■

Ii 10 l Mike DeWine, Governor

Jon Husted, Lt. Governor
Ohio Environmenta.l Laurie A. Stevenson, Director
Protection Agency

NOTICE OF VIOLATION

July 15, 2019 Re: NORWOOD CITY PWS

Notice of Violation
Drinking Water Program
Hamilton County
OH3101703

Mr. Thomas F. Williams

Mayor
City of Norwood
4645 Montgomery Road
Norwood, Ohio 45212

Subject: Sanitary Survey Significant Deficiency NOV — Facility ID #3154756

Community PWS

Dear Mayor Williams:

On May 17, 2019, Mary McGuinn and I met with Mr. Joe Geers, Mr. Brian Williamson,
Mr. Clint Zimmerman, and Mr. Dale Marshal, all city of Norwood staff, to conduct a
sanitary survey of the Norwood City (PWS) public water system. The purpose of our
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). Our inspection included a review of records associated with
facility operations.

During the inspection, the Ohio Environmental Protection Agency (Ohio EPA), observed
violations of Chapter 6109 of the ORC and Chapter 3745 of the OAC. On June 3, 2019,
1 sent you a Notice of Violation (NOV) letter describing the violations observed during
the sanitary survey and asking for an answer within thirty days of the letter's date. I
received your NOV response letter on June 26, 2019. The NOV response letter included
a Dixon Engineering water storage tank inspection from May 14, 2014.

SIGNIFICANT DEFICIENCY

After reviewing the above referenced storage tank inspection, I identified significant
deficiencies. In accordance with OAC Rules 3745-81-60 and 3745-81-61, your public
water system shall respond in writing within thirty days of the date of this letter indicating

Southwest District Office • 401 East Fifth Street • Dayton, OH 45402-2911

epa.ohio.gov • (937) 285-6357 • (937) 285-6249 (fax)
NORWOOD CITY PWS
OH3101703 — Significant Deficiency NOV
July15, 2019
Page 2 of 4

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.

Failure to correct a significant deficiency violation in accordance with a schedule

accepted by the director represents a treatment technique violation and the water
system would be required to issue a Tier 2 public notice to their water consumers.

On July 12, 2019, Ohio EPA staff, including myself, participated in a conference call
with you, additional staff from the city of Norwood, and representatives of the city of
Cincinnati. During the call the city of Cincinnati offered, pending additional agreements
between the parties, to provide short term assistance to the city of Norwood to help with
any immediate action necessary to address the deficiencies in the city of Norwood's
storage tanks while maintaining adequate pressure throughout the distribution system.
While help from the city of Cincinnati will be beneficial to resolving the deficiency, it is
ultimately the responsibility of the city of Norwood, as the owner and operator of the
public water system, to respond to and address this significant deficiency.

1. In accordance with OAC 3745-83-01(H)(1), the owner and operator shall ensure
that all facilities and equipment necessary for the treatment and distribution of
water shall be maintained to function as intended.

a. During the storage tank inspection, Dixon Engineering inspected both

storage tanks and identified advanced metal corrosion, open holes to the
tanks, and evidence of animal intrusion. A dead bird was identified in one
tank's finished drinking water.

b. The report also indicated the last time the interior and exterior of the tanks
were coated was 40 years ago.

c. The condition of the storage tanks presents a defect in the operation and
maintenance of the storage and distribution system that causes, or has
the potential to cause, an unacceptable risk to health or that could affect
the reliable delivery of safe drinking water and constitutes a significant
deficiency.
NORWOOD CITY PWS
OH3101703 — Significant Deficiency NOV
July15, 2019
Page 3 of 4

d. In order to resolve this deficiency, please develop a strategy to

rehabilitate, replace, or eliminate the use of elevated drinking water
storage tanks.

e. In the event the choice is to rehabilitate or replace the tanks, please

develop and provide a copy of an acceptable maintenance program that is
consistent with guidance provided by the American Water Works
Association (AWWA). This program should include:

i. Seasonal external inspections of the storage tanks.

ii. Internal inspections of the storage tanks at least every 5 years.

iii. A description of maintenance activities and time frames for

ensuring maintenance consistent with AWWA guidelines is
conducted.

f. Whether the elevated drinking water storage tanks are rehabilitated,

replaced, or eliminated you must submit plans in accordance with OAC
Chapter 3745-91 for any substantial changes made to the distribution
system in addition to complying with all other applicable requirements of
the OAC.

If you have already resolved the violations listed above, thank you, and please provide
documentation supporting compliance. If you have not yet addressed the violations,
please submit a compliance plan on how the city of Norwood plans to correct the
violations cited above. Documentation of steps taken to return to compliance includes
written correspondence, updated policies, and photographs, as appropriate, and may be
submitted via the postal service or electronically to mariano.haensel@epa.ohio.gov.

Failure to comply with Chapter 6109 of the Ohio Revised Code and rules promulgated
thereunder may result in an administrative or civil penalty. If circumstances delay
resolution of violations, Norwood City PWS shall submit written correspondence
describing the steps that will be taken and dates when compliance will be achieved.

Please note that the submission of any requested information to respond to this letter
does not constitute waiver of the Ohio EPA's authority to seek administrative or civil
penalties as provided in Section 6109.23 and 6109.33 of the Ohio Revised Code.
NORWOOD CITY PWS
OH3101703 — Significant Deficiency NOV
July15, 2019
Page 4 of 4

If you have any questions regarding this leiter, or any other matter involving your water
system, pley~se feel free to contact me by email mariano.haensel@epa.ohio.gov or by
phone at (~37) 285 6113.

Sin

Eri i m tal Specialist

Di i n Drinking and Ground Waters
P I'c Çlrinking Water Group

1iamilton County Health Department

Jeff Davidson, Manager, DDAGW — SWDO
Dan Stine, DDAGW - SWDO
Jeff Stark, District Office Compliance Coordinator, Ohio EPA, DDAGW, SWDO
John McDaniel, DDAGW — SWDO
Mary McGuinn, DDAGW — SWDO

cc: Hamilton County Health Department

Joe Geers, Professional ORC
Mr. Brian Williamson RS, Norwood Health Department
Mr. Clint Zimmerman Lead Man Water Department, Norwood Health Department
Mr. Dale Marshal Health Inspector, Norwood Health Department

MH/bp