Document 1yrZzLx0b3805L82EjYrY1md

Report Title: Inspection Date(s): Regulatory Program(s): Type of Activity: Site/Facility Name: Permittee(s): Site/Facility Operator: Site/Facility Address: Latitude: County/Parish: Permit Number: NAICS Code: Unique Project #: Clean Water Act Compliance Inspection Report 03/11/2024 National Pollutant Discharge Elimination System (NPDES) Compliance Evaluation and Inspection CAN DO Inc. Humboldt CAN DO Inc. Raina Nichols 653 Oak Ridge Rd Hazle Township, PA 18202 40.922269 Longitude: 76.07692065104011 Luzerne County PA0060046 622210 SIC: 4952 ECAD-524 Site/Facility Representative(s): Raiana Nichols, Director of Utilities, CAN DO Inc. Phone: (570) 401-4224 Email: rnichols@hazletoncando.com Daniel Bove, Licensed Operator, CAN DO Inc. Phone: (570) 436-8382 Email: dbove@hazletoncando.com Ed Pietroski, Entech Engineering Phone: (570) 861-0780 Email: epietroski@entecheng.com Mary Peters, Entech Engineering Phone: (570) 868-0275 Email: mpeters@entecheng.com EPA Inspectors: Erin DeSandro, EPA Region 3 Inspector Phone: (215) 814-2125 Email: DeSandro.Erin@epa.gov James Kline Phone: (304) 234-0263 Email: Kline.James@epa.gov State/Local Inspectors: N/A ERIN DESANDRO Digitally signed by ERIN DESANDRO Date: 2024.05.30 13:12:07 -04'00' Report Preparer Signature/Date Supervisor Signature/Date Erin DeSandro, EPA Region 3 NPDES Section 2 3ED33 JESSICA Digitally signed by JESSICA DUFFY DUFFY Date: 2024.05.30 07:54:00 -04'00' Jessica Duffy, EPA Region 3 Section Chief NPDES Section 2 3ED33 Unique Project#: ECAD-524 Date Date CAN DO Inc. Humboldt 03/11/2024 Section Table of Contents Page I Introduction............................................................................ 3 A Inspection Opening Conference...................................................................... 3 B Weather and Precipitation Conditions............................................................. 4 C Summary of the Facility.................................................................................. 4 II Site Activity..................................................................................................... 4 III Observations.................................................................................................... 5 IV Records Review............................................................................................... 9 V Closing Conference......................................................................................... 10 VI List of Attachments.......................................................................................... 11 Unique Project #: ECAD-524 Page 2 of 11 CAN DO Inc. Humboldt 03/11/2024 I. Introduction On March 11, 2024, an inspection team composed of staff from the U.S. Environmental Protection Agency ("EPA") Region III (hereinafter, "EPA Inspection Team") conducted a Compliance Evaluation Inspection of the CAN DO Inc. Humboldt facility (hereinafter, "the facility"). The purpose of the inspection was to observe compliance with the Clean Water Act (CWA) and to verify compliance with the facility's National Pollutant Discharge Elimination System (NPDES) Permit No. PA0060046 (hereinafter, the "Permit") and applicable State and Federal regulations. The Permit effective date is May 1, 2020, and the expiration date is April 30, 2025. A. Inspection Opening Conference The EPA Inspection Team arrived at the facility at est. 1 PM for the inspection. Inspectors met with the following facility representatives: Name Erin DeSandro James Kline Raiana Nichols Daniel Bove Ed Pietroski Mary Peters Table 1: Inspection Attendee List Affiliation Telephone Email EPA Region III Inspectors and Contractors EPA Region 3 (215) 814-2125 DeSandro.Erin@epa.gov Inspector EPA Region 3 (304) 234-0263 Kline.James@epa.gov Inspector Site/Facility Representatives Director of (570) 401-4224 rnichols@hazletoncando.com Utilities, CAN DO Inc. Licensed (570) 436-838 dbove@hazletoncando.com Operator, CAN DO Inc. Senior Project (570) 861-0780 Manager, Entech epietroski@entecheng.com Engineering Entech Engineering (570) 868-0275 mpeters@entecheng.com EPA Inspectors Erin DeSandro and James Kline displayed their credentials to Ms. Nichols at the outset of the inspection and explained the purpose of the inspection was to observe compliance with its Permit. A copy of the Permit is provided as Attachment 6. The EPA Inspection Team informed Ms. Nichols that any information that the