Document 0q7wrEd5DopZRJd6MwzJ3makk

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 3 Four Penn Center 1600 John F. Kennedy Boulevard Philadelphia, Pennsylvania 19103-2029 Report Title: Inspection Date(s): Regulatory Program(s): Type of Activity: Facility Name: Permittee(s): Site/Facility Operator: Facility Address: Lat/Long: County/Parish: Permit Number: NAICS & SIC Codes: Unique Project #: Clean Water Act Compliance Inspection Report August 30-31, 2023 National Pollutant Discharge Elimination System (NPDES) Pretreatment Compliance Inspection- Publicly Owned Treatment Works (POTW) Ambler Wastewater Treatment Plant Borough of Ambler Borough of Ambler 131 Rosemary Ave. Ambler, PA 19002 40.15504, -75.22074 Montgomery PA0026603 221320/4952 3E23WN055A Facility Representative: Point of Contact Jarrett Evans, Assistant Superintendent Phone: (215) 628-9457 Email: awwtpasst@borough.ambler.pa.us EPA Inspector: Jim Kline, Inspector Phone: (304) 234-0263 Email: kline.james@epa.gov Report Preparer Signature/Date Supervisor Signature/Date James Kline Digitally signed by James Kline Date: 2024.02.14 14:15:12 -05'00' Jim Kline (3ED32) Date NPDES Section 1 MARK ZOLANDZ Date: 2024.02.14 14:19:47 -05'00' Digitally signed by MARK ZOLANDZ Mark Zolandz, Section Chief (3ED32) Date NPDES Section 1 Pretreatment Compliance Inspection - Ambler WWTP Table of Contents TABLE OF CONTENTS ..................................................................................................................................... 2 I. INTRODUCTION .......................................................................................................................................... 3 A. AMBLER WWTP - OPENING CONFERENCE ........................................................................................................................ 3 B. AMBLER WWTP - BACKGROUND INFORMATION ............................................................................................................... 3 C. AMBLER WWTP - INDUSTRIAL PRETREATMENT PROGRAM FILE REVIEW...................................................................... 4 II. IU INSPECTION- 727 NORRISTOWN ROAD, LLC. .............................................................................. 5 A. 727 NORRISTOWN ROAD, LLC - OPENING CONFERENCE .................................................................................................. 5 B. 727 NORRISTOWN ROAD, LLC - BACKGROUND INFORMATION ......................................................................................... 6 C. 727 NORRISTOWN ROAD, LLCA - OBSERVATIONS ............................................................................................................. 6 III. IU INSPECTION- KEYSTONE SPECIALTY CHEMICAL, LLC.......................................................... 7 A. KEYSTONE SPECIALTY CHEMICAL, LLC - OPENING CONFERENCE .................................................................................. 7 B. KEYSTONE SPECIALTY CHEMICAL, LLC - BACKGROUND INFORMATION......................................................................... 7 C. KEYSTONE SPECIALTY CHEMICAL, LLC - OBSERVATIONS ............................................................................................... 8 IV. CLOSING CONFERENCES ........................................................................................................................ 8 V. LIST OF ATTACHMENTS .......................................................................................................................... 8 Unique Project #: 3E23WN055A Page 2 of 9 Pretreatment Compliance Inspection - Ambler WWTP I. Introduction On August 30-31, 2023, Inspector Jim Kline (Inspector Kline) from the U.S. Environmental Protection Agency (EPA) Region 3, National Pollutant Discharge Elimination System (NPDES) Section conducted an on-site Pretreatment Compliance Inspection (PCI) of the Borough of Ambler Wastewater Treatment Plant (hereinafter "Ambler WWTP") Pretreatment Program. The Ambler WWTP is located at 505 Church Street Ambler, PA 19002 (See Attachment #1- Photos #1 & #2). The purpose of the inspection was to observe the Ambler WWTP Pretreatment Program's compliance with the Clean Water Act (CWA), the applicable Federal Pretreatment Regulations, and the Facility's National Pollutant Discharge Elimination System (NPDES) permit ID: PA0026603 (See Attachment #2). Prior to the PCI, the Pennsylvania Department of Environmental Protection ("PADEP") was notified of the inspection. The PADEP did not send a representative to attend the PCI. Inspector Kline did provide Ambler WWTP advanced notice of the PCI. All information included in this report is the result of observations made by