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NOTICE OF VIOLATION
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
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.
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.
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
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
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