Facility deemed to be confidential business information ("CBI") should be identified to EPA representatives during the inspection and it would be handled as CBI according to EPA's CBI procedures. Unique Project #: ECAD-524 Page 3 of 11 CAN DO Inc. Humboldt 03/11/2024 B. Weather and Precipitation Conditions During the inspection, weather was cloudy with no precipitation. National Oceanic and Atmospheric Administration (NOAA) National Weather Service precipitation data for the date of the inspection and 5 days prior are provided in the Table 2 below: Table 2. Precipitation Data Station Name Date HAZLETON 1.6 NW, PA US US1PALZ0027 HAZLETON 1.6 NW, PA US US1PALZ0027 HAZLETON 1.6 NW, PA US US1PALZ0027 HAZLETON 1.6 NW, PA US US1PALZ0027 HAZLETON 1.6 NW, PA US US1PALZ0027 HAZLETON 1.6 NW, PA US US1PALZ0027 03/06/2024 03/07/2024 03/08/2024 03/09/2024 03/10/2024 03/11/2024 Precipitation Amount (inches)1 0.40 0.62 0.00 0.02 1.28 0.00 C. Summary of the Site/Facility CAN DO, Inc. is a private, nonprofit economic and industrial development agency that manages the Greater Hazleton CAN DO Humboldt Industrial Park and operates a 1.0 MGD wastewater treatment plant (hereinafter, the "WWTP"), located in Hazle Township, Luzerne County. The Humboldt Industrial Park complex was established in 1972 and stretches approximately 5 miles long. During the inspection, Ms. Nichols estimated that roughly 67 different industries are operating at the site. A list of businesses operating at the park according to CAN DOs website is provide in Attachment 2. Ms. Nichols indicated that the industries that contribute to CAN DO Inc.'s WWTP are located in Humboldt West, Humboldt East, and Humboldt Northwest. While Humboldt Northwest and Humboldt North both receive their source water from Greater Hazleton. Only Humboldt North discharges to Greater Hazleton Joint Sewer Authority. A map of the industrial park is included as Attachment 3. Facility representatives estimate that roughly 90% of flow to the WWTP is coming from 4-5 major industries. II. Site Activity During the inspection, the EPA Inspection Team observed the facility's WWTP. The inspection observations were made pursuant to the requirements of the Permit. The observations from the inspection are described in detail below in the Observations section. Photographs were taken during the inspection by Inspector Kline and are provided in Attachment 1. Influent enters the plant via Influent Pump #1 (Photograph 5). Flow is then directed to preliminary treatment through screw grinder (Photograph 9). Overflow from the screw grinder 1 Source: NOAA National Climatic Data Center (http://www.ncdc.noaa.gov/). Unique Project #: ECAD-524 Page 4 of 11 CAN DO Inc. Humboldt 03/11/2024 area is directed to a bar screen that is manually cleaned (Photograph 10). Then, flow enters the equalization tank (Photographs 3 and 4) and goes through a splitter to two identical anoxic tanks (Photograph 11). The tanks split into three zones that are separated by baffles. In the tanks, the smaller pipe is the return sludge, and the larger pipe is the nitrate recycle at the very end of aeration. Tank 1 and Tank 2 flow to Clarifier 1 and Clarifier 2 respectively (Photographs 24 and 25). Flow circulates around the outer ring of the clarifier. Two return sludge pumps are located at the beginning of the outer ring (Photograph 26). Two mixed liquor recycle pumps are located at the end of the outer ring (Photographs 27 and 31). Flow moves from the clarifier inlet well into the center ring of the clarifier. Both clarifiers direct flow to the sand filter for phosphorus removal (Photographs 49 and 50) and then to disinfection. Disinfection used to be chlorine contact but was updated to three vertical UV bulb units (Photograph 39). Mr. Pietroski indicated that two UV units are usually operating, and one is spare. Flow then goes through the preexisting channels that were installed when the area was previously a chlorine contact for post disinfection aeration (Photograph 41). The WWTP outfall is located directly behind the disinfection area and the effluent discharges to Tomhicken Creek (Photograph 47). The facility also has a stormwater outfall associated with the Permit. The facility originally planned to locate the stormwater outfall directly next to the WWTP outfall. The facility provided correspondence from PADEP (Attachments 7, 8, and 9) instructing the Facility that the stormwater outfall monitoring point should