the tunnel/storage component Alternative 2. Assuming the implementation of the projects shown on Table 5-2 two user rate spreadsheets were developed. They are attached as Figures 5-4 and 5-5. Figure 5-4 shows projected user rate increases on an annual basis as needed until adequate funds are generated to support the program. Figure 5-5 shows rates increases in 5 year periods. These rate increases will be impacted by receipt of grants, low interest loans, changes in the negotiated sewer contracts with outside communities and the periodic evaluations set forth in Section 5.1. These user rate scenarios are submitted to demonstrate the need for at least a 30-year schedule. The actual increases will be determined based on the annual and five year needs in the capital budget. The proposed schedule shows a reduction in the overall schedule to 30 years from the originally proposed 36 years.

000084

TABLE 5-2 Program Schedule - 30 Year Program
Attorney/Client Privileged Document Attorney Work Product
Capital Cost 1998 Capital
Cost

2002

Capital Cost 2003

Rack 9 Separation

$210,900 $500,000 $13,421,300 $100,000 $2,561,600
":,"0',-;;),>-,

~g_Q,,~1t~g:Q;[~~;Wt~;~;ilt~ifflf~;4~~Dtg:;'t9~'t~;~01i(tA;;;>~};:,,-T
WPCS Stora e Phase 1 (20 MG) , WPCS PHASE 1a TREATABILITY/PILOT / POST CONST
Mise Separations CR Re-Aeration Structures

TREATABILITY/PILO.S Rack 40/31 Storage Basin Phase 1 POST c:ONSTR MONITORING Rack 26/28 Treatment Basin Separation 21/22 (partiai)

$232,851 $510,000 $14,818,200 $102,000 $2,828,213

I~

•.,',

,j,::, ' : ' ' ,
$11,230,000 $100,000 $11,454,600 $102,000 $220,816 $828,061 $12,474,600 $103,172,045 $102,000 $8,947,029
:-:W-i:;;_~::;~f~~:'biif,~\

LRACK 40/31 PHASE 2 Ohio Canal Tunnel Phase 1 POST CONSTR MONITORING LCR Stream Restoration

'

~gt!~;~~!1ii~{[~%i@!~~£?:1&31t~M~~,~"ti~3ff;lg;~;%:~i:5#t~~'t ;5~(:}~;- ,:'y-"";'"
$100,000

I

$200,000 $750,000 $12,230,000

"

$11,230,000 WPCS Disinfection Rack 14 Storage Basin Rack 15 Storage Basin Rack 3 Treatment Basin
Rack 12 Treatment Basin

$12,600,000 $1,984,800 $1,651,200 $1,700,100

$53,439,024 $28,098,856 $11,454,600 $13,911,418 $2,191,380 $1,823,058 $1,877,048 $2,430,523 $31,324,870 $102,000 $2,568,534 $8,362,308 $1,096,131 $4,111,155 $13,738,351 $1,846,906 $1,416,536 $3,284,088 $4,778,683 $2,428,426 $2,135,403

POST CONSTR MONITORING
Rack 8 Separation

$100,000 $2,326,400 $7,574,000 $992,800 $3,723,600

, 'J

Rack 30 Separation Rack 36 Storage Basin Rack 10/11 Treatment Basin RACK 4O/31-NS Tunnel PHASE 3 ~,Q~8'2,!l~,~; ,: 'i 4,'>i(:0'h',;';:;;:: ii': ,;, ,' Rack 7/5 Storage Basin Rack 22 Storage Basin Rack 25 Separation Rack 13 Separation Rack 21 Separation Rack 29/27 Treatment Basin subtotal

$1,283,000 $2,974,500 $4,328,200 $2,199,500 $1,934,100

Nine Minimum Controls Miscellaneous Separations Total Capital Cost

$100,000 $200,000 $248,111,800 (1998$) $101,450,172 (2002$)

$100,000 $200,000 $377,341,794 (2003$)

000085

· ._ JAN. 13.2003
.. ~. .-;..:..,<..

11 : 35AM

OHIO EPA NEDO

NO.494

P .1/7

An environment.I nDnprDfit organll'ation

January 8 f 2002

Christopher Jones, Director Ohio l2nvironmental Protection Agency P.O. Box 1049 Columbus, Ohio 43216-1049

RECEIVED
JAN 102003

OHIO EPA NEDO
Re: Request for Issuance of Guidance Dear Director Jones: This Request for Issuance of Guidance is Intencled to ensure that Lock Eleven and the below-signed organizationS do not participate in frivolous Verified Citizen Compl<lin1:s. We llre currently operating under the following Interpretation of l/ilw: AnY point-source dlsch/ilrge of pollutants into the waters of the United States must have either an NPDES permit or an applicable statutory exception. We ask guidance to the following situations: Situation Doe: Is a separate combined-sewer tie-in lawful When it is down-flow of an existing NPDES rack/overflow? See map #1.

Situation Two:
Is a combined-sewer tie-in laWful when it is connectecl cllreetlv from a sewer trunk to a waterway without a rack/overfiow and is not listed on a NPDES permit? See map #2. The City of Akron's answer dated December 6, 2002 (see attached) mentions a "basin" exception to NPDES point·source discharges, It states; "Moreover, even if an overflow had occurred, it would have been considered a combined sewer Qverfiow as part of the eso Rack 37 basin."

Steven De~orq, Director 1373 Gorge BlVd. Akron, Ohio 44310

Phone; (330) 945-6807

Email:

~ockEleven@yahoo.com

000086

c .- "t o - '
,

•
:-."

JRN.13.2003

11:36RM

OHIO EPR NEDO

NO. 494 ,

P.2/7

We ask for guidance in locating any relevant statute, code, regulation, formal or Inform<ll rUle, policy or case law that will assist us in comprehending the legal basis and relevant elements of such an exception. We respectfully submit that this request is an effort tQ,preserve both valuable EPA resources, as well our own, and a timely response would be greatly appreciated. Sincerely,
J

/

-'I

..Jj£tP /Ji~~ ~!
~~dI~ alne Marsh, Director
Date:.LJ,Wt2.3

For friends of the Crooked River and Its members. 2179 Everett Rd. Peninsula, Ohio

Mary Trent, Dir. ctor for n' 1854 Sedro st. Cuyahoga Falls, Ohio 44221 Cc: Ms. Susan Cilppotto Ohio EnVironment'll protection Agency 2110 East Aurora Road Twinsburg, Ohio 44081

and its members.

000087

---

,

-JAN.13.2003 .. .....

11:37AM

OHIO EPA NEDO

NO. 494

P.3/7

COl1)bir1l>d Sew"!

Trtlnk ''A''

Aecioving WaleT$

A4lhprizsd NPDES
CSDRack

MAP #1

To treatment plenl

REceIVED
JAN 1 0 2DGJ OHIO EPA NEDO
000088

JRN.13.2003

11:37RM

OHIO EPR.Ni::DO

NO. 494

p.4/7

Combined SawarTrunl<.

~
Receiving Waiers SswerTower. NO esa

Tq trSl!lrnsnl plonl
Connection in question

~
. Map.#2

000089

JAN.13.2003

11:37AM

OHIO EPA NEDO

NO.494

P.5/7

DEPARTMENT Of rUBLIC SERVICE AKRON ENGINEERING BUREAU 166 SOUTH HIGH STREET, ROOM 701 AKRON, OHIO 44308·1652
Phone: (330) 375.2355, Fax: (330) 375-2288 E-rJl.il, Akron Eng ineer; ng@ci.akron.oh.~'
Oon~ld

DAVID ), C~I.IK, r,~. CITY ENGIN.~R

fE:·B

L. Plu,queU;c

Mayor

December 6, 2002

..

•

Ms. Sandy Cappotto Ohio EPA, Northeast District Office Division of Surface Water 2110 J;ast Aurora Road Twinsburg, Ohio 44087
Re: November S, 2002 Letter from Lock Eleven

pear Ms, ClilppottO: On November 7,2002, the City of Akron L.aw Department received a copy of a letter dated November 6, 2002 from Steven DeBord, Director of Lock Eleven, (the "November 6, 2002 letter'~. The November 6, 2002 letter is addressecl to you and Jodi Swanson·Wilson of U.S. EPA, and Is captioned "Verified Citizen Complaint". While the November 6, 2002 letter refers to attachments (photos and a map), these attachments were not provided to the City of Akron. It is important to note that the November 6, 2002 letter does not comply with the requirements of Ohio Revised Code ("R.C,") §3745.08 and, thus, is not a verified complaint. Despite this fact, the City of Akron recognizes that the letter contains aliegations that the City of Akron is in noncompliance With the permitling requirements of the federal Clean Water Act and R.C. Cllapler 6111 al three separate locations. As a result of these allegations, the City of Akron recently conducted an investigation. The results oHhis investigation are set forth, below, for your consideration. As an overview, this letter demonstrates that the Elliegations are withoLtt merit, and the City of Akron is in compliance with the applicable legal requirements. For organizational purposes, the results of the City of Akron's investigation are discussed under the same three headings that are contained in the NovE;lmber 6, 2002 letter.
Complaint One:

Thera is an existing 36-inch sewer shOWn on LlnqergroLlnd sheet 2375516,

000090

JAN.13.2003
~~

11:37AM

OHIO EPA NEDO

NO. 494

P.5/7

,...

, Ms Sandy Cappotto December 6, 2002 Page 2 There is no evidence to suggest that the 3S,inch sewer is acting as a ·presently occurring overflow''. or combined sewer overflow, ,as alleged in the November 6, 2002 letter. Tne 36-inch sewer matcheq the crown of the 36 x 4S-inch f!:oml:>ined sewer on Main Street, and, thus formed a connection. However, the inverts Were twelve (12) inehe's vertically apart. Moreover, the majority of the flow in the 36 x 48·inch combined sewer line on Main Street was removed in 1924 and sent to the Wolf Ledges Trunle Sewer. Since that time, the 36 x 4S-inch combined sewer line on Main Street has been VE\stly oVersized, ThUS, absent an unusual eircumsti:lnce, the 36 x 4B-inch combined sewer could not flow into the 36-inch sewer. Moreover, even if an overflow had occurred, it would have !:leen considered a combined sewer overflow as part of the cso RaCK 37 basin. Despite the above, anc! in order to i:\lleviate any potential conCerns with this issue, the City of Akron recently disconnected the 36·inch sewer from the 36 x 48-inch combined sewer. This work was completed on November 29, 2002.. The existing connection was filled with brick and mortar. Complaint TWQ.; The November 6, 2002 letter further alleges that an existing €i-inch sanitary sewer line is connected to the Ohio and Erie CanEd at 172 South Main Street. This allegation is basad upon undergrounc! sheet #1175. The City of Aleron recently televised all the sewers in this area and located the relevant 6·inch line. Based upon this investigation, it WI'IS determined that this 6-inch line was previously capped and the sanitary flow was connected to an 8·inch sanitary sewer several years ago. The confusion is likely the reswlt of the fact that underground sheet #1175 has not been updated. , Complaint Three: . Finally, the November 6, 2002 letter alleges that the Fountain Btreet Trlilnsfer Station is discharging hazardous run-Off into II cQmbined sewer, which c1ischarges under a "tirst-~u~h" effect into thE! Ohio and Erie Canal at L.ock 2 via Rack 16. The Noyemper 6, 2002 letter also alleges Wilt the City of Akron mistakenly believes that there is a discharge to the separate sewer system. The City of Akron is well aware tl1at thjs area is in a combined sewer district. In fact, consistent with U.S. EPA's 1994 CSO Policy, the City of Akron has implemented the Nine Minimum Controls ("NMC's") in this area, Specifically, with regard to industrial sources located upstream of GSOs, the City of Akron has inventoried and evaluated all such sources.

000091

JAN.13.2003

11:38AM

OHIO EPA NED9

NO. 494

P.7/7

"

Me Sandy Cappotto Dsc;ember 6, 2002 Page 3 Personnel in the City of A!<ron's pretreatment program evaluated the Fountain Street Transfer Station in June, i 994 and August, 1999. As a result of these evaluations it Was determined that the Founti;lin Street Transfer stEition is a nonsignificant industriiSll user. . • The pretrea"tment program' also inspelfted the Pountain street Transfer Station in July, 2002. This inspection included an evaluation of floor dr01ins located inside the building. The inspection resulted in a finding that "any clischarge to the sewer is incidental and minimal." In light of the above, the City of Akron is in eompli<mce with its pretreatment program, the NMC's, and the 1994 csa policy regarding the Fountain Street Transfer Station.

As set forth above, the allegations set forth in the November 6, 2002 letter are without merit Upon request, the City of Akron would be glad to provide you with all supporting documentation regarding this investigGltlon. Further, if you .have any questions, or need any further information, please do not hesitate to give me a caf!,
~~ry.

Environmental Division Manager PDG/mk
cc:

,t'iok1i~~

J. Kidder M. MeGlinehy D, Celik J. Swanson-Wilson (U.S. EPA Region 5) R. HelVey (U,S. EPA Region 5) S. DeBord (Lock Eleven) E. Marsh (Friends of the Crooked R.iver) D. Nelson (Portage Trail Group ofthe Sierra CILib) M. Trent (Concerned Citizens Against Illeg~1 Contamination) C. Ha (Families Against City Transfer Stations)

000092

JOSEPH P. KIDDER
Service Director

LUNZY O. ARMSTRONG
Deputy Director

VALERIE STRAW
Executive Assistant

JEFF FUSCO
Deputy Director

DONALD l. PlUSQUELUC Mayor

DEPARTMENT OF PUBLIC SERVICE
166 S. High St., Room 201 Akron, OH 44308 Phone: (330) 375-2270 FAX, (330) 375-2100

December 24,2001

Mr. Paul Novak, P.E. Manager Permits & Compliance Section Division ofSurfuce Water, Ohio EPA Lazarus Government Center 122 S. Front Street Columbus, Ohio 43215-1099
Re: City of Akron CSO Long Term Control Plan (LTCP)

Dear Mr. Novak: As you know, the City of Akron has completed its review of your letter dated September 14, 2001. Moreover, we also met on November 29, 2001 in your office to discuss and clarify the issues in your letter and the provisions of the City's CSO Long Term Control Plan ("LTCP"). Needless to say, the City disagrees with several issues raised in your letter. Simply stated, it is the City's position that the CSO LTCP complies with all applicable state and federal guidance and policy documents. While the parties have discussed these issues on several occasions, the City intends to provide a written response to these issues on February 28, 2002. Despite the fact that Akron disagrees with the issues raised in your letter, Akron is willing to conduct the additional evaluations that have been requested by Ohio EPA, and which are noted below. Please keep in mind that by agreeing to perform these additional evaluations, Akron does not admit that its current CSO LTCP is in any way deficient. Specifically, Akron agrees to conduct the following: I. A Further evaluation of express sewers for the major separate sewer areas upstream of combined sewer areas. This will pertain to CSO Rack 18, Northside Sewer areas, and CSO Racks II and 12. 2. Evaluation of additional treatment at the proposed CSO facilities for the Ohio Canal Tunnel, CSO Rack 40, Northside Tunnel and WPCS Secondary Bypass. 3. Evaluation of the proposed schedule. The schedule length will be based on the staging requirements of the various projects, constructability, water quality improvement and City of Akron financial capabilities as related to sewer user rates.
000093

Mr. Paul Novak, P.E. December 24,2001 Page 2 At this time, we propose to submit the express sewer and additional treatment tasks (1 and 2 above), including planning costs and present worth calculations, on or before February 28, 2002. The water quality modeling efforts will be completed in March 2002. Upon receipt of Ohio EPA's comments (if any) on the above submittal (1 and 2 above), we anticipate it will take approximately 30 days to re-evaluate the proposed schedule (3 above). The re-evaluation of the schedule and its submittal date, are dependent on Ohio EPA's review of items 1 and 2.
It is important to note that throughout the review process, Akron has, and will continue to

implement items in the CSO LTCP. The following are examples of CSO control projects implemented by Akron. First, Akron continues to update and implement the previously submitted Nine Minimum Controls. Moreover, the sewer separation for Rack 39 (elimination of CSO 39) has been completed. The design of the sewer separation Rack 9 (elimination of CSO 9) is near completion with construction scheduled for summer of 2002. The proposed 2002 Capital Improvement Budget includes Sanitary Sewer Reconstruction, Sewer System III Correction, Nine Minimum Control Improvements, Miscellaneous Sewer Separations, and reconstruction of a portion of the Little Cuyahoga Interceptor. The City has also started a multi-year evaluation of sewer-river crossings. In addition to the above, Akron continues to monitor the sewer system at a significant expense, including a rain gauge network, flow monitoring and a hydraulic/water model. Finally, Akron continues to seek funding from all possible sources. Akron will be receiving grants of $1,000,000 for CSO improvements and $485,000 for improvement to the Cuyahoga Valley National Park. The House and Senate Conference Report on the VA-HUD FY 2002 Appropriations Bill (HR 2620 and S1216) was approved on November 8, 2001. The legislation includes funding for the Environmental Protection Agency, the National Science Foundation and the Federal Emergency Management Agency. Included in this Bill is an appropriation to the City of Akron of $1,000,000 for continued work on the combined sewer system and $485,000 for a project that would result in improvement to the Cuyahoga Valley National Park. The City greatly appreciates the support of Ohio EPA in Akron's efforts to obtain these funds. If you have any questions or require any further infoffi1ation, please contact Patrick D. Gsellman at 330-375-2357.

;:;J;)v£&. Josep~ Kidder,1::~:
Department of Public Service JPKlPDG/ag c: Mayor Plusquellic, D. Celik, J. Bronowski, D. Crandell, M. McGlinchy, R. Bell, S. Cappotto, File F-04, Environmental Division File
2001·12·24 GSO lolep jpk pdg ag

000094

DEPARTMENT OF PUBLIC SERVICE PUBLIC UTILITIES BUREAU
Donald L. Plusqueilic Mayor

CUSTOMER INQUIRIES:

375-2554
JOSEPH P. KIDDER

Service Direc:cl
DAVID L. CRANDelL, Mgr. Pubiie Utilities Bureau

November 26, 2001

(330) 375-2627
FAX: 375·2072 146 Soutn High Street P,O, 30x 3665 Akron, Ohio 44309-3665

Division Managers:
MICHAEL L. McGlINCHY, PoE. Utilities Services Manager
(330) 375- 22CO FAX: 375-2072

Steve Snyder Fiscal Administration Ohio EPA PO. Box 1049 Columbus, Ohio 43216-1049 Dear Mr. Snyder; Pursuant to your request of Tuesday, November 20, 2001, I am forwarding the City of Akron's Comprehensive Annual Financial Report for the Fiscal Year Ending December 31, 2000. In addition, I am forwarding a Public Utilities Schedules 0 and 0-1, showing the respective sewer and water current debt (principal and interest) annual payments. The other two sheets (not sent to you) of both the sewer and water debt service show either principal or interest. This information was given to Paul Novak during a meeting earlier in 2001, when discussing potential funding with Ohio EPA. Further, I am sending you a list of the City of Akron's outstanding debt as of November 30, 2001. This public record is prepared by our Treasurer's Office and is presented to City Council on a monthly basis. This list only shows the principal on outstanding debt. The sewer and water debt listed on pages 63 and 64 of the Comprehensive Annual Financial Report can be matched with the separate document by the issuance date. The dollar amounts cannot be ma\Ched, except where there is a no-Interest loan. It should be noted that the OWDA loans cannot be refinanced and the OWDA loan and the OPWC loan must follow the agreement payment schedule. Should you have any questions on this material, please call meat 330-375-2627. Sincerely yours,

146 South High Street P,O. 30x 3665 Akron. Chio .<14309-3665 RAY D. HASeO, ?E. Water SuPPiy Menager

(330) 678-0077
FAX: 678-0927 1570 Ravenna Road Kent. Chio 44240

JAMES L SIX, P.E,
'Nater & Sewer Systems Mgr. Water Distribution

(330) 375-2580 Fil,X: 375-2114 565 Jcnnston Street Akron.:)hio 44311 Sewer Maintenance (330) 375-2585
FAX: 375-2399 1055 Heme Avenue Akron, Ohio 44310
RANDALL A. MONTEITH, P.E.

Water Pollution Control Mgr. (330) 928-)164 FAX: 928-2285 2460 Akron-Peninsula Road Akron, Cr.io 442.13

~~~
City of Akron, Public Utilities Bureau DLCllk Enclosures cc: Paul Novak, Ohio EPA File

2 i :01

C ' •.•,' '.~

.~i

to

C:\My Oocuments\dlc letters\Steve Snyder_ Financial Report 11-26-2001.doclfk

000095

SCHEDULID PAOIl3OFJ;

CITY OF AKRON DEPARTMENT OF PUBLIC SERVICE SEWER SYSTEM TOTAL CURRENT DEBT SERViCE

SEWER $YsTI!M

s""""
REVENU!! BOND5
YfAR $25.00 MILLION

OWOALOAM
CS3t1884-01 $15.3 MILLION

aNDAl.OAH

OW'DALOAH

SEWER. SYSTEM

SfWI!R RfV'f:NUe SONOS $13.11 MllltoN

SIMlER S

nn,.

OWOALOAH

S~SY51D1

SEWER. SYSTEM G.o.BONOS !\AOto SYSTEM

OPWCLOAH$
HARCTJACTTVAT!D
MAINOUTFAU

CS30111<lO-01
'17" MILLION

C3S<lSlI4O>
tU MILLION

IlEVENUC BONDS $1t.14 MllLJON

OWDA LOAH 111

C3$108lW041

0.0. riOHOS
GORGe sfW61:

f10 MILLION (5I811

$::U MILLION

TOrAl
9,811,539.47 9,7-45, 737.-40 9,699,721.61 9,6$3,771.44 9,108,535.82 9, 105,013.13

2001 2002

2,347,226.75 2, 345, 703. 75 2,349,698.75 2,3-48,543.75 2,347,043.75 2.345, 4sa 75 2.331,218.75 2,333,216.75 2,332,733.75
2,330,096.25

1,176,439.40 1,176,m.40 1,116,m.40 1,176,439.40 1,176.439.40 1, 176,439. 40 1,176,439.40 1,176,438.40 1.176,439.40 1,116.439.-40 1,176,439.40 1,176,439.40 1,176,439.40 1,176,439..40 1,176,921.93

1,381,487.02 1,381,437.02 1,361,487.02 1,381,487.02 1,381,487.02 1,381.487.02 1.381,467.02 1,381,487.02 1,381,437.02 1,381,437.02 1,381.437.02 1,381,-487.02 1,331,-487.02

961,90246 961,902,46

1,139,467.50 1,097,667.50 1,075,617.50 1,073,305.00
1,069,597.50

848,262.50
850,632.50 8-47,367.50
843,690.00

1.162,340.00 1,162,340.00 1,162,3-40.00 1,162,3-«1.00 1,162,340.00 1, t62,3<W.OO

576,m:n 576,m.22 576,m:12 576.m.12
000 000 0.00 0.00 000 0.00 0.00 0.00 0.00 0.00 000 0.00 0.00 0.00 0.00

n5Ol00 ",75Q00

36,M1.00

106,6n82
87,sn82 66,en82 66,67282

,...""'13
36,424.94

2003
2OQ.4 2005 2006

961,002.46
961,902.46 961,002-46 961,902.46 961,902.46 961,902.46 961,871.59
480,951.23

65,OOJ.OO
61.250.00 57,50000 53,750.00

36,363.n
36,190.37 36, 142.68

649,362.50 8-49,4n.50 864.010.00 861,885.00 863.885.00
664,860.00

56,anal

1,071,347.50 1,071,597.50
1,075,~7.50

66,6n82
66,6n.82

2007
2006
2009

•.00 0.00 000 0.00 •.00 0.00 •.00 •.00 •.00 0.00 0.00 0.00
0.00

•.00 •.00 0.00 0.00 •.00 .00 •.00 000 •.00 •.00 0.00 000 .00
_ ~7~,QQ._

36,1n79
35,8-40.68

7,8&9,500.74
7,892,793.53 7,853,737.06 7,384,644.22

66,Sn.82

1,070,641.50 1,084,137.50 1,070,375.00 1,074,125.00 1,075,-400.00 1,075,250.00 1,011,000.00 1,074,750.00 1,071,000.00

•.00 0.00 0.00 0.00 000 0.00 0.00 •.00 0.00 0.00 0.00
_t?8$,~116

66,6n82
66,612.82

2010 2011 2012 2013 2014 2010 201. 2017 201. 201'

l,3Q.4,823.75 417,593.75 409,368.75 401,143.75 2,337,918.75 2,350,415.00

0.00 0.00 0.00 000 0.00 000 .00 .00 0.00

1,889,760.00 2,nS,620.00 2,783,802.50
2,~,492.50

66,6n.82
66,572.82

8,889,517,99
6,891,937.99 6,593,170.-49 6,695,485.49

66,6T2.82
66,61262

1,381.487.02
1,382,054.09

857,135.00
644,~,OO

66,672.82

6,891,702.59
"'336,247.82

0.00 0.00 0.00 0.00

000 0.00 0.00 0.00

66,6n62
66,6nS2
56,017.84

000 0.00 0.00

0.00 0.00 000

1,137,6n.82
56,017.84 45,363.26

0.00 0.00
$18~632.i50

45,363.26
$U~7.aI9.Q4

7"",.

$30 632 21S.75

'17647073.53

S20 TZlSn.31

$9 138 042.50

$20 493.§l1,50

__

i6.9H.~,~

_.$2301108.88

$128.W.176.83

(1) Adjusted II;) match City Debt Pa~ Schodu!-.

000096

SCHEDUUl 0
P'AOEIOfIJ

CITY OF AKRON DEPARTMENT OF PUBLIC SERVICE SEWER SYSTEM IOTA! CURRENT DEBT SERVICE

SEWeR SYSTEM

$rfflER
R.lWfHUI! BONDS

OWOALOAH
CS3i1lS&4-41
'~~,3 ~.!t-LI9~

OWDALOAH

OWDALO,,"
C3t0884~

SEWEll SYSTEM jIlEVENUI BONoa
!1',H~!1,,1I0H

SEWl!R
'U!VJ!NUE BONOS
'tt.l~ MII"llON _

SEWeR SYSTEM

OW'OAlOAH
C~041

SEWEft. SYSTEW

SE\WPl SYSTEM

Of'WCLOAHS
HARCTfACTlVAtm
MAIN OUTfA.ll

CS3111OO-4'1
t11.~.M.llLIO!L

OWDA LOAN 111

O,O.IIONDS
_9Qff:QE!S~_

O.O.80NDS
MPtO~YSn:M

YEAR
2001

~.()O

MILLION

_

~MII,,!'JOH

119: MIJ:,l,IQ.Ml~i
1,162,3«1.00 1,162,3«100 1,162,340-.00 1,162,3-00.00 1,162,3-40.00 l,I62,J.«l.OO

__ H~ MILLION

ToTAL

2,3.47,228.75 :1,345,703.75 2,349,698.75 2,348,543.75 2,347,043.75 2,345,458.75 2,331,216.75 2,333,218.75 2,332,733.75 2,330,096.25 1,304,823,75 -417,593,75 409,368.75 401,143.75 2,337,916.75 2,350,-425.00

1,176,439.40 1,176,439.40 1,176,439.40 1.176,439.40 1,176,439.40

1,381,487.02 1,381.481.02 1,381,487.02 1,381,487.02 1,381,487.02 1,381,487,02 1,381,481.02 1,381,-487.02 1,361,487.02 1,381,447.02 1,381,487.02 1,361,4&7.02 1,381,487,02 1,381,487.02 1.382.054.09

961,902.46 961,9024a 961,902.46 961,902.46 961,902.46 961,902.46 961,90246 961,90248 961,871.59 480,951.23

1,139,467.50 1,097,667.50 1,075,617,50 1,0n,305,OO 1,069,597.50 1,071,347.50 1,071,597.50 1.075,347.50 1,070,6-4-7.50 l,Q8Jl,137,50 1,070,375.00
1,O74,1~.OO

848.28250
85£l,6325O

576,m.22 576,m.22 576,m,22. 576,m.'l2
0.00 0.00 000 000 000 0.00 0.00 000 000 000 000 0.00 0.00 000 000

n,soo_oo
68,750.00

36,«1.80

108,67282

9,811.539.47 9,H5,T37,4(J

2002

36,364.73
36,424.94

87,61'l82
66,67282 66,672.82 66,672.82

2003
2OQ.I

647,367.50
648,690.00 849,362.50 849,472.50 664,010.00 861,885.00

65,000.00 61,2:50_00 57,500.00 53,750.00

9,699,m.61
9,693,711.449,108,535.82 9,10:5,013.13 7,889,500.7'7,692.793.63 7,853-.T37,OO 7,384,644.22

36,363.n
36,190.37 36,14263

200S 2006
2007

1,176,439.40
1,176,439.40 1,176,439.40 1,176,439.40 1,176,439.40 1,176,439..40 1.176,439.40 1,176,439.40 1,176,439.40 1,176,921.93

66,6n82
66,67282

000 .00 000 '00 000 000 000 000 0.00 000 000 000 000

0.00 0.00 0.00 0.00 000 0.00 0.00 000 0.00 0.00 0.00 0.00 0.00

36,ln19

2006
200l

35,840.68
0.00 0.00 0.00 0.00 0.00 0.00 0.00 000 000 0.00 0.00

66,6n82
66,672.82

863,685.00 864,860.00
1,889,780.00 2, 715,620,00 2,783,80250 2,J9.4,492.50 857,135.00
84.4,-400.00

2010 2011 2012 2013 2014 2015 201. 2017 201. 2019
T""'~

86,672.82 '

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

66,6n.82
66,672.82 66,67262 66,67282

6,889,571.99
6,891,937.99

1,075,400.00 1,075,250.00 1,071,000.00 1,074,750.00 1,071,000.00

6,893,1'10.49

6,895,485.49
6.891,702.59 -4,33G,247.62 1,137,672.82 56,017.84
45,363.26

66,67282
66,fm.82 66,67282 56.017.84 45,363.26

0.00 0.00 0.00 000

.00 0.00 0.00 0.00

0.00 0.00 0.00

000 000 000

0.00 000

$30 632 218.75

$17647073.53

S20

wsn37

$9 138 042.50

$1834063250

po 493 677.50

S§97<10.4000

S330710888

$37875000

P89!J.41.7.l

~7.~.19.04

$t~8.

m

176. 53

(1) Adjuslsd to matcll City OebtPa)ffientSChosdula.

000097

SCHII!OULI D

'AOe 3 0fil3

CITY OF AKRON DEPARTMENT OF PUBLIC SERVICE SEWER SYSTEM TOTAL CURRENT DEBT SERVICE

SEWER
REVENUe: BONDS

OWDALOAJI
C5311B84-01
$1~J:

OWDALOAH

OWOALOAN CJS<lll84O>

SEWER SysnM
R~UEaoNoa

SEWER
REV£HUI! BO+lOS
_t.:!.!Jl MillION

HWER. SYSTOt

C1WOALOAH

CSJ01_

OWDA LOAN (1)
110 MILLION
f5l81l~

~
200.

n"oq!'t!!L!"!()~

M!lllO'L -.!17..11 MILLION
1,361,"87.02 1,361,487.02 1,361,487.02 1,381,487.02 1,381,0487.02 1,381,487.02 1,381,Jl.87.02 1,381,487.02 1,381,487.02 1,361,487.02 1,381,-467_02 1,381,467.02 1,381,oCa7.02 1,381,-467.02 1,382,054.09

t!.8 h!!LlIOfi_ --'.11,14 MILLION

f.UMlllfON

"'-.

SeweR $YSTD1

SEWEft IYSTO!

SEWER SYSTEM

OPWCLOAHa

G,O.acHDS
_ GORGe .._
SewE~

G.o.IONOS
~QtQSYSTeM

HARcTIACTl'VATID
MAIN OUTP'AU
TOTAL

2,341,228.75 2,345,703.75 2,349,698.75 2,348,543.75 2,341,lM3.75 2,345,458.75 2,331,218.75 2,333,218.75 2,332,733.75 2,330,096.25 1,304,823.75 417,593.75 -400,368.75 -401,1-43.75 2,337,918.75 2,350,425.00

1,176,439.40 1,176,439.40 1,176,439.40 1,176,439.40 1,176,439.-40 1,176,439.40 1,176,439.40 1,176,439.040 1,178,439.040 1,176,-439.-40

961,902.<16 961,902.46 961,902.>48 961,902"'6 961,902.46 961,902.46 961,90246 961,902-46 961,871.59 400,951.23

1,139,-467.50 1,007,661.50 1,075,617.50 1,073,305.00 1,069,591.50 l,071,J.47.50 1,071,597.50 1,075,J.47.50 1,070,8-47.50

848,282.50

1,162,340.00 1,162,340.00 1,162, 340JIO 1,162,340.00 1,162,34Q.00 1,162,3<10.00

576,m:n

n,500.00
68,750.00 65,000.00 61,250.00 51,500.00 53,750.00

36,441.80 36,36<4.73 36,424.94

106,67282 87,67282
66,6n82

9,81',53!H7 9,7<45,737"'0
9,699,W.61

= 200S
2004

850,632.50
6-47.367.50 848,690.00

576,m.Zl 576,m:12 576,m_22
0.00 000 0.00 0.00 000 0.00 0.00 0.00 0.00 0.00 0.00 000 0.00 0.00 0.00

36,363.77
36,190.37 36,14268 36,172.79

66,672.82 66,672.82

9,693,771.44 9,106,53.5,82 9,105,013.13 7,889,soo.74

2005 200ll

649,36250
S49,4n.50 8604,010.00 561,885.00

66,sn.az
66,6n.82

2007
200ll

0.00 000 0.00 0.00 0.00 0.00 0.00 0.00 000 0.00 0.00 0.00 0.00

0.00 0.00 0.00 0.00 000 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

35,a.«J.68
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

66,671.82
66,6n82

7.894793.63
7,853,737.08

2009
2010

863,885.00
8&4,860.00
1,889,760.00

1,084,137.50
1,070,375.00 1,07",125.00 1,075,400.00 1,075,250.00 1,071,000.00 1,074,750.00 1,071,000.00

66,671.82

7,384,644.22 6,689,577.99
6,891,937.99

lOll
20.2 2013

1,176,-439.40
1,176,439..40 1,176,439.-40 1,176,439.40 1,176,921.93

0.00 0.00 0.00 0.00 0.00 000 0.00 0.00 0.00

56,an.52
66,612.82 66,612.82

2,nS,620.OO
2, 783,802.50
2,794,492.50 657,135.00

6,893,110.49 6,895,485.049
6.,891,70259 4,336,247.82

2014 2015 20 •• 2017
201.
2019

66,6n82
66,672.82

000 0.00 0.00 000
~17 ~7

0.00 000 000 0.00

844,.wo.oo
0.00 000 0.00

66,en82 66,en82
56,017.64

0.00 000 0.00

1,137,6n82
56,017.84

0.00 0.00
$18 3fO 632.50

45 363.26
~__ ~!J~JiHM.

.45.363.26

r"",~

$30.632.218.75

073.53

S20TnSn31

~

1380<12.50

$20 493 577.50

$§~7<1

0-40.00

S2 307108.88

$378750,00

$289 941.76

,

$128.m.178.53

(1) AdJustlld to match Cily Debt P.ymoeotSChedulos..

000098

SCHEDllLEJh1 PAGE 1 OF 3

CITY OF AKRON DEPARTMENT OF PUBLIC SERVICE BUREAU OF PUBLIC UTILITIES Wlll.ER TOTAL WATElUiYSIEM..QEl:lLSER'llCEBEQUIREMENT
2 ISSUES
QWOA

-DECEMBER 1992
62,679.90 62,547.34
62,650.90

QPWC

~ -FEBRUARY 1998
2001 2002 2003 2004 2005 2006 2007
2008

'"JANUARY 1996
1,590.449.99

.. MAY 1994 2,607,268.75

- JULY 1986
362,500.00

MAY 1981
348,702.00

1999
51,207.80 51,207.80 51,207.80

TOTAL
6,994,115.94 7,024,654.02

YEAR
2001 2002

1,971,307.50 1,978,812.50 1,976,237.50 1,967,487.50
1,965,525.00

1,628,552.50
1,629,318.75

2,611,281.88
2,611,644,37 2,614,401.88

343,750.00
325,000.00

348,702.00 348.702.00 348,702.00 348,702.00

7,004,761.32

1,632,828.13 1,631,286.87 2,544,735.00
2,847,465.00

2,618,301.25 2,621,250.00
2,622,622.50

306,250.00 287,500.00 268,750.00

62,545.68

62,247.43 62,165.42
62,217.20

51,207.80 51,207.80 51,207.80
51,207.80

6,983,422.99
6,964,770.35

2003 2004 2005
2006
2007

1,179,347.50 915,311.25
915,636.88 919,436.25 918,870.00

348,702.00

7,076,157.72
6,498,823.75

2,850,715.00 2,853,712.50
2,850,032.81

2,625,702.50 2,631,037.50
2,637,825.00

61,645.97

51,207.80 51,207.80
51,207.80 51,207.80 51,207.80

6,504,908.15 6,455,394.05
6,457,935.61

2008 2009 2010
2011

2009 2010 2011 2012 2013 2014 2015
2016

918,998.13 922,148.13 920,780.00 923,000.00
925,500.00

2,847,671.88 711,839.06

2,639,300.00 2,644,525.00 2,649,075.00 662,500.00

6,457.177.81
4,329,719.99 3,621,062.80

51.207.80 51,207.80
51,207.80

1,636,707.80 976,707.80 977,207.80 975,707.80 282,207.80
25.603.90

2012 2013 2014
2015

2017 2018
2019

926,000.00 924,500.00 231,000.00

51,207.80 51,20'1.80 51,207.80 25.60390 $25,618,607,49 $34,796,735.63 $1,893,750.00 $2,092,212.00 $498,699.84 $947,34430

2016 2017 2018 2019

$21,399,898.14

$87,247,247.40

MORTGAGE REVENUE .- GENERAL OBLIGATION BONDS H. RADIO COMMUNICAnON SYSTEM BONOS

000099

SCtlEQULE-lL1 PAGE 1 OF 3

CITY OF AI<RON DEPARTMENT OF PUBLIC SERVICE BUREAU OF PUBLIC UTILITIES

WAI.ER
IQIALWAIEfLSYSIEMJ2EElLSEIDitCE-REQUIREMEtlI
2 ISSUES

OWDA

'DECEMBER 1992
62,679.90

OPWC

YEAR

'FEBRUARY 1998 1,971,307.50 1,978,812.50 1,976,237.50 1,967,487.50 1,965,525.00
1,179,347.50

'JANUARY 1996
1,590,449.99

'MAY1994
2,607,268.75

•• JULY 1986
362,500.00

MAY 1981
348,702.00

1999
51,207.80 51,207.80 51,207.80

TOTAL
6,m)4,115.94 7,024,854.02

YEAR
2001 2002

2001 2002
2003

1,628,552.50 1,629,318.75 1,632,828.13 1,631,286.87 2,544,735.00 2,847,465.00
2.850,715.00 2,853,712.50

2,611,281.88 2,611,644.37 2,614,401.88 2,618,301.25
2,621,250.00

343,750.00 325,000.00 306,250.00 287,500.00 268,750.00

348,702.00

62,547.34
62,650.90

2004 2005 2006 2007 2008
2009 2010
2011

348,702.00 348,702.00 348,702.00
348,702.00

62,545.68 62,247.43 62,165.42
62,217.20

51,207.80
51,207.80

7,004,761.32 6,9U3,422.99
6,964.770.35 7,076,157.72 6,498,823.75

2003 2004 2005

51,207.80
51,207.80

915,311.25
915,636.88

2,622,622.50 2,625,702.50

61,645.97

51,207.80 51,207.80
51,207.80 51,207.80 51,207.80

6,504,908.15 6,455,394.05
6,457,935.61

2006 2007 2008 2009
2010

919,436.25

918,870.00 918,998.13 922,148.13 920,780.00 923,000.00 925,500.00 926,000.00
924,500.00

2,850,032.81 2,847,671.88 711,839.06

2,631,037.50 2,637,825.00 2,639,300.00 2,644,525.00 2,649,075.00 662,500.00

6,457,177.81
4,329,719.99 3,621,062.80 1,636.707.80 9?6,707.80

2011
2012

2012 2013 2014 2015 2016 2017 2018
2019

51,207.80 51,207.80
51,207.60

2013 2014 2015 2016
2017

51,207.80
51,207.80

977,207.80
975.707.80

231,000.00

51,207.80 25,60390 $25,618,607.49
$34.796,735.63

2112,207.80
25,603.90

2018 2019

$21,399.898. ·\4

$1,893,750.00

$2,092,21200

$498,699.84

$947,344.30

$87,247,247.40

• MORTGAGE REVENUE ., GENERAL OBLIGATION BONDS
.,. RADIO COMMUNICATION SYSTEM BONDS

000100

:iGtiEIlllLfJl=1
PAGE 1 Of 3 CITY OF AKRON DEPARTMENT OF PUBLIC SERVICE BUREAU OF PUBLIC UTILITIES

lIY8IE.R
TQIALlIYAIER SYSTEM DEBT SERVICE REillllREMENt
2 ISSUES

OWDA ** JULY 1986

..,

OPWC

~
2001 2002
2003 2004 2005

·FEBRUARY 1998

·JANUARY 1996

'MAY1994
2.607,268.75 2.611.281.88

MAY 1981
348,702.00

DECEMBER 1992
62,679.90

1999
51,207.80

TOTAL
6,994.115.94

YEAR 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010
2011

1,971,307.50
1,978,812.50

1,590,449,99 1.628.552.50
1,629,318.75

362.500.00
343,750.00
325,000.00

348,702.00
348,702,00

62,547.34
62,650.90

51.207.80
51,207.80

",024,854.02
7.004,761.32

1,976.237,50 1,967.487.50 1,965,525.00 1.179.347,50 915,311.25
915,636.88
919,436.25

1.632,828.13 1,631.286.87 2.544,735.00 2,847,465,00 2,850.715.00 2.853.712.50 2,850,032.81 2,847.671.88 711,839.06

2,611,644.37 2.614,401.88 2.618.301.25 2.621.250.00 2.622,622.50
2,625.702.50 2,631.037.50

306,250.00 287.500.00 268,750.00

348,702.00 348,702.00 348,702.00

62.545,68 62,247.43 62.165.42
62,217.20

51,207.80 51,207,80 51.207.80
51,207.80

6,983.422.99 6.964.770.35
7,076.157.72 6,498,823.75

2006 2007 2008
2009 2010 2011

61.645,97

51.20780 51.207.80
51,207.80

6.504,908.15 6.455.394.05
6,457,935.61

918,870.00 918,998.13 922.148.13 920,780.00 923,000.00 925.500.00 926,000.00 924.500.00 231.000.00

2,637.825.00 2,639.300,00 2,644,525.00 2.649.075.00 662.500.00

51.207.80 51.207.80 51.207.80 51.207,80
51,207.80

6,457,177.81
4,329,719.99 3,621,062.80

2012 2013 2014 2015
2016

1.6"6,707,80
9;'6,707.80 977,207.80 975,707.80

2012 2013 2014
2015 2016 2017

51.207.80
51,207.80

2017
2018

2019
$21,399,898. '14 $25,618,607.49
$34,796,735.63

51.207.80 25.603.90 $1,893,750.00 $2.092,212.00 $498,699.84 $947.344.30

2112,207,80
;~5,603.90

2018 2019

$87,2<17,247.40

• MORTGAGE REVENUE .. GENERAL OBLIGATION BONDS
•. ., RADIO COMMUNICATION SYSTEM BONDS

000101

Period Ending November 30, 2001 Total Ou tstand in~ 12/31/0 11,500,000 300,000 10,758,098 39,513,046 1,842,341 1,392,819 155,291 50,055,000 19,935,000 1111,800,000 151,152,501 131,810,000 23,800,000 170,000 1,000,000 2,080,000 2,010,000 720,000 210,000 150,000 150,000 9,720,000 3,060,000 3,3B2,IB6 5,180,000 7,695,000 1,451,109 265,891 570,000 1,215,000 3,350,000 1,950,000 505,000 1 020,000 18: 110,000 935,000 5,720,000 3,m,000 3,370,000 1,520,000 H54 ,007 ,196 \0 112,581,130 3,341,700 1,245,000 231,700 881,988 112,634,130 18,706,383 3 F,879,m 32,710,000 Issues 2001
~

DEBT CITY OF AKRON

.

OHIO

DescriDtion

Type Bonds Bonds Loans Loans Loans Loans
Loans

Balance 11,500,000 300,000 l1,239,1l8 39,513,046 l,8H,3H 1,892,819 155,294 60,055,000 19,935,000 1I11,BOO,OOO ISI,m,951 lI9,545,527 Sl,m,809 1,170,000 1,000,000 2,080,000 2,010,000 120,000 210,000 150,000 150,000 33G,000 9,120,000 3,231,138 3 m 195 10:379:381 14,m,158 8,634,561 115,054 510,000 7,215,000 3,350,000 6,236,509 505,000 1,020 000 19,971:000 935,000 8,332,000 5,815,000 3,370,000 1,520,000 1205,211,1l5 10 Ill,199,131 9,051,300 4,245,000 231,700 831,988 p4,199,181 II ,125 ,933 128,m,135 132,110,000 19,105,000 121 550,000 512,692 1 15,512,091 1505,145,133

l!edeemed in 2001 \250,000 50,000 2,056,361 25,603 59,211 20,397 2,970,000 0 P,270,OOO 3,251,912 15,300,000 3,380,000 770,000 100,000 100;000 680,000 120,000 35,000 25,000 25,000 55,000 210,000 0 5,105,000 6,800,000 1,151,109 190,391

Total Outstandin 11/30/0

r

PUBLIC UTILITY DEBT (G.O. ) Water Sewer P.U. SPECIAL REV. (OWDA) Water Sewer P. U. SPBCIAL REV. (OPWCi Water Sewer Recycle 8nergy S1ste. P.U. DBBT (REV8NUB iater ~ortgage Sewer TOTAL P.U. DEBT GENERAL DEBT Off Street Parking Street Improvement Starn Sewer Inprovenent Highway Inprove.ent Real Estate Acquisition Recicle Ener g S1s ten Solld Waste SE orage 'acil. Bunicipal Bldg. Imp. Parks tmlrovenent Hunicipa Gara~e Pedestrian Wal way Co.puter/Communlcation FInal Judgment Public I.provement Convention Center Com.unity Centers Radio Co.munication System Barley Bealth Center Plaza Ascot Park I.lrovetent Inventors Hal oi Pa.e CitiCenter Building Co.bined Dispatch West Side Depot Justice Center Plaza Recreatiooal ,acilities Northwest Fire Station Bunicikal ,acillties Bator quipment Higb St. Renewal Area Energy Conservation TorAL GBNERAL DEBr SPECIAL ASSESSMENrS Street Improve3ent Street Improvement Street Cleaning Street Sealing Street Resurfacing rOTAL S.A. DEBT SPECIAL OBLIGArIONS Canal Park Stadium Income fax Revenue IEDD Revenue Industrial Incubator-ODOD Capital Projects - OPVC GRAND TOTAL
non~rax

10 0 181,m

11,250,000 250,000 10,759,108 36,856,685 1,815,741 1,823,508 135,897 57,095,000 19,935,000 1108,530,000 151,392,039 143,215,521 30,550,809 100,000 3,500,000 1,980,000 1,360,000 600,000 175,000 125,000 125,000 9,120,000 2,991,738 3,382,196 5,214,881 1,620,758 1,130,15B 254,153 570,000 1,215,000 3,350,000 1,076,509 125,000 1,020 000 19,712:000 935,000 8,152,000 6,315,000 3,310,000 I,m ,000 1173,352, H5 10 112,226,181 9,067,300 1,215,000 231,700 881,988 H2,225,181 Hl,125,988 123,819,135 132,710,000 19,705,000 $27 650 ,000 569,755 1 15,157,741 lI54, 963 ,531
000102

lBO,3lO

° ° 0 °
0 0 10 1481,350 Ill,m,527 10,630,809 100,000 0 ° 0 ° ° ° ° 0 ° 171,738 1,399,881 ° 5,125, m 4,180,158 i19,153

Bonds Bonds Bonds Loans Bonds Bonds Bonds Boods Bonds Bonds Bonds Bonds Bonds Bonds Bonds Bonds Bonds Bonds Bonds Bonds Bonds Bonds Bonds Bonds Bonds Bonds Bonds Bonds Bonds Bonds Boods Bonds Bonds Bonds Bonds Notes Bonds Bates Notes Bates Bates Bonds Bates COPs Bonds Bonds Bonds Loans Loans

m,ooo

m,ooo

°

° ° 1,216,509 ° ° 1,807,000 °
2,612,000 ° 3,320,000 0 151,239,949 10 H,515,051 5,719,500

0 ° 2,150,000 80,000

°

131,895,000 10 11,973,000

° 235,000 ° 180,000 ° 60,000 ° °

° ° ° p,515,051
5,119,600

° ° ° ° 11,973,000
10

Revenue

19,705,000 127 650,000 612,692 1 $!,515,059

Ii 1995,01~
159,951,982

114,350 140,177,199

H2,91~

!~ 10

1145,493,801

DEBT CITY OF AKRON OHIO Period Ending November 30, 2001
De,cription PUBLIC OTILITY DEBT (G,O, I Water Sewer P,U, SPECIAL REV, (oml Water Sewer P,O, SPECIAL REV, (OPWCI Water
Sewer

Trpe Bond, Bonds Loans Loan, Loans Loan, Loan, Bond, Bonds Bond, Loans

Total Outstandin 12/31/0 a 11,500,000 300,000 10,758,098 39,513,046
1,842,W

I"ues 2001

New
Balance 11,500,000 300,000
1l,m,H3 39,513,046

Rede"ed in 2001 $250,000 50,000 480,3+0 8,m,361 85,603 69,m 20,391 2,910,000

Total Out,tandinj 11/30/0 $1,250,000 250,000 10,759,108 36,856,685 1,816,7H 1,823,508 135,897 57,095,000 49,935,000 1108,530,000 151,392,039 H3,W,621 30,550,809 700,000 3,600,000 1,980,000 1,360,000 600,000 115,000 l!5,000 125,000 215,000 9,720,000 2,991,738 3,382,\96 5,214,887 7,520,758 4,180,158 254,163 510,000 7,215,000 3,350,000 4,076;509 1,020 000 19, m:ooo 935,000 8,158,000 6,815,000 3,310,000

$0 0 l&l,350

Recycle Energy S1't" P,O, DEBT (REVENUE Water ~ortgage Sewer TOTAL P,U, DEBT GENERAL DEBT Off Street Parking Street I.provesent Star. Sewer Isprovesent Bighwar I.prove.ent Rell Estate Acquisition &eqde EnerH Sy,te. Solid Wa,te orage Facil, ~unicipal Bldg, I.p. Park, Islrovesent

1,m,819 156 ,294

50,065,000 49,935,000 1111,800,000 $54,162,601 \34,810,000 23,800,000 770,000 4,000,000 2,080,000 2,040,000 180,000 810,000 150,000 150,000 330,000 9,120,000 3,060,000 3,m,m 5,480 ,DOD 7,695,000 4,451,109 855 ,891 570,000 1,215,000 3,350,000 4,960,000 505,000 1,020,000 18,170,000 935 ,ODD 5,720,000 3,555 ,ODD 3,370,000 1,520,000 1154,001,496 $0
$12,58~,130

° ° ° °
0 0 10 H81,l50 $H,m,627 10,630,809 700,000 0 0 0 ° 0 0 ° 0 ° 111,738

1,812,344 1,892,319 156,294 60,065,000 49,935,000 1111,800,000 $54,60,951 H9,546,m H,m,809 1,470,000 4,000,000 !,D80,000 8,010,000 120,000 150,000 150,000 330,000 9,720,000 3,231,138 3,m,496 10,m,881 H,m,758 8, 6ll, 567 H5 ,054 570,000 7,215,000 3,350,000 6,236,509 505,000 1,020,000 935,000 8,312, ODD 5,875,000 3,370,000 1,520,000
llO,OOO

p,m,ooo°
3,251,912 $6,300,000 3,880,000 770,000 100,000 100,000 580,000 120,000 35,000 35,000 25,000 55,000

Bonds Bond, Bonds Bonds Bonds Bonds Bonds Bond, Bonds Bonds ~unicipa Gara~e Bonds Pedes trian Wal war Co.puter/Com.unication Bonds Final Judgment Bonds Bonds Fubiic I.provement Bonds Convention Center Co.munity Center, Bond, Radio Communication System Bonds ~or1ey Health Center Plaza Bonds Bonds Ascot Park I.lrovesent Bonds Inventors Hal of Fame CitiCenter Huilding Bonds Combined Dispatcb Bonds West Side Depot Bonds Justice Center Plaza Bonds Recreational Facilities Bonds Northwest Fire Station 80nds . Bonds Kunici a1 Facilities Hotor k quipment Bonds Bond, High St, Renewal Area Energy Conservation Bonds Bonds Notes Bonds Notes Notes Notes Notes Bonds Notes COPs Bonds Bonds Bonds Loans
~oans

0 4,899,881 6,125,758 4,180,158 179,163

1,454,109 m,891

° 5,105,000 ° 6,800,000
!!O ,DOD

0 ° 1,276,509 ° 0

° ° 2,160,000
80,000

°

m,ooo

TOrAL GENERAL DEBT SPECIAL ASSESSMENTS Street Street Street Street TOrAL
3treet Improvement

$51,231,949 $0 11,515,051 5, m,600

° 8,512,000 ° 3,320,000 ° °
1,801,000

19 ,911 ,ODD

m,ooo°
180,000 60,000

$205,m,H5 10 IH,199,181 9,067,300 4,245,000 831,700 881,983 $\4,199,181 114,m,m 28 1 ,819,05 32,710,000

° 131,895,000
$0 11,913,000 0 ° 0 11,913,000 10 $0 10 $42,m 141,350 $40,411,199

° °

t,m,ooo

1173,358, !45
$0 112,m,181 9,061,300
!,m,OOO

Improvement Cleaning Sealing Resurfacing DEBT

3,m,700 4,215 ,DOD 831,100 881,988

° 0 °
$1,515,051 $5,719 ,600 10 10 10 10 10

$.A,

$12,684,130 $8,705,388 128,879, !l5 32,770,000 19 705,000 $ 7;650,000 $612,692 H,516,059 lH5,m,801

°

13l,100 881,m

112 ,226,181 H,m,988 8 F,879,m 32,710,000 19,105,000 $87 650,000 569,155 1 15,161, Hi

SPECIAL OBLIGATIONS Canal Park Stadium Non-Tax Revenue Income Tax Revenue JEDD Revenue Industrial Incubator-OnOD Capital Projects - OPWC GRAND TGrAL

$995, Ol! $59,951,982

\9,705,000 127,650,000 1512,092 15,512,091

l~

$505,H5,783

$464,968,584
000103

DEBT CITY OF AKRON OHIO Period Ending November 30, 2001
Description PUBLiC UTILITY OEBT (G.O.I Water Sewer P.O. SPECIAL REV. (OWDAI Water Sewer P.U. SPECIAL REV. (OPWCI Water Sewer Recycle Energy s stem P.O. DEBT (REVENUE Water Mortgage Sewer Type Bonds Bonds Loans Loans Loans Loans Loans Bonds 80nds 80nds Loans Bonds Bonds Bonds Bonds Bonds Bonds Bonds 80nds Bonds Bonds Bonds Bonds Bonds Bonds Bonds Bonds 80nds Bonds Bonds Bonds Bonds Bonds Bonds Bonds Bonds 80nds Bonds Bonds Bonds Bonds Bonds Notes Bonds Hotes Notes Botes Botes Bonds Notes COPs Bonds Bonds Bonds Loans Loans Total Outstandin 12/31/0 3 $1,500,000 300,000 10,158,098 39,513,046 1,8J2,lH 1,892.319 156; 29, 6D,065,OOO 49,935,000 $111,800,000 154,162,601 $34,810,000 23,800,000 110,000 ,,000,000 2,080,000 2,0,0,000 120,000 210,000 150,000 150,000 330,000 9,120,000 3,060,000 3,382,196 5,480,000 1,695,000 ",5',109 265,891 570,000 1,215,000 3,350,000 ,,960,000 505,000 1,020,000 18,110,000 935,000 5,120,000 1,555,000 3,310,000 1,520,000 $154,007,196 $0 $12,684,130 3,3!7,700 I,W,OOO 231,100 881,988 $12,684,130 $8,106,388 F8,879,m 32,110,000 $9,105,000 127 650,000 1612,692 $4,516,059 $H5,!93,801 New Issues 2001 $0 ,81,350 Balance $I,500,OOD 300,000 11,239,;;8 39,513,046 1,812,3H 1,892,819 156,29, 60,065,000 49,935,000 1111,800,OOO $54,643,951 $49,546,621 3<,00,809 l,l1O,OOO ,,000,000 2,080,000 2,040,000 120,000 210,000 150,000 150,000 330,000 9,120,000 3,231,138 3,382,,96 IO,l79,887 I4,!20,158 8,634,567 H5,05, 570,000 1,215,000 3,350,000 6,236,509 505,000 1,020,000 19,917,000 935,000 6,332,000 6,815,000 3,370,000 1,520,000 $205,2!7,H5 $0 1l!,199,181 9,061,300 1,215,000 231,100 B81,988 114,199,IBl 114,!25,988 128, 819, !35 $32,170,000 $9,105,000 $21 650,000 1612,692 $5,512,091 \505,145,183 Redeemed in 2001 i250,OOO 50,000 180,3<0 2,656,361 25,603 69,2l1 20,391 2,910,000 3 1,210,000° 3,251,912 16,300,000 3,8BO,OOO 110,000 ,00,000 100,000 680,000 120,000 35,000 25,000 25,000 55,000 240,000 5,105,000 6,600,000 1,,5,,109 190,691 Total Outstandin 11130/0

1

1

TOTAL P.O. DEBT GENERAL OEBT Off Street Parking Street I.prove.ent Storm Sewer I.prove.ent Bighw.y I.prove.ent Real Sstate Acquisition Recycle sner!E System SolId Waste orage Faci!. Hunicipal Bldg. Imp. Parks l.~rove.ent Bunicipa Gara~e Pedestrian W.l w.y Computer/Co••unication Final Judg.ent Public I.prove.ent Coovention Center Co~.unity Centers Radio Co.municatinn System Harley He.lth Center Pl.ta Ascot Park Im~rove ..nt Inventors Bal of Fame CitiCenter Building Co.bined Oispatch West Side Depot Justice Center Pl.ta Recreation.l Facilities Northwest Fire Station Kunicikal F.cilities Botor ouip~ent High St: Renew.l Area Snergy Conserv.tion TOTAL GENERAL DEBT SPECIAL ASSESSMENTS Street Improve.ent Street [.prove.ent Street Cle.ning Street Sealing Street Resurfacing TOTAL S.A. DEBT SPSCIAL OBL[GATIONS Can.l Park Stadium Non-Tax Revenue Income Tax Revenue JEDD Re..nue Industrial Incub.tor-ODOD Capital Projects - OPWC GRAND TOTAL

$0 $481,350

° ° ° ° ° ° °

$I,250,ODD 250,000 10,159,108 36,856,685 l,816,Hl 1,823,608 135,891 51,095,000 <9,935,000 $108,530,000 \51,392,039 $43,2lS,621 30,550,809 100,000 3,600,000 1,980,000 1,360,000 600,000 115,000 125,000 125,000 215,000 9,120,000 2,991,138 3,l82,!96 5,214,887 7,620,758 4,180,456 25,,163 570,000 7,215,000 3,350,000 ,,076,509 !25,OOO 1,020,000 19,742,000 935,000 8,152,000 6,815,000 3,310,000 1,520,000 1113,152,H5 1O $12,226,181 9,061,100 ,,245,000 231,100 B81,98B j12,226,181 l!,,25,988 F 8,679,4l5 32,170,000 $9,705,000 $271,50,000 569,155 15,467,Hl H6;,96S ,584
000104

$1l,136,621 10,630,809 100,000

° ° ° 0 °
0

1,899,887 6,125,158 ',180,m 119,163

° ° 111,138 ° 0
° ° °

° °

1,216,509 1,801,000

°

0 2,160,000 60,000

° ° °

° 2,612,000 ° 3,320,000
0

m,ooo °
180,000 60,000

° 151,239,9!9
$0 11,515,051 5,119,600 0 ° ° 11,515,051 15,119,600

131,895,000 10 $1,973,000

° °
0 °

° ° 11,m,OOO
1O 10

l~ $996,Ol~
159,951,982

$!2,m
HO,m,199

H

IH,350

OCT .11. 2001

1:22PM

OHIO EPA NEDO

I.ozar\l. ll1ovornmool Oonter 122 S. Front Stroot Columllqa, OH 4S2.16-10ee

TELE: (814) 644-3020 FAX: (B14)

B~

P,O. ~ox 1049
CQlumbus, OH 4$216-1049

Septemper 14, 2001

Dave Crandell Manager, City pf Akron Public Utilities Bureau 146 SOl.lth High Street . Akron. Ohio 44309 Dear Mr. Cranqell: Ohio EPA's Combined Sewer Overflow (esO) rev!ewgrOUp has completed the review ofthe City of Akron's Long-Term Control Plan (I..TCP). We appreciatt;l the significant efforts Akron has taken to analyze the collection system and receiving streams as weU as alternatives to control overflows. The LTCP is very well prepared and addresses most of our issues. Our comments on the l TCP are outlined below: 1. Presumptive Approach: Akron used the Presumptive APPfO<;lch to Justify use of Ul~mate Integrated Plan Number 2 (Alternative 2), The approaoh can pe based on numl:>er of overflo\\! events or percent capture. Akron's approach is based upon "The elimination or the capture for treatment of no less than 85% by volume ofthe combined sewage collected in the CSS during. precipitation events an a system-wiele annual average basis, ,.", Akron based the 85% capture of combined sewage using the entire collection system area notjustthe area served by combined sewers. The Akron collection system is apprc~imately 20% combined S/:lwers and 80% separately selA/ered, We believe that the intent of the eso Strategy is to utilize oniy the combined sewef portion of the collection system. Page 1 item 11.4, of the Ol1ia !=PA CSO Strategy also notes "An entire collection system is not classified as combined solely because it inclUdes some combined sewers." We believe that l:Iy !.lsing the flows from the separately sl?iwered areas Akron has not shown "85% by volume Of the combined sewage collected in the CSS ••• ".. As an illustration of O!.lr concerns, ifthe entire collection system Is used, two communities could have combined sewers of equal s!;l:e, wijh one of these two communities haVing a portion of separately sewerect area, Theoretically, the community having a portion of separately sewered area would have a higher capture of combined sewage than the esaonly commlJnlty. Bath communities could pe having the s~me water quality Impact on the stream from their CSOs. The community with a portion of separate sewers would be reqUired to do lass to meet the 85% capture criteria,

!lob raft,

ClQy~rnQr

M!l\.Iraan O'connor. Waul-natll ClOVQrnor ChrJ.toph~r Jon"", Director

000105

OCT. 11.2001
.'

1:23PM

OHIO EPA NEDO

NO. 504

P.3/5

Dave Crandell September 14, 2001 Page 2 In addition, the federal CSo strategy states that the numper of overflqw evantslyear and the 65% capture should lead to an equivalent level of captureltreatment. The LTCP indicates that more than 4 overflow events per year will occur under Alternative 2 from several major outfalls. Specifically we are concerned about the number of events (overflows) as well as the volume discharged from Racks 40/31, NSI Tunnel, DCI Tunnel and the Akron WPCS in Alternative 2. Based on the above, we do not feel Akron has met the 'presumptive approach' in the federal CSO Strategy. We also have concerns thatwithout additional treatment or storage, implementation of Alternative 2 will prevent attainment of the Cuyahoga RiVer for biology and p;icteria. 2. Sanitary Sewer Overflows (SSOs): There are several overflows on the Akron system that we feel constitute SSOs SUbject to the secondary treatment reqLlirements. These are overflows thatserve substantial separately sewared areas. We would like to address these overflows as part of our review of the LTCP. The system overflQws in question include Rack 40 (Ioc~teq on the main interceptor), Racks 33 and 35 (located on the Northside Interceptor), Racks 10 and 11, ancl Rack 18 (on the oel). The Akron Lrcp includes the construction of storage basins, treatment basins and tunnels. 'All three concepts InclUde an overflow to waters of the state once the design capacity has been exceeded. Review of Tables 4·2 through 4-5 indicate a sUbstantial discharge of flow and BOD loading from these overflows even after Implementation of Alternative 2. We also have concerns with the WPCS sBOPndary bypass. Review ofTables 4·2 throlJgh 4-5 show that the secondary bypass after completion of Alternative 2 contributes a large amount offlow and loading to the Cuyahoga Riverthus conmPLlting to waterquality impacts In the Cuyahoga. Given that 80% of Akron's collection system is separately sewered, bypasses at the WPCS are discharging significant flows from the separately sewered areas. While we encourage conveyance 01 flow from the combined areas to the POTW to allow for screening, grit removal, storage "mcl/or additional treatment. we WOllld also ask that fjowfrom the separately sewered areas be conveyed/expressed to the POTW to allow for full treatment prior to discharge. An analysis should be provided alii to wily it is not affordable or cost-effective to provide express sewers andlor secondarytreatment to the flows from Rack40 (located on the main interceptor), Racks 33 and 35 (located on the Northside Interceptor), Racks 10 and 11, and Rack 16 (on the OCI) as well as the WPCS sec0.ndary bypass. An analysis on the costeffectiveness to provide advanced physical-chemical treatment SUch as ACTI·FI.O for these overflows should also be provided.

000106

OCT. 11.2001
, .

1:23PM

OHIO EPA NEDO

NO. 504

P.4/S

Dave Crandell September 14, 2001 PageS

3.

Implementation Schedule and Funding: The LTCP recommended Alternative 2 to comply with the CSO PoHcy. The proposed schedule of 35 years. however. exceeds U.S. EPA recommendation (maximum of 20 years). We have significant cpncerns aboLlt sl.!ch a long implementation schedule. We did not see a detailed evaluation ofthe implementation schedLlIe and applicable federal guidance documents on affordabinty and schedules for implementing LTCPs. An LTCP is reqUired to assess the community's financial ability to I.lndertake CSO control projects. The financial assessment is used to determine if a project is feasible, affordable, and to determine the period of time required to complete a project. Please evaluate Alternative 2 and the implementation sched\.lle in the context of the U.S. EPA 'Combined Sewer Overflows-Guidance for Financial Capability Assessment and Scheduie Development.'

4.

TMDL and NPDES Permit Renewal soc! Antldegradation: We plan to integrate review of the LTCP with development of the TMDL for the Cuyahoga River downstream of Akron. The TMPL is scheduled for next year and, as such, we anticipate trying to inclucle the results of our LTCP review into the TMDL. We also plan to delay reissl.lance ofthe NPDES permit until we have resolved the LTCP issues and Cl'ln incorporate them into the NPDES renewal. antidegradatlon, we would like a specific cHscussion In the LTCP on areas in the existing service area as well as possiblt;l new service areaS that may experience new sewer extensions. An evalLlatlon of flow Increases and the effect on discharges from the sewer system and POTW sholJld be condLloted as well possible stream impElots (see Section 13 of Ohio's CSO Strategy and attached language we have used in other NPDES permits). We would like approval of this aspect of the LTep to serve as an antldegradation review to allow us to move away from tradeoffs in future permit tp install (PTI) submittals. We would propose to pUblic notice and take comments on the L.TCP and NPDES in order to address these antidegradation issues.
~egarding

After you have had a chance to review our comments, please contact either of us to arrange a meeting to discuss the l...TCP as well as answer any questions you may have. Sincerely,

?~ J)rrt-'~
Paul Novak, P.E., Mana~er Permits & Compliance Section Division of Surface Water (614) 644-2035

~

l2-. a.~.t/
Ron 13ell, Supervisor NEDO Division of Surface Water (330) 963-1200

000107

OCT .11. 2001

1: 24PM

OHIO EPA NEDO

,
,

.

NO. 604

P.5/5

. ..
Antidegradation Plan The permittee shall submit an antidegradationpJan to llle;:till= information submittal requirements of the antidegraclation regulations, Ohio Administrative Code (OAe) 3745-1-llS. The plan shall incll.1de data and infO\'ll1lltion th4t allows for the examination ofcontrol ~ltematives, review ofthe sooi1l1 anti eoonomio issues related to extellSion of sanitary SeWllfll or the addition of industrilll 4iaoWjl6s tributary to CSOs. If implementation of the plan results in site-speoific lowering ofwater qllll1ity, the director shall oonsider OAe 3746-1.05(C)(6)(a).{m) when making a determination regarding the plan. The plan should:
1) 2)

3)

4)
5)

6)
7) 8)

Idtlllti£y specific geographic areas tributary to cOlllbined sewer overflows to which the communitY p1a:lls to extend sanitary sewer servioe; Determine the drY weather flow CllfIacitics ofthe sewer and interceptor that will receive the increased flow: Detemtines the eldating dry weather:flow in the sewers and interceptors that will receive the increased fiow; Defines hoW much addi;tional dry weather, sanitary flow is planned in the sewers and interceptors; Predicts increases in frequency, duration, volume and poUlltljt!t loads frOlll wet Weather combined sewer overflows that will result from inoreasing the dry wellther flow in the sewers and interceptors; Ifthere is a bypass at the treatment plant, pradicts increases in frequency, duration. volume and pollutllI1t loads from bypasses that will result from the increased base dry weather flow: Predicts water quallty impacts to the receiving slrell1ll that Will result from increased combined sewer overflows and treatment pbmt hyPasses; and EvalMteli alternatives and proposes control mellSures that would eliminatlil increases in combined sewer overflows, treatment plant bypasses, and water qnality impacts.

000108

JOSEPH P. KIDDER Service Director VALERIE STRAW Executive Assistant DONALD L. PLUSQUELLIC

LUNZY O. ARMSTRONG Deputy Director JEFF FUSCO

fE1i
U'fi

if:: Cl~ EnVE[))

~?,Ruty

Director

Mayor

JU L j 0 2000
VHI() EPA. iII.I;..!J.().

DEPARTMENT OF PUBLIC SERVICE

July 10,2000

166 S. High St., Room 201 Akron, OH 44308 Phone: (330) 375-2270 FAX: (330) 375-2100

Ms. Sandra M. Cappotto, Euvironmental Scientist Division of Surface Water Ohio EPA, Northeast District Office 2110 East Aurora Road Twinsburg, OR 44087-1969 Re: City of Akron CSO Long Term Control Plan

Dear Ms. Cappotto: The purpose of this letter is to provide Ohio EPA with the information that was requested in your letter of May 25, 2000 concerning Akron's Long Term Control Plan ("LTCP"). For the sake of convenience, the information set forth below is provided in the same order as requested in your letter; i.e., a summary of the data justifying the calculated 94% flow capture, additional information supporting the prioritization of the projects set forth within the LTCP, and confirmation of Akron's financial commitment for the implementation of the LTCP. In the event that Ohio EPA has any additional questions with regards to the LTCP, we would be more than willing to meet with you and other representatives ofthe Ohio EPA to address the same.

I. Demonstration of the 85% Capture
The CSO Policy states the following about the Presumption Approach:

"The elimination or the capture for treatment of no less than 85% by volume of the combined sewage collected in the CSS during precipitation events on a system-wide annual average basis ... "
For the calculations of Akron's Annual Percent Capture, the following were assumed. • "Treatment" is defined as flows that receive at least primary treatment. • Combined sewage is any flow that is a mixture of stormwater and sanitary flow. • A "precipitation event" occurs when inflow to the WPCS exceeds the average daily flow. We used the following for the definition of Annual Percent Capture: Percent Capture Where,

VCFT
VTOTAL

000109

VCFT

Volume of flow "Captured for Treatment (CFT)". This shall include all influent to the WPCS (including secondary bypass) and all treated overflow from Treatment Basins in Alternative 2.

•

VOVERFLOW = the annual sum of all the untreated overflows from the combined sewer system including the basins and tunnels in Alternative 2. Tbe untreated overflow volume from each control structure was tracked during the model runs (summaries in Table 12-4 in Facilities Plan '98 Alternatives). V TOTAL = V CFT + VOVERFLOW V CFT was calculated as follows: Figure I shows a model generated inflow hydrograph at the WPCS. The flow data is given in hourly time steps (I'It = I hour). At each time step, the WPCS inflow rate, Q;, was checked against the daily average flow rate of 76.5 MGD' (118.4 cfs). This daily average flow rate was taken from the 1998 Akron Facilities Plan. Ifthe WPCS inflow was higher than the average daily flow rate, a precipitation event is said to be occurring and an incremental volume was calculated: V; = Qi x I'It The incremental volumes were summed for the entire year to give the total treated volume during times when inflow was above average (and thus "during precipitation events"). For Alternate #2:

VeFT
VOVERFLOW
VTOTAL

7,257 Mgal 454 Mgal 7,257 + 454 = 7,711 MGal

Percent Capture = 7,257/7,711

= 94%'

The modeled flows for Alternative 2 can be found on Table 4-2 ofthe LTCP.

1 76.5 MGD was the modeled average daily flow for the typical 1994 year at WPCS. Tbis value is above the average daily dry weather inflow shown on Table 2-2 of the 417/2000 submittal because it is an average of dry and wet weather inflows to WPCS. 'The City's Long Term Plan includes an additional 40 Million Gallons of storage at WPCS which was not included in the 94% capture calculation. The storage is provided to reduce secondary bypass and allow a greater amount of flow to receive full treatment.

2

000110

Figure 1. Calculation of Treated Volume When Inflow to WPC$ Above Annual Average
i-+-lNPCS IOIklW {MGD} Average Annual Flow Rille (MOD) I
~___________

180.00

~

,

180.00

j
! _

--,

.

V,'om, "wee, ,""ow""," "ow " "'''' '"",,'

'"""~,

140.00

120.00

~

100.00

i----------

-1i
!!!!!l!!§~=~""' .=<=~;;::;:;:;;:;:==-I .
1/1219418:00 1113194 0:00
Dati! and Time

,£

80.00 - - - -

00.00

------J '::I·~~-~--_·_------~
<000

j::1"::'::'~:--~~':''::'''::''~1+iiI~"m;;;;; ..;;;;;"";;;;;'"';;;;;,,;;;;;'",;;;;;'ow:o=li~;[-I-----~I ..;;;;;""";;;;;
j1I12/fl45:00 1/12/9412:00 11131946:00 1113194 12:00 1113194 18:00

1112/fl4 0:00

11141940:00

II. Prioritization The group of projects set forth in Alternative 2 of the LTCP was selected because it was determined to be the environmentally, technically and economically best method for addressing the CSO's within the City of Akron's combined sewer system. After selecting these projects, the schedule in Chapter 5 was developed for the purpose of implementing these projects in a manner that would effectively and efficiently address the CSO'Si Consisteut with the provisions of the Ohio and federal CSO policies cited within the LTCP, the schedule is intended to address some of Akron's legitimate financial concerns. However, contrary to the statements set forth within your letter, the schedule is not "based solely upon financial capabilities ...." Rather, important environmental and technical aspects were strongly considered during the development of the schedule including but not limited to impacts to sensitive areas. (See Section 3 of LTCP)
It is suggested in your letter that the Northside Interceptor Tunnel ("NSI") project should be implemented earlier in the schedule. However, the data clearly demonstrates that the Ohio Canal Interceptor (OCI) Tunnel will provide the most significant benefits as to reducing the impacts from the CSO's. (See Chapter 5, page 5.4 and Tables 4-2 through 4-5.) Moreover, the CSO's that will be controlled by the OCI discharge into the canal, which in turn discharges into important water bodies, i.e. the Little Cuyahoga River, Cuyahoga River. Given the substantial reduction in volume, events, hours and CBOD loadings that will result from the implementation of the OCI Tunnel, and the associated reduction of the potential impacts to the Little Cuyahoga and Cuyahoga Rivers, the OCI Tunnel was determined to be more environmentally beneficial when compared to the NSI.

In addition to the above, it is important to keep in mind the environmental, technical and engineering considerations regarding the implementation of all of the projects set forth in years 1 through 11. It is necessary to implement these additional projects prior to implementing the OCI or NSI projects. One of the two 20 MG storage basins at WPCS is required before either the OCI

3

000111

or NSI to avoid increased WPCS secondary bypass that would cause additional volume and CBOD loadings to the Cuyahoga River in the CVNRA. The CVNRA, like the Cascade and Gorge Metropolitan Park areas is a State resource water as delineated in Chapter 3 of the LTCP. In fact, the 40 MG of additional WPCS retention basins, even with a greater capture and transport to the WPCS of combined sewerage, will reduce the secondary bypass and allow a greater amount of flow to receive full treatment than now occurs. These considerations are summarized in the following table. The corresponding reductions that are expected to be achieved are set forth in Tables 4-2 thm 4-5 of the LTCP.

Major Projects (in order of staging) CSO Rack #40/31

Reason for Prioritization

- largest CSO by volume - largest stcrage basin - located on the Main Outfall - allow for flow maximization - high priority with Ohio EPA - needed so that other projects will not have an adverse effect on CSO. - gain experience with storage technology prior to design of other storage basins. - largest treatment basin -gain experience with treatment technology prior to design of other treatment basins - needed prior to OCI or NSI in order to not increase secondary by-pass - allows a greater amount of flow to receive full treatment - largest tunnel project - provides the most significant reductions in flow and load - needed prior to NSI tunnel and individual basins in order to not increase secondary bypass - remove CSOs from State Resource Waters and Gorge and Cascade Valley Metro Park

Important Waters Impacted SRW = State Resource Water PCR = Primary Contact Recreation Cuyahoga Valley National Recreation Area (SRW & PCR) Cuyahoga River, American Heritage River (SRW & PCR) Little Cuyahoga River (PCR)

CSO Rack #26/28

Cuyahoga Valley National Recreation Area (SRW & PCR) Cuyahoga River, American Heritage River (SRW & PCR) Little Cuyahoga River (PCR) Cuyahoga Valley National Recreation Area (SRW & PCR) Cuyahoga River, American Heritage River (SRW & PCR)

WPCS Storage Phase I

OCI Tumlel

WPCS Storage Phase I1

Cuyahoga Valley National Recreation Area (SRW & PCR) Cuyahoga River, American Heritage River (SRW & PCR) Little Cuyahoga River (PCR) Cuyahoga Valley National Recreation Area (SRW & PCR) Cuyahoga River, American Heritage River (SRW & PCR)

NSI Tunnel

Cuyahoga Valley National Recreation Area (SRW & PCR) Cuyahoga River, American Heritage River (SRW & PCR) Gorge and Cascade Valley Metropolitan Parks (SRW & PCR) ;

Finally, while the data clearly supports the technical and environmental benefits ofthe schedule proposed in Chapter 5, Akron is more than willing to meet with Ohio EPA and further discuss these benefits and tbe order of implementation, in greater detail.

4

000112

HI.

Financial Commitment

As part of developing its LTCP, the City of Akron evaluated several funding mechanisms. This includes, hut is not limited to, its existing source of revenue. The LTCP contains the level of financial commitment required under the Ohio and federal CSO Policies. Akron will commit to "aggressively pursue financial arrangements" for the implementation of the projects identified within the Long-term Control Plan. Consistent with the policy provisions that are cited in the LTCP, the City of Akron has proposed that the projects should be implemented as part of several successive five-year permits. Thus, the City of Akron, consistent with the federal and Obio CSO policies, has recommended a mechanism for the implementation of the projects. At the same time, and consistent with the expressed provisions of Ohio's CSO Policy, this compliance method will "allow for periodic reassessment of subsequent projects to consider new or improved control technology and to consider new information that may allow the appropriate water quality standards to be achieved using more cost effective controls." Likewise, given the cost of the controls, funding options will also have to be continually evaluated.
It is important to note that Akron has also demonstrated its financial commitment through its past and present actions. Akron has already spent millions of dollars to study the CSO's and to implement controls to reduce the associated impacts.

Finally, it must be pointed out that the City of Akron has proposed a LTCP that will cost more than $248,000,000.00 to implement. (This is in addition to the millions that Akron has already spent to date to study, address, and reduce CSO's, and the $25 million spent to eliminate SSO's.) Obviously, it is not possible from an economic or technical standpoint to implement these projects ovemight. Rather, it will take several years to complete the implementation. The successful implementation of CSO controls will depend upon the joint co-operation and coordination between the City of Akron and Ohio EPA.
If you have any questions or would require any further information, Please contact Patrick Gsellman, P.E. , Environmental Division Manager at (330) 375-2357.

Joseph P. Kidder, Director Department of Public Service attachment C: Mayor Plusquellic, D. Celik, D. Crandell, P. Gsellman, G. Bozeka, File F-04, Environmental Division File

5
000113

State of Ohio Environmental Protection Agency

Northeast District Office
2110 E. Aurora Road Twinsburg, Ohio 44087-1969 TELE (330) 425-9171 FAX (330) 487·0769 Bob Taft, Governor Christopher Jones, Director

May 25, 2000

City of Akron Long Term Control Plan

Mr. Joseph Kidder, Director Department of Public Service 166 S. High Street, Room 20 I Akron, OH 44308 Dear Mr. Kidder: On April 7,2000 the City of Akron suhmitted their Long Term Control Plan (LTCP) for controlling combined sewer overflows (CSO) as ordered by Director's Final Findings and Orders effective September 20, 1994. Based upon ourreview ofthe iuformation provided we have determ ined that the LTCP for the City of Akron is deficient in characterizing the combined sewer system to support the presumptive approach and in demonstrating a commitment to the implementation of the recommended controls. Specific areas of concern which need to be addressed, and are discussed in more detail below, include the modeling data used to determine the 85% capture, scheduling and prioritizing the implementation of controls, especially in sensitive areas identified by the LTCP and demonstrating the City's financial commitment to the overall implementation of the LTCP. Modeling and Documentation to Demonstrate 85°;(. Capture (presumptive Approach) The second criteria for the Presumptive Approach listed in the USEPA "Combined Sewer Overflows: Guidance for Long Term Control Plan" is the "elimination or the capture for treatment of no less than 85% by volume ofthe combined sewage collected in the Combined Scwer System during precipitation events on a system-wide annual basis." As stated by the City's LTCP Ultimate Integrated Plan No.2 would achieve 94% capture; however, the supportive data justifying all the figures in the calculation are not readily identified. In order to fully evaluate the calculation shown on page 4.15 a summary of the appropriate modeling data for the values used must be provided. The supportive data should be presented in a summary format (tables are acceptable) which represents the hydraulic conditions of the collection system under various wet weather conditions. The data must also show how dry weather flows and flows from separate sewer areas were used in the calculation. Scheduling Details and Priorities Sensitive areas identified in Chaptcr 3 ofthe City' s LTCP for the Cuyahoga River planning area include state resource waters and primary contact for recreational use. The relative importance of these areas is not reflected in the implementation plan and compliance schedule found in Chapter 5. In fact, the schedule for implementation is based solely upon financial capabilities which have not been documented. The Gorge and Cascade Valley Metropolitan Parks are areas identified as state resource waters and are impacted by the Northside Interceptor CSOs; however, the program schedule (Table 5-1) for the Northside Interceptor tunnel project is not scheduled until 2021. Another area identified as state resource waters is located in the Cuyahoga Valley National Recreation Area downstream of all CSOs. The projects that will have the greatest impact on Rack 40 and Rack 18, the largest discharges, are delayed until 2011 and 2016. In accordance with the CSO Control Policy the highest priority for controlling overflows should be given
to receiving waters identified as sensitive areas.
Printed on recycled papar

*

000114

MR. KIDDER MAY 25, 2000 PAGE 2.

As presented, the implementation plan does not ensure the initiation or completion of any projects. The program schedule is totally independent of each project grouping. The plan does not discuss whether the entire project will be completed in the five year cycle, whether engineering and fund acquisition will be done earlier so that project construction can begin at the start of the five year cycle, or how the projects will be staggered within each five year cycle and over the five year cycles.
Documentation of Financial Commitment

The CSO Control Policy states that each municipality "is ultimately responsible for aggressively pursuing financial arrangements." The City's LTCP is lacking in any financial commitment for securing the funding necessary for the implementation of Ultimate Integrated Plan No.2 controls. As stated on page 5.7 ofthe LTCP completion of the projects are contingent upon the availability of financing which is assessed with each group of scheduled projects. As part ofthe planning process prior to submittal ofthe LTCP both a capital funding approach and a method for collecting annual funds were to be developed. The City's LTCP would then specify the financial methods selected and how these financial capabilities relate to the implementation schedule for the selected controls. A municipality's financial capabilities is a tool by which to prioritize the implementation of the LTCP controls and not a means by which to determine if the controls of the LTCP will be executed. In summary, the City's LTCP does not effectively demonstrate the City's commitment to provide for the attainment of water quality standards. It should also be noted that the development and implementation of a LTCP is to address the impacts on receiving water quality caused by a municipality's CSO and is not contingent upon the commitment of this agency to grant variances or use designation modification or to address upstream sources as noted on page 4.13 of the City's LTCP. As submitted, this office cannot recommend approval ofthe City's LTCP. All deficiencies noted above must be addressed and a revised LTCP remitted to this office for review not later than thirty days from the above date of this letter. If you should have any questions or would like to schedule a meeting to further discuss these issues please contact this office at (330) 963-1124. Sincerely,

~\du.-- pt· (j.fJ~,J
Sandra M. Cappotto Environmental Scientist Division of Surface Water cc: Mayor and Council, City of Akron Patrick Gsellman, City of Akron Gary Stuhlfauth, CO, DSW Keith Riley, NEDO, DSW Ron Bell, NEDO, DSW
000115

JOSEPH P. KIDDER

Service Director
VALERIE STRAW

LUNZY O. ARMSTRONG Deputy Director JEff FUSCO
Deputy Director
DONALD L. PLUSQUELLIC

Executive Assistant

Mayor

DEPARTMENT OF PUBLIC SERVICE
166 S. High St" Room 201
Akron,OH 44308

November 30, 1999

Phone: (3301 375-2270
FAX: (330) 375-2100

Ms. Sandra M. Cappotto. Environmental Scientist Division of Surface Water Ohio EPA. Northeast District Office 2110 East Aurora Road . Twinsburg, OH 44087-1969 Re: Facilities Plan Update (Long Tenm Control Plan)

Dear Ms. Cappotto: Please find enclosed a report describing the collection system alternative selection for the Akron Facilities Plan CSO Long Term Control Plan (LTCP). The selected alternative, Alternative 2, incorporates storage conveyance tunnels. detention basins. treatment basins and sewer separations. The City is currently prioritizing individual projects from the selected Alternative 2 and determining the required funding levels. The projects have been grouped into initial categories which could be associated with time frames or permit cycles. The groupings are as follows: (1) Rack 40/31 Storage Rack 26/28 Treatment Sewer Separation 39. 9 and partial 21/22 (2) WPCS Storage Phase I Misc. Separations CR Re-Aeration pilot (3) Ohio Canal Tunnel LCR Restoration (4) WPCS Storage Phase II WPCS Disinfection Rack 14 and 15 Storage Rack 3 and 12 Treatment After each grouping period. the projects need to be re-assessed. re-evaluated and re-prioritized based on WQ, local needs. funding etc. The benefits of the first grouping are the projects provide: (1) for a pilot storage basin and treatment basin, (2) control the high priority Rack 40. (3) enhanced floatable control under the nine minimum control activities. (4) river restoraliol'l pilot project. (5) cost-effective separation and (6) improvement in water quality.
000116

(5) Northside Tunnel

(6) Rack 8 and 30 Separation Rack 36 Storage Rack 10/11 Treatment (7) Rack 7/5 and 22 Storage Rack 25, 13, and 21 Separation Rack 29/27 Treatment

Cappotto Nov. 30, 1999 Page 2

Akron has recently spent significant funds at the WPCS and the sewer system eliminating the sanitary sewer overflows which are still plaguing several Ohio cities. During this period, Akron has seen significant rate increases. It needs to be noted that Akron's 1999 annual residential sewer rate ($317) exceeds Canton ($172), Cincinnati ($269), Columbus ($259), Dayton ($305), Lima ($310) and Toledo ($276). It is very close to the Cleveland ($319) rate. Also, the Akron Public Utilities Bureau (PUB) is undergoing significant changes as a result of excessive rates. The rates for water led to a Blue Ribbon Panel to s1udy the PUB. The PUB is currently undergoing a re-engineering process which started in the Business Office. It has been expanded to the entire PUB including Water Treatment Plant, Sewer Maintenance, Wastewater Plant and Utilities Engineering. During this time of funding constraints and transition, Akron will begin a selected Long Term Control Plan by implementing priority projects, pilot projects and enhanced floatable control under the nine minimum control activities. Akron will also seek grants and outside funding sources to supplement the costs of future LTCP projects. The proposed City of Akron 2000 budget includes the following projects: Bowery St (Quaker to State) Separation Project Monitoring/Rain Flow Gauge Maintenance $300,000 Construction of separate sanitary and storm sewers within the area to eliminate CS039 The rain gauge and flow monitoring continued consists of program collection and data maintenance, management of long term flow monitors and rain gauges throughout the City of Akron service area. The program is used to evaluate the performance of the City of Akron sewer and stream system during rain events This proposed pilot stUdy will evaluate improving water quality by restoring the riparian corridor of the Little Cuyahoga river through Elizabeth Park. The project objective is to attain Water Quality Use Designations as proposed by Ohio EPA by improving the habitat for fish and bugs along the riparian corridor. Replace metal plates in common manholes separating sanitary sewer and storm sewer flows in Kelly Avenue area, Firestone Parkway/Front st area, W. Market at Putnam, and Glendale near Dawes. Miscellaneous sanitary sewer repairs, replacement and linings. Includes Rack 33 improvements.
000117

$100,000

Little Cuyahoga River Bank Restoration

$260,000

Over/Under sewer Access Manholes Rehab.

$50,000

Sanitary Reconstruction

Sewer $500,000

Cappotto Nov. 30, 1999 Page 3

At this time, Akron request a meeting with your office to discuss the proposed groupings and time frames for priority projects for incorporation into Akron's 2000 budget and the five-year budget. We would like to schedule a Technical Advisor group meeting in January. In order to continue the selection of projects for development and implementation of the Long Term Control Plan, the City needs to discuss the following issues with the Ohio EPA: • Comments and agreement on the Facilities Plan, Alternative Analysis, and Selected Plan. Re-evaluation of WQS for wet weather. Study use designations for Cuyahoga River, Little Cuyahoga River, and Ohio Canal. Study of variance for the Ohio Edison Gorge. Study of variance for csa receiving streams until the proposed Urban Stream Habitat can be fully assessed. Assist the City in developing funding options, including but not limited to, USEPA, special Congressional action, State Revolving grants/loan, River Navigator assistance, new Clean Water grant program (proposed), etc. Impact of the re-issuance of the City's NPDES permit.

• • • •

•

•

Akron continues to develop access to the receiving streams with bike paths, downtown development, Muslill Store and Cascade Lock Park. Also, the National Heritage River designation and National Park will continue to bring people to the River. We look forward to a solution that will, cost-effectively benefit the Akron rate payers, enhance the parks and trails, and further the goals of the Clean Water Act. Please contact Patrick Gsellman, P.E.. Environmental Division Manager at your convenience at 330-375-2357.

i I

l

!

JPKlPDG/ag Enclosure c: Mayor Donald L. Plusquellic C. D. Haugh J. Bronowski D. Crandell M. McGlinchy G. Bozeka File F-04 Environmental Division File
000118

I

I
I ,

i
i

i
I

I

TOTAL P.04

State of Ohio En.vironmental Protection Agency
STREET ADDRESS:

MAiUNG ADDRESS;
TELE: (614) 644-3020 FAX: (614) 644-2329

1800 WaterMark Drive Columbus, OH 43215-1099

P.O. Box 1049 Columbus. OH 4321£>.1049

December 2 r 1996 Mr. David Crandell Public Utilities Bureau City of Akron P.O. Box 3665 Akron, Ohio 44309-3665 Dear Mr. Crandell: This letter is written to further detail the Ohio EPArs response regarding the City of Akron's request to issue a variance on water quality standards applicable to the Cuyahoga and Little Cuyahoga rivers. The City's Combined Sewer Overflow (CSO) Systemwide Study made the recommendation to establish a variance from warmwater habitat biological criteria for the Cuyahoga River (River Mile [RM] 42.6 to 37.4) and the Little Cuyahoga River (RM 4.6 to 0). A letter dated August 22, 1996 from William Zawiski to you briefly described the Agency1s reservations about these variances. After discussing the matter with my staff, I have decided the Division of Surface Water should not implement the requested variance. I do not believe the adoption of a waterbody variance from meeting the applicable biological criteria is an appropriate program direction for the Agency. The aquatic life use and the associated chemical and biological criteria represent the desired long-term goals for our waterbodies. Our long-standing protocol has been to issue variances to specific sources where evidence is clear that the costs of attaining the standard meets the test of widespread adverse social and economic hardship. When other factors such as habitat preclude attainment of standardS r we have historically revised the aquatic life use designation. Because your report raises issues about the uncertainty of habitat recovery, I believe periodic assessment (and possible revision if appropriate) of the aquatiC' life use designation is a more appropriate course of action. I appreciate your concern over the potential risk r liability and costs that exist when the warmwater standards are not attained. The Division·of Surface Water recently circulated for comment draft rule changes (Ohio Administrative Code 3745-1-07(A)) that helps to reduce this risk. The rule changes place more specifications on the evidence needed before the Agency can require additional regulatory controls on sources impacting stream segments that do not attain the biological criteria. I expect this rule change to be proposed in January of 1997 and to become effective later in 1997. The Division of Surface Water welcomes your comments on this rule change and is willing to further discuss any new data regarding the appropriate aquatic life designation for the Cuyahoga and Little Cuyahoga rivers. If you have questions, please do not hesitate to contact Dan Dudley at (614) 644-2876.

Thomas P. Behlen, Chief Division of Surface Water
st\crandell.dd

cc:

William Skowronski, Northeast District Office William Zawiski r Northeast District Office Seif Amragy, M&A Section Manager Gary Stuhlfauth, WRM Section Chris Yoder, Ecological Assessment Unit wQS file
George V. Voinovich, Governor Nancy P. Hollister, Lt Governor Donald R. Schregardus, Director

*

Printed on Recycled Paper

000119

State of Ohio Environmental Protection Agency

Northeast District Office
2110 E.Aurora Road TWinsburg, Ohio 44087-1969 (216) 425-9171 FAX (216) 487-0769

George V. Voinovich Governor

August 22,1996 Mr, David Crandell City of Akron Public Utilities Bureau146 South High Street P.O. Box 3665 Akron, Ohio 44309-3665 Dear Mr. Crandell: The purpose of this letter is to summarize Ohio EPA's comments on your December 1995 CSO system-wide study and our July 18, 1996, meeting. The City of Akron was required to complete an evaluation of potential receiving stream impacts resulting from combined sewer overflows. The report was also specifically to address the stream impact of peak flows from secondary bypass events at the treatment plant. Both requirements are found in Director's Final Findings and Orders effective September 20, 1994, Order S.c. Order 5.c.iii. required that an approvable report be submitted by December 31, 1995. The report was received at Ohio EPA's Northeast District Office on December 28, 1995. As submitted, the report addressed an assessment of Akron's interpretation of CSO impacts. The report did not fulfill the intent of addressing impacts from secondary bypass events. Past Ohio EPA surveys have detected impacts on the Cuyahoga River as far as 20-25 miles downstream from the WWTP. Conclusions in the December 1995 CSO impacts study indicate that in Akron's opinion, combined sewer impacts are not a major source of degradation to the receiving streams. The Ohio EPA does not concur with Akron's interpretation of the data. Our biological evaluation unit indicates that an impact from CSO's is shown by the data. In addition, several significant flaws exist in the actual sampling protocol used by the city in its study. In general the computer aided modeling was conducted properly. Models used were suited to the needs of the system. Actual rain "events used in the model calibration were of a small size, During the study a 5 or 10 year stonn did not occur. Lack of a significant real rain event did not allow model testing at higher flows. It also did not allow for more accurate detennination of the fate of combined sewage. The model did demonstrate a significant volume of combined sewage'

*

Primed on rocyclad paper

000120

Mr. David Crandell August 22, 1996 Page 2 enters receiving streams during storm events. Modeling ofthe sewer system demonstrates a threshold for combined sewer overflows at 0.1 inch of rain per hour. The niodel did not predict, nor was it discussed, what happens to combined sewage during surcharge events in both the combined sewers and combined sewer overflows. This can constitute a significant-;olume of combined sewage. Water quality modeling stopped at Bath Road. This is not appropriate, as potential Water Quality Standard impacts will occur downstream of this site. The following points will present comments on the data generation/gathering portions of the report:

*
*

Biological field collection methods for both fish and macroinvertebrates showed some deviations from Ohio EPA protocol. The use of a seine downstream of the Ohio Edison dam deviates significantly from EPA electrofishing guidelines. Data generated cannot accurately be included and interpreted with the other results. During the first 1994 sampling effort, it appears that Hester-Dandy samplers were individually analyzed. During the 1995 survey the samplers were composited in accordance with Ohio EPA protocol. Lack of compositing may lead to inaccurate results. Several sites in the 1995 survey also used three Hester-Dandy, plates which is only appropriate for the purpose of generating data for the US EPA NAWQM program. Ohio EPA biomonitoring programs are based on a strict protocol. Deviations or changes may result in generating data which are not comparable. Generally, the Akron data did compare with past EPA results.

*

*

However, the interpretation of study results is the point of greatest difference between Ohio EPA and Akron. The Ohio EPA does not agree with the city in concluding that CSO's are only minor contributors to stream degradation. The city raises different interpretations of significant and insignificant impacts. For example: a change in the ICI values from upstream (16) to downstream (6) demonstrates a significant impact, in Ohio EPA's judgement, independent of attainment at the upstream point (Section 10.6.5.2). This interpretation of significance also carries over to IEI results, where an upstream CSO value of25.5 is reported by Akron as causing an insignificant impact to a downstream value of21 (page 19.6-20). Again the Ohio EPA does not concur with this judgement as a score difference of four points is considered significant, the above mentioned IEI score shows a marginal impact.

000121

Mr. David Crandell August 22, 1996 Page 3 Much comparison is made to attainment ofMWH, even though WWH is the proper use designation. The MWH comparison is not appropriate. The current use designation of all streamS except the Ohio Canal is WWH. Habitat evaluations using the QHEI indicate that in most areas, habitat is not a consideration for non attainment. The Ohio EPA uses a mean QHEI score of 60 in a stream segment to determine if the segment can support the WWH use designation. The city used a score of 70 as indicative ofWWH. As a result, several areas listed as habitat limited (eg. Cuyahoga River Segment 3) are truly not habitat limited, with a mean QHEI of 65. The practice of "agreement" between two separate QHEI evaluations by separate consultants to achieve a single score does not follow Ohio EPA protocol (Section 10.3.3.1.). Separate score sheets from the consultants were not presented. The city did suggest that other sources were the significant causes of non attainment. The Ohio EPA accepts that impairment may be influenced by other sources, but does not agree that they are of greater significance than the CSO's. The Ohio EPA will be assessing other sources during the intensive survey this summer. Due to the small amount of rainfall needed to generate CSO's and the resulting large number of events and volume of combined sewage discharged, CSO events do not always coincide with periods of high stream flows. This is best shown in a slide presented during our July 18 meeting. Titled "Cuyahoga River Dissolved Oxygen Depletion", the slide shows that as base river flows decrease, oxygen stress to the river increases. The city also needs to implement CSO and NPS control measures when available. The final report mentioned the construction of a new baseball stadium as an oppOltunity to work in some off-line controls. During our July 18 meeting it was indicated that no controls were planned. As the Ohio Canal contributes a majority of CSO flow and bacterial loading to the Cuyahoga River, it would appear that control of additional loadings should be addressed. Many coml11Unities have an active stormwater/riparian protection program. Currently the city does not have one. The Ohio EPA stormwater permitting program would prove an ideal vehicle for Akron to gain some control of "other sources" of pollution. The Ohio EPA can get copies of ordinances used in other communities for Akron to review. In addition to the above, the Ohio EPA is obligated to protect downstream uses of the Cuyahoga River. Continued loading of combined sewage, secondary bypass, and bacteria to the Cuyahoga Valley National Recreation Area are not protective.

000122

Mr. David Crandell August 22, 1996 Page 4 At our July meeting, you specifically requested preliminary responses to several use designation changes and variance requests recommended by the study. These were included in Tables I and 2 of Akron's December 29,1995, submittal letter to Ron Bell. Regarding the aquatic life use changes for the Little Cuyahoga River (RM 9.8-4.6) and Camp Brook, Ohio EPA will be evaluating these segments during the 1996 intensive survey. Once this data is available, Ohio EPA will be able to eviIuate if the MWH use designation recommended by your study is appropriate. The Agency does not agree with the recommended MWH use designation for the segment of the Cuyahoga River (RM 46-44.6) impounded by the Ohio Edison dam. The variance requests recommended for the Cuyahoga River (RM 42.6-37.5) and the Little Cuyahoga River (RM 4.6-0.0) are variances from the WWH biological criteria. These segments are impacted by multiple stressors. Considering US EPA guidance, a variance might be an appropriate mechanism to maintain the existing WWH use while allowing time for additional evaluation of the multiple impacts and potential controls. Variances typically are chemical specific, they apply to an effluent, and they are issued to the discharger responsible for the nonattainment. The requests in your letter are new to Ohio EPA, in that they are for "waterbody" variances. They apply to stream criteria (biological), not chemical specific criteria regulated in an effluent, and they are not covered under Ohio EPA's rules. A follow-up letter will further address these variance requests. In regards to the recreational use recommendations included in Table 2 of your letter, the changes to the PCR designation for the Cuyahoga River (RM 46-44.6) and Little Cuyahoga River (RM 9.8-4.6) will be considered as part of the 1996 intensive survey. Ohio EPA's CSO ad hoc committee has identified recreational bacteriological criteria as a topic that it is going to address. There is general agreement that the current criteria do not do a good job assessing receiving waters, particularly when wet weather conditions are considered. At this time, we are not considering issuing wet weather variances for the recreational criteria, particularly considering the multiple sources of high instream bacteria levels during wet weather events. During the conclusion of our July 18, 1996, meeting, the city requested guidance to aide preparation of the Long Term Control Plan. Our recommendation will be to complete preparation of a comprehensive Nine Minimum Control (NMC) plan. In addition, decreases in the volume of CSO loadings will be needed. Several areas of high III (Ohio Canal) should also be investigated for further control. We also believe that the long term control plan should address increased sewer system capacity to handle larger storm flows, toxicity control of industrial discharges to the combined sewer system, priority treatment of separate sewer areas, and treatment of all sewage that reaches the sewage treatment plant. Rack cleaning and maintenance practices must be further developed and implemented. Intensive rack cleaning will result in some reduction in CSO events.

000123

Mr. David Crandell August 22, 1996 Page 5 The Ohio EPA recognizes the potential costs to the city for complete CSO removal. Currently the watershed is impacted by CSO events, and these CSO events exceed the systems capacity to attenuate such impacts. We look forward to working with the City of Akron to move toward the further improvement of the quality of our waters. Should you have further questions please feel free to contact me at 216/963-1134. Sincerely,

William J. Zawiski Environmental Scientist Division of Surface Water WJZ:bp cc: Tom Behlen, CO-DSW John Januska, NEDO-DSW Mark Stump, CO-DSW
(ii;~Y4iS'tUhlfau.1ih;JeOLDSi~.

Jelmy Leshnock, CO-DSW Mark Garner, CO-DSW Chris Yoder, CO-DSW-EES Jeff DeShon, CO-DSW-EES Marc Smith, CO-DSW-EES Bob Miltner, CO-DSW-EES Jack Frieda, CO-DSW-EES Josie Scovanner, CO-DSW Randy Boul11ique, CO-DSW

Bob Wysenski, NEDO-DO Ron Bell, NEDO-DSW Dennis Lee, NEDO-DSW Dave Stroud, NEDO-DSW Steve Tuckerman, NEDO-DSW Sandy Cappotto, NEDO-DSW Kelvin Rogers, NEDO-DSW Dan Rice, OECCC Mary Beth Bimls, Cuyahoga RAP John Debo, CVNRA Summit County Health Department Joe Hadley, NEFCO Wendy Reust, City of Akron

000124

Ohio EPA Comments Regarding CSO System Wide Study and Responses to those Comments
Chapter 5.3 Sampling of Receiving Waters for Macroinvertebrate Analyses Section 5.3.3, P. 5.13, 2nd paragraph, last sentence Reads '~T{owever, samplers at several sites on the Little Cuyahoga River were wrapped in debris to a vGlying extent. ..
Ohio EPA comments: This is a common occurrence in urban streams in Ohio and should not be construed as a negative with regard to success of sampling. Urban debris is likely a "natural" feature which affects natural habitat ccnditions in urban streams with equal frequency. Response: Though this may be a common occurrence, it is not "natural." Particularly since the "artificial substrates are specifically positioned so that they are in areas of good flow they create an obstmction that has a greater tendency to snag debris than "natural" substrates." Also, the specific references in the Little Cuyahoga River events were to extreme cases of debris accumulation including a pair' of jeans wrapped around the samplers.

Section 5.3.3, P. 5.14, 2nd paragraph Ohio EPA comments: It appears that, although two artificial substrate collections were made at each sampling location, only one qualitative sample was collected - in this case when the second set of substrates were ccllected in late September. Ohio EPA protoccls require the qualitative collection to be made at the time of sampler retrieval (Vol. 3, P. V-1-2) so that one has an inventory of species found inhabiting natural substrates at the time the artificial substrates are collected. This is important since ICI Metric 10 requires information from the qualitative sample which is matched with the other 9 metrics based on the artificial substrate collection. Presuming the use of the late September ccllection to determine the Metric 10 for ICI sccres based on the first artificial substrate colonization period (July!August) would be a significant deviation from the Ohio EPA protoccl. This may be important if one is observing substantial differences between the results of each colonization period (e.g., due to changing water quality conditions or seasonal changes in the macroinvertebrate community). Although this may not have significantly altered leI scores, itshould be noted as a deficiency.
Response: It is true that only one qualitative sample was collected to calculate metric ten of the ICI instead of one sample for each event as required by the protocol. During the process of setting and retrieving samplers for the two 1994 sampling events there was a mis-communication between consultants and the qualitative sample was not collected upon retrieval of round 1 samplers. Since the samplers had already been collected there was no reccurse other than to use the qualitative sample collected at the
0161-153

1
000125

end of the season for both events. We could have just used the second sampling round for the report, and used the first round for comparison purposes. Ohio EPA protocol does not require two sampling events for macroinvertebrates. The results from the second event were substantively the same as the first. Even if data from the first event are eliminated, the conclusions drawn by Akron are equally well supported. Section 5.3.3, P. 5.14, 1st bullet The bullet describes the position and location ofartificial substrate samplers. Ohio EPA comments: Use of steel rods to anchor the artificial substrates and suspend them somewhat above the natural substrates is a deviation from Ohio EPA protocols. We attach the substrates to a concrete construction block which is then securely positioned in the natural bottom substrates. This allows an intimate connection with those substrates while keeping the artificial substrates somewhat elevated above finer substrate material. Such a connection facilitates organism colonization from the immediate surrounding natural substrates by providing direct contact via the block with the artificial substrate. This migration is an important means of colonization which, along with drift and other colonization modes, results in the ultimate community established. Use of suspended artificial substrates on a thin steel rod would seem to isolate them from the natural substrates and hamper organism colonization via migration from surrounding substrates. We're not sure of what the consequences of this would be other than the fact that leI scoring and calibration were based on reference data collected using construction blocks and artificial substrates as described above. One of the tenets of our sampling program is that standardized field sampling methodologies must always be used to avoid interjecting additional sampling variability potential. Response: The use of stakes instead of cement blocks to position Hester-Dendy samplers was meant to be consistent with Ohio EPA protocol. The positioning of our samplers was discussed with Bob Davic, Steve Tuckerman and others at NEDO before samplers were placed. During our first round of sampling we positioned samplers on both blocks and stakes at several sites to have a backup set of samplers if one was lost. Almost all of the samplers positioned on cement blocks were not recovered. Some cement blocks were lost even when they had been secured by cords or fastened with stakes. Over 95% of samplers positioned on stakes were recovered both 1994 and 1995 sampling. The samplers were positioned in accordance with the guidance presented on page V-I-2 of Volume II of the user manual. The stakes placed substrates in a situation that is identical to substrates attached on a float in deep water as specified on page V-I-2 of the user manual. Section 5.3.3., P. 5.15, last bullet Ohio EPA comments: We interpret the description of collecting the artificial substrates to mean that they were physically removed from the water and placed in a polyethylene container or bag. This would be a significant deviation from Ohio EPA protocols which requires that individual substrate to be gently and carefully removed (i.e., cut from the block and placed in the sample container while it is submersed (Vol. 3, P.V-1-2). We are greatly concerned about the potential loss of organisms (especially mobile, free-moving forms) while "lifting the sampler quickly" and placing it in a container.
0161-153

2

000126

Response: Our descriptive language was not accurate. Our collection procedures followed the methods described above with the exception that under some current and water conditions, samplers were placed in a fine mesh dip net or large bus pan while still submerged. The samplers were then transferred to containers. Any insects remaining in the net were distributed in the containers. If bus pans were submerged, the water in the pan was screened through a # 40 sieve and the organisms transferred to containers. As evidence for our ability for collecting mobile free moving forms we collected free swimming amphipods, and even cladocerans at several sites. We also collected larger free swinuning forms such as crayfish at numerous locations. In some cases fish were even collected with the samplers (though not recorded). Section 5.3.4, P. 5.15, 2nd paragraph Ihe water in the trays was' then washed through a No. 35 sieve. The sieve was placed over a white pan to collect any small organisms that might pass through the sieve. Ihe organisms were then pickedfrom the screen with forceps andplaced into the sample vessel. The remaining debris in the sieve was rinsed and the pan was visually checkedfor any other small organisms. Ohio EPA comments: Ohio EPA protocols require sorting and picking procedures that include examination of the sample under the dissecting microscope with lOX magnification (Vol. 3, P. V-1-6). It is unclear from the discussion in this paragraph whether any magnification was used in the sorting process. It is our experience that many small organisms can be easily missed with macroscopic examination. Also, our protocols specify the sue of a No. 40 sieve to screen organisms. Their use of a No. 35 sieve (coarser mesh size) was a deviation from standard procedures. Response: Pans were checked under dissecting magnification, though it was not specifically noted in the text. Use of dissecting microscopes to pick samples is not only Ohio EPA procedure but is routinely used by freshwater invertebrate zoologists. The use of # 35 mesh was described since the laboratory initially used that size sieve. About midway through sorting the first round of samples the error was discovered and the lab switched to # 40 sieves. The procedure as described would not lose any small macroinvertebrates since the filtrate passing through the sieve was examined in the white pans. If the procedure was in error, it might have over collected small organisms. The presence of numerous small organisms in the samples is evidence for the effectiveness of the sorting techniques. Section 5.3.6.2, P. 5.17 Ohio EPA comments: Although mentioned that it was used for some sites, we didn't see any use of a Community Similarity Index in the report. This section should be deleted if no evaluation was made. Response: It was used but nothing worth describing was discovered. It was left in the report in case we find something interesting with that statistic in the future.

0161·153

3
000127

Additional note on macroinvertebrate methods: Ohio EPA comments: Although it was not specifically mentioned, the five artificial substrates were apparently treated as replicates and each individually analyzed. This is a deviation from Ohio EPA protocols which states that the five substrates are composited and then analyzed (Vol. 3, P. V-I-5). If replicates are needed at a sampling location, multiple sets of five composted substrates are used. Treating the five substrates as replicates and individually analyzing each one as a separate sample would likely result in a much more intensive analysis of the sample than would occur if treated as a composite. Though certainly not bad in itself, this could potentially lead to inflated leI scores since calibration and scoring of metrics was based on reference data originating from a composited sample. Response: The samplers were counted and identified individually. This is not a deviation from Ohio EPA protocols. Compositing is not required nor should it have a statistically different effect on ICI scores assuming Ohio EPA's subsampling methods are properly designed which we feel are properly designed. The extra effort of counting samplers as individual units was performed in order to understand what deviation was present between samplers within sites in the Akron area. Measuring the differences between samplers helps substantiate some of the sites where samplers were wholly or partially buried during the sampling period because of the significant changes observed in substrate during the study. The scores from the organisms collected on those samplers were calculated based on the set of organisms present on all samplers. Counting samplers individually does not change the organisms found on the whole set of samplers. The Ohio EPA protocol does not require subsampling, and offers it as an option to reduce cost and expense if large numbers of macroinvertebrates are collected. Akron chose not to subsample for most of the data collected for this study. The only subsampling that was done in 1994 was consistent with paragraph 2) on page V-I-6 of Biological Criteria for the protection of Aquatic Life; Volume II: Standardized Biological Field sampling and Laboratory methods for Assessing Fish and Macroinvertebrate Communities. Paragraph 2) states: "After an entire sample has been sorted, subsampling within families containing unmanageable numbers is acceptable." In the second round of our 1994 study, members of the groups Diptera Chironomidae and Trichoptera were subsampled when numbers exceeded 300 within that order. Paragraph 4) of that section says tllat a minimum of 250 organisms should be identified. The protocol does not limit the maximum number of organisms that can be identified. The ICI score should not change significantly if subsampling is or is not used if the statistical interpretations developed by Ohio EPA during the development of the ICI are valid. As is implied later in Ohio EPA's comments, a few more species might be found by the City of Akron's . methods but this should not make a significant difference to ICI scores. The September 1996 issue of JNABS pages 381 -399 contains a series of three current articles discussing the issue of subsampling for regulatory indices that provide additional academic discussion that supports this response.

0161-153

4

000128

Chapter 10.1 Assessment of Aquatic Life Use Attainment of Receiving: Streams Section 10.1.2, P. 10.1-4, 2nd paragraph Ohio EPA comments: Delineations of Ohio's eroregions are based on four physiographic factors (land-surface form, soils, potential natural vegetation, and land use) not four soil areas. Also, there are five ecoregions in Ohio not four; the Cuyahoga basin is in the Erie-Ontario Lake Plain ecoregion. Response: We concur. Table 10.1-4 compared with Figure 10.1-5 Ohio EPA comments: The ICI scores for Event 2 do not jive between the table and tbe figure. Response: You are correct, we missed these changes in the figure. During the fmal data verification, the correct numbers got put in the Table but the figure data was not updated. The figures presented to Ohio EPA in our sePte~ meeting were correct. Section 10.1.3.6, P. 1~1~, 1st paragraph Ohio EPA comments: The scores of 10 (poor) and 18 (fair) at BCR9 and BCRI0 (Event 2) are substantially below the biocriterion and indicate considerable degradation. Additionally, Event 1 scores at BCR8 and BCR9 are also below the biocriterion and the area of insignificant departure. The discussion in this paragraph does not dwell on this (i.e., 4 of 9 samples below the biocriterion) and tends to portray a rosier picture than actually exists in our opinion. Response: . res observed downstream of the WPCS On page 10.6-16 of the report we do highlight th 0 and suggest that the changes in the plants c lorinati n system might be responsible for the depression in scores. Those two sites were edge of the mixing zone and 0.2 miles downstream. Macroinvertebrates this close to the main outfall are much more likely to be affected by plant discharge than by CSO discharging more than 3 miles upstream. Section 10.1.3.7, P. 10.1-11 Ohio EPA comments: It seems inappropriate to discuss attainment of the aquatic life use with respect to MWH in Segments 2 and 3 since the Cuyahoga River is currently designated WWH and does not qualify for the MWH designation in these segments.

0161-153

5

000129

Response: While the comparison may appear to be inappropriate, we believe the comparison useful in describing the current state of aquatic life use attinment. Our contention is that some stretches of the streams might be incapable of attaining WWH uses and may be inappropriately designated. Whether or not Ohio EPA agrees with that position, the comparisons are useful for discussing current aquatic life use attainment. P. 10.1-H, Table 10.1-5 Ohio EPA comments: What is the rationale for indicating attainment of the aquatic life use for the ICI if one of the two scores is above the criterion? It may be equally important that a score is below the biocriterion especially if it is in the low, fair or poor ranges as occurred at sites BCR9 and BCRIO for Event 2. Response: It may be in some cases and was discussed where we thought appropriate. Often the low scores' were clearly related to debris on samplers or partial burial of samplers which we do not feel is an indication of CSO water quality effects, though it may in some cases be an indication of floatables. As an example, one of the sites that appeared to have a significant decline due to debris was BLC2, upstream of the CSO area. Section 10.1.4.4, P. 10.1-15 Ohio EPA comments: Same comment as above regarding the two sites (BLC8 and BLCI0) meeting the WWH biocriterion. However, the Event 1 ICI at BLC8 is not meeting the criterion and should be given some consideration in the assessment. It should be noted that the majority (10 of 13) of scores in this segment (even excluding those from disturbed sites) were well below the WWH biocriterion and indicative of substantial degradation. Again, there seems to be a lot of discussion of results based on MWH which is not the applicable aquatic life use. Response: There is some consideration of that point in later discussion of the repair of rack 39. However, the flow regime at BLC 8 during the first event caused significant slumping of a bank less than 5 feet from our samplers. We felt that that disturbance might have caused some depression of ICI scores. That kind of stream bank erosion is also indicative of an unstable stream which we feel is highly disruptive to macroinvertebrate communities. The site where macroinvertebrates performed better at BLC 10 downstream is somewhat flow controlled by the presence of two low head darns, which may help to stabilize substrates and be less disruptive to macroinvertebrates. We are aware that most of the Little Cuyahoga River sites do not meet WWH criteria. We are highlighting attainment at these downstream locations because we do not see how increased CSO volume, duration and concentration as we get close to these downstream sites should allow these communities to attain WWH if CSO is the primary cause of non-attainment.

0161-153

6

000130

Section 10.1.4.5, P. 10.1-15 and Table 10.1-8 Ohio EPA comments: As above, most of the discussion seems centered around attainment/non-attainment ofMWH which is not the use. The statement about the macroinvertebrate community showing significant attainment at downstream locations must be inappropriately refelTing to MWH since only 2 of 8 sites are listed in the table as attaining WWH for one or both of the events. Response: Piease refer to previous response. Section 10.1.5, P. 10.1-17, last paragraph
Comment refers to listing ofCamp Brook scores

Ohio EPA comments: Although no ICI score is achieving the WWH biocriterion, it should be noted that scores are noticeably lower at the downstream site (especially for Event 2). This may be a reflection of the influence of the CSO. Response: As is noted later in the report, significant changes were observed in substrate deposition at the end of the brook. The downstream samplers in the first event were completely buried. Our field observations seem to indicate that flow effects may have a significant destabilizing influence on the macroinvertebrates at this downstream site. Page 10.3.3 Site-Specific QREI Assessment Ohio EPA comments: EA and ES both conducted QHEI evaluations, yet only the averaged data was presented. We should be able to review both evaluations. It is not appropriate to combine two separate teams results. Response: Scores are available from both teams. Average is a poor choice of terms for the data presented. The Scores used in the report represented the consultants professional judgement of which features of habitat were most significant and were arrived at during a discussion of site features. Some slight differences in interpretation and limits of zones reviewed caused scores to vary. The final scores used were representative of the habitat in the zones as listed. Many sites were revisited to verify habitat features and substantiate scores. Ohio EP A comments: Table 10.3-2 presents QHEI scores associated with the MWH and WWH aquatic life use designations. These values are based on information presented in Volume II. Users manual for Biological Field Assessment of Ohio Surface Wates. These values are no longer applicable, statistical analysis based on a larger database and further analysis of the relationship between the QHEI and instream community performance (Rankin 1989, 1995) has yielded lower numbers than
0161-153

7
000131

those provided in this Table. In general, stream reaches with QHEI scores averaging >60 will likely have the potential to attain the WWH use. Response: The Ohio EPA Volume II issued in January 1988 was updated in February 1988 with an addendum (dated September of 1989) that refers to a publication authored by Ohio EPA's Ed Rankin that is dated November of 1989. It is not clear that the methods for evaluating habitat as expressed in Volume 1I page 8-9 can be modified and incorporate material presented in a publication that post dates the addendum. It is also not clear that use of guidance to promulgate standards for habitat attainment which set water quality standards is an approach that is consistent with Ohio EPA rules and regulations. The technical issue of whether or not habitat limits fish communities could be discussed at considerable length. The QHEI was developed to be a Qualitative measure of habitat and does not provide a precise and accurate tool for measuring the ability of a stream segment to support fish communities. The Ohio EPA uses this tool as an indication to initially determine which designation is appropriate for a stream reach. The City of Akron's intensive study of the CSO receiving streams did not rely on the QHEI as the only method for determining whether a habitat should support a given fish community. The stream conditions, and the disparity between the attaining macroinvertebrate communities and the nonattaining fish communities were the principle rationale for suggesting habitat limitation in the lower Cuyahoga River. To assert that a stream segment is truly habitat limited based on either a QHEI score of 60 or 70 is not sufficient to address the issues of multiple stressors that have been discussed here and elsewhere. Our discussion of flow modifications and the effects of bank stabilization in the lower Cuyahoga are all relevant factors that do not rely on the QHEI as the sole method for evaluating use attainability. Page 10.3-6 Ohio EPA comments: The characterization of the quality of their Segment 3 which is located between the Little Cuyahoga River confluence and Bath Rd. is inaccurate and not supported by their own data. The segment average QHEI, based on their own data, was 64.74 clearly capable of supporting the WWH use. Response: This segment does supportWWH macroinvertebrate use. We feel that a variety of habitat features do limit fish use and will continue to do so. The QHEI is not the only way of looking at habitat, in ecological studies the concept of limitation is defined as the single factor most limited in relation to demand for that factor. A single feature of habitat could limit the recovery of fish communities. Page 10.3-7 Ohio EPA comments: The discussion about the quality of instream habitat in the Little Cuyahoga River is overstated. Segment 1 is characterized as having very poor habitat, despite QHEI scores averaging 55.75. Scores in this range fall into the category that requires more close examination of what
0161-153

8

000132

characteristics may be limiting aquatic life (i.e., a QHEI matrix table - need to examine the MWH:WWH ratios) to determine the potential of that segment. Response: The choice of the words "very poor" may have been inappropriate and was not intended to denote the context ofLRW. Regardless of matrix tables or QHEI scores the stream in this segment contains long stretches that are highly modified and are not conducive to supporting WWH aquatic life. Page 10.3-1 re Paragraph 3 Ohio EPA comments: See previous comments regarding the quality of instream and riparian habitat in Segment 3. Response: See previous comment re: segment 1, This lower portion of the Little Cuyahoga River is also a variable braided chatmel developed because of changes to land use and related river flows, We feel that this unstab Ie channel is a limiting factor. Section 10.3.11.5.4, P. 10.3-40, 1st paragraph Ohio EPA comments: The report states that "this section of the Little Cuyahoga River was evaluated because the biological assessment performed showed that the biological community attained WWH criteria in the Ohio EPA studies and was in non-attainment in this study," Ohio EPA sampling in 1986 and 1991 revealed that neither fish nor macro invertebrates were achieving their respective biocriteria in this Little Cuyahoga segment which was in non-attainment of WWH during both years, So their statement was incorrect. Response: We did not catch this error in our final editing. P. 10.4-1 Sentence 1 The Ohio EPA uses both biological and chemical criteria to assess the aquatic life use attainment ofa water body. Ohio EPA comments: The Ohio EPA uses the biological sampling results from a segment to compare with established biological criteria to determine whether or not that segment is attaining its designated aquatic life use. Water chemistry results and chemical criteria are used to assist the determination of the a%ociated causes and sources of stress to the biological community that may have prevented them from meeting criteria, but not as stated to assess the aquatic life use attainment of a water body, Response: We agree the report did not summarize your efforts well, P. 10.4-1 Paragraph 3 The Akron watershed in the Cuyahoga River basin is highly urbanized and industrialized. This urbanization and industrialization generally exerts significant adverse influences on the biota. The
0161-153

9
000133

extent ojthese adverse influences are not routinely quantified through the Ohio EPA's qualitative evaluation process.

Ohio EPA comments: The extent (I'm assuming that this means the extent of impact) of adverse influences is routinely quantified through Ohio EPA's quantitative biomonitoring and chemical sampling approach. The QHEI, which is a qualitative methodology for evaluating the quality of instream and near field habitat, is used to establish the potential of a given stream segment to support aquatic life and to assist in distinguishing water quality from habitat related impacts to fish communities. Response: The Ohio EPA QHEI method does not allow any consideration to be given to features not immediately visible from the stream. Also the sampling performed by Ohio EPA is traditionally focused on effects and has not typically assessed causes (aside from point sources). In this section we are presenting some new ideas and methods to look at watersheds and non-point source issues. Ohio EPA has not traditionally been able to do much to evaluate land use effects. Current trends at Ohio EPA are moving in this direction. P. 10.4-3 Re: 10.4.2.1 Cuyahoga River Segment lOhio EPA comments: A few points need to be made concerning this very short segment. The Ohio Edison dam is a very high dam in comparison with the average mn-of-river impoundment in Ohio, on the order of eighty feet in height. Despite this height, the Cuyahoga River is impounded only a short distance upstream from the dam due to the steep gradient in that area. The result of this is that there is a very small amount of shoreline and shallow water habitat available in comparison to the stream volume. Redesignation of this segment, although possible, must be accurately delineated and linked to a certainty of the stream remaining in that condition for the foreseeable future. Response: The impoundment is over a mile long, with over two miles of shoreline. It is interesting that this comment suggests that redesignation is possible while Mr. Zawiski's letter denies that this can be done. The dam has been there for over fifty years, it is privately held, and there is no concerted effort to remove it. There are significant environmental issues to be addressed if it were to be removed. It is more certain that the stream will remain that way. P. 10.4-3 Re: 1-.4.2.2 Cuyahoga River Segment 2. Ohio EPA comments: In general, we agree with the conclusions made about this segment. However, the Ohio EPA QHEls from these same areas averaged about ten points higher suggesting event greater potential to support aquatic life in the absence of adverse impacts. Response: Some of our scores were calculated from areas where Ohio EPA has not sampled historically. But we do agree that this section should support WWH fish.

0161-153

10

000134

P. 10.4-3 Re: 10.4.2.3 Cuyahoga River - segment 3. This segment is characterized as having moderate to poor quality habitat, yet the mean QHEI calculated from their own biological sampling sites was 68,1, well above our rule of thumb that a stream segment with an average QHEI equal to or greater than 60 has near and instream habitats sufficient to support a community of aquatic organisms at least consistent with the WWH biological criteria (Rankin 1989), Two additional QHEI sites were included in this segment to support a "system wide" qualitative habitat evaluation, Despite the site selection for these system wide sites which yielded values in the high 50's the mean QHEI for this segment remained well above 60 at 65,0, clearly a segment physically capable of supporting the WWH aquatic life sue. Further for this segment of 75,8, This area is also being characterized as "almost entirely deficient of important riffle-pool-run complexes" yet the Ohio EPA sheets for the same segment note good to excellent channel development. The Segment 3 stream bed gradient is also being characterized as very slight, especially compared with the gradients of Segment 2 and Little Cuyahoga River segment. There are indeeD spots in Segment 2 and in the Little Cuyahoga River that have much steeper gradient than found in Segment 3, However, gradients from 5.3 ft.lmi. To 9.0 ft./mi. Are not slight when compared to other sites throughout Ohio. Response: The QHEI is a qualitative habitat evaluation that is being used quantitatively by Ohio EPA. Because WWH stream performance has been observed by Ohio EPA in streams that score above 60 does not mean that habitat can not be limiting fish community attainment. Single habitat characteristics may limit fish communities but not significantly reduce QHEI scores. Though our use of the adjectives slight and very poor may not be consistent with yours, our opinion is that these reaches contain habitat features that may limit fish community recovery. P. 10.4-4 Paragraph 1. Ohio EPA comments: Another statement is not quite on track "When QHEI scores are in the range requiring BPI the Obio EPA considers it very important to consider other factors that may be influencing the biota." When evaluating environmental quality the Ohio EPA obviously considers all available information to determine what may be influencing the biota. However, when determining the appropriate aquatic life use for a segment, mean QHEls are used to determine that segment's potential. The range referred to above, where professional biologist's BPI is necessary to assign the aquatic life use, ranges from a mean of 45 to 59, clearly not the case for this segment and it therefore is not an issue. Response: We don't think Ohio EPA means to state that BPI is inappropriate just because a certain score achieved a threshold. We certainly would not strive to limit their ability to use or state their best professional judgement based on a qualitative ranking system. Ohio EPA comments: Refers to segment 3 ofCuyahoga River Sediment contamination and periodic chronic toxicity very likely are contributing factors to the reduced biological performance measured, but the argument concerning the effects of habitat is
0161-153

11
000135

baseless. Not only is the habitat within the segment easily capable of supporting the WWH use, but the adjacent areas upstream and downstream from the segment are of even higher habitat quality. Our sampling across Ohio has' shown that individual sites or short segments may have much poorer physical habitat due to a localized disturbance, yet still support aquatic communities closely resembling those sampled at higher quality adjacent sites if other water resource parameters are adequate. Therefore, as pollutional pressures are reduced, such as the periodic problems with clogged pipes causing dry weather overflows, these adjacent improved areas may increase the rate of recovery. Response: Why is the argument baseless? This is not a short segment of the stream we are talking about a nine mile stretch of the Cuyahoga. The comparisons with localized disturbance and short segment issues are inappropriate. In this part of the watershed the undisturbed sites are the short segments. We have spent a considerable number of person hours and have visited almost every single foot of the stream, most on numerous occasions. We feel that the bank stabilization, riparian zone modification and trapezoidal channel significantly inhibit fish communities. The upstream dam and the near absence of high quality feeder streams also will prolong any fish community recovery. We never said that Akron does not intend to deal with nine minimum control issues such as minimizing dry weather overflows, and we would agree that eliminating those sources may have a positive effect on fish communities. We do not agree that expensive long term CSO controls will provide measurable improvement more cost effectively than other measures that can be taken to improve the stream. Ohio EPA comments: The argument is raised that since the macroinvertebrate communities are now achieving WWH criteria, there was no documented chronic toxicity of the Ceriodaphnia during the study and if the fish do not meet criteria...therefore, habitat must be the limiting factor affecting the fish community. We see many instances across the state where one group meets the WQS criteria and the other odes not. Careful interpretation of all available information is useful in determining the reasons for the differences. In this situation, there is a long history of a sampling in the study area that give clues to the impacts to the fish community in the study area. To paraphrase the 1991 Cuyahoga River TSD "the 1991 biological response patterns (downstream for the confluence with the Little Cuyahoga River) suggested organic enrichment. Response: We feel that we have made a careful interpretation of all of the 1994 data and that interpretation does not lead us to the conclusions that you suggest. Does the information contained in our 1994 data provide the same "biological response pattern" that suggests organic enrichment? The guidance in the Ohio EPA user manuals does not provide complete details necessary to interpret these results in this fashion. Even Mr. Yoder's 1995 chapter in Biological Assessment and Criteria discusses areas of considerable ambiguity in this form of interpretation. The percent Glyptotendipes for example is described by Mr. Yoder as showing higher values for conventional municipal impacts, CSOs, and channelization; all of these occur in the Akron watershed. It is not clear from his study that these techniques are a definitive method for distinguishing cause and effect.

0161-153

12

000136

P. 10.4-5 Re: 10.4-3.1 Little Cuyahoga River - Segment 1 Ohio EPA comments: There appears to be a misunderstanding between the designation of an aquatic life use for a given stream segment and the determination of attainment or non-attainment of that designated use. Consistent throughout this document is an attempt to substitute the attainment status of the biological communities (i.e., full, partial or non-attainment) for the procedure to designate the use. Although very important for its own purpose, it just doesn't work this way. Although the author describes a few short reach habitat modifications the areas immediately upstream and dowru;tream from these short reaches easily exceed the WWH Mean QHEI thresholds and therefore with the possible exception of the small impoundment, would not qualify as MWH. To quote Chapter 37451-07 ofOAC stream segments that have been designated Modified Warrnwater "are waters that have been the subject of a use attainability analysis and have been found to be incapable of supporting and maintaining a balanced, integrative adaptive community of warmwater organisms due to irretrievable modifications of the physical habitat. Such modifications are of a long lasting duration (i.e. twenty years or longer) and may include the following examples: extensive stream channel modifications activities permitted under sections of 40 1 and 404 of the act of Chapter 6131 of the Revised Code, extensive sedimentation resulting from abandoned mine land runoff, and extensive permanent impoundment of the free-flowing water bodies. To quote Rankin 1989 the MWH use designation is reserved for extensively modified stream segments or sub-basins. The MWH use is not intended to be applied in a patchwork fashion in a stream or river." The previous mentioned analyses on the average habitat quality in a basin illustrated the ability of isolated areas of degraded habitat within a basin with generally good or high quality habitat to support a WWH or even EWH community. The MWH use is reserved for the converse of this situation: streams where average habitat quality is poor and unlikely to attain a WWH aquatic life use." Response: We agree with the interpretation of3745 1-07. We disagree that those conditions do not exist in the Akron watershed. The "small" impoundment is only one of several significant long lasting and permanent modifications that are apparent on the upper reaches of the Little Cuyahoga. All of these modifications have been and will continue to be present for at least 20 years. P. 10.4-7 Re: 10.4-3.2 Little Cuyahoga River - Segmeut 2 Paragraph 5 Ohio EPA comments: The statement is made that "This is consistent with the discussion in Section 10.2.2 where the Ohio EPA states that use attainability should not be based on physical habitat alone." That is an inaccurate interpretation of Ohio EPA policy. The presence of multiple causes and sources of stress in no way prevents determination of the appropriate use or for that matter precludes the need for remediation of identified impacts including CSOs and SSOs. Besides, doing this now would undermine the effort to accomplish the nine minimum controls in Ohio EPA's CSO Policy. These should be complete first This will permit determination if other factors are precluding full attainment of applicable criteria.

0161-153

13
000137

Response: This study was prepare to help detennine the long term controls necessary to protect water quality. If you are saying you can't tell from the data what impact long term controls might have, we would agree. The Nine Minimum Controls were in place in some degree during the study. P. 10.4-8 Re: 10.4.4 Camp Brook Ohio EPA comments: Things may have changed since we evaluated Camp Creek in 1986, however the habitat evaluation at that time implied a much higher quality stream than detailed in their write-up. We are willing to do a follow-up at our first opportunity which probable will be this summer. Response: Camp Brook has changed since 1986. We hope that your investigations this summer confirmed this. We noticed further degradation and instability of the stream upstream of Rack 12 during our field season. P. 10.4-8 Re: 10.4.S Ohio Canal Ohio EPA comments: I'm not sure what they are implying by the statement "none of its characteristics are natural and it does not have a native biological community." It does support an assemblage aquatic life that deserves protection and protection of downstream uses must be maintained. It is a water of the state, thus it falls under the WQS. Response: As the sentence before the one you quoted states; the canal is a man made structure. P. 10.4-9 Re: 10.4.6 Summary Ohio EPA comments: Table 10.4.6 is stated to list a summary of the current biological use attainment and use attainability of receiving streams in the study area. It accomplishes neither. The use attainment column is inaccurate and doesn't follow the current designations in the state water quality standards. The use attainability is also of the mark and is based on inappropriate use of habitat evaluations, water chemistry and toxicity testing. We will agree with the statements about Segment 1 and 2 on this page with the caveat that the MWH characteristics for Segment 1 are limited to the impounded segment. We couldn't disagree more with the conclusions about Segment 3. They state that water quality is not the principal limiting factor affecting the fish community implying that habitat quality. is the primary limiting factor. It is clear to us that pollution is the cause for the non-attainment of the current and appropriate WWH use based on our past experience in this area. As mentioned before the short reach discussed for Segment 1 constitutes an attempt at patchwork designation and with the high quality adjacent habitat, this would not be approved. Segment 2 easily exceeds the minimum mean QHEI threshold for WWH and should retain its existing designated use. Response: While your past experience may be responsible for some of your comments, it is not clear to us from
0161-153

14

000138

our current experience with the watershed that pollution is the sole cause for non-attainment. It is even more clear to us that there are numerous sources of pollution and there is poor correlation with CSO sources relative to other potential sources of non-attainment. We would disagree that a mile long impoundment behind an 85 foot high dam is a "patch". We also did not suggest that segment 2 should be redesignated.

Chapter 10.5 Assessment of Recreational Use Attainability of Receiving Streams Ohio EPA comments: Again assignment or designation of use gets confused with present use performance. There is an attempt to equate current perfonnance with a segments's ability to support a use, something that we have never agreed to and which eliminates the concept of restoration. For the purposes of "evaluation if the current and potential recreational uses were accurately represented" they. performed and evaluation of the current recreational use of each stream section, Which, although interesting, does not fully consider the potential of a segment (i.e., recreational use can be very low if there is a bacterial problem, despite excellent physical conditions to support that recreational use. However, once that problem is remedied the usage of that resource can dramatically increase. An evaluation of the structural conditions to determine the likelihood of recreational access for each stream section was also conducted. Again, although interesting, especially from a public health perspective, the amount and quality of recreational access is significantly driven by the environmental quality of the resource. If there is a bacteriological problem, people will not be pushing for canoe accesses and boat ramps. However, as soon as the problem clears up the reverse is true. The last step that was proposed was an evaluation of what the appropriate RUD should be for each stream section. This has already been done by the Ohio EPA. In some cases, we have sampled specific segments several times and would have altered the recreational use if the need was demonstrated. Response: USEPA defines existing uses as uses that existed (in 1976) or bad a reasonable potential to exist if pollution did not limit them. On this basis some of the designations for recreational use should be revisited in specific areas such as the Ohio Edison Darn pool. That area has not had permitted recreational uses and access has been restricted for many years. The restrictions are not based on pollution but rather safety of access and use of the water from pbysical hazards. Page 10.5-2 Ohio EPA comments: Although access is limited and contact is prohibited in this dam pool it does take place. This dam pool is regularly fished, with individuals in frequent contact with the water. At a minimum, it should bave the secondary contact recreation designated use to protect for incidental contact and to protect for downstream recreational uses. Response: We concur.

0161-153

15
000139

Section 10.6, P. 10.6-1 Ohio EPA comments: Since much of the Section 5 discussion is repeated in this section, the comments noted above pertaining to the macroinvertebrate results for Section 5 would apply here in this section as well. Response: Plrease refer to the responses to previous comments. Table 10.6-1 Ohio EPA comments: The table alludes to biological sampling sites identified as BCRU, BLCU, and BCBU. There was no discussion with regards to biological data from these sites and we assume there was no data collected. The table should be modified to clarify this. Response: This is clear in the report in other areas, such as Section 5.5.2, Pg. 5.25. Page 10.6-11 Re: 10.6.3.2 - Cuyahoga River Segment 1 - Fish Ohio EPA comments: The statement is made that "the cause of non-attainment in segment 1 cannot be solely attributed .to discharges from CSO rack No. 35. The sites upstream and downstream of the CSO have approximately the same fish community." The sampling data provided, however, provides a somewhat different picture. Although the IBI scores are essentially similar the MIwb scores for both sampling periods are consistently and significantly lower downstream from Rack #35. Although the CSO cannot be solely attributed for the non-attainment it is probably a contributing factor. Response: It is not clear that your conclusion that this is true is any better supported than ours. The pool functions as a lake from a fish perspective and the possible impact on MIwb scores is interesting but not conclusive. Page 10.6-13 Re: 10.6.3.5 Cuyahoga River Segment 2 - Fish Ohio EPA comments: We are curious about the statement concerning the inaccessibility of this segment for sampling. We have successfully put 14' boats into the Cuyahoga River in this segment in the vicinity of RM 43, sampled with the Sportyak method at this location and with the longline method as far upstream as RM 44.0. Evaluation of the impact from CSOs upstream from CR3 and CR4 is complicated by the inappropriate use of seining at CR3 and the absence of multiple samples at CR4. Regardless, the statement "The cause of this nonattainment is not correlated with the position of CSO discharges. The fish community in Segment 2 is very close to attainment of a WWH biology" is misleading. Based on the results provided in this report it cannot be said that CSO impacts are not
0161-153

16

000140

at least partially responsible for the reduced community performance documented. The habitat in Segment 2 is clearly capable of supporting a WWH fish community based on both our data and their own habitat evaluation so clearly habitat is not a limiting factor. Reduced water quality must be adversely affecting the fish community. Response: It was clearly stated in the report, and in all other contacts with Ohio EPA that the conditions at that site were not safe for electro-fishing. In fact Bob Miltner indicated to one of our consultants that the conditions at the next site downstream (our CR 4 site at RM 44) were difficult to sample effectively and safely with electro-fishing during Ohio EP A' s 1996 efforts. We included the seining method at that site in order to obtain some data from a site nearer to the Ohio Edison Dam. We clearly understood that that site would not be directly comparable to other sites in the study and qualified our remarks about that data. Our interpretation of the data would not be significantly changed if the seining site is excluded. Section 10.6.3.6, P. 10.6-14, 2nd paragraph Ohio EPA comments: 1991 Ohio EPA macroinvertebrate sampling sites in close proximity to BCR4 and BCRS were located at RMS 44.0 and 42.8, respectively. ICI scores were 36 and 28, respectively. Another ICI of28 was logged at RM 42.8 in 1993. Response: The point of this comment is unclear. Page 10.6-16 Re: 10.6.3.10 Cuyahoga River Segment 1,2 and 3 - Summary of Aquatic Life Use Attainment Impacts from Existing CSO Discharges Ohio EPA comments: The statement is made that "Segment I is least likely to be significantly impacted by existing CSO discharges." Not true, it is currently documented to be impacted by CSO discharges and the long residence times engendered by discharge to an impoundment ensure that any negative effect associated with reduced water quality from the CSO will be manifested within the impoundment and quite possibly reduce water quality in the segment immediately downstream from the dam. Reductions of wet weather CSOs should result in improvements in aquatic life in Segment I. Response: What is the source of the documentation of CSO impacts? Page 10.6-17 Paragraph 5 Ohio EPA comments: We disagree with the statement that the nonattainment of the fist community in Segment 3 is not directly related to the CSO discharges that enter the segment. The next sentence somewhat contradicts that statement and I partially agree with its conclusions i.e. that the nonattainment is related to the cumulative effect of several factors including chronic toxicity, sediment contamination and CSO discharges. I would also add one factor that has not been raised-impediments to
0161-153

17

000141

reinvasion. Aquatic macroinvertebrates have mechanisms for reinvasion that are not possible for fish, for example aerial dispersal. The Ohio Edison Dam poses a significant barrier for reinvasion for fish in both directions. Sources of repopulation for fish in Segments 2 and 3 are largely limited to sources downstream from this dam. Many of those areas are or have been historically impacted by pollution and therefore have reduced fish communities. As a result, although major gains have been made in water resource quality, it is expected that the fish communities in Segments 2 and 3 will take longer to recover than the macroinvertebrates. I disagree with the inclusion of channel modification and riparian zone modifications in these segments as significant stresses based on previous arguments. Response: We would disagree that these factors can not be limiting to the fish community in this area though we would agree with much of the discussion above. Section 10.6.3.10, Page 10.6-18, lst paragraph Ohio EPA comments: Considerable work has been done to reduce documented problems in the vicinity of Rack 34 and Babb Run. Although the structures are largely in the same place the characterization that no significant alterations to the Akron CSO system has taken place the characterization that no significant alterations to the Akron CSO system has taken place since the Ohio EPA biological work in 1984 is disingenuous. Considerable work has been done and has made an appreciable difference. There was a significant CSO malfunction in Cuyahoga River Segment 2 which occurred after 1984 and which resulted in dry weath.er discharges that lasted for a significant time period before it was found and corrected. This is what caused the problem at our Cuyahoga Street sampling location where ICI scores declined dramatically between 1984 and 1987 and then improved gradually. Response: We have never argued that dry weather overflow events of significant volume can cause a measurable impact to the biology. We are still not convinced that additional long term controls would produce measurable improvement in the fish community. Section 10.6.3.10, P. 10.6-18, 3rd paragraph Ohio EPA comments: Their own database contradicts the statement made in this paragraph (i.e., that other· factors are causing the low performance of the river biology - the implication I suppose is that CSOs are without stress. This is also contradictory to statements made on the previous page including them as one of the contributory factors.) Response: We did not intend to imply that CSO are without stress. We are trying to produce long term controls that will yield measureable benefit for the expense incurred.

0161-153

18

000142

Page 10.6-20 Ohio EPA comments: I did the math using their illI scoring and came up with somewhat different results and therefore conclusions. While it is true that the differences between upstream from the "CSO area" and downstream were not great, they were significant. The sites upstream averaged an illl of 25.5 and the sites downstream average 21 yielding a difference of 4.5. The CSO area fish community was more depressed than those sampled upstream. The presence of seven CSOs obviously could be contributing to that impact. The differences seen in summed MIWB scores upstream and downstream although not quite as great closely approached the level of significance and supports the conclusion of an increase in stress between upstream and downstream from the CSO area. Response: The average score from two passes at two sites described on page 10.6-20 would total 25.5 and the average of the two passes at two sites immediately below the CSO area is 21. We expressed those averages to aid in understanding the difference. The Ohio EPA typically does not average illI scores and it is not statistically appropriate to do so since the scores are a sum of individual metrics. The fmal statement in this paragraph is also inaccurate as the Ohio EPA guidance states in numerous locations that a score difference of four points is considered to be the zone of no statistically significant departure. Therefore any scores showing a difference of25.5 versus 21 would have a real difference of only 0.5. Though a difference of 0.5 may be statistically different it is not clearly an indication of a pollutant impact and it clearly does not differentiate what possible stressor can be causing the change. Page 10.6-23 Ohio EPA comments: Based on the data supplied, the fish communities in the Little Cuyahoga River do improve with downstream distance. However, the conclusion that "cso discharges are not causing an adverse impact on aquatic life" is flawed. Ohio EPA's historical sampling and EA evaluation in 1994 documented the potential for Segment 2 to support WWH. It should easily support a community consistent with the WWH aquatic life use designation. In fact all sites, with the exception of the "System Wide" sites, individually exceed QHEls of 60 revealing this segment could support much better than threshold WWH biological communities based on habitat. Clearly water quality is the factor that is limiting performance, with CSOs contributing to that stress. The scores at RM 1.8 (i.e. IBI = 30) are held up as a demonstration that CSOs are not causing an impact. However, just upstream there appears to be an impact associated with the confluence with the Ohio Canal, which they have modeled to discharge over 66% of the total untreated discharge from the combined sewer system released through eight outfalls. The very argument that they advance on Page 10.6-23 and 10.6-24 to absolve CSOs of problems actually points to CSOs as the reason for the fish community not being improved more than what was sampled. They state that the CSO system is largely the same system that was in place when the Ohio EPA first conducted its sampling in the Little Cuyahoga River in 1984 (Despite the identification and remediation of a severe dry weather overflow problem in the Ohio Canal which to quote "The remediation of this dry weather overflow problem in June of 1994 should have a dramatic effect on the biology in Segment 3 as well as the
0161-153

19

000143

Little Cuyahoga River Downstream of the Ohio Canal confluence."). We believe that many industries in the upper portion of the Little Cuyahoga River watershed are impacting the river via CSOs and spills and run-off that is not controlled through NPDES permits, but they are major impacts. However, many industries that discharged to the Little Cuyahoga River have ceased operations, developed pre-treatment programs, upgraded their treatment processes, etc. In face of these changes, point source pollution problems have diminished in severity with non-point source pollution problems becoming more evident with CSOs a contributor. I fully expect with the development of NPS controls as well as dealing with some of the currently uncontrolled sources, the lower Little Cuyahoga River will fully meet WWH criteria. Response: We would hope that you are correct. However, our interpretation of the data and the physical conditions caused by flow modification in the stream suggests a different conclusion. Section 10.6.5.2, P. 10.6-25, 3rd paragraph In our view, a 10 pt. Difference in ICI scores (16-fair to 6-poor) above and below a CSO would reflect a significant impact from that CSO even though neither site is achieving the biocriterion. Response: The difference between the ICI of 16 and 6 observed at sites upstream and downstream of CSO rack 12 on Camp Brook. The Ohio EPA considers this to be a demonstration ofCSO impact. The CSO study does not state that the difference between a 16 and a 6 is not significant as the comment implies. The CSO study states that both upstream and downstream sites are not in attainment with appropriate biological criteria for macroinvertebrates. The City also has made field observations of significant changes in the depth of sediment in the lower section of Camp Brook during the 1994 study. Those observations are the evidence that supports the statement that channelization and upstream development may be the most significant impact on the macroinvertebrate community. Sediment movement indicates flow effects may have buried or partially buried samplers during the second sampling event. The City and its consultants believe that these effects may be more significant than CSOs as the cause of macroinvertebrate and fish community degradation. The City of Akron is currently measuring the changes in stream bed depth at the lower end of Camp Brook to document the degree of agradation and degradation of sediment over short time periods. Page 10.6-30 re: 10.6.7 Conclusions Ohio EPA comments: The statement that "The nonattaining stream sections cannot be correlated with the 37 Akron CSO discharge points" is not accurate. Several discharge locations have demonstrable impacts associated with them, where the stress associated with the discharge was greater than upstream background conditions and caused a drop in community performance. Additionally, the pervasive nature of 37 discharge points in such a small portion of this watershed tends to have an additive effect with new contributions of untreated wastes just as the stream is recovering from previous upstream contributions. This somewhat masks the impacts associated with any but the more severe discharges.

0161-153

20

000144

Response: If the impact is additive as the above comment implies, then how does the impact go away as we add more CSO? We would like to discuss this situation in more detail. Paragraph 2 Ohio EP A comments: There appears to be an attempt to convince readers of this report that CSOs are responsible for nothing other than a very minor contribution to the impact measured in the study area both historically and more recently. While we agree the CSOs are not the sole cause of the problems documented, I think the data supports that they do contribute to the problem and are a significant contributor. Their own verbiage in other paragraphs implies as much. They also raise the issue of improvements in areas where significant CSO problems should have been documented. I maintain that the data actually does support that those impacts have been documented. Improvements to less than WWH criteria when community values greater then threshold values are expected implies lessened but not alleviated impacts. I also agree that communities upstream from the CSO areas are in nonattainment of criteria, but that is not a reaBon to not control problems associated with CSOs. Response: There is no reason not to control problems associated with CSO unless you can not demonstrate that any measurable benefit will be received for the dollars spent. It is not clear which CSO long term control is the most effective way to improve stream quality. It may also be more effective to spend resources on upstream non-point source controls if more improvements in water quality can be achieved for less cost. Chapter 10.8 Receiving Stream Segments Where Other Pollution Abatement Efforts Could Improve Aquatic Life Use Attainment 10.8.2 Cuyahoga River Ohio EPA comments: Not true that five Cuyahoga River CSO discharges are not limiting the biological community within the river. Response: What data shows that CSOs are more limiting than the factors that we have described? 10.8.2.1 Cuyahoga River Segment 1 Ohio EPA comments: See previous comments re: impact of CSOs. They do present a good case for other factors that should be coO$idered in a comprehensive watershed management plan. The argument to reclassify the impounded portion of the Cuyahoga River to MWH - impounded is valid, but obviously is limited to the impounded portion of the river and should include considerations if this will remain an impoundment.
0161-153

21

000145

Response: See previous responses for impact of CSOs. When we talk about long term CSO control, is it integral with comprehensive watershed management planning? If yes, than the intent of our report has been achieved if we have presented a good case that other factors must be compared to CSO and the most effective remedies that achieve the most benefit must be implemented. It is no longer sufficient to remedy a problem unless we are certain that the problem is real and measurable and the improvement achieved will be equally real and measureable. The specific issue of the impounded section of the Cuyahoga has been discussed elsewhere and it is our view that this structure is permanent and will remain the same for at least twenty years. 10.8.2.2 Cuyahoga River Segment 2 Ohio EPA comments: A lot of figures are thrown around throughout this document without the ability to check the accuracy of the calculations or the ability to determine what they are comparing against. The percentages of flow that the CSOs constitute against whatever is a good example. Additionally, volume is not always a good determinant of the severity of impact associated with a discharge. Instream concentration which is determined by mass loadings and dilution is more important. Response: We agree that some of the figures about CSO proportions are difficult to verify. The sequence of development of this report caused us to base our conclusions on numbers generated by preliminary modeling. The model for the collection system is still developing and real time data is also still being collected to further calibrate the model and provide further checks. We are confident that the relative proportions and frequencies of overflow as discussed in the biological sections are supported by the data collected from the model as described in Chapters 6,7, and 8 of the report. The model is well supported by the data collected and presented elsewhere in the report. In a system this complex all of the final flow numbers will be estimates, averages and ranges so it may never be easy to verify anything but the monitoring. Some of our conclusions are also based on discussions with the people most familiar with the structure and function of the system. The principal concl\J$ion that the Canal contains both high volume and high concentrations of CSO is well supported by the data.

Ohio EPA comments: The first factor that they discuss that might be contributing to the lack of full attainment, especially in the gorge section of the Cuyahoga River, was sampling effort. Every effort should have been taken to replicate the sampling methods that have been used consistently by the Ohio EPA in this segment since 1984. Instead seining was conducted where longline and wading electrofishing had previously been conducted and wading electrofishing methods where we had used the boat electrofishing method. As a consequence, lowered community scores were encountered. The concern with water column toxicity appears to be valid as does the concern over elevated sediment heavy metals concentrations. Although algal toxicity has been demonstrated in other locations, the extensive character of the canopy along this portion of the Cuyahoga River should limit this stressor. This "factor" needs more data to be considered as a serious threat to attainment.

0161-153

22

000146

Response: This issue was addressed above. Every effort was made to sample according to Ohio EPA protocols. Changes in river level can make boat sampling difficult and wading electrofishing possible. Ohio EPA has NEVER electro-fished below the Ohio Edison dam and we would not consider it a safe practice for anyone to do so. 10.8.2.3 Cuyahoga River Segment 3 Ohio EPA comments: The logic applied here is flawed. The multitude of stresses encountered in this segment depress the fish community throughout. The placement of ENs sampling sites and the location of the confluence of the Cuyahoga River with the Little Cuyahoga River prevent determination of the impact associated with the single CSO discharge, Rack No. 36 (RM 42.1). The absence of an appropriate sampling site does not mean that a discharge does not have an impact. The measured depression of the fish community in this segment is an additive problem with many factors contributing to the results seen, including CSOs. Instream and riparian habitat are not signifIcant factors in this segment as explained previously. However, sporadic chronic toxicity and sediment contamination based on the data provided probably do contribute to the impacts seen and may be contributed by CSO discharges. Response: We apparently disagree on the logic presented. If our sampling sites in this region of the Cuyahoga were not appropriately located, why did Ohio EPA perform fish sampling at substantively the same sites in 1996? Page 10.8-8 Re: 10.8.2.4 Cuyahoga River Segment 1, 2, and 3 - Summary of Aquatic Life Use Attainment Impacts from other Sources Again, the logic used has major flaws. A statement is made that because improvements in the biological community have been documented, despite no improvements in the CSO system (actually, there have been major repairs made in the study area, but that is another issue) the CSO system cannot be responsible for the continued non-attainment seen. To the contrary, that is a strong implication that CSOs are at least partially responsible for the pervasive suppression of the aquatic community documented. The improvements in NPDES regulated wastewater discharges as they mention are largely responsible for the improvements in biological community performance with the other mentioned items contributing factors. I'm not sure why the same arguments are presented repeatedly throughout this document, but they are. Response: The logic that Ohio EPA is using to document the responsibility of CSOs for pervasive suppression of the aquatic life is in our opinion equally flawed. The improvements to the CSO system that had been made in 1994 had not cansed a significant reduction in volume or concentration of wet weather flow. Dry weather overflows have been reduced which may have some positive effects and we would agree that those flows may have suppressed the aquatic community. Our opinion based on the data and observation made in this study is that other factors may have a significantly greater
0161-153

23

000147

effect on suppressing biological communities and should be compared to the measured effect of CSO before resources are spent on improvements that may not create better water quality. We present the arguments in the sections of the report where they apply. We did not intend them to be redundant but we did intend the report to be self contained on a chapter basis so minimal cross referencing needed to be done as we moved from methods, to results, to conclusions. Page 10.8-9 Re: 10.8.3 Little Cuyahoga River Ohio EPA comments: See previous comments Response: Ditto. Page 10.8-10 Re: 10.8.3.1 Little Cuyahoga River Segment 1 A statement is made that biology declines between BLC I (Rm 9.8) and BLC 2 (RM 6.8) because the mean IEI and MIwb decline from 26 to 25 and 4.97 to 4.7, respectively and since this is upstream from the first CSO discharge other factors are impairing biology. Contrast tbis to earlier statements that there is no impact associated with the CSO despite the mean illI dropping from 25.5 to 21.0 between upstream and downstream from the first CSO outfalL Response: We may have over generalized here. We should have more specifically referred to the change in ICI scores which was dramatic in the second event Again some of this change may have been attributed to debris. We did not make a significant conclusion except to note the possible influence of the Springfield. Lake Outlet tributary which we have since documented to have a poor macroinvertebrate community. Section 10.8.3.1, P. 10.8-10, 3rd paragraph Ohio EPA comments: The assumption that what is causing impairment upstream from RM 11.0 (Ohio EPA sampling in 1986 and 1991 ) is also impairing communities at RM 9.8 (1994 study) is not necessarily an absolute. There could be a number of other sources involved. Sweeping generalizations comparing recent data with data col1ected 5 to 10 years ago should be made with caution. Response: We would agree that this may be a bit sweeping. However, it is no more general than the generalizations made in earlier Ohio EPA comments comparing 1991 and earlier results, and conclusions to those described in the current effort.

0161-153

24

000148

Section 10.8.3.1, P. 10.8-10, 4th paragraph Ohio EPA comments: Attributing the presence or absence of biological impairment due to sediment contamination based in Kelly and Rite classification results is misleading. The Kelly and Rite system addresses relative concentrations but does not directly assess toxicity. Response: We patterned our interpretation of the Kelly and Hite System after similar treatments seen in Ohio EPA reports. We extended our interpretation to suggest toxicity because of toxicity measured in stream samples. We have since performed preliminary studies where we have used the sediment toxicity method to measure toxicity directly. Our 1996 data has shown toxicity at some sites in both streams. Page 10.8-14 Ohio EPA comments: Considerable effort is made to document where concentrations of sediment metals increased and then when it appeared that the finger points to the CSOs as a potential source for the increase the statement is made that the observed effects are not likely to be due to CSO discharges with explanation offered or given. Response: The direct sampling of CSO effluent performed and documented elsewhere in the study has not shown elevated concentrations of metals in current outfalls in those areas. Section 10.8.3.2, P. 10.8-14, 3rd paragraph Ohio EPA comments: The statement is made that changes observed between BLC4 and BLC 5 are not likely due to CSO discharges. The rationale is given is that these is only one discharge point (Rack No. 11). We don't understand the reasoning behind this. Response: Our rationale also includes the existence of numerous other potential stressors to the aquatic community that are in that area. Also Rack 11 did not appear to have as much volume discharge as other racks within the adjacent upstream and downstream reaches. (1 month design storm - 8500 cfs vs 11,000 to 145,000 cfs at other area racks). Section 10.8.3.2, P. 10.8-15, 1st paragraph Ohio EPA comments: The statement is made that, because of lower flows in later summer 1994, upstream sediments were not moved into the vicinity ofBLC7. The inference is also made that improved macroinvertebrate ICI scores during the same time period were somehow related to this. Again, the logic escapes us.
0161-153

25
000149

Response: Sediment transport processes can cause agradation and degradation that disrupt natural substrate and bury artificial substrates. Page 10.8-16 & 17 Ohio EPA comments: A statement is made that, at BLC9 (RM 1.9), metals concentrations in the sediment are most probably only a slight depressant on the biology of the river. However, lead and mercury are present at this site at extremely elevated levels with cadmium and chromium at slightly elevated levels. It would be nice to see this data evaluated here according to Persaud et. AI. Although there was significant improvement between RM 1.9 and RM 1.8 in QHEI on the order of 12 points, adjacent high quality habitat should buoy up the results found at RM 1.9. The improvement seen at RM 1.8 probably is as a result of a combination of factors including habitat improvements and lessened sediment contaminant exposure. Response: RM1.9 is above the two low head dams that seem to stabilize flow at RM 1.8. The habitat at 1.9 is dominated by shale bedrock which made positioning substrates difficult and would not support good fish populations. The high metals in the sediments are probably specifically related to the point of collection of that sample which was adjacent to a noticeably stained stormwater outfall and may not be representative of general area sediment (of which there is little). We are not familiar with Persaud et al and would appreciate a copy of the complete reference for future use. Ohio EPA comments: At the bottom of Page 10.8-17 the issue of bottom substrate instability was raised as a possible contributing factor to the reduced biological perfOlmance measured at the downstream most site in the Little Cuyahoga River. The QHEI field sheets completed by EA are contradictory. They portray the pools as predominated by the gravel and the riffles predominated by cobbles yet under the riffle/run quality category the riffle/run substrate was characterized as unstable (i.e., gravel and sand). There is a fair amount of embeddedness, but the overall QHEI of 68 should obviously support a WWH community. On Page 10.8-18 the statement is made that the stream bed substrate is mostly sand and gravel which belies what is recorded on the QHEI sheets.

Response: We would agree that the QHEI sheets do not tell the whole story. The channel is shifting and braided in significant sections throughout the fmal half mile journey to the Cuyahoga. We have directly observed and recently measured those changes and it is significant. The channel has been observed to shift a distance of several meters and the cobble and larger stones are moved out into the Cuyahoga at the mouth of the Little Cuyahoga. Ohio EPA comments: The statement is made that the algal species at BLC 11 (RM 0.1) imply a great deal of nutrient enrichment, but that it can't be due to CSOs immediately upstream since they contribute only a
0161-153

26

000150

small amount of the total CSO flow. The grab water sampling data does imply increased organic loadings between BLC9 and BLCII with the highest measured concentrations of ammonia and some of the highest levels of BOD found in the Little Cuyahoga River the CSO is a source and its limited sampling prevents making any definitive statements. Response: We would agree that additional data collection might indicate some nutrient enrichment is clearly related to CSO. However the argument presented above about total loading need to be examined in detail as the water quality model is integrated with the collection system model in the current effort before a more definitive effect can be described. The flow of the two CSOs in the lower Little Cuyahoga River is a small proportion of total CSO.

10.8.6 Conclusions Ohio EPA comments: An attempt was made by this report to show that the various areas of attainment and nonattainment were not well correlated with the 37 CSO discharge points. Details on why this attempt is flawed is presented in responses to statements made in Section 10.6. The attainment ofWWH criteria in the Cuyahoga River and the Little Cuyahoga River downstream from CSO areas and the nonattainment observed in areas upstream of CSO discharge points are used as an argument for the concept that other pollution sources or habitat features are causing nonattainment of criteria in some reaches. First, there were no areas in the study area on the Cuyahoga and Little Cuyahoga River that fully attained criteria so that point isn't valid. The observation that other factors are causing reduce biological performance doesn't preclude. CSOs from adding stress and impact to the system and indeed there are, based on data included in the report, locations where impacts due to CSOs were documented and as pointed out in several locations the problem is complex with several factors contributing to the poor performance measured. The presence of these factors do not, however lead to the conclusion that aquatic life improvements would be minimal by implementing the CSO controls required by Federal and State CSO Policy. In fact, until the nine minimum controls are implemented, we will never know. Response: This document was never intended as a defense against nine minimum controls. We agree that some improvements should be observed as the effects of those controls are realized. Our logic and argument has always been directed at the extent of long term controls necessary to achieve water quality benefit. Ohio EPA comments: It is not surprising that biological results did not correlate well with all the 34 CSO discharge points. Besides the fact that sampling locations were not placed to directly assess potential effects from all the CSOs (i.e., immediate upstream and downstream chemical and biological sites,) we strongly suspect that influences of wet weather CSOs are not fully felt directly near field to the discharge point but are broadly distributed over long stream reaches. Most discharges occur at high flows which tend to quickly disperse the contaminants from the near-field area. Whether contaminants
0161-153

27

000151

are ultimately deposited, assimilated, and where they begin to exert physical/chemical influences under lower flow conditions is likely where a contribution to biological degradation will occur. Differentiating this cumulative impact from all other potential or real impacts originating from other sources (point or non-point or habitat-related) in a complex urban-industrial area would be extremely difficult. Likewise, writing off impacts attributable to the CSOs as not being significant because of all this other "noise" is an inappropriate dismissal of a significant contaminant source, especially given the measured loadings from the CSO system. Response: We would have to agree with much of the discussion in this comment. The conclusion that CSO is the worst problem is the point where the data does not allow us to disagree. The argument that it is difficult to differentiate relative impacts is very valid and we are struggling with developing ways to do that. If CSO were the primary cause of non-attainment the biological criteria should decline consistently as exposure to CSO increases in volume and frequency in a downstream direction. The documented improvement of biological communities downstream of the Ohio Canal CSO contributions directly contradicts that expectation. Until we can better differentiate what improvements will be gained from long term controls we will continue to look for ways to achieve water quality improvements through implementation of programs that will provide a documented water quality benefit. Comments and response to FINAL REPORT APPENDICES Appendix A-12 Final Report of Macroinvertebrate Survey Conducted As a Portion of the City of Akron CSO System Wide Study Table 2 ICls listed for Event 2 are under a column identified as "Round 2 scores on 3 of 5 samplers." This infers that the round 2 results did not include all five artificial substrates(at least with regards to leI calculation). This was not discussed in the main report. Some explanation as to what was done and why it was done is warranted. Response: As was discussed above some of the samples in the second round of sampling were subsampled by family according to Ohio EPA protocols. All macroinvertebrates on all 5 substrates were sorted for each site. In orders where more than 300 individuals were present 3 100 individual subsamples were randomly selected for identification. The individuals in each batch were taken from a single substrate but three substrates were randomly selected from the five at each site. A count was made from all 5 substrates of the total number of individuals in each group where subsampling was performed. That total was used to calculate the number of individuals in each taxa within that family. All of the insects collected in 1994 and subsequent events are currently being maintained by the subcontractor at Akron's expense if Ohio EPA would like to count them in some other fashion.

0161-153

28

000152

Table 2 Ohio EPA comments: A quick comparison of Table 2 with final Report Table 5-13 shows differences (some significant) in reported ICI scores. We recently provided Malcolm Pirnie with an electronic copy of our ICI program. They should be required to verify all their metric scoring and rectify conflicts between these two tables. Response: Data and final scores for all biological sampling were checked by Malcolm Pirnie. The subcontractors were made aware of any corrections and were not required to revise their final reports. The raw data presented in the Appendix represents the data that produced the scores in the report tables.

1995 Study Comments Chapter 1.0 Benthic Macroinvertebrate Survey Section 1.2, P. 1-4, 3rd paragraph Ohio EPA comments: Ohio EPA protocols specify that 3 multiple-plate samplers are used only at National Ambient Water Quality Monitoring Network (NAWQMN) stations; a composite of 5 multiple-plate samplers is to be used at all other sampling locations (Vol. 3, P. V-I-2). Thus, the use of 3 samplers is a deviation from standard protocols and is not the recommended approach. Response: The 1995 sampling was perfonned as part of Akron's continuing effort to understand water quality in the area. The choice of three rather than five substrates was purely economic and was not intended to provide data entirely comparable with the 1994 or Ohio EPA work. The results substantiate, however, that the method using three samplers did not produce significantly different ICI scores at sites which had been sampled previously. Section 1.3, P. 1-5, 1st paragraph Ohio EPA comments: At least for this survey, they recognized that the artificial substrates should be composited even if they only used three of them. However, if they wanted to use the 1995 information to compare to or verify their 1994 results, it seems like they did as much as possible to muddy the water (i.e. 1994 sampling, 5 samplers; 1995 sampling: 3 samplers composited). Response: We did not recognize that substrates should be composited. Again we were interested in furthering our knowledge of the system but we had a smaller budget to perform with. In the interests of maximizing resources and data we chose the subsampling short cut commonly employed by Ohio
0161-153

29

000153

EP A. Despite the allegation that we were "muddying the water" it is again significant how consistent our results were at sites that we revisited. Section 1.5, P. 1-6 and 1-7, 1st paragraph Ohio EPA comments: It's interesting that they acknowledge here that using 5 samplers as replicates might result in a "few extra species" and an inflated ICI score. This was one of our concerns based on their 1994 sampling results. Response: As we discussed if Ohio EPA's subsampling protocol is statistically sound (As we think it is) sUbsampling will not significantly change ICI scores. Again the consistency of our repeat sites despite slight changes in subsampling, supports the sound statistical design of the method. Section 1.5.2, P.ll-10, 1st paragraph Ohio EPA comments: The statement that "the qualitative analysis at the Alder Creek site indicated that the benthic community attained MWH standards" begs the question as to why that use was chosen. This stream is not listed in the WQS and we, therefore, have no idea as to its proper designation. It would have been helpful if a QHEI had been determined but this doesn't appear to be the case. Response: We had been told by Ohio EPA in initial responses to our study that our QHEI scores at sites where we did not fish were not appropriate. We did not include QHEI scores in the 1995 effort. We chose MWH because the scores are close to that use but we do not yet have an opinion on the appropriate use of that small tributary. Given its location and function a LRW designation is equally likely to be appropriate. We did macroinvertebrate sampling there to get some indication if the tributary had significant water quality impairment.

Section 1.5.2, P. 1-11, 2nd paragraph Ohio EPA comments: An eyeball comparison of the ICI scoring lines for Metric 3 (caddisfly taxa) indicates that 2 taxa at BCR9 would score a "2" which would be considered fair rather than good as they stated. It would be nice if they provided a table of each metric and how it scored for all of the quantitative sites, this goes for the Final Report as well. Response: The raw data and metric scores are available for all data at all sites in all studies.

0161-153

30

000154

Section 1.5.3 Ohio EPA comments: What was the purpose of this Tuscarawas sample? Response: Akron does straddle the divide. We were interested in a snapshot of downstream conditions to see if significant issues might exist. As other programs and development patterns change future Akron water quality issues may arise in that basin.

0161-153

31
000155

<0 LINDA A':SOWA
Service ~ctOI

"4

.= <Co VALERI~RAW-;l:;
Executive Assistdrit! I
U)

.

,t.~.0 j.{;~~',O"~'
",1.
);.

\. CI fy

CARL PALMISANO
Deputy Director

j"
01',

'1,-

t

:::,,=U;
C,CJ
~-.

C:>;~·

-'RON.

0"" 0

LUNZY O. ARMSTRONG
Deputy Director

u<.D

CO W

Donald L. Plusquellic

Mayor
DEPARTMENT OF PUBLIC SERVICE 166 5. High 51., Roam 201 Akron, OH 44308 Phone: (216) 375·2270 FAX: (216) 375·2100

JatWlary 25, 1996

Mr. Ronald A. Bell, P.E. GroLiP Leader Division of Surface Water Northeast District Office Ohio Environmental Protection Agency 2110 E. Aurora Road Twinsburg, Ohio 44087 RE:

Akron Combined Sewer Overflow SystemWide Study

Dear Mr. Bell: Enclosed please find two copies of the addendum to the Akron Combined Sewer Overflow System Wide Study. The following pages should replace the existing pages (location) in the CSO System Wide Study: ,-, . • • • • • • • • • • • • Current and Recommended Stream Use Designations Figure (Cover Letter) Current and Recommended Recreational Use Designations Figure (Cover Letter) ./fable 2, Recreational Use Attainment Recommendations (Cover Letter) /Page 24, Section 6.2 (Project Overview) --table 4-1, Key Trunk Interceptor Sewer monitoring Information (Project Overview) JTable 4-2, Stream Sites Time to Peak: Time to Recover (Project Overview) JFigure 4-1, 1994 Monitoring locations (Project Overview) "'Figure 4-3, 1994 Weekly Grab Sampling Locations (Project Overview) {Figure 4-4, 1994 Discrete Grab Sampling Locations (Project Overview) Figure 3-5, 1994 Monitoring Location (Chapter 3) Figure 4-1, 1994 Weekly Grab Sampling Locations (Chapter 4) Figure 4-2, 1994 Discrete Grab Sampling Locations (Chapter 4)

Additional items that are now included with the CSO System Wide Study are as follows: • • Biological Water Quality Assessment for 1995 Photographic Supplement

The Flow Monitoring Supplement (Volumes 1 and 2) were not submitted with the Report. If you feel that this data is needed, we can provide it to you.

000156

RE: Akron Combined Sewer Overflow System Wide Study January 25, 1996 Page 2

Macroinvertebrate sampling was performed in 1995 at ten new sites and four sites previously sampled during the Akron CSO System-Wide study (1994 biological sampling events). Sampling locations were chosen to confirm the 1994 sampling results and to characterize the biological water quality of several streams in the Little Cuyahoga River, Cuyahoga River, Camp Brook, and Tuscarawas River systems. The additional macroinvertebrate sampling supports our contention that the existing CSO's are a minor contributor to water quality degradation in receiving streams. During the 1995 biological sampling, the Water Pollution Control Station had not started dechlorinating the final effluent. Also, construction was occurring along the streams in several locations, such as the Memorial Parkway bridge and East Expressway (1-76) construction projects. Structural conditions in some stream segments prevent attainment of current aquatic life designations. The photographic supplement is intended to highlight these conditions and to provide support for reclassification of aquatic life designations. Additional pictures will follow as they become available to further illustrate the structural conditions in the receiving streams. Please contact Wendy Reust in the Bureau of Engineering at (216) 375-2493 if there are any questions regarding this submittal. Sincerely,

)<,~11b~ a ~9Uj7'Linda A. Sowa, Director Department of Public Service LASIWLR/csn Enclosure c: Donald Schregardus - Ohio EPA/Columbus, Tom Behlen - Ohio EPA/Columbus, George Elmaraghy - Ohio EPA/Columbus, Mark Stump - Ohio EPA/Columbus, Gary Stuhlfauth - Ohio EPA/Columbus wIatt., Bill Zawiski - Ohio EPAlTwinsburg, C. David Haugh, David Crandell wIatt., Michael McGlinchy wIatt., James Six wIatt., Patrick Gsellman wIatt., File C-15, Environmental Division File

H :\PROJEC TS\C\C-15\60122\NlR. CSN

000157

II!

Ii
§
o z

~
Q

~

Q

~

6 iJ
> " Z
N

""

0

000158

CUYAHOGA RIVER--