Inspector Kline, statements made by Ambler WWTP, 727 Norristown Road, LLC, and/or Keystone Specialty Chemical, LLC representatives, materials shown to Inspector Kline by Ambler WWTP, 727 Norristown Road, LLC, and/or Keystone Specialty Chemical, LLC representatives, and/or documents provided by Ambler WWTP, 727 Norristown Road, LLC, and/or Keystone Specialty Chemical, LLC representatives to Inspector Kline at the time of, or subsequent to, the inspection. A. Ambler WWTP - Opening Conference Inspector Kline arrived at Ambler WWTP at 8:00AM on Tuesday August 30, 2023. Upon arrival, Inspector Kline presented his credentials to Mr. Jarrett Evans, Assistant Superintendent. Mr. Evans introduced Inspector Kline to Mr. Patrick Sarro, Plant Superintendent, and Ms. Judy Stevenson, Consultant Environmental Engineering and Management Associates in Harleysville, PA. Mr. Sarro shared with Inspector Kline that he was within days of retirement and stated that Mr. Evans would be a strong candidate for his replacement and would be the contact person for this inspection. Inspector Kline proceeded to conduct an Opening Conference with Mr. Sarro, Mr. Evans, and Ms. Stevenson. Inspector Kline informed Mr. Evans, Mr. Sarro, and Ms. Stevenson that any information that Ambler WWTP deemed to be confidential business information ("CBI") should be identified to Inspector Kline during the inspection and it would be handled as CBI according to EPA's CBI procedures. Inspector Kline informed Mr. Evans, Mr. Sarro, and Ms. Stevenson that photographs would be taken during the inspection (photographs are provided in Attachment #1 of this report). Mr. Evans, Mr. Sarro, and Ms. Stevenson did not make any CBI claims. B. Ambler WWTP - Background Information Ambler WWTP is a wastewater treatment plant owned and operated by the Borough of Ambler. According to the PADEP-issued NPDES Permit, Ambler WWTP has a hydraulic capacity of 6.5 million gallons per day. The Unique Project #: 3E23WN055A Page 3 of 9 Pretreatment Compliance Inspection - Ambler WWTP NPDES Permit was effective October 1, 2018, and expired September 30, 2023, and has been administratively extended. Ambler WWTP discharges to the Wissahickon Creek. According to Mr. Evans, the Ambler WWTP services Ambler Borough, Upper Dublin Township, Lower Gwynedd Township, Whitemarsh Township and Whitpain Township. Mr. Evans stated the most recent jurisdictional agreements date back to 1985. Inspector Kline asked when the last time Ambler WWTP evaluated their local limits for the Pretreatment Program. Ms. Stevenson stated the local limits were recently approved by the EPA in February 2023. Inspector Kline asked Mr. Evans if the Ambler WWTP was current with all EPA annual reporting requirements. Mr. Evans stated Ambler WWTP is current and has not been late with annual reporting. The most recent Annual Report that Ambler WWTP submitted was in 2022 (See Attachment #3). Inspector Kline asked Mr. Evans if Ambler WWTP accepts any hauled-in wastes. Mr. Evans stated they do not accept hauled-in wastes. Inspector Kline asked Mr. Evans if the Ambler WWTP had a Fats Oil and Grease (FOG) Program. Mr. Evans stated there are collection lines, but that program oversight was not part of the Ambler WWTP. C. Ambler WWTP - Industrial Pretreatment Program File Review Inspector Kline conducted an Industrial Pretreatment Program File Review at the Ambler WWTP. According to Mr. Evans, Ambler WWTP currently has eight permitted industrial users (IUs). Inspector Kline asked Mr. Evans if he had a current listing of the permitted IUs. Mr. Evans provided Inspector Kline with a document that listed the IU, IU permit number, IU address, and contact information (See Attachment #4). Inspector Kline asked Mr. Evans, Mr. Sarro, and Ms. Stevenson how the Ambler WWTP identifies potential industrial users. Ms. Stevenson stated the Ambler has developed a Wastewater Discharge Permit Application. Ms. Stevenson provided Inspector Kline with a copy of the Wastewater Discharge Permit Application (See Attachment #5). Inspector Kline asked if the application, Industrial Waste Surveys, or similar type questionnaires are sent out to potential IUs. Mr. Evans stated they do not send surveys out to potential IUs. Mr. Evans stated the Ambler WWTP must develop a plan to identify potential IUs. Inspector Kline asked Mr. Evans how long each IU Permit are valid. Mr. Evans stated each IU Permit is valid for five years. Inspector Kline asked Mr. Evans if inspections and/or sampling are conducted for the IUs. Mr. Evans stated announced inspections are conducted for each IU annually. Mr. Evans added all IUs are sampled by M. J. Reider Associates, their contracted lab. Inspector