be approximately 50 feet down the creek, outside of the WWTP fenced perimeter where recent grading occurred (Photograph 48). Waste activated sludge pumps convey sludge from the clarifiers to the sludge holding tanks (Photograph 51-55). Sludge from the tanks is stored prior to being pumped offsite for disposal. Mr. Pietroski estimated that sludge is pumped 2-3 times a week. In the chemical storage room, Micro CG is kept as a supplement for nitrate removal but has not been used as part of regular operations (Photograph 62). The ferric chloride tank is no longer used, however, there is leftover chemical in the tank that the facility is planning to remove (Photograph 60). Mr. Pietroski stated that polyaluminum chloride injection was introduced to the clarifier inlet 4 weeks prior to the EPA inspection in February 2024. The polyaluminum chloride was added as a coagulant for metal removal (Photograph 58 and 59). II.Observations Observation 1: Part A.1.A-A.1.C of the permit defines effluent limitations and monitoring requirements for Outfall 001 (Sewage Effluent), Outfall 002 (Stormwater associated with industrial activities), and Outfall 101 (Raw Sewage Influent) discharges. Unique Project #: ECAD-524 Page 5 of 11 CAN DO Inc. Humboldt 03/11/2024 According to EPA's ECHO database, the Plant experienced 22 effluent limit exceedances from Outfall 001 between March 11, 2020 and March 11, 2024 (refer to Table 3 below). EPA's ECHO database indicates the Plant was in a state of significant noncompliance (SNC) from October 1, 2022 through March 31, 2023 for consistent Zinc violations. The facility also exceeded TSS parameters for their stormwater outfall in December 2020 (refer to Table 4 below). Table 3: DMR Effluent Limit Exceedances Outfall 001 03/11/2020-03/11/2024 Monitoring Period End Date 08/31/2020 08/31/2020 08/31/2020 09/30/2020 09/30/2021 06/30/2022 08/31/2022 09/30/2022 10/31/2022 11/30/2022 11/30/2022 12/31/2022 12/31/2022 12/31/2022 02/28/2023 02/28/2023 03/31/2023 03/31/2023 03/31/2023 03/31/2023 08/31/2023 08/31/2023 Parameter Desc Nitrogen, ammonia total [as N] Nitrogen, ammonia total [as N] Coliform, fecal general Nitrogen, ammonia total [as N] Phosphorus, Total Zinc, total [as Zn] Coliform, fecal general Zinc, total [as Zn] Zinc, total [as Zn] Zinc, total [as Zn] Zinc, total [as Zn] Zinc, total [as Zn] Zinc, total [as Zn] Zinc, total [as Zn] Zinc, total [as Zn] Zinc, total [as Zn] Nitrogen, ammonia total [as N] Nitrogen, ammonia total [as N] Zinc, total [as Zn] Coliform, fecal general Nitrogen, ammonia total [as N] Coliform, fecal general DMR Value 12.25 42.9 1110. 2.48 3304. .331 1986. .425 .304 .282 .485 .342 .528 1.75 .229 .492 7.35 59.1 .268 2420. 2.51 2420. Limit Value 2.2 18.3 1000. 2.2 2435. .266 1000. .266 .266 .17 .266 .17 .266 1.42 .17 .266 6.6 55. .266 10000. 2.2 1000. Unit mg/L lb/d #/100m L mg/L lb mg/L #/100m L mg/L mg/L mg/L mg/L mg/L mg/L lb/d mg/L mg/L mg/L lb/d mg/L #/100m L mg/L #/100m L Statistical Base MO AVG MO AVG INST MAX MO AVG ANNL TOT DAILY MX INST MAX DAILY MX DAILY MX MO AVG DAILY MX MO AVG DAILY MX MO AVG MO AVG DAILY MX MO AVG MO AVG DAILY MX INST MAX MO AVG INST MAX Unique Project #: ECAD-524 Page 6 of 11 CAN DO Inc. Humboldt 03/11/2024 Table 4: DMR Effluent Limit Exceedances Outfall 002 03/11/2020-03/11/2024 Monitoring Period End Date Parameter Desc DMR Limit Value Value Unit Statistical Base 12/31/2020 Solids, total suspended 214. 100. mg/L INST MAX Observation 2: Part B.I.E.2 of the permit states, "The permittee shall at all times properly operate and maintain all facilities and systems of treatment and control (and related appurtenances) which are installed or used by the permittee to achieve compliance with the terms and conditions of this permit. Proper operation and maintenance includes, but is not limited to, adequate laboratory controls including appropriate quality assurance procedures. This provision also includes the operation of backup or auxiliary facilities or similar systems that are installed by the permittee, only when necessary to achieve compliance with the terms and conditions of this permit." During the site inspection, the EPA Inspection Team observed several components of the treatment train that were not operating properly. The facility did not have a copy of the Emergency Response Plan (ERP), Operation & Maintenance (O&M) manual, or logbook on site. The administrative building of the WWTP was under construction during the site