~~~v AI

CUYAHOaA.FAU.6~

UAH 11U« SEWER

}

/

~

'"""'--

1"--- HOI.E AVEWe
OH10

EDiSON LAKE {oa..}

""""""" NTEflCEPTCfl

l
SAND RUN
AG2

I AG3{HT-i MAH

LITTLE
0UTF~6
1ff'm:;8'TOR

CAlIf' """'" _SEWER

CUYAHOGA RIVER

._
~,

CAMP BROOK
---:~

~
TAW.lA1XlE TAW.lA1XlE

,~

~~1-~:-

1~ __ HA"'"
I

_SEWER

LlTT~ A"'~~
~
lJITLE CUYAHOGA _

,
I

I

"" ~

..,,11

CUYAHOGA RIVER

r---

""""""-T
SEWER

/1, .a:-

RCDeE'A'LT DITCH

L
~G4

E

G

E

N

D

INTBiCEP'IClR Q..CI)
0Cf-2

\
19 .___--OHiO

i

nlO
I~~~/

/--J-{J8

~~~

~

-,

C\Jl
~-

COMllN3)

RAI>l GAUGE MERCEl'TOR

10 MOOAOOFE ---....

SEPMA1E SANITARY INTERCEPTOR WATf5fNAY

020
illM1l6
t2,
~CF!I

RACK OR AEOOLA11NG S1R\JCiUAE
LONG TERM CSO FLOW MONITORING
AND SAMPLING SITE

SHORT TERM esc FLOW MONITOAING AM:) SAMf'lJNG SI1E

r ..c::
0Cf-1

:37AG5 CANAL 5 39
17
TO LOCK 2 PAAK ,
~f3SD

\
L_~,

, - - S!'RtlGFIElD I lAI<BlOflE _SEWER

AG-IO

R • I.

I
\\ """"""'" LAKE OUTlET

~A3S

38

CHMIlER

{»Of jM saMe!:}

"""""""

""""""'-D

LONG 1EAM S'mEAM FLOW MONITORING
AM:)

SAMf'lJNG SI1E SAMf'lJNG SI1E

%W S IHLC~-i

SHORT TERM FLOW MONITORING
AM:)

=-~~
~MAN

LAKE

//

~-

- - - - _,

r-

_ ~\
OHiO

~ I I
I

-I

WC<.FLEOCES~U' _SEWER 1
~ IVLT8
lAI<BlOflE

AG4

I

\1@0"L_
~
\

. Z

IIllOCH
~M8a

LONG 1EAM MERCEl'TOR R.OW
MOIITORING SI1E SHORT TERM INTERCEPTOR A..OW MOIITORING SI1E

Ml.O fMi
PllW STATION

. ~

A G1
.u)FlUN

-i----

lRM< SEWER

'"""'" LAKE

~

CJ-\l'JAL

~

~

/"

I

\

r--_., { L l..
'\

_

~
-

-

'v /

~ ~~ SOOTH3'I<OUTFALL

1

AG7

TFlJN(

SEWER

i&
~
~

PER!dANENT INSTREAM SAMPl.!NG STAllON MASTER METER
USGS GAGING STATION

-~

F<lACe1AAN

CITY OF AKRON CSO SYSTEM WIDE STUDY
1994 MONITORING LOCATIONS
FIGURE 3-5

000159

WOODWm:>
CREEK~_

WPCS

AKRON

CUYAHOGA

::RK~~7 A'
TRVWo;WER

~AHOOAFAU.S~I
"""o;WER

,

CUYAHOOA """"

/--@--

/~

(flARDJ "

I HOWE AD. !---HOMEA""'"
OHO EDISON LAKE (OB.)

CR6

@
SAllTAlN RD.

CAMP
BROOK
&.G3/
~ ~

lI
SAND
RUN
.&.G2

L_

MAJ4

OOTF~6

~~

~~--,
I

TAU..MADOE

TAU..MADOE

N1ERC8"lCR

l--.. _ ~~ ..
UTlLE CUYAHOOA lNTERCS"TOR(t.CO

EAS1WOOO AVE

~1 RIVE~HOGA
)---j'-o
10

CUY

UTILE

?s ~ '"0 r
II

,

y--~

orr",

f1OOS8'S.T

~
>:{
\

~--

L
AG4

E

G

E

N

D
I'"

.

19

·~-OHIO

'Y
\......._-,

RAiN GAUGE INTERCEPTOR SEWER (COMBINED SEWER AREA) INTERCEPTOR SEWER (SEPARATE SANITARY AREA)

\ ~4 >-.-J~37 AGS CANAL
17

5L

~r---~

WATERWr'\Y

020

Rf\CK OR REGULATING STRUCTURE WEEKLY GRAB SAMPLING LOCATIONS PERMANENT INSTREAM SAMPLING STATION

eCR2
~

~6
SUMMIT
LAKE
teN '-JJD RUN
P1.,M> STATION ~

!ill

MASTER METER
USGS GAGING STATION

"
\
-

(~''"-~'" . .4.G4
WOU'LEOGES TRVWo;WER

38L~

C

TO LOCK 2 PAll<

I
I

TRVWo;WER

.&.G10

awA3ER

00lLET

~L'J<E

_

o

f'OI'lCE MAtI

/

/~

~- _ '-. ~ .. ,_
1l'l\N(

_

.-lrlI
\

f"

0Hl0
CANAl

... -- ---.,

tESM1l1lAKE

Y.O RJN f'LU" STATK.lN (

/

~j

'L

AG1

-~-- -

-- -

~~

~

~

r L
-

~~\
.i.G7

~::=z
~

~
-

(~~ """"'"" OUlFAlL
\v/

'\

"" .... FOOOEMAH

"'---1

~K8EWER

CITY OF AKRON CSO SYSTEM WIDE STUDY
1994 WEEKLY GRAB SAMPLING LOCATIONS

000160 4-1 FIGURE

..... ·.":~D~

WOODW"",
CAEEK~

WPCS MUD ________
BROOK
"
I

AKRON

CUYAHOGA RIVER
M<DB1OOK

_ .....
,--" NORTHSDE-MelCe'TCfl

/,..:......@--

/~
I

HOWE RD.

~ HCt.E AveM:

~~~~

G6 I OORQE~

~
i

OHiO EDISON LAKE (08.,.)

CAMP
BROOK

®
TAl.l.MADOE TAl.l.MADOE
,

CR4

S1

I

I
I

~P3L

1

UTILE
36
"'" OOlt'AlL
~

~-HAV«lNS ,

_ .....
D

CUYAHOGA. - RIVER ---"

~~?(dJ
)

r·
5

I/.

\emTAI'1 RD. .---- --®- ~ ----- ~
I

~

L

EAS1WOCOA""-

SAND
RUN
.. G2
!..lm..E CUYAHOGA
~OR(LCO

' ~'- CUYAHOGA y---~ RIVER
\--J-ol0

ITILE

..~
,

~ ~_

/ I-I '- IV'

ROOSEVELT DITCH

~
:/

L
AG4

E

G

E

N

RAIN GAUGE INTERCEPTOR SEWER

___________ OHIO 4 .. G5 CANAL
,~37
• LJ

(COMBI~'ED SEWER AREA)

~«

L~-l __
~

INTERCEPTOR SEWER (SEPARATE SANITARY AREA)

WATERWAY

020 11118
~CR2
@]

RACK OR REGULATING STRUCTURE

~L=2P_

17

i\
I

LAKEMORE

_ .....
f < O f ' R D

S

f

'

R

AG10

eso

DISCRETE GRAB SAMPLING LOCATIONS

STREAM DISCRETE GRAB SAMPLING LOCATIONS PERMANENT INSTREAM SAMPLING STATION MASTER METER USGS GAGING STATION
I'EW Ml.D RlJN

SUMMIT
LAKE
P!JMF' STAllON ~
'

,"3;~.:o:,
WOlFLEDOES
1'RUNK SE'M3'l

kG4_I.
,'

Sf'Rf<Of'RD LAKE OOTLET

CHAMBER.
,

@]

"""""'"

F......

--.J

~OHO

---' \

I

MLO~
f'U,F STATION

/
../ /

/'

, t.ESWTH LAKE

mt.U< ~ j :

?ANAL ,;
e.

r::-"0_-f"~ __ >_, Ie:' "
~"~"''';O J"

• ~
_

"

".'.'

LAKEMORE~\
.. G7

~~z

m..t«SE'NB'I

,.L..J----~/, .? " , ' \

r

:-r--

'\ '

AGl

Ii,
,

~"'"

----1 CITY t0P:)J<RON
/'--

,~ 8QIJTHEIfl 0UTFAl.l..
mM:8EW8'I

\,-/

csa SYSTEM WIDE STUDY @ u1994iDISCRETE GRAB SAMPLING LOCATIONS
.~

";-~;;<:-->-c

RGURE 000161 4-2

,

LINDA A. SOWA
Service Direc lor

~;'
..•..
~

~"t

VALERIE STRAW
Executive Assistant

.,'<;.

"1",0 RON·O'·
Donald L Plusquellic Mayor

~
"i~':'i"'"

0" City 0",

At:' :'~~>.

00'
~

.;~_~,i;':",

CARL PALMISANO
Deputy Director

,:C;.

LUNZY O. ARMSTRONG
Deputy Director

DEPARTMENT OF PUBLIC SERVICE 166 S. High St., Room 201 Akron, OH 44308 Phone: (216) 375-2270 FAX: (216) 375-2100

December 29, 1995 Mr. Ronald A. Bell, P.E. Group Leader Division of Surface Water Northeast District Office Ohio Environmental Protection Agency 2110 E. Aurora Road Twinsburg, Ohio 44087 RE: Akron Combined Sewer Overflow System Wide Study

Dear Mr. Bell: In accordance with the conditions of the September 20,1994 Ohio EPA Director's Final Findings and Orders, the City of Akron is pleased to submit two copies of the City of Akron CSO System Wide Study. The study was conducted to evaluate the CSO discharges and existing receiving stream conditions. The report provides detailed information about the chemical impacts of existing CSO discharges and biological conditions in the receiving streams. The CSO System Wide Study reports significant evidence that the existing CSOs are a minor contributor to water quality degradation in the receiving streams. The study reports that some areas of the receiving streams are in attainment or approaching attainment of aquatic life use designations. Structural conditions in other stream segments are s).lch that aquatic life are not capable of attaining aquatic life use designations in all areas. The attac~efr'1;bIe I lists the streaIlls evaluated in relation to their aquatic life use attainment and the useattaipllbi1itys~pp()rted by the data in the report The City of Akron would like the OhiO, EPA tocO!.1,§iael( the findings of this study and adopt the suggested designations for the stream segm~ntsWith'in the City of Akron. The CSO System Wide Study also examined attailll1ii')l1tofrecreationalvsecriteria qased ort fecal coliform bacteria present in the recetvingstreJW1s.p.uring dry weat\1~, upstteam coliform concentrations are often in exceedence of applicabl¢ standards. Wet weather discharges from CSOs and other sources (urban storm water, SSOs, upstrcai!i cOl)tributio~s) c~ntribute to the exceedence of recreational use standllrds. Table 2 lists the recr.e:ational use designations aM the attainment status of the stream reaches inthe sttidYarea,'o The 0hip ErsAshould ~onsider developing wet weather standards for receiving streams in the State of Ohio. .'
000162

Akron Combined Sewer Overflow System Wide Study December 21, 1995 Page 2

As a result of this study the City will, within the limits of its authority, commit to continuing its program of system wide operation and maintenance improvement. Continuation of the improved operation and maintenance programs for the CSO system will maximize the capture and transport of wet weather flows and minimize exceedences of recreational use criteria. Improved operation and maintenance will also minimize or eliminate dry weather discharge from the CSO's. We look forward to discussing the data, findings and implications of this study with you and your staff. Please contact Wendy Reust in the Bureau of Engineering at (216) 375-2493 if you have any questions regarding this submittal. Sincerely,

~/h/~??' /Jea)-7~
Linda A. Sowa, Director Department of Public Service LASIWLRlcsn c: Donald Schregardus - Ohio EPA/Columbus Tom Behlen - Ohio EPA/Columbus George Elmaraghy - Ohio EPA/Columbus Mark Stump - Ohio EPAJColumbus Gary Stuhlfauth - Ohio EPA/Columbus wiatt. C. David Haugh David Crandell Michael McGlinchy Randall Monteith Patrick Gsellman File C-15 Environmental Division File

51220WLR

000163

Table 1 AKRON CSO SYSTEM WIDE STUDY AQUATIC LIFE USE ATTAINMENT RECOMMENDATIONS Stream Segment R.M. Current Designation WWH WWH WWH Use Attainment Use Attainability Comment MWH Partial WWH Partial WWH MWH WWH VARIANCE will need more time to recover or determine if recovery is possible MWH Impounded behind Ohio Edison Dam Mostly park area, minimal bank stabilization, natural channel Glide area, much bank stabilization, some dredging, flood control channel will
continue as pennanent modification

Cuyahoga River

46-44.6 44.6-42.6 42.6-37.45

Little Cuyahoga River

9.8-4.6

WWH

MWH

Includes channelized, impounded, underground and other highly urbanized modifications
Older urban modifications, some recovery

4.6-0.0

WWH

Partial MWH Some Partial WWH

VARIANCE will need more time to recover or determine if recovery is possible MWH LRW MWH MWH

of stream channel, biological community
appears to have potential to recover but has not recovered in all areas.

Ohio Canal

2.8-1.25 1.25-0.5 0.5-0.0

MWH LRW MWH WWH

MWH NA Partial MWH BelowMWH

Impounded by Lock I which is operated . byODNR Highly modified, mostly underground, entirely man made canal structure Abandoned canal bed that currently has some stream habitat, partially impounded
Both upstream and downstream sites have some modifications, dredging and

Camp Brook

3.2-0.0

channelization, further development is planned upstream.

000164

Table 2 AKRON CSO SYSTEM WIDE STUDY RECREATIONAL USE ATTAINMENT RECOMMENDATIONS Stream Cuyahoga River Segment RM. 46-44.6 Current Designation PCR Existing Reereational Use Attainment Dry and Wet Weather Exceedences Use Attainability Comment Non-Contact
Water contact prohibited by park service. Posted no access. Dry weather overflows will be addressed by Rack 35 improvement plan. Excccdcnccs exist upstream of esa area. Dry weather impact afRack 35 will be addressed.

44.6-42.6 42.6-37.45 Little Cuyahoga River 9.8-4.6

PCR PCR PCR

Dry and Wet Weather Exceedences Dry and Wet Weather Exceedenees Dry and Wet Weather Exceedences

PCR with Wet Weather Variance PCRwith Wet Weather Variance SCR with Wet Weather Variance

Dry weather impact of Rack 35 will be addressed.

Limited access, canalized, impounded,

underground and highly urbanized modifications. Dry weather overflows will be addressed by
improved operation and maintenance. ExcccdcllcCS exist upstream of esa area.

4.6-0.0 Ohio Canal 2.8-1.25 1.25-0.5 0.5-0.0 Camp Brook 3.2-0.0

PCR PCR SCR SCR SCR

Dry and Wct Weather Exceedences Wet Weathcr Exceedcnces Wet Weather Exccedcnces Wet Weather Exceedcnccs Wet Weather Exceedences

PCRwith Wet Weather Vari ancc PCR with Wet Weather Variance SCR with Wet Weather Variance SCR with Wet Weather Variancc SCR with Wet Weather Variance

Dry weather overflows will be addressed by improved operation and maintenance.

Impounded by Lock 1 which is operated by ODNR. Highly modified, mostly underground, entirely man made canal structure Abandoned canal bcd, partially impounded

Access is limited, shallow depths do not encourage recreational usc.

000165

I

o
Ol

o o o o
N

...>.

000166

State of Ohio Environmental Protection Agency STREET ADDRESS: Lazarus Government Center 50 W, Town St., Suite 700 Columbus, Ohio 43215
TELE: (614) 644-3020 FAX: (614) 644·3184 w#w.epa.state.oh.us

MAILING ADDRESS: P.O. Box 1049 Columbus, OH 43216-1049

August2,2007 Re: Ohio EPA Permit No. 31VOOOOO'ED Facility Name: Akron WTP

Akron Public Utilities Bureau 1570 Ravenna Rd Kent OH 44240 Ladies and Gentlemen: Transmitted herewith is one copy of the final National Pollutant Discharge Elimination System permit referenced above. You are hereby notified that this action of the Director is final and may be appealed to the Environmental Review Appeals Commission pursuant to Section 3745.04 of the Ohio Revised Code. The appeal must be in writing and shall set forth the action complained of and the grounds upon which the appeal is based. It must be filed with the Environmental Review Appeals Commission within thirty (30) days after notice of the Director's action. The appeal must be accompanied by a filing fee of $70.00 which the Commission, in its discretion, may reduce if by affidavit you demonstrate that payment of the full amount of the fee would cause extreme hardship. Notice ofthe filing of the appeal shall be filed with the Directors within three (3) days of filing with the Commission. Ohio EPA requests that a copy of the appeal be served upon the Ohio Attorney General's Office, Environmental Enforcement Section. An appeal may be filed with the Environmental Review Appeals Commission at the following address: Environmental Review Appeals Commission 309 South Fourth Street, Room 222 Columbus, Ohio 43215

~

rC:J£.d. ~
Patti L. Smith, Supervisor Permit Processing Unit Division of Surface Water PLSldks Enclosure CERTIFIED MAIL
SENDER: CC;lMPLETE THIS $EPTION
•

',S.

..

• • •

Complete items 1, 2, and 3. Also complete item 4 if Restricted Delivery is desired. .. Print your name and address on the reverse so that we can return the card to you. .. Attach this card to the back of the mailpiece, or on the front if space permits.

o Agent
B. ReceIved by (Printed Name) D. Is delivery address differentfrbm Item 11 0 Yes If YES, enter delIvery address below: 0 No

o Addressee

1. Article Addressed to:
NPDES 3IVOOOOO'ED 8:02:07 (F)

AKRO~ PUBLIC UTILITIES BUREAU
1570 RAVENNA RD KENT,OH 44240
3. Service Type

o Registered o Insured Mall
2.

o

Certified Mail

o Express Mall Ii o Return Receipt for M1chandise o C.O.D.
0 Yes

4. Restricted Delivery? (Extra Fee)

7007 0710 0002 4433 1429
Domestic Return Receipt Ted Strickland, Governor Lee Fisher, Lieutenant Governor Chris Kor\eski, Director
102595-02·M-1541

PS Form 3811, February·2004

000167

Ohio EPA Invoice/Receipt
Date Printed: August 01, 2007 RevenuelD: 616643 Please include this Revenue ID with all correspondence. Organization ID: Information: 17261 City Of Akron - Public Utilities Bureau 146 S High St Akron, OH 44308Effective Date: Revenue Description: Program Name: Reason: DSW- NPDES Permit Issuance NPDES Permitting NPDES Permit Issuance for Akron WTP 3IVOOOOO*ED Due Date: September 16, 2007J Amount Due:

[1)00.00

_.~

September 01, 2007

For some Revenues, Interest and/or Penalties may be charged for late payment. Next Interest Date (if applicable): October 16, 2007

Next Penalty Date (if applicable):

Organization 10: Information:

17261 City Of Akron - Public Utilities Bureau 146 S High St Akron, OH 44308Due Date: [sie16;"2007~'~ Amount Due: lt1-,SO():~=-------=:J Amount Enclosed: $

Secondary Type/ld: Revenue Type:

SNPDE I 31VOOOOO PTONI

_

Remit to: Ohio Environmental Protection Agency - OFA Department L-2711 Columbus,OH 43260-2711
Check 10: Check Date: Check Number: Check Amount:

$

_

000168

Page 1 3IVOOOOO*ED

Application No. OH00006l2 Issue Date: August 2, 2007

Effective Date: September 1, 2007 Expiration Date: August 31, 2012 Ohio Environmental Protection Agency Authorization to Discharge Under the National Pollutant Discharge Elimination System
In compliance with the provisions of the Federal Water Pollution Control Act, as amended (33 U.S.C. 1251 et. seq., hereinafter referred to as the "Act"), and the Ohio Water Pollution Control Act (Ohio Revised Code Section 6111),

The City of Akron Water Treatment Plant is authorized by the Ohio Environmental Protection Agency, hereinafter referred to as "Ohio EPA," to discharge from the wastewater treatment works located at 1570 Ravenna Road, Kent, Ohio, Portage County and discharging to the Twin Lakes tributary and Cuyahoga River in accordance with the conditions specified in Parts I, 11, and III of this pennit. This pemlit is conditioned upon payment of applicable fees as required by Section 3745.11 of the Ohio Revised Code. This permit and the authorization to discharge shall expire at midnight on the expiration date shown above. In order to receive authorization to discharge beyond the above date of expiration, the permittee shall submit such information and forms as are required by the Ohio EPA no later than 180 days prior to the above date of expiration.

Chris Korleski Director

Total Pages: 19

000169

Page 2 3IVOOOOO*ED

Part I, A. - FINAL EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS 1. During the period beginning on date of permit issuance and lasting until permit expiration, the permittee is authorized to discharge in accordance with the following limitations and monitoring requirements from outfall 3IVOOOOOOOI. See Part II, OTHER REQUIREMENTS, for locations of effluent sampling. Table - Final Outfall - 001 - Final
f,ft1uent Characteristic

Discharge Limitations Conccntration Specified Units Loading* kg/day Daily Weekly Monthly

Monitoring Requirements

Measuring
Frequency JlMonth Grab

Parameter
00400 - pH - S.U. 00530 - Total Suspcnded Solids - mgll 50050 - Flow Rate - MGD 82080 Trihalomethane, Total- ugll

Maximum Minimum Weekly

Monthly

Sampling Type

Monitoring Months

9.0
45

6.5 30 102

All All All All

68

1 I 2 Weeks Composite
1/2 Weeks

24hr Total Grab

JlMonth

Notes for Station Number 3IV00000001:

* Effluent loadings based on average design flow of 0.6 MOD.
Sampling shall be performed when discharging. If NO DISCHARGE OCCURS DURING THE ENTIRE MONTH, report "AL" in the first column of the first day of the month on the 4500 Form (Monthly Operating Report). A signature is still required.

* Flow for outfalls 3IVOOOOO 001

& 3IVOOOOO 002 shall be reported on the same day.

000170

Page 3 3IVOOOOO*ED

Part I, A. - FINAL EFFLUENT LIMITATrONS AND MONITORING REQUIREMENTS 1. During the period beginning on date of permit issuance and lasting until permit expiration, the permittee is authorized to discharge in accordance with the following limitations and monitoring requirements from outfall 3IV00000002. See Pmt II, OTHER REQUIREMENTS, for locations of effluent smnpling. Table - Final Outfall - 002 - Final
Emu.ent Characteristic
Parameter

llischarge Liwitations Concentration Specified Units Maximum Minimum Weekly 9.0 45 6.5 30 102 Monthly Loading* kg/day Daily Weekly Monthly
Measuring
Frequency

Monitoring Requirements Sampling Type Grab Monitoring Months

00400 - pH - S.U. 00530 - Total Suspended Solids - mg/I 50050 - Flow Rate - MGD 82080 - Trihalomethane, Total- ug/l

l/Month

All All All All

68

I / 2 Weeks Composite 1/2 Weeks 24hr Total l/Month Grab

Notes for Sfation Number 3IV00000002:

* Effluent loadings based on average design flow of 0.6 MGD. Sampling shall be performed when discharging. If NO DISCHARGE OCCURS DURING THE ENTIRE MONTH, report "AL" in the first column of the first day of the month on the 4500 Form (Monthly Operating Report). A signature is still required.

* Flow for outfalls 3IVOOOOOOOI &

3IV00000002 shall be reported on the same day.

000171

Page 4 3IVOOOOO*ED

Part I, B. - UPSTREAM MONITORING REQUIREMENTS 1. Upstream Monitoring. During the period begilming on date of permit issuance and lasting until permit expiration, the permittee shall monitor the receiving stream, upstream of the point of discharge at Station Number 3IV0000080 I, and report to the Ohio EPA in accordance with the following table. See Pari II, OTHER REQUIREMENTS, for location of sarupling. Table - Upstream Monitoring - 80 I - Final
Effluent Character).stic Discharge Limitations Concentration Specified Units Loading* kg/day Daily Weekly Monthly Maximum Minimum Weekly Monthly

Monitoring Requirements
Measuring Frequency
lIMonth l/Month Grab Grab Sampling Type

Monitoring
Months All All

Parameter
00900 - Hardness, Total (CaC03) - mg/l 01042 - Copper, Total (Cu) - ugll

000172

Page 5 3IVOOOOO*ED

Part I, B. - DOWNSTREAM-NEARFlELD MONITORING REQUIREMENTS
1. Downstream-NearfieId Monitoring. During the period beginning on date of permit issuance and lasting until permit expiration, the permittee shall monitor the receiving stream, downstream of the point of discharge, at Station Number 3IV00000901, and report to the Ohio EPA in accordance with the following table. See Part II, OTHER REQUIREMENTS, for location of sampling.