Kline asked if Ambler WWTP collects the samples and sends the samples to M. J. Reider Associates. Mr. Evans stated M. J. Reider Associates collects, transports, and conducts the analysis for all their sampling. Inspector Kline asked Mr. Evans if any Ambler WWTP Staff attend the sampling events. Mr. Evans stated no Ambler employees are ever present during sampling. Inspector Kline asked Mr. Evans if any of the permitted IUs caused pass through or interference at the Ambler WWTP. Mr. Evans stated that their IUs have not been a problem and have not created a pass through or interference event. Inspector Kline asked Mr. Evans if any of the IUs had any permit parameter exceedances in the past three years. Mr. Evans stated they have not had an IU with a permit parameter exceedance in the past three years. Unique Project #: 3E23WN055A Page 4 of 9 Pretreatment Compliance Inspection - Ambler WWTP Inspector Kline asked Mr. Evans if the Ambler WWTP has an Enforcement Response Plan (ERP) or similar document to address non-compliance by IUs. Mr. Evans stated they have an ERP dated 5/26/2015 (See Attachment #6). Inspector Kline requested and received a copy of the IU Permit issued to Cushman & Wakefield, which is doing business as 727 Norristown Road, LLC located at 727 Norristown Road in Lower Gwynedd (See Attachment #7). Mr. Evans stated the IU Permit is issued to 727 Norristown Road, LLC and is in the Spring House Innovation Park (SHIP) Campus. Mr. Evans stated the campus has multiple lift stations which are connected to an underground wastewater tank with only one permitted outfall which connects to the Ambler WWTP. Mr. Evans stated SHIP consists of several buildings used by individual tenants primarily for scientific research and development (R&D), and R&D labs. Mr. Evans described the tenants as "mini-IUs" under the 727 Norristown Road IU Permit. Inspector Kline asked Mr. Evans how many tenants were located at SHIP. Mr. Evans stated he believed there to be twenty-four tenants. Mr. Evans stated he wanted to clarify his statement, that as of 2019 Ambler WWTP only has received nine actual applications from those tenants at SHIP. Inspector Kline asked why the Ambler WWTP did not have applications from all tenants located at SHIP. Mr. Evans stated he has tried repeatedly to communicate with Mr. Carson Turner, who was the former contact person for Cushman & Wakefield but no longer works there. Mr. Evans stated Ms. Mary Jo Ratigan is the new contact person with Cushman & Wakefield. Inspector Kline asked Mr. Evans how long Ms. Ratigan has been the contact person. Mr. Evans stated Ms. Ratigan has been the contact person since November-December 2022. Inspector Kline asked both Mr. Evans and Ms. Stevenson how the recently approved local limits could be determined with a high degree of certainty without completed and verified applications from each tenant. Neither Mr. Evans nor Ms. Stevenson offered an explanation. Mr. Evans stated he had made multiple attempts to gather the necessary information, but the unresponsiveness has been a problem. Inspector Kline requested a copy of the most recent Inspection Report conducted at 727 Norristown Road, LLC. Mr. Evans stated he conducted the last annual inspection on October 13, 2023 (See Attachment #8). Inspector Kline completed the Field Checklist with input from Mr. Evans and Ms. Stevenson (See Attachment #9Checklist). As part of the PCI, Inspector Kline selected 727 Norristown, LLC for the IU tour portion of the inspection. Inspector Kline decided that 727 Norristown Road, LLC would be inspected on August 31, 2023, at 8:30AM. II. IU Inspection- 727 Norristown Road, LLC A. 727 Norristown Road, LLC - Opening Conference Inspector Kline, Mr. Evans, and Ms. Stevenson arrived at 727 Norristown Road, LLC on August 31, 2013, at approximately 8:30 AM (See Attachment #1- Photos #3 & #4). Inspector Kline presented his credentials to Ms. Mary Jo Ratigan, General Manager, at the outset of the inspection. Ms. Ratigan stated she had been the General Manager since December 19, 2022. Inspector Kline asked Ms. Ratigan if Mr. Carson Turner was employed at 727 Norristown Road, LLC. Ms. Ratigan stated Mr. Turner left in 2021. Ms. Ratigan introduced Inspector Kline to Mr. Robert Feldman, Maintenance Technician. Mr. Feldman stated he has been employed at Unique Project #: 3E23WN055A Page 5 of 9 Pretreatment Compliance Inspection - Ambler WWTP this location for two years. During the Opening Conference, Inspector Kline informed both Ms. Ratigan and Mr. Feldman that any information they deemed to be confidential business information ("CBI") should be identified to Inspector Kline during the inspection and it would be handled