The Village of McComb, Ohio, nestled in Hancock County in the Northwestern part of the state, and their Public Water System serving at least 501 people, Switched both water generation sources AND Water Treatment Plants.
Apparently, at the end of October, 2023, the Village of McComb switched sourcing drinking water from their own municipality to the Village of North Baltimore, Ohio. Why? Why did McComb have to switch water sources from their own Village, proudly established in 1847, to North Baltimore’s water source? And, how was this accomplished? How did the Village of McComb, at the seemingly flip of a switch, change water sources?
The Story Starts Here – in 2014
McComb has a Village Administrator, not a Mayor
Starting in 2013, the Ohio EPA began sending violation letters to the McComb “Village Administrator” regarding disinfection byproducts from the chlorination of drinking water, specifically, Stage 2 Disinfectants and Disinfection Byproducts Rules strengthening public health protection by tightening compliance monitoring requirements for Trihalomethanes (TTHMs) and Haloacetic Acids (HAA5).
The Ohio EPA had to answer to Region 5 EPA in Chicago regarding this rule beginning in January, 2013, after the Village of McComb had SEVEN years to implement procedures to ensure compliance with the Rule. Once Ohio EPA was doing the monitoring of the rule, opposed to the Village Administrator, the Village of McComb was not in compliance. Violation letters began piling up in the Village Administrator’s office.
Hand Delivered Compliance Agreement
On June 9, 2014, the Ohio EPA hand delivered the Village of McComb a BiLateral Compliance Agreement. The Agreement had to be hand delivered because, in our opinion, the Village Administrator ignored all the previous documents and Ohio EPA was on the hot seat with Region 5 out of Chicago. The Village of McComb erected a new water tower, paid for out of the Village’s General Fund, and was cited by the Ohio Auditor’s Office for not following generally accepted accounting principles.
Stage 2 Disinfection Byproducts rule required Public Water System’s to build infrastructure and, to our understanding, in some cases, introduce levees to pay for such infrastructure. McComb built their new water tower, painted the wrong date on the tower, repainted the correct date the village was founded, and that, everyone thought, was the end of the story.
This was just the beginning of the story and problems with McComb’s Public Water System resulting in McComb “switching” to water generation from North Baltimore, apparently, on October 30, 2023.
How Did McComb Get Water for their Public Water System?
The Village of McComb is known as a Surface Water System because their drinking water is generated from water on the surface. This is where a picture is worth a thousand words.
The Village of McComb has two above ground reservoirs, apparently, pumped from Rader Creek, and flowing by gravity, according to Ohio EPA, to the water treatment plant and “clear wells”. In the photo above, there is only one clear well where, today, two clear wells stand.
Has anyone ever been to “Rader Creek”, considered “navigable” by the Ohio EPA? “Navigable”, meaning the body of water, Rader Creek, is in the United States, is subject to the ebb and flow of the tide and/or presently used, or have been used in the past, or may be susceptible for use to transport interstate or foreign commerce.
The above photo should be worth a thousand words. This is Rader Creek.
The above photos of Rader Creek show, in our opinion, to the average person, that the waters are hardly navigable by any type of craft. At one time, before Europeans swarmed the area after the War of 1812, Rader Creek was a tributary of the Portage River connecting to the Blanchard River. However, farming upended the natural ebb and flow of Rader Creek and many other bodies of water in the Ecologically and Environmentally Designated Zone of the Great Lakes Basin. Public Water Systems residing in this specially designated zone of the Great Lakes Basin were subject to additional “EPA rules”. These special rules contributed to the downfall of the Village of McComb who no longer operates a public water system, apparently.
All About NPDES Permits
First, a National Pollutant Discharge Elimination System (NPDES) has nothing to do with the Village of McComb’s drinking water. The issue with Stage 2 Disinfection ByProducts, bilateral compliance agreements, a new water tower, etc., was behind schedule. Delays happen, they’re normal, the important issue, in our opinion, is the issue with TTHMs and HAA5s was, apparently, fixed, permanently. Nothing to see here, move about your business, everything is fine and a okay with McComb’s drinking water.