Table - Downstream-Nearfield Monitoring - 901 - Final
Effluent Characteristic
Parameter

Discharge Limitations
Concentration Specified Units Maximum Minimum Weekly Monthly Loading* kg/day Daily Weekly Monthly

Monitoring Requirements Measuring Frcquency
l/Month l/Month l/Month l/Month Grab Grab Grab Grab Sampling Type Monitori11g Months
All All All All

00010 - Water Temperature - C 00300 - Dissolved Oxygen - mgll 00900 - Hardness, Total (CaCm) - mg/l 01042 - Copper, Total (Cu) - ugll

000173

Page 6 3IVOOOOO*ED

Part I, B. - DOWNSTREAM-NEARFIELD MONITORING REQUIREMENTS I. Downstream-Nearfield Monitoring. During the period beginning on date of permit issuance and lasting until permit expiration, the pemlittee shall monitor thc rcceiving stream, downstream, at Station Number 3IV00000902, and repmi to the Ohio EPA in accordance with the following table. Scc Pari II, OTHER REQUIREMENTS, for location of sarnpling. Table - Downstream-Nearfield Monitoring - 902 - Final
Monitoring Requirements Loading* kg/day Daily Weekly Monthly

Effluent Characteristic

Dischargse.Limitations Concentration Specified Units

Measuring
Frequency l/Day

Parameter
50050 - Flow Rate - MGD

Maximum Minimum Weekly

Monthly

Sampling Type Calculated

Monitoring Months All

NOTES for Station Number 3IV00000902: Flow monitming is necessary for the purpose of maintaining Water Quality Standards in the Middle Cuyahoga River (reconnnended flow 8.5 mgd, page 19 of Middle Cuyahoga River TMDL report). As a separate issue, on September 26, 2006 the Portage County Common Pleas Court (Case No. 98 CV 0325), on remand from the Ohio Supreme Court (Portage Cty. Bd. of Commrs. v. Akron, 109 Ohio StJd 106, 2006-0hio-954.) ordered a minimum aggregate flow release of 8.1 to 9.5 mgd of water which includes 5 mgd of "good quality water" released from Lake Rockwell and 3.1 to 4.5 mgd from "other sources". See Part II. Item H

000174

Page 7 3IYOOOOO*ED

Part II, OTHER REQUIREMENTS A. Description of the location of the required sampling stations are as follows: Description of Location

Sampling Station

3IVOOOOOOOI 3IV00000002 3IV00000902 3IV00000801 3IV00000901

Discharge from lower west lagoon (Lat: 41 NIl' 00 "; Long: 81 W20 ' 05 ") Discharge from lower east lagoon (Lat:4l NIl '00 ";Long:8l W20 '05 ") Ficticious station representing calculated total of water released to comply with daily minimum water release requirement. Sample of Cuyahoga River upstream of Lake Rockwell at State Route 303 (Lat: 41 N 10' 18 "; Long: 81 W 20 ' 07 ") Downstream of Lake Rockwell at the west bank of the river upstream of the Twin Lakes Tributary (Lat: 41 N 10 '52 "; Long: 81 W 20 '07 ")

B. This permit shall be modified, or alternatively, revoked and reissued, to comply with any applicable effluent standard or limitation issued or approved under Sections 301(b)(2)(C) and (D), 304(b)(2), and 307(a)(2) of the Clean Water Act, if the effluent standard or limitation so issued or approved. 1. Contains different conditions or is otherwise more stringent than any effluent limitation in the permit; or 2. Controls any pollutant not limited in the permit. The permit as modified or reissued under this paragraph shall also contain any other requirements of the Act then applicable. C. All parameters, except flow, need not be monitored on days when the plant is not normally staffed (Saturdays, Sundays, and Holidays). On those days, report "AN" on the monthly report form. D. Pelmit limitations may be revised in order to meet water quality standards after a stream use determination and waste load allocation are completed and approved. This permit may be modified, or alternatively, revoked and reissued, to comply with any applicable water quality effluent limitations. E. Grab samples shall be collected at such times and locations, and in such fashion, as to be representative of the facility's performance. F. Final pennit limitations based on preliminary or approved waste load allocations are subject to change based on modifications to or finalization of the allocation or report or changes to Water Quality Standards. Monitoring requirements and/or special conditions of this permit are subject to change based on regulatory or policy changes.

000175

Page 8 3IYOOOOO*ED

G. Within 12 months of the effective date of this Permit, the perm.ittee shall submit to the appropriate Ohio EPA District Office an evaluation of its sludge management plan, which was approved on October 16, 1995. This evaluation shall examine the adequacy of the plan, including any implementation problems encountered and any changes required, and is to reflect the actual sludge disposal practices. The evaluation shall also include a discussion of the current regulatory status of alum sludge and the regulatory appropriateness of the existing sludge management plan as contrasted with applicable current regulations. If significant changes are required, the permittee may be required to submit for approval a modified sludge management plan. H. Within 3 months of pennit issuance the permitee shall submit to Ohio EPA's Northeast District Office, Division of Surface Water an engineering calculation approach to determining water release volumes to satisfy monitoring requirements for Station Number 3IVOOOOO 902. The calculation shall include releases from outfalls 00 1 & 002, seepage rate at Lake Rockwell ("other sources), and release from pipe constituting "good quality
water!!.

1. The Upper Cuyahoga R.iver Total Maximum Daily Load report (TMDL) was approved by U.S. EPA on September 27, 2004. The implementation plan contained development of a reservoir management plan as one of the reasonable assurances. Ohio EPA will continue to work with the City of Akron to develop a mutually acceptable plan within 2 years of permit issuance. The plan shall address both water quality and public water supply needs related to the City of Akron and its water supply customers.

000176

Page 9 3IVOOOOO*ED PART III - GENERAL CONDITIONS
I. DEFINITIONS

"Daily discharge" means the discharge of a pollutant measured during a calendar day or any 24-hour period that reasonably represents the calendar day for purposes of sampling. For pollutants with limitations expressed in units of mass, the "daily discharge" is calculated as the total mass of the pollutant discharged over the day. For pollutants with limitations expressed in other units of measurement, the "daily discharge" is calculated as the average measurement of the pollutant over the day. "Average weekly" discharge limitation means the highest allowable average of "daily discharges" over a calendar week, calculated as the sum of all "daily dischargesH measured during a calendar week divided by the number of "daily discharges" measured during that week. Each of the following 7-day periods is defined as a calendar week: Week I is Days I - 7 of the month; Week 2 is Days 8 - 14; Week 3 is Days 15 - 21; and Week 4 is Days 22 - 28. lIthe "daily discharge" on days 29,30 or 31 exceeds the "average weekly" discharge limitation, Ohio EPA may elect to evaluate the last 7 days of the month as Week 4 instead of Days 22 - 28. Compliance with fecal coliform bacteria or E coli bacteria limitations shall be determined using the geometric mean.
I! Average monthly" discharge limitation means the highest allowable average of lldaily discharges" over a calendar month, calculated as the sum of all "daily discharges" measured during a calendar month divided by the number of "daily discharges" measured during that month. Compliance with fecal coliform bacteria or E coli bacteria limitations shall be detennined using the geometric mean.

"85 percent removal" means the arithmetic mean of the values for effluent samples collected in a period of30 consecutive days shall not exceed 15 percent of the arithmetic mean ofthe values for influent samples collected at approximately the same times during the same period. Absolute Limitations" Compliance with limitations having descriptions of "shall not be less than," "nor greater than, l! Hshall not exceed,H "minimum," or "maximum!! shall be determined from any single value for effluent samples and/or measurements collected.
If

"Net concentration" shall mean the difference between the concentration ofa given substance in a sample taken of the discharge and the concentration of the same substances in a sample taken at the intake which supplies water to the given process. For the purpose of this definition, samples that are taken to determine the net concentration shall always be 24-hour composite samples made up of at least six increments taken at regular intervals throughout the plant day.

000177

Part III General Conditions (Con't)

Page 10 3IVOOOOO*ED

"Net Load" shall mean the difference between the load of a given snbstance as calculated from a sample taken of the discharge and the load of the same substance in a sample taken at the intake which supplies water to given process. For purposes of this definition, samples that are taken to detennine the net loading shall always be 24-hour composite samples made up of at least six increments taken at regular intervals throughout the plant day. "MGD" means million gallons per day.

"mg/I" means milligrams per liter.
"ug/l" means micrograms per liter.
"ng/I" means nanograms per liter.

"S.U.1t means standard pH unit.
llkg/day" means kilograms per day.
"Reporting Code" is a five digit number used by the Ohio EPA in processing reported data. The reporting code does not imply the type of analysis used nor the sampling techniques employed. "Quarterly (l/Quarter) sampling frequency" means the sampling shall be done in the months of March, June, Augus~ and December, unless specificially identified otherwise in the Effluent Limitations and Monitoring Requirements table. . "Yearly (IN ear) sampling frequency" means the sampling shall be done in the month of September, unless specificially identified otherwise in the effluent limitations and monitoring requirements table. "Semi-annual (2/Year) sampling frequency" means the sampling shall be done during the months of June and December, unless specificially identified otherwise. "Winter" shall be considered to be the period from November I through April 30.

"Bypass!! means the iiltentional diversion of waste streams from any portion of the treatment facility.
"Summer" shall be considered to be the period from May I tlrrough October 31. "Severe property damage" means substantial physical damage to property, damage to the treatment facilities which would cause them to become inoperable, or substantial and pennanent loss of natural resources which can reasonably be expected to occur in the absence of a bypass. Severe property damage does not mean economic loss caused by delays in production.

tlUpset" means an exceptional incident in which there is unintentional and temporary noncompliance with technology based permit effluent limitations because of factors beyond the reasonable control of the permittee. An upset does not include noncompliance to the extent caused by operational error, improperly designed treatment facilities, inadequate treatment facilities, lack of preventive maintenance, or careless or improper operation.

000178

Part III General Conditions (Can't)

Page II 3IVOOOOO*ED

"Sewage sludge" means a solid, semi-solid, or liquid residue generated during the treatment of domestic sewage in a treatment works as defined in section 6111.01 of the Revised Code. "Sewage slndge" includes, but is not limited to, scum or solids removed in primary, secondary, or advanced wastewater treatment processes. "Sewage sludge" does not include ash generated during the fIring of sewage sludge in a sewage sludge incinerator, grit and screenings generated during preliminary treatment of domestic sewage in a treatment works, animal manure, residue generated during treatment of animal manure, or
domestic septage.

"Sewage slndge weight" means the weight of sewage sludge, in dry U.S. tons, including admixtures such as liming materials or bulking agents. Monitoring frequencies for sewage sludge parameters are based on the reported slndge weight generated in a calendar year (use the most recent calendar year data when the l'\TPDES permit is np for renewal). "Sewage sludge fee weight" means the weight of sewage sludge, in dry U.S. tons, excluding admixtures such as liming materials or bulking agents. Annual sewage sludge fees, as per section 3745.11(Y) of the Ohio Revised Code, are based on the reported sludge fee weight for the most recent calendar year. 2. GENERAL EFFLUENT LIMITATIONS The effluent shall, at all times, be free of substances: A. In amounts that will settle to fonn putrescent, or otherwise ohjectionable, sludge deposits; or that will adversely affect aqnatic life or water fowl;

B. Of an oily, greasy, or surface-active nature, and of other floating debris, in amounts that will form noticeable accumulations of scum, foam or sheen; .
C. In amounts that will alter the natural color or odor of the receiving water to such degree as to create a nuisance;

D. In amounts that either singly or in combination with other substances afe toxic to human, animal, or aqnatic life;
E. In amounts that are condncive to the growth of aquatic weeds or algae to the extent that snch growths become inimical to more desirable forms of aquatic life, or create conditions that are unsightly, or constitute a nuisance in any other fashion;

F. In amounts that will impair designated instream or duwnstream water uses.
3. FACILITY OPERA nON AND QUALITY CONTROL All wastewater treatment works shall be operated in a manner consistent with the following:

A. At all times, the permittee shall maintain in good working order and operate as efficiently as possible all treatment or control facilities or systems installed or used by the penllittee necessary to achieve compliance with the terms and conditions of this pennit. Proper operation and maintenance also includes adeqnate laboratory controls and appropriate qnality assnrance procedures. This provision requires the operation of back-up or anxiliary facilities or similar systems which are installed by a penuittee only when the operation is necessary to achieve compliance with conditions of the permit.
B. The permittee shall effectively monitor the operation and efficiency of treatment and control facilities and the quantity and qnality of the treated discharge. C. Maintenance of wastewater treatment works that results in degradation of effluent quality shall be schednled during non-critical water quality periods and shall be carried out in a manner approved by Ohio EPA as specified in the Paragraph in the PART III entitled, "UNAUTHORIZED DISCHARGES".

000179

Part III General Conditions (Con't) 4. REPORTING

Page 12 3IVOOOOO*ED

A. Monitoring data required by tbis permit may be submitted in bardcopy format on the Ohio EPA 4500 report form pre-printed by Ohio EPA or an approved facsimile. Ohio EPA 4500 report forms for each individual sampling station are to be received no later than the 15th day of the month following the month-of-interest. The original report form must be signed and mailed to: Ohio Environmental Protection Agency Lazarus Government Center Division of Surface Water Enforcement Section ESIMOR P.O. Box 1049 Columbus, Ohio 43216-1049 Monitoring data may also be submitted electronically using Ohio EPA developed SWIMware software. Data must be transmitted to Ohio EPA via electronic mail or the bulletin board system by tbe 20tb day of the month following the month-of-interest. A Surface Water Information Management System (SWIMS) Memorandum of Agreement (MOA) must be signed by the responsible official and submitted to Ohio EPA to receive an authorized Personal Identification Number (PIN) prior to sending data electronically. A hardcopy of the Ohio EPA 4500 fDIm must be generated via SWIMware, signed and maintained onsite for records retention purposes. B. If the pelmittee monitors any pollutant at the location(s) designated herein more frequently than required by this permit, using approved analytical methods as specified below, the results of such monitoring shall be included in the calculation and reporting of the values required in the reports specified above. C. Analyses of pollutants not required by this permit, except as noted in the preceding paragraph, shall not be reported on Ohio EPA report fonn (4500) but records shall be retained as specified in the paragraph entitled "RECORDS RETENTION". 5. SAMPLING AND ANALYTICAL METHOD Samples and measurements taken as required herein shall be representative of the volume and nature of the monitored flow. Test procedures for the analysis of pollutants shall conform to regulation 40 CFR 136, "Test Procedures For The Analysis of Pollutants" unless other test procedures have been specified in this permit. The permittee shall periodically calibrate and perform maintenance procedures on all monitoring and analytical instrumentation at intervals to insure accuracy ofmeasurements. 6. RECORDING OF RESULTS For each measurement or sample taken pursuant to the requirements of this peIDlit, the permittee shall record the following information: A. The exact place and date of sampling; (time of sampling not required on EPA 4500) B. The person(s) who perfonned the sampling or measurements;

C. The date the analyses were performed on those samples;
D. The person(s) who performed the analyses; E. The analytical techniques or methods used; and F. The results of all analyses and measurements.

000180

Part !II General Conditions (Can't) 7. RECORDS RETENTION

Page 13 3IVOOOOO*ED

The permittee shall retain all of the following records for the wastewater treattnent works for a minimum of three years except those records that pertain to sewage sludge disposal, use, storage, or treatment, which shall be kept for a minimum of five years, including: A. All sampling and analytical records (including internal sampling data not reported);

B. All original recordings for any continuous monitoring instrumentation; C. All instrumentation, calibration and maintenance records;
D. All plant operation and maintenance records; E. All reports reqnired by tbis permit; and F. Records of all data used to complete the application for this permit for a period of at least three years, or five years for sewage sludge, from the date of the sample, measurement, report, or application. These periods will be extended dnring the conrse of any unresolved litigation, or when requested by the Regional Administrator or the Ohio EPA. The three year period, or five year period for sewage sludge, for retention of records shall start from the date of sample, measurement, report, or application. 8. AVAILABILITY OF REPORTS Except for data determined by the Ohio EPA to be entitled to confidential status, all reports prepared in accordance with the terms of this permit shall be available for public inspection at the appropriate district offices of the Ohio EPA. Both the Clean Water Act and Section 6111.05 Ohio Revised Code state that eff]nent data and receiving water qnality data shall not be considered confidential. 9. DUTY TO PROVIDE INFORMATION The permittee shall furnish to the Director, within a reasonable time, any information which the Director may request to determine whether cause exists for modifying, revoking, and reissuing, or tenninating the permit, or to determine compliance with this permit. The permittee shall also fumish to the Director, upon request, copies of records required to be kept by this permit.
10. RlGHT OF ENTRY

The permittee shall allow the Director or an authorized representative upon presentation of credentials and other docnments as may be reqnired by law to:

A. Enter upon the pennittee's premises where a regulated facility or activity is located or conducted, or where records mnst be kept under the conditions of this pennit. B. Have access to and copy, at reasonable times, any records that must be kept under the conditions of the permit.
C. Iuspect at reasonable times any facilities, equipment (including monitoring and control equipment), practices, or operations regulated or required under this permit.

D. Sample or monitor at reasonable times, for the purposes of assuring permit compliance authorized by the Clean Water Act, any substances or parameters at any location.

Or

as otherwise

000181

Part III General Conditions (Can't) 11. UNAUTHORlZED DISCHARGES A. Bypassing or diverting of wastewater from the treatment works is prohibited unless:

Page 14 3IVOOOOO*ED

I. Bypass was unavoidable to prevent loss of life, personal injury, or severe property damage;

2. There were no feasible alternatives to the bypass, such as the use of auxiliary treatment facilities, retention of untreated wastes, or maintenance during nonnal periods of doWntime. This condition is not satisfied if adequate back up equipment should have been installed in the exercise of reasonable engineering judgment to prevent a bypass which occurred during normal periods of equipment downtime or preventive maintenance; and
3. The permittee submitted notices as required under paragraph D. ofthis section, B. If the permittee knows in advance of the need for a bypass, it shall submit prior notice, if possible at least ten days before the date of the bypass. C. The Director may approve an unanticipated hypass after considering its adverse effects, if the Director determines that it has met the three conditions listed in paragraph]] .A. of this section, D. The permittee shall submit notice of an unanticipated bypass as required in section 12. A. E. The permittee may allow any bypass to occur which does not cause effluent limitations to be exeeeded if that bypass is for essential maintenance to assure efficient operation.

000182

Part III General Conditions (Can't) 12. NONCOMPLIANCE NOTIFICATION

Page 15 3IVOOOOO*ED

A. The permittee shalI by telephone report any of the folIowing within twenty-four (24) hours of discovery at (talI free) 1-800-282-9378: I. Any noncompliance which may endanger health or the environment; 2. Any unanticipated bypass which exceeds any efflnent limitation in the permit; or 3. Any upset which exceeds any efflnent limitation in the permit. 4. Any violation of a maximum daily discharge limitation for any of the pOlIutants listed by the Director in the permit. B. For the telephone reports required by Part I2.A., the folIowing information must be included:
1. The times at which the discharge occurred, and was discovered;

2. The approximate amount and the characteristics of the discharge; 3. The stream(s) affected by the discharge;
4. The circumstances which created the discharge;

5. The names and telephone numbers of the persons who have knowledge ofthese circumstances;
6. \Vhat remedial steps are being taken; and

7. The names and telephone numbers of the persons responsible for such remedial steps. C. These telephone reports shalI be confIrmed in writing within fIve days of the discovery of the discharge and/or noncompliance and submitted to the appropriate Ohio EPA district office. The report shalI include the folIowing: 1. The limitation(s) which has been exceeded; 2. The extent of the exceedance(s); 3. The cause of the exceedance(s); 4. The period of the exceedance(s) including exact dates and times; 5. If uncorrected, the anticipated time theexceedance(s) is expected to continue, and 6. Steps being taken to reduce, eliminate, and/or prevent occurrence of the exceedance(s).

000183

Part III General Conditions (Con't) D. Compliance Schedule Events:.

Page 16 3IVOOOOO*ED

If the permittee is unable to meet any date for achieving an event, as specified in the schedule of compliance, the permittee shall submit a written report to the appropriate district office of the Ohio EPA within 14 days of becoming aware of such situation. The report shall include the following: 1. The compliance event which has been or will be violated; 2. The cause of the violation; 3. The remedial action being taken; 4. The probable date by which compliance will occur; and 5. The probability of complying with subsequent and final events as scheduled.

E. The permittee shall report all instances of noncompliance not reported under paragraphs A, B, or C of this section, at the time monitoring reports are submitted. The reports shall contain the infonnation listed in paragraphs Band C of this section.
F. Where the permittee becomes aware that it failed to submit any relevant application or submitted incorrect infonnationin a permit application or in any report to the director, it shall promptly submit such facts or infonnation. 13. RESERVED 14. DUTY TO MITIGATE The permittee shall take all reasonable steps to minimize or prevent any discharge in violation of this permit which has a reasonable likelihood of adversely affecting human health or the environment. 15. AUTHORIZED DISCHARGES All discharges authorized herein shall be consistent with the terms and conditions of this permit. The discharge of any pollutant identified in this permit more frequently than, or at a level in excess of, that authorized by this permit shall constitute a violation of the terms and conditions of this permit. Such violations may result in the imposition of civil and/or criminal penalties as provided for in Section 309 of the Act and Ohio Revised Code Sections 6111.09 and 61 I 1.99. 16. DISCHARGE CHANGES The following changes must be reported to tile appropriate Ohio EPA district office as soon as practicable: A. For all treatment works, any significant change in character of the discharge which the permittee knows or has reason to believe has occlUTed or will occur which would constitute cause for modification or revocation and reissuance. The permittee shall give advance notice to the Director of any planned changes in the permitted facility or activity which may result in noncompliance with permit requirements. Notification of permit changes or anticipated noncompliance does not stay any permit condition.
B. For publicly owned treatment works:

I. Any proposed plant modification, addition, and/or expansion that will change the capacity or efficiency of the plant; 2. The addition of any new significant industrial discharge; and 3. Changes in the quantity or quality of the wastes from existing tributary industrial discharges which will result in significant new or increased discharges of pollutants.

000184

Part III General Conditions (Con't)

Page 17 31VOOOOO*ED

C. For non-publicly owned treatment works, any proposed facility expansions, production increases, or

process modifications, which will result in new, different, or increased discharges of pollutants. Following this notice, modifications to the pennit may be made to reflect any necessary changes in pennit conditions, including any necessary effiuent limitations for any pollutants not identified and limited herein. A detennination will also be made as to wbether a National Enviromnental Policy Act (NEPA) review will be required. Sections 6111.44 and 6111.45, Ohio Revised Code, require that plans for treatment works or improvements to such works be approved by the Director of the Ohio EPA prior to initiation of constlUction.
D. In addition to the reporting requirements under 40 CFR 122.41(1) and per 40 CFR 122.42(a), all existing manufacturing, commercial., mining, and silvicultural dischargers must notify the Director as soon as they know or have reason to believe:

1. That any activity has occurred or will occur which would result in the discharge on a routine or frequent basis of any toxic pollutant which is not limited in the pennit. If that discharge will exceed the highest of the "notification levels" specified in 40 CFR Sections 122.42(a)(1)(i) through 122.42(a)(l)(iv). 2. That any activity has occurred or will occur which would result in any discharge) on a non-routine or infrequent basis, of a toxic pollutant which is not limited in the pennit, if that discharge will exceed the highest of the "notification levels" specified in 122.42(a)(2)(i) through l22.42(a)(2)(iv).
17. TOXIC POLLUTANTS The pennittee shall comply with effluent standards or prohibitions established under Section 307 (a) of the Clean Water Act for toxic pollutants within the time provided in the regulations that establish these standards or prohibitions, even if the permit has not yet been modified to incorporate the requirement. Following establishment of such standards or prohibitions, the Director shall modify this pennit and so notiJY the permittee. 18. PERMIT MODIFICATION OR REVOCATION A. After notice and opportunity for a hearing, this pennit may be modified or revoked, by the Ohio EPA, in whole or in part during its tenn for cause including, but not limited to, the following: 1. Violation of any tenns or conditions of this pennit; 2. Obtaining this pennit by misrepresentation or failure to disclose fully all relevant facts; or

3. Change in any condition that requires either a temporary or permanent reduction or elimination of the
pennitted discharge. B. Pursuant to rule 3745-33-04, Ohio Administrative Code, tbe pennittee may at any time apply to the Ohio EPA for modification of any part of this pennit. The filing of a request by the pennittee for a permit modification or revocation does not stay any pctmit condition. The application for modification should be received by the appropriate Ohio EPA district office at least ninety days before the date on which it is desired that the modification become effective. The application shall be made only on fonns approved by the Ohio EPA.

000185

Part III General Conditions (Con't) 19. TRANSFER OF OWNERSHIP OR CONTROL

Page 18 31VOOOOO*ED

This pennit may be transferred or assigned and a new owner or successor can be authorized to discharge from this facility, provided the following requirements are met:
A. The permittee shall notify the succeeding owner or successor of the existence of this permit by a letter, a copy of which shall be forwarded to the appropriate Ohio EPA district office. The copy of that letter will serve as the permittee's notice to the Director of the proposed transfer. The copy of that letter shall be received by the appropriate Ohio EPA district office sixty (60) days prior to the proposed date of transfer; B. A written agreement containing a specific date for transfer of permit responsibility and coverage between the current and new pennittee (including acknowledgement that the existing permittee is liable for violations up to that date, and that the new permittee is liable for violations from that date on) shall be submitted to the appropriate Obio EPA district office within sixty days after receipt by the district office of the copy of the letter from the permittee to the succeeding owner; At anytime during the sixty (60) day period between notification of the proposed transfer and the effective date of the transfer, the Director may prevent the transfer ifhe concludes that such transfer will jeopardize compliance with the tenllS and conditions of the permit. If the Director does not prevent transfer, he will modify the pennit to reflect the new owner. 20. OIL AND HAZARDOUS SUBSTANCE LIABILITY Nothing in this permit shall be construed to preclude the institution of any legal action or relieve the permittee from any responsibilities, liabilities, or penalties to which the permittee is or may be subject under Section 311 of the Clean Water Act. 21. SOLIDS DISPOSAL Collected grit and screenings, and other solids other than sewage sludge, shall be disposed of in such a marmer as to prevent entry of those wastes into waters of the state, and in accordance with all applicable laws and rules. 22. CONSTRUCTION AFFECTING NAVIGABLE WATERS

This pennit does not authorize or approve the construction of any onshore or offshore physical structures or faeilities or the undertaking of any WOlX in any navigable waters.
23. CIVIL AND CRIMINAL LIABILITY Except as exempted in the pennit conditions on UNAUTHORIZED DISCHARGES or UPSETS, nothing in this pennit shall be construed to relieve the permittee from civil or criminal penalties for noncompliance. 24. STATE LAWS AND REGULAnONS Nothing in this permit shall be construed to preclude the institution of any legal action or relieve the permittee from any responsibilities, liabilities, or penalties established pursnant to any applicable state law or regulation under authority preserved by Section 510 of the Clean Water Act. 25. PROPERTY RIGHTS The issnance of this permit does not convey any property rights in either real or personal property, or any exclusive privileges, nor does it authorize any injury to private property or any invasion of personal rights, nor any infringement of federal, state, or local laws or regulations.

000186

Part III General Conditions (Con't) 26. UPSET

Page 19 3IVOOOOO*ED

The provisions of 40 CFR Section 122.4I(n), relating to "Upset," are specifically incorporated herein by reference in their entirety. For defmition of "upse~" see Part III, Paragraph I, DEFINITIONS. 27. SEVERABILITY The provisions of this permit are severable, and if any provision of this pennit, or the application of any provision of this permit to any circmnstance, is held invalid, the application of such provision to other circmnstances, and the remainder of this permit, shall not be affected thereby. 28. SIGNATORY REQUIREMENTS All applications suhmitted to the Director shall be signed and certified in accordance with the requirements of 40 CFR 122.22. All reports submitted to the Director shall be signed and certified in accordance with the requirements of 40 CFR Section 122.22. 29. OTHER INFORMATION

A. \¥here the permittee becomes aware that it failed to submit any relevant facts in a pelmit application or submitted incorrect information in a permit application or in any report to the Director, it shall promptly submit such facts or information.
B. ORC 6111.99 provides that any person who falsifies, tampers with, or knowingly renders inaccurate any monitoring device or method required to be maintained under this permit shall, upon conviction, be punished by a fine of not more than $25,000 pef violation. C. ORC 6111.99 states that any person who knowingly makes any false statement, representation, or certification in any record or other document submitted or required to be maintained under this peffi1it including monitoring reports or reports of compliance or noncompliance shall, upon conviction, be punished by a fme of not more than $25,000 per violation. D. ORC 6111.99 provides that any person who violates Sections 6111.04, 6111.042, 6111.05, or division (A) of Section 6111.07 of the Revised Code shall be fmed not more than $25,000 or imprisoned not more than one year, or both. 30. NEED TO HALT OR REDUCE ACTIVITY 40 CFR 122.41 (c) states that it shall not be a defense for a permittee in an enforcement action that it would have been necessary to halt or reduce the pennitted activity in order to maintain compliance with conditions of this permit. 31. APPLICABLE FEDERAL RULES All references to 40 CFR in this permit mean the version of40 CFR which is effective as of the effective date of this permit. 32. AVAILABILITY OF PUBLIC SEWERS Not withstanding the issuance or non-issuance of an NPDES pennit to a semi-public disposal system, whenever the sewage system of a publicly owned treattnent works becomes available and accessible, the permittee operating any semi-public disposal system shall abandon the semi-public disposal system and connect it into the publicly owned treattnent works.

000187

222 SOUTH MAIN STREET

AKRON, OH 44308

IID1BlQANDRESS II
A LEGAL PROFESSIONAL ASSOCIATION

, 330.849.6605 DIRECT 330.376.2700 MAIN 330.376.4577 FAX tfmn@ralaw.com

January 4, 2007 VIA FEDERAL EXPRESS

V Ohio Environmental Protection Agency
Attention: Division of Surface Water Permits and Compliance Section Lazarus Government Center 122 South Front Street Columbus, OH 43215 Ohio Environmental Protection Agency Northeast District Office Division of Surface Water 2110 East Aurora Road Twinsburg, Ohio 44087 Re:

AkyO'"

City of Akron's Comments to EPA's November 30,2006 Draft Permit OEPA Draft Permit No. 3IVOOOOO*ED Application No. OH0000612 Public Notice No. 06-12-034

~

Dear Sir or Madam: The following comments to the above-referenced draft NPDES permit, which was public-noticed by Ohio EPA on December 14, 2006 (the "Draft Permit") are being submitted on behalf of the City of Akron, Ohio ("Akron" or the "City"). As a preliminary matter, the City's failure to raise a specific objection shall not be viewed as a waiver of the objection. The City expressly reserves all rights to submit additional objections and comments. General Comments 1. The public comment period is currently only thirty (30) days. The City was not provided with an advanced copy of the Draft Permit prior to the public notice. The comment period currently provided for the City to review the Draft Permit and associated materials, study the issues, draft the comment letter and submit the same to

CLEVELAND

TOLEDO

AKRON

COLUMBUS

CINCINNATI

WASHINGTON, D.C.

TAUJ\HASSEE

ORU\NDO

FORT MyERS

NAPLES

www.ralaw.com

000188

Ohio EPA January 4, 2007 Page 2

the Ohio EPA is insufficient. Moreover, the City has submitted two public records requests to the Ohio EPA. Ohio EPA will not make the public records in the NEDO available to the City of Akron until January 12, 2006. While some records have been provided from the Central office, only the City's application and the draft permit have been made available to date. Thus, the City has not been provided with the opportunity to review all Ohio EPA's public records. As a result of all of the foregoing, the City submitted a request for a forty-five (45) day extension to the comment period. The City has not received a response to this request. Thus, the City again requests that the comment period be extended by forty-five (45) days. 2. Ohio EPA has violated Ohio procedures requiring that the agency issue a proposed permit which would then allow for an adjudication hearing prior to issuance of the fina I permit. 3. Ohio EPA has unlawfully and unreasonably failed to consider technical feasibility, economic reasonableness and expected benefits in issuing this permit as required by Ohio R.C. Section 6111.03(J). It is unlawful and unreasonable for Ohio EPA to impose schedules of compliance for various permit limitations and activities, including studies, which are technically infeasible or economically unreasonable to meet or which fail to take account of reasonable periods for study or construction. 4. Certain provisions within the Draft Permit refer to possible, subsequent modification, revision and/or revocation. For example, see Part II.B. The Ohio EPA's authority to take such an action is limited by its own procedural rules. As a result, the Draft Permit should expressly provide that any such action will only be taken in accordance with Ohio EPA's rules. I.

Part I, B.
1. Downstream-Nearfield Monitoring Requirements at Station Number 31V00000902

The City objects to the monitoring requirements and limitations for Station Number 31V00000902 ("902"). First of all, Ohio EPA is improperly incorporating a Portage County, Ohio Court of Common Pleas involving a riparian dispute into the NPDES permit. See Portage Cty. Bd. of Commrs. v. Akron, (Portage County Common Pleas Case No. 98 CV 0325, September 26, 2006). This case involves a riparian rights dispute between private parties. Ohio EPA was not a party to the that case and is not a riparian owner. Thus,

1394084 Y _02 \ 016756.0006

000189

Ohio EPA January 4, 2007 Page 3

the court decision does not provide Ohio EPA with any rights to regulate the flow at Station Number 902. In addition to the foregoing, Ohio EPA does not have legal authority to regulate the flow at Station Number 902 pursuant to an NPDES permit. In 2004, the u.s. Supreme Court issued a decision that prevents Ohio EPA's ability to take such an action. Specifically, in South Florida Water Management District v. Miccosukee Tribe of Indians, 541 U.S. 95 (2004), the U.S. Supreme Court ruled on the applicability of the NPDES permit requirements to discharges from one water body to the same water body. The U.S. Supreme Court affirmed the accepted view that if two identified volumes of water are "simply two parts of the same water body, pumping water from one into the other cannot constitute an 'addition' of pollutants," Id. at 109; Moreover, water bodies that are not meaningfully distinct water bodies will not require and NPDES permit, Id at 112. See also Catskill Mountains Chapter of Trout Unlimited, Inc. v. City of New York, 273 F.3d 481 (2d Cir. 2001) ("[I]f one takes a ladle of soup from a poLand pours it back into the pot, one has not 'added' soup or anything else to the pot"). Station Number 902 is a fictitious station reporting the calculated total of water released from the dam at Lake Rockwell. The release represents a discharge from one part of the Cuyahoga River to another part of the Cuyahoga River (i.e. a discharge between two parts of the same water body). This release is not subject to the NPDES permit requirements. Contrary to the holding in Miccosukee, the Draft Permit is attempting to regulate a discharge from one water body into the same water body. As a result, the monitoring requirements and limitations at Station Number 902 should be removed from the Draft Permit. 2. Upstream Monitoring Requirements at Station Number 31V00000801 and Downstream-Nearfield Monitoring Requirements at Station Number 31V00000901

The City objects to the monitoring requirements and limitations for Station Number 31V00000801 ("801") and Station Number 31V00000901 ("901"). The City incorporates by reference its comments and objections to Part I, B above. As a result, the monitoring requirements and limitations at Station Numbers 801 and 901 should be removed from the permit.
II.

Part II, Other Requirements

1. Section G. The City does not object to performing an evaluation on the adequacy and implementation of its sludge management plan; however, the City requests that it be provide with 12 months to complete this evaluation, opposed to 6

1394084 v _o2 \ 016756.0006

000190

Ohio EPA January 4, 2007 Page 4

months. In addition, the City is not aware of a change in the regulatory status of alum sludge and, thus, objects to the requirement to perform this additional analysis as part the overall evaluation. 2. Section H. The City objects to Section H. The City incorporates by reference its comments and objections to Part I, B above. As a result, this section should be deleted. 3. Section I. The Ohio EPA does not have the authority to require a reservoir management plan. The City incorporates by reference the City's comments to Part I, B above. As a result, this section should be deleted. Thank you for your consideration of the foregoing comments and objections to the Draft Permit. The City would like the opportunity to meet with Ohio EPA to discuss these comments and objections. In the meantime, if you have any questions or need anything further, please do not hesitate to contact me. Sincerely,

RO~~& ANDRES~A
~,_.../'------pi /

""

~
In '

Terrence S. TSF/sju

~
/. I

.I

,

~

1394084 v _o2 \ 016756,0006

000191

State of Ohio Environmental Protection Agency

~~ODR~~~,,:,,_,,_,
Lazarus Government Center 122 S. Front Street Columbus, Ohio 43215

".. ~_

TELE: (614) 644-3020 FAX: (614) 644-3184 www.epa.state.oh.us

------

~,.AJL.!NG ADDRESS:

January 5, 2007

P.O. Box 1049 Columbus, OH 43216-1049

Re: Akron Public Utilities Bureau Akron WTP 1570 Ravenna Road Kent OH 44240 Ladies and Gentlemen:

Ohio EPA Permit No. 31VOOOOO*ED Facility Name: Akron WTP

Enclosed is a copy of the Public Notice referenced above regarding a draft National Pollutant Discharge Elimination System (NPDESj permit 3IVOOOOO*ED issued to Akron WTP, Kent, Ohio. This notice is being provided to persons on the Ohio EPA Portage County Mailing list, and certain public officials and the regulated entity. The purpose of this notice is to provide a 45 day extension of the comment period of notice OEPA-06-12-034. Interested persons are invited to submit written comments on the draft permit. Comments should be submitted in person or by mail to: Ohio Environmental Protection Agency Permits Section P.O. Box 1049 122 South Front Street Columbus,OH 43216-1049

....

,~

('
i

i--" J

\ ,)

I
Palli L Smith, Supervisor Permit Processing Unit Division of Surface Water PLSfdks

CERTIFIED MAil

.
IlII Complete items 1, 2, and 3. Also ~omplete item 4 if Restricted Delivery is deSIred. II!I Print your name and address on the reverse so that we can return the card to you.. . III; Attach this card to the back ?f the mallpl6ce, or on the front if space permIts.
1. ,",-,.

.

• • •

o Agent o Addressee
B. Re d by ( Printed Name)
C. Date 01 Delivery

/ 4!'If YES, enter delivery address below:

I'

