2 l John R. Kasich, Governor | Mary Taylor, Lt. Governor Ohio Environmental | Craig W. Butler, Director Protection Agency NOTICE OF VIOLATION January 10, 2018 RE: City of Cleveland Notice of Violation Drinking Water Program Cuyahoga County PWS ID 0H1801212 STU ID: 1853710 Nottingham Ms. Margaret Rodgers Plant Operations Manager Department of Public Utilities, Division of Water 1201 Lakeside Avenue Cleveland, OH 44114-1175 Subject: LSSV - Facility ID# 1853710, COMM Dear Ms. Rodgers: On September 15, 2017, Dave Riley, Anne Karey and | conducted a Limited Scope Site Visit (LSSV) of the City of Cleveland public water system, Nottingham Plant. The purpose of the inspection was to determine your facility's compliance with Ohio's drinking water laws as found in Chapter 6109 of the Ohio Revised Code (ORC) and Chapter 3745 of the Ohio Administrative Code (OAC). A request for data and information was emailed to the City on September 22, 2017 a subsequent request for additional information was emailed on October 27, 2017. Based on a review of the data provided, Ohio EPA observed the following violations of Chapter 6109 of the ORC and Chapter 3745 of the OAC. SIGNIFICANT DEFICIENCY During the data review associated with the LSSV, a significant deficiency was identified. In accordance with OAC rules 3745-81-60 and 3745-81-61, your public water system shalll respond in writing within thirty days of the date of this letter indicating how and on what schedule the public water system will address the following significant deficiencies. Whenever feasible, a public water system shall correct a significant deficiency within thirty days of notification. When a public water system is not able to complete a corrective action for a significant deficiency within thirty days, the system shall submit a plan within thirty days of the date of the notice of violation with a schedule for completing corrective actions, and correct the significant deficiency according to the schedule accepted by the director. Consultation with your Ohio EPA district office representative prior to submitting a plan is encouraged. 1, In accordance with OAC Rule 3745- 83-01(H)(1-2), the owner or operator of a PWS shall ensure that all facilities and equipment necessary for the treatment and distribution of water shall be 50 West Town Street» Sute 700 « P.O. Box 1049 » Columbus, OH 43236-1049 {epa.ohlo.gov « (614) 644-3020 + (614) 644-3184 (fax)City of Cleveland January 10, 2018 Page 2 of 6 maintained, at a minimum so as to function as intended. In the event the treatment facilities or equipment no longer function as intended, corrective action (which may include additional maintenance or modifications of the public water system) shall be taken by the owner. (@) Upon reviewing documentation provided by the City, Ohio EPA determined that the sludge collection equipment in the sedimentation basins at the Nottingham treatment plant has been a maintenance issue for an extended period of time. The plastic components of the sludge collection equipment on several sedimentation basins have failed, causing basins to either be taken out of service for repair or have sludge collection equipment that is not functioning as it was intended. Failure of these components contributed to high turbidity water leaving the sedimentation basins causing reduced filter run times and resulting in several individual filter turbidity exceedances in late January and early February 2017. During a meeting to discuss Ohio EPA's data review on December 12, 2017 and in correspondence submitted in association with this data review, City personnel have indicated that the sedimentation basins have issues which prevent the sludge collection system from functioning as intended. In fact at the time of the meeting 1 basin was out of service, 2 basins had broken or improperly functioning sludge collection equipment and only 1 basin was fully functional. Based on information submitted to the Agency, during the turbidity event in January and February of 2017, there were no basins that had fully functional sludge removal equipment. Basin #1 had been brought back on line in December of 2016 without repairs being completed, therefore no collectors were functioning, Basin #2 was placed back into service on January 22, 2017 but several collectors failed immediately. Basin #3 had a collector out for an extended period. Finally, Basin #4 was down for repairs. (0) A significant deficiency is defined as a defect in design, operation, maintenance, administration or a failure or malfunction in a system component that does any of the following: provides a pathway of entry for microbial or other contamination into the distribution system or that is indicative of a failure in a barrier that is already in place; Causes or has the potential to cause and unacceptable risk to health or that could affect the reliable delivery of safe drinking water, as determined by the director. The condition of the sedimentation basins and sludge collection equipment and the inability to properly operate and maintain the sedimentation basins all meet the criteria for determining this facility has a significant deficiency that needs to be corrected immediately. (c) During discussions of this situation in a meeting on December 12, 2017, City personnel indicated that not only is this problem related to replacement materials that were previously installed for the sludge collection equipment, there are also design problems with the existing system which make it prone to breakdown. (e.g. the extreme length of chain drags which create significant stress on the sludge removal component.) (4) Please provide schedules for conducting repairs and for on-going maintenance of the existing sludge collection equipment which are necessary in order to ensure the system will function as intended.City of Cleveland January 10, 2018 Page 3 of 6 (e) Please provide a schedule for conducting an engineering evaluation of the existing design of the sedimentation basins and sludge collection equipment and a schedule for completion of recommended improvements that will prevent these issues from occurring in the future. Failure to correct a significant deficiency violation in accordance with a schedule accepted by the Director represents a treatment technique violation and your water system would be required to issue a Tier 2 public notice to your water consumers. VIOLATIONS The following violations of Ohio's safe drinking water laws and rules were observed. In accordance with OAC rule 3745-81-60, your public water system shall respond in writing within thirty days of the date of this letter indicating how and on what schedule the public water system will address the following violations, and correct the violations according to a schedule accepted by the director. 1. In accordance with OAC Rule 3745-83-01(1)(4)(a), the owner or operator shall report to the appropriate Ohio EPA district office as soon as possible, but within twenty-four hours, the discovery of any serious plant or distribution system breakdown or condition causing or likely to cause any discharge of water not in accordance with Chapter 6109. of the Revised Code or the rules adopted thereunder. (a) Documents provided as part of the information request indicate that in late January and early February of 2017 the system was experiencing a plant upset that caused turbidities in the individual fiter effluent to exceed 0.5 NTU for an extended period (b) Information provided by the City indicates that these turbidity excursions were due to the failure of the sludge collection equipment in the sedimentation basins and a lack of personnel to maintain the system. (0) Please provide a standard operating procedure to ensure that Ohio EPA is notified in accordance with the provisions of the above referenced rule. 2. In accordance with OAC Rule 3745-7-09(A)(1), the owner and operator of record of a public water system, distribution system or water treatment plant within a public water system shall maintain or cause to be maintained operation and maintenance records for each public water system, distribution system and water treatment plant within a public water system. The records shall be housed and maintained in such a manner as to be protected from weather damage and guarantee the authenticity and accuracy of the records contained within. (a) A review of the computerized operators log indicates that the log does not guarantee authenticity or accuracy. For example, a review of the operator's log indicates that information is not being entered in chronological order, The data provided begins on line 2 of the spreadsheet with data from December 19, 2017. Beginning at line 1277 which represents January 31, 2017 at 1:00 AM data should move toward December 19, 2017 in chronologic order. However, this is not the case. Data from line 1277 to line 1274 is in