as CBI according to EPA's CBI procedures. Inspector Kline stated he would be taking photographs during the inspection. Ms. Ratigan stated photographs would not be a problem. Photographs are provided in Attachment #1. Inspector Kline explained that the purpose of the inspection was to observe the Ambler WWTP Pretreatment Program's compliance with the Clean Water Act (CWA) and the applicable Federal Pretreatment Regulations. The inspection was conducted as part of a routine periodic inspection. B. 727 Norristown Road, LLC - Background Information Inspector Kline asked Ms. Ratigan to briefly describe operations at 727 Norristown Road, LLC. Ms. Ratigan stated Cushman and Wakefield manages the leases at Spring House Innovation Park (SHIP) Campus. According to Ms. Ratigan, SHIP tenants are primarily a combination of life science and bioengineering research and development labs. Ms. Ratigan stated there are no manufacturing activities by any tenants on the SHIP Campus. Ms. Ratigan stated many of the tenants are office-use only with only sanitary discharges. Inspector Kline asked Ms. Ratigan if she had a tenant listing for 727 Norristown Road, LLC. Ms. Ratigan provided Inspector Kline with a tenant listing (See Attachment #10). Ms. Ratigan stated the listing was not current, but she would go over the list as some offices had been recently vacated and some of the buildings at SHIP were scheduled for or were in the process of demolition. Ms. Ratigan also provided Inspector Kline with a document titled "Spring House Innovation Park Tenant Summary" (See Attachment #11). Inspector Kline asked Ms. Ratigan if each tenant was provided a Borough of Ambler Wastewater Discharge Permit Application. Ms. Ratigan stated she was aware of the issue regarding Mr. Turner's alleged unresponsiveness. Ms. Ratigan stated she would be working closely with Mr. Evans and the Borough of Ambler to make sure each tenant receives the application, completes the application, and provides Mr. Evans with the information he needs. Ms. Ratigan stated she will ensure each tenant receives the application and would try to have each tenant complete the application and have all applications back within two weeks from today. Inspector Kline asked if sampling is being conducted for any of the tenants. Mr. Feldman stated he was not aware of testing for individual tenants. Mr. Feldman added that quarterly sampling at their permitted sampling outfall does occur. Inspector Kline randomly selected one of the tenants located at 727 Norristown Road, LLC to visit. Inspector Kline selected Keystone Specialty Chemical, LLC. According to Ms. Ratigan, Keystone Specialty Chemical, LLC is in Building #3, Suite #106 (See Section III of this report). C. 727 Norristown Road, LLC - Observations Inspector Kline requested to visit the permitted sampling location of the 727 Norristown Road, LLC SHIP Campus. Ms. Ratigan stated the sampling point was in a grassy area located in the southwest portion of the SHIP Campus map. Inspector Kline took a photograph of the map that Ms. Ratigan referenced (See Unique Project #: 3E23WN055A Page 6 of 9 Pretreatment Compliance Inspection - Ambler WWTP Attachment #1- Photo #5). Accompanying Inspector Kline were Ms. Ratigan, Mr. Feldman, and Ms. Stevenson. Observation #1: Inspector Kline observed the permitted sampling location (See Attachment #1- Photo #6). Ms. Stevenson verified the location was the permitted sampling location. The general area was relatively flat with cut maintained grass with no adjacent buildings. The sampling location consisted of two round and one rectangular surface-level concrete and metal structures. Mr. Feldman lifted the manhole cover. Inspector Kline observed an active discharge flow within the manhole (See Attachment #1- Photo #7). III. IU Inspection- Keystone Specialty Chemical, LLC A. Keystone Specialty Chemical, LLC - Opening Conference Inspector Kline selected Keystone Specialty Chemical, LLC as one of the 727 Norristown Road, LLC tenants within the SHIP Campus to be part of the inspection. Inspector Kline, Mr. Evans, and Ms. Stevenson were escorted by Ms. Ratigan and Mr. Feldman to the Keystone Specialty suite at approximately 12:00 PM on August 31, 2023. Inspector Kline presented his credentials to Mr. William Jones, Formulation Chemist, and Ms. Claudia Roland, Product Development Engineer, at the outset of the inspection. Mr. Jones stated Ms. Leahann Iannotta, Research and Development Manager, was their third full-time employee and supervisor but was not present during the inspection. Mr. Jones added there were only three employees at this location. During the Opening Conference, Inspector Kline informed both Mr. Jones and