/F/ 1'0.7

~~~gN PUBLIC UTILITIES BUREAU
AKRONWTP 1570 f1AVENNA RD KENT'OH 44240

~~iVOO~OO'ED

. D. Is delivery address dIfferent from "" m1? DYes Ice 0 No

01:05:07 (PNEXT)

3. Service Type Certified Man

o o Registered

D

o Express Mail
0 C.O.D.

.

Return Receipt for MerchandISe

D insured Mall

*

4. Restricted Delivery? (Extro Fee)
Pn'nledonRecycledPeper

DYos

2.~ 7006 0810 0003 510b 5088 (Tow.,.".. ." •• , Domestic Return Receipt PS Form 3811, February 2004

102595-02-M~1540

000192

Portage County

PUBLIC NOTICE EXTENSION OF PUBLIC COMMENT PERIOD Notice is hereby given that the Ohio Environmental Protection Agency has extended the public comment period on a draft NPDES permit 3IVOOOOO*ED, issued to the Akron WTP, located at 1570 Ravenna Road, Kent, Ohio. The public comment period for public notice OEPA-06-12-034 issued December 14, 2006 is hereby extended 45 days, and will expire February 27, 2007. Interested persons are invited to submit written comments on the discharge permit. Comments should be submitted in person or by mail to: Ohio Environmental Protection Agency Permits Section P. O. Box 1049 122 South Front Street Columbus, OH 43216-1049 The OEPA permit number (3IVOOOOO*ED) and public notice number (OEPA-06-12-034) should appear next to the above address on the envelope and on each page of any submitted comments. All comments received by the close of business, February 27, 2007 wili be considered for the final permit. Except for the date by which public comment must be received, all other provisions of the prior notice remain applicable.

000193

222 SOU"J"H M,\JN STREET
AKHON,

OH 44308

Im:DfAII&)ANDRESS II
A LEGAL PROfESSIONAL ASSOCiATION

330.8496605 DIRECT 330.376.2700 M."N 3303764577 FAX tfinn@ralaw,com

December 22, 2006 Mr. Paul Novak Manager, Permits Programs Ohio Environmental Protection Agency Division of Surface Water 122 S. Front Street Columbus, OH 43215 Re: City of Akron's Extension Request OEPA Draft Permit No. 3IVOOOOO*ED Application No. OH0000612

I

Dear Sir or Madam: On behalf of the City of Akron ("City"), we request a sixty (60) day extension of the comment period for the above-referenced draft Ohio EPA Permit No. 3IVOOOOO'ED (the "Draft Permit"). The Draft Permit is for the City's water treatment works located at 1570 Ravenna Road, Kent, Ohio, Portage County. The public comment period is currently scheduled to expire on January 5, 2006. The public comment period is currently only thirty (30) days. In this case, the City was not previously provided an advanced copy of the Draft Permit prior to the public notice. The thirty (30) day comment period provided for the City to review the Draft PenT1it and associated 1l1ateriais, retain consultants, study the issues, dratt the comment letter and submit the same to the agency is insufficient. Moreover, the City has not had enough time to review Ohio EPA's records. As a result of the foregoing, the City requests that the comment period be extended by forty-five (45) days. Thank you for your consideration of the foregoing request. If you have any questions or need anything further, please do not hesitate to contact me.

CLEVELAND TOLEDO AKRON 1393812 v_Ol \ 016756.0006

COLUMBUS

CINCL"iNATJ

WASHINGTON, D.C.

TALLAHASSEE

ORLANDO

FORT MYERS

NAPLES

www_rala\v.com

000194

Ohio EPA December 22, 2006 Page 2 Sincerely, ROETZEL & ANDRESS, LPA

··(J!)v\(L,y~ll ,S -=t01U\_JQ~
Terrence S. Finn TSF/sju

1393812 v_OJ \016756,0006

000195

State of Ohio Environmental Protection Agency
STREET ADDRESS:

MAILING ADDRESS:

Lazarus Government Center 122 S. Front Street Columbus, Ohio 43215

TELE: (614) 644-3020 FAX: (614) 644-3184 www.epa.state.oh.us

P.O. Box 1049

Columbus, OH

43216~1049

December 07, 2006 RE: Ohio EPA Permit No.: 3IVOOOOO*ED Facility Name: Akron City WTP

Akron Public Utilities Bureau 1570 Ravenna Road Kent, OH 44240 Ladies and Gentlemen: Transmitted herewith is one copy of the public notice, draft permit, and fact sheet if major permit in the above referenced matter. The public has been invited to submit comments regarding this draft permit. If sufficient pUblic interest is indicated, a public meeting will be held. The permit as drafted will be issued as a final action unless the director revises the permit after consideration of all written comments received during the 30-day period following pUblic notice and consideration of the record of a public meeting, if one is held, or unless the draft is disapproved by the Regional Administrator, U.S. Environmental Protection Agency. You should note that a general condition of your permit states that issuance of a NPDES permit does not relieve you of the dUty of complying with all applicable federal, state, and local laws, ordinances, and regulations.
(

Patti L. Smith, Supervisor Permit Processing Unit Division of Water Pollution Cc PLS/dks Enclosure CERTIFIED MAIL

III Complete items 1, 2, and 3. Also complete item 4 if Restricted Delivery is desired. iii Print your name apq address on the reverse so that we can return the card to you. iii Attach this card to the back of the mailpiece, or on the front if space permits.

o Agent o Addressee
\ IV by ( Printed Name)

.

L

s.'
DYes

1.

NPOES 3IVOOOOO'EO 12:07:06 (0) AKRON PUBLIC UTILITIES BUREAU 1570 RAVENNA RO KENT oH 44240

D. Is delivery address different from item 1? If YES, enter delivery address below:

o No

3. Service Type

o Certified Mal! o Registered o Insured Mall

0 Express Mall 0 Return Receipt for Merchan,dise

0 C.O.D.
0 Yes

4. Restrtcted Delivery? (Extra Fee)

2

7006 2150 0004 6633 7413
3811,
February 2004
Domestic Return Receipt
102595..Q2-M-154C

@

Printed on Recycled Paper

PS Form

000196

State of Ohio Environmental Protection Agency
STREET AD.DRESS: . _

Lazarus Government Center 122 S. Front Street Columbus, Ohio 43215

TELE: (614) 644-3020 FAX: (614) 644~3184 www.epa.stale.oh.us

P.O. Box 1049 Columbus, OH 43216-1049

December 07, 2006 Mayor and Council City of Kent 217 East Summit Street Kent, Oh 44240 Ladies and Gentlemen:

Re: Public Notice No.: 06-12-034

Enclosed is one copy of the Public Notice referenced above regarding National Pollutant Discharge Elimination System (NPDES) permits or modifications. This notice is being advertised in a newspaper of general circulation in the county, and is being provided to certain public officials and the regulated entity. In order to provide further public notice, we will appreciate your assistance in posting this notice in a conspicuous location for a thirty-day period starting on the date of Public Notice. Thank you for your cooperation in this matter.

~inCereIY,

\l

c.J.T~ eX.

. '1

Patti L. Smith, Supervisor Permit Processing Unit Division of Surface Water PLS/dks Enclosure

*

Bob Taft, Governor Bruce Johnson, Lieutenant Governor Joseph P. Koncelik, Director"
Printed on Recycled Paper

Ohio EPA is an Equal Opportunity Employer

000197

67/NE

Application No.: OH0000612 Ohio EPA Permit No.: 3IVOOOOO-ED

National Pollutant Discharge Elimination System (NPDES) Permit Program PUBLIC NOTICE
NPDES Permit to Discharge to State Waters Ohio Environmental Protection Agency Permits Section 122 South Front Street P. O. Box 1049 Columbus, Ohio 43216-1049 (614) 644-2001 Public Notice No. Date of Issue of Public Notice: Name and Address of Applicant: OEPA 6-12-034 Dec-14-2006 Akron Public Utilities Bureau, 1570 Ravenna Road, Kent, OH 44240

Name and Address of Facility Where Discharge Occurs: Outfall Flow and Location List:

Akron City WTP, 1570 Ravenna Road, Kent, Portage County 001 002 780000 gpd 780000 gpd 41N 11' 00" 41 N 12' 00" 81W 20' 00" 82W 20' 00"

Receiving Stream: Nature of Business: Key parameters to be limited in the permit are as follows:

Twin Lakes Outlet to Cuya Drinking Water Treatment Plant

pH, Total Suspended Solids

On the basis of preliminary staff review and application of standards and regulations, the director of the Ohio Environmental Protection Agency will issue a permit for the discharge subject to certain effluent conditions and special conditions. The draft permit will be issued as a final action unless the director revises the draft after consideration of the record of a public meeting or written comments, or upon disapproval by the administrator of the U.S. Environmental Protection Agency. Any person may submit written comments on the draft permit and administrative record and may request a public hearing. A request for public hearing shall be in writing and shall state the nature of the issues to be raised. In appropriate cases, including cases where there is significant public interest, the director may hold a public hearing on a draft permit or permits prior to final issuance of the permit or permits. Following final action by the director, any aggrieved party has the right to appeal to the Environmental Review Appeals Commission.

000198

67/NE

Application No.: OH0000612 Ohio EPA Permit No.: 3IVOOOOO'ED

Interested persons are invited to submit written comments upon the discharge permi!. Comments should be submitted in person or by mail no later than 30 days after the date of this public notice. Comments should be delivered or mailed to both of the following locations: 1) Ohio Environmental Protection Agency, Lazarus Government Center, Division of Surface Water, Permits Processing Unit, 122 South Front Street, P.O. Box 1049, Columbus, Ohio 43216-1049 and 2) Ohio Environmental Protection Agency, Northeast District Office 2110 East Aurora Road, Twinsburg, Ohio 44087. The Ohio EPA permit number and public notice numbers should appear next to the above address on the envelope and on each page of any submitted comments. All comments received no later than 30 days after the date of this public notice will be considered. The application, fact sheets, permit including effluent limitations, special conditions, comments received, and other documents are available for inspection and may be copied at a cost of 5 cents per page at the Ohio Environmental Protection Agency at the address shown on page one of this public notice any time between the hours of 8 a.m. and 4:30 p.m., Monday through Friday. Copies of the public notice are available at no charge at the same address. Mailing lists are maintained for persons or groups who desire to receive pUblic notice for all applications in the state or for certain geographical areas. Persons or groups may also request copies of fact sheets, applications, or other documents pertaining to specific applications. Persons or groups may have their names put on such a list by making a written request to the agency at the address shown above.

000199

Randall A. Monteith, P.E. Pilots Administrator Andre L. Blaylock Business Services Administrator

Brian M. Gresser, P.E. Water Pollution Control Administrator James L. Six, P.E. Water Supply Administrator

DONALD L. PLUSQUELLIC
Mayor Gerald Holland, Director DEPARTMENT OF PUBLIC SERVICE Michael L. McGlinchy, P.E. PUBLIC UTILITIES BUREAU MANAGER

October 27, 2006 Ms. Lily Aaron Ohio EPA - Northeast District Office 2110 East Aurora Road Twinsburg,OH 44087-1969

RE:

Akron Water Supply Plant NPDES Permit #3IVOOOOO Outfall Numbers 001 & 002

Dear Ms. Aaron: Enclosed for processing is all necessary documentation for renewal of the City of Akron Water Supply Plant's National Pollutant Discharge Elimination System Permit. This application no longer includes the previously permitted Outfall Number 003 because of its elimination as part of a recent construction improvement. This application does include Filter Washwater Lagoon Outfall Numbers 001 and 002. If you have any additional questions regarding this application, please contact Jim Six, PE. in the Akron Water Supply Division at (330) 678-0077. Sincerely,

·)~P
MLM/JJB:mb

J

nv4{~c~~

/

/

Michael L. McGlinchy, P.E. Public Utilities Bureau Manager

c: J. Six,

R. Fiasco, J. Bronowski, G. Bozeka

Enclosure: 1
146 S. High Street. Room 900. Akron, Ohio 44309. (330) 375-2627 • FAX (330) 375-2072 www.cLakron.oh.us

000200

Please type, Do not complete by hand.
FORM
U.S, ENVIRONMENTAL PROTECTION AGENCY

GENERAL
LABEL ITEMS

1

EPA

GENERAL INFORMATION
Consolidated Permits Program (Read Ihe "Gelleral !Mlme/iolls" before ,-/ar/ing)

l. EPA LD. NUMBER

3IVOOOOO'DD
1I a preprinted label has been provided, affix it in the designated space. Review the information carefully; if any of it is incorrect, cross through it and enter the correct data in the appropriafe fill-in below. Also, if any of the preprinted data is absent (the area to the

l. EPA 1.0. NUMBER
Ill. FACILITY NAME V. FACiLITY
MAILING ADDRESS

-:Sh£'l;--

.sFs,,"
VI. FACILITY
LOCATiON

#
-f1: gnr,[';dAg1:1

left of the label space lists the information that should appear), please prOVide lt in the proper filHn area(s) below. If the label is complete and correct, you need not complete Items I, 1II, V. and VI (except VI-B which must be completed regardless). Complete all
items if no label has been provided. Refer to the instructions for detailed item descrip· lions and for the legal authorizations under which this data is collected.

II. POLLUTANT CH'ARACTERISTICS

INSTRUCTIONS: Complete A through G to determine whether you need to submit any permit application forms to the EPA. If you answer "yes" to any questions, you must submit this form and the supplemental form listed in the parenthesis following the question. Mark "X~ in the box in the third column .if the supplemental form is attached. If you answer "no~ to each question, you need not submit any of these forms. You may answer "no" if your activity is excluded from permit requkements; see Section C of the instructions. See also, Section 0 of the instructions for definitions of bold~faced terms.
SPECIFIC QUESTIONS
MARK ·x'
f"ORM

SPECIFIC QUESTIONS
YES

MARK 'X'
NO FORM

A. Is this facility a
(FORM2A)

pUblicly owned treatment works which results in a discharge to waters of the U.S.?

'"

'0

X X X X X

B. Does or will this facility (either existing or proposed) include a concentrated animal feeding operation or aquatic animal production facility which results in a discharge to waters of the U.S,? (FORM 28)

X
X X

C. Is this a facility which currently resufts in discharges to waters of the U.S. other than those described in A or B above? (FORM 2C)

D. Is this a proposed facility (other than those described in
A or B above)which wili result in a discharge to waters of the U.S.? (FORM 20)

E. Is this a facility which does not discharge process wastewater? (FORM 2E)

F. Is this a facility which discharges stormwater associated with industrial activity? (FORM 2F)

G. Do you generate sewage sludge that is ultimately regulated by Part 503? Do you generate sewage sludge that is sent to another facility for treatment or blending? Do you process or dedve material from sewage sludge that is disposed in a manner sub'ect to Part 503? FORM 2S

REC'D NOV 0 7 2006

III. NAME OF FACILITY

IV, FACILITY CONTACT

SIX, JIM,
V, FACILITY MAILING ADDRESS

1570 RAVENNA ROAD KENT
VI. FACILITY LOCATION

1570 RAVENNA ROAD
a. COUNT'{ NMAE

PORTAGE COUNTY
c. crT" OR TOWN
D.STATE

E, ZIP COOE

F.

cq, ~;;;r,,, ODE

KENT

OH

44240-6111

EPA Form

3510~1 (Rev. for Ohio

EP

AM'''f a-rr-fB--. DATE

IQ-Ql~

Click to clear all entered inform ion (on both pages of this form)

1
\

-!

I UE

. REVERSE

'CK #Ao~ltol'tJ DATE fo-I3-D\P

Oti!9.-!§P~~J

OCT 3 1 2006~'. ~~
000201

FLi="iR1

CONTINUED FROM THE FRONT VII. SIC CODES
(specify)

(4.-digit, in order of pn'ority)
A, FIRST

3589
(specify)

VIII. OPERATOR INFORMATiON

B.ls the name listed In
Item VIII-A also the owner?

I2SJYOS DNo
C, STATUS OF OPERATOR

o. PHONE
M '" PUBLIC (other IJzanfederal or slate) 0", OTHER (specify)
(specify)

{are""cde &: "".J

F = FEDERAL

S "" STATE
P""PRIVATE
E, SmEET OR P.O. BOX

M

(330) 678 - 0077

1570 RAVENNA ROAD
F. CITY OR TOWN
G.STATE H.ZlP CODE

IX. INDIAN LAND Is this facility located on Indian lands?

KENT

OH

44240-6111

DYes I2SJNo

x. EXISTING ENVIRONMENTAL PERMITS
A. NPDES (Discharges 10 surfoce water)

3IVOOOOO*DD
B. WG
(Underground injection offluids)

E. OTHER (specify)
(specify)

C. RCRA (Hawrd,ms WIlSie)

F, OTHER (specify)

XI. MAP

XII. NATURE OF BUSINESS (provide a brief description)

DRINKING WATER TREATMENT PLANT

XIII. CERTIRCATION

(see instructions)

I certify under penatly of law that I have personally examined and am famimliar with the information submitted in this application and all attachments and that, based on my inquiry of those persons immediately responsible for obtaining the information contained in the application, I belive that the information is true, accurate, and complete. I am aware that there are significant penalties for SUbmitting false information, including the possibility of fine and imprisonment.
A, NAME & OFFICIAL TITLE (/)'pc or print)

B. SIGNATURE

C. DATE SIGNED

MICHAEL L. McGLlNCHY
COMMENTS FOR OFACIAL USE ONLY

EPA Form 351()..1 (Rev. for Ohio EPA use 2/06)

000202

000203

Lake I Rockwell

141.05) MOD

Chemical Oxidation

Coagulation

Flocculation

Sedimentation

Rapid ~and FIltratiOn

Ir=~"
"

Chlorine Disinfection

~
Alternate

Finished Product (40 MGD)

0.05 MGD

~

1MGD

001 MGD

Schematic of Estimated WaterFlow Akron Water Supply Plant Kent, Portage, Ohio

Sludge Lagoons

Package Wastewater Plant

Drying Beds

I

I

OutfallS 001 & 002 1MGD

001 MGD

Twin Lakes Outlet to Cuyahoga River

Drainage Field

000204

EPA 1.0. NUMBER (copy from lIem I ofForll! 1)
Please print or type in the unshaded areas only.

Form Approved,

I

3IVOOOOO

I
Consolidated Pennits Program

OMS No. 2040-0086. Approval expires 3-31-98.

FORM

2C
NPDES

aEPA
a.LATITUDE
1 DEG 2.MIN

U.S. ENVIRONMENTAL PROTECTION AGENCY APPUCATION FOR PERMIT TO DISCHARGE WASTEWATER

EXISTING MANUFACTURING, COMMERCIAL, MINING AND SILVICULTURE OPERATIONS

I. OUTFALL LOCATION

For each outfall, list the latitude and longitude of its location 10 the nearesl15 seconds and the name of the receiving waterA. OUTFALL NUMBER (list)

C. LONGITUDE
3. SEC

1 DEG

2. MIN.

3. SEC

D. RECEIVING WATER (name)

001 002

41 41

11

00 00

81 81

20 20

00 TWIN LAKES OUTLET TO CUYAHOGA RIVER 00 TWIN LAKES OUTLET TO CUYAHOGA RIVER

12

II. FLOWS, SOURCES OF POLLUTION, AND TREATMENT TECHNOLOGIES
A. Attach a line drawing showing the water flow through the facility. Indicate sources of intake water, operations contributing wastewater to the effluent, and treatment units labeled to correspond to the more detailed descriptions in Item 8. Construct a water balance on the line drawing by showing average flows between intakes, operations, treatment units, and outfatls. If a water balance cannot be determined (e.g., for cerlain mining activities), provide a pictorial description of the nature and amount of any sources of water and any collection or treatment measures.

B. For each outfall, provide a description of: (1) All operations contributing wastewater to the effluent, inclUding process wastewater, sanitary wastewater, cooling water,
and storm water runoff; (2) The average flow contributed by each operation; and (3) The treatment received by the wastewater. Continue on additional sheets if necessary. 1. OUTFALL NO. (lisl) 2. OPERATION(S) CONTRIBUTING FLOW a. OPERATION (fist)
FILTER WASHWATER

3. TREATMENT a. DESCRIPTION
SEDIMENTATION RAPID SAND FILTRJl.TION SLUDGE LAGOONS

b. AVERAGE FLOW (include units)
.7B MGD

b. LIST CODES FROM TABLE 2C-1
H

001

H

5 -T

002

FILTER WASHWATER

.78 MGD

SEDIMENTATl"ON RAPID SAND FILTRATION SL'lrDGE LAGOONS

'-0
H

5 -T

OFFICIAL USE ONLY (effluent guidelines SlJb-Calegories)

EPA Form 3510-2C (8-90)

PAGE1of4

CONTINUE ON REVERSE

000205

CONTINUED FROM THE FRONT C. Except for storm runoff, leaks, or spills, are any of the discharges described in Items II-A or B intermittent or seasonal?

[;lI

YES (complete theJorrowing table)

D NO (go 10 SectionlI!)
b, MONTHS

3, FREQUENCY

4. FLOW

a.
1, OUTFALL NUMBER (llsl) 2.0PERATION(s) CONTRIBUTING FLOW (lIst)

I

DAYS PER WEEK (specify average)

a. FLOW RATE (Inmgd)
LONG TERM AVERAGE

B. TOTAL VOLUME (specifY wilh unils)

PER YEAR
(specify ""erage)

2. MAXIMUM
DAILY

1. LONG TERM AVERAGE

2. MAXIMUM C. DURATION
DAILY

(in days)

001 & 002

note: DURING AN EMERGENCY IF SLUDGE
FROM THE PL~~T CAN NOT BE PUMPED TO THE UPPER DRYING BASINS, ABOUT 50,000 GPD EXTRA COULD BE DISCHARGED FROM OUTFALLS 001 AND 002

o

o

o

111. PRODUCTION
A. Does an effluent gUideline limitation promulgated by EPA under Section 304 of the Clean Water Act apply to your facility?

D YES (complete Item lll-B)

lZ] NO (go to Section IV)

B. Are the limitations in the applicable effluent guideline expressed in terms of production (or other measure of operation)?

o

YES (complete Item lll-C)

IZl NO (go to Section IV)

C. If you answered "yes" to Item IIl-B, Itst the quantity which represents an actual measurement of your level of production, expressed in the terms and units used in the applicable effluent guideline, and indicate the affected outfalls. 1. AVERAGE DAILY PRODUCTION c. OPERATION, PRODUCT, MATERIAL, ETC. (specify)

2. AFFECTED OUTFALLS
(list outfafl numbers)

a, QUANTITY PER DAY

b. UNITS OF MEASURE

IV. IMPROVEMENTS A. Are you now required by any Federal, State or local authority to meet any implementation schedule for the construction, upgrading or operations of wastewater treatment equipment or practices or any other environmental programs which may affect the discharges described in this application? This includes, but is not limited to, permit conditions, administrative or enforcement orders, enforcement compliance schedule letters, stipulations, court orders, and grant or loan conditions.

o

YES (complete fheJol/owing table)
2. AFFECTED OUTFALLS a. NO.
b. SOURCE OF DISCHARGE

{ZI NO (go 10 lIem lV-B)
3. BRIEF DESCRIPTION OF PROJECT 4. FINAL COMPLIANCE DATE a. REQUIRED
b, PROJECTED

1. IDENTIFICATION OF CONDITION, AGREEMENT, ETC,

B. OPTIONAL: You may attach additional sheets describing any additional water pollution control programs (or other environmental projects which may affect your discharges) you now have underway or which you plan, Indicate whether each program is now underway or planned, and indicate your actual or planned schedules for construction.

o

MARK "X" IF DESCRIPTION OF ADDITIONAL CONTROL PROGRAMS IS ATTACHED PAGE2of4 CONTINUE ON PAGE 3

EPA Form 3510-2C (8-90)

000206

EPA 1.0. NUMBER (copy from Item} afForm 1)
CONTINUED FROM PAGE 2 V. INTAKE AND EFFLUENT CHARACTERiSTICS A, 8, & C: See instructions before proceeding - Complete one set of tables for each outfall - Annotate the oulfall number in the space provided. NOTE: Tables V-A, V·B, and V-C are included on separate sheets numbered V-1lhrough V-g. D. Use the space below to list any of the pollutants listed in Table 2c-3 of the instructions, which you know or have reason to believe is discharged or may be discharged from any outfall. For every pollutant you list, briefly describe the reasons you believe it to be present and report any anaiytical data in your possession,

1. POLLUTANT
N/A

2, SOURCE

1. POLLUTANT

2. SOURCE

VI. POTENTlAL DlSCHARGES NOT COVERED BY ANALYSIS Is any pollulantlisted in !tern V-C a substance or a component of a substance which you currently use or manufacture as an intermediate or final product or byproduct?

o

YES (list aJl such pollUlanl$ below)

0

NO (go 10 Item VI-B)

EPA Form 3510-2C (8-90)

PAGE 3 of4

CONTINUE ON REVERSE

000207

CONTINUED FROM THE FRONT VB. BIOLOGICAL TOXICITY TESTING DATA

Do you have any knowledge or reason to believe that any biological test for acute or chronic toxicity has been made on any of your.discharges or on a receiving water in relation to your discharge within the last 3 years?
DYES (idenlify the test(s) and describe their purposes below)

[Z] NO (go to Section VII!)

Vlll. CONTRACT ANALYSIS INFORMATION
Were any of the analyses reported in Item V performed by a contract laboratory or consulting firm?

DYES (lisl the name, address, and telephone number of, and pollutants ana/yud by,
each sllch laboratory or firm below)
A. NAME

1ZI NO (go

10

SecNon LX)

B. ADDRESS

C. TELEPHONE
(area code & no,)

D. POLLUTANTS ANALYZED
(fist)

IX. CERTIFICATION

f certify under penalty of law that this document and all attachments were prepared under my direction or supetvision in accordance with a system designed to assure that qualified personne' properly gather and evaluate (he information submitted. Based on my inquiry of the person or persons who manage the system or those persons directly responsible for gathering the infonnation, the information submitted is, to the best of my knowledge and belief, true, accurate, and complete. f am aware that there are significant penalties for submitting false information, including the possibility of fine and imprisonment for knowing violations:
A. NAME & OFFICIAL TITLE (type or prinl)

B. PHONE NO. (area code & no.) (DO) 375-2627

MICHAEL,L. McGLINCHY

D. DATE SIG~D

(,,,, /
EPA Form 3510-2C (8-90)

~~

0

b

PAGE4of4

000208

~-_

... _,. ,-- ..

~,

.~.

V. INTAKE AND EFFLUENT CHARACTERISTICS (continued from page 3 ofFonn 2-C)

PART A -You must provide the results of alleast one analysis for every pollutant in this table. Complete one table for each outfall. See instructions for additional details.

~
OHOOOO612
3, UNITS (specifj'ifbfonk)

OUTFALL NO.

,0>

2. EFFLUENT
a. MAXIMUM DAILY VALUE
1. POLLUTANT
(') CONCENTRATION

b. MAXIMUM 30 DAY VALUE (ifavoiloble)
(')
CONCENTRATION {2) MASS

c. LONG TERM AVRG. VALUE
(ijal'oifable)
(1) CONCENTRATION (2) MASS

d. NO. OF
ANALYSES

a. CONCENTRATlON
b. MASS

4. INTAKE (oplionor) a. LONG TERM AVERAGE VALUE
(')
(2) MASS

(2) MASS

CONCENTRATION

b. NO. OF ANALYSES

a. Biochemical Oxygen Demand (BOD)
b. Chemical Oxygen Demand (COD) c, Total Organic Carbon

2.11 mg/l
19.7 mg/l

(TOC)
d. Total Suspended Solids (TSS) e. Ammonia (a5 N)

6.36 mg/l
11
.018 mg/l
VALUE VALUE VALUE

f. Flow

0-1.S MGD

VALUE VALUE VALUE MINIMUM

VALUE VALUE VALUE MAXIMUM

VALUE VALUE "C VALUE "C
$TANDARD UNITS

g. Temperature
(winter)

0-15 deg eel.

h. Temperature (summer)
i. pH PARTS

15-30 deg eel.
MAXIMUM

MINIMUM

6.73

7.83

Mark. "X" in column 2-a for each pollutant you know or have reason to beHeve is present. Mark ·X" in column 2-b for each pollutant you believe to be absent. If you mafi< column 2a for any pollutant which is limited either directly, or indirectly but expressly, in an effluent limitations guideline, you must provide the results of at least one analysis for that pollutant For other pollutants for which you mark column 2a, you must provide quantitative data or an explanation of their presence in your discharge. Complete one table for each outfall. See the instructions for additional details and requirements. 2, MARK "X" 5, INTAKE (optionar) 3,EFFLUENT 4. UNITS 1. POLLUTANT a. LONG TERM AVERAGE b. MAXIMUM 30 DAY VALUE c. LONG TERM AVRG. VALUE AND a. MAXIMUM DAILY VALUE (ifowlirable) (ifavaif(1bfe) VALUE b CAS NO. b. NO. OF d. NO. OF a. CONCENBELIEVED BEUEVED (1) (') (') (') (i/al'ailable) PRESENT ABSENT ANALYSES ANALYSES b. MASS CONCENTRATION TRATION (2) MASS CONCENTRATION {2) MASS (2) MASS CONCENTRATION (2) MASS CONCENTRATION

,

a. Bromide (24959-67-9)
b. Chlorine. Tolal Residual

I

c. Color
d. Fecal Coliform

X X X

e. Fluoride (16984-48-8)
f. Nitrale--Nilrite (as N)

X X X
PAGE V-1 CONTINUE ON REVERSE

EPA Form 351Q-2C (8-90)

000209

I j t:JVI V·l:I LUN IINUt::U '"'HUM ,",HUN I

2. MARK "X"
1. POLLUTANT

AND
CAS NO.

,
PRESENT

BEUEVED BELIEVED

(jIm'ai/able)
g. Nitrogen, Total Organic (a.I' N) h. Oil and Grease

" ABSENT

a.

MAXIMUM DAILY VALUE
(1)
(2) MASS

3. EFFLUENT b. MAXIMUM 30 DAY VALUE (i[availabfe)
(1)

4. UNITS

5. INTAKE (oplionol)
LONG TERM AVERAGE VALUE

c.

LONG TERM AVRG. VALUE

a.

(ijal'aifable)
(1' CONCENTRATION

CONCENTRATION

CONCENTRATION

{2) MASS

(2) MASS

d. NO. OF ANALYSES

a.

CONCENTRAT10N

b. MASS

(1)

CONCENTRATION

{2) MASS

b. NO. OF ANALYSES

X
X

i. Phosphorus (as P), Total (7723-14-0)
j. Radioactivity

X
X X X X X X X X X X X X X X X X X X
PAGE V~2 CONTINUE ON PAGE V-3

(1) Alplla, Tala! (2) Bela, Tolal
(3) Radium, Total

(4) Radium 226. Total
k. SUlfate (ro-SO;)

(14BOB-79-B)
L Sulfide

(a.y

~1

m. Sulfite
(05.'10)) (14265-45-3)
n. Surfaclants o. Aluminum, Total

(7429-90-5)

p. Barium, Tolal (7440-39-3)
q. Boron, Total (7440-42-8)
f.

Cobalt, Total

(7440-48-4)

s. Iron, Total
(7439-89-6)
t Magnesium, Total

(7439_95-4)
u. Molybdenum. Tota!

(7439-98-7) v. Manganese,
Total

(7439-96--5)

w. Tin, Total
(7440-31-5)

x. Ttlanium, Total
(7440-32-6)
EPA Form 3510-2C (8-90)

000210

I
~~"'''T''''''''''''

EPA !.D. NUMBER (copy fi'om Item I ofForm I)

, ..... .."

,'......... "'-', ,'-',,,,, ...-v

3IVOOOOO

I

OUTFALL NUMBER

001

PART C· If you are a Primary industry and this outfall contains process wastewater, refer to Table 20-2 in the instructions to determine which of the GC/MS fractions you must lest for. Mark ~X" in column 2-a for all such GC/MS fractions that apply to your industry and for ALL toxic metals, cyanides, and total phenols. If you are not required to mark column 2-a (secondary industn'es, nonprocess wastewater outfa{fs, and nonrequired GelMS fractions), mark "X' in column 2-b for each pollutant you know or have reason to believe is present. Mark "X" in column 2-c for each pollutant you believe is absent If you mark column 2a for any pollutant, you must provide the results of at least one analysis for that pollutant. If you mark column 2b for any pollutant, you must provide the results of at least one analysis for that pollutant if you know or have reason to believe it will be discharged in concentrations of 10 ppb or greater. If you mark column 2b for acrolein, acrylonitrile, 2,4 dinitrophenol, or 2~methyl-4, 6 dinitrophenol, you must provide the results of at least one analysis for each of these pollutants which you know or have reason to believe that you discharge in concentrations of 100 ppb or greater. Otherwise, for pollutants for which you mark column 2b, you must either submit at least one analysis or briefly describe the reasons the pollutant is expected 10 be discharged. Nole that there are 7 pages to this part; please review each carefully, Complete one table (afl 7 pages) for each outfall. See instructions for additional details and requirements. 2. MARK "X" 5. INTAKE (OpliOllof) 3. EFFLUENT 4. UNITS 1. POllUTANT b. MAXIMUM 30 DAY VALUE c. LONG TERM AVRG. a. LONG TERM AND a. MAXIMUM DAILY VALUE (ifavailable) VALUE (ifal'Gilable) AVERAGE VALUE CAS NUMBER d. NO. OF a. CONCENb. NO. OF TESTING BELIEVED BELIEVED (1) (1) {1} (1) ; , (iful'ai/ablr:) REQUIRED PRESENT ABSENT CONCENTRATION TRATION b. MASS CONCENTRATION (2) MASS ANALYSES (2) MASS CONCENTRATION {2) MASS CONCENTRATION (2) MASS ANALYSES

I

,

,

,

I

I

METALS, CYANIDE, AND TOTAL PHENOLS 1M. Antimony, Tolal {7440-36-0) 2M. Arsenic, Total (7440-38-2) 3M. Beryllium, Total (7440-41-7)
4M. Cadmium, Total

(7440-43-9) SM. Chromium, Total (744D-47-3) 6M, Copper, Total (7440-50-8)
7M. lead, Total

(7439-92-1)
8M_ Mercury, Total

(7439-97-6)
8M. Nickel, Total (744D-02-0) 10M. Selenium, Total (7782-49-2)

11M. Silver, Tola! (7440-22-4) 12M. Thallium, Total (7440~28-0) 13M. Zinc, Tota! (7440-66-6) 14M. Cyanide, Tolal (57~12.5) 15M. Phenols, Total DIOXIN 2.3,7,8-Tetrachlorodlbenzo-PDioxin (1764-01-6)
EPA Fonn 3510-2C (8-90)

X X X X X X X X X X X X X X X

X

DESCRIBE RESULTS

PAGE V-3

CONTINUE ON REVERSE

000211

CONTINUED FROM THE FRONT 2. MARK "X" 3. EFFLUENT 4. UNITS c.LONG TERM AVRG. VALUE (ifm'oifable)
(1) CONCENTRATION
(2) MASS

5. INTAKE (op/ianal) a.LONG TERM AVERAGE VALUE

1. POLLUTANT

AND
CAS NUMBER (ifol'oi!aiJIr)

,
TESTING REQUIRED

b.

,

b. MAXIMUM 30 DAY VALUE

a. MAXIMUM DAILY VALUE
(2) MASS

(i[ol'oifabfe)
(i) CONCENTRATION (2) MASS

BELIEVED BElIEVEb (1) PRESENT ABSENT CONCENTRATION

d. NO. OF ANALYSES

a.

CONCENTRATION

b. MASS

(1) CONCENTRATION

(2) MASS

b. NO. OF ANALYSES

GC/MS FRACTION ~ VOLATILE COMPOUNDS lV. Accrolein (107-02-8) 2V. Acrylonitrile (107-13-1) 3V. Benzene (71-43-2) 4V. Sis (CII/Oromethyl) Ether (542-88-1) 5V. Bromoform (75-25-2) 6V. Carbon Tetrachloride (56-Z3-5) 7V. Chlorobenzene (108-90-7) 8V. Chlorodi_ bromometl1ane (124-48-1) 9V. Chloroethane (75-00-3) 10V. Z-Chloroethylvinyl Ether (110-75-8) 11V. Chloroform (67-66-3) 12V.Dichlorobromometl1ane (75-27-4) 13V. Dichlorodiftuoromet!lane (75-71-8) 14V.1,1·Dic!lloroethane (75.34-3) 15V.1,Z·Dic!lloroethane (107-06-2) 16V.1,1-Dichloroethylene (75-35-4) 17V. 1,Z-Dichloropropane (78-87-5) 18V.1,3-Dichloropropylene {54Z-75-6) 19V. Elhylbenzene (100-41-4) 20V. Methyl Bromide (74-83-9) 21V. Metl1yl Chloride (74-87-3) EPA Form 351O-2C (8-90)

X X X

X
X X X X
.5 ug/l

X X
X X X X X X X X X X X
.

13.2 ug/l 6.3 ug/l

X
X

X X

.

PAGE

V~4

CONTINUE ON PAGE V-5

000212

CONTINUED FROM PAGE V-4

2. MARK "X"
1. POLLUTANT AND CAS NUMBER (ifGl'ai!able)

,
TESTING REQUIRED

3. EFFLUENT b. MAXIMUM 30 DAY VALUE
(ifavaifable)
(1) CONCENTRATION

4. UNITS

5. INTAKE (op/iO/wl) LONG TERM AVERAGE VALUE

c. LONG TERM AVRG.
VALUE (ifavailable)
(1) CONCENTRATION (2) MASS

a.

a. MAXIMUM DAILY VALUE b. c BELIEVED BELIEVEb (1) PRESENT ABSENT CONCENTRATION (2) MASS

(2) MASS

d. NO. OF ANALYSES

a. CONCENTRATION

b. MASS

(1) CONCENTRATiON

(2) MASS

b. NO. OF ANALYSES

GC/MS FRACTION - VOLATILE COMPOUNDS (r:onlimll.'d)
22V. Methylene Chloride (75-09-2) 23V. 1,1,2,2Tetrachloroethane 79-34-5) 24V. Tetrachloroethylene (127-18--4) 25V. Toluene (108-88-3) 25V,1,2-TransDichloroethylene 156-60-5) 27V.1,1,1-Trichloroethane (71-55-6) 28V, 1.1 ,2-Trichloroethane (79-00-5) 29VTrichloroethylene (79-01-6) 30V. Tricl1lorofluoro~:tane

X X X X X X X X

75-69-4

X
X X X X X X X X X X X X
PAGEV-5 CONTINUE ON REVERSE

31V. Vinyl Chloride (75-01-4)

GC/M$ FRACTION - ACID COMPOUNDS
1A. 2-Chlorophenol (95-57-8)

2A. 2,4-Dichlorophenol (120-83-2)
3A. 2A-Dimethylphenol (105-57-9) 4A.4,5-Dinitro-OCresol (534-52-1) 5A. 2,4-Dinltrophenol (51-28-5) 6A. 2-Nilrophenol (88-75-5) 7A. 4-Nilrophenol (100-02-7) 8A. P-Chloro-MCresol (59-50-7) 9A. Pentachlorophenol {87-86-5} 10A. Phenol (108-95-2) 11A. 2,4,6-Trichlorophenol (88-05-2) EPA Form 351Q-.2C (8-90)

000213

CONTINUED FROM THE FRONT

2. MARK "X" 1. POLLUTANT AND CAS NUMBER
(lja1'ailabfe)

3. EFFLUENT

4. UNITS

5. INTAKE (optiol1al)

,
TESTING REQUIRED

b. MAXIMUM 30 DAY VALUE
b.
BELIEVED PRESENT BELIEVED (1) ABSENT CONCENTRATiON

c. LONG TERM AVRG.
VALUE (((a1'ailable)
(1) CONCENTRATION

a. LONG TERM
AVERAGE VALUE

"

a. MAXIMUM DAilY VALUE
(2) MASS

(ifm,ailabll')
(1) CONCENTRATION

d. NO. OF
(2) MASS ANALYSES

a. CONCEN·
TRATION
b. MASS

(2) MASS

(1) CONCENTRATION

(2) MASS

b. NO. OF ANALYSES

GCfMS FRACTION - BASE/NEUTRAL COMPOUNDS
18. Acenaphthene (83-32-9) 28. Acenaphtylene (208-96-8) 38. Anthracene (120-12-7) 48. Benzidine (92-87-5) 58. 8enzo (a) Anthracene (56-55-3) 6B. Benzo (a) Pyrene (50-32-8) 78. 3,4-Benzofluoranthene (205-99-2) BB. Benzo (ghl) Perylene (191-24-2) 9B. Benzo (k) Fluoranlhene (207-0B-9) 108. 8is (2-Chlom_ l!tIUHy) Methane (111-91-1) 11B. Sis (J-Chlomethyf) Ether (111-44-4) 128. Bis (2Chloroi.l'Opropyf) Ether (10Z-80-1) 138. Sis (2-Ethyl_ hexy!) Phthalate (117-81-7) 14B.4-Bromophenyl Phenyl Ether (101-55-3) 15B. Butyl Benzyl Phthalate (85-68_7) 16B.2-Chloronaphthalene (91-58-7) 178. 4--Chlorophenyl Phenyl Ether (7005-72-3) 188. Chrysene (218-01-9) 19B. Dibenzo (a.h) Anthracene (53-70-3) 20B.1.2-DichlofObenzene (95-50-1) 218.1.3·Di-chlorobenzene {541-73-1) EPA Form 3510-2C (6-90)

.

X X X X X X X X X X X X X X X X X X X X X

.

PAGEV-6 CONTINUE ON PAGE V-7

000214

CONTINUED FROM PAGE V~6

2. MARK "X"
1, POLLUTANT

3. EFFLUENT

4. UNITS

5. INTAKE (opliOllOl) a.lONGTERM AVERAGE VALUE

AND
CAS NUMBER (ifal'ailabic)

a. MAXIMUM DAILY VALUE b. TESTING BELIEVED BELlEVEb (1) REQUIRED PRESENT ABSENT CONCENTRATION (2) MASS

,

,

b. MAXIMUM 30 DAY VALUE (ij"al"ailable)
(1)

c. LONG TERM
(l)

AVRG. VALUE (I[al'ailable)
(2) MASS

CONCENTRATiON

(2) MASS

CONCENTRATION

d. NO. OF ANALYSES

a. CONCEN·
TRATION

b. MASS

(l)

CONCENTRATION

(2) MASS

b. NO. OF ANALYSES

GC/MS FRACTION - BASE/NEUTRAL COMPOUNDS (colliinucd) 22B.1,4-Dichloro_ benzene (106.46-7) 238. 3,3~Dichloro· benzidIne (91·94-1) 24B. Dielhyl Phthalate (84-66-2) 258. Dimethyl Phthalate (131 -11-3) 26B.Di-N-Butyl Phthalate (84-74-2) 278.2,4-Dinitrotoluene (121-14-2)

28R 2,6-Dinitro-toluene (606-Z0-2) 29B- Di-N-OctYI Phthalate (117-84-0) 308.1,2-Dlphenylhydrazine (as Azobenzene) (122-66-7)

318. Fluoranlhene (206-44-0) 328. Fluorene (86-73-7) 338. Hexachlorobenzene (118-74-1) 348. HexachlorobutadIene (87-88-3) 358. Hexachloro_ cyclopentadiene (77-47-4) 36B Hexachloroethane (67~72-1) 378.lndeno (1,2,3-.ed) Pyrene (193-39-5) 38B.lsophorone (78-59-1) 39B. Naphthalene (91-20-3) 40B. NHrobenzene
(98-95~3)

418. N·Nifro-

.sodimefhylamine (62-75-9) 42B. N-Nitrosodi· N-Propylamine (621-64-7)

X X X X X X X X X X X X X X X X X X X X X

PAGE
V~7

EPA Form 3510+2C (8+90)

CONTINUE ON REVERSE

000215

CONTINUED FROM THE FRONT 2. MARK "X" 3. EFFLUENT

4. UNITS

5. INTAKE (oplionaf)

1. POLLUTANT

AND
CAS NUMBER (ilal'Gilahle)

0

b.

,

b. MAXIMUM 30 DAY VALUE

c.

a. MAXIMUM DAILY VALUE
(2} MASS

(ijGl'Gifable)
(l) CONCENTRATION

LONG TERM AVRG. VALUE (i!m'ailabfe)
(2} MASS

a. LONG TERM
AVERAGE VALUE

TESTING REQUIRED

BELIEVED BELIEVEb {1) PRESENT ABSENT CONCENTRATION

(2) MASS

{1) CONCENTRATION

d. NO. OF
ANALYSES

a. CONCENTRATIQN

b. MASS

(l) CONCENTRATION

(2) MASS

b. NO. OF ANALYSES

GC1MS FRACTlON
43B. N-Nllrosodiphenylamlne (86-30-6) 448. Phenanthrene (8S-01-8) 456. Pyrene (129-Oo-0) 46B. 1.2,4-Trichlorobenzene (120-82-1)

BASE/NEUTRAL COMPOUNDS (contillued)

X X X X
PESTICIDES

GC1MS FRACTION
1P.Aldrin
(309-0D-2)

2P.a-BHC (319-84-6) 3P.JJ-BHC (319-85-7) 4P. y-BHC (58-89-g) 5P.o-BHC (319-86-8) 6P. Chlordane (57-74-9) 7P.4,4'-DDT (50-29-3) 8P.4,4'-ODE (72-55--9) 9P.4,4'-DOO (72-54-8) 10P. Dieldrin (£0-57-1) 11P. a-Enosulfan (115-29-7) 12P. jJ-Endosulfan (115-29-7) 13P. Endosulfan Sulfate (1031-07-8) 14P.Endrin (72-20-8) 15P. Endrin Aldehyde (7421-93-4) f6P. Heptachlor (76-44-8) EPA Form 3510·2C (8.90)

X X X X X X X X X X X X X X
X

X
PAGEV-8 CONTINUE ON PAGE V-9

000216

EPA J.D. NUMBER (copyfrom Item 1 ofForm 1)

OUTFALL NUMBER

CONTINUED FROM PAGE V·S

OHOOOO612
3. EFFLUENT
b. MAXIMUM 30 DAY VALUE

001
4. UNITS

2. MARK "X"
1, POLLUTANT AND CAS NUMBER (Ifavailable)
a, MAXIMUM DAILY VALUE b TESTING BELIEVED BELIEVED (l) REQUIRED PRESENT ABSENT CONCENTRATiON (2) MASS

5. INTAKE (opllonaT)

,

,

c. LONG TERM AVRG.
VALUE (ifavoilable)
(1) CONCENTRATION (2) MASS

a. LONG TERM
d. NO. OF a. CONCENANALYSES TRATION AVERAGE VALUE
b. MASS
(1) CONCENTRATION

(ifal'oilable)
(1) CONCENTRATION (2) MASS

(2) MASS

b. NO. OF ANALYSES

GC1MS FRACTION - PESTICIDES (nmliJ1w:d)

HP, Heptachlor Epoxide
(1024-57-3) 18P. PCB-1242 (53469-21-9) 19P. PCB-1254 (11097-69-1) 20P. PCB-1221 (11104-28-2) 21P. PCB-1232 (11141-16-5) 22P. PCB-1248 (12672-29-6) 23P. PCB-1260 (11096-82-S) 24P. PCB-1D16 (12674-11-2) 2SP. Toxaphene (8001-35-2)

X
X X X X X X X X
I
I

I

I
I

I
PAGE V-9

i
I

i

EPA Form 3510-2C (8-90)

000217

v ........ " ...... " , ... ..., ",-".",.

V. INTAKE AND EFFLUENT CHARACTERISTICS (continued from page 3 of Fonn 2-C)

PART A -You must provide the results of at least one analysis for every pollutant in this table. Complete one table for each outfall. See instructions for additional details,

~
OHOOOO612
3. UNITS

OUTFALL NO

co,

2. EFFLUENT
a. MAXIMUM DAILY VALUE
1. POLLUTANT
(1) CONCENTRATiON

(specifY !fhlOllk)
c.lONG TERM AVRG. VALUE (if available)
d. NO. OF
(1) CONCENTRATION
(2) MASS

4. INTAKE (optional)

.~~~.

b. MAXIMUM 30 DAY VALUE (ifavailahlc)
(1) CONCENTRATION

a. LONG TERM

a CONCENTRATION b. MASS

AVERAGE VALUE
(1) CONCENTRATION

(2) MASS

(2) MASS

ANALYSES

(2) MASS

b. NO. OF ANALYSES

a. Biochemical Oxygen
Demand (BOD) b. Chemical Oxygen Demand (COD) c. Total Organic Carbon (TOC) d. Total Suspended Solids (rsS) e. Ammonia (as N)

2.17 mg/l 16.1 mg/l
7.33 mg/1

5

.037 mg/l
VALUE
0~1.5

I
MGD
VALUE VALUE VALUE MINIMUM

..•
VALUE VALUE VALUE MAXIMUM STANDARD UNITS VALUE VALUE VALUE

f. Flow g. Temperature (wil/fer) h. Temperature (summer) VALUE VALUE

0-15 deg eel.

·C ·C

15-30 deg eel.
MAXIMUM

MINIMUM

l. pH
PART B -

6.73

7.64

Mark "X" in column 2-a for each pollutant you know or have reason to believe is present Mark "X" in column 2-b for each pollutant you believe to be absent. If you mark column 2a for any pollutant which is limited either directly, or indirectly but expressly, in an effluent limitations guideline, you must provide the results of at least one analysis for that pollutant For other pollutants for which you mark column 2a, you must provide quantitative data or an explanation of their presence in your discharge. Complete one table for each outfalL See the instructions for additional details and requirements. 5. INTAKE (opli()lwl) 2. MARK "X· 3. EFFLUENT 4. UNITS 1. POLLUTANT a. LONG TERM AVERAGE b. MAXIMUM 30 DAY VALUE c. LONG TERM AVRG. VALUE AND VALUE a. MAXIMUM DAILY VALUE (ifavailable) (ifal'<lilahre) b b. NO. OF CAS NO. 8. CONCENd. NO. OF BELIEVED BELIEVED (1) (1) (1) (1) ANALYSES (ifal'<lilahre) b. MASS CONCENTRATION TRATION PRESENT ABSENT ANALYSES CONCENTRATION (2) MASS (2) MASS CONCENTRATION (2) MASS CONCENTRATION (2) MASS

,

3. Bromide
(24959~67-9)

b_ Chlorine. Tolal Residual C. Color d. Fecal Coliform e. Fluoride (16984·48-8)
f. Nitrate-Nllrite (as tv')

X X X

I

I I I

X X X
PAGE
V~1

EPA Form 351D-2C (8--90)

CONTINUE ON REVERSE

000218

ITEM V-B CONTINUED FROM FRONT

2. MARK "X"

3. EFFLUENT

4. UNITS
c. LONG TERM AVRG. VALUE (ifm'ailable)
(1)

5. INTAKE (optional)

1. POLLUTANT
AND
CAS NO.

BELIEVED BELIEVED
PRESENT ABSENT

"

b.

a. MAXIMUM DAILY VALUE
(1)

b. MAXIMUM 30 DAY VALUE (ifm·ailable)
(1)

a. LONG TERM
AVERAGE VALUE

(ifavailabh;) g. Nilrogen, Tolal Organic (as N)
h. Oil and Grease

CONCENTRATION

(2) MASS

CONCENTRATION

(2) MASS

CONCENTRATION

(2) MASS

d. NO. OF ANALYSES

a. CONCENTRATION

~. MASS

(1)

CONCENTRATION

(2) MASS

b. NO. OF ANALYSES

X
X

i. Phosphorus
(as P), Total
(7723~14-0)

X
X X X X X X X X X X X X X X X X X X
PAGE

j. Radioactivity

(1) Alpha, Total {2) Beta, Total {3) Radium,
Total

{4) Radium 226,
Total

k. Sulfate
(u~'SO,)

(14808-79-8)
I. Sulfide

{as S} m. Sulfite (0.1".)'0;)

(14265-45-3)
n. Surtactants o. Aluminum, Total

(7429-90-5)
p. Barium, Total

(7440-39-3)
q. 80ron, Tolal

(7440-42-8)
f.

Cobalt Total

(7440-48-4)
s. Iron, Total

.

(7439-89-6)

t. Magnesium, Total
(7439-95-4)

u. Molybdenum, Total
(7439-98-7)
v. Manganese, Total

(7439-96-5)

w. Tin, Total
(7440-31-5)

x. Titanium,
Total

(7440-32-6)
EPA Form 3510-2C (8-90)

v-z

CONTINUE ON PAGE V-3

000219

I
",VI" III'iUClJ rl,U'VI ,. r \ ' J i - v

EPA 1.0. NUMBER (wpy from h,m 1"jF",m 1)

I

OUTFALL NUMBER

v, .--v"'v, .:.-,-,

OH0000612

002

PART C - If you are a primary industry and this outfall contains process wastewater, refer to Table 2c~2 in the instructions to determine which of the GCfMS fractions you must test for. Mark "X" in column 2-a for all such GClMS fractions that apply to your industry and for ALL toxic metals, cyanides, and total phenols. If you are not required to mark column 2-a (secondal)' industries, nonprocess wastewater Duffel/s, and nonrequired GCIM$ fractions), mark "X' in column 2·b for each pollutant you know or have reason to believe is present. Mark "X' in column 2-c for each pollutant you believe is absent. If you mark column 28 for any pollutant, you must provide the results of at least one analysis for that pollutant. If you mark column 2b for any pollutant, you must provide the results of at least one analysis for that pollutant if you know or have reason to believe it will be discharged in concentrations of 10 ppb or greater. If you mark column 2b for acrolein, acrylonitrile, 2,4 dinitrophenol, or 2-methyl-4, 6 dinitrophenol, you must provide the results of at least one analysis for each of these pollutants which you know or have reason to believe that you discharge In concentrations of 100 ppb or greater. Otherwise, for pollutants for Which you mark column 2b, you must either submit at least one analysis or briefly describe the reasons the pollutant is expected to be discharged. Note that there are 7 pages to this part; please review each carefully. Complete one table (all 7 pages) for each outfall. See instructions for additional details and requirements. 5. INTAKE (oplionaf) 4. UNITS 3. EFFLUENT 2. MARK "X" 1. POLLUTANT c. LONG TERM AVRG. a. LONG TERM b. MAXlMUM 30 DAY VALUE AND AVERAGE VALUE (Ijavailabfe) VALUE (ifavailabfe) a MAXIMUM DAILY VALUE o. b. d. NO, OF a. CONCENb. NO. OF CAS NUMBER TESTING BELIEVED BELIEVED (1) (1) (1) (1) ANALYSES TRATION b. MASS CONCENTRATION (2) MASS ANALYSES REQUIRED PRESENT ABSENT CONCENTRATION (ifavailobte) (2) MASS CONCENTRATION (2) MASS CONCENTRATION (2) MASS

I

,

METALS, CYANIDE, AND TOTAL PHENOLS 1M. Antimony, Total
(744lJ.-36~0)

2M. Arsenic, Total
(7440-38~2)

3M. Beryllium, Total (7440-41-7) 4M. Cadmium, Total (744lJ.-43-9) SM. Chromium, Total (7440-47-3) 8M. Copper, Total (7440-50-8) 7M. lead, Total (7439-92-1) 8M. Mercury, Total (7439-97-6) 9M, Nickel, Total (7440-02-0) 10M. Selenium, Total (7782-49-2) 11M. Silver, Total (7440-22-4) 12M. Thallium, Total (7440-28-0) 13M. Zinc, Total (7 440-66~6) 14M. Cyanide, Total (57-12-5) 15M. Phenols, Total DIOXIN 2,3.7,8-Telfachlomdibenzo-P. Dioxin (1764-01-6) EPA Form 3510-2C (8-90)

X X X X X X X X X X X X X X X

X

DESCRIBE RESULTS

PAGE V-3

CONTINUE ON REVERSE

000220

CONTINUED FROM THE FRONT

2. MARK "X~
1. POLLUTANT

3. EFFLUENT

4. UNITS

AND CAS NUMBER (ifcrvailable)

a. MAXIMUM DAILY VALUE b. o. TESTING BEUEVED BEUEVED (1) REQUIRED PRESENT ABSENT CONCENTRATION (2) MASS

..

b. MAXIMUM 30 DAY VALUE

c.

(i[avai/able)
(1) CONCENTRATION (2) MASS

LONG TERM AVRG, VALUE (ifal'Uifab/e) (2) MASS

5. INTAKE (optionaf) a. LONG TERM AVERAGE VALUE (1) CONCENTRATION

(1) CONCENTRATION

d. NO. OF
ANALYSES

a. CONCENTRATION

b. MASS

(2) MASS

b. NO. OF ANALYSES

GC/MS FRACTION - VOLATILE COMPOUNDS

1V. Acerolaln (107-02-8)
2V, Acrylonllrile (107-13-1) 3V, Benzene (71-43-2) 4V. Sis (Chlorome1hyl) Ether (542-88-1)

X X X

X
X X X X

511. Bromofonn
(75-25.2) 6V. Carbon Tetrachloride (56-23.5)

7V. Chlorobenzene (108·90·7)
8V. Chlorodl· bromomethane (124-48-1) 9V, Chloroethane (75-00.3) 10V.2-Chloroethylvlnyl Ether (110..75--8) 11V. Chloroform (67-66-3) 12V, Dichlorobrof11Qmethane (75·27-4) 13V. Dichloro· difluoromethane (75-71.8) 14V. 1,1-Dichloroethane (75-34-3) 15V.1,2-Dichloroethane (107-06-2) 16V.1,1-Dichlorcethylene (75-35-4) 17V.1,2-Dichloropropane (78--87-5) 18V.1,3-Dichloro(542·75_6

X
X X X

X
X X
2.3 ugjl

X X
X

X X
X

propyle~:)

X
X

19V. Elhylbenzene (100-41-4)

2W. Methyl
Bromide (74-83-9) 21V, Methyl Chloride (74-87-3)

X X
PAGE V-4 CONTINUE ON PAGE V·S

EPA Form 3510-2C (8-90)

000221

CONTINUED FROM PAGE V-4

2. MARK "X"
1. POLLUTANT

3. EFFLUENT

4. UNITS

I

5. INTAKE (opllonal) a. LONG TERM AVERAGE VALUE
(1)

AND
CAS NUMBER (Ilol'oiloble) GC1MS FRACTION 22V. Methylene Chloride (75-09-2) 23V.1,1,2,2Tetrach~~roethane

a. MAXIMUM DAilY VALUE b TESTING BELIEVED BELIEVED (1) REQUIRED PRESENT ABSENT CONCENTRATION (2) MASS VOLATILE COMPOUNDS (conlinued)

,

,

b. MAXIMUM 30 DAY VALUE (ijtll'aitoble)
(1)

c. LONG TERM AVRG.
VALUE (ijol'oiloble)
(1)

CONCENTRATION

(2) MASS

CONCENTRATION

(2) MASS

d. NO. OF a.·CQNCENANALYSES TRATION

i
b. MASS

CONCENTRATION

(2) MASS

b. NO. OF ANALYSES

79-34-5

24V. Tetrachloroelhylene (127-18-4) 25V. Toluene (108-88-3) 26V.1,2-TransDichloroelhylene 156-60-51 27V,1.1.1-Trichloroethane (71~55~6) 28V.1.1,2-Tricl1loro ethane (79-00-5) 29V Trichloroethylene (79-01-6) 30V. Tricl1lorofluoromelhane 75-69-4} 31V. Vinyl Chloride (75-01-4)
GC/MS FRACTION -ACID COMPOUNDS

X X X X X X X X

i

X
X X X X X X X X X X X X
PAGE V-5

1A. Z-Chlorophenol (95--57-8) 2A. 2,4-Dlchlorophenol (120-83-2) 3A. 2.4-Dimelhylphenol (105-67-9) 4A. 4,6-Dinitro OCresol (534-52~1)

I

SA. 2,4-Dinitro-phenol (51~28-5)
6A. 2-Nitrophenol (88-75-5) 7A. 4-Nilrophenol (100-02-7) 8A. P-Chloro--MCresol (59-50-7)
9A. Penlachlorophenol (87-86-5)
i0A. Phenol
(108~95~2)

l1A. 2,4,6-Trichlorophenol (88-05-2) EPA Form 3510-2C (8-90)

CONTINUE ON REVERSE

000222

CONTINUED FROM THE FRONT

2. MARK "X"
1. POLLUTANT AND CAS NUMBER (ij"al'ailabfe)

3. EFFLUENT b. MAXIMUM 30 DAY VALUE (ifavallable)
(1)

4. UNITS

5. INTAKE {op/lona!)

a. MAXIMUM DAILY VALUE o. b. TESTING BELIEVED BELIEVED (1) REQUIRED PRESENT ABSENT CONCENTRATION (2) MASS

,

c. LONG TERM AVRG.
VALUE (ifal'ailable)
(1)

a. LONG TERM
AVERAGE VALUE a.'CONCENANALYSES TRATION . b, MASS

d. NO. OF

(1)

CONCENTRATION

(2) MASS

CONCENTRATION

(2) MASS

CONCENTRATION

(2) MASS

b. NO. OF ANALYSES

GC/MS FRACTION - BASE/NEUTRAL COMPOUNDS 1B. Acenaphthene (83-32-9) 2B. Acenaphtylene (208-96-8) 38. Anthracene (120-12-7) 48. Benzidine (92-87-5) 58, 8enzo (a) Anthracene (56-55-3) 68. Benzo (a) Pyrena (50-32-8) 78,3,4-8enzoftuoranthene (205-99-2) 8B. Benzo (gili) Perylene (191-24~2) 9B. Benzo (k) Fluoranthene (207-0B-9) lOB. Sis (2-Chloroethoxy) Methane (111-91-1) 118. Sis (2-Chloroelhyl) Ether (111-44-4) 12B. Sis (2_ Chlol'oi,wpropyf) Ether (102-BO-1) 138, Sis (2-Elhylhexy!) Phlhalate (117-81-7) 148. 4-Bromophenyl Phenyl Ether (101-55-3) 158. Butyl Benzyl Phthalate (85-68-7) 16B. 2~Chloronaphthalene (91-58--7) 178.4-Chlorophenyl Phenyl Ether (7005-72-3) 188. Chrysene (218-01-9) 198, Dlbenzo (a,h) Anlhracene (53-70-3) 208. l,2,Dichlorobenzene (95-50-1) 21 B. 1,J-Di-chlorobenzene (541-73-1) EPA Form 3510·2C (8-90)

X X X X X X X X X X X X X X X X X X X X X
PAGE Vee CONTINUE ON PAGE V·7

000223

CONTINUED FROM PAGE V*6 2. MARK "X" 1. POllVTANT AND a. MAXIMUM DAllY VALUE a b. 0 CAS NUMBER TESTING BELIEVED BELIEVED (1) (ij"available) REQUIRED PRESENT ABSENT CONCENTRATION (2) MASS GC/MS FRACTION 228.1,4-0ichlorobenzene (10646-7) 238.3,3*Oichloro_ benzidine (91-94_1) 248.0iethyl Phthalate (84-66-2) 25B. Dimethyl Phthalate (131 -11~3) 26B.Di-N-Bulyl Phthalate \84-74-2} 278.2,4-Dinitro_ toluene (121-14-2) 288.2.6-Dinitrotoluene (606.20_2) 29B. Di-N-Octyl Phthalate (117-84-0) 30B- 1.2-Diphenyl_ hydrazine (as AZDbenzene) (122-66-7) 31B. Fluoranthene (206-44-Q) 328. Fluorene {86-73-7) 338. Hexachloro_ benzene (118-74-1) 348. Hexachloro_ butadiene (87-68-3) 358. Hexachloro_ cyclopentadiene (7747-4) 368 Hexachloro_ ethane (67-72-1) 37B.lndeno (1,2,3-af) Pyrene (193-39-5) 388.lsophorone (78-S9-1) 39B. Naphthalene (91-20-3) 40B. Nitrobenzene (98-95-3) 418. N-Nilrosodimethylamine (62-75-9) 42B. N·Nilrosodi_ N·Propylamine (621-64-7) EPA Form 351O-2C (8-90) BASE/NEUTRAL COMPOUNDS (coillinued)

3. EFFLUENT b. MAXIMUM 30 DAY VALUE
(ifawlilable)
(1)

4. UNITS

5. INTAKE (optiOIlOI)

c. lONG TERM AVRG.
VALUE (ijavailabfe)
(1)

a. lONG TERM
AVERAGE VALUE

CONCENTRATION

(2) MASS

CONCENTRATION

(2) MASS

d. NO. OF a.'CONCENANALYSES TRATION

b. MASS

(1)

CONCENTRATlON

(2l MASS

b. NO. OF ANALYSES

X X X X X X X X X X X X X X X X X X X X X
PAGE V-7 CONTINUE ON REVERSE

000224

CONTINUED FROM THE FRONT 2. MARK "X" 1. POLLUTANT

3. EFFLUENT
b. MAXIMUM 30 DAY VALUE

4. UNITS

5. INTAKE (opfional)

AND
CAS NUMBER (i[m'ai/able)

,

c. LONG TERM AVRG.
VALUE U[al'ailable)
(1)

a. LONG TERM
d. NO. OF a.·CONCEN~ ANALYSES TRATiON
AVERAGE VALUE

b

o.

a. MAXIMUM DAilY VALUE
(2) MASS

(ijal'aifabfe)
(1)

TESTING BELIEVED BELIEVED (1) REQUIRED PRESENT ABSENT CONCENTRATION

CONCENTRATION

(2) MASS

CONCENTRATION

(2) MASS

-

b. MASS

(1)

CONCENTRATION

(2) MASS

b. NO. OF ANALYSES

GC/MS FRACTION - BASE/NEUTRAL COMPOUNDS (con/inued)

438. N-Nilrosodiphenylamine (86-3D-6) 448. Phenanthrene (85-01-8) 458. Pyrene (129-00-0) 46B. 1.2,4-Trichlorobenzene (120-82-1)

X X X X X X X X X X X X X X X X X X
X

GC/MS FRACTION - PESTICIDES
1P.Aldrin (309-00-2)
2P.a~SHC

(319-84-6) 3P·Il-BHC (319-85-7) 4P."{-BHC
(58~8g..9)

5P. "'-SHC (319-86-8) 6P. Chlordane (57-74-9) 7P.4,4'-DDT (5D-29-3) 8P. 4,4'~DDE (72+55·9) 9P.4,4'-000 (72-54-8) 10P. Dieldrin (60-57-1) 11P.o:-Enosulfan
(115~2g..7)

12P·I3+Endosulfan
(115~29-7)

13P. Endosulfan Sulfate (1031.07-8)

14P. Endrin (72-20-8) 15P. Endrin Aldehyde (7421+93-4) 16P. Heptachlor (76--44·8)

X
PAGE v-a CONTINUE ON PAGE V-9

EPA Form 3510-2C (8-90)

000225

EPA 1.0. NUMBER (copy/romI/em I o/Form I) OHOOOO612

OUTFALL NUMBER

CONTiNUED FROM PAGE V-a 3. EFFLUENT 2. MARK "X" 1. POLLUTANT b. MAXIMUM 30 DAY VALUE c. LONG TERM AVRG. AND ,. a. MAXIMUM DAILY VALUE (ijovaifable) VALUE (ijol'ailob/e) b. CAS NUMBER TESTING BELIEVED BELIEVED (1) (1) (1) (ijavailah/e) REQUIRED PRESENT ABSENT CONCENTRATION CONCENTRATION (2) MASS CONCENTRATION (2) MASS (2) MASS

002

4, UNiTS

,

d. NO. OF ANALYSES

a. CONCEN·
TRATION
b. MASS

5. INTAKE (oplionaf) a. LONG TERM AVERAGE VALUE
(1) CONCENTRATION

(2) MASS

b. NO. OF ANALYSES

GC/MS FRACTION - PESTICIDES (conti/1ued)
17P. Heptachlor

Epoxide
(1024-57-3) 18P. PCB-1242 (53469-21-9) 19P. PC8~1254 (11097-69-1) 20P. PCB-1221 (11104-28-2) 21P. PCB-1232 (11141-16-5) 22P. PCB-1248 (12672-29-6) 23P. PCB-1260 (11096-82-5) 24P, PCB-1016 (12674-11-2) 25P. Toxaphene (8001-35-2)

X
X X X X X X X X

EPA Form 3510·2C (8-90)

PAGE V-9

000226

Page 1

DIVISION OF SURFACE WATER

Antidegradation Addendum
In accordance with Ohio Administrative Code 3745-1-05 (Antidegradation), additional information may be required to complete your application for a permit to install or NPDES permit. For any application that may result in an increase in the level of pollu~ants being discharged (NPDES and/or PTI)or for which there might be activity taking place within a stream bed, the processing of the permit(s) may be required to go through procedures as outlined in the antidegradation rule. The rule outlines procedures for public notification and participation as well as procedures pertaining to ~ the levels of review necessary. The levels of review necessary depend on the degradation being considered/requested. The rule also outlines exclusions from portions of the application and review requirements and waivers that the Director may grant as specified in Section 3745-1-05(D) of the rule. Please complete the following questions. The answers provided will allow the Ohio EPA to determine if additional information is needed. All projects that require both an NPDES and PTI should submit both applications simultaneously to avoid going through the antidegradation process separately for each permit.
A. Applicant: AKRON PUBLIC UTILITIES BUREAU Facility Owner, -"C"IT-'-Y-'--'O"'F....!::A"K"R"O::.N"Facility Location (city and county): KENT, OHIO

_ PORTAGE COUNTY _

Application or Plans Prepared By: ~J=E~F~F~B~R~O~N~O~VV~S~K~I Project Name: RENEVVAL OF OEPA PERMIT FOR AKRON VVATER TREATMENT PLANT NPDES Permit Number (if applicable): ~3~IV~O~O~O~O~O~·~D~D~

_

B.

Antidegradation Applicability Is the application for? (check as many as apply) :

Application with no direct surface water discharge (Projects that do not meet the applicability section of 3745-1-05(B)1, i.e., on-site disposal, extensions of sanitary sewers, spray irrigation, indirect discharger to POTW, etc.). (Complete Section E) Renewal NPDES application or PTI application with no increase in loading of currently permitted pollutants. Section E, Do not complete Sections C or D) . requested (Complete

PTI and NPDES application for a new wastewater treatment works that will discharge to a surface water. (Complete Sections C and E)
An expansion/modification

of an existing wastewater treatment works discharging to a surface water that will result in any of the following (PTI and NPDES) : (Complete Sections C and E) ~ addition of any pollutant not currently in the discharge, or '" an increase in mass or concentration of any pollutant currently in the discharge, or '" an increase in any current pOllutant' limitation in terms of mass or concentration.

Click to clear all entered information (on all 4 pages of this form)

000227

19k$:A"RI

Page 2
PTr that involves placement of fill or installation of any portion of a sewerage system (i.e., sanitary sewers, pump stations, WWTP,

etc.)within 150 feet of a stream bed.

Please provide information

requested on the stream evaluation addendum (i.e., number of stream crossings, fill placement, etc.) and complete Section E.

Initial NPDES permit for an existing treatment works with a wastewater discharge prior to October 1, 1996. (Complete Sections 0 and E)
Renewal NPDES permit or modification to an effective NPDES permit that will result in any 0 f the following: (Complete Sections C and E)
~ ~

a new permit limitation for a pollutant that previously had no limitation, or an increase in any mass or concentration limitation of any pollutant that currently has a limitation.

c.

Antidegradation Information

1.

Does the PTI and/or NPDES permit application meet an exclusion as outlined by OAC 3745-1-05 (D) (1) of the Antidegradation rule? Yes (Complete Question C.2) No (Complete Questions C.3 and C.4)

2.

For projects that would be eligible for exclusions provide the following information: a.
b.

Provide justification for the exclusion. Identify the substances to be discharged, including the amount of regulated pollutants to be discharged in terms of mass and concentration. A description of any construction work, fill or other structures to occur or be placed in or near a stream bed. of the

c. 3.

Are you requesting a waiver as outlined by OAC 3745-1-05(D) (2-7) Antidegradation rule?
No

Yes If you wish to pursue one of the waivers, please identify the waiver and submit the necessary information to support the request. Depending on the waiver requested, the information required under question C.4 may be required to complete the application. 4. For all projects that do not qualify for an exclusion a report must accompany this application evaluating the preferred design alternative, non-degradation alternatives, minimal degradation alternatives, and mitigative techniques/measures for the design and operation of the activi ty. The information outlined below should be addressed in this report. If a waiver is requested, this section is still required. a. Describe the availability, cost effectiveness and technical feasibility of connecting to existing central or regional sewage collection and treatment facilities, including long range plans for

000228

Page 3
sewer service outlined in state or local water quality management planning documents and applicable facility planning documents.

b.

List

and

describe

all

government

and/or

privately

sponsored

conservation projects that may have been or will be specifically targeted to improve water quality or enhance recreational opportunities on the affected water resource.

c.

Provide

a

brief

description

below

of

all

treatment/disposal

alternatives evaluated for this application and their respective operational and maintenance needs. (If additional space is needed please attach additional sheets to the end of this addendum) .
Preferred design alternative:

Non-degradation alternative(s):

Minimal degradation alternative(s)

Mitigative technique/measure(s)

At a minimum, the following information must be included in the report for each alternative evaluated.
d.

Outline of the treatment/disposal system evaluated, including the costs associated with the equipment, installation, and continued operation and maintenance. Identify the substances to be discharged, including the amount of regulated pollutants to be discharged in terms of mass and concentration. Describe the reliability of the treatment/disposal system, including but not limited to the possibility of recurring operation and maintenance difficulties that would lead to increased degradation. Describe any impacts to human health and the overall quality and value of the water resource. Describe and provide an estimate of the important social and economic benefits to be realized through this proposed project. Include the number and types of jobs created and tax revenues generated. Describe environmental benefits to be realized through this proposed project. Describe and provide an estimate of the social and economic benefits that may be lost as a result of this project. Include the impacts on commercial and recreational use of the water resource.

e.

f.

g.

h.

i.

j.

000229

Page 4
k.

Describe project.

the environmental benefits lost as a result of this Include the impact on the aquatic life, wildlife,

threatened or endangered species. 1. A description of any construction work, fill or other structures to occur or be placed in or near a stream bed. Provide any other information that may be useful in evaluating this application.

m.

D.

'Discharge Information

1.

For treatment/disposal systems constructed pursuant to a previously issued Ohio EPA PTI, provide the following information: PTI Number PTI Issuance Date Initial Date of Discharge

2.

Has the appropriate NPDES permit application form representative effluent data?
Yes (go to E)

been submitted including

No (see below) If no, submit the information as applicable under a. a OR b as follows: a completed

For entities discharging process wastewater attach 2C form.

b.

For entities discharging wastewater of domestic origin attach the results of at least one chemical analysis of the wastestream for all pollutants for which authorization to discharge is being requested and a measurement of the daily volume (gallons per day) of wastewaters being discharged.

E.

Based on my inquiry of the person or persons who manage the system or those persons directly responsible for gathering the information, the information is, to the best of my knowledge and belief, true, accurate and complete. This section must be signed by the same responsible accompanying permit application or certification as per who signed the 122.22.

Da te

-'-_"--t-"'-''''--

_

h:"evised.adm
June 30, 1997

000230

000231

From: To:

CC:
Date: Subject: Attachments:

"Trudics, Patty" <TrudiPa@ci.akron.oh.us> "Paul Novak (paul.novak@epa.state.oh.us)" <paul.novak@epa.state.oh.us> "Gary Stuhlfauth (gary.stuhlfauth@epa.state.oh.us)" <gary.stuhlfauth@epa.. 12/19/20063:04 PM eity of Akron - Draft NPDES Permit biomon1106.pdf; biomon0206.pdf; biomon0506.pdf; biomon0705.pdf; biomon0706. pdf; biomon1105.pdf; Letter to Paul Novak.pdf; eso - September 2006.xls; es a - August 2006.xls; eso - October 2006 Additionallnfo.doc; eso - October 2006.xls; eso - September 2006 Additionallnfo.doc; eso - August 2006 Addit ionallnfo.doc

Mr. Novak: The originals will be sent to you today via U.S. mail.

000232

Randall A. Mootellll, P.E.
Pilols Administrato,

_ M. Gresse" P.E. Waller PollUilOO Conlrol Admlmslralor

Andre L Bl"yIocl<

J"mes L Six. P.E.
Wa!ef SUpply Admm",lnllo'

au.,,,,,,,,, SeMces Mmi"",iralor

DONALD L PLUSQ!.1El.LlC Mayor
Gerald Holland, Ol",,*,'

DEPAA11Il£l;!T OF PUBlIC SERVICE
Michael L MicGlinclly, l'.E. PUBUC UTlUTIES BUREAU MANAGER

December 18, 2006

Me Paul Novak, Manager Permits 1& Comptiance Section Division of Surface Waler Ohio Environmental Protection Agency PO. Box 1049 Cotumbus,OH 43216-1049 Dear Mr. Novak: Thanks again for arranging the November 2006, conference call which parties discussed the City of AAron's comments to the draft NPOES pennit for the City's Water Pollution Control Station. The City also appreciates the lactthet the Ohio EPA will keep the comment period open for any additional City commants. During the conference cell, Gary Stuhlfauth requested the City's most recent toxicity data. In response to this request, I have enclosed copies of the quarterly toxicity reports dated 7/27/2005,11/30/2005,2/1612006,511812006, 7f2112006, and 11/27f2006 for Gary's review. (l believe that this data was previously submitted as part of the MOR process.) We appreciate Gary's willingness to review this additional data. Hopefully, Ohio EPA wiU agree that the chron[<; toxicity limits that were inciuded in the draft permit should be removed and replaced with a monitoring only requirement If you or Gary require copies of the toxicity reports for periods prior to those submitted, pJease let me know. To assist in your consideretion of our comments, I have also attached CSO informalion for August, Septemoor and October of this year. As discussed, this information is submitted to the Ohio EPA as part of tha Cify's monthly operating reports, The City believes that the CSOs have been adequately characterized, and that the information that is currantly submitted is more than sufficient for monitoring and reporting purposes. Hopefully you will come to the same conclusion as yOU review the attached information Coosi$tent with the City's prior comment, the within the draft permit for future in a manner that is similar to the monitoring and reporting of ceos should be
146 S. Hlgll SIIl!et. Room !loo • Akroo. Ol1lo 44308.

_.ci.a!<l:'ol1.oo.us

000233

Mr. P. Novak December 18. 2006 Page 2 prOllision in the City's 1994 permit In addition. the City should also be permitted to continue to submit this data to the Ohio EPA in the attached format Duling our conference call, you informed us that you intend to have one of the Ohio EPA's modelers evaluate the changes in the flow conditions within the Cuyahoga River and determine if the limitations within the draft permit need to be revised based upon this more recent deta. Please let me know if Ohio EPA needs any further information from the City regarding this review and evaluation process.

As discussed. the City will provide Ohio EPA with a copy of the NFA report when it is
complete. We are still on schedule to complete the report by the end 01 December. It is our understanding that the Ohio EPA does not plan to issue a response to the City's comment leller until after Ohio EPA has reviewed and evaluated the NFA report Again thank you for agreeing to keep the comment period open as we continue to gather and supply information fur your consideration. Sincerely,

Randall A. Monteith, P.EPilots Administrator RAM:pt Attachments c:

Gary $tuhlfauth (Ohio EPA)
FINPDES

000234

I I I I I

RESULTS OF CHRONIC TOXICITY TESTS 3-Brood Renewal - Ceriodaphnia dubia (water flea) 7 Day Renewal - Pimephales promelas (fathead minnow) Test period: November 14-21, 2006 Sample collection period: November 12-17, 2006 Report date: November 27, 2006

I I I I I I I I I I I I I I

Conducted For: City of Akron WPCS 2460 Akron-Peninsula Road Akron, Ohio 44313 Ohio EPA Permit 3PFOOOOO

Conducted and Prepared By: EnviroScience, Incorporated 3781 Darrow Rd. Stow, OR 44224 (330) 688-0111

, Aquatic Biologist

000235

RESULTS OF CHRONIC TOXICITY TESTS
3-Brood Renewal - Ceriodaphnia dubia (water flea) 7 Day Renewal- Pimephales promelas (fathead minnow) Test period: February 7-14,2006 Sample collection period: February 5-10, 2006 Report date: February 16,2006

Conducted For: City of Akron WPCS 2460 Akron-Peninsula Road Akron, Ohio 44313 Ohio EPA Permit 3PFOOOOO' JD

Conducted and Prepared By: EnviroScience, Incomorated 3781 Darrow Rd. Stow,OH44224 (330) 688-0 III

_L;:..{/+,ll£O).,"""1/-"";;iJLa""", .

.: .UJ~;.(" ,f- : :o:. . _ _, Aquatic Biologist

000236

"Excelfence in EcologIcal Monitoring"

May 18, 2006
Mr. Rob Katzmark City of Akron Water Pollution Control Station 2460 Akron-Peninsula Rd. AkrOlJ, OH 44313

Dear Mr. Katzmark: Enclosed are thirteen (13) copies ofEnviroScience's report for the following whole effluent toxicity (WET) tests that were initiated May 9, 2006 using effluent from Akron's Outfall 602:
(l) 3-brood static, renewal chronic bioassay using Ceriodaphnia dubia (water flea) and (1) 7-day static, renewal chronic bioassay using Pimephales prome/as (fathead minnow).

The tested concentrations were 57, 66, 76, 87, and 100 percent effluent. Effluent was diluted with upstream receiving water (water flea) or synthetic freshwater (minnow). Receiving water collected from the far-field downstream site was tested at full-strength. Toxicity was not shown in the effluent, but there was a significant reproduction effect in water fleas exposed to the far- field.
WET endpoints for City ofAkron WWTP 3PFO()OOO, 0512006 sample collection period: 05107106-05112106

C. dubia P. promelas
dubia P. promelas

acute acute chronic chronic

TU,=AA «0.2) TU,=AA «0.2) TU,=AA «1.0) TU,=AA «1.0)

c.

Upstream (801):

48HR C. dubia 96HR P. promelas 7Day C. dubia 7Day P. promelas

= AA (0% affected) = 20% affected = AA
= =

(0% affected) = 28% affected 100% affected (reproduction effect) 40% affected

Far-field (904):

7Day C. dubia 7Day P. promelas

Please don't hesitate to call me or our laboratory manager, Tracy Meder, if you should have any questions. Sincerely, .,1 "»1('-/. O.
I
(j

Uvf ClkUA1 LA- d
enclosures

CGA:V'--'

Nancy A. Black, Aquatic Biologist

330·688-0111

I

3781 DARROW ROAD. STOW. OHIO 44224 TOLL FREE: 800-940-4025 I FAX: 330-688-3858

000237

RESULTS OF CHRONIC TOXICITY TESTS 3-Brood Renewal - Ceriodaphnia dubia (water flea) 7 Day Renewal - Pimephales promelas (fathead minnow) Test period: July 12-19,2005 Sample collection period: July 10-15, 2005 Report date: July 27, 2005

Conducted For: City of Akron POTW 2460 Akron-Peninsula Road Akron, Ohio 44313 Ohio EPA Permit 3PFOOOOO*m

Conducted and Prepared By: EnviroScievce, Incorporated 3781 Darrow Rd. Stow, OR 44224 (330) 688-0111

_iJ~-F'a",.{ji.U~'",O",-.~_7(e_·~_u.:c.:t-.. 0
I

, Aquatic Biologist

000238

RESULTS OF CHRONIC TOXICITY TESTS
3-Brood Renewal- Ceriodaphnia dubio (water flea) 7 Day Renewal - Pimephales promelas (fathead minnow) Test period: July 11-18, 2006 Sample collection period: July 9-14, 2006 Report date: July 21,2006

Conducted For: City of Akron WPCS 2460 Akron-Peninsula Road Akron, Ohio 44313 Ohio EPA Pennit 3PFOOOOO' JD

Conducted and Prepared By: EnviroScience, Incorporated 3781 Darrow Rd. Stow, OH 44224 (330) 688-0111

000239

RESuLTS OF CHRONIC TOXICITY TESTS
3-Brood Renewal - Ceriodaphnia dubio (water flea) 7 Day Renewal - Pimephales promelos (fathead minnow) Test period: November 15-22, 2005 Sample collection period: November 13-19, 2005 Report date: November 30, 2005

Conducted For: City of Akron WPCS 2460 Akron-Peninsula Road Akron, Ohio 44313 Ohio EPA Permit 3PFOOOOO' JD

Conducted and Prepared By: EnviroScience. Incorporated 3781 Darrow Rd. Stow, OH 44224 (330) 688-0111

__ ty--l-"'nLC!4"":<?f"'-"O"".~~-,-=,·",,J"-"k'~_' Aquatic Biologist .
I ()

000240

CITY OF AKRON, OHIO
WET WEATHER COMBINED SEWER OVERFLOWS OCTOBER 2006
TOTAL DURATION IN HOURS CODE:80999

STATION NUMBER 3PFOOOOO

NUMBER OF DAYS CODE:

NUMBER OF EVENTS 80998

VOLUME IN MILLION GALS CODE: 50050

046/R03 S ARLINGTON ST DIST 047/R04 MILL ST 048/R05 RIVER ST 049/R06 FACTORY ST 050/R07 S CASE AVE 051/R08 N CASE AVE-DUBLIN ST 052/R09 WILLIAMS ST ** 053/R10 CASE-NEWTON DISTRICT 054/R 11 HAZEL ST TRUNK *** 055/R12 HOME AVE DISTRICT 056/R13 MADERIA ST 057/R14 N FORGE ST 058/R15 FOREST HILL DISTRICT 059/R16 WOLF LEDGE TRUNK 060/R17 EXCHANGE ST 061/R18 WILLOW RUN TRUNK 062/R19 W MARKET ST 063/R20 W NORTH ST *** 064/R21 N HOWARD ST 065/R22 NORTH HILL TRUNK 066/R23 N MAPLE ST OUTLET 067/R24 W MARKET ST OUTLET 068/R25 OTTO ST 069/R26 AQUEDUCT ST OUTLET 070/R27 UHLER AVE $$ 071/R28 MEMORIAL PKWY 072/R29 UHLER-CARPENTER 073/R30 CUYAHOGA ST % 074/R31 PORTAGE-SUNNYSIDE % 075/R32 CARPENTER HEIGHTS 076/R33 NORTHSIDE INTERCEP 077/R34 RIVERSIDE BLVD 078/R35 GORGE BLVD DISTRICT 079/R36 MERRIMAN RD OUTLET 080/R37 BOWERY ST 081/R02(N,S) RETENTION TANK 0821R39 QUAKER ST 083/R40 CUYAHOGA ST % R38 S BROADWAY

5 4 5 0 4 2 Elim. 6 4 5 2 7 5 5 3 4 2 ++ ++ ++ 2 4 4 2

10 7 13 0 6 2 Elim. 11 9 13 2 30 14 7 3 10 2 ++ ++ ++ 2 11 12 3

13.59 5.12 11.13 0.00 5.23 0.75 Elim. 24.09 12.58 14.15 1.22 16.49 4.89 16.99 4.26 17.68 4.10 ++ ++ ++ 0.43 13.76 8.06 4.38

0.361 0.482 0.244 0.000 0.410 0.021 Elim. 0.401 4.977 3.920 0.039 0.331 0.140 0.367 0.095 33.692 0.785 ++ ++ ++ 0.008 0.391 0.276 0.000

$$
4 6 2 1 5 6 5 5 3 2 1 Elim.

$$
7 11 3 2 10 16 12 16 4 3 1 Elim.

$$
7.45 9.21 3.14 0.79 6.14 12.81 1.96 12.52 10.36 0.91 2.50 Elim.

$$
0.276 0.109 0.182 0.181 0.775 0.303 0.015 1.525 0.210 0.017 0.000 Elim.

#
2

#
2

#
3.85

#
0.096

* (R39) Sewer separation was completed 8/18/2000. ** (R09) Sewer separation was completed 7/27/2004. *** (R11 , R20) Backflow from canal and river into the rack/sewer has been seen at these sites in the past. ++ (R21, R22, R20) Units found inoperable. Replacement units received, to be installed in November. $$ (R27) Unit failed after 8/20/2006. No data since. # (R40) ADS monitoring reported no overflows, but overflows were observed 10/17 and 10/27. % (R30,R31,R40) Overflows flow into new retention tank after 10/16/2006. Tank overflow monitoring is still being installed and calibrated. 000241

ADDITIONAL INFORMATION

As a result of the 1.99 inches of rainfall on October 17, 2006, the storm overflow pump at the Mud Run pump station started 23 times and ran a total of 2.6 hours pumping about 468,000 gallons of sewage into Mud Run Ditch. The Little Cuyahoga retention tank has been constructed and is in the final stages of programming to finalize the controls and inflow and overflow monitoring. Combined sewer Racks 30 and 31 as well as Rack 40 overflow into the tank as of October 16, 2006. The full tank volume was captured on October 17 and October 27 which was pumped back to the sewer for treatment, but the tank overflows to the river was not monitored as the programming is not completed yet. There were no dry weather overflows during the month of October 2006.

000242

CITY OF AKRON, OHIO
WET WEATHER COMBINED SEWER OVERFLOWS SEPTEMBER 2006
TOTAL DURATION IN HOURS CODE:80999

STATION NUMBER 3PFOOOOO

NUMBER OF DAYS CODE:

NUMBER OF EVENTS 80998

VOLUME IN MILLION GALS CODE: 50050

046/R03 S ARLINGTON ST DIST 047/R04 MILL ST 048/R05 RIVER ST 049/R06 FACTORY ST 050/R07 S CASE AVE 051/R08 N CASE AVE-DUBLIN ST 052/R09 WILLIAMS ST ** 053/R10 CASE-NEWTON DISTRICT 054/R 11 HAZEL ST TRUNK *** 055/R12 HOME AVE DISTRICT 056/R13 MADERIA ST 057/R14 N FORGE ST 058/R15 FOREST HILL DISTRICT 059/R16 WOLF LEDGE TRUNK 060/R17 EXCHANGE ST 061/R18 WILLOW RUN TRUNK 062/R19 W MARKET ST 063/R20 W NORTH ST *** 064/R21 N HOWARD ST 065/R22 NORTH HILL TRUNK 066/R23 N MAPLE ST OUTLET 067/R24 W MARKET ST OUTLET 068/R25 OTTO ST 069/R26 AQUEDUCT ST OUTLET 070/R27 UHLER AVE $$ 071/R28 MEMORIAL PKWY 072/R29 UHLER-CARPENTER 073/R30 CUYAHOGA ST 074/R31 PORTAGE-SUNNYSIDE 075/R32 CARPENTER HEIGHTS 076/R33 NORTHSIDE INTERCEP 077/R34 RIVERSIDE BLVD 078/R35 GORGE BLVD DISTRICT 079/R36 MERRIMAN RD OUTLET 080/R37 BOWERY ST

081/R02(N,S) RETENTION TANK 082/R39 QUAKER ST 083/R40 CUYAHOGA ST R38 S BROADWAY

3 4 5 0 3 2 Elim. 5 5 4 0 6 4 4 4 2 3 ++ ++ ++ 1 4 0 0 $$ 4 5 1 0 3 3 2 5 2 3 0 Elim. 0 1

6 4 9 0 3 2 Elim. 8 10 5 0 22 6 5 4 3 3 ++ ++ ++ 1 6 0 0 $$ 4 6 2 0 4 3 4 6 2 7 0 Elim. 0 1

1.78 0.97 1.29 0.00 0.64 0.17 Elim. 1.26 2.90 2.20 0.00 4.53 1.57 4.31 0.69 1.94 0.76 ++ ++ ++ 0.09 2.60 0.00 0.00 $$ 1.37 4.54 0.31 0.00 1.43 3.42 0.35 2.49 0.57 0.49 0.00 Elim. 0.00 0.17

0.013 0.053 0.013 0.000 0.000 0.000 Elim. 0.010 0.336 0.395 0.000 0.012 0.043 0.168 0.000 2.853 0.017 ++ ++ ++ 0.000 0.041 0.000 0.000 $$ 0.090 0.045 0.025 0.000 0.210 0.064 0.002 0.199 0.001 0.000 0.000 Elim. 0.000 0.000

* (R39) Sewer separation was completed 8/18/2000. ** (R09) Sewer separation was completed 7/27/2004. *** (R11, R20) Backflow from canal and river into the rack/sewer has been seen at these sites in the past. ++ (R21, R22, R20) Units found inoperable. Replacement units ordered. $$ (R27) Unit failed after 8/20/2006. No data since. 000243

ADDITIONAL INFORMATION

There were no dry weather overflows during the month of September 2006.

000244

CITY OF AKRON, OHIO
WET WEATHER COMBINED SEWER OVERFLOWS AUGUST 2006
TOTAL DURATION IN HOURS CODE:80999

STATION NUMBER3PFOOOOO

NUMBER OF DAYS CODE:

NUMBER OF EVENTS 80998

VOLUME IN MILLION GALS CODE: 50050

046/R03 S ARLINGTON ST DIST 047/R04 MILL ST 048/R05 RIVER ST 049/R06 FACTORY ST 050/R07 S CASE AVE 051/R08 N CASE AVE-DUBLIN ST 052/R09 WILLIAMS ST ** 053/R10 CASE-NEWTON DISTRICT 054/R11 HAZEL ST TRUNK *** 055/R12 HOME AVE DISTRICT 056/R13 MADERIA ST 057/R14 N FORGE ST 058/R15 FOREST HILL DISTRICT 059/R16 WOLF LEDGE TRUNK 060/R17 EXCHANGE ST 061/R18 WILLOW RUN TRUNK % 062/R19 W MARKET ST 063/R20 W NORTH ST *** 064/R21 N HOWARD ST 065/R22 NORTH HILL TRUNK 066/R23 N MAPLE ST OUTLET 067/R24 W MARKET ST OUTLET 068/R25 OTTO ST 069/R26 AQUEDUCT ST OUTLET 070/R27 UHLER AVE $$ 071/R28 MEMORIAL PKWY 072/R29 UHLER-CARPENTER 073/R30 CUYAHOGA ST 074/R31 PORTAGE-SUNNYSIDE 075/R32 CARPENTER HEIGHTS 076/R33 NORTHSIDE INTERCEP 077/R34 RIVERSIDE BLVD 078/R35 GORGE BLVD DISTRICT 079/R36 MERRIMAN RD OUTLET 080/R37 BOWERY ST 081/R02(N,S) RETENTION TANK 082/R39 QUAKER ST 083/R40 CUYAHOGA ST R38 S BROADWAY

3 4 5 0 3 2 Elim. 5 5 4 0 6 4 4 4 2 3 ++ ++ ++ 1 4 0 0 2 4 5 1 0 3 3 2 5 2 3 0 Elim. 0 1

6 4 9 0 3 2 Elim. 8 10 5 0 22 6 5 4 3 3 ++ ++ ++ 1 6 0 0 2 4 6 2 0 4 3 4 6 2 7 0 Elim. 0 1

1.78 0.97 1.29 0.00 0.64 0.17 Elim. 1.26 2.90 2.20 0.00 4.53 1.57 4.31 0.69 1.94 0.76 ++ ++ ++ 0.09 2.60 0.00 0.00 0.14 1.37 4.54 0.31 0.00 1.43 3.42 0.35 2.49 0.57 0.49 0.00 Elim. 0.00 0.17

0.013 0.053 0.013 0.000 0.000 0.000 Elim. 0.010 0.336 0.395 0.000 0.012 0.043 0.168 0.000 2.853 0.017 ++ ++ ++ 0.000 0.041 0.000 0.000 0.000 0.090 0.045 0.025 0.000 0.210 0.064 0.002 0.199 0.001 0.000 0.000 Elim. 0.000 0.000

* (R39) Sewer separation was completed 8/18/2000. ** (R09) Sewer separation was completed 7/27/2004. *** (R11, R20) Backflow from canal & river into rack/sewer has been seen at these sites in the past. % (R18) Unit failed 2/14/06. Unit repaired 8/23/2006. ++ (R21, R22, R20) Units found inoperable. Replacement units ordered. $$ (R27) Unit failed after 8/20/2006. No data since. 000245

ADDITIONAL INFORMATION

There were no dry weather overflows during the month of August 2006.

000246

Sep 12 06 04:01 p

Akron Waler - Admin

330-376-2072
Brian M. Gresser, P.E.
Water PoDutiDn Control Administrator

Randall A Monteith, P.E. Pilots Administrator

Andre L. BlaylocK
Business Services Administrator

James L Six, P.E. Water Supply Adm',nistrator

DONALD l. PLUSQUELLIC Mayor
Gerald Holland, Director DEPARTMENT OF PUBLIC SERVICE Michael L. McGlinchy, P.E. PUBLIC UTILITIES BUREAU MANAGER

VIA FACSIMILE (614-644-2745)

Seplember 12, 2006 Ms. J. Hodanbosi Ohio Environmental Protecljon Agency Division of Surface Wa1er 122 South Front Street Columbus, OH 43215 RE>: Public RE>cords Request NPDES Pennit for the City of Akron Wastewater Treatment Plant 2460 Akron-Peninsula Road, Akron, Summit County, Ohio 44313 OEPA Draft Pennit No. 3PFOOOO[l'LD Application No. OH0023833 Public Notice No. 06-1)8-066

Dear Ms. Hodanbosi: Pursuant 10 Ohio Revised Code Chapter 149, this letter serves as a written requesllo review ali records in the custody of the Ohio Environmenlal Prolection Agency ("Ohio EPA") Division of Surface Water related to the' following: (1) the above-referenced draft permit; and/or (2) the Iota I maximum daily loads ("TMDLs") for the Middle and Lower Cuyahoga River. This pUblic records requesl includes, but is not limited la, copies of ali data, reports, notes, correspondence, working files, electronic files, approvals, all recQrds pertaining tQ sampling data that were used to establish effluent limits and conditions in lhe above-referenced draft permit, all records related to the preparatiQn and issuance ofTMDLs for the Middle and Lower Cuyahoga River and olher records, whether contained in written, electronic Dr other format or media, either submitted tQ or generaled by the Ohio EPA that in anyway reialesto the draft permit or TMDLs. Please contact me at lhe address below or by phQne at 330-375-2627 when lhese records are available for review. In the meantime, if you have any quesnons regarding this request, please feel free to contact me. Thank you in advance fQr your assistance with lhis matter. Sincerely,

'\ :/~':,-; .::~::.'>,:-::~.~:.Randail A Monleith, Pilots Administrator

,'/? ':; -:::;:'-~;:f' /' ).;:.-_<~".,c.( h- / /,...i;.;<.--('·~/l.-..-'\.

PE

RAM:pt c: G. Bozeka, M. McGlinchy
146 S, High Street. Room 9DD • Akron, Ohio 44309. (330) 375-2627 • FAX (330) 375-2072 wv."w.ci.akron.oh. us

000247

From: To: Date: Subject:

Paul Novak Randy Monteith 9/25/200611:51:33 AM Re: Request for extension of comment period

Randy - as we had discussed, Ohio EPA will extend the comment period on the NPDES permit an additional 45 days. The final date for comments on the draft permit will be Close of Business November 13,2006 Please call with any questions. »> "Monteith, Randy" <MonteRa@ci.akron.oh.us> 9/15/2006 11 :36 AM »> Paul,

We are attempting to meet your 30 day comment period but we are having difficulty gathering all the information needed to adequately prepare our comments. We have submitted records requests to Region 5, the Northeast district and the Central office. The only response we have received to date is from the central office via a fax dated September 13 that stated:

"received your FOIA fax re: Akron WWTP and TMDLs; takes - 2 weeks to pull info and then need to have our Legal Office review it - will contact you when ready for review"

The message was from Jhodanbo (Jo) at fax #614-644-3020.

We want to be able to submit all appropriate comments but, without the additional time originally requested, and the delays inherent in reviewing the records, we will be unable to provide detailed comments on the draft permit for reasons beyond our control. Therefore I must repeat our Service Director's request for a 90 day extension to December 28, 2006.

Please inform us of your response at the earliest possible date.

Thank you.

Randall A. Monteith, P.E. Pilots Administrator

000248

Randall A. Monteith, P.E. Piiots Administrator Andre L. Blaylock Business Services Administrator

Brian M. Gresser, P.E. WPC Plant Administrator James L. Six, P.E. Water Supply Piant Administrator

DONALD L. PLUSQUELLIC
Mayor Gerald Holland, Director DEPARTMENT OF PUBLIC SERVICE Michael L. McGtinchy, P.E. PUBLIC UTILITIES BUREAU MANAGER

December 13,2005 Ohio EPAlDivision of Surface Water Pennit Compliance Unit!Attn: Kemper Lazarus Govennnent Center P.O. Box 1049 Columbus, Ohio 43216-1049 Subject: Self-Monitoring Report I am herewith transmitting the November 2005, report for the City of Akron monitoring points 3PF0000046 through 3PF0000083. Enclosed also are the results ofbiomonitoring testing in November. I am also enclosing an amended report for Station 3PF00000601 for October 2005. That report did not include a maximum pH value that I am now reporting. The Ohio Monthly Report Fonn (EPA 4500) reports for monitoring points 3PFOOOOOOO 1, 3PF00000583, 3PF00000585, 3PF00000586, 3PF00000601 through 3PF00000604, 3PF00000801 through 3PF00000806, 3PF00000901, and 3PF00000904 are being transmitted electronically in the SWIMware fonnat. Sincerely,

Brian M. Gresser, P.E., Plant Administrator Water Pollution Control Division BMGIDBC:mld Enclosures c: Michael McGlinchy File

/owW~

Akron Water Pollution Control. 2460 Akron Peninsula Road. Akron, Ohio 44313. (330) 928·1164 • FAX (330) 928·2285 000249 www.ci.akron.oh.us

ADDITIONAL INFORMATION

There was one dry weather overflow during the month of November 2005. This was event 0511-77-4438 at Rack 15 on November 3,2005. This overflow resulted from a leaf buildup on the rack and lasted 1.28 hours with an overflow volume less than 500 gallons (0.000 mgal). An incident report dated November 10, 2005 was sent to OEPA.

000250

CITY OF AKRON, OHIO
WET WEATHER COMBINED SEWER OVERFLOWS NOVEMBER 2005
TOTAL DURATION IN HOURS CODE:80999

STATION NUMBER 3PFOOOOO

NUMBER OF DAYS CODE:

NUMBER OF EVENTS 80998

VOLUME IN MILLION GALS CODE: 50050

046/R03 S ARLINGTON ST DIST 047/R04 MILL ST 048/R05 RIVER ST 049/R06 FACTORY ST 050/R07 S CASE AVE 051/R08 N CASE AVE-DUBLIN ST 0521R09 WILLIAMS ST ** 0531R10 CASE-NEWTON DISTRICT 054/R11 HAZEL ST TRUNK *** 055/R12 HOME AVE DISTRICT 056/R13 MADERIA ST 057/R14 N FORGE ST 058/R15 FOREST HILL DISTRICT 059/R16 WOLF LEDGE TRUNK 060/R17 EXCHANGE ST 061/R18 WILLOW RUN TRUNK 062/R19 W MARKET ST 063/R20 W NORTH ST *** 064/R21 N HOWARD ST 065/R22 NORTH HILL TRUNK *% 066/R23 N MAPLE ST OUTLET 067/R24 W MARKET ST OUTLET 068/R25 OTTO ST + 069/R26 AQUEDUCT ST OUTLET 070/R27 UHLER AVE 071/R28 MEMORIAL PKWY 072/R29 UHLER-CARPENTER 073/R30 CUYAHOGA ST 074/R31 PORTAGE-SUNNYSIDE 075/R32 CARPENTER HEIGHTS 076/R33 NORTHSIDE INTERCEP 077/R34 RIVERSIDE BLVD 078/R35 GORGE BLVD DISTRICT 079/R36 MERRIMAN RD OUTLET 080/R37 BOWERY ST 081/R02(N,S) RETENTION TANK 0821R39 QUAKER ST 083/R40 CUYAHOGA ST R38 S BROADWAY

4 4 4 0 3 1 ** 4 4 4 0 5 4 4 2 4 2 ++++ 0
*%

6 11 9 0 7 1 ** 8 6 6 0 11 5 5 2 6 2 ++++ 0
*%

1 5 + 3 1 +++ 4 1 2 4 ++ 3 4 2 1 0 * 0 3

1 24 + 8 5 +++ 9 1 4 5 ++ 6 6 3 1 0 * 0 4

5.36 4.00 2.93 0.00 1.37 0.11 .* 6.64 3.55 3.02 0.00 6.42 1.55 6.45 0.54 4.76 0.38 ++++ 0.00 *0/0 0.06 3.56 + 2.70 0.79 +++ 3.58 0.17 2.99 3.41 ++ 2.91 2.19 3.13 0.10 0.00 * 0.00 3.13

0.031 0.Q18 0.059 0.000 0.010 0.000 ** 0.027 0.896 0.475 0.000 0.138 0.016 5.112 0.016 8.259 0.044 ++++ 0.000
*%

0.000 0.080 + 0.000 0.003 +++ 0.024 0.009 0.020 0.130 ++ 0.098 0.158 0.025 0.001 0.000 * 0.000 0.069

* (R39) Sewer separation was completed 8/18/2000. ** (R09) Sewer separation was completed 7/27/2004. *** (R11, R20) Backflow from canal and river into the rack/sewer has been seen at these sites in the past. + (R25) Power turned off January 13 for rack relocation, partial separation. ++ (R33) Sensor was found inoperable. No data. +++ (R28) Unit failed 9/4/05. No data since. ++++ (R20) Out of service since 1011/05. *% (R22) Out of service since 10/1/05. 000251

Michael L. McGllnchy. P.E. Public Utilities Bureau Manager Richard A. Merolla Service Director Brian M. Gresser. P.E. Water Pollution Control Administrator

DONALD L PLUSQUELLiC Mayor

December 17.2008

Ohio EPA/Division of Surface Water Permit Compliance Unit/Attn: Ed Swindall Lazarus Government Center P.O. Box 1049 Columbus, Ohio 43216-1049 Subject: Self-Monitoring Report am herewith transmitting the November 2008. report for the City of Akron monitoring points 3PF0000046 through 3PF0000084.
J

Enclosed also are results of bio-monitoring testing in November. The Ohio Discharge Monitoring Report (eDMR) (EPA 4500) reports for monitoring points 3PF00000001. 3PF00000583,3PF00000585. 3PF00000586,3PF00000601 through 3PF00000604. 3PF00000801 through 3PF00000806. and 3PF00000901 are being submitted electronically in the eDMR format. Sincerely,

{,irJ;fM\ IVV~~/
Brian M. Gresser. P.E.• Plant Administrator Water Pollution Control Division BMG/GLS:jmn Enclosures c: Michael McGlinchy File

2460 Akron Peninsula Road. Akron, Ohio 44313. (330) 928-1164. FAX (330) 928-2285 lNWW.ci.akron.oh.us

000252

CITY OF AKRON, OHIO
WET WEATHER COMBINED SEWER OVERFLOWS NOVEMBER 2008
TOTAL DURATION IN HOURS CODE:80999

STATiON NUMBER 3PFOOOOO

NUMBER OF DAYS CODE:

NUMBER OF EVENTS 80998

VOLUME IN MILLION GALS CODE: 50050

046/R03 S ARLINGTON ST DIST 047/R04 MILL ST 048/R05 RIVER ST 049/R06 FACTORY ST 050/R07 S CASE AVE 051/R08 N CASE AVE-DUBLIN ST 0521R09 WILLIAMS ST 2 053/R10 CASE-NEWTON DISTRICT 054/R11 HAZEL ST TRUNK 3 055/R12 HOME AVE DISTRICT 056/R13 MADERIA ST 057/R14 N FORGE ST 058/R15 FOREST HILL DISTRICT 059/R16 WOLF LEDGE TRUNK 060/R17 EXCHANGE ST 061/R18 WILLOW RUN TRUNK 062/R19W MARKET ST 063/R20 W NORTH ST 3 064/R21 N HOWARD ST 065/R22 NORTH HILL TRUNK 066/R23 N MAPLE ST OUTLET 067/R24 W MARKET ST OUTLET 068/R25 OTTO ST 069/R26 AQUEDUCT ST OUTLET 070/R27 UHLER AVE 071/R28 MEMORIAL PKWY 072/R29 UHLER-CARPENTER 075/R32 CARPENTER HEIGHTS 076/R33 NORTHSIDE INTERCEP 077/R34 RIVERSIDE BLVD 078/R35 GORGE BLVD DISTRICT 079/R36 MERRIMAN RD OUTLET 080/R37 BOWERY ST 081/R02(N,S) RETENTION TANK 082/R39 QUAKER ST 1 083/R40,31,30 Cuyahoga St. Storage Fac. 084/R38 S BROADWAY
1

4

8

a
3

a
3

o
2

a
2

a
Elim. 2

a
Elim.

1 1

5 1 1

a
5
5 2

a
14 5 2

o
2

a
2

a
2

a
2

a
4 7 3

a
10 15

6

o
o
a a
1 1 5 1

a

a
a

a
1 1 13

1

o
a a

o
a

o
Elim.

a a
Elim.

o o

a

a

4.12 0.00 073 0.00 0.55 0.00 Elim. 2.84 0.72 0.64 0.00 842 1.12 2.23 0.00 1.17 000 0.68 000 10.15 17.63 2.82 0.00 000 0.00 0.00 0.88 0.31 13.66 0.94 000 0.00 0.00 000 Elim. 000 0.00

0.000 0.000 0.006 0.000 0000 0000 Elim. 0.021 0.036 0.040 0000 0.176 0.000 0.062 0000 0.992 0.000 0.019 0.000 2.978 0.014 0.026 0.000 0000 0.000 0.000 0.001 0000 0.042 0.009 0000 0000 0.000 0.000 Elim. 0000 0.000

2

(R39) Sewer separation was completed 8/18/2000. (R09) Sewer separation was completed 7/27/2004. 3 (R11, R20) Backfiow from canal and river into the rack/sewer has been seen at these sites in the past. 083 (R30,R31,R40) Overfiows flow into new retention tank after 10/17/2006. ADDITIONAL INFORMATION
There was one dry weather overflow in November 2008. On November 12, a sewage discharge to Alder Creek was discovered. The discharge occured as a result of a hole in a sanitary sewer where the pipe was partially collapsed. The sewage leached through the soil to the surface and ran into Alder Creek. This overflow was reported as incident #0811-77-4357. Please see letter to Ohio EPA, NEDO dated November 21, 2008 from the City of Akron for more information regarding this event

The November 2008 Wet Weather Combined Sewer Overflows Report does not include data for Rack 22 for November 1 -10 due to construction of the new rack and transfer of the telemetry equipment from the old site to the new one.

000253

CITY OF AKRON, OHIO
WET WEATHER COMBINED SEWER OVERFLOWS AUGUST 2006
NUMBER OF DAYS CODE: NUMBER OF EVENTS 80998
TOTAL DURATION IN HOURS CODE:80999

STATION NUMBER 3PFOOOOO

VOLUME IN MILLION GALS CODE: 50050

046/R03 S ARLINGTON ST DIST 047/R04 MILL ST 048/R05 RIVER ST 049/R06 FACTORY ST 050/R07 S CASE AVE 051/R08 N CASE AVE-DUBLIN ST 052/R09 WILLIAMS ST ** 053/R10 CASE-NEWTON DISTRICT 054/R11 HAZEL ST TRUNK *** 055/R12 HOME AVE DISTRICT 056/R13 MADERIA ST 057/R14 N FORGE ST 058/R15 FOREST HILL DISTRICT 059/R16 WOLF LEDGE TRUNK 060/R17 EXCHANGE ST 061/R18 WILLOW RUN TRUNK % 062/R19 W MARKET ST 063/R20 W NORTH ST *** 064/R21 N HOWARD ST 065/R22 NORTH HILL TRUNK 066/R23 N MAPLE ST OUTLET 067/R24 W MARKET ST OUTLET 068/R25 OTTO ST 069/R26 AQUEDUCT ST OUTLET 070/R27 UHLER AVE $$ 071/R28 MEMORIAL PKWY 072/R29 UHLER-CARPENTER 073/R30 CUYAHOGA ST 074/R31 PORTAGE-SUNNYSIDE 075/R32 CARPENTER HEIGHTS 076/R33 NORTHSIDE INTERCEP 077/R34 RIVERSIDE BLVD 078/R35 GORGE BLVD DISTRICT 079/R36 MERRIMAN RD OUTLET 080/R37 BOWERY ST 081/R02(N,S) RETENTION TANK 082/R39 QUAKER ST 083/R40 CUYAHOGA ST R38 S BROADWAY

3 4 5

o

6 4 9

o

3 2
Elim.

3 2
Elim.

5 5 4

8
10

o

o
22 6 5 4 3 3
++ ++ ++
1

5

6 4 4 4 2 3 ++ ++ ++
1

1.78 0.97 1.29 0.00 0.64 0.17 Elim. 1.26 2.90 2.20 0.00 4.53 1.57 4.31 0.69 1.94 0.76

0.013 0.053 0.013 0.000 0.000 0.000 Elim. 0.010 0.336 0.395 0.000 0.012 0.043 0.168 0.000 2.853 0.017

++ ++ ++
0.09 2.60 0.00 0.00 0.14 1.37 4.54 0.31 0.00 1.43 3.42 0.35 2.49 0.57 0.49 0.00 Elim. 0.00

++ ++ ++
0.000 0.041 0.000 0.000 0.000 0.090 0.045 0.025 0.000 0.210 0.064 0.002 0.199 0.001 0.000 0.000 Elim. 0.000 0.000

o o
2 4 5

4

o o
2 4 6 2

6

o
3 3 2 5 2 3

1

o

o
1

4 3 4 6 2 7

o o
1

Elim.

o

Elim.

0.17

* (R39) Sewer separation was completed 8/18/2000. ** (R09) Sewer separation was completed 7/27/2004. *** (R11, R20) Backflow from canal & river into rack/sewer has been seen at these sites in the past. % (R18) Unit failed 2/14/06. Unit repaired 8/23/2006. ++ (R21, R22, R20) Units found inoperable. Replacement units ordered. $$ (R27) Unit failed after 8/20/2006. No data since.

000254

ADDITIONAL INFORMATION

There were no dry weather overflows during the month of August 2006.

000255

CITY OF AKRON, OHIO
WET WEATHER COMBINED SEWER OVERFLOWS SEPTEMBER 2006
TOTAL DURATION IN HOURS CODE:80999

STATION NUMBER 3PFOOOOO

NUMBER OF DAYS CODE:

NUMBER OF EVENTS 80998

VOLUME IN MILUONGALS CODE: 50050

046/R03 S ARLINGTON ST DIST 047/R04 MILL ST 048/R05 RIVER ST 049/R06 FACTORY ST 050/R07 S CASE AVE 051/R08 N CASE AVE-DUBLIN ST 052/R09 WILLIAMS ST ** 053/R10 CASE-NEWTON DISTRICT 054/R11 HAZEL ST TRUNK *** 055/R12 HOME AVE DISTRICT 056/R13 MADERIA ST 057/R14 N FORGE ST 058/R15 FOREST HILL DISTRICT 059/R16 WOLF LEDGE TRUNK 060/R17 EXCHANGE ST 061/R18 WILLOW RUN TRUNK 062/R19 W MARKET ST 063/R20 W NORTH ST *** 064/R21 N HOWARD ST 065/R22 NORTH HILL TRUNK 066/R23 N MAPLE ST OUTLET 067/R24 W MARKET ST OUTLET ST 068/R25 069/R26 AQUEDUCT ST OUTLET 070/R27 UHLER AVE $$ 071/R28 MEMORIAL PKWY 072/R29 UHLER-CARPENTER 073/R30 CUYAHOGA ST 074/R31 PORTAGE-SUNNYSIDE 075/R32 CARPENTER HEIGHTS 076/R33 NORTHSIDE INTERCEP 077/R34 RIVERSIDE BLVD 078/R35 GORGE BLVD DISTRICT 079/R36 MERRIMAN RD OUTLET 080/R37 BOWERY ST 081/R02(N,S) RETENTION TANK 082/R39 QUAKER ST 083/R40 CUYAHOGA ST R38 S BROADWAY

ono

3 4 5 0 3 2 Elim. 5 5 4 0 6 4 4 4 2 3 ++ ++ ++ 1 4 0 0

6 4 9 0 3 2 Elim. 8 10 5 0 22 6 5 4 3 3 ++ ++ ++ 1 6 0 0

1.78 0.97 1.29 0.00 0.64 0.17 Elim. 1.26 2.90 2.20 0.00 4.53 1.57 4.31 0.69 1.94 0.76 ++ ++ ++ 0.09 2.60 0.00 0.00

0.013 0.053 0.013 0.000 0.000 0.000 Elim. 0.010 0.336 0.395 0.000 0.012 0.043 0.168 0.000 2.853 0.017 ++ ++ ++ 0.000 0.041 0.000 0.000

$$
4 5 1 0 3 3 2 5 2 3 0 Elim. 0 1

$$
4 6 2 0 4 3 4

$$
1.37 4.54 0.31 0.00 1.43 3.42 0.35 2.49 0.57 0.49 0.00 Elim. 0.00 0.17

$$
0.090 0.045 0.025 0.000 0.210 0.064 0.002 0.199 0.001 0.000 0.000 Elim. 0.000 0.000

6
2 7 0 Elim.

a
1

* (R39) Sewer separation was completed 8/18/2000. ** (R09) Sewer separation was completed 7/27/2004. *** (R11, R20) Backflow from canal and river into the rack/sewer has been seen at these sites in the past.

++ (R21, R22, R20) Units found inoperable. Replacement units ordered. $$ (R27) Unit failed atter 8/20/2006. No data since.

000256

ADDITIONAL INFORMATION

There were no dry weather overflows during the month of September 2006.

000257

CITY OF AKRON, OHIO
WET WEATHER COMBINED SEWER OVERFLOWS OCTOBE.R 2006
TOTAL DURATION IN HOURS CODE:80999

STATION NUMBER 3PFOOOOO

NUMBER OF DAYS CODE:

NUMBER OF EVENTS 80998

VOLUME IN MILLION GALS CODE: 50050

046/R03 S ARLINGTON ST DIST 047/R04 MILL ST 048/R05 RIVER ST 049/R06 FACTORY ST 050/R07 S CASE AVE 051/R08 N CASE AVE-DUBLIN ST 052/R09 WILLIAMS ST ** 053/R10 CASE-NEWTON DISTRICT 054/R11 HAZEL ST TRUNK *** 055/R12 HOME AVE DISTRICT 056/R13 MADERIA ST 057/R14 N FORGE ST 058/R15 FOREST HILL DISTRICT 059/R16 WOLF LEDGE TRUNK 060/R17 EXCHANGE ST 061/R18 WILLOW RUN TRUNK
0621R19 W MARKET ST 063/R20 W NORTH ST *** 064/R21 N HOWARD ST 065/R22 NORTH HILL TRUNK 066/R23 N MAPLE ST OUTLET 067/R24 W MARKET ST OUTLET 068/R25 OTTO ST 069/R26 AQUEDUCT ST OUTLET 070/R27 UHLER AVE $$ 071/R28 MEMORIAL PKWY 072/R29 UHLER-CARPENTER 073/R30 CUYAHOGA ST % 074/R31 PORTAGE-SUNNYSIDE % 075/R32 CARPENTER HEIGHTS 076/R33 NORTHSIDE INTERCEP On/R34 RIVERSIDE BLVD 078/R35 GORGE BLVD DISTRICT 079/R36 MERRIMAN RD OUTLET 080/R37 BOWERY ST 081/R02(N,S) RETENTION TANK 082/R39 QUAKER ST 083/R40 CUYAHOGA ST % R38 S BROADWAY

5 4 5

10 7 13

o
4 2
Elim. 6

o

4 5 2 7 5 5 3 4 2 ++ ++ ++
2 4 4 2

6 2 Elim. 11 9 13
2 30 14

7 3
10

2 ++ ++ ++
2 11 12 3

13.59 5.12 11.13 0.00 5.23 0.75 Elim. 24.09 12.58 14.15 1.22 16.49 4.89 16.99 4.26 17.68 4.10

0.361 0.482 0.244 0.000 0.410 0.021 Elim. 0.401 4.977 3.920 0.039 0.331 0.140 0.367 0.095 33.692 0.785

++ ++ ++
0.43 13.76 8.06 4.38

++ ++ ++
0.008 0.391 0.276 0.000

$$
4 6 2 1

$$
7
11 3 2 10 16 12 16

$$
7.45 9.21 3.14 0.79 6.14 12.81 1.96 12.52 10.36 0.91 2.50 Elim. # 3.85

$$
0.276 0.109 0.182 0.181 0.775 0.303 0.015 1.525 0.210 0.017 0.000 Elim. # 0.096

5
6 5 5 3 2 1 Elim. # 2

4 3
1 Elim. # 2

* (R39) Sewer separation was completed 8/18/2000. ** (R09) Sewer separation was completed 7/27/2004.
*** (R11, R20) Backflow from canal and river into the rack/sewer has been seen at these sites in the past. ++ (R21, R22, R20) Units found inoperable. Replacement units received, to be installed in November. $$ (R27) Unit failed after 8/20/2006. No data since. # (R40) ADS monitoring reported no overflows, but overflows were observed 10/17 and 10/27. % (R30,R31,R40) Overflows flow into new retention tank after 10/16/2006. Tank overflow monitoring is still being installed and calibrated. 000258

ADDITIONAL INFORMATION

As a result of the 1.99 inches of rainfall on October 17,2006, the storm overflow pump at the Mud Run pump station started 23 times and ran a total of2.6 hours pumping about 468,000 gallons of sewage into Mud Run Ditch. The Little Cuyahoga retention tank has been constructed and is in the final stages of programming to finalize the controls and inflow and overflow monitoring. Combined sewer Racks 30 and 31 as well as Rack 40 overflow into the tank as of October 16, 2006. The full tank volume was captured on October 17 and October 27 which was pumped back to the sewer for treatment, but the tank overflows to the river was not monitored as the programming is not completed yet. There were no dry weather overflows during the month of October 2006.

000259

3PFOOOOO MAJOR City of Akron WWTP 2460 Akron Peninsula Road Akron, OH 44313

OH0023833

File 3 of 4

I fI! 1 5

Iv! E_A_O-"
000260

No. 2·15~L UPC 10334

State of Ohio Environmental Protection Agency

STREET ADDRESS:
Lazarus Government Center 50 W. Town St., Suite 700 Columbus, Ohio 43215
TELE: (614) 644-3020 FAX: (614) 644-3184 www.epa,$tate.oh.u$

MAILING ADDRESS: P.O. Box 1049 Columbus,OH 43216-1049

August 7, 2007 Richard Merolla, Service Director City of Akron 203 Municipal Building 146 South High Street Akron, OH 44308 Dear Mr. Merolla Based on our discussions with U.S. EPA we understand that you will be performing 5 stress tests of the entire Akron Wastewater Treatment Plant between now and mid-2008. Ohio EPA acknowledges that some violations of permit limits may occur during the stress testing as the limits of operation are determined. We will consider these factors in our data tracking and use appropriate discretion in reviewing the plant's compliance status. The stress test must be conducted to maintain sufficient solids and effective biomass in the treatment plant so that the plant returns to its normal operating status as soon as possible after the completion of each test event. Please notify the Northeast District Office as soon as possible in advance of the beginning and end of each stress test event. Sincerely,

o

~'/ e ,/"-{- ~//11 co<

r?:",t, J----

George Elmaraghy, P.E., Chief Division of Surface Water
GE/EN

cc:

Sandy Cappotto, NEDO/DSW Paul Novak Margaret Malone, AGO

Ted Strickland, Governor lee Fisher, Lieutenant Governor Chris Korleski, Director

@

Printed on Recycled Paper

Ohio EPA is an Equal Opportunity Employer

000261 ®~"7

222 SOUTH MAIN STREET

I~ANDRESS II
A LEGAL PROFESSIONAL ASSOCIATION

AKRON,OH44308 330.849.6605 DiRECT 330.376.2700 MAIN 330.376.4577 FAX

tfinn@,)"alaw.com

January 22, 2007

VIA FEDERAL EXPRESS Ohio Environmental Protection Agency Attention: Division of Surface Water Permits and Compliance Section Lazarus Government Center 50 West Town Street, Suite 700 Columbus, OH 43215 Re: City of Akron's Comments to Ohio EPA's August 28, 2006 Draft Permit OEPA Draft Permit No. 3PFOOOOO*LD Application No. OH0023833 Public Notice No. 06-08-066

REC'D JAN 23 2007
Dear Sir or Madam: The City of Akron (the "City") submitted written comments to the abovereferenced draft NPDES permit on November 13, 2006. The following is a supplement to the City's comments. At the time the City submitted its comments, the City was in the process of preparing an additional No Feasible Alternatives ("NFA") Analysis for the secondary bypass of the City's water pollution control station and a Financial Assessment and Affordability Analysis. A copy of the NFA analysis, along with part one of the City's Financial Assessment and Affordability Analysis was provided to Paul Novak on December 29,2006. The City expects to complete part two of its Financial Assessment and Affordability Analysis by February 15, 2007. Once completed, the City will provide part two of its Financial Assessment and Affordability Analysis to Ohio EPA. The additional NFA Analysis and part one of the Financial Assessment and Affordability Analysis are part of the City's CSO Long Term Control Plan and, thus, are also incorporated into the City's comments to the above-referenced draft NPDES permit. Once completed, part two of the City's Financial Assessment and Affordability

CLEVELAND

TOLEDO

AKRON

COLUMBUS

ClNCINN,m

WASHINGTON, D.C.

TALLAHASSEE

ORlANDO

FORT MYERS

NAPLES

www.ralaw.com

000262

Ohio EPA January 22, 2007 Page 2

Analysis will also become part of the City's Long Term Control Plan, and incorporated into the City's comments to the above-referenced draft NPDES permit. Thank you for your consideration of this supplement to the City's comments. If you have any questions or need anything further, please do not hesitate to contact me. Sincerely, ROETZEL & ANDRESS, LPA

//"v
TSF/sju cc: Peggy Malone

_./(./1--------v Terrence S. Finn

A 0-1

1397861 v_a! \016756.0006

000263

Randall A. Monteith, P.E. Pilots Administrator Andre L Blaylock Business Services Administrator

Brian M. Gresser, P.E. Water Poliution Control Administrator

James L. Six, P.E. Water Supply Administrator

DONALD L. PLUSQUELLIC Mayor
Gerald Holland, Director DEPARTMENT OF PUBLIC SERVICE Michael L. McGlinchy, P.E. PUBLIC UTILITIES BUREAU MANAGER

December 18, 2006

Mr. Paul Novak, Manager Permits & Compliance Section Division of Surface Water Ohio Environmental Protection Agency P. O. Box 1049 Columbus, OH 43216-1049 Dear Mr. Novak:
~-·"i

Thanks again for arranging the November 29, 2006, conference call in which the parties discussed the City of Akron's comments to the draft NPDES permit for the City's Water Pollution Control Station. The City also appreciates the fact that the Ohio EPA will keep the comment period open for any additional City comments. During the conference call, Gary Stuhlfauth requested the City's most recent toxic),ty data. In response to this request, I have enclosed copies of the quarterly toxicity '-! reports dated 7/27/2005, 11/30/2005, 211612006, 5/18/2006, 7/21/2006, and 11/27/2006 for Gary's review. (I believe that this data was previously submitted as part of the MOR process.) We appreciate Gary's willingness to review this additional data. Hopefully, Ohio EPA will agree that the chronic toxicity limits that were included in the draft permit should be removed and replaced with a monitoring only requirement. If you or Gary require copies of the toxicity reports for periods prior to those submitted, please let me know. To assist in your consideration of our comments, I have also attached csa information for August, September and October of this year. As discussed, this information is submitted to the Ohio EPA as part of the City's monthly operating reports. The City believes that the CSOs have been adequately characterized, and that the information that is currently submitted is more than sufficient for monitoring and reporting purposes. Hopefully you will come to the same conclusion as you review the attached information. Consistent with the City's prior comment, the provision within the draft permit for future monitoring and reporting of CSOs should be drafted in a manner that is similar to the
146 S. High Street. Room 900. Akron, Ohio 44308. (330) 375-2627 • FAX (330) 375-2072 WW\N.cLakron.oh.us

000264

Mr. P. Novak December 18, 2006 Page 2 provision in the City's 1994 permit. In addition, the City should also be permitted to continue to submit this data to the Ohio EPA in the attached format. During our conference call, you informed us that you intend to have one of the Ohio EPA's modelers evaluate the changes in the flow conditions within the Cuyahoga River and determine if the limitations within the draft permit need to be revised based upon this more recent data. Please let me know if Ohio EPA needs any further information from the City regarding this review and evaluation process. As discussed, the City will provide Ohio EPA with a copy of the NFA report when it is complete. We are still on schedule to complete the report by the end of December. It is our understanding that the Ohio EPA does not plan to issue a response to the City's comment letter until after Ohio EPA has reviewed and evaluated the NFA report. Again thank you for agreeing to keep the comment period open as we continue to gather and supply information for your consideration. Sincerely,

RAM:pt Attachments c: Gary Stuhlfauth (Ohio EPA) F/NPDES

S:\Dept\Service\PUB Administmtion\Randy\2006-12-18 Oepa additional info ram pt.doc

000265

222 SOUTH MAIN STREET

AKRON, OH 44308

I_ANDRESS II
A LEGAL PROFESSIONAL ASSOCIATION

330.849.6605 DIRECT 330.376.2700 MAIN 330.376.4577 FAX tfinn@ralaw,com

November 13, 2006

VIA HAND-DELIVERY Ohio Environmental Protection Agency Attention: Division of Surface Water Permits and Compliance Section Lazarus Government Center 122 South Front Street Columbus, OH 43215 Re:

ffC'IJ NO V18 l006

City of Akron's Comments to Ohio EPA's August 28,2006 Draft Permit OEPA Draft Permit No. 3PFOOOOO*LD Application No. OH0023833 Public Notice No. 06-08-066

Dear Sir or Madam: The following comments to the above-referenced draft NPDES permit, which was public-noticed by Ohio EPA on August 28, 2006 (the "Draft Permit"), and the accompanying Fact Sheet are being submitted on behalf of the City of Akron, Ohio ("Akron" or the "City"). Attached to this letter, and incorporated by reference herein, is a copy of the Draft Permit with the City's proposed revisions. The proposed revisions appear in redlined text. Some of the proposed revisions are merely corrections to minor typos, paragraph references and similar types of changes. There are additional changes that are more substantive in nature. While the majority of the proposed revisions should be self-explanatory, a more detailed explanation of most of the proposed revisions is set forth, below. In addition to proposed revisions, the City's comments also includes several requests for clarification and explanation. For Ohio EPA's convenience, the following comments and/or explanations contain corresponding references to the respective permit terms and conditions.

CLEVELAND

TOLEDO

AKRON

COLUMBUS

CINCINNATI

WASHINGTON, D.C.

TALLAHASSEE

ORLANDO

FORT MYERS

NAPLES

000266
www.ralaw.com

Ohio EPA November 13, 2006 Page 2

General Comments 1. As recognized in the Ohio EPA's Fact Sheet, the City submitted its CSO Long Term Control Plan in 1998, along with updates in 2000 and 2002 (the "Long Term Control Plan"). The City is still waiting for the approval of the Long Term Control Plan. The Long Term Control Plan was submitted pursuant to U.S. EPA's 1994 CSO Control Policy (the "1994 CSO Control Policy"), and Section 402(q) of the Clean Water Act, which requires that each permit issued for a CSS must comply with the 1994 CSO Control Policy. Thus, it would be unreasonable and unlawful to renew the City's NPDES permit before the approval of the Long Term Control Plan. 2. The comment period provided for the City to review the Draft Permit and associated materials, retain consultants, study the issues, draft the comment letter and submit them to the agency is insufficient. Indeed, the City only recently was given access to Ohio EPA and U.S. EPA records. Moreover, after reviewing the available documents, it appears that the City may not have received all of the documents associated with the Draft Permit. In order to provide the City with an adequate opportunity to evaluate and analyze these documents and confirm that it has received all of the requested documents, the City requests an additional sixty (60) day extension to the comment period. In the event that Ohio EPA fails to extend the comment period, the City reserves all rights to supplement the following comments. 3. Ohio EPA has violated Ohio procedures requiring that the agency issue a proposed permit which would then allow an adjudication hearing prior to issuance of the final permit. 4. Ohio EPA has unlawfully and unreasonably failed to consider technical feasibility, economic reasonableness and expected benefits in issuing this permit as required by Ohio R.C. Section 6111.03(J). It is unlawful and unreasonable for Ohio EPA to impose schedules of compliance for various permit limitations and activities, including studies, which are technically infeasible or economically unreasonable to meet or which fail to take account of reasonable periods for study or construction, including, but not limited to, (1) design work, (2) easement acquisitions, (3) the bidding, awarding and execution of contracts and (4) the need to obtain permits to install. 5. Several statements within the Fact Sheet are inaccurate. The City is under no obligation to comment upon or point out each and every inaccurate statement. Akron does not admit that any statement within the Fact Sheet is accurate.

1373454 v _o5 \ 016756.0006

000267

Ohio EPA November 13, 2006 Page 3

6. In each table within the Draft Permit, the term loading has an asterisk next to it. However, there is no explanation or definition provided. The City requests clarification. 7. The flow conditions stated in the Fact Sheet are incorrect and not applicable to current Cuyahoga River configuration/conditions. Thus, the aquatic life waste load allocations ("WLAs") used to determine effluent limits and WLAs used to determine whole effluent toxicity (including dilution ratios) are set too low. A more detailed discussion is provided on page 12. I.

Part I, A.
1. Interim Effluent Limitations and Monitoring Requirements for 3PF000000001

A. The acute and chronic toxicity monitoring requirements should be removed and placed in the chart in Part I, A. Interim Effluent Limitations and Monitoring Requirements for 30F000000602.
It is not clear why the Whole Effluent Toxicity monitoring location is proposed to be moved from its existing permitted location (602) to the final outfall channel (001). It does not seem probable that Ohio EPA expects that any scenarios where storm water, combined sewage and other wet weather flows that would receive primary treatment would be expected to be in attainment of a Chronic Whole effluent criterion. The goal of the 1994 CSO Control Policy is to improve water quality by providing additional capture and primary equivalent treatment of combined sewage flows. If those flows were captured and treated at a remote location they would not receive secondary treatment and would not be expected to meet a whole effluent waste load allocation based standard. The 1994 CSO Control Policy provides that "CSOs are not subject to secondary treatment requirements applicable to POTWs." 59 FR 18688, 18689 (April 19, 1994). As set forth above, an NPDES permit for a CSS must comply with the 1994 CSO Control Policy. Notably, the previous permit required acute toxicity testing at the final outfall (during bypass events) for a period of two years and all chronic testing was conducted on effluent collected at 602. Even if an additional treatment system is implemented at the WPCS it is likely that wet weather flows will not receive secondary equivalent treatment under all conditions and will therefore have the potential to have measurable WET result. Given the sensitivity of Ceriodaphnia dubia to road salt and other pollutants commonly found in storm water, measurement of Chronic WET in the final effluent channel will result in

1373454 v~05 \ 016756.0006

000268

Ohio EPA November 13, 2006 Page 4

increased detection of toxicity from these sources in the event that bypass occurs at some point during the week long chronic sampling period. While Akron does not agree to the requirements for, or the implementation schedule of a high rate treatment system for the current secondary bypass flows, Akron is concerned that if such a system is implemented it has the potential to increase the likelihood of measured toxicity in the final effluent. Recent studies performed on Actiflo and Densi-deg systems have documented both acute and chronic effects that may be related to application of additional polymer in those systems. No studies have been performed (to our knowledge) on those treatment systems that demonstrate that their effluent can consistently meet the WLA requirements proposed for C. dubia in Akron's permit. The manufacturers of those systems have not been able to provide our consultants with any studies that show their systems do not cause effluent toxicity to sensitive aquatic life. Regardless of the implementation of proposed CSO controls, Akron feels that WET testing should continue to be monitored at the existing monitoring location in order to measure the potential for continued attainment of the current status where no violations of the proposed WLA standards have been documented.

B. In the notes section, the months in which "quarterly-tox 1" monitoring occurs should be revised. The City should have the flexibility to select the month within each quarter based upon plant operations.

2.

Final Effluent Limitations and Monitoring Requirements for 3PF000000001

A. The chronic toxicity monitoring requirements should be removed and placed in the chart in Part I, A final Effluent Limitations and Monitoring Requirements for 3PF00000602. See the comments in IA of the response letter. B. The chronic toxicity limits should not be included in this permit.

Ohio EPA has not clearly demonstrated, documented or defined reasonable potential for the Akron WPCS effluent to cause instream toxicity. The justification and definition of reasonable potential provided in the permit and fact sheet is not consistent with the data and does not consider the relevant facts reported in the tests completed for the City of Akron WPCS effluent monitoring station. While low level chronic toxicity has been measured in the effluent of the Akron plant it has occurred in less than 20% of samples over the last five years. The observed effects have been low level chronic reproductive effects on Ceriodaphnia dubia with no significant mortality to C. dubia and
1373454 v _o5 \ 016756.0006

000269

Ohio EPA November 13, 2006 Page 5

no fish effects. The performance of stream macroinvertebrates downstream of the WPCS indicates attainment of applicable biocriteria. No chemical criteria associated with chronic toxicity have been violated by the plant effluent. On page 7 of the Fact Sheet Ohio EPA determines that the waste load allocation (WLA) for chronic toxicity is 1.09 TU c . The Fact Sheet does not clearly elucidate the derivation for that value and the referenced guidance does not clarify the methodology used to determine this WLA. Given the subjective nature of toxicity testing Ohio EPA should provide explicit derivation of calculation in or appended to the Fact Sheet. Until the City has received and had time to review such documentation, the City maintains this objection and reserves its right to appeal. According to Federal Guidance presented in the "Technical Support Document for Water Quality-based Toxics Control (EPA/505/2-90-001)" as referenced in the Ohio EPA fact sheet and to the guidance in Procedure 6 of OAC 3745-33-07(B)(10) which is referenced to 40 C.F.R. § 132 Appendix F, Ohio EPA has not used the appropriate parameters for their calculation of reasonable potential. The Fact Sheet states that Ohio EPA used a Coefficient of variation (CV) of 0.6 to calculate the wasteload allocation of Chronic Toxicity. Appendix F of 40 C.F.R. § 132 states that "when there are 10 (or1 ) more individual WET tests, the multiplying factor taken from Table F6-1 of this procedure shall be based on a CV calculated as the standard deviation of the WET tests divided by the arithmetic mean of the WET tests". The actual CV of the TUc results presented in Table 4 would be 0.18 which results in a multiplying factor of 1.2 (using a CV of 0.2 rounded up from 0.18 with an n of 13 tests) from Table F6-1. The calculation of reasonable potential should then be: Highest observed TUc (1.6) X Multiplying Factor (1.2) X effluent flow/downstream flow (based on Ohio EPA dilution ratio of 1.3 to 1 = (0.77»= 1.48 The value for PEQ of 1.9 TUc in the Fact Sheet is therefore elevated and inconsistent with the procedure in Part 132. However that value is still higher than what Ohio has proposed as the wasteload allocation for Chronic toxicity of 1.09TUc (since the second decimal place is not a significant digit in TUc calculations this should be rounded to 1.1). However, it is important to note that two of the measured values for chronic toxicity in Table 4 occurred in February and the third in November. All three of these samples were collected during periods when river flow was more than three times greater than 7Q10 flows and the two February samples were collected during winter
1

The "or' was apparently omitted as a typographic error in the statute, but is inferred from the preceding sentence which states "Where there are less than 10 individual WET tests ... "

1373454 v _o5 \ 016756.0006

000270

Ohio EPA November 13, 2006 Page 6

weather. The November sample was also collected during a period when NOM weather records indicate some recorded snowfall at Northeast Ohio Stations. As set forth below, all of these events occurred at times when the results could have been affected by road way deicing activities. It is also important to note that far field samples (collected outside of the mixing zone) showed no evidence of chronic toxicity in samples collected during the same period as the effluent tests. A review of the laboratory reports for each of the tests provides some indication that helps identify the potential cause of the toxicity and a strong indication that the effluent does not have a reasonable potential to violate was or the wasteload allocation for Chronic Toxicity. The sample showing the highest toxicity (1.6 TUc) was collected (February 3, 5, and 7 th 2003) during a period of cold weather and in fact the river upstream of the plant was frozen so that an upstream sample was not collected. Conductivity of that sample was measured in the three February 2003 samples between 1894 j..Imhos/cm and 2470 j..Imhos/cm averaging more than double the conductivity of typical Akron effluent (around 900 j..Imhos/cm). These facts suggest that road salt from deicing operations has likely contributed to the reproductive effects seen in the test. City records indicate road salt activity occurred three times during that week in 2003. The other February test shows a less pronounced toxicity effect (TUc 1.1) and also a lower conductivity value (between 1244 j..Imhos/cm and 2160 j..Imhos/cm). The November 2004 test shows a slightly elevated conductivity range (1080 j..Imhos/cm to 1181 j..Imhos/cm) and an intermediate level of toxicity (TUc 1.4). City records do not show salting activity directly during these two test periods but the observed effect might be related to road salt applied during previous days or weeks. Weather records indicate precipitation and near freezing temperatures in early November 2004. Flows in the River during this November period as measured at the Old Portage Gauging station indicate flow from 300 to 460 cfs (193 to 297 MGD) which is equivalent to a dilution ratio of > 3 to 1. While there is no direct measure of road salt in the Akron system as a potential toxicant, sodium chloride produces reproductive toxic effects in Ceriodaphnia at a conductivity range of 800 to 900 j..Imhos/cm since that is the range that is bracketed in the Standard reference toxicant tests performed by toxicity testing laboratories routinely to test the consistency of their test organisms from month to month. Laboratories use Salt as a reference toxicant because it is readily available, relatively safe and produces a consistent toxic effect. It is Akron's position that the effects observed in the effluent from their treated combined sewage are potentially an effect of road salt rather than any other potential toxicants in the waste stream.

1373454 v _o5 \ 016756.0006

000271

Ohio EPA November 13, 2006 Page 7

Given the absence of any measured far field effect (measured directly in far field screening tests2 ) and the relatively low values of the measured chronic effects it does not appear that Ohio EPA has any evidence to support the position that there is reasonable potential for Akron's effluent to violate the waste load allocation for Chronic toxicity. In addition we have reviewed Ohio EPA's public comment draft permit condition with regard to the proposed WET limit as these limits are set under Ohio law (despite U.S. EPA's objection to the use of biocriteriaas a final arbiter of water quality attainment the Ohio regulations makes several assessments that are valid in the determination of reasonable potential). For the reasons described below, Akron believes that Category 3 or 4 of Table 1 in OAC Rule 3745-33-07 more accurately describes Akron WPCS's effluent, that is, that toxicity is "possible" or "none" rather than "adequately documented." 40 C.F.R. Part 132, Appendix F, Procedure 6 allows the permitting agency the flexibility to determine what is valid and representative data in the first instance, before applying the statistical multipliers in the procedure. Both the preamble to the final GLI regulation and the Supplemental Information Document made it clear that states retain the discretion to determine what constitutes valid and representative data. See 65 Fed. Reg. at 47873 ("Section D of Procedure 6 is neutral with respect to the validity of particular pieces of WET data ..."); See also SID at page 405 ("an implicit and obvious premise in the ... WET procedure is that the WET data used to project maximum effluent quality are valid data that are representative of the effluent.") U.S. EPA has recently (and emphatically) underscored this point in the brief defending its position to the Sixth Circuit Court of Appeals against the recent challenges to U.S. EPA's veto of Ohio's reasonable potential procedure for WET. The City urges Ohio EPA to discard these isolated, low level reproduction numbers (with no corresponding mortality indicated in the same chronic tests) as non-representative outliers. If that is done, no reasonable potential is indicated and neither limits nor monitoring for WET should be required. In addition to not being the best use of limited resources, we believe that the "weight of the evidence" supports the finding that toxicity at Akron WPCS is, at best, "possible." Evidence from 2006 testing indicates that the toxicity may now fall in the "none" range. While Akron does not dispute that some toxicity has been detected and meets some of the criteria for "possible" documentation, other data suggests that the
2

No significant difference between far field sample and control in any of the three tests where toxicity was observed in effluent.

1373454

v~05

\016756.0006

000272

Ohio EPA November 13, 2006 Page 8

toxicity has been detected on an intermittent basis and there is no clear relationship to attainment of biological criteria in the Cuyahoga River. Nor is there any evidence from the existing toxicity testing of a chronic effect in the far field (outside the chronic mixing zone) samples. The percent of tests in excess of the WLA in all recent test has decreased for all endpoints since the analysis performed on tests prior to May of 2005. Given the WLA of 1.09 TU c and 0.38 TU a the actual percent exceedance should be:

Ceriodaphnia dubia (Cladoceran "water flea") Chronic • 3 of 18 valid tests 16.66% (reproduction endpoint) • 0 of 18 valid tests 0% (survival endpoint) • Acute 0 of 18 valid tests 0% Pimephales promelas (fish) Chronic • 0 of 18 valid tests 0% (growth endpoint) • 0 of 18 valid tests 0% (survival endpoint) Acute $ 0 of 18 valid test 0%
Of the chronic endpoints, NONE exceed the 30% criteria that supports "adequate" documentation, and 1 is in the range of 10-20% supporting an analysis of a "possible" degree of toxicity. No endpoints for acute toxicity of either species or for chronic toxicity of fish exceed the WLA. On average. this evidence suggests a downward trend towards "none" toxicity rather than the "strong suspicion" of toxicity that is required in Ohio EPA guidance for implementation of a toxicity limit in permits. Of the 5 tests performed in 2005 and 2006 (not included in Ohio EPA analysis which appears to have collected only data prior to May of 2005) no tests indicated any chronic effect. Table 1 of 3745-33-07 indicates that reasonable potential be determined by evaluation of a series of attributes. It is not clear from the proposed permit or from the fact sheet prepared by Ohio EPA how reasonable potential was justified according to the procedure defined by Ohio rules in this table. The geometric mean of exceedences is <.5 times the WLA. Nearfield mortality of Ceriodaphnia dubia has not been observed. farfield mortality has also not exceeded control levels and did not co-occur with the instances of reproductive effects listed in Table 4 of the fact sheet. The available

1373454 v _o5 \ 016756.0006

000273

Ohio EPA November 13, 2006 Page 9

documentation of instream effects strongly suggests that there is no chronic impact on macroinvertebrate communities (Ceriodaphnia dubia is used as a test organism to indicate potential effects on instream macroinvertebrates). Ohio EPA, in the Fact Sheet, states that "2000 results show significant improvement since 1996... Macroinvertebrates improved from 'fair' to 'very good.'" No biocriteria data more recent than 2000 are cited in the fact sheet. Given the absence of measured biological effects (attainment of macroinvertebrate biocriteria measured more than 5 years ago) it is difficult to imagine that toxicity is characteristic of the Akron WPCS effluent. As stated above, the weight of evidence contains indications of a range of toxicity problems from "none" to "possible" documentation. Including current results in the analysis show a complete lack of "adequate" documentation of toxicity in the effluent. Therefore, the toxicity limitations within the Draft Permit should be removed, and replaced with a monitoring only requirement. Finally, without waiving the foregoing objection to the toxicity limitation, the City notes there is a conflict between the monthly limit and quarter sampling frequency requirement in the Draft Permit. C. The "quarterly-tox 1" monitoring timeframes should be revised. See comments in 1B of this letter.

3. Interim Effluent Limitations and Monitoring Requirements for 3PF000000602

A. Please note that the City is also objecting to the final effluent limitations for 3PF000000602 (See Below). In the event the City's objection is overruled, the City will need seventy two (72) months to meet the final effluent limitations for 3PF000000602.
B. defined. C. The City of Akron requests that the frequency of oil and grease sampling be consistent with the current permit. The City of Akron currently samples twice per month (once between day 1 and 14 and once between 15 and 28). Notably, the City of Akron has had no' violations for oil and grease exceedances. D. In the notes section, the flow measurement should be revised to account for actual metering at the WPCS. As a result, the flow measurement should be The City of Akron requests clarification of the term "residue" be

1373454 v _o5 \ 016756.0006

000274

Ohio EPA November 13, 2006 Page 10

based upon summation of metering readings measuring flow from aeration basins one through six. 4. Final Effluent Limitations and Monitoring Requirements for 3PF000000602 A The City is also objecting to the final effluent limitations for 3PF000000602. To the extent that the final effluent limitations and monitoring requirements differ from the interim effluent limitations and monitoring requirements, the final effluent limitations and monitoring requirements should begin seventy two (72) months from the effective date of this permit consistent with the City's comments above. B. Consistent with the comments for the interim effluent limitations and monitoring requirements, the City of Akron requests that the term "residue" be defined. C. Consistent with the comments for the interim effluent limitations, the City of Akron requests that the frequency of oil and grease sampling be consistent with the current permit. The City of Akron currently samples twice per month (once between day 1 and 14 and once between 15 and 28). Notably, the City of Akron has had no violations for oil and grease exceedances. D. The City objects to the effluent limits for phosphorus, CBOD and ammonia nitrogen. If not changed or omitted, the effluent limits should be in summer only. Phosphorus The draft permit proposes to lower the existing concentration limits for Total Phosphorus from 1.5 mgll (weekly) and 1.0 mg/I (monthly) to 0.65 mg/I (weekly), with no monthly limit. It also proposes to lower Total Phosphorus loading from 511 kg/day (weekly) and 341 kg/day (monthly) to 221 kg/day (weekly), with no monthly limit. Both of these changes are scheduled to become effective 36 months from the effective date of the permit. According to the Fact Sheet, at pages 6 and 9 and Table 10, the final effluent limits for Phosphorus were based on results of the September, 2003 report on Total Maximum Daily Loads for the Lower Cuyahoga River (the "2003 TMDL Report") and were calculated to meet the wasteload allocation ryJLA) for Phosphorus in that report. The City objects to the imposition of the final limits for Phosphorus for the same reasons set forth in its August 28, 2003 comments on Ohio EPA's 2003 TMDL Report. A complete copy of those comments, along with the expert report of Dr. Robert Singer

1373454 v _o5 \ 016756.0006

000275

Ohio EPA November 13, 2006 Page 11

of Metcalf & Eddy regarding the "Effect of Lake Rockwell Watershed Management on Water Quality in the Middle Cuyahoga River" was submitted to Ohio EPA by letter dated August 28, 2003 from Jeff Fusco to Bill Zawiski. Both the City's comments and the accompanying report by Dr. Singer are hereby incorporated in their entirety into the City's comments on Draft NPDES Permit No. 3PFOOOOO*LD. Technical Issues. As explained more fully in the City's comments on the 2003 TMDL Report, the concept that quantitative reduction of Phosphorus concentration at the low values present in much of the Lower Cuyahoga River will result in measurable improvement in the biocriteria is a poorly supported and untested hypothesis. The 1999 Ohio EPA technical bulletin, the "Associations Report" upon which the TMDL for phosphorus is premised, has been heavily criticized for logical and statistical flaws. The Associations Report is based on tautological reasoning and does not provide quantitative support for the phosphorus concentration targets chosen. In the 2003 TMDL Report and in the Associations Report, relatively weak correlations between phosphorus concentration and aquatic community performance to imply causation are used. Since many of the metrics of the aquatic community scoring system were developed (according to Ohio EPA biocriteria manuals) to measure or "indicate" nutrient enrichment, it is inevitable that a correlation will exist between these numbers. Yet in no way is there sufficient quantitative experimental data to show that a regression relationship (one variable is independent and the other variables value is directly dependent on the first) exists where biocriteria scores are caused by (dependent on) the concentration of Phosphorus in streams. The only mechanism that can demonstrably link nutrient (phosphorus) concentration to biocriteria performance is dissolved oxygen deficits caused by excessive algal growth. 3 The Ohio EPA Associations Report contains no significant sampling of algae or any other measures of photosynthesis or primary production in relation to sites where

3 In contrast to the focus on phosphorus, the City of Akron has documented a direct relationship between

the observed Dissolved Oxygen deficits and CBOD concentrations in the stream, through a combination of continuous monitoring, sampling and modeling of sources of CBOD in the watershed. Observed deficits were readily accounted for by modeled CBOD sources. Carbonaceous Biological Oxygen Demand measures the process of respiration as aerobic organisms consume organic material. Since much of that activity is from microorganisms other than algae, it is not clear what mechanism Ohio EPA is proposing that produces a direct nutrient limitation or phosphorus dependency. The sampling of chlorophyll performed by City of Akron and the other biological studies of the river do not indicate that over productive or eutrophic conditions are the principal factors in creating low dissolved oxygen for brief periods in the Lower Cuyahoga River. The Draft, as well as the foundation Associations Report, lack the evidence to support a credible TMDL based on phosphorus.

1373454 v _o5 \ 016756.0006

000276

Ohio EPA November 13, 2006 Page 12

the reported relationship between phosphorus concentration and biological scores is described. The Associations Report simply does not support the allegation that reduction in phosphorus will result in improved biocriteria. A TMDL that is not based on sound science or legal authority is neither reasonable nor lawful, and cannot be used as the basis for imposing effluent limitations in the City's NPDES permit. While the Phosphorus targets are certain to result in excessive expenditures for municipalities, improvement based on the targets identified in the 2003 TMDL Report are far from certain. Due to the lack of certainty, there is not a sufficient basis for including the phosphorus limit within the permit. The phosphorus targets set in this TMDL are the equivalent of guessing and hoping. As a general matter, the dynamics of interactions between the different forms of Phosphorus and assimilation in river systems are not well understood. Thus, as the City of Akron stated in its comments on the draft report, the adoption of a Phosphorus TMDL should have been postponed awaiting further sufficient scientific and technical foundation to determine if a causative relationship between phosphorus and biocriteria actually exists. Additional Concerns, In addition to the issues raised in the City's August 28, 2003 comment letter, the load allocations and WLAs in the 2003 TMDL Report were inappropriate for a number of reasons. As explained in the Singer report, Lake Rockwell should not have been characterized as a "source" or been assigned a load allocation in the TMDL because it is actually a net sink or trap for Phosphorus and suspended solids. Concentrations of nutrients and suspended solids are higher above Lake Rockwell, and higher below outfalls from downstream wastewater treatment plants, than in the reservoir and immediately below it. A number of studies indicate that, instead of being a source of nutrients, Lake Rockwell functions to remove nutrients. The improper characterization of the Lake Rockwell Release in the TMDL's existing source load allocation results in an inappropriate WLA for the City of Akron POTW. Furthermore, the 2003 TMDL Report did not properly account for changes in lowflow conditions resulting from the Lake Rockwell and Mogadore releases, as well as from recent repairs to leaking sewer lines that previously allowed approximately 6 mgd of flow to escape from the river during dry weather conditions. In fact an analysis of the USGS data from the Old Portage Gage (used by Ohio EPA to define upstream 7010 critical flows) shows that in the most recent 10 year period the average low flow for any 7 day period was not less than 63 cfs, which is 12 cfs (or about 7 mgd) greater than the critical low flow value of 51.5 cfs used by Ohio EPA in their calculation of load limitations, Though the most recent ten year period is not as statistically representative as the 70+ year period of record analyzed by Ohio EPA, as a practical matter the more recent ten year period is more representative of the current state of the watershed because it accounts for improvements made to infiltrating sewers, increased releases

1373454

v~05

\ 016756,0006

000277

Ohio EPA November 13, 2006 Page 13

from upstream impoundments and other watershed changes which apparently have increased the baseflow in the stream. The location of the Old Portage Gage represents the best available upstream data, and is also conservative in that flow at that gage does not include flow from the Sand Run and Mud Brook watersheds. While those two watersheds may not contribute a large proportion of flow they will generally provide some additional flow upstream of the Akron WWTP discharge point. Legal Issues. Ohio EPA is not required to implement the WLA from the 2003 TMDL Report in Akron's NPDES permit because U.S. EPA's approval of the TMDL was unlawful. Section 303(d) of the Federal Clean Water Act provides U.S. EPA with the authority to approve a TMDL that is "established a level necessary to implement the applicable water quality standards." Because the State of Ohio does not have an applicable water quality standard for Phosphorus, U.S. EPA's approval of the 2003 TMDL Report was unlawful and exceeded the scope of U.S. EPA's statutory authority. Even if this were not the case, Ohio EPA cannot implement the TMDL because it has not incorporated the 2003 TMDL Report into its continuing planning process as required by Sections 303(d)(2) and 303(e) of the Clean Water Act. Cost of Phosphorus Removal. The WPCS already has infrastructure in place to provide continuous chemical precipitation treatment for phosphorus. Based on the influent/effluent phosphorus concentrations for 2000 to September 2006, we believe the increase in annual operating costs (chemical and sludge disposal costs) will be $273,000. This represents an approximate one percent increase in user rates. This cost to users is unwarranted and unjustified. CBOD and Ammonia Nitrogen The draft permit proposes to lower the weekly average concentration limits for CBOD 5 day from 15 mg/I to 10 mg/1. It also proposes to lower the weekly average CBOD 5 day loading from 5110 kg/day to 3407 kg/day. (There is no change in the monthly average concentration or loading limits.) This change is scheduled to become effective 36 months from the effective date of the permit. According to the Fact Sheet, at page 6, the water quality-based effluent limits for CBOD5 were determined as part of the dissolved oxygen water quality modeling conducted for the 2003 TMDL Report. For that reason, the proposed effluent limits for CBOD5 suffer from many of the same errors that render the proposed Phosphorus limits unlawful and unreasonable, as discussed above. The City objects to the proposed reduction in loading limits for GBOD5 and Ammonia. Neither of these load reductions properly account for pollutant load reductions that are expected to occur as the result of implementation of the City's GSa
] 373454 v _o5 \ 016756.0006

000278

Ohio EPA November 13, 2006 Page 14

long term control plan. Because the impact of those reductions on dissolved oxygen conditions in the receiving stream is unknown at this time, no reduction in the permitted load from the wastewater treatment plant should be required before further sampling and evaluation of the changes resulting from the CSO control measures can be performed. Finally, any limits for CBOD5 included in the permit should be specified as effective only during the summer months of June through September. As stated in the Fact Sheet at page 9, the final effluent limits for Ammonia-N and CBOD5 were calculated in order to maintain the instream water quality criterion of 5.0 mgll for dissolved oxygen "during the summer." There is no rational basis for imposing these limits during the winter months. II. Part I, B.

1. ssa Monitoring Effluent Limitations and Monitoring Requirements for 3PF00000300 A. The Draft Permit incorrectly defines sanitary sewer overflow ("SSO''). Consistent with other sections within the Draft Permit, the definition of SSO should be revised to limit it to overflows, spills, releases and diversions of wastewater from the sanitary sewer system into waters of the state. B. Clarification is required to establish what is expected of City personnel in terms of monitoring the collection system for SSOs. City personnel cannot practicably monitor every foot of every sewer line 24 hours per day. 2. Sludge Monitoring Requirements for 3PF00000584

A. The first note should be revised to provide that monitoring is only required when sludge is removed from the wastewater treatment facility and disposed of as exceptional quality ("EQ") sludge, as opposed to composted material. 3. Siudge Monitoring Requirements for 3PF00000586

No additional comments (other than those included in the general comments) at this time.

1373454

v ~05

\ 016756.0006

000279

Ohio EPA November 13, 2006 Page 15

4.

Influent Monitoring Requirements for 3PF00000601

No additional comments (other than those included in the general comments) at this time. 5. Bypass Monitoring Limitations and Monitoring Requirements

A. The introductory paragraph should be revised as follows to be consistent with current permit and other introductory paragraphs in the Draft Permit:
During the period beginning on the effective date of this permit and lasting until the expiration date, the permittee is authorized to discharge in accordance with the following limitations and monitoring requirements from station: 3PD00000603 only when plant peak influent flows exceed 110 MGD and the flow equalization pumping capacity is being maximized due to storm related events and activities.** See Part II, OTHER REQUIREMENTS, for locations of effluent sampling. B. The chart should be revised to require flow rate monitoring during all months of the year instead of quarterly. C. The City has made a no feasible alternatives ("NFA") analysis for the secondary bypass in accordance with the provisions of the U.S. EPA's 1994 CSO Policy. The City, however, is in the process of updating its NFA analysis at U.S. EPA's direction. As a result, the third note in the note section should be revised as follows: When the plant peak influent flow exceeds 110 MGD and the flow equalization pumping capacity is being maximized due to storm related events and activities the permittee shall be deemed to meet the conditions of 40 C.F.R. § 122.41(m) and Part III, Item 11. D. As set forth above, the City has performed a NFA analysis for the secondary bypass in accordance with 1994 CSO Policy. This analysis, which is currently being updated by the City at U.S. EPA's direction, proVides for an adequate justification of the secondary bypass in accordance with the 1994 CSO Policy. On page 8 of the Fact Sheet there is a statement that Station 603 will be eliminated when certain CSO projects become operational. There is no such proposal within the City's LTCP.

1373454 v_OS \ 016756.0006

000280

Ohio EPA November 13, 2006 Page 16

In addition, the Fact Sheet conflicts with the provisions of the Draft Permit. As a result, the statement should be eliminated from the Fact Sheet. 6. Upstream Monitoring Requirements for 3PF00000801

A. The "quarterly-tox 1" monitoring timeframes should be revised. (See comments at 1.1.B of this response letter).
7. Downstream-AIM Monitoring Requirements for 3PF00000901

No additional comments (other than those included in the general comments) at this time. III. Part I, C. Schedule of Compliance A. Municipal Pretreatment Schedule

The first paragraph should be revised to require the program modification request or technical justification to be submitted no later than 15 months from the effective date of the permit. Depending upon the effective date of the permit, the City will need additional time to collect and evaluate the samples. B. Municipal Pretreatment Schedule - Mercury

No additional comments (other than those included in the general comments) at this time. C. Tributary Community Permit Program

The paragraph should be revised as follows: Not later than March 15 of each calendar year, the permittee shall submit a report that summarizes the status of each tributary community during the previous calendar year based upon information provided to the permittee by the tributary communities. The report shall include a summary of bypasses and overflows which occurred during the previous twelve months as reported to permittee by tributary communities. The report shall be submitted to the Ohio EPA, Northeast District Office. The permittee is not responsible for the completeness or the veracity of the

1373454 v_05 \ 016756.0006

000281

Ohio EPA November 13, 2006 Page 17

information it communities.

receives

from

each

of

the

satellite

D. Schedule to Meet Final Effluent limits (Please note that this heading has been modified) The City does not believe the limits in the final table are necessary, appropriate, reasonable or lawful. (See above). However, without waiving its objection to these limits, if these limits are included in the final permit, the City needs additional time in order to comply with the limits. The deadline in the second paragraph must be extended to at least 24 months. The deadline in the third paragraph must be extended to at least 48 months. The deadline in paragraph 3(c) must be extended to at least 72 months. The deadline in paragraph 4 must be extended to at least 72 months. E. Wastewater Treatment Plant and Sewer System Improvements

The Draft Permit includes a compliance schedule for three CSO projects, which are identified as: a 20 Million Gallon Storage Basin; a Sewer Separation Project; and a High Rate Sedimentation System (which is assumed to mean an Additional Treatment Process). As recognized in the Fact Sheet, the City's LTCP has yet to be approved, and negotiations are still ongoing. It is unlawful and unreasonable to require the installation of these projects prior to the approval of the LTCP. Within the Fact Sheet, Ohio EPA states that these projects would be required regardless of the alternatives that are ultimately included within the LTCP. There is no basis for this statement. In light of the current status of the negotiations, it is premature to predict which projects will be part of the approved LTCP. Since the statement is wrong, it should be stricken from the Fact Sheet. In addition to the above, the LTCP does not provide for a "High Rate Sedimentation System." The City did make a conditional offer to study and install an "Additional Treatment" process at three possible locations. Since the conditions associated with that offer have not been met, the Additional Treatment process cannot be considered to be part of the LTCP.

1373454 v _o5 \ 016756.0006

000282

Ohio EPA November 13, 2006 Page 18

Even if the conditions for Additional Treatment had been met, it is premature to select a specific type of additional treatment, let alone determine the capacity or implementation schedule for such an option. In addition to the reasons set forth above, the City is currently updating its NFA analysis at U.S. EPA's direction. By selecting a specific form of Additional Treatment, along with the capacity and implementation schedule, Ohio EPA is prejudging the outcome of that analysis. Finally, below are cost estimates for an Enhanced High Rate Clarification Process (which is just one example of an Additional Treatment process and has been selected merely for providing a cost estimate) and for a 20 Million Gallon Storage Basin. There is a significant cost associated with each control. In light of the significant costs associated with these controls, and in light of the uncertainties associated with the specific types of controls that will eventually be included within the approved LTCP, it would be economically unreasonable to include a requirement for any LTCP controls within the permit. As a result of the foregoing, the compliance schedule should be deleted.
EHRC Process

The probable project costs for EHRC project are below. The following costs consider an Actiflo process for capital and 0 & M costs and an average annual processed flow of 783 MG (annual average for 2000-2005). • • • 40 MGD Capacity Facility - $10 million Project Cost 100 MGD Capacity Facility - $23 million Project Cost Annual 0 & M to treat 783 MG - $235,000

Storage Basin

The probable construction cost for a WPCS storage basin are based on cost estimates from ARCADIS and other consultant studies prepared from 2000 to 2006. • • 20 MG storage - $27 million Project Cost (Includes flow conduits, pumping station, etc.) Additional 0 & M costs to be calculated.

1373454 v _o5 \ 016756.0006

000283

Ohio EPA November 13, 2006 Page 19

IV.

Part II Other Requirements
Section B. This section should be revised to read as follows: The plant must be adequately staffed and operated to insure compliance with this permit and any applicable permits to install.

Section C. The description of the location of sampling station 3PF00000001 should be revised to read as follows: Downstream of stations 3PF00000602 and 3PF00000603 and prior to plant discharge point, except for dissolved oxygen, which is at the cascade outfal1. 4 The description of the location of sampling station 3PF00000901 should be revised to read as follows: Downstream of plant discharge point at Bath Road Bridge. The description of the location of sampling station 3PF0000584 should be revised as follows: Sludge disposal as exceptional quality material. Section E. The following CSO stations should be removed from the permit because these overflows have been removed from the system: 3PF00000052, 3PF00000073,3PF00000074. The name of station 3PF00000083 should be revised to the following name: Cuyahoga Street Storage Facility/Former Rack 40/30/31. Section F. The following CSO stations should be removed from the permit: 3PF00000052,3PF00000073,3PF00000074. The following reporting code and corresponding monitoring requirements should be removed: 00530 and 80082.
4 The sampling location for dissolved oxygen was approved by a letter to the City from Ohio EPA dated April 6, 1999.

1373454 v _o5 \ 016756.0006

000284

Ohio EPA November 13, 2006 Page 20

The following sentence should be removed because CSOs have been characterized: The permittee shall set up a rotating schedule to sample at least five (5) stations during each storm event. Samples should be collected during the first 30 minutes of discharge. Section G. This section should be revised to identify the City's plan for implementing the Nine Minimum Controls. Specifically, this section should read as follows: The combined sewer system shall be operated and maintained in compliance with the permittee's Nine Minimum Controls Plan submitted on November 1, 1996 and amended on March 18, 1998. Section H. Part 1.6.6 of the draft permit requires the City to report all discharges from station number 3PD00034300. The "measuring frequency" is specified as "when discharging." Station number 3PD00034300 is defined in Part II. H.of the Draft Permit. However, there is no protocol, procedure or guidance provided for inspection frequencies, and no definition is provided to distinguish "sanitary sewers" from "combined sewers" within the City's system. Clarification is required to establish what is expected of City personnel in terms of monitoring the collection system for isolated events that would not otherwise be recorded. City personnel cannot practicably monitor every foot of every sewer line 24 hours per day. Additional clarification is also needed for the requirement for immediate notification of SSOs that "substantially endanger human health" on page 26 of the Draft Permit. Not all SSOs that occur in "high exposure areas" such as waters where primary contact recreation occurs will necessarily endanger human health. For example, the volume of the discharge, the pollutant concentration in the discharge, the time of day and the season in which it occurs can all affect the likelihood of endangerment. A tengallon discharge in a rainstorm in the middle of a winter night is not likely to endanger anyone, even if it is proximate to a bathing beach. Similarly, not all dry weather overflows will substantially endanger human health if they occur in low-exposure areas. Finally, the language in Part II.H at page 26 of the draft permit should be revised, at a minimum, to provide that SSOs that do not reach waters of the state are not considered a reportable occurrence. Section I. The sentence should be revised as follows: The permittee shall maintain in good working order and operate as efficiently as possible the "treatment works" and

1373454 v_OS \016756.0006

000285

Ohio EPA November 13, 2006 Page 21

"sewerage system" as defined in ORC 6111.01 as effective on the date of this permit to achieve compliance with the terms and conditions of this permit. Section L. The City requests that the term "critical value" be defined.

Section M. The sentence should be revised as follows: The discharges that receive secondary treatment must obtain at least 85 percent removal of carbonaceuous biochemical oxygen demand (five-day) and suspended solids (see Part III, Item 1) except in compliance with 40 C.F.R. Part 130. Section O. This section should be removed. The Draft Permit is an NPDES permit issued under the Clean Water Act. As a result, the permit should not implement Resource Conservation and Recovery Act ("RCRA") regulations. Sections Q, R, and S: These sections should be moved and inserted into the footnotes of each table for the Final Effluent Limitations and Monitoring Requirements for 3PF000000601 and 3PF000000602. Section T. The paragraph should be revised as follows because the last phrase which includes the terms "any other actions" is overly broad and goes beyond the Director's authority: All disposal, use, storage, or treatment of sewage sludge by the Permittee shall comply with Chapter 6111 of the Ohio Revised Code, Chapter 3745-40 of the Ohio Administrative Code and any further requirements specified in the NPDES permit. Section BB. paragraph. The words "listed below" should be removed from the first

The columns titled "Description of Modification" and "Date of Approval" should be removed. Section BB(8)(a). The first paragraph should be revised to include the word "calendar" in between "previous" and "quarter."

1373454 v _o5 \ 016756.0006

000286

Ohio EPA November 13, 2006 Page 22

Section CC(3)(a). Based on arguments above, station 3PF00000001 should be removed and replaced with 3PF00000602. The paragraph should be revised to add the following at the end of the paragraph: "in accordance with OAC procedures." Section CC(3)(c). Since the reasonable potential has not been demonstrated for a trigger to initiate a Toxicity Reduction Evaluation ("TRE"), this section should be removed. V. Part III General Conditions 1. Definitions

The definition of "Average weekly" should be revised as follows: "Average weekly" discharge limitation means the highest allowable average of "daily discharges" over a calendar week, calculated as the sum of all "daily discharges" measured during a calendar week divided by the number of "daily discharges" measured during that week. Each of the following 7-day periods is defined as a calendar week: Week 1 is Days 1 - 7 of the month; Week 2 is Days 8 - 14; Week 3 is Days 15 - 21; and Week 4 is Days 22 through the last day of the month. Compliance with fecal coliform bacteria or E coli bacteria limitations shall be determined using the geometric mean. The definition of "quarterly (1/Quarter) sampling frequency" should be revised as follows: "Quarterly (1/Quarter) sampling frequency" means the sampling shall be done in each calendar quarter, unless specifically identified otherwise in the Effluent Limitations and Monitoring Requirements table.

1373454 v_ 05 \ 016756,0006

000287

Ohio EPA November 13, 2006 Page 23

Thank you for your consideration of the foregoing comments and the attached revisions to the Draft Permit. The City would like the opportunity to meet with Ohio EPA to discuss these comments and the City's concerns with the Draft Permit and Fact Sheet. In the meantime, if you have any questions or need anything further, please do not hesitate to contact me. Sincerely, ROETZEL & ANDRESS, LPA
NA-

jr;/J(0

Terrence S. Finn TSFfsju Enclosure

1373454 v_OS \ 016756.0006

000288

Page 1 3PFOOOOO*LD Application No. OH0023833 Issue Date: Effective Date: Expiration Date: 5 years Ohio Environmental Protection Agency Authorization to Discharge Under the National Pollutant Discharge Elimination System In compliance with the provisions of the Federal Water Pollution Control Act, as amended (33 U.S.c. 1251 et. seq., hereinafter referred to as the "Act"), and the Ohio Water Pollution Control Act (Ohio Revised Code Section 6111), City of Akron is authorized by the Ohio Environmental Protection Agency, hereinafter referred to as "Ohio EPA,ll to discharge from the Water Pollution Control Center wastewater treatment works located at 2460 Akron Peninsula Road, Akron, Ohio, Summit County and discharging to Cuyahoga River in accordance with the conditions specified in Parts I, II,

and III of this permit. This permit is conditioned upon payment of applicable fees as required by Section
3745.11 of the Ohio Revised Code.

This pennit and the authorization to discharge shall expire at midnight on the expiration date shown above. In order to receive authorization to discharge beyond the above date of expiration, the permittee shall submit such information and [OnTIS as are required by the Ohio EPA no later than 180 days prior to the above date of expiration.

Joseph P. Koncelik Director
Total Pages: 49

000289

3PFOOOOO*LD Part I, A.. INTERIM EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS 1. During the p'eriod beginning on the effective date of this permit and lasting for a period of 48 months after the effective date, the permittee is authorized to discharge in accordance with the following limitations and monitoring requirements from the following outfall: 3PFOOOOOOOOI . See Part II, OIlIER REQUIREMENTS, for locations of effluent sampling. Table· Final Outfall- 001 . Interim· 001 - Final
--~~.

1~~ia"Tua

/i Ceriodaphnia~

fD;i~: 61425'~AcuteToxic~

i/iJ Deleted: ' ,urge L'" DlSC h umtatlOns Momtormg ReQlnrements .. . I"i'j~eted:. I11I ' Ir=--'--' . Measuring Sampling Monitor)J'rg' ~eted: .
Frequency I/Day Type ContimlOUS

;'ic;el~:.J
~ .~. ,. ~
~ . -I

/ ~Ieted:-

J

I

\

ii'{ Deleted: . i,,',lir---------.. . ..
Effluent CharactClistic

j
J

"-'j

Parameter 00300 - Dissolved Oxygen - mg!!
31616~FecalColifonn-#/lOOml

Concentration Specified Units Maximum Minimum Weekly Monthly 5.0

Loading * kg/day Daily Weekly Monthly

All

2000

1000
_ __L
. __ ' .

lfDay
<
__'f.

Grab
Continuous

50050-FlowRate-MGD

:0060~ChIOrine, TOtalReSidUal~mgll_
v__ -----~" --~

O.~24.
--~,

L

_ _

.

J_

,
--Y

__.l/Da
_v___

1/Day y
_

All

'II Summer ,\It ! I ! r leted VI; ~D~e~~~:~I~IQ~"~'~rt~,,~~~~~

Monthi> / Deleted" _ /:\1/ 1 '

=:J

~UltiPleGrab __ <Summe}~;.<{l>eleted:Q",rtedy.toX]
v_
_'I'--~

\j/~f, Deleted: 24hrComposite

~

Yc___

.J!

v_

__'1'_

1,

.

j

~=~n~a~426-ChrOlUCTOXlCltY,

J.'/0TI:SforStationNu ber3PF00000001: ..
~

rn

.___

__ __ . __ .

.

___~;:>:d"b".TUo
,fill,

Total residual chlorine ~ See Pmi II, Item N.

\,fl\~\\\Gr~: ,i\\
\~<;\ {ileleted: \1<:l\ro;leted:_ 1\1\\,..-111:\\\LE~leted:.
\'1\\\'(;::;::'-

Deleted: ._m

,,--

----,
~

---!'
!

. Whole effluent toxicity - See Part II, Item CC.

1 ,\ \ 1 . . " 1

-I
~

I ,---.J

- "Quarterly-tox 1" monitoring-;,>hal!

?~cur ~~ch calen~3:r qUJI!~r:.

__

m

, \~.~II\\Dei~;.
\

~
~
-om

\
1

\ II\{ Deleted: l/Quarter
,'..

\\ ,I', Deleted:,I'--, _

..

._

-

\ \\ Deleted: 24hrComposite
\ ,,\ Deleted: Quarterly-toxl

I -I
..--'

,

\1 ~eleted: ~_

"'

", .....

..Deleted: months are Januar;, APril~J' fl
L~UIY, and O~tober,

~

"l'1

000290

Page 3 3PFOOOOO*LD Part I, A. - FlNAL EFFLUENT LIMITATIONS AND MONITORlNG REQUIREMENTS 2. During the period begiIllling 48 months from the effective date of this permit and lasting until the expiration date, the pennittee is authorized to discharge in accordance with the following limitations and monitoring requirements from the following outfall: 3PFOOOOOOOl. See Part n, OTHER REQUIREMENTS, for locations of effluent sampling. Table - Hnal Outfall- 001 - Final

Effluent Characteristic Parameter 00300 - Dissolved Oxygen - mg/l 31616 - Fecal Coliform· #/100 lUI 50050 - Flow Rate· MGD 50060 - Chlorine, Total Residual- lUg/I
'1' _

Discharoe Limitations Concentration Specified Units Maximum Minimum Weekly Monthly
5.0

Monitoring Requirements
Loading

* kg/day
Monthly Measuring Frequency l/Day 1IDay liDay
lIDay
v._

Dail

Weekly

y
2000 0.024
.y-'l. _ _ _ _ _

1000

Sampling Type Continuous Grab

·t· - : - -~matted Table ,omonng _.. M Months All Summer

-r )
1

Continuous
Grab

All
Summer
_'L - - -

' ' _ _" Deleted: 61426 - Chronic Toxicity,
/
dUbia-_~ .. ~.~~~_

.:¥ __ ..

'I'

y
_ 'l. -. ,,- __ ..

_ __ -"- - - - -". - - -

,~~~~

Cenodaphnia4

J
J

_~

NOTES for Station Number 3PF00000001:

~:~~~~, ~~~~: -~:~-----~~_ ..._-~~
(/\\

- Total residual chlorine - See Pmi II, Item N.
''------.

q\ \ \{''":::~::::~~~~~~~~~~'"1

I

Deleted: Deleted: ~

1>\:' \

/,\' l\ll
\ \ '\

I~:::::I\

Deleted: l.~ Deleted: -

J
.-=-

I

~

- "Quarterly-tox 1n monitoring shall occur each calendar quarter.

..

, I'" Deleted: _ 1>\ , ,I' Deleted: , '(

_ .J'

~\

Deleted: 1/Quarter Deleted: Quarterly-taxi
Part II, Item ce. ._

" \ \\ \\~-_._- ,~.~._---- .. _--~ .. ~----- ..~I Deleted.: 24hr Composite
)

l,

]

Deleted:'. Whole effluen;toxieity - S~e'l

\

Del~~: m;nth~ a;~"~~ril,-=-l

,J

July, and October.

.....J

000291

3PFOOOOO*LD Part I, A. - INTERIM EFFLUENT LIMITATrONS AND MONITORING REQUIREMENTS
3 ,During the period beginning on the effective date of this permit and lasting for a period of.ll-EI~?!1!hS_~ft~r_t~~ ~lf~c_tiv~ .9~t.~~_t!t~ p~f!~t!~e)§ _ ~ __ - - {Deleted:-36 ] authorized to discharge in accordance with the following limitations and monitoring requirements from the following outfall: - - - . , , - - - - - - . ---

3PF00000602. See Part II, OTHER REQUIREMENTS, for locations of effluent sampling.
Table - Internal Monitoring Station - 602 - Interim

Eftluent Char\!cteristic

Discharge Limitations
Concentration Specified Units Loading

* kg/day
Monthly

Parameter
00010 ~ Water Temperature - C 00300 Dissolved Oxygen - mg/I
¥

Maximum

Minimum

Weekly

Monthly

Daily

Weekly

Measuring Frequency

1/Day IlDay

00335 - Chemical Oxygen Demand (Low Level) • mg/l 00515 ~ Residue, Total Dissolved - mg/! 00530 - Total Suspended Solids - mgll
00550 - Oil and Grease, Total - mgIJ 00610 - Nitrogen, Ammonia (NH3) - mgtl 00610 - Nitrogen, Ammonia (NIB) - mgtl 00610 - Nitrogen, Ammonia (NI-l3) - mgll 00630 - Nitrite Plus Nitrate, Total- mg/l 00665 - PhosphonJs, Total (P) - mg/l 00719 - Cyanide, Free - mg!l 01074 ~ Nickel, Total Recoverable - ugfl01094 - Zinc, Total Recoverable - ugfl 01113 - Cadmium, Total Recoverable - ug!l 01114 - Lead, Total Recoverable - ugfl 01118 - Chromium, Total Recoverable10

l/Day
23 IS 7835 3850
784

Monitoring RemJiremcnts Sampling Monitoring Type Months Maximum Indicating Thennometer All Continuous All Composite All Composite Composite
Qr~~

5110 2555
511

I! 2 Weeks lroay
.z~1~t12

All All

__
.

___ ~Q..
Dec.-Feb. ~ - ~ June-Scp. Mar-May & Oct-Nov

11.3
2.3

7.5
1.5

lroay IlDay 1/Day 1/2 Weeks 2/Weck 1/2 Weeks liMonth IIMonth l/Month l!Month IIMonth

Composite

Compos1tl~

i D'e 'Ieted : Week

-~~.~

----··-----1
~

I

7.1
1.5

4.8
1.0

2419
511

1635
341

Composite Composite Composite Grab Composite Composite Composite Composite Composite Composite 2411r Composite

All All All All All All All All
A_I_I_ _
Onartcr!y-tox 1

ugll
01119 - Copper, Total Recoverable - ug!! 61425 -~ Acute Toxicitv, CeJioctanhnill dnhia -- TUll

000292

000293

Page 5 3PFOOOOO*LD

Effluent Characteristic Parameter
01220 - Chromium, Dissolved Hexavalent - ug/l Maximum Minimum

Discharge Limitations

Concentration Specified Units
Weekly Monthly

Loading * kg/day Daily Weekly Monthly

50050 - Flow Rate - MGD
50092 - Mercury, Total (Low Level) - ngl1

61941 - pH, Maximum - S.U.
61942 - pH, Minimum- S.U. 80082 - CBOD 5 d ·U1WI " 61426 - Chronic Toxicity Ceriod;1uh1Jia duhia- TUe

9.0
6.5
18

'.'

10 'v 1.0

.JJ .• "

5J1O

J ..VI

07

Measuring Frequency LiMonth l/Day lIMonth liDay 1/Day l/Dav

MonitonngReauirements Sampling Monitoring Type Months Grab All Continuous All Grab All Continuous All Continuous All Composite A
24hr Composite
Quarterly~tox 1

l&lliu:lTI

"

LlMlT

QUAR TERLY

NOTES for Station Number 3PF00000602: * Effluent loadings based on average design flow of 90 MOD. - Total residual chlorine - See Part II, Item N. - Nickel, zinc, cadmium, lead, total cbromium and copper - See Part II, Item Q. - Dissolved hexavalent chromium - See Part lI, Item R. - Mercury - See Part II Items R, Y and Z. - Free cyanide - See Part II, Items R and AA - Ammonia-nitrogen, phospborus and CBOD5 - See Schedule of Compliance Item D -. Flow measurement based upon the summation of-p:~t~rln_Kr~~~i~gsJ~~a~Ij~g_fl~~il~9!.1l ae!~t~0!1_b~~i~~_ ~_ througpi5, __
----,. -<:.:- _ -f Deleted: four L.: ,__ Deleted: to

- Whole effluent toxicity - See Part II. Item ce.

"':"-1

) ,

, Deleted: and 2; 3 and 4; 5 and

000294

3PFOOOOO*LD Part I, A. - FINAL EFFLUENT LlMITATIONS AND MONITORING REQUJREMENTS

4. During the period beginningJl,~l~I!.tl!~,,:frC!~ _tl!e_ ~ffe~!,i~~ ~O:.t<:: <?fth~s y~~i! ~c! ta~tin_g_~~!i! !h_e _e.~pix~tLop_d_a!e-,- !.h,,~ ]J_~l~n~i!t~~~? _a~!h_o~~~d_ 19__. _ ~ - -{ Del~ed;}6------.:~~_.J discharge in accordance with the following limitations and monitoring requirements fium the following outfall: 3PF00000602. See Part II,
OTHER REQUIREMENTS, for locations of effluent sampling. Table - Internal Monitoring Station - 602 - Final

Effluent Characteristic

Discharcre Limitations

Monitoring Requirements

Parameter

Concentration Specified Units Maximum Minimum Weekly Monthly

wading * kg/day Daily Weekly Monthly

Measming Frequency

Sampling Type

Monitoring Months

00010 - Water Temperature - C

00300 - Dissolved Oxygen - mg/l
00335 ~ Chemical Oxygen Demand (Low Level) • mgfl 00515 ~ Residue, Total Dissolved - mg!! 00530 ~ Total Suspended Solids ~ mg!1 00552 ~ Oil and Grease, Hexane Extr Method mgll 00610 ~ Nitrogen, Ammonia (NH3) - mgil 00610 - Nitrogen, Ammonia (NH3) - mg/l 00610 ~ Nitrogen, Ammonia (NH3) ~ mg/l

liDay liDay

Maximum Indicating Thclmometer Continuous

All All
All All All
~11 _ ~ .

23
10 113 13 7.1

15

7835

5110

liDay Composite li2 Weeks Composite l!Day Composite .J/M9]~th _ "" _ qr,a~ .. _ _

·1 Del~te(i: yw-~ek ~_.~-~

73

3850 511
2419

2555
1635

lIDay

I/Day
lIDay

4.8

Composite Composite Composite

00630 - Nitrite Plus Nitrate, Total - lUg/I 00665 - Phosphorus, Total (P) - rug/I 00719 - Cyanide, Free - mgJI 01074 - Nickel, Total Recoverable - ugll 01094 ~ Zinc, Total Recoverable - ug/l 01113 - Cadmium, Total Recoverable - ug/l 01114 - Lead, Total Recoverable ~ ug/l 01118 - ChromiulU, Total Recoverable - ug/l
1L
~.

Jr

_

,

1/2 Weeks Composite ____ :y'?V!e_k.. __ ~ C0..1nJ'~~it~ 1/2 Weeks Grab " IlMonth Composlte IIMonth Composite l/Month Composite l/Month Composite lIMonth Composite

Feb. Sep Mar-May & Oct-Nov All ~g -All - ~ - --r:::;::_ ..-.' l Deleted: 221 All All All All All
June~

Dec.

~

{Delet;d7o:6S-.----_._--.-J

..::.:===::.:...

_.

l

~

- - - - - - - - - - - - - - - - -C:,- -[f"T.;ted:~---

J

'1 Formatted: Font: 10 pt.

"". "~J

000295

Page 7 3PFOOOOO*LD

Effluent Characteristic Parameter

Discharge I imitations Concentration Specified Units wading * kg/day Daily Weekly Monthly Maximum Minimum Weekly Monthly

Measuring
Frequency l/Month

Monitoring Requirements Sampling Monitoring

01119 - Copper, Total Recoverable - ugll
01220 - Chromium, Dissolved Hexavalent ugJl 50050 ~ Flow Rate - MOD 50092 - Mercury, Total (Low Level) ~ ng/l 61941 - pH, Maximum - S.D.
v._r.~

Type Composite

Months All

l/Month
l/Day I1Month 1/Day
V.V
..~~

Grab
Continuous Grab Continuous

All
All All All
,

9.0

", ,.. ,,,,,"u,,. -

'.LV.

.... "".","'"",
C'oJn1)ositc 2411f Comnosite

...

80082 CBOD 5 d.i!Y.::.Jllill

15

10

5.110

3407

l!Day

,

.<i1.:!2.2....:....f.Qpic Toxiciw C'eliodaphnia cluhi,,- TUe

lLQlillrlQI

All I Ql1arterlY-tox~~_~
__ -

Deleted mi·~ CBOD 5 day

-EJill

NOTES for Station Number 3PF00000602. * Effluent loadings based on average design flow of90 MGD. - Total residual chlorine - See PaliII, ltem N. - Nickel, zinc, cadmium, lead, total chromiwn and copper - See Part II, Item Q. - Dissolved hexavalent chromium - See Part II, Item R. - Mercury - See Part II Items R, Y and Z. - Free cyanide - See Part II, Items Rand AA. - Ammonia-nitrogen, phospborus and CBOD5 - See Schedule of Compliance Item D
- Flow measurement based upon the summation of four metering readings measuring flow to aeration basins 1 and 2; 3 and 4; 5 and 6. Sampling at station 3PF00000602 for these parameters shall occur one detention time (the time it takes for a volume of water to travel through the treatment plant) after sampling at station 3PF0000060J for the same parameters on the same day.

Sampling for parameters at station 3PF0000060L 3PF00000602 and 3PF00000901 shall occur the same day.

000296

3PFOOOOO*LD Part I, B. - SSO MONITORlNG EFFLUENT LIMITATIONS Al\1J) MONITORlNG REQUIREMENTS
1. SSO Monitoring. During the period beginning on the effective date of this pennit and lasting until the expiration date, the pennittee shall monitor at Station Number 3PF00000300, and report to the Ohio EPA in accordance with the following table. See Part II, OTHER REQUIREMENTS, for location of sampling.

Table - SSO Monitoring - 300 _. Final

Effluent Chamcterisric

Parameter 74062 - Overflow Occurrence· No.Month

Discharge Limitations Concentration Specified Units Loading * kg/day Maximum Minimum Weekly Monthly Daily Weekly Monthly

Monitoring Requirements Measuring Sampling Monitoring Frequency Type Months Vv'hen Disch. Total All

NOTES for Station Number 3PF00000300: - A sanitary sewer overflow is an overflow, spill, release, or diversion of wastewater from a sanitary sewer system to waters of the state'T)}l_e~~ __ ~ __ - ~~~T~-overflows shall be monitored when they discharge. "'-~- --~-~ ,:, ~~r"f.!1~ p~?~e_~(c9~:mting_o~~l~T!:~g~s.! ~~ch }~~a!i9Ij 9~ ~e_~~~i!a!y ~~~e!'"~y~te::~ _~h_e~e:_the perrni~tee positiv~ly identi:0e.~ D1'1t,t!1l?f_e }~, ~ _ ~ __ ~ overflow, spill, release, or diversion of wastewater on a given day that enters waters of the state is counted as one occurrence. For example, if on a given day overflows occur from a manhole at one location and from a damaged pipe at another location and they both enter waters of the state, record two occurrences for that day, If overflows from both locations continue on the following day, record two occurrences for the following day. At the end ofthe month, total the daily occurrences and report this number in the first column of the first day of the month on the 4500 Ponn (Monthly Operating Report). If there are no overflows during the entire month, report "'zero" (0). - All sanitary sewer overflows are prohibited except under emergency conditions where the overflow occurs in full compliance with all of the provisions of 40 CFR I22.4I(m) and Part III Item II ofthis NPDES pemit.

,-------.-.-.
-I

'-~----I

II

Deleted:'1

.__~

000297

Page 9 3PFOOOOO*LD Part I, B. - SLUDGE MONlTORING REQUIREMENTS 2. Sludge Monitoring. During the period beginning on the effective date of this pennit and lasting until the expiration date, the pennittee shall monitor the treatment works' final sludge at Station Number 3PF00000584, and report to the Ohio EPA in accordance with the following table. See Part IT, OTIIER REQUIREMENTS, for location of sludge sampling. Table - Sludge Monitoring - 584 - Final

Eflluent Characteristic

o

Parameter 00611 - Ammonia (NH3) In Sludge - mg/kg 00627 - NiLTogen Kjeldahl, Total In Sludgemglkg 1003 - Arsenic, Total In Sludge - mglkg 01028 - Cadmium, Total In Sludge - mg/kg 1043 - Copper, Total In Sludge -mglkg 01052 - Lead, Total In Sludge - mg/kg 01068 - Nickel, Total In Sludge - mglkg 01093 - Zinc, Total In Sludge - mglkg 01148 - Selenium, Total in Sludge - mglkg

Discharge Limitations Concentration Specified Units Loading * kg/day Maximum Minimum Weekly Mon1hly Daily Weekly Monthly

Measuring Frequency I/Mon1h l/Mon1h l/Month IfM"on1h l/Month lIMonth l/Mon1h I/Month l/Month l/Month lIMonth I/Mooth I/Month I/Month

Monitoring Requirements Sampling Monitoring Type Months Composite All Composite All Composite Composite Composite Composite Composite Composite Composite Composite Total Total Composite Composite

o

41 39 1500 300 420 2800 100
1000

All All
All

3164 J - Fecal Califonn in Sludge -MPN/G
51129 70316 71921 78465 - Sludge Fee Weight - dry tons - Sludge Weight - Dry Tons - Mercury, Total Tn Sludge - rngikg - Molybdenum In Sludge· rng/kg

17 75

All All All All All All All All All

NOTES for Station Number 3PF00000584:

- Monitoring is required when sludge is removed from the wastewater treatment facility and disposed of as.f~c~lJti~p_~1 guali!x: ,K~c: s}l!c!Ke}~ ._ ". removed during the entire month, report HAL" in the first column of the first day of the month on the 4500 Form (Monthly Operating Report). A signature is still required. - Units of mg/kg are on a dry weight basis.

.

~ed: composted material~

000298

3PFOOOOO*LD
_Sludge weight is a calculated total for the sampliug period. _See Part II, Items T, D, V, Wand X.

000299

Page 11 3PFOOOOO*LD Part I, B. - SLUDGE MONITORING REQUIREMENTS 3. Sludge Monitoring. During the period beginning on the effective date of this permit and lasting until the expiration date, the permittee shall monitor the treatment works' final sludge at Station Number 3PF00000586, and report to the Ohio EPA in accordance with the following table. See Part II, OTIJER REQUIREMENTS, for location of sludge sampling. Table - Sludge Monitoring - 586 - Final

Effluent Characteristic
Parameter

Discharge Limitations Concentration Specified Units Loading * kg/day Daily Weekly Monthly Maximum Minimum Weekly Monthly

51129- Sludge Fee Weight - chy tons

Measuring Frequency I/Year

Monitoring Requirements Sampling Monitoring Months Type Total December

NOTES for Station Number 3PF00000586:

- Monitoring is required when sludge is removed from the wastewater treatment facility and disposed of by hauling to a solid waste landfilL
Monthly operating report data shall be submitted in December. lfno sludge is removed during the reporting period, repmi "AL" in the first

column of the first day of the month on the 4500 Fonn (Monthly Operating Report). A signature is still required. - Sludge weight is a calculated total for the sampling period. - See Part II, Items T, D, V and X.

000300

3PFOOOOO*LD Part I, B. - INFLUENT MONITORING REQUIREMENTS 4. influent Monitoring. During the period beginning on the effective date of this pennit and lasting until the expiration date, the pennittee shall monitor the treatment works' influent wastewater at Station Number 3PF0000060 1, and report to the Ohio EPA in accordance with the following table. Samples of influent used for detennination of net values or percent removal must be taken the same day as those samples of effluent used for that determination. See PaJi II, OTIffiR REQUIREMENTS, for location of influent sampling. Table - Influent Monitoring - 601 - Final

Effluent Characteristic
Parameter 00530 - Total Suspended Solids - mgfl 00720 ~ Cyanide, Total mg!1 01074 - Nickel, Total Recoverable - ug/l 01094 ~ Zinc, Total Recoverable ~ ug/l 01113 ~ Cadmium, Total Recoverable - ug/l 01114 - Lead, Total Recoverable ~ ug/l 01118 -Chromium, Total Recoverable ugll 01119 - Copper, Total Recoverable - ug/l 01220 - Chromium, Dissolved Hexavalent ug/l 50092 - Mercury, Total (Low Level) - ngll 61941 -pH, Maximum - S.U. 61942 -pH, Min,imum ~ S.U. 80082 - CBOD 5 day - mgtl

Discharge Limitations Concentration Specified Units Loading * kg/day Daily Weekly Monthly Maximum Minimum Weekly Monthly

Monitorina Requirements ;-,ampling Monitoring Months Type Composite All liZ Weeks Grab All l/Month Composite All All 1/Month Composite All l/Month Composite l/Month All Composite 1/Month Composite All l/Month Composite All 1/Month Grab All LIJ\1onth Grab All l/Day Continuous All lIDay Continuous All lIDay Composite All

Measuring Frequency 1iDay

NOTES for Station Nnmber 3PF0000060l: - Nickel, zinc, cadmium, lead, total chromium and copper - See Part II, Item Q. - Dissolved hexavalent chromium and total cyanide - See Part II, Item S. - Mercury - See Part II, Items S and Y.

000301

Page 13

3PFOOOOO*W
Palt I, B, - BYPASS MONITORlNG LlMITATIONS AND MONITORING REQUIREMENTS
~

5. Bypass Monitoring. During the period beginning on the effective date of this permit and lasting until the expiration date, the pennitte~ _. authorized to discharge in accordance with the following limitations and monitoring requirements ii'om station: 3PD00000603 only when plant peak influent flows exceed 110 MGD and the flow equalization pumping capacity is being maximized due to stonn related events and activities. See Part II. OTIIER REQUIREMENTS, for location of effluent sampling, Table - Bypass Monitoring· 603 - Final

.._--_. Deleted: shall monitor the treatment

.~

i

plant's bypass when discharging, at Station Number 3PF00000603, and report to the OhioEPA in accordance with the fol1owing table. See Part II, OTHER REQUIREMENTS, for location of l sampling. _

j

Effluent Characteristic

Parameter 00530 - Total Suspended Solids - mg/l 01074 - Nickel, Total Recoverable - ug/l 01094 - Zinc, Total Recoverable - ug!l 01113 - Cadmium, Total Recoverable - ug/l Oll14 - Lend, Total Recoverable - ug/l 01118 - Chromium, Total Recoverable - ug/l 50050 - Flow Rate - MOD 50092 - Mercury, Total (Low Level) - ng/l 80082 - CBOD 5 day - mg/l

Discharge Limitations Monitoring Requirements Loading * kg/day Measuring Sampling Monitoring Concentration Specified Units Daily Weekly Monthly Frequency Maximulll Minimum Weekly Monthly Type Months When Disch. Composite All 157 lIQuarter Composite Quarterly l/Quarter Composite Quarterly lIQuarter Composite Quarterly

I1Quarter l/Quartcr

Composite Composite

Quarterly Quarterly

When Disch. ContinuOlls IIQuarter Grab
91

vbll_ ,.
Quarterly All

-1 Deleted: Q~arterlY

When Disch. Composite

NOTES for Station Number 3PF00000603:
c h d'l ' f] - Data lOr th e numb er 0 f occurrence(s) per d ay, teal y duratIon an d t htota a1'Iy .. ow may b · e Id e estlmat ed. - Sampling shall be perfOlmed when discharging. Ifno discharge occurs during the monitoring period, repOlt "AL" in the first column of the first day of the month on the 4500 FOlID (Monthly Operating Report). A signature is still required.

Deleted: Treatment plant bypass is prohibited except under emergency
conditions
I

lI
I
I

liS

authorized by fede.ral

~nA actiy~i~s

-"Wh. e!.1 -

M

tl1.5I-t. the pel:!nitt~~ shall be _d~emed to meet th~- .~~)]lditions of 40 _C.ER. § 1.2_2.41 (1[1) af!.d Pa~rt III, Item 11 L .... _ _ __ __ _ _ _ _ _. __ --.." S P rt II, It Y , ercury - ee a em. \ "
,\ \

thepl~_t p ~~k_ in !1l;l~t JI5J~_s~?,~e~~ .J JQMqI?~q !h_e}lp~~~~u~~~.a~i9~ P~J?p~g_c~E~cit¥ is~~ei~g_f!1~i!?iz~e4~d._!1~ !O_. ~t~rrn ~el~t~d_ ~v_.~~s .' . ._

regulation 40 CPR 122.41 (m) and Part

J

I

" \'?:~""""~~~~~~~~~j '; Deleted:

pennit;tr~gllrdleSS of if thCthSC cond~lions arc mc , In no event mllY e pCnTIlllee discharge from this outfaJl~ unless

~;~~ I I , Gencrnl Conditions, of this

J

\}teted, 1 ~eted, ,

. . __ ~_:J

~

...

J

000302

3PFOOOOO*LD Part I, B. - UPSTREAM MONITORING REQUIREMENTS 6. Upstream Monitoring. During the period beginning on the effective date of this pennit and lasting until the expiration date, the permittee shall monitor the receiving stream, upstream of the point of discharge at Station Number 3PF0000080l , and report to the Ohio EPA in accordance with the following table. See Part II, OTHER REQUIREMENTS, for location of sampling.

Table - Upstream Monitoring - 801 - Final

Effluent Characteristic

Parameter
00010 - Water Temperature ~ C 00300 - Dissolved Oxygen '- mg/I 00400 - pH - S.U. 00610 - Nitrogen, Ammonia (NI-13) - mg/I 00665 - Phosphorus, Total (P) - mg/I 31616· Fecal Coliform· #/100 ml 61438 - 7-Day Chronic Toxicity Ceriodaphnia dubia - % Affected

Discharge Limitations Loading * kg/day Concentration Specified Units Maximum Minimum Weekly Monthly Daily Weekly Monthly

Monitoring Requirements

Measuring Freqnency lJMonth I/Month lfMontll l/Month lIMonth 1/Month l/Quarter

Sampling Type Grab Grab Grab Grab Grab Grab Grab

Monitoring Months All All All All All Summer Quarterly~tox 1

NOTES for Station Number 3PF0000080l: - Whole effluent toxicity - See Part n, Item

ce.
qU~lieh
Del;t~;~;~;h-,-"re---·------::J--

- "Quarterly tox 1"

monitoring1t'}b~lJ OCC~T

ea.ch .~~lenda!

Deleted: January, April, July, and
October..

===-~~~--,

.~

!

000303

Page 15 3PFOOOOO*LD Part I, B. - DOWNSTREAM-AIM MONITORING REQUIREMENTS 7. Downstream-AIM Monitoring. During the period beginning on the effective date of this pennit and lasting until the expiration date, the pennittee shall monitor the receiving 'iream, downstream of the point of discharge, at Station Nnmber 3PF0000090 1 , and report to the Ohio EPA in accordance with the following table. See Part II, OTHER REQUIREMENTS, for location of sampling. Table - Downstream-AIM Monitoring - 90 1 - Final

Effluent Characteristic Parameter 00010 - Water Temperature - C 00300 - Dissolved Oxygen - mg!! 00400 - pH-S.U. 00610 - Nib'ogen, Ammonia (NIB) - mg/I 00665 - Phosphonls, Total (P) - mg/l 00720 - Cyanide, Total- mg/I 00900 - Hardness, Total (CaeD3) - mg!l 01074 - Nickel, Total Recoverable - ug/J 01094 - Zinc, Total Recoverable - ug/l 01113 - Cadmium, Total Recoverable - ug/1 01114 - Lead, Total Recoverable - ugfl 01118 - Chromium, Total Recoverable - ug/l 01119 - Copper, Total Recoverable - ug/l 01220 - Chromium, Dissolved Hexavalent - ug/l 31616 - Fecal Colifonn - #/100 ml

Discharge Limitations Concentration Specified Units Loading * kg/day Maximum Minimum Weekly Monthly Daily Weekly Monthly

Measuring Frequency lIMonth IlMonth l/Month l/Month I/Month l/Month l/lvfonth L'Month llMonth 1/Month lfMonth lfMontb l/Month L'I\.1onth lfMonth

Monitoring Requirements :::.mnpling Type AU Grab AU Grab AU Grab AU Grab AU Grab AU Grab All Grab AU Grab AU Grab AU Grab AU Grab AU Grab AU Grab AU Grab Summer Grab

- Nickel, zinc. cadmium, lead, total chromium, copper, dissolved hexavalent chromium and total cyanide - See Part II, Item Q",

~~l~: ~_ ...

000304

Page 16

3PFOOOOO*LD
Part I, C - Schedule of Compliance A. Municipal Pretreatment Schedule 1. The pennittee shall evaluate the adequacy of local industrial user limitations to attain compliance with final table limits. A technical justification for revising local industrial user limitations to attain compliance with fmal table limits, along with a pretreatment program modification request, or technical justification for retaining existing local industrial user limitations shall be submit to Ohio EPA, Central Office Pretreatment Unit, this permit. (Event Code 52599)

in duplicate, as soon as possible, but no later thanJj)p.9DtP~ !r9~_t~~ ~fJ~c:!iy~ ~'!t~ 5'f.. __ ~ _-~: 6

---

Technical justification is required for arsenic, cadmium, total chromium, dissolved hexavalent chromium, copper, cyanide, lead, molybdenum, nickel, selenium, silver and zinc unless screening of wastewater and sludge indicate these pollutants are not present in significant amounts. Furthennore, technical justification is required for any other pollutants where a local limit may be necessary to protect against pass through and interference. To demonstrate technical justification for new local industrial user limits or justification for retaining existing limits, the following infonnation must be submitted to Ohio EPA: a. Domestic/background and industrial pollutant contributions b. Treatment plant removal efficiencies c. A comparison of maximum allowable headworks loadings based on all applicable criteria. Criteria may include sludge disposal, NPDES pennit limits, and interference with biological processes such as activated sludge, sludge digestion, nitrification, etc d. If revised industrial user discharge limits are proposed, the method of allocating available pollutant loads to industrial users e. Supporting data, assumptions, and methodologies used in establishing the infonnation a through d ahove 2. a. If revisions to local industrial user limitations are detennined to be necessary, no later than 4 months after the date of Ohio EPA approval of the pretreatment program modification request to revise local industrial user limitations, the pennittee shall incorporate revised local industrial user limitations in all industrial user control documents. b. Within one week of completing this requirement, the permittee shall notify, in writing, the Ohio EPA Central Office Pretreatment Unit.

B. Municipal Pretreatment Schedule - Mercury

000305

Page 17

3PFOOOOO*LD
The permittee shall evaluate the adequacy of local industrial user limitations for mercury. A technical justification for revising local industrial user limitations, along with a pretreatment program modification request, or technical justification for retaining existing local industrial user limitations shall be submitted to Ohio EPA, Central Office Pretreatment Unit, in duplicate, as soon as possible, but no later than 28 months from the effective date of this permit (Event Code 52599). To demonstrate technical justification for new local industrial user limits or justification for retaining existing limits, the following information must be submitted to Ohio EPA: a. Domesticlbackground and industrial pollutant contributions. When representative sampling of the collection system or industrial pollutant contributors conducted using EPA Method 245.1 or 245.2 shows mercury concentrations that are below detection, EPA Method 1631 shall be used to quantify domesticlbackground and industrial pollutant contributions of mercury. b. Treatment plant removal efficiencies. When representative sampling of the influent or effluent conducted using EPA Method 245.1 or 245.2 shows mercury concentrations that are below detection, EPA Method 1631 shall be used to quantify influent and effluent mercury concentrations. c. A comparison of maximum allowable headworks loadings based on all applicable criteria. Criteria may include sludge disposal, NPDES permit limits, and interference with biological processes such as activated sludge, sludge digestion, nitrification, etc. d. If revised industrial user discharge limits are proposed, the method of allocating available pollutant loads to industrial users. When appropriate, revised industrial user discharge limits may include narrative local limits requiring industrial users to develop and implement best management practices for mercury. 1hese narrative local limits may be used either alone or as a supplement to 3: numeric limit. e. Supporting data, assumptions, and methodologies used in establishing the information a through d above. To demonstrate technical justification that local limits for mercury are not currently necessary, the permittee shall submit effluent and sludge data showing that mercury is not present in significant amounts. The data shall be accompanied by an evaluation supporting the determination that local limits for mercury are not currently necessary. 2. a. If revisions to local industrial user limitations are detennined to be necessary, no later than 4 months after the date of Ohio EPA approval of the pretreatment program modification request to revise local industrial user limitations, the permittee shall incorporate revised local industrial user limitations in all industrial user control documents. b. Within one week of completing this requirement, the pennittee shall notify, in writing, the Ohio EPA Central Office Pretreatment Unit.

000306

Page 18 3PFOOOOO*LD
C. Tributary COIIll11uriity Pennit Program
J

j Deleted: Not later than March 15th of
'[ each calendar year the pennittee shall
,i submit a prol,'Tess report documenting the

~

i ,community during the previous calendar
r
l

, compliance status of each tributary

I. Not later than March 15 of each calendar year, the pelmittee shall submit a report that summarizes the status of each tributary community during the previous calendar year based upon infonnation provided to the permittee by the tributary communities. The report shall include a summary of bypasses and overflows which occurred dill"iug the previous tvielve months as reported to permittee by tributary commnuities. The report shall be submitted to the Ohio EPA. Northeast District Office. The pennit)ee is not responsible for the completeness or the veracity of the information it receives from each of the satellite cornmunities'l. __
'L _

....--.
I

year. The report shall include a summary of the bypasses and overflows which occurred during the previous twelve months. The report shall be submitted to the Ohio EPA Northeast District Office.

_. .Deleted: D. Schedule to Meet Lower

, , , , , ,,
~I

, , II . The permittee shall immediately begin
an evaluation of the capability of the existing treatment facilities to meet the final efl1uent limits for ammonia~nitrogen (June -September), phosphorus and CBOD5 (5~day carbonaceous biochemical oxygen demand), Both operational procedures, unit process configuration, and other appropriate measures shall be evaluated."

Cuyahoga TMDL Limits'l

,

,

,

/

I
2. Not later than 12 months from the effective date of this permit, the permittee shall implement measures identified in lhe evaluation that can reasonably be expected to maximize the ability of the existing treatinent facilities to achieve the fmal effluent limits for ammonia-nitrogen (June - September), phosphorus and CBOD5. Permits To Install shaH be obtained if necessary.~

11

3. If the final effluent limits for ammonianitrogen (June - September), phosphorus and CBOD5 are not achieved by implementing measures identified in the evaluation, not later than 18 mOnths from the effective date of this permit, the pennittee shall submit a general plan to the Ohio EPA Northeast District Office to achieve the final effluent limits. [Event Code 1299]~

I
The general plan for achieving the final effluent limits shall address, as a minimum, the fonowing:~

I
a. The treatment teclmology required to achieve the fmal eftluent lilllits.~ b. Cost estimates of required improvements and operation, maintenance, and replacement costs for the improved facility.~ c. A fixed date compliance schedule for meeting the final effluent limits, As a minimum, this schedule should include dates for: submission of approvable detail plans; completion of construction; attainment 0 f operational level; notification of the Ohio EPA Northeast District Office within 14 days of attaining operational level; and achieving the final effluent limits not later than 36 months from the effective date 0.fthis peCrnj L:!:.!he financial mechanism to be ... 2

I

I

000307

Page 21 3PFOOOOO*LD Part II, Other Requirements

A.

The wastewater treatment works must be under supervision of a Class N State

certified operator as required by rule 3745-7- 02 of the Ohio Administrative Code.

B.
Q..~rmjt

The plant must be adequately staffed and operated to insure compliance with this
and any applicable reITh/ts to instal1.

.[2, ~ ~ _ )~e_s~rl~t~op-_or1Ae)~)(;~a~ip!?- ~f ~h_e_r~q~!~~~ §~f!1:elillKsj'!t~op~ ~~e _a§ f~llo_~s~
Sampling Station

__ ..

- --( Deleted: B. . The plant must be staffed
and operated in accordance with the Ohio EPA approved Operation and

1
I
J

Description of Location

~aintenanceManuaL~

c.

3PFOOOOOOOI

3PF00000584 3PF00000586 3PF0000060l 3PF00000602 3PF00000603 3PF00000801 3PF00000901

.downstream of,stations 3PF00000602 and 3PF9000060~' and prior __ - fi);leted: Combination of t~ plant discharie··o~i~t -. i~r dissol;~d- o;yg~;, which ~t ~ ~ - - Deleted: ') the cascade outfall ' .rFo;';;';;';tted~~.~"-~'-N·~t-B-I~d~~~~ . I Irma .'vnt.O 0 Sludge disposal as exceptIOnal quality matena., _ _ _ _ _ _ _ __ _ \.. . - - Sludge disposed of by hauling to a solId waste landfill -1 Deleted: composted material Raw influent Effluent from fmal settling tanks prior to mixing with secondary

Final effluent

Lat: 41N 09' 00"; Long: 81W 33' 45"

excePt

{s

bypass

Secondary treatment bypass prior to mixing with effluent from final settling tanks
Upstream of plant discharge point

Dovvnstream of plant discharge point at Bath Road Bridge

*During winter months the permittee is authorized to discharge from an alternate
temporary outfall approximately 1,310 feet south of3PFOOOOOOOI only during periods

of maintenance on the chlorine contact tanks or discharge structure. D. All parameters, except flow, need not be monitored on days when the plant is not

normally staffed (Saturdays, Sundays, and Holidays). On those days, report "AN" on the monthly report form.

000308

Page 22 3PFOOOOO*LD E.
The permittee is authorized to discharge from the following overflows only during wet weather periods when the flow in the sewer system exceeds the capacity of the sewer system.

CSO Station Number 3PF00000046 3PF00000047 3PF00000048 3PF00000049 3PF00000050

Description of Location

Receiving Water

Kelly Avenue, Rack 3 Lat: 4103' 50"; Long: 8128' 52"

Little Cuyahoga

~~e!m~~:~~~g:

8131' 12"

:::~e~:n::hOga
Little Cuyahoga

/iE,ed, ]PF00000052;;;:i~.~~~ ~I
..

(~ ~Ieted: Little Cuyahoga

__.__)
_

Lat: 41 04' 12"; Long: 81 29' 20" Factory Street, Rack 6 Lat: 41 03' 54",· Long: 81 28' 59"

~:~~ ~ve @SouthCaseAveLittleCuyahoga
Lat: 4104' 10"; Long: 81 29' 18' North Case Avenue & Dublin
Street, Rack 8

>tE.~,leted: _~ i// /rD~i~ted: 3PFOOOO~O~5J~~~~~"'-"-l
"1 L
I

/i ,"I Rack 9~ 'J" Lat: 41 04' 20": Long: 8129' 09"
"

Ii f Deleted: WillialUS Street@KentStreet1il
Little Cuyahoga
._.,' -

I
!

~

iii:: L . .
Little Cuyahoga
. LIttle Cuyahoga"
,/11 I,'

iii !

il·~

3PF00000051

Iii /,' /

r

.. ~~

J

I

Deleted: CascAvenuc- Nev,ton Street
Dislrict1[ Rack 10'1 Lat41 04' 27"; Long: 8129' O!"
--

Lat:4104'20",'Long:8129'09" 3PF00000053 _ 11',000006054- - - - - .. .Ji

Case Avenue - Newton Street Distlict

Rack 10
Rack!1

==-"'"'-'""''''''' ~ --- ,I "i
---III/

,;! I I

i;I'/ I,'i,"I

J

1

Deleted: Little Cuyahoga

t~~ei1Sfr~~;};~;;nD;s~~9~ 01 '~
Lat~~104'45";~ong,8129'08~~

- - - . Little

Cuyah~ga _- _~/i,: /'[ ~el~led' JPFOOOOO05411
/ / I (Deleted: ~/J/ ,/1 Rackll
f

~ ~j

..
Dls;nc~4~

Hazel Street Truck,

3PF00000055
-1" ,_

Home Avenue District. Rack 12
Lat.:~105' 13~'iJ;;ong:8129'34'~.

3PF00000056

Madeira Street. behind Holland Oil Rack 13
tracks. Rack 14 __ [at: ~q 9r 01": LJ?n.,g; 81 29'
,, ".

Camp Brao}; _ ___ ) / L~t 4104' 45", Long 8129'08" , __. "_ Deleted: Camp Brook Little Cuyahoga - _- '" -'" / fDelete~: 3PFOOOOO05~~I__

/1
-

-:=l

L

J.-'

North Forge Street nOlih of railroad
44'~

Lat::tl 05' 13"; ~gng: 81 29' 34'~ ~ _"

H

_

_

_

_

_

_

_

Little CuyahQ&§;._

~_

-

-

D,-,.eI:ted:
II

Home-A~nu.'D..'.'''ic' R';;]
Long: 81 29' 34" --~

Lat: 4L 05' 13"; '-.{; ~ --

\

-'<' _ _ _ _ _ _ _ _ _ _ _ 'C

_ _ _ __ __ _ __ _ _ _ _ _ ~ . ..

\- -

~eleted; 3PF000000561

~eted: Litt!eCuyahoga

.

""L_
1\
I

fDeleted: Madell";] Street, behind
Holland

_

Oll~

I; IJ
":\

,iRackI3. La~:41 05' 13"; Lon~: 8129' 34"

I

~eletedmF;00ooO;71 ~

, 'rn::;::;
"

'I Deleted: North Forge Street north of
railroad' "Itracks, Rack 14 -

\; tat: 4_1",~' 07"; Long: 81~~4"

(Deleted: Little Cu~ahOga

~

000309

Page 23 3PFOOOOO*LD 3PFOOOOO058

Forest Hill District in park ravine
Rack 15 Lat: 4105' 25"; Long: 5130'14" Wolf Ledges Truck, Rack 16 Lat: 41 04' 42"; Long: 81 31' 22" Exchange Street, Rack 17 Lat:41 04'45";Long:8131' 19" Willow Run Truck, Rack 18 Lat: 4105' 09"; Long: 8131' 09" West Market Street, Rack 19 Lat: 41 OS' 10"; Lnng:81 31' 08" West North Street, Rack 20 Lat: 4105' 28"; Long: 8131'03" North Howard Street, Rack 21 Lat: 41 OS' 31"; Long: 81 30'57" North Hill Trunk@NorthHoward Street, Rack 22 Lat: 41 OS' 33"; Long: 81 30'57" North Maple Street, Rack 23 Lat: 41 OS' 38"; Long: 81 31' 09" West Market Street Outlet @ Ravine Street, Rack 24 Lat: 4105' 39"; Long: 81 32' 14"

Little Cuyahoga

3PFOOOOO059 3PFOOOOO060 3PFOOOOO061 3PFOOOOO062 3PFOOOOO063 3PFOOOOO064 3PFOOOOO065

Ohio Canal Ohio Canal Ohio Canal Ohio Canal Ohio Canal Little Cuyahoga Little Cuyahoga

3PFOOOOO066 3PFOOOOO067

Little Cuyahoga Little Cuyahoga

000310

Page 24 3PFOOOOO*LD 3PF00000068 3PF00000069 Otto Street District, Rack 25 Lat: 41 OS' 40"; Long: 81 32' 15" Aqueduct Street Outlet east of Hickory Street, Rack 26 Lat: 41 06' 08; Long: 81 31' 39" Uhler Avenue @ Memorial Parkway Rack 27 Lat: 4106' 15"; Long: 8131' 38" Tallmadge Ave @ Memorial Parkway Rack 28 Lat: 41 OS' 15"; Long: 81 31' 39" Uhler Avenue - Carpenter Street Outlet Rack 29 Lat: 4106' 33"; Long: 8131' 39" CaDJcnter Heights District @ Cascade Park Road, Rack 32 Lat: 41 07' 12"; Long: 81 31 '20"P S 'd 0 f 11 ortage - unnYSl e lit a Rack 31 Lat: 41 06'-54";L~rl'£: 8131'-40': NOlih Side Interceptor@Cuyahoga - - River & Main Street. Rack 33 Lat: 41 OT 23"; Long: 8130' 38"Carpenter Heights District @ Cascade .. ~ .. _"' _ _ _ _ _ _ _ Park Road. Rack 32 Lat: 41 07' 12": Long: 81 31 '20". - ,,. Riverside Drive District along Metroparks Easement Road, Rack 34 Lat: 4107' 24": Long: 8129' 54"North
_- - - - - _ - - - - - - -... ~ ------"' -.

Little Cuyahoga Little Cuyahoga

3PF00000070

Little Cuyahoga

3PF00000071

Little Cuyahoga

3PFoooooon

Little Cuyahoga
/ ( (Deleted: 3PFOD000073~ ~

I(Del~ted: LittleCUya!~o~~

J

3PF00000075 '3PF00000074

CuyahogaLittle Cuyahoga _ _

_

u/
I
I

i

'L ___-------------.J ~~~~~~~~~
Deleted:CuyahQgaStreet-PeckRoad
Outk~

j

! (

3PF00000076 '3PF00000075
..lI' "

- C~yahogaCU'yahogi

- - - -- ~ -- -/

;'

,I

- __ - ~-:ted:
II I /

Rack 30 tat 4106 50", Long 8131'39"
Little Cuyahoga

r,D",e" leted,: 3PF00000074~" .~

.,

j,J

,/f~:~~~~:portage-suru:;;ideOutfall'l

L~~~~~~~~~~~
n ,n

~

~

"
--------".-------.j

3PF00000077 '3PF00000076
-'l' _ ".

CuyahogaCuyahog,\
j

,--' "JDeleted:Cuyahoga ,,~~="""
D
,./

l La~,: 41 06' 54"; Long: 81 31' 40"

::::=:J-

__
J ' /

l'L,le,.eted: 3PFOOOOOO..7.. 51.'.__ ~_ .
__ _
Cascade'J
ParkRoad,Rack32'J

J

Side Interceptor @Cuyahoga River & Main Street. Rack 33 ,,- - - - - - - - - - - Lat: 41 01' 23"; Long: 8130' 3'8:;',._-

I'D.eleted: carpente:Heights DiStrict@1
.f~I_et~~: Cuyahoga

!
_.J
/1"

,.

3PF00000077

Riversigc Drive District along Metroparks Easement Rpad, Rack 34

Cuyahog~

-----

-/

'iLat:4101'12";Long:813I'20" --,-_.. .

;':::::::: ::::: :.Lat: 41 07'24",

LOng~ 81.29' 54'~:::::~::::__

------

:::::: <jt,ed:3PF00000076
.,

1

~

~

--"

i

Deleted: North Side Interceptor@
Cuyahoga'J River & Main Street, Rack 33 ,

1

i

" \

\\ \

\ \ , \ Lat: 4101' 23"; Long: 8130' 38"

l

i

I
i

i

\\\'1 Deleled' 3PFoooooon1: \ "1
"
\
\

~
.....

\

.
'(::1

,-

-j

Deleted: Riverside Drive District alon!1
Metroparks Easement Road, Rack 34'1

'.

". Lat:41 01' 24"; Long: 81 29' 54"

rDel~~d: Cuyahoga

=:J

000311

Page 25 3PFOOOOO*LD 3PF00000078 Cuyahoga Gorge Boulevard District @ Front Street Bridge, Rack 35 Lat: 4107' 04"; Long: 81 29' 37" Merriman Road Outlet along abandoned Cuyahoga railroad track bed, Rack 36 Lat: 4107' 19"; Long: 81 32' 02" Ohio Canal Bowery Street, Rack 37 Lat: 4104' 48"; Long: 8131' 12" Little Cuyahoga South Arlington District @ Retention Tank No.2 - 9th Avenue @ Settlement Street, Racks 2N and 25 Lat: 4103' 34"; Long: 81 28' 26" [:uvahoga Stree_t ,,~!~F8:ge)~asjn _ ~. !-ittl~ ~':.lyal:l9g,! Old Rack 40130/31 Lat: 41 06' 54"; Long: 81 31' 40"

3PF00000079

3PF00000080 3PF00000081

3PF00000083

,

Deleted: Main O~tfa';l @
Street
,

cuYahoga~1

,-~~,---

F. The pennittee shall monitor the collection system ovemows at stations 3PF00000046,3PF00000047,3PF00000048,3PF00000049,3PFOOOOO050, 3PF00000051 ,,3PF00000053, 3PF00000054, 3PF00000055, 3PF00000056, 3PFoooo6057~ 3PFoo'oo6651( 3PF00000059, 3PFooooootio, 3PF00000061, 3PF00000062, 3PF00000063, 3PF00000064, 3PF00000065, 3PF00000066,3PF00000067,3PFOOO00068,3PFOOO00069,3PFOOOOO070, 3PF00000071 , 3PFOOOOOOn,,3PFOO,0000752 • • • . . . . . " • • • • . . . . . . 3PF00000076,3PF00000077,3PF00000078,3PF00000079,3PFOOO00080, 3PF00000081, 3PF00000083 and report to the Ohio EPA in accordance with the following table: CHARACTERISTIC Reporting Code Units
~____ __~

, , ' {l;;;i;;,;;lI: 3PFooooo05~. __ ~

MONITORING REQUIREMENTS Parameter
~

Measurement Frequency
J

Sample Type

~

_

- - §eted: 00530

50050 80998 80999
~-----

Million Gallons Volume
_% _
J
~ _ _ _ _ _

When discharging
J

Daily Estimate
_

NumberlMonth Occurrences
Hours Duration

When discharging
When discharging

Estimate
Daily Estimate

\:~,:t~Ie~~~,: Suspended Soli'ds
\ '(Deieted: IlMonth

,

~ted: rog/I

.'

'.

-.---J J.. 1
,

J
)

Monitoring data shall be submitted for each month when discharge occurs. When discharge occurs, the monthly monitoring report shall be attached to the nonnal monthly report form (EPA-4500).

-------------------------------------- --------------

\\\\t Delete~: 80082

\ ~ted: Grab
mgll

~

'~>rDel;;t~d:
",~.

\ \\[DeJeted: ~BOD5 '\ \CDeleted: IIMonth

-',
------..--J
] ,_ _.__

.=:J

\, ~~!~~

Grab

~:=J

1rotating schedule to sample at least five
(5) stations during each stonn event. should collected during the I Samplesminutes be discharge,'.'--_ _.J of \ first 30

Deleted: The permittee shall set up a

000312

Page 26

I
;1
/ I

3PFOOOOO*LD

(Deleted: entirewaSlewa-~;-~atment

-.J

I!!
I

rl)~leted: so that the totalloadill;~f-"

G. The combined sewer i'~s!~n:! ~h~altb_e_oF~~a!e_(ap.~ ~j!!t~ip.~c! Ln"<:,()~~pliance . \yi~h the
nine minimum control plan submitted on November 1, 1996 and amended on March 18_ 1998, "__ __ _ _ _ __ "" "" _

I is minimized. To accomplish this, the i pennittee ~hall utilize the following
c.:::hno logtes,:,Y

pollutant, discharged during wet weather

/[ Dcle-;d~"';');~vide pro;;r operation

i and maintenance for the collection system

I
I i
i

and the combined sewer overflow points;~ . 2) provide the maximum use of the collection system for storage of wet weather flow prior to allowing overflows;"tj 3) review and modify the pretreatment program to minimize the impact of nondomestic discharges from combined i sewer overflows;~1 4) maximize the capabilities of the POTW to treat wet weather flows, and 1 maximize the wet weather flow to the i i wastewater treatment plant within the limits of the plant's capabilities;~ 5) prohibit dry weather overflows;'1 6) control solid and floatable materials in the combined sewer overflow discharge; 7) conduct required inspection, monitoring and reponing of CSOs;1 8) implement pollution prevention programs that focus on reducing the level of contaminants in CSOS; and~ 9) implements a public notification program for areas affected by CSOs, especially beaches and recreation areas.'

'1
I

H. Sanitary Sewer Overflow (SSO) Reporting Requirements'

A sanitary sewer overflow is an overflow, spill, release, or diversion ofWllstewater fTom a sanitary sewer system. SSOs do not include wet weather discharges from combined sewer overflows specifically listed in Part II of this NPDES pennit (if any). Ail SSOs are prohibited except under emergency conditions where the overflow occurs in full compliance with an of the provisions of40 CFR 122.41 (m) and Part 1lI Item II of this NPDES pennit. Sanitary sewer overflows must be reported as reqll-ired below.'

'1I. Reporting for SSOs That Imminently
and Substantially Endanger Human Health ~I

I
a) Immediate Notification'

I
YOll must notify Ohio EPA (1-800-2829378) and the appropriate Board of Health (Le., city or county) within one 1 i hour of learning of any SSO from your sewers or from your maintenance contract areas that may imminently and I substantially endanger human health. The telephone report must identitY the location, estimated volume and receiving ! water, if any, oflhe overflow. An SSO 1 that Illay inuninently and substant ... 3
I

I
I

000313

Page 27 3PFOOOOO*LD

J. _1]1~ jJ~~i!t~~

Possible the "treatment works" and "sewerage system" as defmed in ORC 6111.01 as effective on the date of this permit to achieve compliance with the terms and conditions of this permit,_ ~ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __ __ _ _ _

~h_a!1 ~~~~t~~}~

E9Qc! ~9IIs!!?g, ~rsI~r_ a_TIs! _op~~~te_a_s .~ffjcj~n.!ly_a.? __ ___ /
..

" Iaware of any SSO that may imminently
and substantially endanger human health,

/ i

/1'1

{ Deleted: b) Follow-Op Writ~en Report'lJ
Within 5 days of the time you be\:ome

. you mU51 provide the appropriate Ohio
indudes:~

EPA district office a written report that

,
:
I I

ri)lheestimaleddateandtimeWhenthe
overflow began and stopped or wil! be

J. Composite samples shall be comprised of a series of grab samples collected over a 24hour period and proportionate in volume to the sewage flow rate at the time of sampling. Such samples shall be collected at such times and locations, and in such a fashion, as to be representative of the facility's overall perfonnance. K. Grab samples shall be collected at such times and locations, and in such fashion, as to be representative of the facility's performance.

stopped

(ifknown);~

OJ) the location ortlle SSO including an
identification number or designation if one exists;~ (iii) the receiving water (if there is one); ~ (iv) an estimate of the volume of the SSG (ifknownMl (v) a description of the sewer system component from which the release occurred (e.g., manhole, constructed overflow pipe, crack in pipe);~ (vi) the cause or suspected cause of the
overflow;~

~

(vii) steps taken or planned to reduce, eliminate, and prevent reoccurrence of the overflow and a schedule of major milestones for those steps; and,r (viii) steps taken or planned to mitigate the impact(s) of the overflow and a schedule of major milestones for those steps.,r A document showing the acceptable format for a 5-day follow up written I report can be downloaded from the Ohio EPA Division of Surface Water Pennits Program Technical Assistance web page

1

"ttp://www.epa.state.oh.usldsw/pennitsJte h
chnical_assistance.hlml,r

,11 1

2.. Reporting for All SSGs, Including Those That Imminently and Substantially Endanger Human Health'

1

a) _Monthly Operating Reports~

Sanitary sewer overflows that enter waters of the state, either directly or through a stonn sewer or other conveyance, shall be reported on your I monthly operating reports. You must ~ report the system-wide number of I occurrences for SSOs that enter waters of I the state in accordance with the I requirements for station number 300.·A I monitoring table for this station is ~ included in Part I, B of this NPDES I pennit. For the purpose of counting I occurrences, each location on the sanitary sewer system where there is an overflow, spill, release, or diversion of wastewater
l.~n a given day i":,,cou~ted as one , .., 4

1

Deleted: and to prevent di-;;har;~ the waters of the state, surface of the i ground, basements, homes, buildings, etc J

000314

Page 29 3PFOOOOO*LD
L. Multiple grab samples shall be comprised of at least three grab samples collected at intervals of at least three hours during the period that the plant is staffed on each day for sampling. Samples shall be collected at such times and locations, and in such fashion, as to be representative of the facility's overall performance. The critical value shall be reported.

M. The discharges that receive secondary treatment~u.§~~b_t,!i!! .?~ le~s_t 55? p~r_c~.I!:t. removal of carbonaceous biochemical oxygen demand (five-day) and suspended solids (see Part ill, Item I) except in compliance with 40 C.P.R. Pmi 130, .. _
N. The parameters below have had effluent limitations established that arc below the Ohio EPA Quantification Level (OEPA QL) for the approved analytical procedure promulgated at 40 CPR 136. OEPA QLs may be expressed as Practical Quantification Levels (PQL) or Minimum Levels (ML). Compliance with an effluent limit that is below the OEPA QL is determined in accordance with ORC Section 6111.13 and OAC Rule 3745-33-07(C). For maximum effluent limits, any value reported below the OEPA QL shall be considered in compliance with the effluent limit. For average effluent limits, compliance shall be determined by taking the arithmetic mean of values reported for a specified averaging period, using zero (0) for any value reported at a concentration less than the OEPA QL, and comparing that mean to the appropriate average effluent limit. An arithmetic mean that is less than or equal to the average effluent limit shall be considered in compliance with that limit. The pennittee must utilize the lowest available detection method currently approved under 40 CFR Part 136 for monitoring these parameters.

-- ~eleted:-treatment wor~

)

000315

Page 30 3PFOOOOO*LD REPORT1'JG: All analytical results, even those below the OEPA QL (listed below), shall be reported. Analytical results are to be reported as follows: 1 . Results above the QL: Report the analytical result for the parameter of concern. 2. Results above the MDL, but below the QL: Report the analytical result, even though it is below the QL. 3. Results helow the MDL: Analytical results below the method detection limit shall be reported as "below detection" using the reporting code "AA". The following table of quantification levels will be used to determine compliance with NPDES permit limits:

Parameter Chlorine, Total Residual

PQL 0.050 mg/I

ML

This pennit may be modified, or, alternatively, revoked and reissued, to include more stringent effluent limits or conditions if infonnation generated as a result of the conditions of this permit indicate the presence of these pollutants in the discharge at levels above the water quality based effluent limit (WQBEL).

f ~ ~ip-~l--.r:e!1!1-tt Ji~1!i~a!io~s ~a§~<t q1! Qr~lirp.!n_a!'t qr_ajJp~"oY~9:

subject to change based on modifications to or finalization of the allocation or report or . .•. . . . changes to Water QualIty Standards. Momtonng reqUIrements and/or specIal conditlons of this permit are subject to change based on regulatory or policy changes.

y.r~~t~ lo_a~_a!I9~a~~o!?-~ ¥~

-1 Deleted: O. POTWs that accept
i hazardous wastes by truck, rail, or dedicated pipeline are considered to be hazardous waste treatment, storage, and disposal facilities (TSDFs) and are subject to regulation under the Resource Conservation and Recovery Act (RCRAM! Under the "pennit-by-rule" regulation found at40 CFR 270.60(c), a POTW
must:~

I
!

1) comply with all conditions of its

1 number and comply 12 )obtain a RCRA 10 and reporting1 with certain manifest

! NPDES permit,,.

I 14)
I

requirements under RCRA,~ 3) satisfY corrective action requirements, m,et"1l fed,ml. "nd 10,,1 pretreatment requirements.~

and~

""to.

- - - _ .. _ - - - - - '

000316

Page 31 3PFOOOOO*LD
.J~ ~1l_disp9~~,_u§~,_s!~r~ge..< 9~ ~~~ajIP~t_of.~~"Y.,!g~ §lu~g~ ~l' ~h_e_~e~f!li!~e~ ~l:!a)t c_0!TI.Ply with Chapter 6111 ~(tl}~_ Qhi9-,~eyis~g~_o9~,_Gh_ap~e~ 274_5.:-4°_ ~fJb-~ QllLo_ ____ _____

""

Deleted: Q. Sampling for these

Administrative Code~~y_f9!:1!:t~r_r~ql!:.i~e!!le!1ts_sp~~~:l1~d_ip. _t~i§ I'';!Y_R:E~SJ~e!IPit'L U. Each day when sewage sludge is removed from the wastewater treatment plant for use or disposal a representative composite sample of sewage sludge shall be collected and monitored for total solids. Results of the monitoring shall be used to calculate the total Sewage Sludge Weight (Monthly Operating Report code 70316) and total Sewage Sludge Fee Weight (Monthly Operating Report code 51129) for the reporting period specified by this NPDES permit. The results of the daily monitoring and the weight calculations shall be maintained on site for a minimum of five years. The test methodology used shall be Part 2540 G of Standard Methods for the Examination of Water and Wastewater, 18th Edition, 1992, To convert from gallons of liquid sewage sludge to dry tons of sewage sludge: dry tons ~ gallons x 834 (lbs/gallon) x 0.0005 (tons/lb) x decimal fraction total solids. V. Sewage sludge composite samples shall consist of six to twelve grab samples collected at such times and locations, and in such fashion, as to be representative of the facilities sewage sludge.

---- - - --

- -- - -

- - --- --

',
\"
I'
II

,
I' II
II 1"
1~,
"I

parameters at station 3PF0000060I, 3PF00000602 and 3PF000009Oi shall occur the same day.~
R. Sampling at station 3PF00000602 for these parameters shall occur one detention time (the time it takes for a volume ofwaler to travel through the
treatment plant) after sampling at station 3PF0000060l for the same parameters on the same day.'
~

II

;'

\', ,,'.
1,1

,L\ ",

~\,

<,\ parameters on the same day.~

S. Sampling at station 3PF0000060! for these parameters shall occur one detention time (the time it takes for a volume of water to !Tavel through the treatment plant) prior to sampling at station 3PFOOOO0602 for the same
_

Ii

\\",1'---.::.~

.. ~J'

w. A grab sample of sewage sludge that has been treated to meet requirements for
application to the land shall be monitored for dioxin, as the term dioxin is defined in rule 3745~40~01 of the Ohio Administrative Code, as per the monitoring frequency, methodologies and reporting requirements described in rule 3745-40~06 of the Ohio Administrative Code. X. No later than January 31 of each calendar year the Pennittee shall submit two (2) copies of a report summarizing the sewage sludge disposal, use, storage, or treatment activities of the Pennittee during the previous calendar year. One copy of the report shall be sent to the Ohio EPA, Division of Surface Water, P.O. Box 1049, Columbus, Ohio 43216-1049, and one copy ofthe report shall be sent to the appropriate Ohio EPA District Office. The report shall be submitted on Ohio EPA Form 4229.

000317

Page 32 3PFOOOOO*LD

y. lhe permittee shall use EPA Method 1631 promulgated under 40 CFR 136, to comply
with the mercury monitoring requirements of this pennit at stations 601, 602 and 603. The detection level for Method 1631 is 0.2 ng/1. The quantification level is 0.5 ng/I. Z. Mercury Information for Next Renewal Application Ohio rules for implementing water quality standards [OAC 3745-2-08(L)] require that mixing zones for bioaccumulative chemicals of concern (Bees) bephased out as of November 15,2010. This means that dischargers will need to meet water quality standards at the discharge point for Bees after that date. Mercury is considered a BCe. I) Based on an evaluation of mercury data for outfall 3PF00000602 collected using Method 1631 , the permittee shall submit one of the following to Ohio EPA with lI,e next renewal application: a) A letter stating that the discharge is able to comply with a monthly average water quality-based effluent limit for mercury of 1.3 ng/I. b) If the permittee detennines that compliance with a monthly average water qualitybased effluent limit for mercury of I .3 og/l is not possible without the construction of expensive end-of-pipe controls, a variance from the mercury water quality standards is available under section D(l 0) of rule 3745-33-07. If the permittee determines it is eligible, it may submit an application for coverage under this mercury variance. Section D(lO)(a) of rule 3745-33-07 includes information on eligibility for coverage and lists the information that must be included in the application; or c) If the permittee detennines that compliance with a monthly average water qualitybased effluent limit for mercury of 1.3 ng/I is not possible, and it is not eligible for coverage under the mercury variance available at section D(lO) of rule 3745-33-07, it may submit an application for an individual variance from water quality standards. Section (D)(l-3) of rule 3745-33-07 provides information on the applicability and conditions of an individual variance. Section (D)(4) of the rule lists the information that must be included in the application. A guidance document explaining both the mercury variance and the individual variance as well as an example of an acceptable mercury variance application are available at http://www.epa.state.oh.usldsw/guidance/guidance.html (Permit Guidance 10). Copies are available upon request from Ohio EPA, Central Office, Division of Surface Water, Pennits Section. Applications submitted under this item shall be sent to the Division of Surface Water at the appropriate Ohio EPA District Office. AA. It is understood by Ohio EPA that at the time permit becomes effective, an analytical method is not approved under 40 CPR 136 to comply with the free cyanide monitoring requirements included in the permit. The permittee shall utilize method 4500-CN I in Standard Methods until U.S. EPA promulgates a method for analyzing free cyanide under 40 CFR 136.

000318

Page 33 3PFOOOOO*LD BE. Pretreatment Program Requirements

The pennittee's approved pretreatment program and sub~'equentmodification\i!H::I~~i!1g _, __ - §'i;ted: listed belOW,,,,,.._ _ _ conditions of such approvals, shall be an enforceable teffil and condition of this permit. 'L _ _ _ _ ~~_ _ ~ _ "" _ _ _ _ _ _ _ _ _ ". ~ .• "" _, - - {~_eleted: Des;ription OfMOdifiCf55ij To ensure that the approved program is implemented in accordance with 40 eFR 403 and Chapter 6111 of the Ohio Revise Code, the permittee shall comply with the following conditions:
1. Legal Authority

===:J

The pennittee shall adopt and maintain legal authority which enables it to fully implement and enforce all aspects of its approved pretreatment program including the identification and characterization of industrial sources, issuance of control documents, compliance monitoring and repOliing, and enforcement.
2. Industrial User Inventory The pennittee shall identify all industrial users subject to pretreatment ~iandards and requirements and characterize the nature and volume of pollutants in their wastewater. Dischargers determined to be Significant Industrial Users according to OAC 3745-3OI(BB) must be notified of applicable pretreatment standards and requirements within 30 days of making such a detennination. This inventory shall be updated at a frequency to ensure proper identification and characterization of industrial users. 3. Local Limits The permittee shall develop and enforce technically based local limits to prevent the introduction of pollutants into the POTW which will interfere with the operation of the POTW, pass through the treatment works, be incompatible with the treatment works, or limit wastewater or sludge use options.

000319

Page 34 3PFOOOOO*LD The permittee shall use the following water quality based values when evaluating local limits for the following pollutants, which do not have discharge limitations: Arsenic 135 ug/l 5.8 ug/I 12 ug/I 131 ug/I 5.7 ug/l 24 ug/I 136 ug/I 120 ug/l 272 ug/l

Cadmium
Chromium, hexavalent Chromium, total Cyanide Copper Lead Nickel Zinc

For the purpose of periodically reevaluating local limits, the permittee shall implement and maintain a sampling program to characterize pollutant contribution to the POTW from industrial and residential sources and to determine pollutant removal rates through the P01W. The permittee shall continue to review and develop local limits as necessary. 4. Control Mechanisms The permittee shall issue individual control mechanisms to all industries determined to be Significant Industrial Users as define in OAC 3745-3-QI(BB). Control mecbanisms must meet at least the minimum requirements ofOAC-3745-3-03(C)(l)(c). 5. Industrial Compliance Monitoring The pennittee shall sample and inspect industrial users in accordance with the approved program. However, monitoring frequencies must be adequate to determine the compliance status of industrial users independent of information submitted by such users. Sample collection, preservation and analysis must be performed in accordance with procedures in 40 CPR 136 and with sufficient care to produce evidence admissible in judicial enforcement proceedings. The permittee shall also require, receive, and review self-monitoring and other industrial user reports when necessary to determine compliance with pretreatment standards and. requirements. 6. POTW Priority Pollutant Monitoring The permittee shall annually monitor priority pollutants, as defined by U.S. EPA, in the POTW's influent, effluent and sludge. Sample collection, preservation, and analysis shall be performed using U.S. EPA approved metbods.

000320

Page 35 3PFOOOOO*LD a. A sample of the influent and the effluent shall be collected when industrial discharges are occurring at normal to maximum levels. Both samples shall be collected on the same day or, alternately, the effluent sample may be collected following the influent sample by approximately the retention time of the POTW. The samples shall be 24 hour composites except for volatile organics and cyanide which shall be collected by appropriate grab sampling techniques. Sampling of the influent shall be done prior to any recycle streams and sampling of the effluent shall be after disinfection. Another sample shall be representative of sludge removed to final disposaL A minimum of one grab sample shall be taken during actual sludge removal and disposal unless the POTW uses more than one disposal option. If multiple disposal options are used, the POTW shall collect a composite of grab samples from all disposal practices which are proportional to the annual flows to each type of disposal. b. A reasonable attempt shall be made to identify and quantify additional constituents (excluding priority pollutants 'and unsubstituted aliphatic compounds) at each sample location. Identification of additional peaks more than ten times higher than the adjacent background noise on the total ion plots (reconstructed gas chromatograms) shaH be attempted through the use of U.S. EPAINIH computerized library of mass spectra, with visual confirmation by an experienced analyst. Quantification may be based on an order of magnitude estimate compared with an internal standard. The results of these samples must be submitted on Ohio EPA Fonn 4221 with the permittee's annual pretreatment report. Samples may be collected at any time during the 12 months preceding the due date of the annual report and may be used to fulfill other NPDES monitoring requirements where applicable. 7. Enforcement The permittee shall investigate all instances of noncompliance with pretreatment standards and requirements and take timely, appropriate, and effective enforcement action to resolve the noncompliance in accordance with the permittee's approved enforcement response plan. On or prior to August 15th of each year, the permittee Shall publish, in the largest daily newspaper within the permittee's service area, a list of industrial users which, during the previous 12 months, have been in Significant Noncompliance [OAC 3745-3-03(C)(2)(g)] with applicable pretreatment standards or requirements.

000321

Page 36

3PFOOOOO*LD
8. Reporting All reports required under this section shall be submitted to the following address in duplicate: Ohio Environmental Protection Agency Division of Surface Water Pretreatment Unit P.O. Box 1049 Columbus, OH 43216-1049 a. Quarterly Industrial User Violation Report On or prior to the 15th day of March, June, September and December the permittee shall report the industrial users that are in violation of applicable pretreatment standards during the previous calendar quarter. The report shall be prepared in accordance with guidance provided by Ohio EPA and shall include a description of all industrial user violations and corrective actions taken to resolve the violations. b. Annual Pretreatment Report On or prior to May 15th of each year, the permittee shall submit an annual report on the effectiveness of the pretreatment program, prepared in accordance with guidance provided by Ohio EPA. The report shall include, but not be limited to: a discussion of program effectiveness; and industrial user inventory; a description of the permittee's monitoring program; a description of any pass through or intetference incidents; a copy of the annual publication of industries in Significant Noncompliance; and, priority pollutant monitoring results. 9. Record Keeping All records of pretreatment activities including, but not limited to, industrial inventory data, monitoring results, enforcement actions, and reports submitted by industrial users must be maintained for a minimum of three (3) years. This period of retention shall be extended during the course of any umesolved litigation. Records must be made available to Ohio EPA aud U.S. EPA upon request. 10. Program Modifications Any proposed modifications of the approved pretreatment program must be submitted to the Ohio EPA for review, on forms available from Ohio EPA and consistent with guidance provided by Ohio EPA. If the modification is deemed to be substantial, prior approval must be obtained before implementation; otherwise, the modification is considered to be effective 45 days after the date of application. Substantial program modifications include, among other things, changes to the POTW's legal authority, control mechanism, local limits, confidentiality procedures, or monitoring frequencies.

000322

Page 37 3PFOOOOO*LD

cc. Biomonitoring Program Requirements
Compliance Monitoring Program As soon as possible, but not later 3 months after the effective date of this permit, the entity shall initiate an effluent biomonitoring program to evaluate compliance with the whole effluent toxicity limits of 1.0 TUc (monthly) and 1.8 TUc (maximum) for Ceriodaphnia dubia at outfall3PFOOOOOOO 1 . The whole effluent toxicity limits become effective 48 months after the effective date of the penuit.

General Requirements
All toxicity testing conducted as required by this permit shall be done in accordance with Reporting and Testing Guidance for Biomonitoring Required by the Ohio Environmental Protectiou Agency (hereinafter, the "biomonitoring guidance"), Obio EPA, July 1998 (or current revision). The Standard Operating Procedures (SOP) or verification,of SOP submittal, as described in Section 1.B. of the biomonitoring guidance, shall be submitted no later than three months after the effective date of this permit. If the laboratory perfonning the testing has modified its protocols, a new SOP is required. Testing Requirements

1.

Chronic Bioassays

For the duration of this permit, the pennittee shall conduct quarterly chronic toxicity tests using Cenodaphnia dubia on effluent samples from outfall 3PF00000602. These tests shall be conducted as specified in Section 3 of the biomonitoring guidance. t _, _ ~ ~ ~ ~ 2. Testing of Ambient Water

-

~d~ '\l