NPDES Permits revolve around the treating of waste water after you, as a home owner, for example, utilize water produced by McComb’s Water Treatment Plant in every way possible and this water goes down the drains at your house into the Village’s sewer system. We suggest reading these documents.
Three months after the BiLateral Compliance Agreement regarding Stage 2 Disinfection ByProducts, the Village Administrator received a Notice of Violation regarding McComb’s WasteWater Treatment Plant and corresponding NPDES Permit. The biggest problem, in our opinion, was, at the time, in August, 2014, when the above document was published by the Ohio EPA, the Village of McComb did not have a sewer plant. McComb, at that time, 10 years ago, did not have a sewer plant, an actual building with four walls and a roof designed to treat Waste Water especially waste water from you, as a consumer of the water, flush down your toilet. We contend, putting forth for argument, McComb had been trying to build a sewer plant since 1987 when the Water Quality Act passed Congress.
In our opinion, the issue with Disinfection ByProducts, put the Village of McComb on Ohio EPAs radar. Plus Region 5 EPA out of Chicago was watching as well. In our opinion, in the rust belt, EPA laws were not popular. The documents listed above, and we recommend you read each of them, begin an onslaught of Notices of Violation regarding McComb’s Waste Water Treatment Plan and corresponding NPDES Permit.
McComb Water makes local news for turning brown
https://www.beaconjournal.com/story/news/state/2015/08/23/state-brown-water-in-northern/10434160007/
Surprise Inspection
On January 13, 2015, eight months before the Village of McComb made news across northwest Ohio for serving brown water, the Ohio EPA did an Unnannounced Survey. We fully recommend you read the documents. The timeline of our initial question … Why? Why did the Village of McComb have to switch water treatment plants starts in June, 2014, with the BiLateral Compliance Agreement and moves through October 30, 2023, the day McComb, apparently, flipped a switch and residents in McComb were now being served North Baltimore drinking water.
And, for the record, the publisher has zero doubt this switch in water generation for McComb was accomplished, by Northwest Water and Sewer District, with every eye dotted and every tee crossed regarding how McComb switched. However, we’re not at the part of the story to fully introduce Northwest Water and Sewer District. Perhaps another questions is Why? Why did McComb have to switch to NWWSD?
Inspection, McComb Water Treatment Plant
On April 7, 2015, nine months after the BiLateral Compliance Agreement, several months after NDPES Violation letters, which, again, have nothing to do with drinking water, and three months after the “surprise” laboratory inspection (being the laboratory inside the McComb Water Treatment Plant where a multitude of testing on drinking water before the water is dispersed to you as a customer), Ohio EPA conducted a Sanitary Survey Inspection of McComb’s Water Treatment Plant.
The Village Administrator had 15 action items requiring a response within 30 days. Also, there were 27 Recommendations.
The Village of McComb Responds on May 6, 2015, just meeting the deadline of 30 days.
We fully recommend you read the documents.
On August 19, 2015, while McComb is making local news for brown water, Ohio EPA conducted further Sanitary Surveys at the McComb Water Treatment Plant on August 12, 2015, and August 13, 2015. Manganese is specifically addressed.
Let the record show we are publishing documents and opinion.
On July 27, 2016, the Village of McComb, and their public water system, was absorbed by Northwest Water and Sewer District. For the record, since this date, consumers of the village’s water could rest easy knowing every eye was going to be dotted and every tee crossed.
McComb HAD a problem with Mercury
The above document indicates the Village of McComb failed to monitor their drinking water for heavy metals, including Mercury for the period January 1, 2011 through May 31, 2011. Other heavy metals, like arsenic, barium, beryllium, cadmium, cyanide, nickel, etc. ,were not monitored during this period. In our opinion, McComb went ahead and served their citizens drinking water assuming there were no heavy metals, like Mercury, present in the drinking water.
