Record · Enforcement
correspondence (response to NOV)
edoc-454946
Fields
agency
Ohio EPA, Northwest District Office
instrument
correspondence (response to NOV)
case_no
—
respondent
City of Lima
facility
Lima Wastewater Treatment Plant (WWTP)
permit_no
2PE00000
issued_date
2016-06-15
effective_date
—
supersedes
—
penalty_usd
—
stipulated_penalties
—
status
active
summary
This is a June 15, 2016 response letter from Frost Brown Todd LLC (attorneys for the City of Lima) to Ohio EPA's Northwest District Office, written in reply to a Notice of Violation dated June 1, 2016, concerning the loss of approximately 2,500 gallons of sodium hypochlorite (NaOCl) at the Lima WWTP on April 12–14, 2016. The City disputes each of the six alleged violations on legal grounds but commits to implementing protocol changes, encloses an incident investigation report, and provides an adopted SOP to prevent recurrence. No civil penalty is assessed in this document; it is a respondent's correspondence rather than an agency enforcement order.
note
—
obligations
- requirement Submit report detailing the City's investigation of the NaOCl incident, conclusions, and procedures to prevent recurrence (enclosed with this letter)
- deadline —
- status met
- requirement Adopt and implement Standard Operating Procedure (SOP) for sodium hypochlorite handling to prevent future losses
- deadline 2016-06-14
- status met
- requirement File formal request to approve Eric Markley as operator of record
- deadline —
- status met — filed 2016-06-10
- requirement SOP to contain notification requirements for release of hazardous substances, including contact info for Allen County EMA and Ohio EPA Spill Hotline
- deadline —
- status met
- requirement Address all six NOV findings within 15 days of receipt of the June 1, 2016 NOV
- deadline —
- status met — responded via this letter
⚠ Gaps in the record
- This document is a respondent's (City of Lima) response letter to an NOV — not the NOV itself or an agency enforcement order; the instrument classification reflects that.
- The originating NOV is dated June 1, 2016, and was issued by Ohio EPA NWDO (Elizabeth A. Wick); that document is not fully reproduced here.
- Permit number '2PE00000' is cited in the letter text; OCR rendered it inconsistently but the image text confirms '2PE00000' on page 2.
- SOP effective date appears to be '6-14-16' (June 14, 2016) per the handwritten notation, verified against image.
- No case number or docket number is referenced in this correspondence.
Where it connects
oepa/lima/edoc-454946.order.yaml · p.1 · oepa