~~~-~~

In conjunction with the chronic toxicity tests, upstream control water shall be collected at
a point outside the zone of effluent and receiving water interaction at station 3PF00000801. Testing of ambient waters shall be done in accordance with Section 3 of the biomonitoring guidance. 3. a. Data Review Reporting

Following completion ofeach quarterly bioassay requirement, the permittee shall report results of the tests in accordance with Sections 3.11.1. and 3.H.2.a. of the biomonitoring guidance. Ohio EPA will evaluate the results in order to judge compliance with the whole effluent toxicity limits of 1.0 TUe (monthly) and 1.8 TUe (maximum) for Ceriodaphnia dubia at outfall 3PF00000602.. ~1]J~ ~,,~~h_o!e_ ~f[ly~n1 !~?'}01yJ~~!S~~e~2f!l~ ~ff~~tiy~ j§ _ ~ ~ months after the effective date of this pennit. In addition, this pennit may be modified to require additional biomonitoring or to require further investigation of toxicity in accordance with OAC procedures. "' ~ ~ ~ ~ _ ~ ~ ~ ~ ~ ~ "" ~ ~ ~ ~ _ ~ ~ ~ ~ ~ ~ ~ ~~~~~~

-~:

3PFOOOOOOol·-----:==J

- -( Deleted:...::

,J

000323

Page 38 3PFOOOOO*LD

b. Definitions
TUc Chronic Toxicity Units
c"

IOO/IC25

This equation for chronic toxicity units applies outside the mixing zone for wannwater modified warrnwater, exceptional warmwater, coldwater~ and seasonal salmonid use designations except when the following equation is more restrictive (Ceriodaphnia dubia only):
TUc Chronic Toxic Units ~ IOO/square root of (NOEC x LOEC)
reduction evaluation (TRE)~

Deleted: c. Trigger to'i~ifute a toxici;l

1

I

Based Upoll evaluation of the data required under 3,3, above, Ohio EPA personnel will detennine if a TRE will be
required ofllle pennittee. A decision to

require a TRE will be based upon
professional judgment and the following decision criteria:~

'1
i

i limit of 1.0 TUc in the outfall
3PFOOOOOOOI effluent'i

1) two or more tests exceed the montllly

1

2) two or more tests exceed the maximum limit of 1.8 TUc in the outfall
effluent;~

3PFOOOOOOOI

3) a review of the test procedures for adequacY;,r

'1

'4) evaluation of the normality ofProcess 1
and treatment plant operations at the time of sampling;~