Ms. Roland that any information that they deemed to be confidential business information ("CBI") should be identified to Inspector Kline during the inspection and it would be handled as CBI according to EPA's CBI procedures. During the inspection, neither Mr. Jones nor Ms. Roland identified any CBI. Photographs were taken during the inspection by Inspector Kline and are provided in Attachment #1. Inspector Kline explained that the purpose of the inspection was to observe the Ambler WWTP Pretreatment Program's compliance with the Clean Water Act (CWA) and the applicable Federal Pretreatment Regulations. The inspection was conducted as part of a routine periodic inspection. B. Keystone Specialty Chemical, LLC - Background Information Inspector Kline asked Mr. Jones and Ms. Roland to provide a brief historical description of their facility and what Keystone Specialty Chemical, LLC does at this location. Mr. Jones first stated that he was in his current position since 2019. Ms. Roland added she had been at this location for two years. Mr. Jones added, Ms. Iannotta had been at this location for over four years. Mr. Jones stated they are a research and development lab for the formulation of chemicals used in agriculture. Inspector Kline asked Mr. Jones if they generate hazardous wastes. Mr. Jones stated they do generate some hazardous wastes and that they hired Triumvirate Environmental about a year ago for hazardous waste management in their lab. Inspector Kline asked Mr. Jones to briefly describe the research and development process within their lab. Mr. Jones stated solid base solutions of 100 grams or less are primarily tested within a Unique Project #: 3E23WN055A Page 7 of 9 Pretreatment Compliance Inspection - Ambler WWTP beaker. Mr. Jones added solvents are used but because of their frequency of use, the solvent is used up before it reaches expiration. Mr. Jones stated the solutions are monitored for stability and once the process is completed and wasted, it is packaged in the appropriate waste container for disposal. Inspector Kline asked if any hazardous wastes are disposed in the sink drain. Mr. Jones stated hazardous wastes are not disposed in the sink drain. Mr. Jones added Elk Environmental was retained for emergency response if needed at their location. C. Keystone Specialty Chemical, LLC - Observations Inspector Kline requested to tour Keystone Specialty Chemical, LLC. Accompanying Inspector Kline on the tour were: Mr. Evans, Ms. Stevenson, Ms. Ratigan, Mr. Feldman, Mr. Jones, and Ms. Roland. Observation #1: Inspector Kline observed a floor drain within the lab (See Attachment #1- Photo #8). Mr. Jones stated he believed the floor drain was plugged. Observation #2: Inspector Kline asked if he could see where some of the chemicals were stored within the lab. Mr. Jones show Inspector Kline a chemical storage area which was in a cabinet beneath the countertop (See Attachment #1- Photo #9). Inspector Kline did not observe any of the stored chemicals as being expired. This concluded the physical inspection portion of Keystone Specialty Chemical, LLC and 727 Norristown Road, LLC. Inspector Kline left the SHIP Campus at approximately 1:00PM. IV. Closing Conferences After the inspections of Keystone Specialty Chemical, LLC and 727 Norristown Road, LLC, Inspector Kline conducted individual closing conferences at each facility. Inspector Kline shared preliminary observations about each facility. Inspector Kline reiterated that all preliminary observations discussed were not compliance determinations. All preliminary observations shared were subject to further investigation by EPA upon the additional review of records and documentation. Additional observations may be contained in this inspection report that were not identified at the time of the closing conference after EPA reviewed additional materials following the inspection. Inspector Kline conducted a closing conference with Mr. Evans, Mr. Sarro, and Ms. Stevenson at the close of the Ambler WWTP- Industrial Pretreatment Program File Review. This concluded the PCI. V. List of Attachments Attachment 1. Photographs Attachment 2. NPDES Permit PA0026603 Attachment 3. 2022 Annual Report Attachment 4. List of IUs Attachment 5. Wastewater Discharge Permit Application Unique Project #: 3E23WN055A Page 8 of 9 Attachment 6. Enforcement Response Plan (ERP) Attachment 7. 727 Norristown Road, LLC- IU Permit Attachment 8. 727 Norristown Road, LLC- Inspection Report Attachment 9. PCI Checklist Attachment 10. 727 Norristown Road, LLC- Tenant Listing Attachment 11. 727 Norristown Road, LLC- Tenant Summary Pretreatment Compliance Inspection - Ambler WWTP Unique Project #: 3E23WN055A Page 9 of 9