The above document cites the Village of McComb for having anywhere from roughly five times to twenty times the acceptable limit of Mercury in their waste water. McComb, lying in the environmentally designated zone known as the Great Lakes Basin, was subject to more stringent discharge allowances for mercury. Additionally, McComb required a “variance” to their NPDES permit to discharge waste water with mercury amounts exceeding acceptable limits. McComb’s NPDES permit is renewed roughly every five years. The above document details Ohio EPAs inspection in order to issue the new NPDES permit for 2012-2017.
The above document, produced two years after granting McComb a variance to their NPDES permit, cites the Village of McComb for not reporting their Pollutant Minimization Program. The program, in essence, in our opinion, tasked McComb with identifying the source of the Pollutant, in this case, Mercury, and take action to help their “waste water treatment plant”, at the time, be in accordance with acceptable Mercury waste water discharge.
However, this was an impossible task. Because, in 2015, McComb didn’t have a true waste water treatment plant. Today’s waste water treatment plants have the capability to cleanse mercury below the stringent Great Lakes Basin requirements. It will always be Fascinating to us Ohio EPA issued NPDES permit after NPDES permit, every five years, all the while, McComb had failed to build a modern sewer plant. Or, apparently, a “water reclamation” facility.
Interestingly, we could not locate these documents referencing Mercury and NPDES permits on Ohio EPAs edocuments search. So, we are, in essence, publishing these documents. Also, we could not locate a copy of the BiLateral Compliance Agreement from June, 2014, on Ohio EPA edocuments.
Was McComb REALLY a Surface Water System? Let’s speculate and share our opinion based on a Preponderance of Evidence
Or, did the Village of McComb, possibly, serve Ground Water? And, if the Village of McComb was serving ground water, did Ohio EPA have knowledge McComb was, possibly, serving Ground Water? In our opinion, switching to North Baltimore’s water supply was more efficient than making the Village of McComb an “official” Ground Water Public Water System even though, possibly, McComb had been serving Ground Water INSTEAD of Surface Water, possibly, for many years. Sources tell us there are a couple of places in McComb where one can pump ground water with a hand pump. One being at the golf course and another at the “soft ball” fields.
We encourage you to read the documents included as Ohio EPA ordered the Village of McComb to “seal their well” and comments were made by Ohio EPA, when the well was ordered sealed, “we didn’t know they still had a well”. This source spoke on the condition of anonymity.
We’re told a saying in the Village of McComb is “It takes a Village”. Yes, it does take a village, in our opinion, to have spent Millions of dollars on drinking water infrastructure only to have it abandoned for unknown reasons.
And yes, in our opinion, it takes a Village of Idiots to not realize something is very wrong when strolling Rader Creek and what’s known as Reservoir #2. In our opinion, based on the people we’ve spoken regarding the subject matter, the photos we have seen, satellite imagery, etc., Rader Creek and Reservoir #2 are not a Viable Long Term Circulatory Surface Water Source for drinking water. In our opinion, the well Ohio EPA ordered sealed was utilized to fill Reservoir #2 with Ground Water. In our opinion, when McComb could no longer pump Ground Water into Reservoir #2, it began to dry up. Reservoir #2 in McComb began to stagnate due to fresh water not being circulated into the Reservoir.
If you’re ever in McComb, Ohio, take a stroll to their Reservoirs and notice how “dead” everything seems. How “stagnant” everything seems. Then, go to the two Reservoirs in the seat of Hancock County, Findlay, and notice the difference for yourself.
Locals can say what they would like about the Blanchard River (Findlay is a Surface Water System sustained by the Blanchard River) but when one goes to the two reservoirs in Findlay, they are teeming with life. Birds, fish, etc., etc. The Blanchard River and Findlay’s two above ground reservoirs, are a testament to pumping water into gigantic above ground reservoirs and treating the water before it reaches the Water Treatment Plant for final treatment and distribution to consumers.
McComb’s Public Water System Woes are like an Onion with lots of layers leading to more and more questions
Why are there documents written by Ohio EPA yet not available on their edocuments search?