1

~) evaluation of ambient toxicity data and"J

I
i

,

6) evaluation orany available biosurvey

1

~~~

'

The pennittee shall receive written notification from the Ohio EPA if a TRE is required. If a TRE is not required based upon the above criteria, Ohio EPA will review the biomonitoring results as in 3.a.
above.~

000324

Page 39 3PFOOOOO*LD
P ART III - GENERAL CONDlTIONS
1. DEFINITIONS

"Daily discharge" means the discharge of a pollutant measured during a calendar day or any 24~hour period that reasonably represents the calendar day for purposes of sampling. For pollutants with limitations expressed in units of mass, the "daily discharge" is calculated as the total mass oftlle pollutant discharged over the day. For pollutants with limitations expressed in other units of measurement, the "daily discharge" is calculated as the average measurement oftlle pollutant over the
day.

"Average weekly" discharge limitation means the highest allowable average of "daily discharges" over a calendar week, calculated as the sum of all "daily discharges" measured during a calendar week divided by the number of "daily discharges" measured during that week. Each of the following 7-day periods is defined as a calendar week: Week 1 is Days I - 7 of the month; Week 2 is Days 8 - 14; Week 3 is Days 15 - 21; and Week 4 is Days 22 throlH!h the last clay of the month. ~o3np!i~n.s:~ \yi!hJ~~at ~ ~ __ " _ - -If Deleted: _28. If the "daily discharge" coliform bacteria ,or E coli bacteria limitations shall be detennined using the geometric mean. on days 29, 30 or 31 exceeds the "average weekly" discharge limitation, Ohio EPA "Average monthly" discharge limitation means the highest allowable average of "daily discharges" may elect to evaluate the last 7 days of i the month as Week 4 instead of Days 22over a calendar month; calculated as the sum of all "daily discharges" measured during a calendar ~_~~~~ _~~~~~ month divided by the number of "daily discharges" measured during that month. Compliance with fecal coliform bacteria or E coli bacteria limitations shall be determined using the geometric mean.

I

"85 percent removal" means the arithmetic mean of the values for effluent samples collected in a period of 30 consecutive days shall not exceed 15 percent of the arithmetic mean of the values for influent samples collected at approximately the same times during the same period. "Absolute Limitations" Compliance with limitations having descriptions of "shall not be less than," "nor greater than," shall not exceed," "minimum," or "maximum" shall be detennined from any single value for effluent samples and/or measurements collected. "Net concentration" shall mean the difference between the concentration of a given substance in a sample taken of the discharge and the concentration of the same substances in a sample taken at the intake which supplies water to the given process. For the purpose of this defmition, samples that are taken to determine the net concentration shall always be 24-hour composite samples made up of at least six increments taken at regular intervals throughout the plant day.

000325

Palt III General Conditions (Can't)

Page 40 3PFOOOOO'LD

"Net Load" shall mean the difference between the load of a given substance as calculated from a sample taken of the discharge and the load of the same substance in a sample taken at the i.ntake which supplies water to given process. For purposes of this defInition, samples-that are taken to determine the net loading shall always be 24-hour composite samples made up of at least six increments taken at regular intervals throughout the plant day. "MGD" means million gallons per day. "mg/l" means milligrams per liter. "ug/l" means micrograms per liter. "ng/l" means nanograms per liter. "S.U." means standard pH unit. "kg/day" means kilograms per day. "Reporting Code" is a five digit number used by the Ohio EPA in processing reported data. The reporting code does not imply the type of analysis used nor the sampling techniques employed. "Quarterly (l/Quarter) sampling frequency" means the sampling shall be doneJn each ca!end~r guartcJi. unless specifically identified otherwise i.n the Effiuent Limitations and Monitoring Requirements table. "Yearly (l/Year) sampling frequency" means the sampling shall be done in the month of September, unless specifically identified otherwise in the effiuent limitations and monitoring requirements table. "Semi-annual (2/Year) sampling frequency" means the sampling shall be done during the months of June and December, unless specifically identified otherwise. "Winter" shall be considered to be the period from November I through April 30. "Bypass" means the intentional diversion of waste streams from any portion of the treatment facility. "Sununer" shall be considered to be the period from May 1 through October 31. "Severe property damage" means substantial physical damage to property, damage to the treatment facilities which would cause them to become inoperable, or substantial and permanent loss of natural resources which can reasonably be expected to occur in the absence of a bypass. Severe property damage does not mean economic loss caused by delays in production. "Upset" means an exceptional incident in which there is unintentional and temporary noncompliance with technology based pennit effluent limitations because of factors beyond the reasonable control of the pennittee. An upset does not include noncompliance to the extent caused by operational error, improperly designed treatment facilities, inadequate treatment facilities, lack of preventive maintenance, or careless or improper operation.

"" -~d~------'-"'-i
Deleted: the months of March, June,
AUb'Ust, and December,

000326

Page 41 Part III General Conditions (Con't)

3PFOOOOO*LD

"Sewage sludge" means a solid, semi-solid, or liquid residue generated during the treatment of domestic sewage in a treatment works as defined in section 61110 I of the Revised Code. "Sewage sludge" includes, but is not limited to, scum or solids removed in primary, secondary, or advanced wastewater treatment processes. "Sewage sludge" does not include ash generated during the firing of sewage sludge in a sewage sludge incinerator, grit and screenings generated during preliminary treatment of domestic sewage in a treatment works, animal manure, residue generated during treatment of animal manure, or domestic septage. "Sewage sludge weight" means the weight of sewage sludge, in dry U.S. tons, including admixtures such a'l liming materials or balking agents. Monitoring frequencies for sewage sludge parameters are based on the reported sludge weight generated in a calendar year (use the most recent calendar year data when the NPDES pennit is up for renewal). "Sewage sludge fee weight" means the weight of sewage sludge, in dry U.S. tons, excluding admixtures such as liming materials or bulking agents. Annual sewage sludge fees, as per section 3745.11(Y) of the Ohio Revised Code, are based on the reported sludge fee weight for the most recent calendar year. 2. GENERAL EFFLUENT LIMITATlONS The effluent shall, at all times, be free of substances:

A. In amounts that will settle to fonn putrescent, or otherwise objectionable, sludge deposits; or that will adversely affect aquatic life or water fowl;
B. Of an oily, greasy, or surface-active nature, and of other floating debris, in amounts that will fonn noticeable accumulations of scum, foam or sheen; C. In amounts that will alter the natural color or odor of the receiving water to such degree as to create a nuisance, D. in amounts that either singly or in combination with other substances are toxic to human animal or, aquatic life;
E. In amounts that are conducive to the growth of aquatic weeds or algae to the extent that such growths become inimical to more desirable forms of aquatic life, or create conditions that are unsightly, or constitute a nuisance in any other fashion;

F. In amounts that will impair designated instream or downstream 3. FACILITY OPERATION AND QUALITY CONTROL

wat~ uses.

All wastewater treatment works shall be operated in a manner consistent with the following:
A. At all times, the permittee shall maintain in good working order and operate as efficiently as possible all treatment or control facilities or systems installed or used by the pennittee necessary to achieve compliance with the tenns and conditions of this pennie Proper operation and maintenance also includes adequate laboratory controls and appropriate quality assurance procedures. This provision requires the operation of back-up or auxiliary facilities or similar systems which are installed by a pennittee only when the operation is nec{,,'Ssary to achieve compliance with conditions of the pennit.

B. The permittee shall effectively monitor the operation and efficiency of treatment and control facilities and the quantity and quality of the treated discharge.
C. Maintenance of wastewater treatment works that results in degradation of effluent quality shall be scheduled dating non-critical water qualiiy periods and shall be carried out in a manner approved by Ohio EPA as specified in the Paragraph in the PART III entitled, "UNAUTHORIZED DISCHARGES".

000327

Part III General Conditions (Contt) 4. REPORTING

Page 42 3PFOOOOO'LD

A. Monitoring data required by this permit may be submitted in hardcopy fonnat on the Ohio EPA 4500 report fonn pre-printed by Ohio EPA or an approved facsimile. Ohio EPA 4500 report forms for each individual sampling station are to be received no later than the 15th day of the month following the month-of-interest. The original report fonn must be signed and mailed to: Ohio Environmental Protection Agency Lazarus Government Center Division of Surface Water Enforcement Section ES/MOR P.O, Box 1049 Columbus, Ohio 43216-1049 Monitoring data may also be submitted electronicaI1y using Ohio EPA developed SWIMware software. Data must be transmitted to Ohio EPA via electronic mail or the bulletin board system by the 20th day of the month following the month-of-interest. A Surface Water Information Management System (SWIMS) Memorandum of Agreement (MOA) must be signed by the responsible official and submitted to Ohio EPA to receive an authorized Personal Identification Number (PIN) prior to sending data electronically. A hardcopy of the Ohio EPA 4500 form must be generated via SWIMware, signed and maintained onsite for records retention purposes.

B. If the permittee monitors any pollutant at the location(s) designated herein more frequently than required by this pennit, using approved analytical methods as specified below, the results of such monitoring shall be included in the calculation and reporting of the values required in the reports specified above.
C. Analyses of pollutants not required by this pennit, except as noted in the preceding paragraph, shall not be reported on Ohio EPA report fonn (4500) but records shall be retained as specified in the paragraph entitled "RECORDS RETENTION". 5. SAMPLING AND ANALYTICAL METHOD Samples and measurements taken as required herein shall be representative of the volume and nature of the monitored flow. Test procedures for the analysis of pollutants shall conform to regulation 40 CFR 136, "Test Procedures For The Analysis of Pollutants" unless other test procedures have been specified in this permit. The permittee shall periodically calibrate and perfonn maintenance procedures on all monitoring and analytical instrumentation at intervals to insure accuracy of measurements. 6. RECORDING OF RESULTS For each measurement or sample taken pursuant to the requirements of this permit, the permittee shall record the following information: A. The exact place and date of sampling; (time of sampling not required on EPA 4500) B. The person(s) who perfonned the sampling or measurements; C. The date the analyses were perfonned on those samples; D The person(s) who performed the analyses;

E. The analytical techniques or methods used; and
F. The results of all analyses and measurements.

000328

Page 43 Part III General Conditions (Can't) 7. RECORDS RETENTION The pennittee shall retain all of the following records for the wastewater treatment works for a minimum of three years except those records that pertain to sewage sludge disposal, use, storage, or treatment, which shall be kept for a minimum of five years, including: A. All sampling and analytical records (including internal sampling data not reported);
B. All original recordings for any continuous monitoring instrumentation;

JPFOOOOO'LD

C. All instmmentation, calibration and maintenance records;

D. All plant operation and maintenance records;
E. All reports required by this permit; and
F. Records of all data used to complete the application for this pennit for a period of at least three years, or five years for sewage sludge, from the date of the sample, measurement, report, or application.

These periods will be extended during the course of any unresolved litigation, or when requested by the Regional Administrator or the Ohio EPA. The three year period, or five year period for sewage sludge, for retention of records shall staI1 from the date of sample, measurement, report, or application. 8. AVAILABIUTY OF REPORTS Except for data determined by the Ohio EPA to be entitled to confidential status, all reports prepared in accordance with the terms of this permit shall be available for public inspection at the appropriate district offices of the Ohio EPA. Both the Clean Water Act and Section 0111.05 Ohio Revised Code state that effluent data and receiving water quality data shall not be considered confidential. 9. DUTY TO PROVIDE INFORMATION The permittee shall furnish to the Director, within a reasonable time, any information which the Director may request to detennine whether cause exists for modifying, revoking, and reissuing, or terminating the permit, or to detennine compliance with this permit. The permittee shall also fumish to the Director, upon request, copies of records required to be kept by this permit 10. RIGHT OF ENTRY The pennittee shall allow the Director or an authorized representative upon presentation of credentials and other documents as may be required by law to:
A. Enter upon the permittee's premises where a regulated facility or activity is located or conducted, or where records must be kept under the conditions of this pennit.

B. Have access to and copy, at reasonable times, any records that must be kept under the conditions of the permit. C. Inspect at reasonable times any facilities, equipment (including monitoring and control equipment), practices" or operations regulated or required under this permit. D. Sample or monitor at reasonable times, for the purposes of assuring permit compliance or as otherwise authorized by the Clean Water Act, any substances or parameters at any location.

000329

Page 44 Part III General Conditions (Can't) 11. UNAUTHORIZED DISCHARGES A. Bypassing or diverting of wastewater from the treatment works is prohibited unless: 1. Bypass was unavoidable to prevent loss of life, personal injury, or severe property damage; 2. There were no feasible alternatives to the bypass, such as the use of auxiliary treatment facilities retention of untreated wastes, or maintenance during normal periods of downtime. This condition is not satisfied if adequate back up equipment should have been installed in the exercise of reasonable engineering judgment to prevent a bypass which occurred during nonnal periods of equipment downtime or preventive maintenance; and 3. The pennittee submitted notices as required under paragraph D. of this section, B. If the permittee knows in advance of the need for a bypass, it shall submit prior notice, if possible at least ten days before the date of the bypass.
C. The Director may approve an unanticipated bypass after considering its adverse effects, if the Director detennines that it has met the three conditions listed in paragraph Il.A. of this section.

3PFOOOOO'LD

D. The permittee shall submit notice of an unanticipated bypass as required in section 12. A. E. The pennittee may allow any bypass to occur which does not cause eff1uent limitations to be exceeded if that bypass is for essential maintenance to assure efficient operation.

000330

Page 45· Part III General Conditions (Cant) 12. NONCOMPLIANCE NOTIFICATION A. The permittee shall by telephone report any of the following within twenty~four(24) hours of discovery at (toll free) 1~800~282-9378: · Any noncompliance which may endanger health or the environment; 2. Any unanticipated bypass which exceeds any effluent limitation ill the permit; or 3. Any upset which exceeds any effluent limitation in the pemlit. 4. Any violation of a maximum daily discharge limitation for any of the pollutants listed by the Director in the pennit. B. For the telephone reports required by Part 12.A., the following information must be included: · The times at which the discharge occurred, and was discovered; 2. The approximate amount and the characteristics of the discharge; 3. The stream(s) affected by the discharge; 4. The circumstances which created the discharge; 5. The names and telephone numbers of the persons who have knowledge of these circumstances; 6. What remedial steps are being taken; and 7. The names and telephone numbers of the persons responsible for such remedial steps. C. These telephone reports shall be confirmed in writing within five days of the discovery of the discharge and/or noncompliance and submitted to the appropriate Ohio EPA district office. The report shall include the following: · The limitation(s) which has been exceeded; 2. The extent of the exceedance(s); 3. The cause of the exceedance(s); 4. The period of the exceedance(s) including exact dates and times; 5. If uncorrected, the anticipated time the exceedance{s) is expected to continue, and 6. Steps being taken to reduce, eliminate, and/or prevent occurrence of the exceedance(s).

3PFOOOOQ'LD

000331

Part III General Conditions (Can't) D. Compliance Schedule Events:

Page 46 3PFOOOOO*LD

If the pennittee is unable to meet any date for achieving an event, as specified in the schedule of compliance, the permittee shall submit a written report to the appropriate district office of the Ohio EPA within 14 days of becoming aware of such situation. The repmt shall include the following: 1. The compliance event which has been or will be violated; 2. The cause of the violation; 3. The remedial action being taken; 4. The probable date by which compliance will occur; and 5. The probability of complying with subsequent and fmal events as scheduled. E. The permittee shall report all instances of noncompliance not reported under paragraphs A, B, or C of this section, at the time monitoring reports are submitted. The reports shall contain the information listed in paragraphs Band C of this section. F. Where the permittee becomes aware that it failed to submit any relevant application or submitted incorrect infonnation in a permit application or in any report to the director, it shall promptly submit such facts or information. 13. RESERVED 14. DUTY TO MITIGATE The permittee shall take all reasonable steps to minimize or prevent any discharge in violation of this penuit which has a reasonable likelihood of adversely affecting human health or the environment. 15. AUTHORIZED DISCHARGES All discharges authorized herein shall be consistent with the terms and conditions of this permit. The discharge of any pollutant identified in this permit more frequently than, or at a level in excess of, that authorized by this permit shall constitute a violation of the terms and conditions of this pennit. Such violations may result in the imposition of civil and/or criminal penalties as provided for in Section 309 of the Act and Ohio Revised Code Sections 6111.09 and 6111.99. 16. DISCHARGE CHANGES The following changes must be reported to the appropriate Ohio EPA district office as soon as practicable:
A.. For all treatment works, any significant change in character of the discharge which the permittee knows or has reason to believe has occurred or will occur which would constitute cause for modification or revocation and reissuance. The pennittee shall give advance notice to the Director of any planned changes in the permitted facility or activity which may result in noncompliance with pennit requirements. Notification ofpennit changes or anticipated noncompliance does not stay any pennit condition.

B. For publicly owned treatment works:

1. Any proposed plant modification, addition, and/or expansion that will change the capacity or efficiency of the plant;

000332

2. The addition of any new significant industrial discharge; and 3. Changes in the quantity or quality of the wastes from existing tributary industrial discharges which will result in significant new or increased discharges of pollutants.

000333

Part III General Conditions (Con't)

Page 47 3PFOOOOO'LD

C. For non~publicly owned treatment works, any proposed facility expansions. production increases, or process modifications, which will result in new, different, or increased discharges of pollutants. Following this notice, modifications to the pennit may be made to reflect any necessary changes in pennit conditions, including any necessary effluent limitations for any pollutants not identified and limited herein. A determination will also be made as to whether a National Environmental Policy Act (NEPA) review will be required. Sections 6111.44 and 6111.45. Ohio Revised Code, require that plans for treatment works or improvements to such works be approved by the Director of the Ohio EPA prior to initiation of construction. D. In addition to the rep011ing requirements under 40 CFR 122.41(1) and per 40 CFR 122.42(a), all existing manufacturing. commercial, mining, and silvicultural dischargers must notify the Director as soon as they know or have reason to believe: 1. That any activity has occurred or will occur which would result in the discharge on a routine or frequent basis of any toxic pollutant which is not limited in the pennit. If that discharge will exceed the highest of the "notification levels" specified in 40 CFR Sections 122.42(a)( l)(i) through 122A2(a)(I)(iv). 2. That any activity has occurred or will occur which would result in any discharge, on a non~routine or infrequent basis, ofa toxic pollutant which is not limited in the pennit, ifthat discharge will exceed the highest of the "notification levels" specified in l22.42(aX2Xi) through I22.42(a)(2)(iv).
17. TOXIC POLLUTANTS

The permittee shall comply with effluent standards or prohibitions established under Section 307 (a) of the Clean Water Act for toxic pollutants within the time provided in the regulations that establish these standards or prohibitions, even if the pennit has not yet been modified to incorporate the requirement. Following establishment of such standards or prohibitions, the Director shall modify this pennit and so notify the permittee.
18. PERMIT MODIFICATION OR REVOCATION

A. After notice and opportunity for a hearing, this permit may be modified or revoked, by the Ohio EPA, in whole or in part during its term for cause including, but not limited to, the following: 1. Violation of any terms or conditions of this permit; 2. Obtaining this permit by misrepresentation or failure to disclose filly all relevant facts; or 3 . Change in any condition that requires either a temporary or permanent reduction or elimination of the permitted discharge. B. Pursuant to rule 3745-33-04, Ohio Administrative Code, the pennittee may at any time apply to the Ohio EPA for modification of any part of this pennit. The filing ofa request by the pennittee for a pennit modification or revocation does not stay any pennit condition. The application for modification should be received by the appropriate Ohio EPA district office at least ninety days before the date on which it is desired that the modification become effective. The application shan be made only on forms approved by the Ohio EPA.

000334

Page 48 Part III General Conditions (Cont) 19. TRANSFER OF OWNERSHIP OR CONTROL This permit may be transferred or assigned and a new owner or successor can be authorized to discharge from this facility, provided the following requirements are met:
A. The permittee shall notify the succeeding owner or successor of the existence of this permit by a letter, a copy of which shall be forwarded to the appropriate Ohio EPA district office. The copy of that letter will serve as the permittee's notice to the Director of the proposed transfer. The copy of that letter shall be received by the appropriate Ohio EPA district office sixty (60) days prior to the proposed date of transfer

JPFOOOOO*LD

B. A written agreement containing a specific date for transfer ofpenmt responsibility and coverage between the current and new penmttee (including acknowledgement that the existing pennittee is liable for violations up to that date, and that the new pennittee is liable for violations from that date on) shall be submitted to the appropriate Ohio EPA district office within sixty days after receipt by the district office of the copy of the letter from the pennittee to the succeeding owner;
At anytime during the sixty (60) day period between notification of the proposed transfer and the effective date of the transfer, the Director may prevent the transfer ifhe concludes that such transfer will jeopardize compliance with the tenns and conditions of the pennit If the Director does not prevent transfer, he will modify the permit to reflect the new owner. 20. OIL AND HAZARDOUS SUBSTANCE LIABILITY Nothing in this pennit shall be construed to preclude the institution of any legal action or relieve the pennittee from any responsibilities, liabilities, or penalties to which the penllittee is or may be subject under Section 311 of the Clean Water Act. 2 I . SOLIDS DISPOSAL Collected grit and screenings, and other solids other than sewage sludge, shall be disposed of in such a manner as to prevent entry of those wastes into waters of the state, and in accordance with all applicable laws and rules. 22. CONSTRUCTION AFFECTING NAVIGABLE WATERS This pennit does not authorize or approve the construction of any onshore or offshore physical structures or facilities the undertaking of any work in any navigable waters. 23- CIVIL AND CRIMINAL LIABILITY Except as exempted in the pennit conditions on UNAUTHORIZED DISCHARGES or UPSETS, nothing in this permit shall be construed to relieve the permittee from civil or criminal penalties for noncompliance. 24. STATE LAWS AND REGULATIONS Nothing in this permit shall be construed to preclude the institution of any legal action or relieve the pennittee from any responsibilities, liabilities, or penalties established pursuant to any applicable state law or regulation under authority preserved by Section 510 of the Clean Water Act. 25. PROPERTY RIGHTS The issuance of this pennit does not convey any property tights in either feal or personal property, or any exclusive privileges, nor does it authorize any injury to private property or any invasion of personal

000335

rights, nor any infringement of federal, state, or local laws or regulations.

000336

Part III General Conditions (Cont) 26. UPSET

Page 49 3PFOOOOO'LD

The provisions of 40 CFR Section 122.41(n), relating to "Upset," are specifically incorporated herein by reference in their entirety. For definition of upset," see Part III, Paragraph 1, DEFINITIONS. 27. SEVERABILITY The provisions of this penuit are severable, and if any provision of this penuit, or the application of any provision of this pennit to any circumstance, is held invalid, the application of such provision to other circumstances, and the remainder of this pennit, shall not be affected thereby. 28. SIGNATORY REQUIREMENTS All applications submitted to the Director shall be signed and certified in accordance with the requirements of40 CFR 122.22. All reports submitted to the Director shall be signed and certified in accordance with the requirements of 40 CFR Section 122.22. 29. OTHER INFORMATION A. Where the pennittee becomes aware that it failed to submit any relevant facts in a pennit application or submitted incorrect information in a penuit application or in any report to the Director, it shall promptly submit such facts or infonnation. B. ORC 61 I 1.99 provides that any person who falsifies, tempers with, or knowingly renders inaccurate any monitoring device or method required to be maintained under this pennit shall, upon conviction, be . punished by a fme of not more than $25,000 per violation. C. ORC 6111.99 states that any person who knowingly makes any false statement, representation, or certification in any record or other document submitted or required to be maintained under this pennit induding monitoring reports or reports of compliance or noncompliance shall, upon conviction, be punished by a fme of not more than $25,000 per violation. D. ORC 6111.99 provides that any person who violates Sections 6111.04, 6111.042, 6111.05, or division (A) of Section 6111.07 of the Revised Code shall be fmed not more than $25,000 or imprisoned not more than one year, or both. 30. NEED TO HALT OR REDUCE ACTIVITY 40 CFR 122.41 (c) states that it shall not be a defense for a permittee in an enforcement action that it would have been necessary to halt or reduce the permitted activity in order to maintain compliance with conditions of this permit. 31. APPLICABLE FEDERAL RULES All references to 40 CER in this permit mean the version of 40 CFR which is effective as of the effective date of this pennit. 32. AVAILABILlTY OF PUBLIC SEWERS Not withstanding the issuance or non-issuance of an NPDES permit to a semi-public disposal system, whenever the sewage system of a publicly owned treatment works becomes available and accessible, the permittee operating any semi-public disposal system shall abandon the semi-public disposal system and connect it into the publicly owned treatment works.

000337

77!NE

Application No.: OH0023833 Ohio EPA Permit No.: 3PFOOOOO*W

National Pollntant Discharge Elimination System (NPDES) Permit Program PUBLIC NOTICE
NPDES Permit to Discharge to State Waters Ohio Environmental Protection Agency Permits Section 122 South Front Street P. O. Box 1049 Columbus, Ohio 43216-1049 (614) 644-2001 Public Notice No.: Date of Issue of Public Notice: Name and Address of Applicant: OEPA 6-08-066 Aug-28-2006 Mayor and Council, City of Akron, 166 South High Street, Akron, OH 44313 City of Akron WWTP, 2460 Akron Peninsula Road, Akron, OH, Summit County 001 001 90,000,000 GPD Cuyahoga River 41 N 09' 00"

Name and Address of Facility Where Discharge Occurs: Outfall Flow and Location List: Receiving Stream: Nature of Business: Key parameters to be limited in the permit are as follows:

81 W 33' 45"

Municipal Wastewater Treatment Plant Chlorine, Total Residual, Chronic Toxicity, Ceriodaphnia dubia, Dissolved Oxygen, Fecal Colifonn, Arsenic, Total In Sludge, Cadmium, Total In Sludge, Copper, Total In Sludge, Fecal Colifonn in Sludge, Lead, Total In Sludge, Mercury, Total In Sludge, Molybdenum In Sludge, Nickel, Total In Sludge, Selenium, Total In Sludge, Zinc, Total In Sludge, CBOD 5 day, Nitrogen, Ammonia (NH3), Oil and Grease, Hexane Extr Method, Oil and Grease, Total, Phosphorus, Total (P), Total Suspended Solids, pH, Maximum, pH, Minimum, CBOD 5 day, and Total Suspended Solids

On the basis of preliminary staff review and application of standards and regulations, the director of the Ohio Environmental Protection Agency will issue a permit for the discharge subject to certain effiuent conditions and special conditions. The draft pennit will be issued as a final action unless the director re\tises the draft after consideration of the record of a public meeting or written comments, or upon disapproval by the administrator of the U.S. Environmental Protection Agency. Any person may submit written comments on the draft permit and administrative record and may request a public hearing. A request for public hearing shall be in writing and shall state the nature of the issues to be raised. In appropriate cases, including cases where there is significant public interest, the director may hold a public hearing on a draft permit or permits prior to final issuance of the permit or permits. Following final action by the director, any aggrieved party has the right to appeal to the Environmental Review Appeals Commission.

000338

nINE

Application No.: OH0023S33 Ohio EPA Pennit No.: 3PFOOOOO*LD

Interested persons are invited to submit written comments upon the discharge pennit. Comments should be submitted in person or by mail no later than 30 days after the date of this public notice. Comments should be delivered or mailed to both of the following locations: 1) Ohio Environmental. Protection Agency, Lazarus Government Center, Division of Swface Water, Permits Processing Unit, 122 South Front Street, P.O. Box 1049, Columbus, Ohio 43216-1049 and 2) Ohio Environmental Protection Agency, Northeast District Office 2110 East Aurora Road, Twinsburg, Ohio 44087. The Ohio EPA pennit number and public notice numbers should appear next to the above address on the envelope and on each page of any submitted comments. All comments received no later than 30 days after the date of this public notice will be considered. The application, fact sheets, pennit including effluent limitations, special conditions, comments received, and other documents are available for inspection and may be copied at a cost of 5 cents per page at the Ohio Environmental Protection Agency at the address shown on page one of this public notice any time between the hours of 8 a.m. and 4:30 p.m., Monday through.Friday. Copies of the public notice are available at no charge at the same address. Mailing lists are maintained for persons or groups who desire to receive public notice for all applications in the state or for certain geographical areas. Persons or groups may also request copies of fact sheets, applications, or other documents pertaining to specific applications. Persons or groups may have their names put on such a list by making a written request to the agency at the address shown above.

000339

80082 - CBOD 5 day - mg!1

10

10

3407

3407

D. Schedule to Meet Lower Cuyahoga TMDL Limits 1 . Tne permittee shall immediately begin an evaluation of the capability of the existing treatment facilities to meet the final effluent limits for ammonia-nitrogen (June -September), phosphorus and CBOD5 (5-day carbonaceous biochemical oxygen demand). Both operational procedures, unit process configuration, and other appropriate measures shall be evaluated. 2. Not later than 12 months from the effective date of this permit, the permittee shall implement measures identified in the evaluation that can reasonably be expected to maximize the ability of the existing treatment facilities to achieve the final effluent limits for ammonia-nitrogen (June September), phosphorus and CBOD5. Permits To Install shall be obtained if necessary. 3. If the final effluent limits for ammonia-nitrogen (June - September), phosphorus and CBOD5 are not achieved by implementing measures identified in the evaluation, not later than 18 months from the effective date of this permit, the permittee shall submit a general plan to the Ohio EPA Northeast District Office to achieve the fmal effluent limits. [Event Code 1299] The general plan for achieving the final effluent limits shall address, as a minimum, the following: a. The treatment technology required to achieve the final effluent limits. b. Cost estimates of required improvements and operation, maintenance, and replacement costs for the improved facility. c. A fixed date compliance schedule for meeting the final effluent limits. As a minimum, this schedule should include dates for: submission of approvable detail plans; completion of construction; attainment of operational level; notification of the Ohio EPA Northeast District Office within 14 days of attaining operational level; and achieving the final effluent limits not later than 36 months from the effective date of this permit. d. The financial mechanism to be used to fund the required improvements, operation, maintenance, and replacement costs. 4. The permittee shall attain compliance with the final effluent limits for ammonia-nitrogen (June - September), phosphorus and CBODS not later than 36 months from the effective date of this permit. (Event Code 5699) E. Wastewater Treatment Plant and Sewer System Improvements Page 19 3PFOOOOO*LD 1 . Wastewater Treatment Plant - 20 Million Gallon Storage Basin The permittee shall install a 20 million gallon storage basin at the wastewater treatment plant as expeditiously as practicable, but not later than the dates developed in accordance with the following schedule: a. Submit detail plans for the 20 million gallon storage basin as soon as possible, but not later

000340

than 24 months from the effective date of this permit. (Event Code 01299) b. Advertise for construction bids, receive bids, and award contracts as soon as possible, but not later than 30 months from the effective date ofthis permit. (Event Code 01899) c. Commence construction as soon as possible, but not later than 33 months from the effective date of this permit. [Event Code 03099) d. Complete construction as soon as possible, but not later than 56 months from the effective date of this permit. (Event Code 04599) e. Notify the appropriate Ohio EPA District Office within seven days of completing items b, c and d. 2. Sewer Separation Project - Racks 21/22 a. The permittee shall complete the sewer separation projects for racks 21/22 that are included in the "Long Term Control Plan 98, April 2000 (Updated September 2000 and May 2002)", which has been submitted to Ohio EPA and is not yet approved, as expeditiously as practicable, but not later than December 31 , 2007. b. The permittee shall notify the appropriate Ohio EPA District Office within seven days of completing the sewer separation projects. 3. Wastewater Treatment Plant - High Rate Sedimentation System The permittee shall install Phase 1 High Rate Sedimentation System for flows in excess of the secondary treatment capacity at the wastewater treatment plant as expeditiously as practicable, but not later than the dates developed iu accordauce with the following schedule: a. Submit a general plan as soon as possible, but not later than 12 months from the effective date of this permit, describing the general design and operation of the Phase I High Rate Sedimentation System. The Phase I High Rate Sedimentation System shall be designed for a peak sustained flow no less than 100 MOD. (Event Code 01299) b. Submit detail plans for the Phase I High Rate Sedimentation System as soon as possible, but not later than 24 months from the effective date of this permit. (Event Code 01299) Page 20 3PFOOOOO*LD c. Advertise for construction bids, receive bids, and award contracts as soon as possible, but not later than 30 months from the effective date of this permit. (Event Code 01899) d. Commence construction as soon as possible, but not later than 33 months from the effective date o£this permit. (Event Code 03099) e. Complete construction as soon as possible, but not later than 56 months from the effective date of this permit. (Event Code 04599)

000341

f. NotifY the appropriate Ohio EPA District Office within seven days of completing items c, d and e.

I) provide proper operation and maintenance for the collection system and the combined sewer overflow points; 2) provide the maximum use of the collection system for storage of wet weather flow prior to allowing overflows; 3) review and modify the pretreatment program to minimize the impact of nondomestic discharges from combined sewer overflows; 4) maximize the capabilities of the POTW to treat wet weather flows, and maximize the wet weather flow to the wastewater treatment plant within the limits of the plant's capabilities; 5) prohibit dry weather overflows; 6) control solid and floatable materials in the combined sewer overflow discharge; 7) conduct required inspection, monitoring and reporting of esos; 8) implement pollution prevention programs that focus on reducing the level of contaminants in esos; and 9) implements a public notification program for areas affected by esos, especially beaches and recreation areas. H. Sanitary Sewer Overflow (SSO) Reporting Requirements A sanitary sewer overflow is an overflow, spill, release, or diversion of wastewater from a sanitary sewer system. SSOs do not include wet weather discharges from combined sewer overflows specifically listed in Part II of this NPDES permit (if any). All SSOs are prohibited except under emergency conditions where the overflow occurs in full compliance with all of the provisions of 40 ePR 122.41 (m) and Part III Item II ofthis NPDES permit. Sanitary sewer overflows must be reported as reqnired below. 1. Reporting for SSOs That Imminently and Substantially Endanger Human Health a) Immediate Notification You must notifY Ohio EPA (1-800-282-9378) and the appropriate Board of Health (i.e., city or county) within one hour ofleaming of any SSO from your sewers or from your maintenance contract areas that may imminently and substantially endanger human health. The telephone report must identify the location, estimated volume and receiving water, if any, of the overflow. An SSO that may imminently and substantially endanger human health includes dry weather overflows, major line breaks, overflow events that result in fish kills or other significant harm, and overflow events that occur in sensitive waters and high exposure areas such as protection areas for public drinking water intakes and waters where primary contact recreation occurs. b) Follow-Up Written Report Within 5 days of the time you become aware of any SSO that may imminently and substantially endanger human health, you must provide the appropriate Ohio EPA district office a written report that includes: (i) the estimated date and time when the overflow began and stopped or will be stopped (if known);

000342

(ii) the location of the SSO including an identification number or designation if one exists; (iii) the receiving water (if there is one); (iv) an estimate of the volume of the SSO (if known); (v) a description of the sewer system component from which the release occurred (e.g., manhole, constmcted overflow pipe, crack in pipe); (vi) the cause or suspected cause of the overflow; (vii) steps taken or planned to reduce, eliminate, and prevent reoccurrence of the overflow and a schedule of major milestones for those steps; and (viii) steps taken or planned to mitigate the impact(s) of the overflow and a schedule of major milestones for those steps. A document showing the acceptable format for a 5-day follow up written report can be downloaded from the Ohio EPA Division of Surface Water Permits Program Technical Assistance web page at http://www.epa.state.oh.us/dsw/permits/technical_assistance.html

2. Reporting for All SSOs, Including Those That Imminently and Substantially Endanger Human Health a) Monthly Operating Reports Sanitary sewer overflows that enter waters of the state, either directly or through a storm sewer or other conveyance, shall be reported on your monthly operating reports. You must report the system-wide number of occurrences for SSOs that enter waters of the state in accordance with the requirements for station number 300. A monitoring table for this station is included in Part I, B of this NPDES permit. For the purpose of counting occurrences, each location on the sanitary sewer system where there is an overflow, spill, release, or diversion of wastewater on a given day is counted as one OCCurrence. For example, if on a given day overflows occur from a manhole at one location and from a damaged pipe at another location and they both enter waters of the state, you should record two occurrences for that day. If overflows from both locations continue on the following day, you should record two oCCurrences for the following day. At the end of the month, total the daily occurrences from all locations on your system and report this number using reporting code 74062 (Overflow Occurrence, No./Month) on the 4500 form for station number 300. Page 28 3PFOOOOO*LD b) Annual Report You must prepare an annual report of all SSOs in your collection system, including those that do not enter waters of the state. The annual report must be in au acceptable format (see below) and must include: (i) A table that lists an identification number, a location description, and the receiving water (if any) for each existing SSO. If an SSO previously included in the list has been eliminated, this shall be noted. Assign each SSO location a unique identification by numbering them consecutively, beginning with 301. (ii) A table that lists the date that an overflow occurred, the unique ill of the overflow, the name of affected receiving waters (if any), and the estimated volume of the overflow (in millions of

000343

gallons). The annual report may summarize information regarding overflows ofless than approximately 1,000 gallons. (iii) A table that summarizes the occurrence of water in basements (WIDs) by total number and by sewershed. The report shall include a narrative analysis of WID patterns by location, frequency and cause. Not later than March 31 of each year, beginning in 2005, you must submit two copies of the annual report for the previous calendar year to the appropriate Ohio EPA district office. You also must provide adequate notice to the public of the availability of the report. Systems serving fewer than 10,000 people are not required to prepare an annual report if all monthly operating reports for the preceding calendar year show no discharge from overflows. A document showing the acceptable format for an annual SSO report can be downloaded from the Ohio EPA Division of Surface Water Permits Program Technical Assistance web page at http://www.epa.state.oh.us/dsw/permits/technical_assistance.html.

Description of Modification Local Limits Enforcement Response Plan Permits Ordinance Significant Industrial User List

Date of Approval 10/31/90, 09/15/92, 10/04/95 OS/21/91 09/15/92 OS/21/91 05/13/91

000344

State of Ohio Environmental protection Agency
MAILING ADDRESS:

STREET

AD~",RE,-,S",S,"-'

~

.

P.O. Box 1049

Lazarus Government Center 122 S. Front Street Columbus, Ohio 43215

TELE: (614) 644-3020 FAX: (614) 644-3164 www.epa.state.oh.us

Columbus, OH 43216-1049

September 28, 2006 Re: Ohio EPA Permit No. 3PFOOOOO*LD Facility Name: City of Akron WWTP

Mayor and Council City of Akron 166 South High Street Akron OH 44313 Ladies and Gentlemen: Enclosed is a copy of the Public Notice referenced above regarding a draft National pollutant Discharge Elimination System (NPDES)permit3PFOOOOO*LD issued to City of Akron WWTP, 2460 Akron Peninsula Rd, Akron, Ohio. This notice is being provided to persons on the Oh',o EPA Summit County Mailing list, and certain public officials and the regulated entity. The purpose of this notice is to provide a 45 day extension of the comment period of notice OEPA-06-1 0-01 O. Interested persons are inv·,ted to submit written comments on the draft permit. Comments should be submitted in person or by mail to: Ohio Environmental Protection Agency Permits Section P.O. Box 1049 122 South Front Street Columbus,OH 43216-1049

~
\

Patti L. Smith, Supervisor Permit Processing Unit Division of Surface Water PLS/dks

G,-;:X~ j. '-~
II ?ompJete items 1, 2, and 3. Also complete • Ite,m 4 if Restricted Delivery is desired. Pnnt your name and address on the reverse so that we can return the card to you II Attach this car~ to the back of the m~ilPiece or on the front If space permits. '

CERTIFIED MAIL

o Agent o Addresse
D. Is delivery address different fmm item 1? 0 Yes If YES, enter delivery address below: 0 No

NPDES 3PFOOOOO*LD 9:28:06 (PNEXT) MAYOR AND COUNCiL CITY OF AKRON 166 SOUTH HIGH STREET AKRON OH 44313
3. Service Type Certified Mall 00 Registered Insured Mail

o

0

0 Express Mail Return Receipt for

Me!'
:

handise

0 C.O.D.

2, •. '

4. Restrletsd Delivery? (Extra Fee)

0 Yes

7006 0810 0002 0010 7341
PS Form

3811,

February 2004

Domestic Aetum Receipt

i02595-02-M-1540

*

Ohio EPA is an Equal Opportunity Employer
PrinledonRecyciedPaper

000345

Summit County

PUBLiC NOTICE EXTENSION OF PUBLIC COMMENT PERIOD Notice is hereby given that the Ohio Environmental Protection Agency has extended the public comment period on a draft NPDES permit 3PFOOOOO'LD, issued to the City of Akron WWTP, located at 2460 Akron Penninsula Road, Akron, Ohio. The pUblic comment period for public notice OEPA-06-10-010 issued October 5,2006 is hereby extended 45 days, and wili expire November 13, 2006. Interested persons are invited to submit written comments on the discharge permit. Comments should be submitted in person or by mail to: Ohio Environmental Protection Agency Permits Section P. O. Box 1049 122 South Front Street Columbus, OH 43216-1049 The OEPA permit number (3PFOOOOO*LD) and pUblic notice number (OEPA-06-10-010) should appear next to the above address on the envelope and on each page of any submitted comments. Ali comments received by the close of business, November 13, 2006 will be considered for the final permit. Except for the date by which public comment must be received, ali other provisions of the prior notice remain applicable.

000346

From:

To:
Date: Subject:

Paul Novak Randy Monteith 9/25/2006 11 :51 :33 AM Re: Request for extension of comment period

Randy - as we had discussed, Ohio EPA will extend the comment period on the NPDES permit an additional 45 days. The final date for comments on the draft permit will be Close of Business November 13,2006. Please call with any questions. >>> "Monteith, Randy" <MonteRa@cLakron.oh.us> 9/15/2006 11 :36 AM >>> Paul,

We are attempting to meet your 30 day comment period but we are having difficulty gathering all the information needed to adequately prepare our comments. We have submitted records requests to Region 5, the Northeast district and the Central office. The only response we have received to date is from the central office via a fax dated September 13 that stated:

"received your FOIA fax re: Akron WWTP and TMDLs; takes - 2 weeks to pull info and then need to have our Legal Office review it - will contact you when ready for review"

The message was from Jhodanbo (Jo) at fax #614-644-3020.

We want to be able to submit all appropriate comments but, without the additional time originally requested, and the delays inherent in reviewing the records, we will be unable to provide detailed comments on the draft permit for reasons beyond our control. Therefore I must repeat our Service Director's request for a 90 day extension to December 28, 2006.

Please inform us of your response at the earliest possible date.

146 South High Street, Suite 900 . Thank you. Akron, Ohio 44308 office: 330-375-2627 Randall A. Monteith, P.E. <mailto:montera@ciakron.oh.us> montera@ci.akron.oh.us Pilots Administrator fax: 330-375-2072

Click here to visit our-website <http://ci.akron.oh.us/pubutl.html> http://ci.akron.oh.us/pubutl.html

000347

State of Ohio Environmental Protection Agency
STREET ADDRESS:
_~ ~.

-,M",A",IL",IN.G ADDRESS;

Lazarus Government Center 122 S. Front Street Columbus, Ohio 43215

TELE: (614) 644-3020 FAX: (614) 644·3184

www.epa.state.oh.us

P.O. Box 1049 Columbus, OH 43216,1049

August 22, 2006 RE: Ohio EPA Permit No,: 3PFOOOOO*LD Facility Name: Akron WWTP

Mayor and Council City of Akron 166 South High Street Akron,OH 44313 Ladies and Gentlemen: Transmitted herewith is one copy of the pUblic notice, draft permit, and fact sheet if major permit in the above referenced matter. The public has been invited to submit comments regarding this draft permit. If sufficient pub:ic interest is indicated, a public meeting will be held. The permit as drafted will be issued as a final action unless the director revises the permit after consideration of all written comments received during the 30-day period following public notice and consideration of the record of a public meeting, if one is held, or unless the draft is disapproved by the Regional Administrator, U.S. Environmental Protection Agency. You should note that a general condition of your permit states that issuance of a NPDES permit does not relieve you of the duty of complying with all applicable federal, state, and local laws, ordinances, and regulations.

7:-J.5
PLS/kep Enclosure CERTIFIED MAIL

-'
I te • Complete items 1, 2, and 3. ~\so_~omp e 't m 4 If Restricted Delivery IS desired. II ~~int your name and address on the reverse so that we can return the card to you.. . • Attach this card tothe back?f the mallplece,
1. Article Addressed to:

Patti L. Smith, Supervisor Permit Processing Unit Division of Water Pollution C(

•

•

0 Agent

0 Addressee

c.CQ~~o;,D~ery/ {) i-- 7 ---e;,
1?
D. Is delivery address different trom item. . If YES, enter delivery address beloW.

_-,o~r~0:f1n:th~e~f~ro~n~t ~lf~sp~a:,:c::e.c:p:::er~m:::,lt=s:....

-----11

0 Yes

0 No

NPOES 3PFOOOOO*lO YOR ANO COUNCil WiA KRON HIGH STREET AKRON OH 44308

8:22:06 (0)

~~~S~U~H

3. Service Type Certified Mail

o o Registered

o Insured Mail

0 Express Mail . O Return Receipt for M Achandlsl

f

,

0

C.O.D.

4. Restricted Delivery? (Extra Fee)
2. Article Number (Transfer from service label)
Printed on Recycled Paper

0 Yes

*

7006 0810 0002 0010 4050
Domestic Return Receipt

PS Form 3811 , February 2004

000348

State of Ohio Environmental Protection Agency
STREET ADDRESS;

Lazarus Government Center i22 S. Front Street Columbus, Ohio 43215

TELE: (614) 644-3020 FAX: (614)644-3184
www.epa.state.oh.us

P.O. Box 1049 Columbus, OH 43216-1049

August 22, 2006

Re: Public Notice No.: 06-08-066

Mayor and Council City of Akron 166 South High Street, Rm. 301 Akron, OH 44308 Ladies and Gentlemen: Enclosed is one copy of the Public Notice referenced above regarding National Pollutant Discharge Elimination System (NPDES) permits or modifications. This notice is being advertised in a newspaper of general circulation in the county, and is being provided to certain public officials and the regulated entity. In order to provide further public notice, we will appreciate your assistance in posting this notice in a conspicuous location for a.thirty-day period starting on the date of Public Notice. Thank you for your cooperation in this matter.

,\?~J.~
Patti L. Smith, Supervisor Permit Processing Unit Division of Surface Water PLS/kep Enclosure

Sincerely,

*

Bob Taft, Governor Bruce Johnson, Lieutenant Governor Joseph P. Koncelik, Director
PrintedonRecyciedPaper

Ohio EPA is an Equal Opportunity Empfoyer

000349

77/NE

Application No.: OH0023833 Ohio EPA Permit No.: 3PFOOOOO*LD

National Pollutant Discharge Elimination System (NPDES) Permit Program PUBLIC NOTICE
NPDES Permit to Discharge to State Waters Ohio Environmental Protection Agency Permits Section 122 South Front Street P. O. Box 1049 Coiumbus, Ohio 43216-1049 (614) 644-2001 Public Notice No.: Date of Issue of Public Notice: Name and Address of Applicant: OEPA 6-08-066 Aug-28-2006 Mayor and Council, City of Akron, 166 South High Street, Akron, OH 44313

Name and Address of Facility Where Discharge Occurs:

City of Akron WWTP, 2460 Akron Peninsula Road, Akron, OH, Summit County 001 001 90,000,000 GPO Cuyahoga River 41 N 09' 00" 81 W 33' 45"

Outfall Flow and Location List: Receiving Stream: Nature of Business: Key parameters to be limited in the permit are as follows:

Municipal Wastewater Treatment Plant

Chlorine, Total Residual, Chronic Toxicity, Ceriodaphnia dubia, Dissolved Oxygen, Fecal Coliform, Arsenic, Total In Sludge, Cadmium, Total In Sludge, Copper, Total In Sludge, Fecal Coliform in Sludge, Lead, Total In Sludge, Mercury, Total In Sludge, Molybdenum In Sludge, Nickel, Total In Sludge, Selenium, Totai In Sludge, Zinc, Total In Sludge, CBOD 5 day, Nitrogen, Ammonia (NH3), Oil and Grease, Hexane Extr Method, Oil and Grease, Total, Phosphorus, Total (P), Total Suspended Solids, pH, Maximum, pH, Minimum, CBOD 5 day, and Total Suspended Solids

On the basis of preliminary staff review and application of standards and regulations, the director of the Ohio Environmental Protection Agency will issue a permit for the discharge subject to certain effluent conditions and special conditions. The draft permit will be issued as a final action unless the director revises the draft after consideration of the record of a public meeting or written comments, or upon disapproval by the administrator of the U.S. Environmental Protection Agency. Any person may submit written comments on the draft permit and administrative record and may request a public hearing. A request for public hearing shall be in writing and shall state the nature of the issues to be raised. In appropriate cases, including cases where there is significant public interest, the director may hold a pUblic hearing on a draft permit or permits prior to final issuance of the permit or permits. Following final action by the director, any aggrieved party has the right to appeai to the Environmental Review Appeals Commission.

000350

77/NE

Application No.: OH0023833 Ohio EPA Permit No.: 3PFOOOOO'LD

Interested persons are invited to submit written comments upon the discharge permit. Comments should be submitted in person or by mail no later than 30 days after the date of this public notice. Comments should be delivered or mailed to both of the following locations: 1) Ohio Environmental Protection Agency, Lazarus Government Center, Division of Surface Water, Permits Processing Unit, 122 South Front Street, P.O. Box 1049, Columbus, Ohio 43216-1049 and 2) Ohio Environmental Protection Agency, Northeast District Office 2110 East Aurora Road, Twinsburg, Ohio 44087. The Ohio EPA permit number and pUblic notice numbers should appear next to the above address on the envelope and on each page of any submitted comments. All comments received no later than 30 days after the date of this pUblic notice will be considered. The application, fact sheets, permit including effluent limitations, special conditions, comments received, and other documents are available for inspection and may be copied at a cost of 5 cents per page at the Ohio Environmental Protection Agency at the address shown on page one of this public notice any time between the hours of 8 a.m. and 4:30 p.m., Monday through Friday. Copies of the public notice are available at no charge at the same address. Mailing lists are maintained for persons or groups who desire to receive pUblic notice for all applications in the state or for certain geographical areas. Persons or groups may also request copies of fact sheets, applications, or other documents pertaining to specific applications. Persons or groups may have their names put on such a list by making a written request to the agency at the address shown above.

000351

National Pollutant Discharge Elimination System (NPDES) Permit Program

FACT SHEET
Regarding an NPDES Permit To Discharge to Waters of the State of Ohio for the Akron Wastewater Treatment Plant (WWTP) Public Notice No.: 06-08-066 Public Notice Date: 8-28-06 Comment Period Ends: 9-28-06 OEPA Permit No.: 3PFOOOOO*LD Application No.: OH0023833

Name and Address of Applicant: Mayor and Council City of Akron 203 Municipal Building 146 South High Street Akron, Ohio 44308

Name and Address of Facility Where Discharge Occurs: Akron WWTP 2460 Akron-Peninsula Road Akron, Ohio 44313 Summit County

Receiving Water: Cuyahoga River

Subsequent Stream Network: Lake Erie

Introduction Development of a Fact Sheet for NPDES permits is mandated by Title 40 of the Code of Federal Regulations, Section 124.8 and 124.56. This document fulfills the requirements established in those regulations by providing the information necessary to inform the public of actions proposed by the Ohio Environmental Protection Agency, as well as the methods by which the public can participate in the process of finalizing those actions. This Fact Sheet is prepared in order to document the technical basis and risk management decisions that are considered in the determination of water quality based NPDES Permit effluent limitations. The technical basis for the Fact Sheet may consist of evaluations of promulgated effluent guidelines, existing effluent quality, instream biological, chemical and physical conditions, and the relative risk of alternative effluent limitations. This Fact Sheet details the discretionary decision-making process empowered to the Director by the Clean Water Act and Ohio Water Pollution Control Law (ORC 6111). Decisions to award variances to Water Quality Standards or promulgated effluent guidelines for economic Or technological reasons will also be justified in the Fact Sheet where necessary. Procedures for Participation in the Formulation of Final Determinations The draft action shall be issued as a final action unless the Director revises the draft after consideration of the record of a public meeting or written comments, or upon disapproval by the Administrator of the U.S. Environmental Protection Agency.
Fact Sheet for Akron Wastewater Treatment Plant NPDES Permit Renewal, 2006 -1-

000352

Within thirty days of the date of the Public Notice, any person may request or petition for a public meeting for presentation of evidence, statements or opinions. The purpose of the public meeting is to obtain additional evidence. Statements concerning the issues raised by the party requesting the meeting are invited. Evidence may be presented by the applicant, the state, and other parties, and following presentation of such evidence other interested persons may present testimony of facts or statements of opmlOn. Requests for public meetings shall be in writing and shall state the action of the Director objected to, the questions to be considered, and the reasons the action is contested. Such requests should be addressed to:

Legal Records Section Ohio Environmental Protection Agency Lazarns Government Center P.O. Box 1049 Columbus, Ohio 43216-1049
Interested persons are invited to submit written comments upon the discharge permit. Comments should be submitted in person or by mail no later than 30 days after the date of this Public Notice. Deliver or mail all comments to:

Ohio Environmental Protection Agency Attention: Division of Surface Water Permits and Compliance Section Lazarus Goverumeut Ceuter P.O. Box 1049 Columbus, Ohio 43216-1049
The OEPA permit number and Public Notice numbers should appear on each page of any submitted comments. All comments received no later than 30 days after the date of the Public Notice will be considered. Citizens may conduct file reviews regarding specific companies or sites. Appointments are necessary to conduct file reviews, because requests to review files have increased dramatically in recent years. The first 250 pages copied are free. For requests to copy more than 250 pages, there is a five-cent charge for each page copied. Payment is required by check or money order, made payable to Treasurer State of Ohio.

Fact Sheet for Akron Wastewater Treatment Plant NPDES Permit Renewal, 2006
-2-

000353

Location of Discharge The Akron wastewater treatment plant discharges to the Cuyahoga River at River Mile (RM) 37.45. The approximate location of the facility is shown in Figure I. The Cuyahoga River flows into Lake Erie. This segment of the Cuyahoga River is described by Ohio EPA River Code: 19-00 I and USEPA River Reach #: 04-110002-00 I. The Cuyahoga River is designated for the following uses under Ohio water quality standards (OAC 3745-1-26): Warmwater Habitat (WWH), State Resource Water (SRW, beginning 0.25 miles downstream of the Akron discharge), Agricultural Water Supply (AWS), Industrial Water Supply (IWS), and Primary Contact Recreation. The Cuyahoga River study area is shown in Figure 2. Facility Description The Akron wastewater plant is an advanced treatment facility with an average design flow of 90 million gallons per day (MGD). Wet stream processes include influent screening, grit removal, flow equalization, preaeration, phosphorus removal by chemical addition, primary settling, activated sludge aeration, secondary clarification, chlorination, and dechlorination. Solid stream processes include aerated sludge mixing, gravity thickening, and dewatering by belt filter presses. Sludge is composted on site and ultimately disposed of by selling as a nonfood soil conditioner. Approximately 94 percent of the Akron service area is sewered. Of these sewers, approximately 71 percent are separate and 23 percent are combined. Akron has submitted a CSO long term control plan, Long Term Control Plan 98 (Updated September 2000 and May 2002). The City, Ohio EPA, U.S. EPA and the Department of Justice continue to negotiate approval of the plan. The City has had an Ohio EPA approved pretreatment program since July 1995. Based on the 2006 annual program report, 25 categorical industrial users and 30 significant noncategorical industrial users discharge to the Akron plant. Description of Existing Discharge Table 1 presents chemical specific data for the final effluent collected by Ohio EPA and by the City as part of its industrial pretreatment program. Table 2 presents a summary of unaltered monthly operating report data for Akron outfalls 001 and 602. Data are presented for the period January 2001 through December 2005, and current permit limits are provided for comparison. Tables 3 and 4 sunnnarize the results of acute and chronic whole effluent toxicity tests of outfall 602 effluent conducted by Ohio EPA and by the City under the terms of its current NPDES permit. Table 5 summarizes the chemical specific data for outfalls 00 I and 602 and presents the average and maximum Projected Effluent Quality (PEQ) values. Receiving Water Quality / Environmental Hazard Assessment
An assessment of the impact of a permitted point source on the immediate receiving waters includes an evaluation of the available chemical/physical (water column, effluents, sediment, flows), biological (fish and macroinvertebrate assemblages), and habitat data which have been collected by Ohio EPA pursuant to the Five-Year Basin Approach for Monitoring and NPDES Reissuance. Other data may be used provided it was collected in accordance with Ohio EPA methods and protocols as specified by the Ohio
Fact Sheet for Akron Wastewater Treatment Plant NPDES Permit Renewal, 2006 -3-

000354

Water Quality Standards and Ohio EPA guidance documents. Other information which may be evaluated includes, but is not limited to, NPDES permittee self-monitoring data and effluent and mixing zone bioassays conducted by Ohio EPA, the permittee, or U.S. EPA. Ohio EPA relies on a tiered approach in attempting to link administrative activity indicators (i.e., permitting, grants, enforcement) with true environmental indicators (i.e., stressor, exposure, and response indicators). Stressor indicators generally include activities which have the potential to degrade the aquatic environment such as pollutant discharges (permitted and unpermitted), land use effects, and habitat modifications. Exposure indicators include whole effluent toxicity tests, tissue residues, and biomarkers, each of which provides evidence of biological exposure to stressor or bioaccumulative agents. Response indicators include the more direct measures of community and population response and are represented here by the biological indices which comprise Ohio EPA's biological criteria. The key is in using the different types of indicators within the roles which are the most appropriate for each. Describing the causes and sources associated with observed impairments relies on an interpretation of multiple lines of evidence including the water chemistry data, sediment data, habitat data, effluent data, biomonitoring results, land use data, and biological response signatures within the biological data itself. Thus the assignment of principal causes and sources of impairment represents the association of impairments (defined by response indicators) with stressor and exposure indicators. Use attainment is a term which describes the degree to which environmental indicators are either above or below criteria specified by the Ohio Water Quality Standards (WQS; Ohio Administrative Code Chapter 3745-1). Assessing use attainment status for aquatic life uses involves a primary reliance on the Ohio EPA biological criteria (OAC Rule 3745-1-07; Table 7-14). These are confined to ambient assessments and apply to rivers and streams outside of mixing zones. Numerical biological criteria are based on multimetric biological indices which include the Index of Biotic Integrity (IEI) and modified Index of Well-Being (MIwb), which indicate the response of the fish community, and the Invertebrate Community Index (IC), which indicates the response of the macroinvertebrate community. Numerical endpoints are stratified by ecoregion, use designation, and stream or river size. Three attainment status results are possible at each sampling location -full, partial, or non-attainment. Full attainment means that all of the applicable indices meet the biocriteria. Partial attainment means that one or more of the applicable indices meet the biocriteria or one of the organism groups reflects poor or very poor performance. An aquatic life use attainment table is constructed based on the sampling results and is arranged from upstream to downstream and includes the sampling locations indicated by river mile, the applicable biological indices, the use attainment status (i.e., full, partial, or non), the Qualitative Habitat Evaluation Index (QHEI), and commcnts and observations for each sampling location.
Akron WWTP

The following narrative descriptions are based on field activities conducted in the vicinity of the Akron wastewater treatment plant. Information for the various segments of the Cuyahoga River are as follows:
Little Cuyahoga River to Yellow Creek - Waterbody ID# OH89 27 Since 1996, this segment has shown significant improvement, particularly in the fish, beginning downstream from the Little Cuyahoga and extending downstream from the Akron WWfP. Good quality fish at the mouth of the L. Cuyahoga and improved fish communities downstream suggests CSO (combined sewer overflow) remediation efforts in Akron are paying off. The results could also reflect the gradual recovery from severely toxic conditions in the 1980s and continued impacts from the urban Fact Sheetfor Akron Wastewater Treatment Plant NPDES Permit Renewal, 2006 -4000355

runoff, CSO and SSOs (sanitary sewer overflows). Fish recovery has historically lagged behind the macroinvertcbrates which, throughout the 1990s, declinedbelow the Little Cuyahoga but maintained at least marginally good quality. Water chemistry in the reach is generally good except following rain events and subsequent sewer overflow and urban runoff discharges. Survey results for 1996-2000 found elevated metals, nutrients, oxygen-demanding wastes and coliform bacteria levels following even modest rains. The biologieal integrity narrative assessment for this segment (RM 42.30-37.20) describes this 5.1 river mile stretch as 'Fair'. The aquatic life use for this segment has been determined to be in 'Partial Support'. Yellow Creek to Brandywine Creek - Waterbody ID# OH89 14 Biological community health declined below the Akron WWTP, but 2000 results show significant improvement since 1996. Fish from RM 33.3 (Bolanz Rd. four miles dst. Akron WWTP) shifted from 'Very Poor' in 1996 to 'Fair-Poor' in 2000. Macro-invertebrates improved from 'Fair' to 'Very Good'. The trend continued downstream at Peninsula (RM 29) and attainment improved from 'Non' to 'Partial'. Communities reflected significant background enrichment but a lessening of the toxic influences and gross organic loadings found in earlier surveys. Nutrient levels were elevated below Akron, but water chemistry is generally good except following rain events. Fish recovery in the Cuyahoga has historically lagged behind the macroinvertebrates, so the 2000 results may reflect a continuation of the initial improving trends first observed in the late 1980s and early 1990s following of severe and toxic impacts. The biological integrity narrative assessment for this segment (RM 37.20-24.20) has 7.3 miles described as 'Fair' and 5.7 miles as 'Poor'. The aquatic life use is split between 7.3 miles in 'Partial Support' and 5.7 miles in 'Non-Support'. Brandywine Creek to Tinkers Creek - Waterbody ID#OH89 11 2000 sampling was not conducted within the segment, but stations bracketing the reach (upstream from Brandywine Creek and downstream Tinkers Creek) indicate a significant improving trend in fish communities downstream from Akron. The biological integrity narrative assessment for this segment (RM 24.20-16.4) has 5.2 miles described as 'Fair' and 2.6 miles as 'Good'. The aquatic life use is described with 2.6 miles in 'Supported' and 5.2 miles in 'Partial Support'. Tinkers Creek to Big Creek Waterbody ID# OH89 6 Sampling downstream from Tinkers Creek at RM 15.6 found the first 'Full' attainment ofWWH ever recorded in the Cuyahoga downstream from Akron. The improvement continued the recovery trend that began 25 miles upstream in the Akron area. Positive changes are primarily attributed to a lessening of toxic impacts and continued reductions in loadings from the Akron sewer system. Between Mill Creek and the Southerly WWTP, the fish dropped to the poor range. Besides urban/industrial runoff: CSO, and SSO stressors, a large Mill Creek sewer line break in February 2000 may have contributed to the decline. Fish improved to 'Fair' downstream from Southerly, resulting in 'Partial' attainment. This represents a significant improvement over the poor/very poor fish communities (and Non-attainment) in previous surveys. The results fit the overall improving trend in the lower Cuyahoga between Akron and Cleveland.
Fact Sheet/or Akron Wastewater Treatment Plant NPDES Permit Renewal, 2006 -5-

000356

Nutrient levels were elevated throughout the reach with both point and non-point contributors. Water quality standard exceedances were detected for copper, lead, and zinc and elevated concentrations of cadmium, chromium, and nickel were found in numerous samples between Tinkers Creek and Big Creek. The biological integrity narrative assessment for this segment (RM 16.40-7.20) has 1.5 miles described as 'Good', 6.7 miles as 'Fair', and 1.0 as 'Poor'. The aquatic life use is split between 1.5 miles 'Supported', 6.7 miles as 'Threatened' and 1.0 miles in 'Non-Support'. Development of Water Ouality-Based Effluent Limits Parameter Selection Effluent data for the Akron wastewater plant was used to determine what parameters should undergo a wasteload allocation. The major source of effluent data was the selfmonitoring data reported by the facility from January 2001 through December 2005. Data from the pretreatment program for 2001 through 2005 were also used. Effluent data for the parameters at station 602 are from samples that were collected at a location prior to mixing with the bypass. The effluent data were checked for outliers, and no extreme values were eliminated. This data was then used to calculate the estimated level of a pollutant in the effluent, otherwise referred to as the projected effluent quality (PEQ). The PEQ is calculated as both a monthly average value and a daily maximum value (PEQ", and PEQm~' respectively). The PEQ values for this facility are presented in Table 5. For those parameters that required a wasteload allocation (WLA), the results were based on the applicable Outside Mixing Zone criteria for Warmwater Habitat, the Human Health (nondrinking) criteria, the Wildlife criteria, the Agricultural Water Supply criteria, and the Inside Mixing Zone Maximum criteria in the Cuyahoga River. All allocations except for ammonia toxicity were based on the following stream design flows: average aquatic life WLAs used the 7QIO flow, maximum aquatic life WLAs used the IQIO, WLAs to maintain human health and agricultural water supply criteria were based on the harmonic mean now, and wildlife WLAs used the 90QIO. Seasonal ammonia toxicity was evaluated using the 30QIO flow. The data used in the wasteload allocation are listed in Tables 6 and 7. The wasteload allocation results to maintain all the applicable criteria are presented in Table 8. Water quality based emuent limits for ammonia-nitrogen, CBOD, (5-day carbonaceous biochemical oxygen demand), dissolved oxygen and total phosphoms were determined as part of the study, Total Maximum Daily Loads for the Lower Cuyahoga River (Ohio EPA; September 2003). The limits were calculated to maintain the dissolved oxygen water quality standard in the Cuyahoga River and meet the wasteload allocation for phosphoms. They are presented in fact sheet Table 10. The complete TMDL report is available at the following Ohio EPA web site: http://www.epa.state.oh.us/dsw/tmdl/index.html. Dissolved Metals Translators Dissolved metal translators (DMTs) were used in developing wasteload allocations for cadmium, chromium, copper, lead, nickel and zinc. The DMTs for cadmium were based on very little data. In addition, the chronic effective water quality criteria for cadmium and lead exceed the high risk biocriterion levels. The limited dissolved metal data used in the DMT development and the biocriteria data support the use of caution concerning the pennit requirements for these metals.

Fact Sheet for Akron Wastewater Treatment Plant NPDES Permit Renewal, 2006 -6-

000357

In some cases, it is possible that the use of a DMT may result in instream concentrations of metals that increase the risk of non-attainment of the use designation. This was evaluated for Akron wastewater treatment plant. As shown below, the application of the dissolved metal translators resulted in effective total recoverable criteria that were higher than the total recoverable criteria listed in OAC 3745-1.

Parameter Cadmium Copper Lead Zinc

Total Recoverable 4.6 18 18 240

Effective (Based on DMT) 5.3
22

150 250

The Cuyahoga River near Akron treatment plant is not attaining its designated use; however, the nonattainment can not necessarily be attributed to metals from outfall 602. In addition, the City has not requested any increase in permitted load, Therefore, the facility can receive permit limits up to their current limits without undergoing any further review to ensure that the limits for the metals will protect the biological criteria. Whole EfJluent Toxicity The wasteload allocation calculations for whole effluent toxicity are similar to those for aquatic life criteria [using the chronic toxicity unit (TU,) and 7Ql0 flow for average and the acute toxicity unit (TU") and 1QlO flow for maximum], These values are the levels of effluent toxicity that should not cause instream toxicity during critical low-flow conditions. For the Akron treatment plant, the wasteload allocation values are 0.38 TU, and 1.09 TU,. When the acute wasteload allocation is less than 1,0 TU" it may be defined as: Dilution Ratio (downstream flow to discharger flow) upt02tol greater than 2 to 1 but less than 2,7 to I 2.7 to 1 to 3,3 to I Allowable Effluent Toxicity (percent effects in 100% effluent) 30 40 50

The acute wasteload allocation for Akron is 30 percent mortality in 100 percent effluent based on the dilution ratio of 1.3 to 1. Reasonable Potential! Effluent Limits/ Hazard Management Decisions After appropriate effluent limits are calculated, the reasonable potential of the discharger to violate the water quality standards must be determined. Each parameter is examined and placed in a defined "group". Parameters that do not have a water quality standard or do not require a wasteload allocation based on the initial screening are assigned to either group 1 or 2. For the allocated parameters, the preliminary effluent limits (PEL) based on the most restrictive average and maximum wasteload allocations are selected from Table 8. The average PEL (PEL",) is compared to the average PEQ (PEQ"g) from Table 5, and the PELm~ is compared to the PEQm~' Based on the calculated percentage of
Fact Sheet for Ah'on Wastewater Treatment Plant NPDES Permit Renewal, 2006
-7-

000358

the allocated value [(PEQ"g -;- PEL,",) X 100, or (PEQm~ -;- PELm~) X 100)], the parameters are assigned to group 3, 4, or 5. The groupings are listed in Table 9. The final effluent limits are determined by evaluating the groupings in conjunction with other applicable rules and regulations. Tables II, 12 and 13 present the final effluent limits and monitoring requirements proposed for Akron stations 001, 602 and 603 and the basis for their recommendation. Destriptions of these three stations are as follows: Station 00 I is the final effluent discharged from the plant. Flows from stations 602 and 603 combine and are discharged through station 00 I. During the recreation season, all flow discharged through station 00 I is disinfected by chlorination. Station 602 is the effluent from the final settling tanks prior to mixing with the secondary treatment bypass, station 603. Station 603 is a bypass arOlmd secondary treatment. Discharges through station 603 occur during storm events, receive primary treatment, and mix with flows from station 602 prior to chlorination and discharge through station 00 I. Discharges through station 603 are authorized only when plant peak influent flows exceed 110 MGD, and the flow equalization pumping capacity is being maximized due to storm related events and activities. The draft permit proposes to end this authorization to discharge at the time that certain combined sewer overflow control projects become operational (see Table 13).

Station 3PFOOOOOOOI (Table 11)
The limit proposed for dissolved oxygen is based on dissolved oxygen modeling that was performed as part of the Lower Cuyahoga River TMDL. The dissolved oxygen limit, and the limits proposed for ammonia-N and CBOD s (Station 602), which also were determined by the dissolved oxygen modeling, are shown in Table 10. They reflect current permit limits, plant design criteria and the recommendations oftheTMDL. Limits proposed for fecal coliform are based on Water Quality Standards (OAC 3745-1-07). The proposed limit for total residual chlorine is based on the wasteload allocation (Table 8). The effluent limit for chlorine at outfall3PFOOOOOOOI is less than the quantification level of 0.05 mg/I. However, a Pollutant Minimization Program is not required because the dosing rate of dechlorination chemicals ensures that the water quality based effluent limit is being met. Evaluating the acute and chronic toxicity results in Tables 3 and 4 under the provisions of 40 CFR Part 132, Appendix F, Procedure 6, gives a chronic PEQ of 1.9 TU," No acute toxicity was detected. Reasonable potential for toxicity is demonstrated, since the chronic PEQ exceeds the wasteload allocation value of 1.09 TU,. Consistent with Procedure 6 and OAC 3745-33-07(B)(IO), a monthly average limit of 1.0 TU, and a daily maximum limit of 1.8 TU, are proposed. It is proposed that the final effluent limits for toxicity become effective 48 months from the effective date of the permit. Quarterly monitoring using Ceriodaphnia dubia with a trigger to conduct a toxicity reduction evaluation

Fact Sheet/or Akron Wastewater Treatment Plant NPDES Permit Renewal, 2006 -8-

000359

is proposed as the interim condition. The results in Tables 4 and 5 show that C. dubia is the most sensitive test species. As noted in Tables 3 and 4, the May 2003 test results were deleted from the reasonable potential determination for whole effluent toxicity. This is based on evaluating the test data using Method Guidance and Recommendations for Whole EfJluent Toxicity (WEI) Testing (40 CFR Part 136) (EPA821-B-00-004, U.S. EPA, July 2000) and considering other information included in the test report. The proposed limits for toxieity were derived from the wasteload allocation values, 0.38 TU, and 1.09 TU" using the procedures in section 5.4, Permit Limit Derivation, of the Technical Support Document for Water Quality-based Toxics Control (EPA/505/2-90-001, U.S. EPA, March 1991). A coefficient of variation of 0.6 and an acute-to-chronic ratio of 10 were used in the calculations. Based on the calculations, a monthly average limit of 1.0 TU, and a daily maximum limit of 1.8 TU, are proposed. Flow monitoring is proposed based on best engineering judgment.
Station 3PF00000602 (Table 12)

The final effluent limits proposed for ammonia-nitrogen and CBOD 5 are based on dissolved oxygen modeling that was performed as part of the Lower Cuyahoga River TMDL. They are shown in Table 10 and reflect current permit limits, plant design criteria and the recommendations of the TMDL. To maintain the instream water quality criteria of 5.0 mg/I for dissolved oxygen during the summer, the TMDL recommended setting weekly average limits for ammonia-N and CBOD5 .The limits proposed for ammonia-N during the spring, fall and winter are plant design criteria and are a continuation of existing permit limits. Tliey are protective of the dissolved oxygen water quality criteria. The final effluent limits proposed for phosphorus are based on results of the Lower Cuyahoga1MDL (Table 10). Weekly average phosphorus limits are proposed consistent with the recommendation of the TMDL. A three year schedule of compliance is proposed for meeting the final effluent limits for phosphorus, CBOD, and summer ammonia-N, with current permit limits applying during the interim period. The limits proposed for total suspended solids reflect the existing permit limits and are plant design criteria. . Limits proposed for oil and grease and pH are based on Ohio Water Quality Standards (OAC 3745-1-07).

Total dissolved solids (residue) is included in Group 5 under the risk assessment procedure (Table 9). However, using the discretion allowed in paragraph A(5) of Rule 3745-33-07, monitoring, rather than effluent limits, is proposed for this pollutant. The PEQ values calculated for this pollutant (Table 5) may not be representative of its actual level in the plant effluent. Only two data points were available for total dissolved solids, and the results were well below the wasteload allocation. The purpose of the proposed monitoring is to collect additional data on the frequency of occurrence and variability of this pollutant in the plant's effluent. Based on reasonable potential for requiring monitoring in NPDES permits [OAC 3745-33-07(A)), monitoring is proposed for free cyanide. This pollutant is included in Group 4 under the risk assessment procedures (Table 9).
Fact Sheet for Akron Wastewater Treatment Plant NPDES Permit Renewal, 2006 -9-

000360

Based on reasonable potential for requiring monitoring in NPDES permits [OAC 3745-33-07(A)], monitoring is proposed for cadmium, total chromium, dissolved hexavalent chromium, copper, lead, mercury, nickel and zinc. Because these pollutants were included in Groups 2 and 3 under the risk assessment procedures (Table 9), monitoring at a reduced frequency of once per month is proposed. The purpose of the monitoring is to maintain a current data base on the level of these pollutants in the plant effluent. This data will be used to assess reasonable potential at future permit renewals. No low level mercury data is available for the Akron plant. Special conditions are proposed in Part II of the permit that require the City to use EPA Method 1631 for monitoring mercury in the plant influent, effluent and secondary bypass. The City is also required to evaluate the low level data collected under this permit and determine if it will be able to comply with a monthly average mercury limit of 1.3 ng/l, which will apply after November 2010 when a mixing zone phase out for mercury and other bioaccumulative chemicals of concern becomes effective. If the City would not be able to comply with this limit, it has the option of applying for a variance to the water quality standard as part of its next renewal application. Additional monitoring requirements proposed at station 602 are based on best engineering judgment. In addition to permit compliance, this data is used to assist in the evaluation of effluent quality and treatment plant performance, for designing plant improvements, and conducting future stream studies. Station 3PF00000603 (Table 13) Monitoring for flow, dissolved oxygen, CBOD s, suspended solids and metals is proposed based on best engineering judgment. The purpose of the monitoring is to obtain data that will assist in evaluating plant operations during wet weather and in characterizing the pollutant loads that are discharged at the plant during wet weather. It is proposed that the existing daily maximum concentration limits for CBOD s and total suspended solids be continued. Other Monitoring Additional monitoring requirements proposed for influent, upstream/downstream and sludge stations are based on best engineering judgment and vary according to the type and size of the discharge. In addition to permit compliance, this data is used to assist in the evaluation of effluent quality and treatment plant performance, for designing plant improvements, and conducting future stream studies. Provisions for reporting sanitary sewer overflows (SSOs) are proposed. These provisions include: the reporting of the system-wide number of SSO occurrences on monthly operating reports; telephone notification of Ohio EPA and the local health department, and 5-day follow up written reports for certain high risk SSOs; and preparation of an annual report that is submitted to Ohio EPA and made available to the public. Many of these provisions were already required under the "Noncompliance Notification", "Records Retention", and "Facility Operation and Quality Control" general conditions in Part III of Ohio NPDES permits, although the permits did not explicitly state their application to SSOs.

Fact Sheet/or Akron Wastewater Treatment Plant NPDES Permit Renewal, 2006

-10000361

Combined Sewer Overflow Provisions Special conditions are proposed in the pennit that require the monitoring and reporting of the City's combined sewer overflows and implementation of the nine minimum controls. Akron has submitted a CSO long tenn control plan, Long Term Control Plan 98 (Updated September 2000 and May 2002). The City, Ohio EPA, U.S. EPA and the Department of Justice continue to negotiate approval of the plan. A compliance schedule is proposed for the City to implement three CSO control projects that would be required regardless of the alternatives that are ultimately included in an approved long tenn control plan. 1bese projects are: - Construction of a 20 million gallon storage basin at the wastewater treatment plant (56 months to complete); - The partial sewer separation for Racks 21/22 (complete by December 2007); and - Construction of a high rate sedimentation system at the wastewater plant that is designed to treat a peak sustained flow no less than 100 MGD (56 months to complete).

Fact Sheet for Akron Wastewater Treatment Plant NPDES Permit Renewal, 2006 -11-

000362

Figure 1. Approximate location of Akron wastewater treatment plant.

Fact Sheet for Aleron Wastewater Treatment Plant NPDES Permit Renewal, 2006
-12-

000363

Cuyahoga River 42.27

f.

Li!tle c:uJ"_hoga

_I

39.78 _

.M.ud Broo~ _ _

.I

Akron WWTP ~ 37.45
37.16

t

Figure 2. Cuyahoga River Study Area.

Fact Sheet for Akron Wastewater Treatment Plant NPDES Permit Renewal, 2006
-13-

000364

Table 1. Effluent Characterization Summary of analytical results for the Akron wastewater treatment plant outfall 3PF00000602. All values are in ~g/l unless otherwise indicated. OEPA = data from analyses by Ohio EPA; PT = data from pretreatment program reports; PEQ = projected effluent quality; ND = below detection (detection limit); NA = not analyzed.
PARAMETER OEPA 911 0/0 1 OEPA 7116/01 PT 9/13/05 PT 9113/04 PT 10110102 PT 9117101

Arsenic

3.5 20 ND(0.20) ND(30) ND(lO) ND(5) ND(lO) ND(2.0) 23 NA ND(40) ND(2.0) NA 182 42 680 ND(2.1) 9.8(5.3) 1.75(0.5) 0.54(0.5) 0.92(0.5) ND(0.5)

3.7 21 ND(0.20) ND(30) ND(IO) ND(5) NA ND(2.0) 35 NA 40(ND) ND(2.0) NA 192 47 726 2.1(2) ND(5.1) 1.55(0.5) ND(050) 1.92(0.5) 0.54(0.5)

ND(2)

ND(20) NA ND(5) ND(20) ND(20) NA ND(8) ND(40) NA ND(0.5) ND(20) ND(20) ND(20) NA 100(20) NA ND(lO) ND(lO) ND(5) ND(5) ND(5) ND(5)

ND(5) NA ND(5) ND(50) 15(5) NA ND(lO) ND(5) NA ND(0.2) ND(50) ND(5) ND(50) NA 64(50) NA ND(lO) ND(lO) ND(5) ND(5) ND(5) ND(5)

ND(5) NA ND(0.5) ND(25) ND(13) NA ND(lO) ND(4) NA ND(0.2) ND(l3) ND(5) ND(13) NA 73(5) NA ND(lO) ND(lO) ND(5) ND(5) ND(5) ND(S)

Barium
Cadmium Chromium

NA
ND(IO) ND(lO) ND(lO) NA ND(lO) ND(2) NA ND(0.2) ND(IO) ND(5) ND(IO) NA 38.1(10) NA ND(lO) ND(IO) ND(5) ND(5) ND(5) ND(5)

Copper
Cyanide, free

Cyanide, total
Lead Manganese

Mercury
Nickel Selenium

Silver
Strontium

Zinc
TDS (mg/I) Phenol Dimethylphthalate

Chloroform
Tetrachloroethene

Toluene
Bromodichloromethane

Fact Sheet for Akron Wastewater Treatment Plant NPDES Permit Renewal, 2006
-14-

000365

Table 2. Effluent Characterization Summary of current permit limits and unaltered monthly operating report data for Akron wastewater treatment plant outfalls 3PFOOOOOOO 1 and 3PF00000602. All values are based on annual records unless otherwise indicated. "a" = weekly average; * = 5th percentile for dissolved oxygen.

Outfall 001

Dissolved Oxygen Dissolved Oxygen Fecal Coliform Flow Rate Flow Rate Flow Rate Chlorine, Total Residual

Summer
Winter Annual Summer
Winter

mgll mgll #/100

5.0 minimum
5.0 minimum

Annual

ml MGD MGD MGD
mgll

1000
Monitor
Monitor

2000'

Annual

Monitor -

0.026

544 333 629 920 906 1826 966

7.2 8.0 63 65.1 71.9 67.8 0.006

6.0'
5.2*

3360 108 132 120 0.0131

4.4-10.4 5.2-12.4 4-480000 47.2-232 46.6-238 46.6-238 0-0.04

Outfall 602

Water Temperature Dissolved Oxygen Dissolved Oxygen Chemical Oxygen Demand pH, Maximum pH, Minimum Total Suspended Solids Oil and Grease Nitrogen, Ammonia (NH3) Nitrogen, Ammonia (NH3) Nitrite Plus Nitrate, Total Phosphorus, Total (P) Nickel, Total Recoverable Zinc, Total Recoverable Cadmium, Total Recoverable
Lead, Total Recoverable

Annual
Summer

C
mgll mgll mgll

Monitor

Monitor
Monitor Monitor

Winter Annual Annual
Annual Annual Annual
Summer

S.U. S.U.
mgll mgll mgll mgll mgll mgll

-15 # # Monitor

9.0 6.5 23' 10
# #

Winter

Annual Annual
Annual

Annual
Annual
Annual

Chromium, Total Recoverable

Annual

ugll ugll ugll ugll ugli

1.0 344 231 2 22.4 Monitor

1.5' 516 244 3 63

1825 607 414 1201 1818 1818 1823 123 608 607 123 1241 242 242 242 242 242

15.3 5.9 6.6 21.9 7.1 7 5.8 0 0.065 0.0966 9.9 0.69 0 56.8 0 1.97 0

22.3
4.4* 5.1*

36.6 7.3 7.2 9.8 0 0.476 1.09 12.4 1.2 29.3 85.1 0.44 4 2.11

2.9-24.1 2.3-7.9 3.6-9.2 0-64.3 6.79-7.7 6.6-7.4 0.6-46 0-8.5 0-1.54 0-5.77 4.55-13.4 0.24-2.19 0-68.2 31.2-99.1 0-1.9 0-12.1 0-10.2

Fact Sheet for Akron rVastClvater Treatment Plant NPDES Permit Renc1val, 2006 -15-

000366

Copper, Total Recoverable Chromium, Dissolved Hexavalent Flow Rate Flow Rate Flow Rate CBaD 5 day CBaD 5 day Mercury, Total Cyanide, Free

Annual Annual
Summer
Winter

ugll ugll

28 12.8
Monitor Monitor

44 20

Annual
Summer
Winter

MGD MGD MGD
mgll mgll ugll mgll

Annual Annual

Monitor 10 10 0.02 0.017

15' 15' 1.5 0.062

242 273 920 906 1826 833 812 240 134

5.77 0 60.1 68 63.9 0 2.7 0 0.001

10.4 0 86.9 93.8 91.1 2.95 4.63 0 0.004

0-17.1 0-2 35-116 45.6-103 35-116 0-14.4 0-12 0-0 0-0.01

#

Ammonia limits: 1.5 mg/l (30 day) 2.3 mg/l (weekly) June - September 7.1 mg!1 (weekly) March - May and October - November 4.8 mg!1 (30 day) 11.3 mgll (weekly) December - February 7.5 mg!1 (30 day)

Fact Sheet/or Akron Wastewater Treatment Plant NPDES Permit Renewal, 2006
-16-

000367

Table 3. Summary of acute toxicity test results on the Akron wastewater treatment plant effluent from outtall 3PF00000602.

TEST DATE(a)
05/03/05(E) 02/22/05(E) ll/02/04(E) 05/04/04(E) 02/03/04(E) 11/04/03(E) 11/04/03(E) 07/08/03(E) 05/06/03(E)* 02/04/03 (E) 11/05/02(E) 05/07/02(E) 021l2/02(E) 05/08/0 I (E) 02/06/01 (E) . 09110/01(0)' 07/16/01(0)'

CeriodaDhnia dubio 48 hour

Fathead Minnows 96 hour
°/oMi

Dpb
0 0 0 0 0 0 0 0 0

C'

LCS(ld

EC so c

%Af

TDa'

NFh

Dpb
5 2 5 8 2 8 8 10 0 0 8 2 0 5 2 2 2
8

C'

LC SO d >100 >100 >100 >100 >100 >100 >100 >100 >100 >100 >100 >100 >100 >100 >100 >100 >100

ECsoc

%Af

°,loM i
2 0 0 0 0 0 0 5 15 0 0 5 0 5 5 5 0

TDa'

NF h

0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 5 0

>100 >100 .>100 >100 >100 >100 >100 >100 >100 >100 >100 >100 >100 >100 >100 >100 >100

>100 >100 >100 >100 >100 >100 >100 >100 >100 >100 >100 >100 >100 >100 >100 >100 >100

0 0 0 0 0 0 0 0 30 0 0 0 0 0 0 5 0

0 0 0 0 0 0 0 0 30 0 0 0 0 0 0 5 0

BD BD BD BD BD BD BD BD
0.6

NT NT NT NT NT NT NT NT NT NT NT NT NT NT NT
5 5

>100 >100 >100 >100 >100 >100 >100 >100 >100 >100 >100 >100 >100 >100 >100 >100 >100

2 0 0 0 0 0 0 5 15 0 0 5 0 5 5 5 0

BD BD BD BD BD BD BD BD BD BD BD BD BD BD BD BD BD

NT NT NNT NT NT NT NT NT NT NT NT NT NT NT NT
0 0

NT
0 0 0 0 0 0 0

BD BD BD BD BD BD BD BD

NT
0 0 22 34 25 0 0

2 0 0 2 8 0 5 0

Fact Sheet for Akron Wastewater Treatment Plant NPDES Permit Renewal, 2006 ·17·

000368

Table 3 (Continued)
a
g

0 "" EPA test; E"" entity test

TUa:;;: Acute Toxicity Units b UP ;;:: upstream control water
c

LCso = Median Lethal Concentration NT:;;: not tested e EC so = Median effects concentration
d

NF "" Near Field Sample In the Acute Mixing Zone C "" laboratory water control '%M "" percent mOTta1ity in 100% effluent
h

BD "" below detection f %A "" percent adversely affected in 100% effluent * = deleted from reasonable potential determination

# = 48 hr. screening test

Fact Sheet for Akron Wastewater Treatment Plant NPDES Permit Renewal, 2006 -18-

000369

Table 4. Summary of chronic toxicity test results on Akron 3PF00000602 WWTP effluent
Test Date (a)

Ceriodaphnia dubia 7-Day

Fathead Minnows 7-Day
Reproduction

upb

CC

IC 2s d

ruc c
LOEC'

Survival
NOECg
100 100 100 100 100 100 100 100 100 100 100 100 100 100

FF;

Upb

C'

IC2sd

TU/

Survival
STUj

Growth

FF i

, ru"
BD BD BD BD BD BD BD BD BD BD BD BD BD BD

LOEC'
>100

NOECg
100 100 66 100 100 100 100 100 57 100 100 100 100 87

ru,"
BD BD
1.4 10 0 0 0 10 0 15 10

GTUck

OS/03/0S(E) 02/22/05(E) 1l/02/04(E) 05/04/04(E) 02/03104(E) 1l/04103(E) 07/08103(E) 05106103(E)' 02/04/03(E) 11/05/02 (E) 05107102 (E) 02/12/02 (E) 05108/0l(E) 02106/01 (E)

10 0 0 0 0 0 0 0

0 0 20 0 0 0 0 10 0 0 0 0 0 0

>100 >100
97.8

BD BD
1.0

>100
>100

2
12 5 0 5 2 15 10 8

>100
>100 >100 >100 >100

BD BD BD BD BD BD BD BD BD BD BD BD BD BD

BD BD BD BD BD BD BD BD BD BD BD BD BD BD

BD BD BD BD BD BD BD BD BD BD BD BD BD BD

42 0

>100
76 >100

>100

8
8 12 20 38 5

8
18 15 28 28 12 10 32 41 17 48 18

>100 >100
>100

BD BD BD BD
1.18 1.17

>100 >100 >100 >100
>100 >100

BD BD BD BD BD
1.6

>100
>100

>100
>100

>100 84.5 85.2
>100

>100
>100 66

0
10 0 0 0 0 0 0

>100
>100

NT
0 0 0 0 0

NT
50 18 28 46 35

BD BD BD BD BD

>100 >100
>100

>100
>100

BD BD BD BD
1.1

3
3 15

>100
>100

>100
>100

BD
>100 100

>100 >100 >100

>]00
>100

>100

8
12

>100

ao = EPA test; E = entity test hTU c = chronic toxicity units based on LOEe and NOEC bur = upstream control water iFF = far-field effect jSTUc = TUc based on LOBe and NOEC for survival cc = laboratory water control dIC 25 = inhibition concentration twenty-five kGTU c = TUc based on LOEC and NOEC for growth eruc = chronic toxicity units based on IC25 BD = below detection !'LOEe = lowest observed effects concentration NT = not tested eNOEC = no observed effects concentration * = deleted from reasonable potential detennination

Fact SheetJor Akron Wastewater Treatment Plant NPDES Permit Renewal, 2006
-19-

000370

Table 5. Effluent Data for Akron WWTP 602

Parameter

Units

Samples

# of MDL

#> PEQ

Average PEQ

Maximum

Self-Monitoring Data: Cadmium, total Chlorine, total residual (001) Chromium+ , dissolved Chromium, total Copper, total Cyanide, free Lead, total Mercury Nickel, total Nitrate+ Nitrite-N PhOsphorus, total Suspended solids, total Zinc, total Ammonia-N (Summer) Ammonia-N (Winter) Ohio EPA and Preatment Data: Arsenic Barium Manganese Strontium Total dissolved residue (solids) Phenol Dimethylphtha1ate Chloroform Tetrach1oroethene Toluene Bromodich1oromethane ug!l ug/1 ug!l ug!l mg!l ugll ug!l ug/l ug/1 ug!l ugll 3 2 2 2
2 2
6

ug!l ug!l ug!l ug!l ug!l mg!l ug/l ug!l ug!l mg/l mg!l mg!l ug!l mg/l mg!l

242 966 273 242 242 134 242 240 242 123 1241 1823 242 409 301

81 949 2

0.33 0.008 1.0 1.8 8.3 0.0038 3.6 22.6 8.8 0.83 6.8 65.1 0.22 6.85

0.50 0.013 1.4 2.5 10.7 0.0058 5.1 32.1 12.1 1.2 10.9 89.2 0.52 10.9

78
240 94 184 0 54 123 1241 1823 242 335 278

2
2

8.1 58 97 533 2014 5.8 15 4.8 1.5 5.3 1.5

11.1 80 133 730 2759 8.0 21 6.6 2.0 7.3 2.0

2 2
2

1 1
2

6 2
2 2 2

1 2 1

Fact Sheet for Akron Wastewater Treatment Plant NPDES Permit Renewal, 2006 -20-

000371

Table 6. Water Quality Criteria in the Study Area Outside Mixing Zone Criteria Average Maximum Aquatic Aquatic AgriLife A Wildlife Life A culture 50 5.3 11 14000 14000 64000 48000 190 0.0031 50000 35000 580 160000 61000 1400000 2400 1700 1800 51000 180 5300 400 140 53 62 340 48000 4700 1300 430 560 3100 95000 9400 2600 850 1100 6200 100 10 200 100 25000 100 250 1500 150 220 340 2000 680 4000 250 500 0.0013 100 500
11

Parameter Cadmium, total" Chlorine, total residual Chromium", dissolved Chromium, totalB Copper" Cyanide, free Lead, totalB Mercury Nickel, total" Nitrate + Nitrite-N ZincB Total Dissolved Solids Arsenic Barium Manganese Strontium Phenol Chloroform Tetrachloroethene Toluene Bromodichloromethane
C

Units ug/l ug/l ug/l ug/l ugll ug/l ug/l ugll ugll mg/l ug/l mg/l ug/l ug/l ug/l ug/l ugll ug/l ug/l ug/l ug/l

Human Health A 730

Inside Mixing Zone Maximum 26 38 31 2300 72 44 5600 3.4 1900

A

13 19 16 1200 36 22 2800 1.7 920

150 22 5.2 150 0.91 100

Human Health and Aquatic Life criteria are Tier I unless otherwise indicated. " Aquatic criteria is based on dissolved form of parameter; human health and agriculture criteria are based on the total recoverable form. Refer to dissolved metal paragraph for more information. c Carcinogen.

A

Fact Sheet/or Akron Wastewater Treatment Plant NPDES Permit Renewal, 2006
-21-

000372

Table 7. Instream Conditions and Discharger Flow Parameter 7QIO (cfs) Value 51.54 51.54 77.85 37.28 76.76 62.50 105.27 200.67 25.% 100.% 222.0
summer winter

annual
summer winter

lQI0 90QI0 30QlO

(efs) (efs) (efs)

Harmonic Mean Flow (cfs) Mixing Assumption

annual annual summer winter annual
average
maxnTIum

. Basis USGS gage #04206000 USGS gage #04206000 USGS gage #04206000 USGS gage #04206000 USGS gage #04206000 USGS gage #04206000 USGS gage #04206000 USGS gage #04206000 Chronic criteria default assumption Stream"to-discharge ratio LEAPS; 57 values, O<MDL, 1998-2002 LEAPS; LEAPS; LEAPS; LEAPS; 76 values, O<MDL, 56 values, O<MDL, 76 values, O<MDL, 56 values, O<MDL, 1998-2002 1998-2002 1998-2002 1998-2002

Instream Hardness (mg/l) pH Temp. (S.U.) (Deg. C)

summ.er
winter

7.7 7.9 21.9 5.6

Background Water Quality (ugll) Cadmium, total Chlorine, tot residual Chromium, total Chromium", dissolved Copper, total Cyanide, free Lead, total Mercury Nickel, total Nitrites & Nitrates Zinc, total Ammonia (Summer, mg/l) Ammonia (Winter, mg/l) Total Dissolved Solids (mg/l) Arsenic Barium

0.0 0.0 15.0 0.0 0.0 0.0 1.0 0.0 0.0 1.12 12.25 0.025 0.12 464.0 2.6 58.5

STORET; 32 values, 32<MDL, 2000-2002 No representative data available STORET; 32 values, 31 <MDL, 2000-2002 No representative data available STORET; 32 values, 32<MDL, 2000-2002 No representative data available STORET; 32 values, 23<MDL, 2000-2002 No representative data available STORET; 32 values, 32<MDL, 2000-2002 STORET; 31 values, O<MDL, 2000-2002 STORET; 32 values, 10<MDL, 2000-2002 STORET; 28 values, 21<MDL, 2000-2002 LEAPS; 56 values, O<MDL, 1998-2003 STORET; 32 values, O<MDL, 2000-2002 STORET; 32 values, 3<MDL, 2000-2002 STORET; 32 values, O<MDL, 2000-2002

(No representative data available for the remainder of the parameters listed in Table 6.) Dissolved Metal Translators Cadmium Chromium Copper Lead Nickel Zinc Akron WWTP flow (cfs)

1.26 1.07 1.26 10.53 1.05 1.08

OEPA; OEPA; OEPA; OEPA; OEPA; OEPA; DSW

4 values, 3<MDL, 6 values, O<MDL, 6 values, O<MDL, 6 values, I<MDL, 6 values, O<MDL, 6 values, O<MDL,

1996-97 1996-97 1996-97 1996-97 1996-97 1996-97

139.26

Fact Sheet/or Akron Wastewater Treatment Plant NPDES Permit Renewal, 2006 -22-

000373

Table 8. Summary of Effluent Limits to Maintain Applicable Water Quality Criteria Average Agri Supply Wildlife 68 A
A A

Parameter (ug/l) Cadmium, totalB,c Chlorine, total residual(OOl) Chromium+ 6, dissolvedB Chromium, tota1B ,c Copper, total
C

Human Health 993 A 19044 87057 65300 258 0.00422
B

Aquatic Life 5.8 12 12

Maximum Aquatic Life 16 24 20 1517 46 28 3549 2.16 1230 314 430 2520

Inside Mixing Zone Maximum 26 38 31 2300 72 44 5600 3.4 1900 500 680 4000

19038

131 680
A

163 24 5.7 164 0.00148 0.994 120 272 1596 164 235

A A

Cyanide, free Lead, totalB,c MercuryB Nickel, total .c Nitrates & Nitrites (mg/l)B Zinc, total e TDS (mg/l)
Arsenic
B

136 l3.6 A 272 135.6 34002 A 135

5849l

A

47605 A 788
A
A

Barium
A
B

2l762l

c

Allocation must not exceed the Inside Mixing Zone Maximum. Parameter would not require a WLA based on reasonable potential procedures; however, parameter was allocated per request of Permits Group. Allocation based on applicable dissolved metal translator

Fact Sheetfor Akron Wastewater Treatment Plant NPDES Permit Renewal, 2006

-23000374

Table 9. Parameter Assessment for Outfall 602 Group I Parameter has no applicable WQS. No limit recommended. Monitoring optional. Dimethylphthalate Group 2Existing effluent less than 25% ofWQS or all data below minimum detection limit. WLA not required. No limit recommended. Monitoring optional. CadmiumA Chromium+', diss. Chromium, total Chloroform Group 3ChromiumA NickelA Toluene Tetrachloroethene LeadA Nitrites & Nitrates Mercury Bromodichloromethane Arsenic Manganese Phenol Strontium

PEQrn'X < 50% of the maximum PEL and PEQ"g < 50% of the average PEL. No limit recommended. Monitoring optional.
Copper

Zinc A

Barium

Group 4-

PEQrn'X 2: 50% but < 100% of the maximum PEL or PEQ,vg 2: 50% but < 100% of the average PEL. Monitoring is appropriate. Cyanide, free Chlorine, Total Residual

Group 5-

PEQrn'X 2: 100% of the Maximum PEL or PEQ,vg 2: 100% of the average PEL or either the average or maximum PEQ is between 75 and 100% of the PEL and certain conditions that increase the risk to the environment are present. Limits to Protect Numeric Water Quality Criteria Effluent Limits Parameter Units Outfall 602 Applicable Period annual Average 1596 Maximum

Total Dissolved Solids mgll

A

BasedonDMT

Fact Sheet for Akron Wastewater Treatment Plant NPDES Permit Renewal, 2006 -24-

000375

Table 10. Lower Cuyahoga TMDL and Modeling Results for Parameters at Outfall 602

Limits to Protect Numeric Water Quality Criteria Effluent Limits 30-day 7-day Average Average

Parameter

Units

Outfall

Applicable Period

Ammonia, Nitrogen Ammonia, Nitrogen Ammonia, Nitrogen Phosphorus CBOD, Dissolved Oxygen

mg/l mg/l mgll mg/l mg/l mg/l

602 602 602 602 602 001

summer fall/spring
winter

annual annual annual

1.5 Existing Permit Limits Existing Permit Limits 0.65 10 10 - 5.0 Minimum-

Effluent limits are based on modeling for the 2003 Cuyahoga TMDL.

Fact Sheet/or Akron Wastewater Treatment Plant NPDES Permit Renewal, 2006 -25-

000376

Table 11, Final effluent limits and monitoring requirements for Akron outfall 3PFOOOOOOO 1 and the basis for their recommendation, Effluent Limits Concentration Loading (kg/day)' 30 Day Daily 30 Day Daily Average Maximum Average Maximum - - - - - - - - - - - - Monitor - - - - - - - - - - - - - - - - - - - - - Not less than 5,0 at any time - - - - -2000' 0,024

Parameter Flow Dissolved Oxygen Fecal Coliform Summer Only Chlorine Residual Summer Only Whole Effluent Toxicity
Ceriodaphnia dubia

Units MGD mg/l

Basisb M,BEJ EP, TMDL WQS WLA

#/IOOml 1000 mg/l

TUc

LO

1.8

WET

,
b

Effluent loadings do not apply at station 3PFOOOOOOOL Definitions: EP - Existing Permit; M -- BEJ of Permit Guidance 1: Monitoring Frequency Requirements for Sanitary Discharges; TMDL = Modeling results for the Total Maximum Daily Loads for the Lower Cuyahoga River, 2003; WET = Whole Effluent Toxicity, 40 CFR Part 132, Appendix F, Procedure 6 and OAC 3745-33-07(B)(10); WLA = Wasteload Allocation procedures (OAC 3745-2); WQS = Ohio Water Quality Standards (OAC 37451),

, 7 day average limit

Fact Sheet/or Akron Wastewater Treatment Plant NPDES Permit Renewal, 2006 -26-

000377

Table 12. Final effluent limits and monitoring requirements for Akron outfall 3PF00000602 and the basis for their recommendation. Effluent Limits Concentration Loading (kg/day)' 30 Day Daily 30 Day Daily Average Maximum Average Maximum

Parameter

Units

Basisb

M MGD - - - - - - - - - - - - Monitor - - - - - - - - - - - - - - Flow oC M - - - - - - - - - - - - Monitor - - - - - - - - - - - - - - Temperature M mg/l - - - - - - - - - - - - Monitor - - - - - - - - - - - - - - Dissolved Oxygen PD,EP, TMDL 10 10' 3407 3407' mg/l CBOD, 15 23' 5110 7835' PD,EP mg/l Suspended Solids Ammonia-N 1.5' 511' TMDL (June - September) mgll 7.1' 1635 2419' PD, EP (Mar-May)(Oct-Nov)mg/1 4.8 11.3' 2555 3850' PD, EP 7.5 (Dec-Feb) mg/l 0.65' 221' TMDL Phosphorus mg/l - - - - - - - -Not to exceed 10 at any time - - - - - - WQS Oil and Grease mg/l - - - - - - - - - - - - 6.5 to 9.0 - - - - - - - - - - - - - WQS pH S.U. - - - - - - - - - - - - Monitor - - - - - - - - - - - - - - M COD mg/l Nitrate(N) + - - - - - - - - - - - - Monitor - - - - - - - - - - - - - - mg/l Nitrite(N) M RP - - - - - - - - - - - - Monitor - - - - - - - - - - - - - - Cyanide, Free fig/l RP,M - - - - - - - - - - - - Monitor - - - - - - - - - - - - - - Cadmium, T. R. fig/l RP,M - - - - - - - - - - - - Monitor - - - - - - - - - - - - - - Chromium, T. R. fig/l Hex. Chromium RP,M figll - - - - - - - - - - - - Monitor - - - - - - - - - - - - - - (Dissolved) figll - - - - - - - - - - - Monitor - - - - - - - - - - - - - - Copper, T. R. RP,M RP,M fig/l - - - - - - - - - - - Monitor - - - - - - - - - - - - - Lead, T. R. RP,M Mercury, T. R. ng/l - - - - - - - - - - - - Monitor - - - - - - - - - - - - fig/I - - - - - - - - - - - - Monitor - - - - - - - - - - - - - - Nickel, T. R. RP,M fig/I - - - - - - - - - - - - Monitor - - - - - - - - - - - - - - RP,M Zinc, T. R. RP Dissolved Solids, T mg/l - - - - - - - - - - - - Monitor - - - - - - - - - - - - - - , Effluent loadings based on average design discharge flow of 90 MGD.
b

Definitions:

EP = Existing Permit; M = BEJ of Permit Guidance 1: Monitoring Frequency Requirements for Sanitary Discharges; PD = Plant Design Criteria; RP = Reasonable Potential for requiring water quality-based effluent limits and monitoring requirements in NPDES permits (3745-33-07(A)); TMDL = Modeling results for the Total Maximum Daily Loads for the Lower Cuyahoga River, 2003; WQS = Ohio Water Quality Standards (OAC 3745-1).

, 7 day average limit.

Fact Sheet for Akron Wastewater Treatment Plant NPDES Permit Renewal, 2006

-27-

000378

Table 13. Final effluent limits and monitoring requirements for Akron outfa1l3PF00000603 and the basis for their recommendation. Effluent Limits Concentration Loading (kg/day) 30 Day Daily 30 Day Daily Average Maximum Average Maximum - - - - - - - - - - - - Monitor - - - - - - - - - - - - - - - - - - - - - - - - - - Monitor - - - - - - - - - - - - - - 91 157 - - - - - - - - - - - - Monitor - - - - - - - - - - - - - - - - - - - - - - - - - - Monitor - - - - - - - - - - - - - - - - - - - - - - - - - - Monitor - - - - - - - - - - - - - - - - - - - - - - - - - - Monitor - - - - - - - - - - - - - - - - - - - - - - - - - - Monitor - - - - - - - - - - - - - - - - - - - - - - - - - - Monitor - - - - - - - - - - - - - - BEJ BEJ BEJ, EP BEJ, EP BEJ BEJ BEJ BEJ BEJ BEJ

Parameter Flow Dissolved Oxygen CBOD s Suspended Solids Cadmium, T. R. Chromium, T. R. Lead, T. R. Mercury, T. R. Nickel, T. R. Zinc, T. R.

Units MGD mg/! mg/l mg/l fLg/l fLg/l fLg/l ng/l fLg/l fLg/l

, Definitions:

BEJ = Best Engineering Judgment; EP

=

Existing Permit.

Fact Sheet/or Akron Wastewater Treatment Plant NPDES Permit Renewal, 2006
-28-

000379

Randall A. Monteith, P.E. Pilots Administrator Andre L Blaylock Business Services Administrator

Brian M. Gresser, P.E. WPC Plant Administrator

James L Six, P.E. Water Suppiy Plant Administrator

DONALD L. PLUSQUELLIC Mayor
Gerald Holland, Director DEPARTMENT OF PUBLIC SERVICE Michael L. McGlinchy, P.E. PUBLIC UTILITIES BUREAU MANAGER

March 14,2005 Joe Koncelik, Director Ohid EnvirDuro.ental ;::ToleCL1Ulj l;.gelh':y Division of Surface Water Lazarus Government Center 122 South Front Street, PO Box 1049 Columbus, OH 43216-1049 Subject: Signatory to reports from the City of Akron Permit # 3PFOOOOO*JD

Dear Mr. Konceliek: The City of Akron, Public Utilities Bureau would like to name Mr. Brian M. Gresser, P.E., as a duly authorized representative of Michael L. McGlinchy, P.E., Public Utilities Bureau Manager to certify the monthly operating reports required by its NPDES permit. Mr. Gresser is the Plant Administrator at the Akron Water Pollution Control Station and is a Class IV Ohio Wastewater Works Operator in responsible charge of the wastewater treatment plant, composting facility and environmental compliance. If you should require any Additional information or have any questions regarding this assignment free to call me at (330) 375-2627 or Mr. Gresser at (330) 928-1] 64 x 430.
Sincerely,

tee I

-'Y~~ j. }vU):J1J
Michael L. McGlinchy, PE Public Utilities Bureau Manager 'VILM/BMGltrr c: Jerry Holland Brian Gresser Donald Calvert Sandra Cappotto File

7

CitiCenter. 146 S. High Street. Room 9UO. t,kran. Ohio 44308. (330) 375-2627 ,FAX (330) 375-2072 w\\'v/ ::i.c.kron,oh,us 000380

AN
November 12, 1999

jl~:.;.

',",""

,' "oi
,~

16 :1-

;,

," "'~

Q

CITY OF AKRON AKRON POLLUTION CONTROL STATION 166 S. HIGH ST AKRON, OH 44308

ANNUAL DU Payment D
[ FOR WASTEWATER, H NPDES Permit No.: 3PFOOOOO

Facility Name: CITY OF AKRON AKRON Average Daily Flow for the period May 1, 1 (Design flow for new facilities; NA = stat 8ase Fee: $ 36000.00 Major Surcharge: $ 0.00

LL

TOTAL FE
Late charge of 100/0 ass. Detach payment stub below and mail with youl Ohio EPA Off D Columb. This is a lockbox payment address. Do not ma questions, please call the Annual Discharge Fee of F

).// "\
,

---~

,

'
I

-

«
'n
Q

~

...
~

21

B
w

\,
'" g
~

"3
~
Q

cb
N

;;<
CITY OF AKRON AKRON POLLUTION CONTROL STATION 166 S. HIGH ST AKRON, OH 44308

~

~ "'.£: go :E a x '" "

B

~ .9

" ~

~

:!\

~
Q

~

0.0

" .e [ ~ g I
=

lIJ

Due Date: January 30, 2000 Mail payment and stub with your check, made I Ohio EPA Office of Fiscal Administration, Department 631, Columbus, OH 43265-0631 Revenue ID # Total Fee Due: NPDES Permit No.:

'"

cLU

o~

E

g
0:

E

'" ~
LIl

11:

FOR OFFICE USE ONL Y 0000111573 Check ID# $ 36000.00 Check Date Check # 3PFOOOOO Amount

000381

JOSEPH P. KIDDER

Service Director
VALERIE STRAW Executive Assistant DONALD l. PLUSQUELLIC

LUND' O. ARMSTRONG Deputy Director JEFF FUSCO
Deputy Director

Mayor

DEPARTMENT OF PUBLIC SERVICE
100 S. High St., Room 201 Akron, OH 44308 Phone: (330) 375·2270 FAX: (330) 375·2100

December 15, 1998

Ms. Sandra M. Cappotto, Environmental Scientist Division of Surface Water Ohio EPA, Northeast District Office 2110 East Aurora Road Twinsburg, OR 44087-1969 Re:

City of Akron Ohio EPA NPDES Permit No. 3PFOOOOO"rn Director's Findings and Orders (September 20, 1994)

Dear Ms. Cappotto: Per the requirements of the Ohio EPA Director's FinalF'il1clings al1<iOr<iersdated SeptembeL20, 1994, Page 4, Paragraph 6, the City of Akron is submitting the following documents: Facilities Plan 98, Volume 1 Secondary Flow Routing, Impact Study System Wide Study, Phase II. By way of this letter, a copy of these documents are being forwarded to the Division of Surface, Ohio EPA, Columbus. Please note that the City of Akron previously requested an extension of time in order to submit the Final Facilities Plan Update and CSO Long Term Control Plan. The proposed date to submit the plan was November 30, 1999. This extension is needed due to (1) additional work required due to the findings of the impact study, (2) application of the watershed approach, including increased public input, (3) unforeseen circumstances, (4) Ohio EPA review time of the Impact Study that was longer than Akron expected and (5) Ohio EPA timing in issuance of the new GLI based NPDES pennit. Detailed discussion on each of these factors was provided in the letters to Ohio EPA dated September 21, 1998 and November 9, 1998. We understand that our request is being favorably received, and we are willing to assist in anyway possible to expedite said favorable response. The Northeast District OfTices participation and input into the Technical Advisory Group has been appreciated.

000382

Ms. Sandra M Cappotto December 15, 1998 Page 2

It is the intention of the City to provide an interim submittal of the Facilities Plan Update, Volume II (Non-Traditional Alternative, Collection System Alternatives and WPCS Integrated Alternatives) on April 30, 1999. Additional interim dates for several project sub-tasks were previously provided to the Agency leading up to the November 30, 1999 final submittal date. Also note that the data tables in Volume I will be updated to the most recent data available at the time of the Volume II submittal. Please feel free to contract me or David L. Crandell, Public Utilities Bureau Manager at (330) 375-2627 if you have any questions or need additional information

44r Jose~~idder,
Attachments c:

S~~,

c;}<;?;1 10&1---1

Director Department of Public Service JPKJPDG/JJB/kbs

Ohio EPA Central Office, Division of Surface Waters wiatt.' C. D. Haugh D. Crandell M. McGlinchy P Gsellman J. Bronowski File F-4 Environmental Division File

000383

JOSEPH P. KIDDER
Service Director

VALERIE STRAW
Executive Assistant

JEFF FUSCO
Deputy Director

DONALD l. PLUSQUaVlcFT
Mayor

DEPARTMENT OF PUBU&'SERVlGE:

September 21, 1998 Donald R. Schregardus, Director Ohio EPA P.O. Box 1049, 1800 WaterMark Dr. Columbus, Ohio 43266-0149 Subject

166 S. High St., Room 201 Akron, OH 44308 Phone: (330) 375·2270 FAX: (330) 375-2100

"

City of Akron Ohio EPA NPDES Permit No: 3PFOOOOO*ID Director's Findings and Orders

Dear Mr. Schregardus: The City of Akron is requesting an extension oftime in order to submit the Facilities Plan Update and CSO Long Term Control Plan shown as Order Number 6 of the Director's Final Findings and Orders effective September 20, 1994. This extension is needed due to (1) additional work required due to the findings of the impact study submitted December 28, 1995, (2) application of the watershed approach, including increased public input including public meetingslhearings and meetings with the tributary communities, (3) unforeseen circumstances, (4) Ohio EPA review time of the Impact Study that was longer than Akron expected and (5) Ohio EPA timing in issuance of the new GLI based NPDES permit (including the 1996 Watershed Water Quality Monitoring Report) These circumstances could not have been anticipated at the time of the initial development of the schedule and scope. The proposed date to submit the plan is November 30, 1999. The attached outline briefly discusses each of the factors influencing the need for the time extension in order to properly complete this plan. Ohio EPA-NEDO has been kept informed on the progress of the Facilities Plan Update and CSO effort. They are currently a member of the City's Technical Advisory Group. The City is committed to the development and implementation of the Facilities Plan Update and CSO Long Term Control Plan. The Facilities Plan Update and CSO related funds expended during the development of these plans was as follows: 1993 1994 1995 $2,649,000 $2,435,000 $2,445,000 1997 1998 $735,800 $3,602,600

A significant portion of the work completed can be submitted to the Agency for review at this time and in the near future. This includes the WPCS secondary flow routing project memorandum, the

000384

Donald R. Schregardus September 21, 1998 Page 2

Phase II Impact Study, the Updated Facilities Plan and several technical memorandums. This information has been made available to the Technical Advisory Group. We plan to coordinate the discussion ofthe time extension with the NEDO and set-up a schedule for submitting the interim reports and memorandum. A timeline is also being developed reflecting the new schedule date. This will be submitted to the NEDO in the near future. Please feel free to contact me or David L. Crandell, Public Utilities Bureau Manager, at 330-375-2627 if you have any questions, need additional information or wish to set up a meeting.

Enclosure c: Sandy Cappotto, NEDO-OhioEP,A. C.D. Haugh D. Crandell M. McG!inchy P. Gsellman File: F-04 1. Bronowski Environmental Division File

000385

City of Akron Ohio EPA NPDES Permit No: 3PFOOOOO*ID Director's Findings and Orders Time Extension The City of Akron is requesting an extension of time in order to submit the Facilities Plan Update and CSO Long Term Control Plan shown as Order Number 6 of the Director's Final Findings and Orders effective September 20, 1994. This extension is needed due to (1) additional work required due to the findings of the impact study submitted December 28, 1995, (2) application of the watershed approach, including increased public input including public meetings/hearings and meetings with the tributary communities, (3) unforeseen circumstances, (4) Ohio EPA review time of the Impact Study that was longer than Akron expected and (5) Ohio EPA timing in issuance of the new GLI based NPDES permit (including the 1996 Watershed Water Quality Monitoring Report). These circumstances could not have been anticipated at the time of the initial development of the schedule and scope. The proposed date to submit the plan is November 30, 1999. The following outline briefly discusses the factors influencing the need for the time extension. 1. Findings of impact study WPCS Secondary Flow Routing Ohio EPA's comments on the impact study indicated that additional investigation was required on the effects ofthe secondary flow routing on the receiving stream. In response to this the City expanded the scope of the project to specifically show the effect on the treatability curves developed for the Akron Water Pollution Control Station (WPCS). Also all the integrated alternatives being developed for the collection system are being evaluated for the effect on the secondary flow routing. A draft project memorandum is available upon request. This project resulted in an additional 2 months of work. Problems with the Northside Interceptor In the calibration of the sewer model a discrepancy (unbalanced flow) was found in the Northside Interceptor. This discrepancy let to additional field work and the discovery of excessive deposition ofsolids in the interceptor affecting both performance of the sewer and miscalculation in the model. Until this line could be cleaned, televised and re-monitored completion of the model was delayed. This situation was reviewed with the Ohio EPA on several occasions. The investigation, cleaning and re-monitoring resulted in an additional 3 months of work. Need for additional data collection The impact study showed the need of additional data in several areas including flow measurement, sampling, biological work, sediment analysis, and dissolved oxygen monitoring.

000386

The City met these needs by completing tbe Phase II Impact Study. This information was needed to begin model calibration and alternative development. This requirement of the Phase II Impact Study resulted in a delay in the project schedule. A draft Phase II Impact Study is available for review upon request. The Phase II Impact Study required an additional 9 months of work. Need for additional model refinement The receiving stream model required significantly more time to construct and calibrate thilll originally anticipated. Originally, dissolved oxygen was not considered to be a significant problem in the receiving stream and did not require to be modeled. The original emphasis was on modeling bacteria. Due to concerns at the WPCS in regard to dissolved oxygen and upstream CSOs the modeling needs were re-evaluated. This effort required additional field work, model calibrations and time. The locations of the additional D.O. monitoring plan was reviewed with NEDO Ohio EPA and their comments and suggestions were incorporated into the D.O. Monitoring Plan. This additional work was completed as part of the Phase II Impact Study. Several stream cross sections had to be re-surveyed due to changing conditions in the stream channel. Also, Ohio EPA requested that the City extend the limits of the model to Bolanz Rd. (a point further downstream). This additional work required I month to complete. Infrastructure Needs The Impact Study pointed out several areas where infrastructure needs required evaluation to determine if replacement was needed. As previously noted, the Northside Interceptor was one area needing further evaluation. Another area was the Ohio Canal Interceptor. Prior to determining the integrated alternatives for the Ohio Canal area, the interceptor needed to be internally inspected and assessed. The internal inspection of the Ohio Canal has yet to be completed as ofthe date ofthis letter. The initial inspection required 2 months. The inspection can not be completed due to the high velocities in the sewer. A request to temporarily bypass a section of sewer, in order to complete the inspection, was recently submitted. Upon completion of the inspection it is anticipated that an additional I month will be required to complete the Ohio Canal Alternatives. 2. Watershed Approach Background Contributions The City is attempting to identifY and quantifY background contributions resulting in failure to meet water quality standards. Ohio EPA has requested that the CSO Long Term Control Plan be expanded to include an evaluation of these factors. The City of Akron agrees that the most "cost-beneficial" solutions should be selected. In order to investigate areas outside the

000387

CSO realm, 2 months of additional work have already been performed and 1 month will be required. This is beyond the original scope of the Findings and Orders. Non-Traditional Alternatives There have been requests from the Ohio EPA and the Technical Advisory Group to review "non traditional alternatives" in regard to improving water quality. In order to investigate areas outside the CSO realm, 2 months of additional work has already been performed. One month of additional work will be required. This is beyond the original scope of the Findings and Orders. Public Participation The original scope did not include the proper time frames required for the required amount of public participation. The city is anticipating completing the alternatives in the next six months and then formalizing the public comment. Public input has been received by the TAG group throughout the development of the plan, but additional comment will still be needed. Additionally, the City Council and Administration participation is essential due to the projected impact on the sewer rates. The City would also like to allow for more input from Ohio EPA on the proposed plan before the formal public comment period. The City is also planning to have discussions with the tributary communities outside of the TAG meetings. These discussions will include the selection of the integrated alternatives and watershed issues involving the individual communities. 3. Unforeseen Circumstances Rack 40 Impact After completion of the Impact Study a field investigation determined the activation (overflow) of the Main Outfall Siphon Structure, now know as Rack 40, to the Little Cuyahoga River during a rain event. Due to this activation, the overflow was monitored and inputted into the model. Due to the modeled flows and the state of the instream water quality in this area, Rack 40 became a priority for the CSO program. The complexity of this CSO required the creation of a separate study to detailed the discharge flow rate and volume. This study required an additional 3 months which was not originally anticipated. Additional time is needed to continue to study this CSO in regard to flow rate and volume. The recent rain events of August 23 and 24, which were in the area of a 2 to 5 year storm return frequency, did not result in an overflow from CSO 40 on the 24th. According to the model, this CSO should have been active during both events. Therefore, the City is currently designing a flow measuring device, possibly a flume, to be installed by City personnel on an emergency basis in order to measures flow from several storm events. The installation of the flume, collection of data, and analysis will require an additional 4 months from the date ofthis letter.

000388

Model Results It was anticipated by the City that the CSO and receiving stream model would provide the City witb a method to rank and prioritize alternatives based on an imj>Tovement to instream water quality. As expected, the model results showed that CSO abatement provides little or no benefit toward meeting water quality. This required the City to adjust the model to more accurately reflect the flows and loads from the storm water drainage areas and the background (non-CSO) contributions. This additional work of 2 months allowed for improvements in the model to reflect the CSO-only contributions. This will assist in ranking and prioritizing the alternatives. LTCP Approach The City originally plarmed to follow the CSO strategy's demonstration approach to determine the required CSO controls. After several attempts to utilize this method it was determined that a combination ofthe two methods (demonstration and presumption approach) would be required along with the consideration of a Best Professional Judgement (BPJ) plan. The actual implementation ofthese methods has required considerably more time than originally thought. Completion of the evaluation is expected to take an additional 6 months. 4. Review TimesfPermit Issues Review Time The impact study was submitted on December 29, 1995 and comments were received from the agency August 22, 1996. At that time a request was made to the Ohio EPA to review the designated uses and its applicability along with a variance request. This request was responded to on December 2, 1996. Several meetings were held to discuss these issues and at the time it seemed to be progressing at a satisfactory pace. But in hind-sight, these effects resulted in approximately 12 months of additional time. Biological Data The collection of biological data by the City and the release of the State's data resulted in 10 months of additional time. This data was/is crucial in determining priorities for the CSO alternatives and the "non-traditional" alternatives. The City's data was available in February 1997 and the State's data was available December 1997.
It should be noted that the depressed biology in the area of CSO 40 contributed to the discovery of it' s activation.

000389

5. Permit Issues NPDES Permit
It was originally anticipated that the Long Term Control Plan would be in its final review stage at the time ofthe issuance ofthe new NPDES Permit. At that time the Plan would have been revised based on the Permit, as required. As of this date the City has not received its new permit, therefore the LTCP may require additional time for the incorporation of new permit requirements. Until the new permit is received, it can not be determined how much additional time will be required for the LTCP.

Water Quality Report The information from the 1996 Watershed Water Quality Monitoring Report is needed for the development of the alternatives in order to understand the impact on the receiving stream from the CSOs and background contributors.

000390

State of Ohio Environmental Protection Agency
STREET ADDRESS:
MAIUNG ADDRESS;
TELE: (614} 644-3020 FAX: (614) 644-2329

1800 WaterMark Drive
Columbus, OH 43215-1099

P.O. Box 1049 Columbus, OH 43216-1049

May 15th, 1998

David L. Crandell, Public Utilities Bureau Mgr. 146 South Higb Street, P.O.Box 3665, suite 900 Akron,OH44309-3665

Re: City of Akron WWTP

Dear Mr. Crandell: As requested, please find attached one copy of the Water Quality Pennit Support Document (WQPSD) for the City of Akron wastewater treatment plant and the biological and water quality infonnation. Both of these documents will be included, in part, in tbe fact sheet for the City of Akron WWTP. If you have any questions regarding the WQPSD, or require any additional infonnation, please feel free to contact me at, (614) 644-4823.

Since~~~c~
Panl Cree Division of Surface Water

*'

George V. Voinovich, Governor Nancy P. Hollister, Lt Governor Donald R. Schregardus, Director
Printed on Recyded Paper

000391

:::'J
CD
~

0
0 0 0 0

J:

0

...,

N

(J)
~

N

000392

Ohi.EPA
State afOhic Environmental Protection Agency

122 S. Front Street - Post Office Box 1049 Columbus, Ohio 43216-1049 614644-2050

July 05, 2006

RE:

Renewal of OEPA Permit No. 3IVOOOOO'DD App. No. OH0000612 Expiring Apr-30-2007

AkronWTP 1570 Ravenna Road Kent, OH 44240 .Dear Environmental Dept. Representative: Enclosed is one copy of Form 1 and 2C applications for renewal of your National Pollutant Discharge Elimination System (NPDES) permit. If the facility discharges storm water associated with industrial activity, excluding construction and that wastestream is to be authorized by the renewal permit then you must also submit a Form 2F. If a different form is needed it may be obtained by calling (614) 644-2156 or by going to the Ohio EPA website http://www.epa.state.oh.us/dsw/permits/npdesform.html. In the space provided for "EPA I.D. number" in the application, use the NPDES number, which for your permit, is 3IVOOOOO. File two paper copies of the application with Ohio EPA Northeast District Office 2110 East Aurora Rd, Twinsburg,OH 44240 and one electronic version using SWIMware. If you have questions regarding the electronic submittal of the application, please check the SWIMware website at: http://www.epa.state.oh.us/dsw/swims/swimintro.html or call the SWIMware Hotline at (614) 644-2050. When you first save the electronic copy in SWIMware you must provide a name for the application; please use the following name: 31V000002006. Do not file the paper or electronic versions of the application with the U.S. EPA. Filing of this application for the NPDES permit does not relieve you of the responsibility of filing applications for other permits that may be appropriate. Regulation requires this application to be signed only by the person authorized as described in the instructions Section B, Form 1. The application must be received by the Ohio EPA no later than 180 days prior to the expiration date of your permit, unless the permit contains an earlier submittal date. Revised Code 3745.11 requires that a non-refundable application fee of $200.00 accompany the application. The check should be made payable to the "Treasurer of the State of Ohio". In order to address issues reiated to OAC 3745-1-05 (Antidegradation Rule), also complete and submit the enclosed antidegradation addendum. Should there be any questions reG 330-963-1200. SENDER: COMPLETE TH/S SECr/ON

.
COMPLe:TE THIS SECT/ON 01'l0ELlVERY
.

.
o
Addressee

(~eIY,

II Complete items 1, 2, and 3. Also complete item 4 if Restricted Delivery is desired.
II Print your name and address on the reverse

A. Signatu-re

J G--cL J.
Patti L. Smith, Supervisor Permit Processing Unit Division of Surface Water Certified Mail Enclosures: Antidegradation , Forn, cc: DSW- NEDO, Portage Coun t

X

\Y\\c:h<J-:.. &

~ent

,c. '

that we can return the card to you. II Attach this card to the back of the mailpiece, or on the front if space permits.
SO

B. Received by ( Printed Name)

JU ~. Dt~f 200e~
D'l»s D No

1. Article Addressed to:

D. Is dativel)' address different from item 11 If YES, enter delivery address below:

31VOOOOO'DD AKRONWTP Attn: ENVIRONMENTAL DEPT. 1570 RAVENNA ROAD KENT,OH 44240
3. ~iCeType Certified Mail Registered Insured Mail

o o

o o

Express Mail Return Receipt for Merchandise

DC.O.D.
DYes

4. Restricted Delivery? (Extra Fee)

000393

7005 2570 0001 3211 3236
PS

Form 3811, February 2004

Domestic Return Receipt

102595-02-M-' 540

State of ohio Enviromnental Protection Agency
STREETADDRESS: MAILING ADDRESS:

Lazarus Government Center
122 S. Front Street

TELE: (614) 644-3020 FAX: (614) 644-2329

P.O. Box 1049

Columbus, OH 43216-1049

Columbus, OH 43215-1099 March 27, 2002 Re: Ohio EPA Permit No. 3IVOOOOO*DD Facility Name: Akron Water Treatment Plant

Akron Public Utilities Bureau 1570 Ravenna Road Kent, OH 44240 Ladies and Gentlemen: Transmitted herewith is one copy of the final National Pollutant Discharge Elimination System permit referenced above. You are hereby notified that this action of the director is final and may be appealed to the Environmental Review Appeals Commission pursuant to Section 3745.04 of the Ohio Revised Code. The appeal must be in writing and shall set forth the action complained of and the grounds upon which the appeal is based. It must be filed with the Environmental Review Appeals Commission within thirty (30) days after notice of the director's action. A copy of the appeal must be served on the director of the Ohio Environmental Protection Agency and the Environmental Law Division of the Office of the Attorney General within three days of filing with the Commission. An appeal may be filed with the Environmental Review Appeals Commission at the following address: Environmental Review Appeals Commission 236 East Town Street, Room 300 Columbus, Ohio 43215

~elY'.

Patti L. Smith, Supervisor Permit Processing Unit Division of Surface Water PLSjdks Enclosure CERTIFIED MAIL

rc.P"-. d. S

..rl-_

•

Complete items 1, 2, and 3..Also ~omplete item 4 if Restricted Delivery IS deSired. II Print your name and address on the reverse so that we can return the card to you.. . II Attach this card to the back ?f the mal1plece, or on the front if space permits.
1. Article Addressed to·

'--.J.l.K."-'-'-"

DYes D No

3. Serv;ce Type o Certified Mail o Registered

0 Express Mail 1 0 Return Receipt for Merdlandise 0 C.O.D. 0 Yes

'f===

o Insured Mail
~

4. Restricted Delivery? (Extra Fee)

7001 1940 0000 2940 5279
Domestic Return Receipt

*

PS Form 3811, August 2001
Printed on Recycled Paper

000394

102S9S-01·M·2509

NOTICE

OF

NPDES

PERMIT

FEE

DUE

INVOICE
OFFICE USE ONLY REVENUE ID#: DOCUMENT #: 275370 24651

ORGANIZATION #: PLACE ID#: Entity Name: Akron Public Utilities Bureau Mailing Address:
Kent,

34842 3IVOOOOO*DD
May 1,

Permit No.:

Effective Date:

2002

1570 Ravenna Road OR 44240

Facility Location:
Akron Water Treatment Plant
Kent,

1570 Ravenna Road OR 44240
Permit fees for the above facility were computed in accordance with the following information and at rates established in Section 3745.11 of the Ohio Revised Code.

Outfall Number 001 002 003

Design Flow (GPD) 600,000 600,000 4,000

Rate

Charges

$ $ $

750.00 750.00 100.00

$ $ $

750.00 750.00 100.00

I

FEE PAYMENT DUE:

$ 1600.00

I

Please remit not later than 15 days after the cited effective date of this permit. Make check payable to "Treasurer, State of Ohio" and mail it to: Ohio Environmental Protection Agency Lazarus Government Center Office of Fiscal Administration P. O. Box 1049 122 South Front Street Columbus, OR 43216-1049 Please return this· copy with your remittance.

000395

Page I 3IVOOOOO*DD

Application No. OH00006l2 Issue Date: March 27,2002 Effective Date: May 1, 2002 Expiration Date: April 30, 2007 Ohio Environmental Protection Agency Authorization to Discharge Under the National Pollutant Discharge Elimination System In compliance with the provisions of the Federal Water Pollution Control Act, as amended (33 U.S.C. 1251 et. seq., hereinafter referred to as the "Act"), and the Ohio Water Pollution Control Act (Ohio Revised Code Section 6111), The City of Akron Water Treatment Plant is authorized by the Ohio Envirorimental Protection Agency, hereinafter referred to as "Ohio EP ~" to discharge from the waste water treatment works located at 1570 Ravenna Road, Kent, Ohio, Portage County and discharging to the Cuyahoga River in accordance with the conditions specified in Parts I, II, and III of this permit. This permit is conditioned upon payment of applicable fees as required by Section 3745.11 of the Ohio Revised Code. This permit and the authorization to discharge shall expire at midnight on the expiration date shown above. In order to receive authorization to discharge beyond the above date of expiration, the permittee shall submit such information and forms as are required by the Ohio EPA no later than 180 days prior to the above date of expiration.

. " .~,<

Christopher Jones Director Total Pages: 23

000396

Page 2 31VOOOOO*DD

Part I, A. - FINAL EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS 1. During the period beginning 36 months following permit issuance and lasting nntil the expiration date, the permittee is authorized to discharge in accordance with the following limitations and monitoring requirements from outfall 3IV00000003. See Part II, OTHER REQUIREMENTS, for locations of effluent sampling. Table - Final Outfall - 003 - Final
Monitoring Requirements Loading* kg/day Daily Weekly Mouthly Measuring
Frequency

Effluent Characteristic
Parameter

Discharge Limitations Concentration Specified Units MaximumMinimum Weeldy Monthly

Sampling Type Grab 24hr Total Estimate Grab Grab Grab Grab Estimate

Monitoring Months

00010 - Water Temperature - C 00056 - Flow Rate - GPD 00083 - Color, Severity - Units 00300 - Dissolved Oxygen - mgll 00400 - pH - S.U. 00530 - Total Suspended Solids - mg/I 00610 - Nitrogen, Arrunonia (NH3) - mg/I 01330 - Odor, Severity - Units 01350 - Turbidity, Severity - Units 31616 - Fecal Coliform - #/100 ml 50060 - Chlorine, Total Residual - mg/l 80082 - CHOD 5 day - mg/I 2000 0.038 12 1000 0.006

I/Week I/Day l/Day I/Week

All All All All All All All All All
Summer Summer

9.0
12 1.5

6.5

l/Month

8
1.0

0.18 0.023

0.12 0.015

I/Month I/Month I/Day I/Day I/Month

Estimate
Grab

1/2 Weeks Grab 0.12 I/Month Grab

8

0.18

All

Notes for Station Number 3IV00000003:

* Effluent loadings based on average design flow of 0.004 MGD. - Sampling shall be performed when discharging. If NO DISCHARGE OCCURS DURING THE ENTIRE MONTH, report "AL" in the first column of the first day of the month on the 4500 Fonn (Monthly Operating Report). A signature is still required. - See Part II, Item G. - Color, Odor and Turbidity - See Part II, Item E.
000397

Page 3 3IVOOOOO'DD

Part I, A. - FINAL EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS 1. During the period beginning on the effective date of this permit and lasting until the expiration date, the permittee is authorized to discharge in accordance with the following limitations and monitoring requirements from outfa1l3IVOOOOOOOl. See Part II, OTHER REQUIREMENTS, for locations of effluent sampling. Table - Final Outfall- 001 - Final
Effluent Characteristic
Parameter

Discharge Limitations Concentration Specified Units Loading' kglday MaximumMinimum Weekly Monthly Daily Weekly Monthly 9.0 45
6.5

Monitoring Requirements

Measuring
Frequency

Sampling Type

Monitoring Months
All All All All

00400 - pH - S.U. 00530 - Total Suspended Solids - mg/l 50050 - Flow Rate - MGD 82080 - Tribalomethane, Total - ug/l

1/2 Weeks Grab

30

102

68

1/2 Weeks Composite 1/2 Weeks 24hrTotal

IlMontb

Grab

Notes for Station Number 3IVOOOOOOOI:

*

Effluent loadings based on average design flow of 0.6 MGD. Sampling shall be performed when discharging. If NO DISCHARGE OCCURS DURING THE ENTIRE MONTH, report "AL" in the first column of the first day of the month on the 4500 Form (Monthly Operating Report). A signature is still required. See Part II, Item G.

000398

Page 4 3IVOOOOO*DD

Part I, A. - FINAL EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS 1. During the period beginning on the effective date of this pennit and lasting until the expiration date, the pennittee is authorized to discharge in accordance with the following limitations and monitoring requirements from outfall 3IV00000002. See Part II, OTHER REQUIREMENTS, for locations of effluent sampling. Table - Final Outfall- 002 - Final
Effluent Characteristic
Parameter

Discharge Limitations Concentration Specified Units MaximumMinimum Weekly Monthly Loading* kglday Daily Weekly Monthly
Measuring

Monitoring Requirements
Frequency
1/2 Weeks Grab

Sampling Type

Monitoring Months All All All All

00400 - pH - S.U. 00530 - Total Suspended Solids - mg/l 50050 - Flow Rate - MGD 82080 - Trihalomethane, Total- ugll

9.0
45

6.5

30

102

68

I I 2 Weeks Composite
1/2 Weeks 24hr Total

I/Month

Grab

Notes for Station Number 3IV00000002:

*

Effluent loadings based on average design flow of 0.6 MGD.

Sampling shall be perfonned when discharging. IfNO DISCHARGE OCCURS DURING THE ENTIRE MONTH, report "AL" in the first column ofthe first day ofthe month on the 4500 Fonn (Monthly Operating Report). A signature is still required. See Part II, Item G.

000399

Page 5 3IVOOOOO*DD

Part I, A. - INTERIM EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS 1. During the period beginning on the effective date of this permit and lasting until 36 months following the permit issuance, the permittee is authorized to discharge in accordance with the following limitations and monitoring requirements from outfall3IV00000003. See Part II, OTHER REQUIREMENTS, for locations of effluent sampling. Table - Final Outfall - 003 - Interim
Effluent Characteristic Parameter 000 I 0 - Water Temperature· C 00056 • Flow Rate· GPD 00083 - Color, Severity - Units 00300 - Dissolved Oxygen - mg/l 00400 - pH - S. U. 00530 - Total Suspended Solids - mg/I 00610 - Nitrogen, Ammonia (NH3) - mg/l 01330· Odor, Severity - Units 01350· Turbidity, Severity - Units 31616· Fecal Coliform· #/100 ml 50060 - CWorine, Total Residual - mgll 80082 - CHOD 5 day - mg/I 2000 0.038 15 10 1000 0.006 0.23 0.15 18 12 0.27 0.18 Discharge Limitations Concentration Specified Units MaximumMinimum Weeldy Monthly Loading' kg/day Daily Weekly Monthly Measuring Frequency IlWeek IlDay IlDay IlWeek IlMonth I/Month IlMonth IlDay IlDay l/Month Grab 24hr Total
Estimate

Monitoring Requirements Sampling Type Monitoring Months All All All All All All All All All Summer
Summer

Grab Grab Grab Grab Estimate Estimate Grab

1/2 Weeks Grab IlMonth Grab

All

Notes for Station Number 3IV00000003:

* Effluent loadings based on average design flow of 0.004 MGD. - Sampling shall be performed when discharging. If NO DISCHARGE OCCURS DURING THE ENTIRE MONTH, report "AL" in the first column of the first day ofthe month on the 4500 Form (Monthly Operating Report). A signature is still required. - See Part II, Item G. - Color, Odor and Turbidity - See Part II, Item E.
000400

Page 6 3IVOOOOO*DD

Part I, B. - SLUDGE MONITORING REQUIREMENTS
1. Sludge Monitoring. During the period beginning on the effective date of this permit and lasting until the expiration date, the permittee shall monitor the treatment works' final sludge at Station Number 3IV00000588, and report to the Ohio EPA in accordance with the following table. See Part II, OTHER REQUIREMENTS, for location of sludge sampling.

Table - Sludge Monitoring - 588 - Final
Effluent Characteristic Parameter 70316 - Sludge Weight - Dry Tons 70318 - Sludge Solids, Percent Total- % Discharge Limitations Concentration Specified Units Loading' kg/day MaximumMinimum Weekly Monthly Daily Weekly Monthly Monitoring Requirements Measuring Frequency l/Month l/Month Total Grab Sampling Type Monitoring Months
All All

NOTES for Station Number 3IV00000588:

* Monitoring is required when sludge is removed from the wastewater treatment facility and disposed of at another wastewter treatment plant.
Ifno sludge is removed during the entire month, report "AL" in the first column of the first day of the month on the 4500 Form (Monthly Operating Report). A signature is still required.

** Units of mglkg are on a dry weight basis. *** Sludge weight is a calculated total for the sampling period.

000401

yage / 3IVOOOOO*DD

Part I, B. - DOWNSTREAM-FARFIELD MONITORING REQUIREMENTS 1. Downstream-Farfield Monitoring. During the period beginning on the effective date of this permit and lasting until the expiration date, the permittee shall monitor the receiving stream, downstream of the point of discharge, at Station Number 3IV00000901, and report to the Ohio EPA in accordance with the following table. See Part II, OTHER REQUIREMENTS, for location of sampling. Table - Downstream-Farfield Monitoring - 901 - Final
Effluent Characteristic
Parameter

Discharge Limitations Concentration Specified Units MaximnmMinimnm Weekly Monthly Loading* kg!day Daily Weekly Monthly Measuring Frequency IlMonth I/Week I/Week IlMonth IlMonth IlMonth

Monitoring Requirements

Sampling Type Grab Grab Grab Grab Grab Grab

Monitoring Months Winter Summer
Summer

00010 - Water Temperature - C 00010 - Water Temperature - C 00300 - Dissolved Oxygen - mg!l 00300 - Dissolved Oxygen - mg!l 00900 - Hardness, Total (CaC03) - mgll 01042 - Copper, Total (Cu) - ug!1

Winter All All

000402

Page 8 31VOOOOO*DD

Part I, B. - UPSTREAM MONITORING REQUIREMENTS I. Upstream Monitoring. During the period beginning on the effective date of this pennit and lasting until the expiration date, the pennittee shall monitor the receiving stream, upstream of the point of discharge at Station Number 31V0000080I, and report to the Ohio EPA in accordance with the following table. See Part II, OTHER REQUIREMENTS, for location of sampling. Table - Upstream Monitoring - 801 - Final
Discharge Limitations Concentration Specified Units
Parameter

Effluent Characteristic

Monitoring Requirements
Loading* kg/day Weekly Monthly Measuring Frequency 1lMonth IlMonth Grab Grab Sampling Type Monitoring Months All All

MaximumMinimum Weekly

Monthly

Daily

00900 - Hardness, Total (CaC03) - mg/l 01042 - Copper, Total (Cu) - ug/l

000403

Page 9 3IVOOOOO*DD

Part L C. - SCHEDULE OF COMPLIANCE Industrial Construction Schedule I. The permittee shall achieve compliance with the final effluent limitations for outfall 3IV00000003 as specified in Part LA. of this NPDES permit as expeditiously as practicable. In any event, the permittee shall attain final compliance not later than the dates developed in accordance with the following schedule: a. The permittee shall submit to the appropriate Ohio EPA district office a complete and approvable PTI application and detailed plans for achieving final compliance for outfall 3IV00000003 as soon as possible, but not later than 18 months following permit issuance. (Event Code 01299) b. The permittee shall have completed construction as soon as possible, but not later than 24 months following permit issuance. (Event Code 04599) c. The permittee shall have attained full compliance with the final effluent limitations for outfall 3IV00000003 as soon as possible, but not later than 36 months following permit issuance. (Event Code 05599)

000404

Page 10 3IVOOOOO*DD

Part II, OTHER REQUIREMENTS A. Description of the location of the required sampling stations are as follows: Sampling Station Description of Location

3IVOOOOOOOI 3IV00000002 3IV00000003

3IV00000588 3IV00000801

3IV00000901

Discharge from lower west lagoon (Lat: 41 N 11'00 n; Long: 81 W20 'OS n) Discharge from lower east lagoon (Lat: 41 N 11' 00 n; Long: 81 W 20 '05 n) Discharge from sanitary package plant prior to entering the Cuyahoga River (Lat: 41 N 10' 48 n; Long: 81 W 20 '07 n) Sludge monitoring station for sludge removed from sanitary package plant. Sample of Cuyahoga River upstream of Lake Rockwell at State Route 303 (Lat: 41 N 14' 18 n; Long: 81 W 18 ' 13 n) Downstream of Lake Rockwell at the west bank of the Cuyahoga River upstream of the Twin Lakes Tributary (Lat: 41 N 10' 52 n; Long: 81 W 20 '07 n)

B. This permit shall be modified, or alternatively, revoked and reissued, to comply with any applicable effluent standard or limitation issued or approved under Sections 301(b)(2)(C) and (D), 304(b)(2), and 307(a)(2) ofthe Clean Water Act, if the effluent standard or limitation so issued or approved. 1. Contains different conditions or is otherwise more stringent than any effluent limitation in the permit; or 2. Controls any pollutant not limited in the permit. The permit as modified or reissued under this paragraph shall also contain any other requirements of the Act then applicable. C. All parameters, except flow, need not be monitored on days when the plant is not normally staffed (Saturdays, Sundays, and Holidays). On those days, report nAN" on the monthly report form. D. Permit limitations may be revised in order to meet water quality standards after a stream use determination and waste load allocation are completed and approved. This permit may be modified, or alternatively, revoked and reissued, to comply with any applicable water quality effluent limitations.

000405

Page 11 3IVOOOOO*DD

E. If Severity Units are required for Turbidity, Odor, or Color, use the following table to determine the value between 0 and 4 that is reported. REPORTED VALUE* SEVERITY DESCRIPTION

TURBIDITY

ODOR

COLOR

0 1

2
3 4

None Mild Moderate Serious Extreme

Clear Light Solids Heavy Solids

None Musty Septic

Colorless Grey Black

* Interpolate between the descriptive phrases. F. Grab samples shall be collected at such times and locations, and in such fashion, as to be representative of the facility's performance. G. Effluent disinfection is not directly required, however, the entity is required to meet all applicable discharge permit limits. If disinfection facilities exist, they shall be maintained in an operable condition. Any design of wastewater treatment facilities should provide for the capability to install disinfection if required at a future time. Disinfection may be required if future bacteriological studies or emergency conditions indicate the need. H. Final permit limitations based on preliminary or approved waste load allocations are subject to change based on modifications to or finalization of the allocation or report or changes to Water Quality Standards. Monitoring requirements and/or special conditions of this permit are subject to change based on regulatory or policy changes.

I. Within 4 months of the effective date of this Permit, the permittee shall submit to the appropriate Ohio EPA District Office an evaluation of its sludge management plan, which was approved on October 16, 1995.
This evaluation shall examine the adequacy ofthe plan, including any implementation problems encountered and any changes required, and is to reflect the actual sludge disposal practices. If significant changes are required, the permittee may be required to submit for approval a modified sludge management plan.

000406

Page 12

3IVOOOOO*DD

J. Not later than January 31 of each calendar year, the permittee shall submit two (2) copies of a report summarizing the sludge disposal and/or reuse activities of the facility during the previous year. One copy of the report shall be sent to the Ohio EPA, Division of Surface Water, Central Office, and one copy ofthe report shall be sent to the appropriate Ohio EPA District Office. This report shall address: I) Amount of sludge disposed of/reused in dry tons. 2) Method(s) of disposal/reuse. 3) Summary of all analyses made on the sludge, including any priority pollutant scans that may have been performed. (If a priority pollutant scan has been conducted as a part of the pretreatment program, the most recent analysis should be submitted.) 4) Problems encountered including any complaints received. The cause or reason for the problem and corrective actions taken to solve the problem should also be included. Any incidents of interference with the method of sludge disposal shall be identified, along with the cause of interference (i.e., excessive metals concentration, contaminated sludge, etc.) and the corrective actions taken.

000407

Page 13 3IVOOOOO*DD PART III - GENERAL CONDITIONS I.DDEFINITIONS "Daily load" is the total discharge by weight during auy calendar day. If only one sample is taken during a day, the weight of pollutaut discharge calculated from it is the daily load.

'!Daily concentration" means the arithmetic average of all the determinations of concentration made during the day. If only one sample is taken during the day, its concentration is the daily concentration. Coliform bacteria limitations compliauce shall be determined using the geometric meau.
"Weeldy load" is the total discharge by weight during auy 7-day period divided by the number of days in that 7-day period that the facility was in operation. If only one sample is taken in a 7-day period, the weight of pollutaut discharge calculated from it is the 7-day load. If more thau one sample is taken during the 7-day period, the 7-day load is calculated by determining the daily load for each day sampled, totaling the daily loada for the 7-day period, aud dividing by the number of days sampled.

"Weekly coucentrationt! means the arithmetic average of all the determinations of daily concentration limitation made during the 7-day period. If only one sample is taken during the 7-day period, its concentration is the 7-day concentration for that 7-day period. Coliform bacteria limitations compliauce shall be determined using the geometric meau.
"Monthly load" is the total discharge by weight during all days in a calauder month divided by the number of days that the facility was in operation during that month. If only one sample is taken during the month the weight of pollutaut discharge calculated from it is the monthly load. If more thau one sample is takeu during the month, the monthly load is calculated by determining the daily load for each day sampled, totaling the daily loads for the month aud dividing by the number of days sampled. "Monthly concentration11 means the arithmetic average of all the determinations of daily concentration made during auy calender month. If only one sample is taken during the month, its concentration is the monthly concentration for that period. Coliform bacteria limitations compliauce shall be determined using the geometric mean.

"85 percent removal" means the arithmetic mean of the values for effluent samples collected in a period of 30 consecntive days shall not exceed 15 percent of the arithmetic meau of the values for influent samples collected at approximately the same times during the same period. "Absolute Limitations" Compliance with limitations having descriptions of Hshall not be less than," "nor greater than, ,t II shall not exceed," "minimum," or "maximum II shall be detennined from any single value for effluent samples andlor measurements collected. "Net concentration" shall mean the difference between the concentration of a given substance in a sample taken of the discharge aud the concentration of the same substances in a sample taken at the intake which supplies water to the given process. For the putpose of this defInition, samples that are taken to determine the net concentration shall always be 24-hour composite samples made up of at least six increments taken at regular intervals throughout the plaut day.

000408

Part III General Conditions (Con't)

Page 14 3IVOOOOO*DD

"Net load" shall mean the difference between the load of a given substance as calculated from a sample taken of the discharge and the load of the same substance in a sample taken at the intake which supplies water to given process. For purposes of this definition, samples that are taken to determine the net Loading shall always be 24-hour composite samples made up of at least six increments taken at regular intervals throughout the plant day. "MGD" means million gallons per day.

"rog/l means milligrams per liter. "ug/l" means micrograms per liter.
"Reporting Code" is a five digit number used by the Ohio EPA in processing reported data. The reporting code does not imply the type of analysis used nor the sampling techniques employed. "Quarterly (l/Quarter) sampling frequency" means the sampling shall be done in the months of March, June, August, and December, unless specificially identified otherwise in the Effluent Limitations and Monitoring Requirements table. "Yearly (I/Year) sampling frequency" means the sampling shall be done in the month of September, unless specificially identified otherwise in the effluent limitations and monitoring requirements table. "Semi-annual (2/Year) sampling frequency" means the sampling shall be done during the months of June and December, unless specificially identified otherwise. "Winter" shall be considered to be the period from November I through April 30. "Bypass" means the intentional diversion of waste streams from any portion ofthe treatment facility. "Summer" shall be considered to be the period from May I through October 31. "Severe property damage" means substantial physical damage to property, damage to the treatment facilities which would cause them to become inoperable, or substantial and permanent loss of natural resources which can reasonably be expected to occur in the absence of a bypass. Severe property damage does not mean economic loss caused by delays in production.

ll

"Upset" means an exceptional incident in which there is unintentional and temporary noncompliance with technology based permit effluent limitations because of factors beyond the reasonable control of the permittee. An upset does not include noncompliance to the extent caused by operational error, improperly designed treatment facilities, inadequate treatment facilities, lack ofpreventive maintenance, or careless or improper operation.

000409

Part III General Conditions (Con't) 2. GENERAL EFFLUENT LIMITATIONS The effluent shall, at all times, be free of substances:

Page 15 3IVOOOOO*DD

A. In amounts that will settle to fonn putrescent, or otherwise objectionable, sludge deposits; or that will adversely affect aquatic life or water fowl;
B. Of an oily, greasy, or surface-active nature, and of other floating debris, in amounts that will form

noticeable accumulations of scum, foam or sheen;
C. In amounts that will alter the natural color or odor of the receiving water to such degree as to create a nuisance;

D. In amounts that either singly or in combination with other substances are toxic to human, animal, or aquatic life;
E. In amounts that are conducive to the growth of aquatic weeds or algae to the extent that such growths become inimical to more desirable forms of aquatic life, or create conditions that are unsightly, or constitute a nuisance in any other fashion; F. In amounts that will impair designated instream or downstream water uses. 3. FACILITY OPERATION AND QUALITY CONTROL All wastewater treatment works shall be operated in a manner consistent with the following:
A. At all times, the permittee shall maintain in good working order and operate as efficiently as possible all treatment or control facilities or systems installed or used by the pennittee necessary to achieve

compliance with the terms and conditions of this permit. Proper operation and maintenance also includes adequate laboratory controls and appropriate quality assurance procedures. This provision requires the operation of back-up or auxiliary facilities or similar systems which are installed by a permittee only when the operation is necessary to achieve compliance with conditions of the permit.
B. The permittee shall effectively monitor the operation and efficiency of treatment and control facilities and the quantity and quality of the treated discharge.
C. Maintenance of wastewater treatment works that results in degradation of effluent quality shall be scheduled during non-critical water quality periods and shall be carried out in a manner approved by Ohio EPA as specified in the Paragraph in the PART III entitled, "UNAUTIIORIZED DISCHARGES".

4. REPORTING A. Monitoring data required by this permit may be submitted in hardcopy fonnat on the Ohio EPA 4500 report fonn pre-printed by Ohio EPA or an approved fucsimile. Ohio EPA 4500 report forms for each individual sampling station are to be received no later than the 15th day of the month following the month-of-interest. The original report fonn must be signed and mailed to: Ohio Environmental Protection Agency Lazarus Government Center Division of Surface Water Enforcement Section ESIMOR P.O. Box 1049 Columbus, Ohio 43216-0149

000410

Part III General Conditions (Con't)

Page 16 3IVOOOOO*DD

Monitoring data may also be submitted electronically using Ohio EPA developed SWIMware software. Data must be transmitted to Ohio EPA via electronic mail or the bulletin board system by the 20th day of the month following the month-of-interest. A Surface Water Information Management System (SWIMS) Memorandum of Agreement (MOA) must be signed by the responsible official and submitted to Ohio EPA to receive an authorized Personal Identification Number (PIN) prior to sending data electronically. A hardcopy of the Ohio EPA 4500 form must be generated via SWIMware, signed and maintained onsite for records retention purposes. B. If the permittee monitors any pollutant at the location(s) designated herein more frequently than required by this permit, using approved analytical methods as specified below, the results of such monitoring shall be included in the calculation and reporting of the values required in the reports specified above. C. Analyses of pollutants not required by this permit, except as noted in the preceding paragraph, shall not be reported on Ohio EPA report form (4500) but records shall be retained as specified in the paragraph entitled "RECORDS RETENTION". 5. SAMPLING AND ANALYTICAL METHOD Samples and measurements taken as required herein shall be representative of the volume and nature monitored flow. Test procedures for the analysis of pollutants shall conform to regulation 40 CFR 136, "Test Procedures For The Analysis of Pollutants" unless other test procedures have been specified in this permit. The permittee shall periodically calibrate and perform maintenance procedures on all monitoring and instrumentation at intervals to insure accuracy of measurements. 6. RECORDING OF RESULTS For each measurement or sample taken pursuant to the requirements of this permit, the permittee shall record the following information: A. The exact place and date of sampling; (time of sampling not required on EPA 4500)
B. The person(s) who performed the sampling or measurements;

C. The date the analyses were performed on those samples; D. The person(s) who performed the analyses; E. The analytical techniques or methods used; and F. The results of all analyses and measurements.

000411

Part III General Conditions (Con't) 7. RECORDS RETENTION

Page 17 3IVOOOOO*DD

The permittee shall retain all of the following records for the wastewater treatment works for a minimum of three years, including: A. All sampling and analytical records (including internal sampling data not reported);

B. All original recordings for any continuous monitoring instrumentation;

C. All instrumentation, calibration and maintenance records;
D. All plant operation and maintenance records; E. All reports required by this permit; and F. Records of all data used to complete the application for this permit for a period of at least three years from the date of the sample, measurement, report, or application. These periods will be extended during the course of any unresolved litigation, or when requested by the Regional Administrator or the Ohio EPA. The three year period for retention of records shall start from the date of sample, measurement, report, or application. 8. AVAILABILITY OF REPORTS Except for data determined by the Ohio EPA to be entitled to confidential status, all reports prepared in accordance with the terms of this permit shall be available for public inspection at the appropriate district offices of the Ohio EPA. Both the Clean Water Act and Section 6111.05 Ohio Revised Code state that effluent data and receiving water quality data shall not be considered confideutial. 9. DUTY TO PROVIDE INFORMATION The permittee shall furnish to the Director, within a reasonable time, any information which the Director may request to determine whether cause exists for modifying, revoking, and reissuing, or tenninating the permit, or to determine compliance with this permit. The permittee shall also furnish to the Director, upon request, copies of records required to be kept by this permit. 10. RIGHT OF ENTRY The permittee shall allow the Director or an authorized representative upon presentation of credentials and other documents as may be required by law to:
A. Enter upon the permittee's premises where a regulated facility or activity is located or conducted, or where records must be kept under the conditions of this permit.
B. Have access to and copy, at reasonable times, any records that must be kept under the conditions of the permit.

C. Inspect at reasonable times any facilities, equipment (including monitoring and control equipment), practices, or operations regulated or required under this permit.
D. Sample or monitor at reasonable times, for the purposes of assuring pennit compliance or as otherwise authorized by the Clean Water Act, any substances or parameters at any location.

000412

Part III General Conditions (Con't) I I. UNAUTHORIZED DISCHARGES

Page 18 3IVOOOOO*DD

A. Bypassing or diverting of wastewater from the treatment works is prolubited unless:
I. Bypass was unavoidable to prevent loss of life, personal injury, or severe property damage; 2. There were no feasible alternatives to the bypass, such as the use of auxiliary treatment facilities, retention of untreated wastes, or maintenance during normal periods of downtime. This condition is not satisfied if adequate back up equipment should have been installed in the exercise of reasonable engineering judgment to prevent a bypass which occurred during normal periods of equipment downtime

or preventive maintenance; and
3. The permittee submitted notices as required under paragraph D. of this section, B. If the permittee knows in advance of the need for a bypass, it shall submit prior notice, ifpossible at least ten days before the date of the bypass.
C. The Director may approve an unanticipated bypass after considering its adverse effects, if the Director determines that it has met the three conditions listed in paragraph I I.A. of this section.

D. The permittee shall submit notice of an unanticipated bypass as required in section 12. A. E. The permittee may allow any bypass to occur which does not cause effluent limitations to be exceeded

if that bypass is for essential maintenance to assure efficient operation.

000413

Part III General Conditions (Con't) 12. NONCOMPLIANCE NOTIFICATION

Page 19 3IVOOOOO*DD

A. The petnlittee shall by telephone report any of the following within twenty-four (24) hours of discovery at (toll free) 1-800-282-9378: 1. Any noncompliance which may endanger health or the enviromnent; 2. Any unanticipated bypass which exceeds any effluent limitation in the p=it; or 3. Any upset which exceeds any effluent limitation in the petnlit 4. Any violation of a maximum daily discharge limitation for any of the pollutants listed by the Director in the petnlit.
B. For the telephone reports required by Part 12.A., the following infotnlation must be included:

1. The times at which the discharge occurred, and was discovered; 2. The approximate amount and the characteristics of the discharge; 3. The strearn(s) affected by the discharge; 4. The circumstances which created the discharge; 5. The names and telephone numbers of the persons who have knowledge of these circumstances; 6. What remedial steps are being taken; and 7. The names and telephone numbers of the persons responsible for such remedial steps. C. These telephone reports shall be confmned in writing within five days of the discharge and submitted to the appropriate Ohio EPA district office. The report shall include the following:

1. The limitation(s) which has been exceeded;
2. The extent of the exceedance(s); 3. The cause of the exceedance(s); 4. The period of the exceedance(s) including exact dates and times; 5. If uncorrected, the anticipated time the exceedance(s) is expected to continue, and 6. Steps being taken to reduce, eliminate, and/or prevent occurrence of the exceedance(s).

000414

Part III General Conditions (Con't) D. Compliance Schedule Events:

Page 20 3IVOOOOO *DD

If the permittee is unable to meet any date for achieving an event, as specified in the schedule of compliance, the permittee shall submit a written report to the appropriate district office of the Ohio EPA within 14 days of becoming aware of such situation. The report shall include the following: 1. The compliance event which has been or will be violated; 2. The cause of the violation; 3. The remedial action being taken; 4. The probable date by which compliance will occur; and 5. The probability of complying with subsequent and final events as scheduled. E. The permittee shall report all instances of noncompliance not reported under paragraphs A, B, or C of this section, at the time monitoring repotts are submitted. The reports shall contain the information listed in paragraphs B and C of this section. F. Where the permittee becomes aware that it failed to submit any relevant application or submitted incorrect information in a permit application or in any report to the director, it shall promptly submit such facts or infonnation. 13. RESERVED 14. DUTY TO MITIGATE The permittee shall take all reasonable steps to minimize or prevent any discharge in violation of this permit which has a reasonable likelihood of adversely affecting hnman health or the environment. 15. AUTHORIZED DISCHARGES All discharges authorized herein shall be consistent with the terms and conditions of this permit. The discharge of any pollutant identified in this permit more frequently than, or at a level in excess of, that authorized by this permit shall constitute a violation of the terms and conditions of this permit. Such violations may result in the imposition of civil andlor criminal penalties as provided for in Section 309 of the Act and Ohio Revised Code Sections 6111.09 and 6111.99. 16. DISCHARGE CHANGES The following changes must be reported to the appropriate Ohio EPA district office as soon as practicable:
A. For all tteatment works, any significant change in character of the discharge which the permittee knows or has reason to believe has occurred or will occur which would constitute cause for modification or revocation and reissuance. The permittee shall give advance notice to the Director of any planned changes in the permitted facility or activity which may result in noncompliance with permit requirements. Notification of permit changes or anticipated noncompliance does not stay any permit condition. B. For publicly owned treatment works:

1. Any proposed plant modification, addition, andlor expansion that will change the capacity or efficiency of the plant; 2. The addition of any new significant industrial discharge; and 3. Changes in the quantity or quality of the wastes from existing tributary industrial discharges which will result in significant new or increased discharges of pollutants.

000415

Part III General Conditions (Con't)

Page 21 3IVOOOOO*DD

C. For non-publicly owned treatment works any proposed facility expansions, production increases, or process modifications, which will result in new, different, or increased discharges of pollutants. Following this notice, modifications to the permit may be made to reflect any necessary changes in permit conditions, including any necessary effluent limitations for any pollutants not identified and limited herein. A determination will also be made as to whether a National Environmental Policy Act (NEPA) review will be required. Sections 6111.44 and 6111.45, Ohio Revised Code, require that plans for treatment works or improvements to such works be approved by the Director of the Ohio EPA prior to
initiation of construction.

D. In addition to the reporting requirements under 40 CFR 122.41(1) and per 40 CFR 122.42(a), all existing manufacturing, commercial mining, and silvicultural dischargers must notify the Director as soon as they know or have reason to believe: I. That any activity has occurred or will occur which would result in the discharge on a routine or frequent basis of any toxic pollutant which is not limited in the permit. If that discharge will exceed the highest of the "notification levels" specified in 40 CFR Sections I 22.42(a)(1)(i) through 122.42(a)(1)(iv). 2. That any activity has occurred or will occur which would result in any discharge, on a non-routine or infrequent basis, of a toxic pollutant which is not limited in the permit, if that discharge will exceed the highest of the "notification levels" specified in 122.42(a)(2)(i) through 122.42(a)(2)(iv). 17. TOXIC POLLUTANTS The permitree shall comply with effluent standards or prohibitions established under Section 307 (a) of the Clean Water Act for toxic pollutants within the time provided in the regulations that estahlish these standards or prohibitions, even if the permit has not yet been modified to incorporate the requirement. Following establishment of such standards or prohibitions, the Director shall modify this permit and so notify the permittee. 18. PERMIT MODIFICATION OR REVOCATION A. After notice and opportunity for a hearing, this permit may be modified or revoked, by the Ohio EPA, in whole or in part during its term for cause including, but not limited to, the following: I. Violation of any terms or conditions of this permit; 2. Obtaining this permit by misrepresentation or failure to disclose fully all relevant facts; or 3. Change in any condition that requires either a temporary or permanent reduction or elimination of the permitted discharge. B. Pursuant to rule 3745-33-04, Ohio Administrative Code, the permittee may at any time apply to the Ohio EPA for modification of any part of this permit. The filing of a request by the permittee for a permit modification or revocation does not stay any permit condition. The application for modification should be received by the appropriate Ohio EPA district office at least ninety days before the date on which it is desired that the modification become effective. The application shall he made only on forms approved by the Ohio EPA.

000416

Part III General Conditions (Con't) 19. TRANSFER OF OWNERSHIP OR CONTROL

Page 22 3IVOOOOO*DD

This permit may be transferred or assigned and a new owner or successor can be authorized to discharge from this facility, provided the following requirements are met:
A. The permittee shall notify the succeeding owner or successor of the existence of this permit by a letter, a copy ofwhich shall be forwarded to the appropriate Ohio EPA district office. The copy of that letter will serve as the permittee's notice to the Director of the proposed ttansfer. The copy of that letter shall be received by the appropriate Ohio EPA district office sixty (60) days priorto the proposed date of transfer; B. A written agreement containing a specific date for transfer of permit responsibility and coverage between the current and new permittee (including acknowledgement that the existing permittee is liable for violations up to that date, and that the new permittee is liable for violations from that date on) shall be submitted to the appropriate Ohio EPA district office within sixty days after receipt by the district office of the copy of the letter from the permittee to the succeeding owner; At anytime during the sixty (60) day period between notification of the proposed transfer and the effective date of the transfer, the Director may prevent the ttansfer ifhe concludes that such transfer will jeopardize compliance with the terms and conditions of the pennit. If the Director does not prevent transfer, he will modify the permit to reflect the new owner. 20. OIL AND HAZARDOUS SUBSTANCE LIABILITY Nothing in this permit shall be construed to preclude the institution of any legal action or relieve the permittee from any responsibilities, liabilities, or penalties to which the permittee is or may be subject under Section 311 of the Clean Water Act. 21. SOLIDS DISPOSAL Collected screenings, slurries, sludges, and other solids shall be disposed of in such a manner as to prevent entry of those wastes into waters of the state. For publicly owned treatment works, these shall be disposed ofin accordance with the approved Ohio EPA Sludge Management Plan. 22. CONSTRUCTION AFFECTING NAVIGABLE WATERS This permit does not authorize or approve the construction of any onshore or offshore physical structures or facilities or the undertaking of any work in any navigable waters. 23. CIVIL AND CRIMINAL LIABILITY Except as exempted in the permit conditions on UNAUTHORIZED DISCHARGES or UPSETS, nothing in this permit shall be construed to relieve the permittee from civil or criminal penalties for
noncompliance.

24. STATE LAWS AND REGULATIONS Nothing in this permit shall be construed to preclude the institution of any legal action nor relieve the pennittee from any responsibilities, liabilities, or penalties established pursuant to any applicable state law or regulation under authority preserved by Section 510 of the Clean Water Act. 25. PROPERTY RIGHTS

The issuance of this permit does not convey any property rights in either real or personal property, or any exclusive privileges, nor does it authorize any injury to private property or any invasion of personal rights, nor any infringement of federal, state, or local laws or regulations.

000417

Part III General Conditions (Con't) 26. UPSET

Page 23 3IVOOOOO*DD

The provisions of 40 CFR Section 122.4I(n), relating to "Upset," are specifically incorporated herein by reference in their entirety. For definition of "upset," see Part III, Paragraph I, DEFINITIONS. 27. SEVERABILITY The provisions ofthis pennit are severable, and if any provision of this pennit, or the application of any provision of this permit to any circumstance, is held invalid, the application of such provision to other circumstances, and the remainder of this pennit, shall not be affected thereby. 28. SIGNATORY REQUIREMENTS All applications submitted to the Director shall be signed and certified in accordance with the requirements of 40 CFR 122.22. All reports submitted to the Director shall be signed and certified in accordance with the requirements of 40 CFR Section 122.22. 29. OTHER INFORMATION
A. Where the pennittee becomes aware that it failed to submit any relevant facts in a pennit application or submitted incorrect information in a permit application or in any report to the Director, it shall promptly submit such facts or infonnation.

B. ORC 6111.99 provides that any person who falsifies, tampers with, or knowingly renders inaccurate any monitoring device or method required to be maintained under this permit shall, upon conviction, be punished by a fine ofnot more than $25,000 per violation. C. ORC 6111.99 states that any person who knowingly makes any fillse statement, representation, or certification in any record or other document submitted or required to be maintained under this pennit including monitoring reports or reports of compliance or noncompliance shall, upon conviction, be punished by a fme of not more than $25,000 per violation. D. ORC 6111.99 provides that any person who violates Sections 6111.04, 6111.042, 6111.05, or division (A) of Section 6111.07 of the Revised Code shall be fined not more than $25,000 or imprisoned not more than one year, or both. 30. NEED TO HALT OR REDUCE ACTMTY 40 CFR 122.41 (c) states that it shall not be a defense for a pennittee in an enforcement action that it would have been necessary to halt or reduce the pennitted activity in order to maintain compliance with conditions of this penni!. 31. APPLICABLE FEDERAL RULES All references to 40 CFR in this pennit mean the version of 40 CFR which is effective as of the effective date of this penni!.

000418

DEPARTMENT OF PUBLIC SERVICE PUBLIC UTILITIES BUREAU
Donald l. Plusquellic Mayor

CUSTOMER INQUIRIES:
375·2554

September 18, 2001

JOSEPH P. KiDDER
Service Director

DAVID L CRANDElL, Mg,. Public Utilities Bureau (330) 375·2627 FAX: 375·2072 146 South High Street P,O, Box 3665 Akron, Ohio 44309-3665
Division Managers: MICHAEL L McGLlNCHY. P.E. ·~ties Services Manager ,.0) 375·2200 FAX: 375·2072 146 South High Street P.O, Box 3665 Akron. Ohio 44309-3665

Ohio Environmental Protection Agency Lazarus Government Center Division of Surface Water Permits Processing Unit 122 South Front Street Columbus,OH 43216 RE: Akron's Comments to Ohio EPA NPDES Permit No. 3IVOOOOO *DD Public Notice No. 01-07-019

Ohio Environmental Protection Agency Northeast District Office 2110 East Aurora Road Twinsburg, OH 44087

Rt:CF.W
SEP 1 9 2001
Ohio Environmental pro19cuon

Dear Sir or Madam:

RAY D. FLASCO. P.E. Water Supply Manager (330) 678,0077 FAX: 678·0927 1570 Ravenna Road Kent. Ohio 44240

JAMES L SIX. P.E.
Water & Sewer Systems Mgr. Water Distribution (330) 375·2580 FAX: 375·2114 565 Johnston Street Akron, Ohio 44311 Sewer Maintenance 0) 375·2585 .I: 375·2399 1055 Home Avenue Akron, Ohio 44310

TIle fullowing are the City of Akron's comments with respect to the draft National Pollutant Discharge Elimination System (NPDES) Permit dated July 12, 2001, for the Akron Water Treatment Plant located at 1570 Ravenna Road, Kent, Ohio 44240. These comments are in addition to the comments expressed in the August 22, 200 I meeting with Ohio EPA. A copy of the draft permit is attached as Attachment A. TIle July 12,2001 draft Permit was preceded by June 12, 2001 correspondence from the Ohio EPA Northeast District Office indicating the reasons for changes in the draft Pennit from the current Permit. A copy ofthe June 12, 2001 correspondence is attached as Attachment B.
Comment 1: The addition of Discharges 004 and 005 is not permitted by the Clean Water Act.

RANDAll A. MONTEiTH, P.E.
Woter Pollution Control Mgr. (330) 928·1164 FAX: 928·2285 2460 Akron-Peninsula Road Akron, Ohio 44313

The gravity flow routing device (proposed "Discharge 005") and the raw water bypass (proposed "Discharge 004") are not susceptible to NPDES permitting. As explained at the August 22, 2001 meeting with Ohio EPA, both the gravity flow routing device and the raw water bypass simply act as siphons from one side of the dam to the otber. At no point in these pipes is there an addition of pollutants. As such, neither the gravity flow routing device nor the raw water bypass constitute a discharge subject to NPDES permitting. See, e.g., National Wildlife Federation v. Gorsuch, 693 F.2d 156 (D,C. Cir, 1982) (adopting EPA's position that dams do not require NPDES permits); National Wildlife Federation v. Consumers Power Co., 862 F.2d 580 (6th CiT. 1988). Ohio EPA specifically considered and rejected a proposal to put NDPES permitting on the Rockwell Dam structures as legally untenable just two years ago. Compare the July 1999 Draft Middle Cuyahoga TMDL with the March 2000 Final Middle Cuyahoga TMDL; see also sworn

000419

Akron's Comments to Ohio EPA NPDES Permit No. 3IVOOOOO *DD Public Notice No. 01-07-019

September 18,2001 Page 2

deposition testimony of Ohio EPA personnel. Attachments C and D. Ohio EPA has provided no justification for altering its previous conclusion that the structures are not susceptible to NPDES permitting. Neither the facts nor the law allow such an interpretation. Comment 2: Alleged non-attainment "downstream" does not provide authority to regulate the gravity flow routing device and the raw water bypass in this NPDES Permit.

In addition to the lack oflegal authority, there is no factual foundation to support a requirement to regulate the gravity flow routing device and raw water bypass. The June 12, 2001 letter (Attachment B) that preceded the issuance of the draft permit cited alleged non-attainment "downstream" from Rockwell Dam as a reason for adding proposed Discharges 004 and 005 to Akron's NPDES permit. The June 12, 2001 letter states that "[t]he initial results from the 2000 Cuyahoga River Survey show the river in noncompliance with biological criteria below the Lake Rockwell dam and in compliance above the dam." Based on information provided to Akron and confirmed at the August 22 meeting, the nearest sampling point downstream to Rockwell Dam undertaken in the 2000 Cuyahoga River Survey was at River Mile 55.7. This sampling point is at Standing Rock, which is at the head ofthe Kent Dam Pool, more than two miles downstream from Rockwell Darn. The referenced sampling point is only technically "downstream" from Rockwell Dam. It is, however, a mere mile downstream from the confluence of Breakneck Creek. As the Middle Cuyahoga TMDL clearly demonstrates, impacts from Breakneck Creek, including wastewater discharges from the Franklin Hills Wastewater Treatment Plant and the Ravenna Wastewater Treatment Plant and the existence of the Kent Dam Pool have detrimental effects in the Kent Dam Pool. To ascribe non-attainment with biological criteria in the Kent Dam Pool to the existcnce ofRnckweli Dam because it is technically upstream, while at the same time ignoring the immediate effect ofthe Kent Dam and the overwhelming inpnts from Breakneck Creek, is factually inaccurate and can in no way jnstify additional NPDES conditions in the Akron permit. More importantly, Ohio EPA undertook the Middle Cnyahoga TMDL for the express purpose of bringing the Cuyahoga River"downstream" from Rockwell Dam, in particular, downstream of Breakneck Creek, into attainment with water quality standards, including biological criteria. The TMDL recommends that the Kent Darn be modified or eliminated, that the Munroe Falls Dam be modified or eliminated, that various dischargers improve their operations and restrict their addition of pollutants into the Cuyahoga River, and that Akron undertake certain actions. Akron has undertaken everything suggested of it in the TMDL and more. Singling out the Rockwell Dam as the cause for non-attainment "downstream" when the TMDL has identified other specific actions that have a more immediate affect on water quality is unjustified. The TMDL should be permitted to attain water quality standards as it was finalized and approved by US EPA.

000420

Akron's Comments to Ohio EPA NPDES Permit No. 3IVOOOOO *DD Public Notice No. 01-07-019

September 18, 2001 Page 3

Comment 3:

The definition of "receiving waters" must be changed.

As demonstrated at the August 22, 200 I meeting, Akron's 00 I and 002 outfalls discharge into the Twin Lakes Outlet, and not into the Cuyahoga River. These two discharges of high quality water make up the overwhelming majority of Akron's discharges under the NPDES Permit. Akron's small sanitary package plant (Discharge 003) is the plant's only discharge into the Cuyahoga River. As reflected in the draft Permit, Akron has committed to eliminating the 003 discharge. Therefore, the definition of "receiving waters" in the Permit should be changed to "Twin Lakes Outlet and the Cuyahoga River" on an interim basis. Once the 003 discharge is eliminated, the receiving waters should be listed solely as "Twin Lakes Outlet." Comment 4: The Middle Cuyahoga TMDL does not provide authority to institute stricter discharge levels on the 003 discharge.

The Middle Cuyahoga TMDL was approved by US EPA for "monitoring only" for the segment from Rockwell Dam down to Breakneck Creek. As a matter oflaw, the TMDL's incorporation into the state water quality standards cannot form a basis for imposing the stricter discharge limits in the proposed final permit on the 003 discharge. Nonetheless, Akron is committed to undertaking Ohio EPA's suggestion and eliminating the 003 discharge, in compliance with the aggressive construction schedule set forth in the draft Permit. Akron also continues to request Ohio EPA's assistance in developing a proper sampling protocol for the interim permit period given the unique features of this discharge. Comment 5: Monitoring requirements should be changed to properly reflect actual discharges.

As noted above in Comment 3, Akron's 00 I and 002 discharges are into the Twin Lakes Outlet, and not into the Cuyahoga River. The only discharge into the Cuyahoga is the miniscule 003 discharge, for which Akron is committed to eliminate as expeditiously as practicable but no later than the end of the 36 months of the interim limits. The current and proposed in-stream monitoring requirements are at Route 303 (location 80 I), seven miles upstream of the water plant, and on ti,e Cuyahoga River upstream from the confluence of the Twin Lakes Outlet (location 901). The requirement to monitor at Station 801 at Route 303 is not reflective of any water related to Akron's discharges under this NPDES Permit and should be eliminated. (The NPDES Permit for the Shalersville Water Plant, Ohio EPA Permit No. 3PH00037*GD, includes a condition to undertake downstream sampling at a very similar point.) Akron's NPDES monitoring conditions should be altered to accurately monitor Akron's discharges and not for any unrelated pnrposes. These monitoring requirements are not rationally related to the discharges from the plant, and should be changed. A more accurate monitoring system would provide "upstream" water quality being monitored in the Twin Lakes Outlet upstream from the 00 I and 002 discharges and "downstream" monitoring should be in the

000421

Akron's Comments to Ohio EPA NPDES Pennit No. 3IVOOOOO "DD Public Notice No. 01-07-019

September 18, 200 I Page 4

Twin Lakes Outlet downstream tiom the 00 I and 002 discharges. For the limited time that the 003 diseharge operates, "upstream" and "downstream" should b~ located so as to monitor the impaet of this small discharge. Once the 003 diseharge is eliminated, the Cuyahoga monitoling conditions (inelnding that at location 901) should also be eliminated.

Comment 6:

The requ;"ement to mtlnito.· for trihalomethanes for 001 and 002 discharge should be eliminated.

Monitoring for trihalomethanes ("THM's") in the sludge lagoon discharge is an unnecessary monitoring requirement and we request that monitoring the lagoon dIscharges 00 I and 002 for THMs be eliminated from the pennit. We are not aware oftriha!omethane limits for diseharges to surfaGe waters or what negative effect THMs have on the environment. The last twelve (12) monthly THM results at the Akron Water Plant lagoon discharges 001 and 002 have averaged only 4.07 micrograms per liter. This is 0.00407 milligrams per liter, an environmentally insignificant amount. These near zero results are expected from 001 and 002 because there is no normal source for THMs in this lagoon water. Trihalomethanes fonn when chlorine is mixed with water containing organic molecules such as humic and fulvic acids. The Akron Water Plant does not normally feed chlorine prior to its final chemical addition in the High Service Pump Station. The water that goes to the lagoons is mostly backwash water taken from a holding tank below the filters. This holding tank is ahead of the elearwell and the pump station and plior to any chlorine addition. The Akron Water Plant uses chlorine dioxi.de and potassium pennanganate instead of chlorine as a pre-oxidant. Chlorine dioxide and potassium pennanganate do not create trihalomethancs, which is the principal reason they are used at the Water Plant. Since the -.beginning of this year the Water Plant has switched to a new replacement high efficiency cblorine dioxide generator that produces minimal amonnts of free chlorine. As stated in our August 22, 200 I meeting, since August 2000, the high solid laden coagulationsedimentation sludge has been pumped directly to the upper freeze dry lagoons that have no discharge to a receiving stream. Even iftrihalomethanes were created, THMs are somewhat volatile and a large percentage would dissipate into the air. The lagoons for the discharges 001 and 002 are conducive to releasing volatile chemicals to the atmosphere because they have a large surface area of about 6.6 acres each and have about I to 3 feet offree water above the settled sludge. Even iftrihalomethanes would reach the discharge points of the lagoons, the water is ~,aseaded over rocks th2t furtller aerate the flow before it reaches the Twin Lakes Outlet. Comment 7: The limit en flow through the 001 and 002 discharges should be increased to 2 mgd.

The discharge from these lagoons is very high quality water from the filter backwash. On occasion, the volume on a given day can increase above the 0 6 mgd limit currently in this draft pemlit. A 2.0 mgd flow limit will allow for these occasions. Discharges from 00 I and 002 seldom occur at the same time.

000422

Akron's Comments to Ohio EPA NPDES Permit No. 3IVOOOOO *DD Public Notice No. 01-07-019

September 18, 2001 Page 5

The high quality of the water will not decrease, but will enhance the water quality ofthe receiving waters in Twin Lakes Outlet. Akron appreciates the opportunity to make these comments. Very truly yours,

~~~
Public Utilities Bureau Attachments cc: Joseph P. Kidder George A. Bozeka Cheri Cunningham Louis L. McMahon Ray D. Fiasco

• Complete items 1, 2, and 3. Also complete item 4 it Restricted Oeliv8(y is desired.
Print your name and address on the reverse so that we can return the card to you. R Attach this card to the back of the mailpiece, or on the front if space permits.
1.

•

c.

x
D.

o Agent
P
Addressee
No

"-"='" Article Addressed to: NPDES 3IVOOOOO . 8 :.8: 01 (Comments) Mr. David Crandell. Publlc Utilities Bureau Ci ty of Akron 65 South High Street Akron. Ohio 44308
r;..

DYes

o

o Certified Mail o Express Mail f o Registered o Return Receipt for Merchandi t8
o
Insured Mail

o

C.O.D.

~

4. Restricted Delivery? (Extra Fee)

0 Yes

~

7001 0360 0000 6380 1566
Domestic Return Receipt

PS Form 3811, July 1999

1025gS-00-M-0952

Louis.McMahon@ThompsonHine.com Fax216..566..5800 Phone 216..566..5639

10108900.\

000423

ATTACHMENT A

000424

Page I 3IVOOOOO'DD

Application No. OH0000612 Issue Date: Effective Date: Expiration Date: 5 Years Ohio Environmental Protection Agency Authorization to Discharge Under the National Pollutant Discharge Elimination System

In compliance with the provisions of the Federal Water Pollution Control Act, as amended (33 U.S.C. 1251 et. seq., hereinafter referred to as the "Act"), and the Ohio Water Pollution Control Act (Ohio Revised Code Section 6111), .
The City of Akron Water Treatment Plant is authorized by the Ohio Environmental Protection Agency, hereinafter referred to as "Ohio EPA," to discharge from the waste water treatment works located at 1570 Ravenna Road, Kent, Ohio, Portage County and discharging to the Cuyahoga River in accordance with the conditions specified in Parts I, II, and ill of this permit. This permit is conditioned upon payment of applicable fees as required by Section 3745.11 of the Ohio Revised Code. This permit and the authorization to discharge shall expire at midnight on the expiration date shown above. In order to receive authorization to discharge beyond the above date of expiration, the permittee shall submit such information and forms as are required by the Ohio EPA no later than 180 days prior to the above date of expiration.

.-

Christopher Jones Director Total Pages: 26

000425

Page 2 3IVOOOOO"DD

Part I, A. - FINAL EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS 1. During the period beginning 37 months following permit issuance and lasting until the expiration date, the permittee is authorized to discharge in accordance with the following limitations and monitoring requirements from outfall 3IV00000003. See Part II, OTHER REQUIREMENTS, for locations of effluent sampling. Table - Final outfall - 003 - Final

lill!JImI Characteristic
Parameter 00010 - Water Temperature· C 00056 • Flow RNote - GPD 00083 • Color, severity· Units 00300 • Dissolved Oxygen· mgll 00400 - pH - S.U. 00530 • Total sespended Solids· rngll 00610. Nitroges. Ammonia (NIl3) - mgll 01330 - Odor, Severity· Units 01350. Turbidil¥. Severity· Units 31616 • Fecal Qliform - #/100 ml 50060. Chlorilll; Total Residual. mgll 80082 . CBOD 5 day - mgll 2000 0.038 12 9.0 12 6.5

Discharge Limitations Concentration Specified Units MaximumMinimum Weekly Monthly Loading" kg/day Daily Weekly Monthly Measuring Frequency I/Week llOay llOay I/Week I/Month

Monitoring Requirements Sampling Type Grab 24hrTotai Estimate Grab Grab Grab Gmb Estimate Estimate Grab Monitoring Months

All All
All

All All All All All All
Summer Summer All

8
1.0

0.18 0.023

0.12 0.015

I/Month I/Month llOay llOay

1.5

1000 0.006

I/Month

1/2 Weeks Gl'llb 0.12 I/Month Gl'llb

8

0.18

Notes for Stalion Number 3IV00000003: • Effluent loliliings based on average design flow of 0.004 MGD. _Sampling shtll be performed when discharging. IfNO DISCHARGE OCCURS DURING THE ENTIRE MONTH, report "AL" in the fIrst column of the fll'St day of the month on the 4500 Form (Monthly Operating Report). A signature is still required. . See Part II, llem G. _Color, Odor:md Turbidity - See Part II, Item E.
000426

Page 3 3IVOOOOO'DD

Part I, A. _FINAL EFFLUENT LIMITATIONS AND MONITORlNG REQUIREMENTS

1. During the period beginning on the effective date of this permit and lasting until the expiration date, the permittee is authorized to discharge
in accordance with the following limitations and monitoring requirements from outfaIl3IV00000004. See Part II, OTHER REQUIREMENTS, for locations of effluent sampling.
Table - Final Outfall- 004 - Final
lill1Jl!'nt Chafacteristic Parameter 50050 - Flow Rate - MOD Discharge Limitations Concentration Specified Units Maximum Minimum Weekly Monthly Loading' kg/day Daily Weekly Monthly Measuring Frequency IlDay Monitoring Re'lJ!irements Sampling Type Monitoring Months

24hr Total Estimate AIl

Notes for Station Number 3IVOOO00004: Sampling shall be performed when discharging. If NO DISCHARGE OCCURS DURING THE ENTIRE MONTllI:, report "AL" in the fIrst column of the first day of the month on the 4500 Form (Monthly Operating Report). A signature is still required. See Part II, Item G.

000427

Page 4 31V00000'DD Part I, A. • fINAL EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS 1. During the period beginning on the effective date of this permit and lasting until the expiration date, tl1e permittee is authorized to discharge in accordance with the following limitations and monitoring requirements from outfall 3IVOOOOOO05. See Part II, OTHER REQUIREMENTS, for locations ofeffiuent sampling. Table _Fillll.l Outfall - 005 - Final :sIDuent Cbaracteristic Parameter 00010 _Water Temperature - C 00300 _Dissolved Oxygen - mgll 00530 _Total suspended Solids - mgll 00610 _Nill0gen, Ammonia (NH3) - mgll 00665 _Pbosphoros, Total (P) - mgll 00945 • Sulrtle. (504) - mg/I 01055 _M.....nese, Total (Mn) - ugll 50050 • Flo... Rale - MOD 80082 _CBOI) 5day· mgll Notes for~on Number 3IVOOOOOO05: Sampling shall be performed when discharging. IfNO DISCHARGE OCCURS DURING THE ENTIRE MONTH, report "AL" in the fIrst column oflhc fIrSt day of the month on the 4500 Form (Monthly Operating Report). A signature is still required.
See Part II, Item G.

Djscbarge Limitations Concenlmtion Specified Units Loading" kg/day Maximum Minimum Weekly Monthly Daily Weekly Monthly

Monitoring Requirements Measuring Sampling Monitoring Frequency Type Months IlMonth IfWeek IlMonth IlMonth IlMonth IlMonth IlMonth IlDay IlMonth
Grab Grab Grab Grab Grab Grab drab
All

-

-

-

. -

-

-

-

-

-

-

All All All
All

-

-

-

.
.

-

-

. -

-

-

All

.

-

-

.

All All

24br Total Estimate All
Grab

-

-

-

000428

Page 5 3IVOOOOO"DD

Part I, A. - FINAL EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS

1. During the period beginning on the effective date of this permit and lasting until the expiration date, the permittee is authorized to discharge in accordance with the following limitations and monitoring requirements from outfall 3IVOOOOOOOl. See Part II, OTHER REQUIREMENTS, for locations of effluent sampling.
Table - Final autfall- 001 - Final
EmuMt Characteristic Parameter 00400 - pH - S.U. 00530 - Total suspended Solids - mg/l 50050 - Flow Rate - MGD 82080 - Trihalomethane, Total - ug/l Discharge Limitations Concentration Specified Units MaximumMinimum Weekly Monthly Loading" kg/day Daily Weekly Monthty Measuring Frequency 1/2 Weeks Grab 30 102 Morliloring Requirements Sampling Type Morlitoring Months All All

9.0
45

6.5

68

I / 2 Weeks Composite
I /2 Weeks 24hr Total IIMonth Grab

All
All

Notes for Station Number 3IVOOOOOO01:

* Effluent loadings based on average design flow of 0.6 MGD. Sampling shall be performed when discharging. If NO DISCHARGE OCCURS DURING THE ENTIRE MONTH, report "AL" in the fIrst colunm of the first day of the month on the 4500 Form (Monthly Operating Report). A signature is still required.
See Part II, Item G.

000429

Page 6 3IVOOOOO'DD

Part I, A. - FINAL EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS

I. During the period beginning on the effective date of this permit and lasting until the expiration date, the permittee is authorized to discharge in accordance with the following limitations and monitoring requirements from outfall 3IVOOOOOO02. See Part II, OTHER . REQUIREMENTS, for locations of effluent sampling.

Table. Final Outfall - 002 - Final
Effluent Characteristic Parameter 00400. pH - S.U. 00530 - Total Suspended Solids - mg/l 50050. Flow Rate· MGD 82080. Trihalometbane, Total - ug/l Discharge Limitations Concentration Specified Units Maximum Minimum Weekly Monthly 9.0 Loading' kg/day Daily Weekly Monthly Measuring Frequency 1/2 Weeks Gtab 30 102 Monitoring Requirements Sampling Type Monitoring Months

6.5

All All All All

45

68

1 / 2 Weeks Composite 1/2 Weeks 24hr Total IlMontb Grab

Notes for Station Number 3IV00000002: '" Effluent loadings based on average design flow of 0.6 MGD. Sampling shall be performed when discharging. If NO DISCHARGE OCCURS DURING THE ENTIRE MONTH, report "AL" in the fIrst column of the fIrst day of the month on the 4500 Form (Monthly Operating Report). A signature is still required. See Part II, Item G.

000430

Page 7 3IVOOOOO'DD

Part I, A. - INTERIM EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS I. During the period beginning on the effective date of this permit and lasting until 36 months following the permit issuance, the permittee is authorized to discharge in accordance with the following limitations and monitoring requirements from outfa1l3NOOOO0003. See Part II, OTHER REQUIREMENTS, for locations of effluent sampling. Table - Final Outfall - 003 - Interim
.lill!yent Characteristic Parameter 000 10 - Water Temperature - C 00056 - Flow Rate - GPD 00083 - Color, Severity - Units 00300 - Dissolved Oxygen - mgll 00400 - pH - S.U. 00530 - Total Suspended Solids - mgll 00610 - Nitrogen. Ammonia (NH3) - mgll 01330 - Odor. Severity - Units 01350 - Turbidity, Severity - Units 31616 _ Fecal Colifonn - #/1 00 ml 50060 - Chlorine, Total Residual - mg/I 80082 _CBOD 5 day - mgll 2000 0.038 15 10 1000 0.006 0.23 0.15 18 12 0.27 0.18 Discharge LjrnjtatioDl! Concentration Specified Units MaximumMinimum Weekly Monthly Loading' kg/day Daily Weekly Monthly Measuring Frequency I/Week IlDay IlDay IfWeek l/Month I/Month I/Month IlDay IlDay I/Month Grab 24hr Total Estimate Grab Grab Grab Grab £Stirnate estimate Grab Monitoring Requirements Sampling Type Monitoring Months

All All
All

All All All All
All

All
Summer

1/2 Weeks Grab l/Month Grab

Summer

All

Notes for Station Number 3IV00000003: • Effluent loadings based on average design flow of 0.004 MGD. _Sampling shall be performed when discharging. If NO DISCHARGE OCCURS DURING THE ENTIRE MONtH, report "AL" in the ftrst column of the first day of the month on the 4500 Form (Monthly Operating Report). A signature is stiU required. _See Part II, Hem G. _Color, Odor and Turbidity - See Part II, Item E.
000431

Page 8 3IVOOOOO·DD

Part I, B. - SLUDGE MONITORING REQillREMENTS

1. Sludge Monitoring. During the period beginning on the effective date of this permit and lasting until the expiration date, the permittee shall monitor the treatment works' final sludge at Station Number 3IVOO000588, and report to the Ohio EPA in accordance with the following table. See Part II, OTHER REQillREMENTS, for location of sludge sampling.

rable - Sludge Monitoring - 588 - Final
EfflUent Cha~acteristic Plrmneter Discharge Limitations Loading· kg/day Concentration Specified Units Weekly Monthly Maximum Minimum Weekly Monthly Daily Monitoring Requirements Measuring Frequency l/Month l/Month Total Grab Sampling Type Monitoring Months All

70316 - Sludge weight - Dry Tons

70318 - Sludge Solids. Percent Total - %

All

NOTES for Station Number 3IV00000588:

• Monitoring is required when sludge is removed from the wastewater treatment facility and disposed of at another wastewter treatment plant. [fno sludge is removed during the entire month, report "AL" in the first column of the first day of the month on the 4500 Form (Monthly Dperating Report). A signature is still required.

... Units of mgIlcg are on a dry weight basis.

..... Sludge weight is a calculated total for the sampling period.

000432

Page 9 3lVOOOOO'DD

Part I, B. - DoWNSTREAM-FARFIELD MONITORING REQUIREMENTS

1. Downstream·Farfield Monitoring. During the period beginning on the effective date of this permit and lasting until the expiration date, the
permittee shall monitor the receiving stream, downstream of the point of discharge, at Station Number 3IV0000090l, and report to the Ohio EPA in accordance with the following table. See Part II, OTHER REQUIREMENTS, for location of sampling. Table - Downstream-Farfield Monitoring - 901 - Final
pflluenl Glmracteristic !'ammeter 00010 - Water Telllperature - C 00010 - Water Temperature - C 00300 - Dissolved Oxygen - mgIJ 00300 - Dissolved Oxygen - mgIJ 00900 - Hardness, Total (CaC03) - mgIJ 01042 - Copper, Total (Cu) - ugIJ Discharge Limitations Concentration Specified Units Maximum Minimum Weekly Monthly Loading' kg/day Daily Weekly Monthly Measuring Frequency IlMonth llWeek llWeek IlMonth IlMonth IlMonth Grab Grab Grab Gmb Grab Grab Monitoring Reouirements Sampling Type Monitoring Months Winter Summer Summer Winter

All All

000433

Page 10 3IVOOOOO"DD

Part I, B. - UPSTREAM MONITORING REQUIREMENTS 1. Upstream Monitoring. During the period beginning on the effective date of this permit and lasting until the expiration date, the permittee shall monitor the receiving stream, upstream of the point of discharge at Station Number 3IV00000801, and report to the Ohio EPA in accordance with the following table. See Part II, OTHER REQUIREMENTS, for location of sampling. Table - Upstream Monitoring - 801 -.Final
Emuent Characteristic parameter 00900 - Hardness, Total (CaC03) - mgII 01042 - Copper, Total (Cu) - ugII Discharge Limitations Concentration Specified Units MaximumMinimum Weekly Monthly Loading" kg/day Daily Weekly Monthly Measuring Frequency IlMonth IlMonth Grab Grab Monitoring Requirements Sampling Type Monitoring Months

All
All

000434

Page II 3IVOOOOO·DD

Part 1. C. - SCHEDULE OFCOMPLIANCE Industrial Construction Schedule 1. The pennittee shall achieve compliance with the fmal effluent limitations for outfall 3lVOOOOOO03 as specified in Part IA. of this NPDES pennit as expeditiously as practicable. In any event, the pennittee shall attain final compliance not later than the dates developed in accordance with the following schedule: a. The pennittee shall submit to the appropriate Ohio EPA district office a complete and approvable PTI application and detailed plans for achieving fmal compliance for outfall 3IV00000003 as soon as possible, but not later than 18 months following permit issuance. (Event Code 01299) b. The permittee shall have completed construction as soon as possible, but not later than 24 months following pennit issuance. (Event Code 04599) c. The permittee shall have attained full compliance with the fmal effluent limitations for outfall 3lV00000003 as soon as possible, but not later than 36 months following permit issuance. (Event Code 05599)

000435

Page 12

3IVOOOOO·DD

Part II, OTHER REQUIREMENTS A. Description of the location of the required sampling stations are as follows: Sampling Station Description of Location

3IVOOOOOOO1 31V00000002 3IVOOO00003

3IVOOOO0004

,3IVOOOOO005 3IV00000588 3IVOOOO0801

3IVOOOO0901

Discharge from lower west lagoon (Lat: 41 N 11 '00"; Long: 81 W 20 '05") Discharge from lower east lagoon (Lat: 41 N 11 '00"; Long: 81 W 20 '05") Discharge from sanitary package plant prior to entering the Cuyahoga River (Lat: 41 N 10' 48 "; Long: 81 W 20 '07") Discharge from 12 inch line entering Cuyahoga River on east bank (water used to meet ODNR contract obligations for diversion) (Lat: 41 N 10' 54 "; Long: 81 W 19 ' 57 ") Discharge from gravity flow routing system (Lat: 41 N 10' 57 "; Long: 81 W 19 '52 ") Sludge monitoring station for sludge removed from sanitary package plant. Sample of Cuyahoga River upstream of Lake Rockwell at State Route 303 (Lat: 41 N 14' 18 "; Long: 81 W 18 '13 ") Downstream of Lake Rockwell at the west bank of the Cuyahoga River upstream of the Twin Lakes Tributary (Lat: 41 N 10' 52 "; Long: 81 W 20 '07 ")

B. This permit shall be modified, or alternatively, revoked and reissued, to comply with any applicable effluent standard or limitation issued or approved under Sections 301(b)(2)(C) and (D), 304(b)(2), and 307(a)(2) of the Clean Water Act, if the effiuent standard or limitation so issued or approved. I. Contains different conditions or is otherwise more stringent than any effluent limitation in the permit; or 2. Controls any pollutant not limited in the permit. The permit as modified or reissued under this paragraph shall also contain any other requirements of the Act then applicable.

C. All parameters, except flow, need not be monitored on days when the plant is not normally staffed (Saturdays, Sundays, and Holidays). On those days, report "AN" on the monthly report form.

000436

Page 13 3IVOOOOO*DD

D. Pennit limitations may be revised in order to meet water quality standards after a stream use determination and waste load allocation are completed and approved. This permit may be modified, or alternatively, revoked and reissued, to comply with any applicable water quality effluent limitations. E. If Severity Units are required for Turbidity, Odor, or Color, use the following table to determine the value between 0 and 4 that is reported. REPORTED VALUEO' SEVERITY DESCRIPTION

TURBIDITY

ODOR

COLOR

0 1 2 3 4

None. Mild Moderate Serious Extreme

Clear Light Solids Heavy Solids

None Musty Septic

Colorless Grey Black

*

Interpolate between the descriptive phrases.

F. Grab samples shall be collected at such times and locations, and in such fashion, as to be representative of the facility's performance. G. Effluent disinfection is not directly required, however, the entity is required to meet all applicable discharge permit limits. If disinfection facilities exist, they shall be maintained in an operable condition. Any design of wastewater treatment facilities should provide for the capability to install disinfection if required at a future time. Disinfection may be required if future bacteriological studies or emergency conditions indicate the need. H. Final permit limitations based on preliminary or approved waste load allocations are subject to change based on modifications to or fmalization of the allocation or report or changes to Water Quality Standards. Monitoring requirements and/or special conditions of this permit are subject to change based on regulatory or policy changes.

1. Within 4 months of the effective date of this Permit, the permittee shall submit to the appropriate Ohio EPA District Office an evaluation of its sludge management plan, which was approved on October 16,1995.
This evaluation shall examine the adequacy of the plan, including any implementation problems encountered and any changes required, and is to reflect the actual sludge disposal practices. If significant changes are required, the permittee may be required to submit for approval a modified sludge management plan.

000437

Page 14 3IVOOOOO·DD

J. Not later than January 31 of each calendar year, the permittee shall submit two (2) copies of a report summarizing the sludge disposal and/or reuse activities of the facility during the previous year. One copy of the report shall be sent to the Ohio EPA, Division of Surface Water, Central Office, and one copy of the report shall be sent to the appropriate Ohio EPA District Office. This report shall address: 1) Amount of sludge disposed oflreused in dry tons. 2) Method(s) of disposal/reuse. 3) Summary of all analyses made on the sludge, including any priority pollutant scans that may have been performed. (If a priority pollutant scan has been conducted as a part of the pretreatment program, the most recent analysis should be submitted.) 4) Problems encountered including any complaints received. The cause or rea,son for the problem and corrective actions taken to solve the problem should also be included. Any incidents of interference with the method of sludge disposal shall be identified, along with the clluse of interference (Le., excessive metals concentration, contaminated sludge, etc.) and the corrective actions taken.

000438

Page 15 3IVOOOOO'DD PART III - GENERAL CONDITIONS I. ,DEFINITIONS "Daily load" is the total discharge by weight during any calendar day. Ifonly one sample is taken during a day, the weight of pollutant discharge calculated from it is the daily load. "Daily concentration" means the arithmetic average of all the determinations of concentration made during the day. If only one sample is taken during the day, its concentration is the daily concentration. Coliform bacteria limitations compliance shall be determined using the geometric mean. "Weekly load" is the total discharge by weight during any 7-day period divided by the number of days in that 7-day period that the facility was in operation. If only one sample is taken in a 7-day period, the weight of pollutant discharge calculated from it is the 7-day load. If more than one sample is taken during the 7-day period, the 7-day load is calculated by determining the daily load for each day sampled, t<>talir.g the daily loads for the 7'day period, and dividing by the number of days sampled. "Weekly concentration" means the arithmetic average of all the determinations of daily concentration limitation made during the 7-day period. If only one sample is taken during the 7-day period, its concentration is the 7-day concentration for that7-day period. Coliform bacteria limitations compliance shall be determined using the geometric mean. "Monthly load" is the total discharge by weight during all days in a calander month divided by the number of days that the facility was in operation during that month. If only one sample is taken during the month the weight of pollutant discharge calculated from it is the monthly load. If more than one sample is taken during the month, the monthly load is calculated by determining the daily load for each day sampled, totaling the daily loads for the month and dividing by the number of days sampled. "Monthly concentration" means the arithmetic average of all the determinations of daily concentration made during any calender month. If only one sample is taken during the month, its concentration is the monthly concentration for that period. Coliform bacteria limitations compliance shall be determined using the geometric mean. "85 percent removal" means the arithmetic mean of the values for effiuent samples collected in a period of30 consecutive days shall not exceed 15 percent of the arithmetic mean of the values for influent samples collected at approximately the same times during the same period. "Absolute Limitations" Compliance with limitations having descriptions of "shall not be less than," "nor greater than," "shall not exceed," "minimum," or "maximum" shall be determined from any single value for effiuent samples and/or measurements collected. "Net concentration" shall mean the difference between the concentration of a given substance in a sample taken of the discharge and the concentration of the same substances in a sample taken at the intake which supplies water to the given process. For the purpose of this defInition, samples that are taken to determine the net concentration shall always be 24-hour composite samples made up of at least six increments taken at regular intervals throughout the plant day.

000439

Part III General Conditions (Con't)

Page 16 3NOOOOO"DD

"Net load" shall mean the difference between the load of a given substance as calculated from a sample taken of the discharge and the load of the same substance in a sample taken at the intake which supplies water to given process. For purposes of this defInition, samples that are taken to determine the net Loading shall always be 24-hour composite samples made up of at least six increments taken at regular intervals throughout the plant day. "MGD" means million gallons per day. "mgll" means milligrams per liter.

"ug/1" means micrograms per liter.
"Reporting Code" is a fIve digit number used by the Ohio EPA in processing reported data. The reporting code does not imply the type of analysis used nor the sampling techniques employed. "Quarterly (l/Quarter) sampling frequency" means the sampling shall be done in the months of Mareh, June, August, and December, unless specificially identifIed otherwise in the Effluent Limitations and Monitoring ReqUirements table. "Yearly (1IYear) sampling frequency" means the sampling shall be done in the month of September, unless specificially identified otherwise in the effluent limitations and monitoring requirements table. "Semi-annual (2IYear) sampling frequency" means the sampling shall be done during the months of June and December, unless specifIcially identified otherwise. "Winter" shall be considered to be the period from November I through April 30. "Bypass" means the intentional diversion of waste streams from any portion of the treatment facility. "Summer" shall be considered to be the period from May I through October 31. "Severe property damage" means substantial physical damage to property, damage to the treatment facilities which would cause them to become inoperable, or substantial and permanent loss of natural resources which can reasonably be expected to occur in the absence of a bypass. Severe property damage does not mean economic loss caused by delays in production. "Upset" means an exceptional incident in which there is unintentional and temporary noncompliance with technology based permit effluent limitations because offactors beyond the reasonable control of the permittee. An upset does not include noncompliance to the extent caused by operational error, improperly designed treatment facilities, inadequate treatment facilities, lack of preventive maintenance, or careless or improper operation.

000440

Part III General Conditions (Con't) 2. GENERAL EFFLUENT LIMITATIONS The effluent shall, at all times, be free of substances:

Page 17 3IVOOOOO·DD

A. In amounts that will settle to form putrescent, or otherwise objectionable, sludge deposits; or that will adversely affect aquatic life or water fowl;

B. Of an oily, greasy, or surface-active nature, and of other floating debris, in amounts that will form

noticeable accumulations of scum, foam or sheen;
C. In amounts that will alter the natural color or odor of the receiving water to such degree as to create a

nuisance;
D. In amounts that either singly or in combination with other substances are toxic to human, animal, or aquatic life; E. In amounts that are conducive to the growth of aquatic weeds or algae to the extent that such growths become inimical to more desirable forms of aquatic life, or create conditions that are unsightly, or constitute a nuisance in any other fashion; F. In amounts that will impair designated instream or downstream water uses. 3. FACILITY OPERATION AND QUALITY CONTROL All wastewater treatment works shall be operated in a manner consistent with the following: A. At all times, the permittee shall maintain in good working order and operate as efficiently as possible all treatment or control facilities or systems installed or used by the permittee uecessary to achieve compliance with the terms and conditions of this permit Proper operation and maintenance also includes adequate laboratory controls and appropriate quality assurance procedures. This provision requires the operation of back-up or allXiliary facilities or similar systems which are installed by a permittee only when the operation is necessary to achieve compliance with conditions of the permit

B. The permittee shall effectively monitor the operation and effiCiency of treatment and control facilities and the quantity and quality of the treated discharge.
C. Maintenance of wastewater treatment works that results in degradation of effluent quality shall be scheduled during non-critical water quality periods and shall be carried out in a manner approved by Ohio EPA as specified in the Paragraph in the PART III entitled, "UNAUTHORIZED DISCHARGES", 4. REPORTING A. Monitoring data required by this permit may be submitted in hardcopy format on the Ohio EPA 4500 report form pre-printed by Ohio EPA or an approved facsimile. Ohio EPA 4500 report forms for each individual sampling station are to be received no later than the 15th day of the month following the month-of-interest The original report form must be signed and mailed to: Ohio Environmental Protection Agency Lazarus Government Center Division of Snrface Water Enforcement Section ESIMOR P.O, Box 1049 Columbus, Ohio 43216-0149

000441

Part III General Conditions (Con't)

Page 18 3IVOOOOO*DD

Monitoring data may also be submitted electronically using Ohio EPA developed SWlMware software. Data must be transmitted to Ohio EPA via electronic mail or the bulletin board system by the 20th day of the month following the month-of-interest. A Surface Water Information Management System (SWIMS) Memorandum of Agreement (MOA) must be signed by the responsible official and submitted to Ohio EPA to receive an authorized Personal Identification Number (PIN) prior to sending data electronically. A hardcopy of the Ohio EPA 4500 form must be generated via SWlMware, signed and maintained omite for records retention purposes. B. If the permittee monitors any pollutant at the location(s) designated herein more frequently than required by this permit, using approved analytical methods as specified below, the results of such monitoring shall be included in the calculation and reporting of the values required in the reports specified above. C. Analyses of pollutants not required by this permit, except as noted in the preceding pwJlgnlph, shall not be reported on Ohio EPA report form (4500) but records shall be retained as specified in the paragraph entitled "RECORDS RETENTION". 5. SAMPLING AND ANALYTICAL METHOD Samples and measurements taken as required herein shall be representative of the volume and nature monitored.f1ow. Test procedures for the analysis of pollutants shall conform to regulation 40 CFR 136, "Test Procedures For The Analysis of Pollutants" unless other test procedures have been specified in this permit. The permittee shall periodically calibrate and perform maintenance procedures on all monitoring and instrumentation at intervals to insure accuracy of measurements. 6. RECORDING OF RESULTS For each measurement or sample taken pursuant to the requirements of this permit, the permittee shall record the following information: A. The exact place and date of sampling; (time of sampling not required on EPA 4500)

B. The person(s) who performed the sampling or measurements;
C. The date the analyses were performed on those samples; D. The person(s) who performed the analyses; E. The analytical teChniques or methods used; and F. The results of all analyses and measurements.

000442

Part III General Conditions (Con't) 7. RECORDS RETENTION

Page 19 31V00000'DD

The permittee shall retain all of the following records for the wastewater treatment works for a minimum of three years, including: A. All sampling and analytical records (including internal sampling data not reported); B. All original recordings for any continuous monitoring instrumentation; C. All instmmentation, calibration and maintenance records; D. All plant operation and maintenance records; E. All reports required by this permit; and F. Records of all data used to complete the application for this permit for a period of at least three years from the date of the sample, measurement, report, or application. These periods will be extended during the course of any unresolved litigation, or when requested by the Regional Administrator or the Ohio EPA. The three year period for retention of records shall start from the date ofsample, measurement, report, or application. . 8. AVAILABILITY OF REPORTS Except for data determined by the Ohio EPA to be entitled to confidential statos, all reports prepared in accordance with the terms of this permit shall be available for public inspection at the appropriate district offices of the Ohio EPA. Both the Clean Water Act and Section 611 1.05 Ohio Revised Code state that effiuent data and receiving water quality data shall not be considered confidential. 9. DUfY TO PROVIDE INFORMATION The permittee shall furnish to the Director, within a reasonable time, any information which the Director may request to >letermine whether cause exists for modifying, revoking, and reissuing, or terminating the permit, or to determine compliance with this permit. The permittee shall also furnish to the Director, upon request, copies ofrecords required to be kept by this permit. 10. RlGHT OF ENTRY The permittee shall allow the Director or an authorized representative upon presentation of credentials and other documents as may be required by law to: A. Enter upon the permittee's premises where a regulated facility or activity is located or conducted, or where records must be kept under the conditions of this permit. B. Have access to and copy, at reasonable times, any records that must be kept under the conditions of the permit. C. Inspect at reasonable times any facilities, equipment (including mOnitoring and control equipment), pracHces, or operations regulated or required under this permit. D. Sample or monitor at reasonable times, for the purposes of assuring permit compliance or as otherwise authorized by the Clean Water Act, any substances or parameters at any location.

000443

Part II! General Conditions (Con't) II. UNAUTHORIZED DISCHARGES A. Bypassing or diverting of wastewater from the treatment works is prohibited unless:

Page 20 3IVOOOOO"DD

1. Bypass was unavoidable to prevent loss of life, personal injury, or severe prqperty damage;
2. There were no feasible alternatives to the bypass, such as the use of auxiliary treatment facilities, retention of untreated wastes, or maintenance during normal periods of downtime. This condition is not satisfied if adequate back up equipment should have been installed in the exercise of reasonable engineering judgment to prevent a bypass which occurred during normal periods of equipment downtime or preventive maintenance; and 3. The petmittee submitted notices as required under paragraph D. of this section,

B. If the permittee knows in ·advance of the need for a bypass, it shall submit prior notice, if possible at least ten days before the date of the bypass.
C. The Director may approve an unanticipated bypass after considering its adverse effects, if the Director determines that it has met the three conditions listed in paragraph II.A. of this section. D. The permittee shall submit notice of an unanticipated bypass as required in section 12. A. E. The permittee may allow any bypass to occur which does not cause emuent limitations to be exceeded if that bypass is for essential maintenance to assure efficient operation.

000444

Part IT! General Conditions (Con't) 12. NONCOMPLIANCE NOTIFICATION

Page 21 3IVOOOOO'DD

A. The permittee shall by telephone report any of the following within twenty-four (24) hours of discovery at (toll free) 1-800-282-9378: 1. Any noncompliance which may endanger health or the environment; 2. Any unanticipated bypass which exceeds any effluent limitation in the permit; or 3. Any upset which exceeds any effluent limitation in the permit. 4. Any violation of a maximum daily discharge limitation for any of the pollutants listed by the Director in the permit. B. For the telephone reports required by Part 1;2.A., the following information must be included: I. The times at which the discharge occurred, and was discovered; 2. The approximate amount and the characteristics of the discharge; 3. The stream(s) affected by the discharge; 4. The circumstances which created the discharge; 5. The names and telephone numbers of the persons who have knowledge of these circumstances; 6. What remedial steps are being taken; and 7. The names and telephone numbers of the persons responsible for such remedial steps. C. These telephone reports shall be confirmed in writing within five days of the discharge and submitted to the appropriate Ohio EPA district office. The report shall include the following:

l. The limitation(s) which has been exceeded;
2. The extent of the exceedance(s); 3. The cause of the exceedance(s); 4. The period of the exceedance(s) including exact dates and times; 5. Ifuncorrected, the anticipated time the exceedance(s) is expected to continue, and 6. Steps being taken to reduce, eliminate, and/or prevent occurrence ofthe exceedance(s).

000445

Part III General Conditions (Con't) D. Compliance Schedule Events:

Page 22

3IVOOOOO·DD

If the permittee is unable to meet any date for achieving an event, as specified in the schedule of compliance, the permittee shall submit a written report to the appropriate district office of the Ohio EPA within 14 days of becoming aware of such situation. The report shall include the following:

I. The compliance event which has been or will be violated;
2. The cause of the violation; 3. The remedial action being taken; 4. The probable date by which compliance will occur; and 5. The probability of complying with subsequent and final events as scheduled.
E. The permittee shall report all instances of noncompliance not reported under paragraphs A, B, or C of this section, at the time monitoring reports are submitted. The reports shall contain the information listed in paragraphs B and C of this section.

F. Where the permittee becomes aware that it failed to submit any relevant application or submitted
incorrect information in a permit application or in any report to the director, it shall promptly submit such facts or information. 13. RESERVED

14. DUTY TO MITIGATE
The permittee shall take all reasonable steps to minimize or prevent any discharge in violation of this permit which has a reasonable likelihood of adversely affecting human health or the environment 15. AUTHORIZED DISCHARGES All discharges authorized herein shall be consistent with the terms and conditions of this permit. The discharge of any pollutant identified in this permit more frequently than, or at a level in excess of, that authorized by this permit shall constitute a violation of the terms and conditions of this permit Such violations may result in the imposition of civil and/or criminal penalties as provided for in Section 309 of the Act and Ohio Revised Code Sections 6111.09 and 6111.99.

000446

Part III Geneml Conditions (Con't) 16. DISCHARGE CHANGES

Page 23 3IVOOOOO'DD

The following changes must be reported to the appropriate Ohio EPA district office as soon as pmcticable: A. For all treatment works, any significant change in chamcter of the discharge which the permittee knows or has reason to believe has occurred or will occur which would constitute cause for modification or revocation and reissusnce. The permittee shall give advance notice to the Director of any planned changes in the permitted facility or activity which may result in noncompliance with permit requirements. Notification of permit changes or anticipated noncompliance does not stay any permit condition. B. For publicly owned treatment works: I. Any proposed plant modification, addition, and/or expansion that will change the capacity or efficiency of the plant; 2. The addition of any new significant industrial discharge; and 3. Changes in the quantity or quality of the wastes from existing tributary industrial discharges which will result in significant new or increased discharges of pollutants. C. For non-publicly owned treatment works any proposed facility expansions, production increases, or process modifications, which will result in new, different, or increased discharges of pollutants. Following this notice, modifications to the permit may be made to reflect any necessary changes in permit conditions, including any necessary effiuent limitations for any pollutants not identified and limited herein. A determination will also be made as to whether a National Environmental Policy Act (NEPA) review will be required. Sections 6111.44 and 6111.45, Ohio Revised Code, require that plans for treatment works or improvements to such works be approved by the Director of the Ohio EPA prior to initiation of construction. D. In addition to the reporting requirements under 40 CPR 122.41(1) and per 40 CPR 122.42(a), all existing manufacturing, commercial mining, and silvicultuml dischargers must notify the Director as soon as they know or have reason to believe: I. That any activity has occurred or will occur which would result in the discharge on a routine or frequent basis of any toxic pollutant which is not limited in the permit. If that discharge will exceed the highest of the "notification levels" specified in 40 CPR Sections 122.42(a)(I)(i) through 122.42(a)(l)(iv). 2. That any activity has occurred or will occur which would result in any discharge, on a non-routine or infrequent basis, of a toxic pollutant which is not limited in the permit, if that discharge will exceed the highest of the "notification levels" specified in 122.42(a)(2)(i) through 122.42(a)(2)(iv). 17; TOXIC POLLUTANTS The permittee shall comply with effiuent standards or prohibitions established under Section 307 (a) of the Clean Water Act for toxic pollutants within the time provided in the regulations that establish these standards or prohibitions, even if the permit has not yet been modified to incorporate the requirement. Following establishment of such standards or prohibitions, the Director shall modify this permit and so notify the permittee.

000447

Part m General Conditions (Con't) 18. PERMIT MODIFICAnON OR REVOCAnON

Page 24

3IVOOOOO·DD

A. After notice and opportunity for a hearing, this permit may be modified or revoked, by the Ohio EPA, in whole or in part during its term for cause including, but not limited to, the following:

I. Violation of any terms or conditions of this permit;
2. Obtaining this permit by misrepresentation or failure to disclose fully all relevant facts; or 3. Change in any condition that requires either a temporary or permanent reduction or elimination of the permitted discharge. B. Pursuant to rule 3745-33-04, Ohio Administrative Code, the permittee may at any time apply to the Ohio EPA for modification of any part ofthis permit. The filing ofa request by the permittee for a permit modification or revocation does not stay any permit condition. The application for modification should be received by the appropriate Ohio EPA district office at least ninety days before the date on which it is desired that thewodification become effective. The application shall be made only on formS approved by the Ohio EPA. 19. TRANSFER OF OWNERSHIP OR CONTROL This permitmay be transferred or assigned and a new owner or successor can be authorized to discharge from this facility, provided the following requirements are met: A. The permittee shall notify the succeeding owner or successor of the existence of this permit by a letter, a copy of which shall be forwarded to the appropriate Ohio EPA district office. The copy of that letter will serve as the permittee's notice to the Director of the proposed transfer. The copy of that letter shall be received by the appropriate Ohio EPA district office sixty (60) days prior to the proposed date of transfer; B. A written agreement containing a specific date for transfer of permit responsibility and coverage between the current and new permittee (including acknowledgement that the existing permittee is liable for violations up to that date, and that the new permittee is liable for violations from that date on) shall be submitted to the appropriate Ohio EPA district office within sixty days after receipt by the district office of the copy of the letter from the permittee to the succeeding owner; At anytime during the sixty (60) day period between notification of the proposed transfer and the effective date of the transfer, the Director may prevent the transfer if he concludes that such transfer will jeopardize compliance with the terms and conditions ofthe permit. If the Director does not prevent transfer, he will modifY the permit to reflect the new owner. 20. OIL AND HAZARDOUS SUBSTANCE LIABILITY Nothing in this permit shall be construed to preclude the institution of any legal action or relieve the permittee from any responsibilities, liabilities, or penalties to which the permittee is or may be subject under Section 311 ofthe Clean Water Act. 21. SOLIDS DISPOSAL Collected screenings, slumes, sludges, and other solids shall be disposed of in such a manner as to prevent entry of those wastes into waters of the state. For publicly owned treatment works, these shall be disposed of in accordance with the approved Ohio EPA Sludge Management Plan. 22. CONSTRUCTION AFFECTING NAVIGABLE WATERS This permit does not authorize or approve the construction of any onshore or offshore physical structures or fadlitiet. or the ~ o£ any ",ark '" any "'*"ipble

w-...

000448

Part III General Conditions (Con't)

Page 25 3TVOOOOO·DD

23. CIVIL AND CRIMINAL LIABILITY
Except as exempted in the permit conditions on UNAUTHORIZED DISCHARGES or UPSETS, nothing in this permit shall be construed to relieve the permittee from civil or criminal penalties for noncompliance. 24. STATE LAWS AND REGULATIONS Nothing in this permit shall be construed to preclude the institution of any legal action nor relieve the permittee from any responsibilities, liabilities, or penalties established pursuant to any applicable state law or regulation under authority preserved by Section 510 of the Clean Water Act. 25. PROPERTY RIGHTS The issuance of this permit does not convey any property rights in either real or personal property, or any exclusive privileges, nor does it authorize any injury tu private property or any invasion of personal rights, nor any infringement of federal, state, or local laws or regulations. 26. UPSET The provisions of 40 CPR Section 122.4 1(n), relating to "Upset," are specifically incorporated herein by reference in their entirety. For defmition of "upset," see Part III, Paragraph I, DEFINITIONS. 27. SEVERABILITY The provisions of this permit are severable, and if any provision of this permit, or the application of any provision of this permit to any circumstance, is held invalid, the application of such provision to other circumstances, and the remainder of this permit, shall not he affected thereby. 28. SIGNATORY REQUIREMENTS All applications submitted to the Director shall be signed and certified in accordance with the requirements of 40 CPR 122.22. All reports subiirltted to the Director shall be signed and certified in accordance with the requirements of 40 CFR Section 122.22. 29. OTHER INFORMATION A. Where the permittee becomes aware that it failed to submit any relevant facts in a permit application or submitted incorrect information in a permit application or in any report to the Director, it shall promptly submit such facts or information.

B. ORC 6111.99 provides that any person who falsifies, tampers with, or knowingly renders inaccurate
any monitoring device or method required to be maintained under this permit shall, upon conviction, be punished by a fine of not more than $25,000 per violation. C. ORC 6111.99 states that any person who knowingly makes any false statement, representation, or certification in any record or other document submitted or required to be maintained under this pennit including monitoring reports or reports of compliance or noncompliance shall, upon conviction, be puuished by a fine of not more than $25,000 per violation. D. ORC 6111.99 provides that any person who violates Sections 6111.04, 6111.Q42, 6111.05, or division (A) of Section 6111.07 of the Revised Code shall be fined not more than $25,000 or imprisoned not more than one year, or both.

000449

Part III General Conditions (Con't)

Page 26 3IVOOOOO·DD

30. NEED TO HALT OR REDUCE ACTIVITY
40CFR 122.4I(c) states that it shall not be a defense for a pennittee in an enforcement action that it would have been necessary to halt or reduce the pennitted activity in order to maintain compliance with conditions of this permit

31. APPLICABLE FEDERAL RULES
All references to 40 CPR in this permit mean the version of40 CFR which is effective as of the effective date of this permit

.-

000450

67!NE

Application No. OH0000612 Ohio EPA Permit No. 3IVOOOOO*DD

National Pollutant Discharge Elimination System (NPDES) Permit Program PUB L I C NOT ICE

NPDES Permit to Discharge to State Waters
Ohio Environmental Protection Agency Permits Section 122 South Front Street P. O. Box 1049 Columbus, Ohio 43216-1049 (614) 644-2001

Public Notice No. OEPA-01-07-019 Date of Issue of Public Notice: July 19, 2001 Name and Address of Applicant: Akron Public Utilities Bureau, 1570 Ravenna Road, Kent, OH 44240 Name and Address of Facility Where Discharge Occurs: Plant, 1570 Ravenna Road, Kent, OR 44240 Location of Discharge: 001 - 41" 11' 00" N; , 002 - 41" 11' 00" N' 003 41' 10' 48" N; 004 - 41" 10' 54" N; 005 - 41' 10' S7" N; 81" 81' 81' 81' 81" 20' 20' 20' 19' 19' Akron Water Treatment

-

05 11 W 05" W

07" W 57" W 52 11 W

Receiving Water:

Cuyahoga River

This applicant is a municipality which operates an existing water treatment facility. The current operations of this discharger result in an average effluent flow of 1,204,000 gallons per day. Key parameters to be limited in the permit are as follows: pH, Total Suspended Solids, Ammonia Nitrogen, Fecal Coliform, Total Chlorine Residual, and CBODS '

000451

ohio EPA Permit No. 3IVOOOOO*DD Public Notice No. 01-07-019 On the basis of preliminary staff review and application of standards and regulations, the director of the Ohio Environmental Protection Agency will issue a permit for the discharge subject to certain effluent conditions and special conditions. The draft permit will be issued as a final action unless the director revises the draft after consideration of the record of a public meeting or written comments, or upon disapproval by the administrator of the U.s. Environmental Protection Agency. Any person may submit written comments on the draft permit and administrative record and may request a public hearing. A request for public hearing shall be in writing and shall state the
nature of the issues to be raised. In appropriate cases, including cases

where there is significant public interest, the director may hold a public hearing on a draft permit or permits prior to final ~ssuance of the permit or permits. Following final action by the director, any aggrieved party has the right to appeal to the Environmental Review Appeals Commission. Interested persons are invited to submit written comments upon the discharge permit. Comments should be submitted in person or by mail no later than 30 days after tue date of this public notice. Comments should be delivered or mailed to both of the following locations: 1) Ohio Environmental Protection
Agency, Lazarus Government Center, Division of Surface Water, permits

Processing Unit, 122 South Front Street, P.O. Box 1049, ColUmbus, Ohio 432161049 and 2) Ohio Environmental Protection Agency, Northeast District Office, 2110 East Aurora Road, Twinsburg, Ohio 44087. The Ohio EPA permit number and public notice numbers should appear next to the above address on the envelope and on each page of any submitted comments. All comments received no later than 30 days after the date of this public notice will be considered. The application, fact sheets, permit including effluent limitations, special
conditions, comments received, and other documents are available for

inspection and may be copied at a cost of 5 cents per page at the Ohio Environmental Protection Agency at the address shown on page one of this public notice any time between the hours of 8 a.m. and 4:30 p.m., Monday through Friday. Copies of the public notice are available at no charge at the
same address. Mailing lists are maintained for persons or groups who desire to receive

public notice for all applications in the state or for certain geographical
areas. Persons or groups may also request copies of fact sheets,

applications, or other documents pertaining to specific applications. Persons or groups may have their names put on such a list by making a written request to the agency at the address shown above.

000452

ATTACHMENT B

000453

Sot<

oe Ohio

~ Enviroa.......i !'TO_a

-'COlley

Northeast District OfrJCe
I 10 E. Aurora Road Ninsburg, Ohjo 44087-1969 Bob Tatt. Governor Christopher ~ones, Director

June 12, 2001

Mr. Ed Maynard Akron Water Plant 1570 Ravenna Road Kent, Ohio 44240 Dear Mr. Maynard: This wnler conducted an inspediCln of the fadlity on ApIiI 20, 2001 as part of general preparation for the . NPDES permit renewal. . The permit renewal will cover seveiai discussed below: 1.

new"areas not previously Covered.

The specific points will be

The sanilary package plant will contain an Interim and final effluent limits tables. The flnat table will address recommended effluent limits contained in the March 2000 Middle Cuyahoga River TMDL The dlstrlct llilIce ~ n also includes a compliance schedule to meet finallable efIIuent limits. The initial results from the 2000 Cuyahoga River survey show the river in noncompliance with biological criteria below the Lake Rockwell dam and in compliance above the dam. This office believes that the physical strucl1!fe of. the dam is partially responsible for nonattainmenl, In addition. the dam has two discharge" points which may be considered point sources for purposes of NPOES permitling. One point is the 12 inch line used to discharge flow for purposes of complying with obllgattons pertaining to the water diversion. The other point source is the bottom withdrawal referred to as the flow routing strudure. Bottom wilhdtawal waters have bean shown to have low dissolved oxygen. lower temperntures, higher phosphorus and sulfide. This otlIce has concerns relating to the quality/ of water released from the dam and Its potential downsfream impacts. It is recommended that the NPOES renewal include outfall monitoring stations for both discharge points. The existing downsll'eam siallon Will be maintained with several additional parameters suCh as temperature and dissolved oxygen.

2.

3.

Should you have further questlons please call me at 3301963-1134.

~~~~S~
Environmental SCientist Division of Surface Water WJZ:per

Sincerely,

,

pc:

Dennis Lee. NEDC-OSW Steve Tuekem1an. NEDC-OSW

..... ,

000454

ATTACHMENT C
Excerpt of Deposition Testimony of Steve Tuckerman October 27,1999

000455

146

1 2 3 4
5

other occasions when you boated upstream from the Ohio Edison dam?

A

Yes.
Has Ohio EPA ever considered requesting that

Q

Akron apply for an NPDES permit for Rockwell
dam?

6 7 8

A

Yes, we have.
When did you first consider that? I guess I first need a clarification on who you mean by we.

Q
A

9
10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25

Q
A

Ohio EPA, to the best of your knowledge.
And who within Ohio EPA? There have been

discussions among staff levels at the Northeast District Office about how best to understand what's happening with the reservoir releases and the water quality, and so there were discussions at staff levels maybe a year or two years ago.

Q

All right.

And have there been any discussions

since that time, to your knowledge?

A

Yes.

When we were reviewing the TMDL process,

we recommended from the district level that we include it as part of the monitoring strategy.

Q

And why did the district office make that
recommendation?

A

We felt we didn't have enough information to

Cady & Wanous Reporting Services,

Inc.

000456

Tuckerman, steve 10/27/99 Volume I

Page 146

147

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25

really understand exactly with what's going on

with the water quality or quantity with the Lake Rockwell discharge.
more information.

We were trying to gather

Q

What,

if anything, has happened to the district

office's recommendation?

A

As I understand it, that recommendation was not carried forward in the TMDL final document that

went to the U.S. EPA.

Q

Let's talk about the discharges from the Akron
water plant. What study, if any, have you done

concerning the effects of the effluent from the
Akron water plant at Lake Rockwell?

A

The only work -- I wouldn't call it a study.
The only work that I've done in relation to that was the samples that we set up as, to our intensive survey, in response And

in that portion.

then subsequent to that one or two grab samples of effluent from their discharge channel and

sampling that to check on water quality.

That's

the only things that I have been personally
involved in when it comes to discharges from

their water treatment plant.

Q

What were the results of the samples taken from the discharge channel at the water plant?

Cady & Wanous Reporting Services, Inc.

000457

Tuckerman, steve 10/27/99 Volume I

Page 147

ATTACHMENT D

Excerpts of Deposition Testimony of Robert Wysenski

October 26, 1999 and November 11,1999

000458

149

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25

for purposes of the model.

Just one question to

see if you have any knowledge about this.

Did

you consider, either with respect to the TMDL report or in your analysis of this segment of the river, any impacts to flow that have occurred as a result of the pumping by Portage county from its wells at Shalersville?

A
Q

No,

I don't believe that was taken into account.

And have you addressed that issue in any context? context? Have you looked at that issue in any

A

Not that I'm aware of.

Again, the model

starting at that segment below Lake Rockwell, whatever the flow is, it is. I mean, the flows

that were generated are based on that.

Q

The flows into Lake Rockwell have no impact on the model?

A
Q

That's correct. There's a reference in the report in a couple of

places to the possibility of NPDES permitting
for the Lake Rockwell release. Are you familiar

with that?

A
Q

Yes, I am. And there is an indication on page 23 that such permitting is currently under discussion. Has

000459

Wysenski, Robert 10/26/99 Volume I

Page 149

150

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25

there been any decision made about whether a permit can or will be required for that release?

A

Yes.

A decision was made that NPDES permit

would not be required for that release. Q And if you know, was that based on a legal
analysis or was there some other reason for that decision?

A Q

Legal analysis was involved in that decision. Were there other reasons that it was decided not to pursue that?

A Q A

Yes.

What were those reasons? In the spirit of trying to get everyone to cooperate on the preferred option, it was viewed

that putting an NPDES permit requirement on that
discharge would make it even more difficult for the City of Akron to agree to release that water. There was an understanding that that

would probably make it much more difficult for the City of Akron to go along with our
recommended plan, our recommended option I

should say. Q
There's a discussion in the report at page 15 at

the top about calibration of the model. A Okay.

000460

Wysenski, Robert 10/26/99 Volume I

Page 150

280

1

Q

Also on page two, in the first full paragraph in
the last sentence it is stated, lilt was also

2 3
4

noted that we are looking at whether we should put the dam release under NPDES permit (this has
not been done before)
.~

5
6
7
A Q

Do you see that sentence?

Yes, I do.
In what discussions have you participated concerning whether or not to put the dam release
at Lake Rockwell under an NPDES permit?

8 9

10
11 12
13

A

That issue'S come up numerous times throughout this entire initiative. Actually, it probably There are

came up even before this initiative.

14 15
16

other dams in northeastern Ohio that we have had similar concerns with and discussed putting them

under NPDES permit as well.
Q

17 19 19 20
21

What is the current status of the agency's discussions of this topic?

A

A determination was made that we would not put

that dam release under NPDES permit.
Q
A

When was that determination made? As we were finalizing the TMDL report, which would have been in the spring of '99.

22

23
24
Q

Why did the agency decide not to put this dam
under an NPDES permit?

25

Cady & Wanous Reporting Services, Inc.

000461

Wysenski, Robert 11/29/99 Volume III

Page 280

281

1 2
3

A

I believe there were two primary reasons.

One t

we had a legal interpretation from our legal
section, our internal folks, that

4
5
6

MR. SCHMIDT;

I think I'm
thi~

going to 9bject.

JPelieve

is

c~11in9

for

attorney-client privilege. Q
Okay. What was the other reason?

7

8
9

A

Political and strategic.

It was felt that

trying to get Akron to agree to releasing more

10
11 12
13

water was going to be difficult enough.

The

threat of putting that release under NPDES permit probably would cause Akron to be more
resistant to the idea of releasing more water.

14

15
16

(Plaintiffs' Exhibit No. 449 was marked.)

17
18
19

Q

I'm now handing you what has been marked as Plaintiffs' Exhibit 449. 1 1 m also going to

provide you with a copy of a document that has Peen previously marked as Exhibit 55.
particular, r'm going to refer to the conservation index of Exhibit 55. Have you had a chance to review that document?

20
21
22
23
24

And in

25

A

Yes, I have.

Cady & Wanous Reporting Services, Inc.

000462

Wysenski, Robert 11/29/99 Volume III

Page 281

State of Ohio Environmental Protection Agency
STREET ADDRESs: IAAIUNG ADDRESS:

Lazarus Government Center 122 S. Front Street Columbus, OH 43215-1099

TELE: (614) 644-3020 FAX: (614) 644-2329

P.O. Box 1049 Columbus, OH 43216-1049

July 12, 2001 Re: Ohio EPA Permit No. 3IVOOOOO*DD Facility Name: Akron Water Treatment Plant

Akron Public Utilities Bureau 1570 Ravenna Road Kent, OH 44240 Ladies and Gentlemen: Transmitted herewith is one copy of the Public Notice and Draft Permit in the above-referenced matter.

,-

The public has been invited to submit comments regarding this draft p~rrnit. If sufficient public interest is indicated, a public meeting will be held. The permit as drafted will be issued as a final action unless the director revises the permit after consideration of all written comments received during the 30-day period following Public Notice and'consideration of the record of a public meeting, if one is held, or unless the draft is disapproved by the Regional Administrator, u.s. Environmental Protection Agency. You should note that a general condition of your permit states that issuance of an NPDES permit does not relieve you of the duty of complying with all applicable Federal, State, and local laws, ordinances, and regulations.

"'~~~.~
Martha D. Spurbeck, Supervisor Permit Processing Unit Division of Surface Water MDS/kep Enclosure CERTIFIED MAIL

Sincerely,

,~,

~t-

Is delivery addres d" . If YES S Ifferent from item 1? , enter delivery address below: .

o Agent o Addressee DYes o No

lC

ULiljti23

=
ail

o
2. Article Number (C
Opy from service label)

Insured Mail
.

0

o Return Recelpt for MerchanlpIse . I)
C.O.D.

0

Express Mail

~

Ii

4. Restricted Delivery? (Ext.

ra Fee)

0

Yes

U

000463

State of Ohio Enviromnental Protection Agency
STREET ADDRESS: MAILING ADDRESS:

Lazarus Government Center 122 S. Front Street
Columbus, OH 43215-1099

TELE: (614) 644-3020 FAX: (614) 644-2329

P.O. Box 1049 Columbus, OH 43216-1049

July 12, 2001 Re: PUBLIC NOTICE NO. 01-07-019

postmaster
United states Post Office Kent, OH 44240

Dear Postmaster: Enclosed is one copy of the Public Notice referenced above regarding National Pollutant Discharge Elimination System (NPDES) permits or modifications. This notice is being advertised in a newspaper of general circulation in the county, and·~s being provided to certain public officials and the regulated entity. In order to provide further notice, we will appreciate your assistance in posting this notice in a conspicuous location for a thirty-day period starting on the date of Public Notice. Thank you for your cooperation in this matter.

'-~~~,~~
Martha D. Spurbeck, Supervisor Permit Processing Unit Division of Surface Water MDS/kep Enclosure

Sincerely,

*

Bob Taft, Governor Maureen O'Connor, Ueutenant Governor Christopher Jones, Director
Printed on Recycled Paper

000464

State of Ohio Environmental Protection Agency
STREET ADDRESS: MAILING ADDRESS:

Lazarus Government Center 122 S. Front Street
Columbus, OH 43215-1099

TELE: (614) 644-3020 FAX: (614) 644-2329

P.O. Box 1049 Columbus, OH 43216-1049

July 12, 2001 Re: PUBLIC NOTICE NO. 01-07-019

Mayor and Council City of Kent 217 East Summit Street Kent, OH 44240 Ladies and Gentlemen: Enclosed is one copy of the Public Notice referenced above regarding National Pollutant Discharge Elimination System (NPDES) permits or modifications. This notice is being advertised in a newspaper of general circulation in the county, and is being provided to certain public officials and the regulated entity. In order to provide further public notice, we will appreciate your assistance in posting this notice in a conspicuous location for a thirty-day period starting on the date of Public Notice. Thank you for your cooperation in this matter.

""f"r\~~. ~ ~
Martha D. Spurbeck, Supervisor Permit Processing Unit Division of Surface Water

Sincer~ly,

MDS/kep
Enclosure

*

Bob Taft, Governor Maureen O'Connor, Ueutenant Governor Christopher Jones, Director
Printed on Recycled Paper

000465

67/NE

Application NO. OH00006l2 Ohio EPA Permit No. 3IVOOOOO*DD

National Pollutant Discharge Elimination System (NPDES) PUB L I C NOT ICE

Pe~it

Program

NPDES Permit to Discharge to State Waters

Ohio Environmental Protection Agency Permits Section l22 South Front Street P. O. Box l049 Columbus, Ohio 432l6-l049 (6l4) 644-200l
Public Notice No. OEPA-Ol-07-0l9 Date of Issue of Public Notice: July 19, 200l Name and Address of Applicant: Akron Public Utilities Bureau, 1570 Ravenna Road, Kent, OH 44240 Name and Address of Facility Where Discharge Occurs: Plant, 1570 Ravenna Road, Kent, OH 44240 Location of Discharge: OOl 002 003 004 005 410 4lO 4lO 4lO 4lO ll' ll' 1p' lO' lO'
001f DOl! 48 11 54" 57 11

Akron Water Treatment

N; N; N; N; N' ,

8lo 8lo 8lO 8lO Slo

20' 20' 20 ' 19' 19'

05" W 05 11 W
07" W 57 11 W 52 n W

Receiving Water:

Cuyahoga River

This applicant is a municipality which operates an existing water treatment facility. The current operations of this discharger result in an average effluent flow of 1,204,000 gallons per day. Key parameters to be limited in the permit are as follows: pH, Total Suspended Solids, Ammonia Nitrogen, Fecal Coliform, Total Chlorine Residual, and CBOD S _

000466

Ohio EPA Permit No.

3IVOOOOO*DD

Public Notice No. Ol-07-0l9 On the basis of preliminary staff review and application of standards and regulations, the director of the Ohio Environmental Protection Agency will issue a permit for the discharge subject to certain effluent conditions and

special conditions.

The draft permit will be issued as a final action unless

the director revises the draft after consideration of the record of a public meeting or written comments, or upon disapproval by the administrator of the U.S. Environmental Protection Agency. Any person may submit written comments on the draft permit and administrative record and may request a public hearing. A request for public hearing shall be in writing and shall state the nature of the issues to be raised. In appropriate cases, including cases where there is significant public interest, the director may hold a public hearing on a draft permit or permits prior to final issuance of the permit or permits. Following final action by the director, any aggrieved party has the right to appeal to the Environmental Review Appeals Commission. Interested persons are invited to submit written comments upon the discharge permit. Comments should be submitted in person or by mail no later than 30 days after the date of this public notice. Comments should be delivered or mailed to both of the following locations: 1) Ohio Environmental Protection Agency, Lazarus Government Center, Division of Surface Water, Permits Processing Unit, 122 South Front Street, P.O. Box 1049, Columbus, Ohio 432161049 and 2) Ohio Environmental Protection Agency, Northeast District Office, 2110 East Aurora Road, Twinsburg, Ohio 44087. The Ohio EPA permit number and public notice numbers should appear next to the above address on the envelope and on each page of any submitted comments. All comments received no later than 30 days after the date of this public notice will be considered. The application, fact sheets, permit including effluent limitations, special conditions, comments received, and other documents are available for inspection and may be copied at a cost of 5 cents per page at the Ohio Environmental Protection Agency at the address shown on page one of this public notice any time between the hours of 8 a.m. and 4:30 p.m., Monday through Friday. Copies of the public notice are available at no charge at the same address. Mailing lists are maintained for persons or groups who desire to receive public notice for all applications in the state or for certain geographical areas. Persons or groups may also request copies of fact sheets, applications, or other documents pertaining to specific applications. Persons or groups may have their names put on such a list by making a written request to the agency at the address shown above.

000467

State of Ohio Environmental Protection Agency
STREET ADDRESS: MAILING ADDRESS: TELE: (614) 644-3020 FAX: (614) 644-2329

Lazarus Government Center 122 S. Front Street Columbus, Ohio 43215

P.O. Box 1049 Columbus, OH 43216-1049

January 22, 2001

RE:

Renewal of OEPA Permit No. 3IVOOOOO'CD App. No. OH0000612 Expiring 10/28/2001

AkronWTP 1570 RAVENNA ROAD KENT ,OH 44240 Ladies and Gentlemen: Enclosed is one copy of Form 1 and 2C applications for renewal of your National Pollutant Discharge Elimination System (NPDES) permit. If the facility discharges storm water associated with industrial activity, excluding construction, and that wastestream(s) is to be authorized by the renewal permit then you must also submit a Form 2F. If a different form is needed it may be obtained by calling (614) 644-2053 or by going to the U.S. EPA website http://www.epa_gov/owm/npdes.htm. In the space provided for "EPA I.D. number" in the application, use the NPDES number, which for your permit, is OH0000612. File two copies of the application with Ohio EPA Northeast District Office 2110 East Aurora Road, Twinsburg, oH 44087. Do not file this application with the U.S. EPA Filing of this application for the NPDES permit does not relieve you of the responsibility of filing applications for other permits that may be appropriate. Regulation require this application to be signed only by the person authorized as described in the instructions Section B, Form 1. Revised Code 3745.11 requires that a non-refundable application fee of $200.00 accompany the application. The check should be made payable to the "Treasurer of the State of Ohio". In order to address issues related to OAC 3745-1-05 (Antidegradation RUle), also complete and submit the enclosed antidegradation addendum. A possible alternative to renewing an individual NPDES permit is obtaining general NPDES permit coverage. The application, known as a Notice of Intent (NOI), for general permit coverage is significantly less complex than the enclosed applications. General permit coverage is available to facilities that have storm water, coal mining, noncontact cooling water, small sanitary and petroleum-related corrective action wastewater discharges. Check the Eligibility section of the appropriate General permit to determine whether coverage under that permit is applicable. Should there be any questions reoardino this matter. Dle'!se feel. fr£le to contact the Northeast District Office at 330-963-1200.

Sincerely,

_.B
II

Martha D. Spurbeck, Supervisor Permit Processing Unit Division of Surface Water Certified Mail

~

Complete items 1, 2, ana. 3. Also complete item 4 if Restricted Delivery is desired. II Print your name and address on the reverSe so that we can return the card to you. iii Attach this card to the back of the mailpiece, or on the front if space permits.
1. Article Addressed to:

Akron WTP
1570 RAVENA RD KENT , OH 44240

3IVOOOOO'CD

Enclosures: Antidegradation , FOI cc: DSW - Northeast District Off

3. Service Type

o

o

o

Certified Mail Registered Insured Mail

o

o Return Receipt for Mercha
o C.O.D.
0 Yes

Express Mail

[

*

4. Restricted Deiivery? (Extra Fee)
Printed on Recycled Paper

"

"

2. Articie Number (Copy from service label)

PS Form

3811,

-1000 00CX700 d.'-(()~~o0(511 000468
Domestic Return Receipt
102S9S-00.M-0!

July 1999

SIC COOES(4~digit; in order ofpriority)
A. FIRST

I I i AIzV'OII\

.
"

(specify)

(specify)

O.FOURTH

(specify)

. OPERATOR INFORMATION

::-1 T
C. ST A TUSO F OPER ATOR

'(Enter the appropriate lefterinto the answer box; if "Other", specify.) (specify)

N

u
HI 11

PRINkil\l&WAi"£R SUPPLY

C, DATE SIGNED

I)"

Form 3510·' (Rev. 10~80) Reverse

>} L'.~.

Government Printing Office

1985 - 486-785/32991

000469

000470

.IEPA
Please print or type in the unshaded areas only .

1.0. NUMBER (copy trom Item 1 of Fonn 1)

1

rorm Approved OMS No. 2040-0086 Approval expires 5-31-92
"""".

FORM NPDES

2C

oEPA~;tI~iING MANUFACTURING, COMMERCIAL, MINING AND ~r\;;;"-;;,
.

ft·

. .' ' ) \ 0 . ) .

••.•

U.S_ ENV'RONMENTA~PROTECTOON APPLICATION FOR PERMIT TO OISCHARGE

•.

'~rFALL
N~i'?s~JER

Consolidated Permits Program

......

;:~~ci":/ . . . . .· c•• ,-'
.....

-'1.;_j(,;c';"!"j'~

LOCATION Fo:'each outfall,list the latitude and longitude of its location to the nearest 15 seconds and the name of the receiving water.
B. LATITUDE
I. DlIl:G.

·····.7;:

A.~~~TFALL

.-3.

C. LONGITUDE
I. PlrG,
~.

~. MIN.'

see.

IIIIIN.

3.

sire.

I·"

b'.,RECEIVING WATER: (,;arne)

·':;;":;:::~>;,"':);-·.·-:<;:-,:':i~/i_;

001

4-1

iI
12-

00

002.. 00,3

4-1
4-1

00
4,1)

81 8I
81

20
2..0

/0

20

00 Twi'V) /...dkes Ouflt4·+o Cuvaho~!-k?t\ler 00 TtJ!l/\ I...akP,<.,. (A,+jet +0 Cu~Ak o-;.:~ R;-vevI d 15 (,J\lA h()c~ RiveV' ,
<..J

II. FLOWS, SOURCES OF POLLUTION, AND TREATMENT TECHNOLOGIES A. Attach a line drawing showing the water flow through the facility. Indicate sources of intake water, operations contributing wastewater to the effluent; and treatment units labeled to correspond to the more detailed descriptions in Item 8. Construct a water balance on the line drawing by showing average' flows between intakes, operations, treatment units, and outfalls, If a water balance cannot be determined (e.g., far certain mining activities), pr'ovide a pictorial description of the nature and amount of any sources, of water and any collection or treatment measures. B. For each outfall, provide a description of: (1) All operations contributing wastewater to the effluent, including process wastE:water, sanitary wastewater, ~ooling water, and storm water runoff; (2) The average flow contributed by each operation; and (3) The treatment received by the wastewater. Continue .In additional sheets if necessary.
1.0UT~

FALLN

(list)

a. OPERATION (list)

2. OPERATloN'Sj CONTRIBUTING FLOW b, AVERAGE FLOW

3. TREATMENT a. DESCRIPTION
b, LIST CODES FROM TABLE 2C-1

(include units)

001

J=,I-t-P,1r l,dA.-':"h

,,..,....LV"'

O,f! MbD ("-/(~sr<A\I\ (''''D~
:::
f:d. 1.2 MGt:., I)

Sed ·i\N\-eVl:+-A:tmiA

I-V

S lu,---!r:lf'>, I ~.
<J

",'1£

"A

!

ooz. P'·-l·-h"v-I,I ',,-,,-IA', ,....

.i
.A

d_-t---t--:
I/l.t::

Ls"TI
b··T

(~.5

MG-D

".-d 0:SlrAIA (·.;:ID,

-, ») ::.1~2 Mb-D

SediVVleiQla:hoiA S ti ,,..\ f"'P L ",,..-,,,,~~,,.r"
<.J
'-..,)

r HJ I
1

-~-

no:.?> -is--: ~ '4 "1 rAP IA b-:::,-1--l->., -TVY"a+~M+ Pi:':\ .•

+

/,4DO 6-PD ( rl P$. irAl1I Gau,

" +, OQQ.fz P D
/

~

..J

,-

66+ Rew\D\k;l L_~~_ I-/VI I-D /Vi '1 V .1\ 0-.. Ra Fic! ~;::o.\f\rl !+~V--- 1-1< DI $- \1\ --FFC--+,,/:>\1\ (~hlcrrw' ?-F '-.:(- e l='v-e- ky::~--h,<::>V\ () 1-1. ,~ _ \!,'n!,';+ L;- {A~ 2-·H

r

10:
~

'-J

-

~
000471
,-"""
,-"

.

orFICIAL USE ONLY (eff1uent guidelines BUb-categories)

,..,., -.

~.

~,.""

~;"

,,.

~.

,..

- .,

-

.,.

.-

.• ".,..

"""

"

;~ "00:

CONTINUED FROM THE FRONT C. Except fo~ storm runoff, leaks, o~sP~Us.}:lr~ any of the discharges described in

liMA or B intermittent

"0 YES (complete the
1.0UTFAL.L.

following table) 3. FREQUENCY

IgJNO(goto

2.0PERATION(S}
CONTRIBUTING FL.OW

a.

DAYS

b.

NUMBER (list)

PER WEEK

(list)

average)

(specifY

PE(,RpeYcEif~R ~~~~~~f.~~~~1,2·'.~L~O~N·~.·--J·T~'~N~.~·~~~5~j average)
,T

MONTHS

a, FLOW"RATE (in mgd) ,

1.·,I.QNG· TERM
AVtl:RAOE

2. MAXIMUM
DI\.II..Y

....

AVI!:RAGE

)'''11>31.:'

001

Nate:

.Dv,-i1t\~ d-\I\ ew.e~lAOf

&00z..

lfs\ud~e firoM,+f,"\B piSiA+

o

o

o

o

u~ dv-y ~ ba-<;,MS,,,,i::(;v

caV\ 111.0+- be pu l'\jftX:\ 4-0 +ite

covk4 be d~aV'Cjed k-....v\ ou+f'",ljs
00 I

5"o,oOO&PD e~

alAd

002"

Ill. PRODUCTION A. Does an effluent guideline limitation promulgated by EPA under Section 304 of the Clean Water Act apply to your facility?

o

YES

(complete Item III·B) (complete Item III·C)

IXJ

NO

(10 to Section IV)

B. Are the limitations in the applicable effluent guideline expressed in terms of production (or other measure of operation)?
DYES

~NO (go to Section IV)

C. If you answered "yes" to Item tll-B, list the quantity which represents an actual measurement of your level of production, expressed in the terms and units used in the applicable effluent guideline, and indicate the affected outfalls.
1. AVERAGE DAILY PRODUCTION
a.
QUANTITY PER DAY

'2. AFFECTED
OUTFALLS

b.

VNITS OF MEASURE

C. OPe:RATION, PROOUCT, MATE;RIAL, ETC,

(specify)

(list outfall numbers)

)-,

IV.lIMPROVEMENTS

A. Are you now required by any Federal, State or local authority to meet any implementation schedule for the construction, upgrading or operation of waste· water treatment equipment or practices or any other environmental programs which may affect the discharges described in this application? This includes,' but is not limited to, permit conditions, administrative or enforcement orders, enforcement compliance schedule letters, stipulations, court orders, and gran,t or loan conditions, 0 YES (complete the following table) ~ NO (go to Item IV-B)
1. I D EN T I FICA T 10 N 0 F CO N 0 I T I ON '1_-,,2~'~"r-Fc.cF~E~C~T~E:..:D~O=.:U~T,-,-P~"~'-~'-=S=---j

3. BRIEF DESCRIPTION OF PROJECT

4. FINAL COM PIAN E DATE:
aUIRED

AGREEMENT, ETC.

8.

NO.

b.OIOUflCE;

OF

DIIlCHAflGE;

a.

Re:·

J.6CTE:Q

b. PRO-

J
B. OPTIONAL: You may attach additional sheets describing any additio:Jna! water pollution control programs (or other environmental projects which may affect your discharges) you now have underway or which you plan. Indicate whether each program is now underway or planned, and indicate your actual or 000472 planned schedules for construction. DMARK .. x .. IF DESCRIPTION OF ADDITiONAL. CONTROL PROGRAMS IS ATTACHED -~EPA Form 3510-?(: IR"" /-R51 PAGE 2 OF' 4 CONTINUE ON PAGE

EPA 1.0. NUM.SER(copy from Item 1 of Farm 1)

· "ONTINUED FROM PAGE 2 V. INTAKE AND EFFLUENT CHARACTERISTICS

A, 8, & C:
~f

See instructions before proceeding ~ Complete one setof tables for each outfall'~'AI1notatet'he NOTE: Tables V.,A"V.S. and V~C are included on separate sheets numbered V·1through V-9.

6~L1se

the space below to llst'¥ny of the pollutants listed in Table 2c-3 of the instructions, which you knowor have discharged from any outfarr:,~,Forevery~()lIutant you list, briefly descr"lbe the reaso~syoubelieveit to be present possession.)~ "
i,'J,

1. POLLUTANT

2. SOURCE

1, POLLUTANT

!-:cV71.-:p:-:O:-:T=E=N=T=IA=L:-°D"I=SC=H-:A-:R"G:-:E"S"N:;;O::;T;:-;C:;O~V7E ;:"R;;";:E";;O:";8=Y:;-";A;";N=A;:"L;"'Y:;;:"S"IS"""
Is a ny pollutant listed in Item V -C a substance or a component of a substance which you currently use or manufacture as an intermediate or final product or byproduct?
,~,..~

I

_ .

~

---'==--:.~

DYES

(list all_ pollutants below) _ such

-'-'-__=~='__

---"'L:..~~::.:...:.:..::.:...

NO

(go to Item VI-B)

_

000473
EPA Form 3S10-2C (8-90)
PAGE 3 OF 4

CONTINUE ON REVERSE

CONTINUED FROM THE FRONT

VII,

BIO~OGICA~ TOXICITY

TESTING DATA

Do you have any knowledgeo~l~asontobeliew:t:hatany biol.ogical test,f0racute or chronic toxicity has been made receiving water in relation to your: discharge ~Ithin the last 3 years?

o

YES

:'.::::>,:.:, (identify the test(s) and describe their purposes below)

NO

(go to Section VIII)

IILCONTRACT

ANA~YSIS INFORMATION

.• '

Were any of the analyses reported in Item V performed by a contract laboratory or consulting firm?

'~'c:ir,.¥]q~~ ~ ','

o

YES

(list the name, address, and telephone number of, and pollutants analyzed by, each such laboratory or firm below)
B. ADDRESS C,

"'~O (go to Section IX) .94N(

A. NAME

ELEf'HONE

D.

area code & no.)

LLUTANTS ANALYZED

list

IX, CERTIFICATION

I certify underpenalty oflaw that this document and aI/attachments were prepared undermy direction or supervision in accordance with 8 system designed to assure that qualifiedpersonnelproperlygather andevaluate the information submitted. Based on my inquiry of the person orpersons who manage the system or those persons directly responsible for gathering the information the information submittedis, to the best ofmy knowledge and belief. true, accurate, and complete. I am aware that there are significant penalties for submitting false information including the possibility of fine and imprisonment for knowing Violatjo"~)A. NAME 8: OFFICIAL TITLE (type or print) B. PHONE NO. (area

code & no.)

o.

DATE SIGNED

t!J4/~S-~(
EPA Form 3510·2C (8.90)
PAGE 4 OF 4

000474

LAKE . 'CHEMICAL .I RAPID SAND CHLORINE i ROCKWELL 41.051 MG~IOXIDATIONI41051 MGDICOAGULATIONI41.051 MGU{LOCCULATIONI41.051 MGDI SEDIMENTATION I41 001 MGDI FILTRATION 140.001 MGDI DISINFECTION,
UOSMGD

PRODUCT 4O,._u
UOO1 MGD

1MGD SLUDGE LAGOONS
OUTFALLS 001 AND 002

N!~I]l~t~P_<!.~~l:!!L_ ...

PACKAGE WASTEWATER PLANT
OUTFAlL 003 0,001 MGD

1MGD TWIN LAKES OUTLET TO CUYAHOGA RIVER

CUYAHOGA RIVER

DRYING BEDS

SCHEMATIC OF WATER FLOW AKRON WATER SUPPLY PLANT KENT, PORTAGE, OHIO

000475

PLEASE PRINT OR 1 .. ~ IN THE UNSHADED AREAS ONLY. You may report some or all of this information on separate sheets (use the same format) instead of completing these P<1gcs.

SEE INSTRUCTIONS.

•
a.

~ ... fEPA 1.0. NUMSE" lcopyfrom Item

lof

Form 1)

~~,

OH 0000 G 12.
OUTFALL NO.

V. INTAKE AND EFFLUENT CHARACTERiSTiCS (continued from page 3 of Form 2-CJ

001

PART A - You must provide the results of at least one analysis for every pollutant in this table. Cornplete one table for each outfall. See instructions for additional details.
1.
POLL.UTANT MAXIMUM DAILY VALUE •

MAXI~~M a ~~y Gum e)
I

2. EFFLUENT
3.y VALUE
MAS"

(.·flf'cif~' if blank)
ANALYSES

3. UNITS

4 INTAKE: 0 riollal . ) a. LONG TERM ( p
CONCENTFfATlON

II!
NTllAT10N a. Biochemical

Id

MA5"

Id
CONCENT"ATJoN

d. NO. OF

a.CONCENTRATION

(z)

b. MASS

Id

{~ J

MASS

Oxygen Demand
(BOD)

0.10 8 (,4.. )I'1i~\<t)'"

Bl;:,.lo .....

b. Chemical Oxygen Demand (COD,

13.8

C. Total Organic Carbon (TOC)
d. Total Suspended Solids (TSS)

4.52.
2. O.2.e
VALUE VALUE
VALUE

e. Ammonia
f. Flow

(as. N)

VALUE

0-1.2. M0D
VALUE VALUE
VALUE

g. Temperature
(winter)

VALUE:;

0- IS °c
VALUE
V~LUE

°C
VALUE

h. Temperature
(summer)

VALUE

IS-]OOC
MINIMUM
MAXIMUM

°C
MINIMUM
MAXIMUM

i. pH

1.4G

~

STANDARD UNITS

PARTB -

Mark "X" in column2-a for each pollutant you know orhave reason to believe is present. Mark "X" in column 2-b for each pollutant you believe to be absent. If you ma7f<.lcolu~~· 2a for anypoHutant which is limited ejther directly, or indirectly but expressly, in an effluent limitations gUideline, you must provide the results of at least one analysis forthatpollutant. For other pollutants for which you mark column 28, you must provide quantitative data or an explanation of their presence in your discharge. Complete one table for each outfall. See the instructions for additional details and requirements.
3, EFFLUENT
(01

1. POLLUT- Z.MA'fIfK'-;(,jil
ANT AND

4. UNITS

C

AS NO
.

(ifalJadableJ

•

I.IEVE I.IEVe: fORe:' ASSENT

a. "'~,._ b. "''''
SENT

a. MAXIMUM DAIL.Y VAL.UE _
CONCENTRATION

Ib , MAXIM(UM 3.0 DAY il ouai/aWe)

I

hi

MASS

I

II)

CONCENTRATION

I

ld

VALUE le,L.ONG T,f;:,RM f':., VRG. VAL.UET dNO . 0 (II aVO! able) II II) ANALMAS'> ICONCIONT"ATlON

I

(ll

MASS

I

a. CONCENTRATION

"1

5. INTAKE (optional)
a. LONG TERM. AVERAGE VALUE

-I

b, MASS

YSES

cONeELiJ~ATIO:'-

h_1

MASS

l

11..1.· ANALw -YSES

t.

-NO OFI

S, Bromide (24959-67-9) b. Chlorine, Total Residual c, Color
d. Fecal

i-.

i"X

Coliform 8. Fluoride (16984-48·8J
f. NltrateNitrite (as NJ

X

X
;X
PAGE

EPA Form 3510·2C (8-90)

v-

CONTINUE ON REVERSE·

000476

, Ill:fVl v-o

I,..V·"'''''U ED

FROM FRONT
3 .......... F'LUENT a. MAXIMUM DAILY VAL.UE
b.

L POLLUT~ ANT AND CAS NO. (if available)

2. MARK 'X'

4.UNITS
C.LONG TEf;M 8-~!"G. VALUE d.NO.OF (i at'ada ,'J a. CONCENANALTRATION b. MASS

5. INTAKE (OpriOl/ill)
LONG TERM AVERAGE VALUE
fl.

a .. E",p£"vl!:£:' .. ,o:V" .0SENT

b.ut:: ~
">;NT

MAX'~ff~v;8a~tY VAL.Ue

C;ONC;E~~JRATION

ld

MA""

CO"'CENTI<AT'ON

g. Nitrogen,
TotalOrganrc
(n.~

'"

{ .. ] M"5"

COf'H".~'''!",,,'t'o,,

(,) "'A';5

YSES

CONCE~'''!''AT'ON

).NO.OF ANAL-

ld

MA"s

YSES

NJ

X
)(

h.Olland

Grease
I. Phosphorus (as P), Total
(7723-14--0)

X
X
X

j, Radioactivity (1) Alpha,

Total
(2) Bota,

Total
(3) Radium,

Total
(4) Radium 226,Total
k. Sulfate (08 S04) (14808'79-81 t Sulfide
(tUS)

/<
;<.
X ;< X
X
X
.
I

..

m. Sulfite
(as S03)

(14265·45-3)
n. .. surfaCUlnts

o. Aluminum,
Total (7429·90-5'
P,'_ ~_ar!Um. Total-' -,

(744()'39-31

I'i-

X
)(

q.

Boron,

Total, (744()'42-81 r. cobalt, Total (7440.48-4) .. -Iron, Total
(7439-89-6)

;< ;<

t. Magnesium, Total (1439·95-4) lJ. Molybdenum, Total {7439·98-7l v. Manganese, Total (7439.96-5l

'/

X
><

w. Tin, Total
(144Q·31.5)

x, Titanium•
Total

(7440-32·6)

EPA Form

..
;/
2

Oil

0)

r!'"

\1.

..................:0-' ................. .

000477

£,,:,

-

CONTINUED FROM PAGE 3 OF FORM 2-C

•

EPA I.D. NUMBER

(copy from Item 1 of Farr" ') OUTFAl.L. NUMBER

......-

P"I

6H

uOoo6/2

OOl

PART

c~

If you are a primary industry and this outfall contains process wastewater, refer to Table 2c-2 in the instructions to determine which of the GC/MS fractions you must test for. Mark "X" in column 2-a for all such GC/MS fractions that apply to Your industry and for ALL toxic metals. cyanides, and total phenols. If you are not required to mark column 2·a (secondary industrie..., nonprocess wastewater Ductalls, and nonrequired GC/MS fractions), mark "X" in column 2-b for each pollutant you know or have reason to beHeve is present. Mark "X" in column 2-c for each pollutant you believe is absent. If you mark column 2a for any pollutant. you must provide the results of at least one analysis for that pollutant. If you mark column 2b for any pollutant, you must provide the results of at least one analysis for that p~l!utant if you know or have, reason to believe it will be djscharg~d in concentrations of 10 ppb or .greater.lf you mark column 2b for ~crolein, acryl~nitrile, 2~4 dinitrophenol, or 2-methylA, 6 dinItrophenol, you must provIde the results of at least one analySIS for each of these pollutants whIch you know or have reason to beheve that you dIscharge In concentrations of 100 ppb or greater, Otherwise, for pollutants for which you mark column 2b, you must eithp.r submit at least one analysis or briefly describe the reasons the pollutant is expected to be discharged, Note that there Bre 7 pages to this part; please review each carefully, Complete one table (all 7 pages) for each outfall. See instructions for additional details and requirements.

~.;.

,

1. POLLUTANT
AND CAS
NUMBER

aTE5T
ONO

(if available)

" QUIR-

..

%. MARK 'X'

BE' BE' I.I\iVI< I..EVE

b.

e.

PRE· SENT

SENT

..

3. EFFLUENT
3. MAXIMUM DAILY VALUE
CONCIl:NTRJlTION

4. UNITS
c,LONG TIf~M ~;1,~G. VALUE d NO.OF I ava1/a e) a. CONCENANAL' TRATION YSES

5. INTAKE (optional)
AtJ'E7Pl2;1z

b. MAXI~Pr~lJ~Ha'i1rc{ VALUE

"

101

hi

MASS

II'!
CONCENTRATION

(zl

MASS

cONcJ!t~~I"'ATroN

b, MAss

fl}

It}

MA$S

CONCENTRATION
'.

;,~RLttE lzl MAn

b, NO.OF ANALYSES .

METALS, CYANIDE, AND TOTAL PHENOLS
1M. An'timony,

,

!.>

"

Total (7440.36-0J
2M; Arsenic, Total (7440·38·2) 3M. Beryllium, Total. 7440-41·7J 4M. Cadmium, Total (7440·43·9)

)(

X.
X
)<

5M. Chromium,

Totel (7440·47-3)
SM, tower. Total (7440-50-81

X
)(

7M.lead, Total (7439-92-11 8M. Mercury. Total
(7439-97-6)

X

X
X

"

..".

9M.' Nickel. Total
(7440.02·0)

10M. selenium, Total (7782-49·2)
11M. Sliver, Total (7440-22·4)
.'

X
K

12M. Thalllum, Total {744Q"28·0} 13M. Zinc, Total (7440·66·6) , 4M. Cyanide, Total (57-12-5) 15M. Phenols,

;<
)(

X
)(
OESCRIBE
RESULTS

Total DIOXIN 2,3,7.a·Tfltra·
chlorodiben'to-P· Dioxin (1764-01·6)

,
PAGE V-3

"

.

"

,"::'?", :'C'
000478

X

EPA Form 3510·2C (8-901

CONTINUE ON REVERSE

...""'''', .................. -MTHE FRONT
I. POLLUTANT AND CAS NUMBER '. (if DIlDilable)
2. MARK 'X'
a.TEtl;T all:- Co ElE,N4 .. ,EVil! l",IlVIl "RIOS&HT QUIl'!'&NlT

..-

b.

..X X

3. EFFLUENT
a. MAXIMUM OAIL,Y VALUE (0) ell ", ... n b. MAXI~,'ir;;u~Haf;~JY VALUE
(0)
i:::O",CIiNTRAT,ON

4. UNJTS
C.LONG Ttf!,<M !/;~r.5" VALUE d NO.Of' I ovalO e

5.INT-AKE (OptiOltQI)

eO",eeNlTRATION

{~J MA5$

CONCI!:~VR"'TIO'"

(~,

ANAL-

a. CONCENTRATION

M ... ,.5

YSES

b. MASS

(I)

A:h".'Ro,.~1:.tEARL~IFl" CONlC,l.:NhI MAU TffATION

b. NO.OF ANALYSES

GCIMS FRACTION - VOLATILE COMPOUNOS
1V. Acrolein

(107-02-8)
2V. Acrylonitrile (107-13-1J
3V~

X

Benzene

(71-43-2)
4V. als (ChIaromethyl) Ether
(542-88-1)

X

5V. Bromoform

(76-26-2)
6V. Carbon
(56-23-5)
T8tr.Chl~rlde

X
X
X

7V ~ Chlorobenzene

(108-90-7)
8V. Chlorodlbromomethane (124-48-1)
9V-. Chloroethene

X
X
X
.

........
.
....

(76-00-31
10V.2oChlor<>o Gthylvlnyl, Ether

(110-75-8)·
,11 V.,',Chloroform

.
..

(67-66-31+
12V. Olchlorobromomethane (75.27-4) 13V.Olchlorodlfluoromethane '

)(

X X
)(

(76-71-81
14V. ,1,l-0IchIOroethane (75.034-3)

!ethane (107..Q6-2)

,16V.1.2·0Ichlor o·

X

!16V.1,1.0Ichloro. ; ethylene (75-35-4) 17V. l,2-0lchloropropane (78-81~5)

X

X

l8V.1,3·0ichI0fQ......... (542-75-.)
. 19V. Ethylbenzene (10Q.-41·4) 20V. Methyl Bromide (74-83-91 21V. Methyl Chloride (74-87-3)

X

X
><

X
1J.
.•"n.

\

,
"

t 000479

EPA Fo,m 351

AGEV

......- ...........................

CONTINUED FRUM

1. POLL.UTANT
AND CAS NUMBER
(i(ouailable)

~ARK 'X'
aTli:!IT • fiEc.ee:IN .... I,.U::Vl!: I,.II!Ve: lUI" fOREAII~ QUI"S!tNT U:NT

t"AU~

v_

-

1 '

~

-

~

.......

,

~

'.
a,

3. EFF'LUENT

~fb

MAXIMUM DAILy VAL.UE

b. MAX!M~M 3~ (,(auaia
CONCl<NTRATlON

f:CY e)
Izi

VALUE
M"'SS

C• • NG

{ NI I CONCE"'TRATION

I

hI

"''''S5

II I

CONCE~'J.. ATrON

-

!

T1if,M
I

"ih!:j" aualla e
(zJ

4. UNITS
VALUE d NO.OF
ANALMASIO a.

5. JNT~i1+-'(optio"aIJ

CONCEN-

VSES

TRATION

b. MASS

.&~'I'I'~~NG l,"Ai M

E

b. NO.0F:
ANAL.-

(.I

CONCItNTHATIQN

fzl

MA"

YSES

GC/MS FRACTION - VOLATILE COMPOUNDS (conHnLled)
22V. Methylene Chloride (75-09-2) 23V.1.1.2.2-Tetrachloroethane (79-34-5) 24V. Tetraehloroethylene (127-18-4) 25V _ Toluene ('08-88·3) 26V. 1.2-Transotchloroethylene (156-6o-5) 27V.1.1,1-TrIchloroethane (71-65-6) 28V. 1,1.2·Trlchloroethane (79-00-5) 29V. Trichloroethylene (79-01-6) 30V. Trlchlorofluoromethana
(75..-69-4)

'I<

?'
f..
X

~;"

.

f..

;

X
X
/

X
X

31V.,Vlnyl Chloride (75-01-4)

Ix
X
...

>

GC/MS FRACTION - ACID COMPOUNDS

.. . /

!1 A. 2-Chloropheno
i (95·57-8)

!2A. 2,4-0Ichloroi phenol (120-83-2)
13A. 2.4-Dimethyl. phenol (105-67-9)

X
X X
.

!

: 4A. 4.S-0Initro-QCresol (534·62-1)

! ,phenol (51-28-5)
6A.2-Nitrophenol (88-75·5) 7 A. 4-N itrophenol (100-02-7) SA. P-Chloro·MCresol (59-50-7) 9A. Pentachlorophenol (87·86·5) 10A. Phenol (108·95·2) 11 A. 2,4,6·Trichlorophenol . (88-06-2)

; SA. 2,4-Dinitro-

X

X

X
I(

X

i I
I
I

,
I

I
I

I

X

.!

I
""

I
000480

y

I

.
,.,.II.! .,."""""",""'''''

........... .,.

... ,.,. ......... u .."

...

~.~

...

~---

FROM THE FRONT
2. MARK 'X'
a.TE'IT
QU ... •

f. POLLUTANT

3. EFFLUENT

4. UNITS
C.LONG

5. INTAKE (optional;
...

AND CAS NUMBER (i/ available)

oN" l.'''''''' "AI<;OIl"

b.

8"*

C. DE.. lIit"'E
seNT

$11':"'''

...
X
X
X

a.

MAXIMUM DAILY VAL.UE

1;:1. MAX1r"W';iu~Sar;;&t
CONt!;;N""AT''''N

VALUE
"'AS,.

T/ff,}tll!'i,i£f::y'

VALUE

CONCENT ..... TION

I"

[I) ... "'SS

GC/MS FRACTION
1 B. Acenaphthene (8:J..32-9) 28. Acenaphtylene
(208*96-8)

BASE/NEUTRAL COMPOUNOS

'"

d.NO.OF ANALVSES

a. CONCENTRATlON

III

C""',.l>:NP' .. flO ....

[ol

I tl ..... !>S

b. MASS

'~'t:"'o°Aro:,~

tEARL"CE

b. NO.OF
ANALVSES

10)

CONCl!N* T ..... TION

It! ........

,

3B. Anthracene (120-12·7) 48. Benzidine o. (92-87*6) 58. Senzo (0.) Anthracene (56-55-3)
6B~

-.

X

X
)(
'"

Senzo (0.) Pyrene (SQ-32.8)
7a~-3,4--Benzo.

fluoranthene

(205-99-2)
8B. Sanzo (,hi) Perylene (191.24-2) 98.- Senzo (It) F luor.nthene

X

..

~

X X X
X
rC

etho=y) Methan~_

(207.(l8-9) 10B. Sis (2-Chlort>* (111-91-1) _-

11 B. 81. (2·Chlorodh,.,) Ethllt';"" - . .,

(111-44-4) '12B.8is(2.ch1oioUoP"'PJ'#I El!loW 11 02-60-"
138. Bit (2-Ethylhe:cyl}Phthalate-

(117-81-7)
148. 4-Bromo· phenyl Phenyl ..•, Ether (101-55·3) 158. Butyl Benzyl Phthalate (85·68·7 .16B.2·Chloronaphthalene -(91-58·7) 17 B. 4-Chloro· phenyl Phenyl Ether (7005-72·3) 188. Chrysene (218-01-9) 198. Oibenzo (e,h) Anthracene

X

><

X X
X

X

(53-70-3)
20B. 1,2·01chlorobenzene (95·50-1) 218.1.3-Dlchlorobenzene (541.73-1

X

.
,.

X

«

-

000481
CON ' E ON PAGE V-7

PA ~6

\,.UroI IlrllU~1J rn",HVI ~";;"~i';- - -

,
3, EFFLUENT
C. e,"I..Il!VIE '0'

t. POL.L..UTANT
AND CAS

~ARK'X'
aTI£!l.T

~'.

....

-~

4_ UNITS
c,LONG

5.INT,t.,
A.

~

(optiOlwfj
b. NO.OF
ANAL,

NUMBER
(if at>ailable)

,

Q,!,n-

.... .E· ".. "'b.
1..,150 V t!.

eO?;-

a. MAXIMUM OAIL Y VALUE
CO ..

b. MAXI~W;;1JJHa~fe{ VALUE
COMC"N~""''''oN

Tfffar;}af'ta'tFer'

VALUE

d. NO.OF
ANALVSES

a.

SEMT

seNT

cL~'Jn ... .,.,o.. 1

(d ... "'''''

h'

ld ... "ss.

C<l,..C,,~'~J.... TlUN .

I.J ...... ,,'"

CONCENTRATION

b. MASS

~·Ei?....NGGE ~\RL"0E
Id ... ",.,

,

II)

CONeF.N_ T""',,"'ON

YSES

GC/MS FRACTION
228. 1.4-0ichIOf'O· benzene (106·46·7 236. 3.3'-Dichloro benzidine (91·94-1) 248. Dlethyl Phthalate (84-66-2) 258. Dimethyl Phthelate (131-11-3) 26B. D1~N·Butyl phthalate (84-74-2) 218. 2.4-0Initrotoluene (121~14-2) 28B.2.6-0Inltf'0tolU8n8 (606-20-2)

BASE/NEUTRAL COMPOUNDS

(contim~ed'

X
"

X

><.

X
X

X

1
"
32B~

X
X
I

,

29B. OI-N~Octvl 1~~f1hthalat.
~,~ 117~4-0)

1 ,2.0'Oh••V'. fazlne (GIl Azoen¢) (122-66-7

X
X X
X

B.:-Fluonmthene

,l2lM>44-0), '

. ,

-(11-47:..t)
(78-59.1)

Fluofene (88-73.7) " ,

;,~,

1118-7"1) """
348. Hex8-

'-'

.,
.

chlcrobutlldlene (87·88-3) 358. Hexachloro~ eyclopentadtene 368. HIII)(BChloroethane (67-72-1) 378.lndeno
(1.2.3-cd)

X
X
)(

(193-39-6)

Pyrena

,

X X
.

388. lsophorone 39B. Naphthalene (91-20-3) 408. Nitrobenzene (98-95-3)

'f. X
,

1 418.

N·Nltrosodlmethylamine I (62-75.9) 1 428. N_Nltrosodl_ I N·Propylemlne i ;621-64.7)

X

X
tA..gO\
PAGE V-7

........ Je___

,.. .... "

000482

.&:"ill"_"~

........................"",.. .,..".,..

,-"Ul'tI ll'll ....

ED FROM THE FRONT
2. MARK 'X'
8.T"'!IT

.._>~

..

"1. POL.LUTANT
AND CAS

NUMBER
-(if allfJilablc)

,N<

Q~I'"

..-

"'l!.VI!

b. ... "".
lIeNT
"Rli'

...,eVI! seNT

e.

A.-

!lI.E-

8. MAXIMUM DAIL.Y VAL.UE
co .. c

4. UNITS J. EFFLueNT b. MAx"TrvH..!_M 3_1 ~fcY VALUE "C.l-ONG T1f/~l~aff.:I'M~r- VALUE d. NO.O (,I (It'{I! a c) Fa. CONCENANAL,

-

5. INTAKE: (optiol/iJI)

r,:!.'},. . .

TlON

I

hi ...... "5

1,1

CONC"".'.~.~~

III

"'A:'i~

CONe "NT" .. T,nN

(,)

(dM"'SS

YSES

TRATION

b. MASS

,~·r~?Ar;,~ t-EA1~E ill Co"C""· hi MA'li1l TU ... T'ON
..

b.NO.OF ANAL' YSES

GC/MS FRACTION - BASE/NEUTRAL COMPOUNDS
436. N·Nitro· sodiphenylamlne
(86.3()..6)

(con tinued)

X
X

"
,

448. Phenanthrene
(8S-01-B>

.

456. pyrene (129-00-0) 46B. 1,2,4· Trl· chlorobenzene (12().82-1)

X
X X
-:

GCIMS FRACTION - PESTICIDES
1P. Aldrin

(309-00·2)
2P. a·BHC (319-84-6) 3P. il-BHC (319-85·7) 4P. "Y·BHC (SS-89-9) Sp.e-SHC (319-86-8) GP. Chlordane (S7-74-9)

X
X
K

X

X
X
;X

7P.4,4'·00T (50.29·3) SP.4,4··ODE
(72·55-9) gP. 4,4'~DDO (72-S4-6) lOP • DIeldrin (6Q.S7-1 ) 1 1P. a_Endosulfan (I1S-29-7) 12P. fj.Endosulfan (115-29-7) _ 13P. EndO$ulfan Sulfate

X
X

X

X
X

('031--o7-8)
14P. Endrin

(72·20-8)
16P. Endrln Aldehyde

X
X
-.

I I
-.
"

(.7421-93-4)
16P. Heptachlor (76-44-8)

- -_.

X

.

............

000483 -~.~
« ............ n ...... .-~#

....

I':::PA I.D. NUMBER (copy (rom liNn 1 uf Forml:'IOUTFALL NUMBER
~Ul"

111'llUC;V rnUIVI

r~,Q v-v

OHC
c..
,,~.

JOlO12
3. EFFLUENT

4,£\
'I

I

00:14. UNITS
5.
3. CONCEN'

,~

,
(oprional)
b. NO.OF
ANAL'

; 1. POLL.UTANT

L. MARK 'X'
aTlOilT

INTA,~_

1
;

AND CAS NUMBER (if available)

,"'<:;

QUIR'

"Ii'

..

b.

"E'

,~'"'' .... t;.
9,,"'T

'"'"v" . Alt·
S,,"'T

a. MAXIMUM DAILY VALUE

b. MAXI~H~lJ~i?a~t{ VAL.UE

C.LONG T!ff(1'iJm~a'br:/t. VAL.UE d. NO.OF

,d
CO"'CL",TRJlTlO'"

hI

MASS

10' CONCc"'T"ATH>N

hl ...... ss

CD",c,,~~I"ATlO'"

ANAL'

III

MA,.S

YSES

TRATION

b. MASS

~.",~~N~~EARr...~E
(,I CONe .. ",_ TRATIO".

hI

MA.S

YSES

; GC/MS FRACTION - PESTICIDES (continued)
117P. Heptachlor 1 EPoxide j (1024~57~3)

X

I
,"

j 18P. PCB-1242
1(53469~21'9)

x:.
><
X

~ 19P. PCB·1254 ';(11097-69.1)

1

20P. PCB-1221 (11104-28·2)

j , (11141.16·5)

'21P. PCB-1232

><
X
X
X

.

,

122P. PCB·124B ' (12672-29-6) i23P. PCB·1260 , (1109&-82-5) 24P.
PCB~1016

(12674-11~2)

I

25P. Toxaphene ' (8001-35·2)

X

•

I
9

000484
______ ..Lt>.n\

_

~.;

EPA 1.0. NUMBER

(cop)' from Item 1 of Form 1)

~

PLEASE PRINT OR 1 . .: IN THE UNSHADED AREAS ONLY. You may report som~ or all of this information on separate sheets (use the same format! instead of completing thc$Q pages.

rS~E~E..~N~S~T~R;:.:;U~C~T~I~O~N~S~. . I

- - - - -....

~~. ~ ~ .:~;:.>~. ~1~.~~;'~..:~'tiI;-.:-<...

C \4 00 00 <0 I '2
t.

~

...

;,~_s'"

QUTF'ALL NO.

V. INTAKE AND EFFLUENT CHARACTERISTICS (continued from page 3 of Form 2·C) ..S. -

--< =;. ~:t:;;~~:::

~'~;~:~"

~

-~" '~'~-"":'

3. UNITS

~

0 0 2.
4. INTAKE (optiollal)
~
b. NO. OF ANALYSES,

PART A· You must provide the results of at least one analysis for every pollutiJnt in this table. Complete one table for each outfalL See instructions for additional details.
Z. EFFLUENT
I.

POLLUTANT

a.

b MAXIMJ,lM 30 DAY VALUE MAXIMUM DAILY V A L U E ' (if auailable)

C LONG Tl';:F

.

(if

auallable) .
(2)

f.t,VRG

AL
MA5"

d

NO

OF

(.~p",cir~' {(blank)

1.)
C N

rzl
\.ItA

MJllIS

(ll
CONC£NT .. ATION

(2} MASS

(I)
CONCENTFIATION

ANALYSES

\.~OANT~~~~

b.

MASS

a. loJ

LONG TERM
{2} MASS

CONCENTlfATlON

a. Biochemical Oxygen Demand (BOD)
b. Chemical

0 1157 n .)
.0

Gei(lW' . 4~i' .. ,,--t;d",

J, ..... ;t"

(COD)

Oxygen Demand
c. Total Organic

13
5
-

c ~

r-

Carbon (TOG)
d. Total Suspended

~

4

0

""\')

Solids (TSS)

.::J

e. Ammonia (as N)

0

~

10
VALUE VALUE VALUE

VALUE

f. Flow

0 VALUE

I . 2.
.

M G

D
VALUE VALUE

g.Temperature
(winter)

0 ---15
VALUE

a
~

0C

VALUE

C
VALUE

h.

Temperature

(summer)

I S-- - :> 0
MINIMUM

_

"c
MAXIMUM

,

VALUE

0C
STANDARD UNITS

VALUE

MINIMUM

MAXIMUM

LpH

7.

~5

PART B ~

Mark "X"ln column 2~a for each pollutant you know or have reason to believe is present. Mark "X" in column 2~bfor each pollutant you believe to be absent. If you ma~'column 2a for any pollutant which is limited either directly, or indirectly but expressly, in an effluent limitations guideline, you must provide the results of at least one analysis forthatpollutant. For other pollutants for which you mark column 28, you must provide quantitative data or an explanation of their presence in your discharge. Complete one table for each outfall. See the instructions for additional details and requirements;
Z. MA'ftk'"
I.lp

I. POt.LUTANT AND

3. EFFLUENT

4. UNITS
C.LONG

5. INTAKE {oprional}

CAS NO. ({favailable)
8.

8. u- b. BE:v

'it E:'

u~~~

a.

MAXIMUM DA1L.Y VALUE

b.

!le:NT

$"l!:NT

I) CONCItN~IH'TION

MAXI~ff~u~Ha,?r;{ VAL.UE
( I (2}
MAS,>

hI

"'lA$S

CONCEN'TRATlON

( CON(";£:N~1lA,T10N

Tlfrar;;Gl~a"brcr' VALUE
{2}
MASS

d.NO. 0 ANALYSES

a CONCEN
TRATION -

b. MASS

A;;'E'R~NG~l,~RL~E'
CONCEN'T'RA,T.ON

td

ANAL~
YSES

NO.OF

"'lASS

Bromide

124959·67·9)
b. Chlorine.

V I"

Total Residual

X

c. Color
d. Fecal Coliform e. Fluoride

'X
X

I' 6984-48·8)
f. Nitrate-

X

Nitrite (as

N)

X
P4r..F" V.I

EPA Form 3510-2C (8-90)

CONTINUE ON REVERSE

000485

ITErlJ V·D

\...VI\l1 "\Iv .........

FROM FRONT
. 3. EFFLUENT 4, UNITS 5. INTAKE (o{ltir!/lI1/J
b. MAXIMUM 3,0 OAY VALUl::': c,LONG Tt;:RM AVRG. VALUE d (ifauQllabl,,) ~ (I(at'mlabl,') . NO.OF
C'''''CEN'T><AT'ON
<l l.ONG TERM AV"ERAGE VALUE

1. POLLoUT.
ANT AND ,

2. MARK 'X'
- b at',;t..~i;;~~ L"'V"-O a. MAXIMUM CAlLY VAL.UE
pRESI<NT All' SENT

(i{auailable)

CAS NO.

I CONCE~.VRAT'ON

I
ld
""A'SS

I

(:l

'

( 1

iJ.

CONCEN-

,ANAL-

TRATION

MA<;"

COtH':Ie. ""TI'lATla",

(.'1

b.

MASS

-=r'J'.

). NO.OF
ANALYSES

MA$S

YSES

CONCEN'TIOAT'ON

Id

MA""

g. Nitrogen,
(usN)
Total Organ ll::

,/
"

h. all and

.J

Grease
I. Phosphorus {as rl, Total
(7723·14·0)

('\

><.
~/

..

J. RadioactivitY
(ll Alpha, Total (2) Beta, Total
(3) Radium,

'"

X
-

Total
(4) Radium

>(
X

226. Total
k. Sulfate
,.. S04) (14800'79-8)

rv
,A

v

,. Sulfldo
(0# S)

m. Sulfite (.. S0 3)

V

I'

(14265·45·3J . . n. surfacunts

/"

,

;;<
I '\

.
1. ,
~,_c
:"';1,,"

o. Aluminum,
(7429·9().5) p. B~r,lum, '.' Total' (7440-39-3)
q.

Toto'

-.,{

X
I'

'",
-~~~

'''"'

Boron, Toto' .

(744fl.42-81

-./

r. CObal\
Total (744fl.48·4)
.. Iron, Total

t<

17439·S9·6)
t. Magnesium,

X
'X
-./
I'

Total (7439·95·4)
u. Molybdenum,

Total (7439·98·7) v. Manganese. Total (7439·96·5)

X
X
~ _ • __ • (S-90)
~-_._-

w. Tin, Total
11440·31.5)
x, Titanium. Total (744Q.32·6)

000486 - - --

1&_.:'"

~

EPA

E V·3

CONTINUED FROM PAGE 3 OF FORM 2-C

PART C _ If you are a primary industry and this outfall COntains process wastewater, refer to Table 2c:2 in the instructions to determine which of the GC/MS fractions you must test for. Mark "X" in column 2.a for all such GC/MS fractions that apply to your industry and for All toxic metals, cyanides, and total phenols. If you are not required to mark column 2·a (secondary industries. nonprocess
wastewater outfalls. and nonrequired GC/MS fractions). mark "X" in column 2-b for each pollutant you know or have reason to believe is present. Mark "X" in column 2·c for each pollutant you
believe is absent.lf you mark column 2a for any pollutant, you must provide the results of at least one analysis forth at pollutant. If you mark cotumn 2b for any pollutant, you must provide the results of at least one analysis for that pollutant if you know or have reason to believe it will be discharged in concentrations of 10 ppb or greater. If you mark column 2b for acrolein, acrylonitrile, 2,4 dinitrophenol. or 2·methyl-4, 6 dinitropheno.l, you must provide the .results of at least one analysis for ~ach of the.se pollutants which. you k,:ow or ha~e reason to believe that you. discharge in concentrations of 100 ppb or greater. Otherwise, for pollutants for whIch you mark column 2b, you must elthflr submIt at least one analYSIS or briefly descrIbe the reasons the pollutant IS expected to be discharged. Note that there are 7 pages to this part; please review each carefully. Complete one table (all 7 pages) for each outfall. See instructions for additional details and requirements. 1. POL.L.UTANT
AND CAS NUMBER

b.

EPA 1.0. NUMb,",...! (copy from llem 1 of Forr- • J OUTFALL NUMBER
I--

~I

p"4"

,

OH

0000 (;/2-

002..

I

,

aTEST

oNG

(if available)

QUIR-

..

2. MARK 'X'
fiE;·

3. EFFLUENT

4. UNITS
T1fra'ta~a'brer' VALUE d NO.OF a. CONCENANAL' TRATION YSES C"NCl'l:~~lnATION {d MASS
C.LONG

C. aa;LII!!;V~

tolEVE
PRE-

a. MAXIMUM DAlLy VALUE
CONCEOfTnAT1OOf

b. MAXI~Pr~v;Ha'i:~1' VALUE
II')
CONCE:NTRATlON {z} MASS

AB-

SENT

SENT

Id

b. MASS

AVER
(lJ
-

5.- INTAKE (optional) a. LONG TERM b. NO.OF
GE

1:)

MAS'

COPiCEN· T!'t .... TION

VALUE ld ....... "

ANALVSES'. >,~

METALS, CYANIDE, AND TOTAL PHENOLS 1M. Antimony, Total (1440.36-0)
2M: Arsenic, Total

-

---

-,

X
X

(7440-38-2) 3M, eerylllum, Total,744O-41-7) 4M. Cadmium, Total (7440-43-9) SM. Chromium, Total (7440-47-3)

X
X X

6M, C<>ppot, Total 17_60-6) 7M, Lead. T"",) 17439-92-1)
8M. Mercury. Total (7439-97-6) 9M: Nickel, Total (744Q..02-0) .._. 10M. Selenium, Total (7782·49-2) 11M. Sliver, Total (7440-22-4) 12M. Thallium, Total (7440·28-0) 13M. Zinc, Total (7440·66·6) 14M. Cyanide, Total (57-12·5) 15M. Phenols, Total DIOXIN 2.3,7,8-T etra· chlorodibem:o-PDioxin (1764-01-6)

X

-

X

X
"
,

X

X

t<
X
'>(

X

;<
-

"

"

>,

.

-,',<
000487

--<

DESCRIBE RESULTS

><
PAGE V·3

EPA Form 3510-20 (8-90)

CONTINUE ON REVERSE

CONTINUED

rHUMI .... ""

NT r,...........
3. EFFLUENT
8. MAXIMUM OAIL,Y VALUE b.

I. POLLUTANT

2. MARK 'X'
&Te:ST
ING

4. UNITS
'.CONG T1if<M !l~r.r' VACUE d NO.OF I OUOI a e ANAL-

5. INTAKE (opriOllal)

I

AND CAS

,

NUMBER
(If IJIlGiIGble)

QUilt-

.,-

I"Ili:Vlt

b.

II"~

liE;I.II&Va

Co

I'"IIE-

saNT

sa NT

.,-

MAXI~}f~IJ~iYa~~';fVALUE
I,)

a.

f,)
CONe E: NT" ATIOH

(<tjMAn

CONe&NT",,,nOH

hI

MASS

CONC.l!:~~IRATION

hI MA~S

VSES

CONCENTRATION

'a.
b. MASS

LOANG ~E"'~ ...

b. NO.OF

Itl

CONcaNTRATIOfi

hi

MASS

ANALYSES

GC/MS FRACTION - VOLATILE COMPOUNDS
1V. Acrolein (107-02-8) 2V. Acrylonitrile
(107~13-1)

X

.

><
X

av. Benzene (71-43-2) 4V. Bis {ChloJ"O-o methyl} Ether (542-88-1) . 5V. Bromoform
(75~25-2)

X
X

BV. Carbon Tetrachloride (56-23-5) 7V. Chlorobenzena (106-90-7) BV. Chlorodlbromomethane (124-48-1) 9V. Chloroethl1ne (76~OO-3) " 10V. 2-ehloro~ ethylvlnylEther (110-75-8) '11 V .. Chloroform (57-86-3) :; , 12V. Dlchloro· bromomethane (75-27-4) 13V. Olchlorodifluoromethane (76-71-8) 14V.1.1·0Ichloro ethane (75-34-3) 16V.1.2-Dichlor oethane (107..Q6-2) 116V. 1,1.0Ichloro ; ethylene (75·35-4) 17V.1.2-01chloropropane (78-87-5)
18V.l,3·Dk:hloropropyl.... (542-75-6)

X

X X
X

X
X

.

.

X

X
X

X
)(

X
X
><

. 19V. EthylbenZllIne
(10Q.41-4)

20V. Melthyl Bromide (74-B3~9) 21V. Methyl Chloride (74-87-3)
__ ..............
~n

X

t<
\

.

EPA Fo,m

\ 000488 .... ,.. ...,..

• ....... " . . . . . . . . . .,. ,~ iii!

<;vr<l INVhU "HVM~1. POL.LUTANT ARK
NUMBER AND CAS
(If allallable)
T l.~~~~' ai:':~1'
Re:I"~E'

I
'X'

-

, ,

- Id

- - .VALUE
MASS

3. EFFl.UENT
8. MAXIMUM DAIL.Y VALUE

l.~l!;~~'
Aa-

b.

MAXI~Prr;:u~Harg(;r

c. • NG
co ..

--

!

-

-

-

1

4. UNITS
T{if,.M ~il;l:j" VA<;UE d NO,OF I GlJalla e a. CONCEN· ANALTRATION

5.INTAi"'·4(optiotlal)

QUIA"

SIl!:NT

SIlI:HT

CONCE!.lJ"'''TIONI

h-I

MA5$

CONCENT""TlON

hI

ce~~Jf'l"TrON

b. MASS

Aih,-'R~~1:t,"AL~E
(I

b. NO.OF
ANAL'
YSES

lzl

MASS

YSES

f

CON(;e: ...•

TIt"T'ON

hI

MAU

GC/MS FRACTION - VOLATILE COMPOUNDS
22V. MethVlene Chloride (75-09.2)

(continued)

X

23V.1,1,2,2·Tstra.
chloroethane

(79·34-51
24V. Tetrachloro·

><
X
.

,

~.~.

"

ethylene (121·18-4)
25V. Toluene

('08-88·31

><
X
\(

26V. 1,2-TransDlchloroethvlene (156·60-5)

,

27V.1,1,1-TrI.
chloroethane

(71.55-6) 28V. 1,1,2-Trlchloroethane (79-0o-S)
29V. Trichloroethylene (79.Q1·6) 30V. Trlchlorofluoromethane (75·69-4) 31V. Vinyl Chloride (75-01-4)

X
.

X

.

X
X
.,.
'

GC/MS FRACTION - ACIO COMPOUNDS
11 A. 2-Chloropheno

..
..

<

1(95·57-81

X
•

I phenol

1,2A. 2,4·01chloro-

(120.g3~21

r<
X
.

..

i 3A. 2,4·0imethyl· i phenol (105-67·9)
: 4A. 4,6-0Inltro·0Cresol (534-52·1) SA. 2,4-0Initro· phenol (51-28·5) GA. 2-N itrophenol (88·75-5) 7 A. 4·N itrophenol (100.02·7) SA. P-Chloro·M· Cresol (59·50·7) 9A_ Pentachlorophenol (57-86·5) lOA. Phenol (108·95·2) 11 A. 2,4.6-Tri· chlorophenol , (88·06-2)

X

X
X
)(
X
I

;<

I
I

I

I -I
I

I

X

I
"""

I
I

I
i

I
000489
,...,...

X

......... ,

..

............

,.".

",

... ,

",..,,~'""

....,.'"

-_ ....

NUED FROM THE FRONT
2. MARK 'X'
iJ.TE"T

1. POLLUTANT AND CAS
NUMBER (if auadable)

Q\.JI"'-

".

b. e .. • .. ,,,"ve;

.0'

1',..". .Il!:NT

... aVE

c..

• IlNT

...
)(

"E-

8_ MAXIMUM DAILY VALUE
C:ONCENTR",TIQN

b. MAXIM~M

31 'i:fc;t (Ir(~UaJa)c

3. EFFLUENT
VALUE le,LONG TlfftM

Illl'(ll/IIC)

"':tFt

4. UNITS
I NO OF t.. ANAL- a. CONCEN' TRATION
YSES

5. INTAKE (optiOfll.llj

G . VALUE

1"

(;1

MASS

CONCli~';"ATlON

III "' .. ""

c<,.,,,-,,,l~I""TlO'"

b. MASS

III ....... "

(0)

A'~'''''~~~~"t,EARL~"" CoNce ...• I" ........ T" .... TION

b, NO.OF ANALYSES

GC/MS FRACTION - BASEINEUTRAL COMPOUNOS

1 B. Acenaphthene (83-32-9) 28. Acenaphwlene
(208·96-8)

X X
X
X

38. Anthracene (120-12·7) 48. Benzidine (92-87-5) 5B~

Bemo (a)

Anthracene (56-55-3) 6B. BanzO (a) pyrene (50-32-8) 7 B~:3.4-B.nzofluorenthene (205-99-2) 8B. Sanzo (ghi) Perylene (191-24-2) 98/Sanzo (If) Fluoranthe-ne (207-08-9) lOB. Bitt (2·Chloroethos)') Methane (111-91-1) 11 B.Bls (2·Chlorottthyl}.Ether·;" ("'-44-41'
I

;;<

.-""-,-

X
X
X

X
X
X

"""""I e-{102-60-1)
138. Bl, (t·Ethyl. hell(~l) Phthalate (117-8'-71 149. -4-Bromo~ phanylPhenyl'c Ether (101·55~3) 15B. Butyl Benzyl Phthalate (85·68·7 168. 2·Chloro~ 'naphthalene -(91-58-7) 178.4oChlorophenyl Phenyl Ether (7005·72·3) 18B. Chrysene (21S·01·9) 19B. Oibenzo (a,h) Anthracene (53·70·31 20B. 1,2·Dlchlorobenzene (95-50-1 ) 218.l.3·Dlchla r a· benzene (541.73·'

12B. 8isl2'-'

X

X
X

X
X

f.

X

_

.
,'.

;x.
y,
PA ~.6

000490 ' EON PAGE V-7 CON

~---------

UMBE"
\.oVI'4I II\lUI.::U rnv'.'·,

;-

-

~

.
-':~

1. POLLUTANT
AND CAS NUMBER (if ollailoblr)

IIIMB'>1ARK
af~:~T

'x'
"'''':VIl'
Co

3, EFFLUENT
8. MAXIMUM DAILY VALUe: b. MAXI"1}}-r;:v~Ha71fit VAL.UE

4. UNITS
C.L.ONG T1ffiM ~:'b~r' VAL.UE d. NO.Or I oUaI/a e a. CONCEN· ANALTRATION YSES

S.INTt..
A e-'E''F?ANGE

• (I/paollal)

.No;;.

<::O"<::l.~'}""T'O",1 (~I "''''''"S GC/MS FRACTION - BASEINEUTRAL COMPOUNDS (continued'
.,.ii;' Q"!..... " .. t:. ""NT

.... "'v ..

b .• E·

"E-

"' ... ."'NT

'<I <;0 ... <:: '" NT" '" r'ON

Cd

MAS$

<;("'H:"~'TJ""'T'O'"

b. MASS

~ERL.~E hI .....••

b. NO.OF i '
ANAL.-

!,l

MAs$

ttl

<:;ON<::""'_ nt .... T'O..,
.

YSES

228. 1.4-Dlchloro. benzene (106·46·7 238. 3,3'·Dichlora benzidine (91-94-1> 248. Oiethyl Phthalate (84-66·2) 25B. Dimethyl Phthalate (131·11·3) 26B.' DI·N·ButYl Phthalate (84-74-2) 27 B. 2.4-0Inltrotoluene (121·14-2) 288. 2.-6·0In1trotoluene (606·2002) 29B. DI-.N·Qctyl .' Phthalate '.' 117-84-0)

X X

~
.

"

,

X X
X

X
X
"

X
X

... rulne (Q1I Azo-en¢J

B.-1.2~Dlphenyl~ (122..a~7

,i206-44-0) .

;i-8~' fluoranthene

><

:·328: Fluoren",~S .(86-73-7)/ ",.!.'
338. 1118-74-1)
;-,-.,,;

I

X
X X
X
.

348. Hex.-\,<- :"~ .chlorobutadlene (87-68-3) 358. HexachloroCyclopentadl.ne ' (77-47;..e) 36B. Hexachlofo.ethane (67~72-1)

.
X X X

378. Indena.
fl.2.3-cd) PYNme:,

(193-39·5)
388. tsophorone (78-59-1) 398. Naphthalene (91·20-3) 40B. Nftrobenzene (98-95.3)
N·Nltro~

X

I 418. sodlmffthylamine
I (62-75-9)
!~.prOPYI8mln.
621~54--7)
~ftA

X
X

I
i
PAGE V-7

.

.

1 428. N·Nltrosodl-

X

000491
........... , ........... ""... ,
""~~#~""cco."

e __

.,,or<fln.. ~ 111..90)

,",""'" , ,,'" ...... u

, •• "". . . .

HE FRONT
2. MARK ·X·

<. • ,,~~

"I. POL.L.UT ANT AND CAS NUMBER

aT":ST

SIIlHT Sl'INT CONC ",L')n"T,o,,1 '(if Qvailable) Q~"'1:J ... " .." GC/MS FRACTION.- BASE/NEUTRAL COMPOUNDS (continued)
'"Rio:'
.0'

"G .E·

b.• II!'
Il!.V~

Co .II!:' l..l€VII!:

8. MAXIMUM OAIL.Y VAL.UE

3. b. MA"XIMLlM

(If tll'(li

37a f.ji(JY c)
I J]

EFFLUC:'~T

-C.L.ONG

.
4. UNITS
5. INTAKE (0l'tiOlJaJj

VAL-UE
M ",;;'So

T1f/~;t~a;((l'tnr' VAL.UE
1,1 '-1"'''5

d, NO.OF
ANAL.· YSES

cO"c",,,,""".!..!~

'"

"t.>"<:"~'rl,,.. r,,.,..

3. CONCENTRATION

b. MASS

1,1

C:ONCENT ..... nON

~·_i,~N1 ~\RL~E 111 ...... as

b. NO.OF ANAL' YSES

438. N-Nitro· sodiphenylamine (86-30.6) 448. Phenanthrene (85-01-8)

X
X

"
,

458. Pyrena ('29·00-0)
46B. 1,2,4· Trichlorobenzene ('2ll-82·') 1P. Aldrin (309-00·2) 2P. a-SHe (319-84-6)

X
X
-

GC/MS FRACTION - PESTICIDES

X

,..,....

:x
X
X
X X

3P. ~.SHC (3'9-85·7)
4P. 'Y·8HC (5U-89·9)

.P./i·SHC (3'9-86-8) 6P. Chlordane (57'74-9)
7P.4A'·DOT (5Q.29-3) SP.4,4'·DOE (72-55-9) 9P.4,4'·000 (72·54-B) lOP. -Dieldrin (60-57.') 11P. (1.Endosulfan (115-29·7) 12P. fj-Endosulfan (115·29-71 . 13P. Endo$ulfan Sulfate (1031·07-8) 14P. Endrin (72-20--8)
15P. Endrln

X

"c-

X

X X
;X

:
,
!

,

X X
X

I
I i I
-.
.. 000492
~.""

Aldehyde

(7421-93·4)

l6P; Heptachlor (76-44..al
-

,

•...

X

X

--~.

.- ....... _............... I
..

CONTINUED FROM
; 1. POl,LUTANT

P$~V.8

:.c~""'~ARK 'W

r
101 _ I cONct.:NTRAT,o .. 1 III
(continued)

EPA 1.0. NUMa-

'copy from 1{em 1 of Form l)IOUTFALL NUMBEF

~l

0 H

L -' 00

G 12.
III ... ,,~s

~j.1
.-

002.
4. UNITS
CONCENTRATION b. MASS ANALMA'>" YSES

,
5.INTA"

,
{optional}

1 .
:

AND CAS NUMBER
(i{available)

an:$T

:~C/MS FRACTION _ PESTICIDES
{17P. Heptachlor EPox;d. ',(1024-57-3 1

QU"" ' .

0:::_

:1,1

3. EFFLUENT
3. MAXIMUM OAIL.Y VALUE
MASS

1 .. ~1' C 8££<.I,,"' . oc': I..I~~~ ."
,l<NT IUH.T

b. MAXIM,UM 3.0 DAY VALUE (i{aval/able)

C.L-ONG Tr:RM AVRG. VALUE, I7rauai/able) t< NO.OF a

a LONG VALUE ---.flL"·ERAGE: TERM

b . NO.OF
ANALYSES

III f CO"C~,"'T""UON I
J

It] CONCE"'''-''ATION

J J

ld

Id cONee ... T"ATION

·1
I

III

MAIIII

I

I

l
l

I

I

IV 1'\

i (53469·21·91

1,8P. PCB·1242

x
x

119P. PCB-1254 1(11097.69.1)

PAGE V-9

000493
_ .. ~ .........
~.'Lnn\

PLEASE PRINT OR 1 . ..: IN THE UNSHADED AREAS ONLY. YOu may report some or all of this information on separate sheets (use the same format) instead of completing these pages.

SEE INSTRUCTIONS.

•
a.

~ ... rPA LD. NUMBER (copy from Item

I of Form 1)

~""
OUTFALL NO.

OH 0000 b 12
()O3
(.~llf'cih'

V. INTAKE AND EFFLUENT CHARACTERISTICS (continued from page 3 of Form 2·C)

PART A· You must provide the results of at least one analysis for every pollutant in this table. Complete one table for each outfall. See instructions for additional details.
2. EFFLUENT

1. POL,LUT ANT
a. ,Biochemical Oxygen Demand
(BOD)

MAXIMUM DAILY VAL.UE

b. MAXI~l..,r;;tJ;8(j75iit
CONCE:NT>iATION

VALUE
MASS

c.LONG Tift/II P.>~~G. VALUE f
I

3. UNITS if blank)
b. MASS

4. INTAKE (OptiOl/{llj
a.
LONG TERM

,

aUG/In

c)

d, NO. OF
ANALYSES

·
·

1<1
T

"

C:}

MASS

1<1

C:}

CONCENTOfIlTION

1<1

Cd

a. CONCEN·
TRATfON

MASS

CONCItNTOfATION

I"

b. NO. OF ..

ld

MASS

ANALYSES

6.48
45",0

b. Chemical Oxygen Demand
(COD)

c. Total Organic Carbon' (TOC) d, Total Suspended Solids (TS8) e. Ammonia (as N)

13. b 7
7
I

2!.'f
VAL.UE VAL.UE VALUE VALUE
"

....

f. Flow
g. Temperature
(winter)

900VALUE VALUE

4,0 0 0 a;pJ
VALUE VALUE VALUE

0·-15 ue.V~LUE

°c
VALUE

h. Temperature
(summer)

11.F-.30°C
MINIMUM MAXIMUM MINIMUM MAXIMUM

i. pH

7.07

PARTB -

Mark "X" in column 2~a for each pollutant you know or have reason to believe is present. Mark "X" in column 2-b for each pollutant you believe to be absent. If you ma1\'column 2a for any pollutantwhich is Iimitede!therdirectly, or indirectly but expressly, in an effluent limitations guideline, you must provide the results of at least one analysis forthatpollutant, For other pollutants for which you mark 'column 28, you must provide Quantitative data or an explanation of their presence in your discharge. Complete one table for each outfall. See the instructions for additional details and requirements.
Z. MJrRK"X'~ l' 3. EFFLUENT 4. UNITS 5. INTAKE (oprional)
B. LONG TERM AVERAGE VALUE

-- ---------- --CONCE:~VRJlTlO'"

VALUE

°c
STANDARD UNITS

,

.'

.•..
'.

..

.;;

•

I. POLLUT.. ANT AND CAS NO.
(jf available)

-

.

a.

Be;-

I.IJ!;Vl!; PRe:' Jlt!:NT

b.IlE:I.IEVe SENT

.0-

a.

MAXIMUM DAiLY VAL.UE

b.

MAXI~ff~lI~Ha~tJY VALUE

CONCE:NTRAT'ON

101

I:)

MASS

CONCENTOfAT,ON

101

ld

C.LONG T/fr(l~a/{f1~r:.;t VALUE dNO.O ANAL-

MASS

Id

MJlSS

YSES

a. CONCENTRATION

b. MASS
.

CO"'CE:~~flATION

It)

Ib. ANAL-NO. OF
YSES

MASS-

8. Bromide (24959-61-9) b. Chlorine, Total Residual c. Color d. Fecal Coliform 8. Fluoride
{16984-48-81

X
.X

X

X
X

f. NltrateNitrite (as N)

X
PAGE V·I

,

·

EPA Form 3510·2C (8-90)

CONTINUE ON REVERSE· 000494

ITEI'lI V·tj t...Uf'llll'llUI;;LJ FROM FRONT

1. POL,L,UTANT AND CAS NO. (if u,Joilable)

2. MARK 'X'
1..1 E:V I:

3. EFFLUENT
b, M AXI~ff";1u;;Haf:t:Y V A L.U I:;:

d. UNITS
c.LONG Ttfla~(ll{a'tr..?' VAL.UE d. NO.OF ANAL'

5. INTAKE (Of'tiwll1/)
A ~>EloPA~GE TVEARt"U E
). NO. OF' ANALYSES

8.

ali:'

SENT

P~Il:-

L"'V'" AO:510:'"

b ....: ;;, a. MAXIMUM DAIL,.Y VALUE

CONCE~~IR"TIO'"

ld

MASS

,<I
CU .. C"' ........ ATlO'"

a.

CONCEN-

(ll

MA<).S

CO"'C;-:"~''!'''''TlO'''

(-') "''''55

YSES

TRATION

b. MASS

cO"C--:J.']HA'ION

1>J ... " .....

g. Nitrogen.
(as

Total Organic NJ

';/.,
X

h. Oll and Gresl8
l. phosphorus (as P). Total
(1723·14-01
j.

.

X
t<X X

Radioactivity

(1)

Alpha, Toul

(2) Beta, Total

..

(3) Radium, Total __ (4) Radium
226~Total

X
X

k. Sulfate
(08

804)

(14808·79-8)

(.. 8,

I. Sulfide

....

X

.

m. Sulflt1l
(a. 803)

(14265·45-3)
n. surfactllnts ........

X

o. Aluminum, Total (7429·9o.S) Total·','-';" 17440-39-31 q.Boron, Total, (7440-42-8) r. cobalt.: Totsl (744Q..4S·4)
I.

><
X )< X
X

I~

p.

B~r./Um, .-

Iron, Total {7439·89-6)
t. Magnesium.

X
)<
)(

Total (7439·95-4) u. Molybdenum, Total (7439-98·71 v, Manganese. Total {7 439·96·5} w.Tln, Total P4.40·31'S)
)t. Titanium, Total

;X

(144Q.32·6)

EPA Form 3510-2C (S-OO)

..
,<,

..... .- .....

TI

... :' 000495

"

V-3

CONTINUED FROM PAGE 3 OF FORM

•

EPA 1.0_ NUMBER (copy (mm Ilem 1 of Farr- ') OUTFALL NUMBER
~

-

2~C

OH 0000 6/2

003

f-"~'"

PART C -

If you are a primary industry and this outfall contains process wastewater, refer to Table 2c-2 in the instructions to determine which of the GC/MS fractions you musttest for. Mark "X" in column 2.a for all such GC/MS fractions that apply to your industry and for ALL toxic metals, cyanides, and total phenols. If you are not required to mark column 2·a (secondary industr;es, nonprocess wastewateroutfalls, and nonrequired GC/MS fractions), mark "X" in column 2-b for each pollutant you know or have reason to believe is present. Mark "X" in column 2·c for each pollutant you believe is absent. If you mark column 2a for any pOllutant. you must provide the results of at least one analysis for that pollutant. If you mark column 2b for any pollutant. you must provide the results of at least one analysis for that pollutant if you know or have reason to believe it will be discharged in concentrations of 10 ppb or greater. If you mark column 2b tor acrolein. acrylonitrile, 2,4 dinitrophenol. or 2-methyl·4. 6 dinitrophenol, you must provide the results of at least one analysis for each of these pollutants which you know or have reason to believe that you discharge in concentrations of 100 ppb or greater. Otherwise, for pollutants for which you mark column 2b, you must eithp.r submit at least one analysis or briefly describe the reasons the pollutant is expected to be discharged. Note that there are 7 pages to this part; please review each carefully. Complete one table (all 7 pages) for each outfall. See instructions for additional details and requirements.
Z. MARK ·x·
a,TItST

~',

t.

POLLUTANT AND CAS NUMBER (if available)

ONR.QUIA'-

LleVlt

b..

BE-

C. BELlI'l:VE AR-

a. MAXIMUM DAILY VAL.UE

3. EFFLUENT b. MAXI~[f~~8a'&~,v VALUE

4. UNITS

S~

INTAKE (optional)
b. NO.OF
ANAL-

c.LONG Tfffa~at'ta'trer' VALUE

d NO.OF

PillESENT

SENT

101 CONCENTRATION

(2) MASS

I,;
CONCENTR/Io.flON

(21 MASS

CONCE~;JRATION

III

MASS

ANAl.YSES

a. coNeEN-

TRATION

b. MAss
~
~

A:J-E'R"A~1r"t,~RL"'0E
(I) eONCEl'4_ TRATloN {2} MASS
,
~

YSES

METALS, CYANIDE, AND TOTAL PHENOLS 1M. Antimony. Total (7440_36_0) 2M; Arsenic. Total (7440-38-2) 3M. Beryllium, Total. 7440-41-7) 4M. Cadmium, Total (744043-9)

.

~

i

,'"

X
J(
,"v:
~ ~

X

x:
X
X
• -'?

SM. Chromium, Total (7440.47-3) 6M. Copper, Total (7_50-81 7M. Lead, Tmal (7439-92-11
8M. Mercury, Total (7439-97-6)

X
)\
·-'.4+'

9M; Nickel, Total
(7440-02.0)

:x
/<-

;-%'

10M. Selenium. Total (7782·49·2) 11M. Silver. Total
(7440-22·4)

X
;<

12M. Thallium. Tot:al (7440-28-0)
13M. Zinc, Total (7440-66·6) 14M. Cyanide, Total (57-12-5)

X
X
>(
~~~ .t~,

15M. Phenols, Total

DIOXIN 2.3,7,a-Tetrachlorodibenzo-P· Dioxin {1764·01·6)

>C

~ ~ ~

DESCRIBE RESULTS

y
PAGE V·3

000496
CONTINUE ON REVERSE