visit and Mr. Bove and Ms. Nichols indicated this was due to the construction. The ERP provided electronically ater the inspection by Ms.Nichols appeared to last be updated in January 2018. The facility contacts listed on the document were not accurate. The updated contacts were provided in a separate file but were directly incorporated into assigned ERP (Attachment 10). The O&M manual provided electronically ater the inspection by Ms.Nichols is dated July 2009 and has not been updated to accurately reflect the facility (Attachment 11). The O&M states, "the current NPDES Permit for the facility has an effective date of April 17, 2003, and an expiration date of April 18, 2008." This and minor modifications in red indicate that the O&M has not been officially revaluated during the current permit cycle. The address listed in the O&M has not been updated. The listed address is 901 Oak Ridge Road, Hazleton, PA 18202. The updated address provided by the facility is 653 Oak Ridge Rd Hazle Township, PA 18202. Clarifier #2 had areas of floc accumulation on the clarifier arm and in the center of the clarifier ring. There was build up of biological growth attached to the clarifier arm and Unique Project #: ECAD-524 Page 7 of 11 CAN DO Inc. Humboldt 03/11/2024 the weir. The water of Clarifier #2 appeared to have high turbidity and cloudy consistency indicating poor settleability (Photographs 31-37). The post-UV depth channels had considerable biological growth along the sides of the channel (Photograph 42). The wastewater outfall appeared to have a cloudy consistency and there was visible foam in the receiving stream (Photograph 47) There was an active light alarm during the inspection on the Outdoor Control Panel on the Pump #1 Variable Frequency Drive. Mr. Bove stated that the alarm was because of a sand filter pump failure, and that the alarm had occurred that morning before the EPA Inspection Team's arrival (Photographs 56 and 57). Observation 3: Part 3.C.2 of the permit states, "the permittee shall provide notice to DEP as soon as possible but no later than 45 days prior to any planned changes in the volume or pollutant concentration of its influent waste stream as a result of indirect discharges or hauled-in wastes, as specified in paragraphs 2.a. and 2.b.... a. Introduction of New Pollutants (25 Pa. Code 92a.24(a)) ... b. Increased Loading of Approved Pollutants (25 Pa. Code 92a.24(a)) ..." In 2022, the Niagra bottling facility came online and is now the facility's largest contributor. According to Mr. Pietroski the WWTP Daily Avg Flow is approximately 700k-800k GPD and Niagra alone is 300k-400k GPD. Niagra's influent is coming from Greater Hazleton public drinking water supply. Greater Hazleton is using a zinc orthophosphate for corrosion control. In 2022-2023 the WWTP was in SNC for Zinc exceedances and facility representatives indicated that the discharge coming from Niagra was the likely source. Ms. Nichols also stated that ammonia/phosphorus violations at the WWTP were believed to be coming from the Hershey facility and a bakery at the industrial park. It was unclear at the time of inspection if PADEP was notified prior to the reported Zinc exceedances of Niagra coming online and that the associated wastewater contributions would double the flow to the WWTP. Mr. Pietroski and Mr. Bovestated that there are no flow meters or regular sampling established at any of the industries. Mr. Pietroski stated that they have the capability to sample on an as needed basis. It was also unclear if the introduction of each new industry which would alter the quantity of flow, alter the concentration of current pollutants, or introduce new pollutants for any of the Unique Project #: ECAD-524 Page 8 of 11 CAN DO Inc. Humboldt 03/11/2024 industries contributing to the WWTP, is being reported to PADEP. It is also unclear if the facility is routinely checking with the industries to ensure their waste stream is not changing. The facility has proposed a solution to revise the tariff to include language that gives them the ability to regulate what is coming into the plant from the industries. However, because CAN DO Inc. is not a Publicly Owned Treatment Works (POTW) as defined in 40 CFR 403.3(q) it is not authorized to enforce a pretreatment program as stipulated in 40 CFR Part 403. IV. Records Review The following documents were requested by the EPA Inspection Team following the EPA inspection: DMRS from 2021-2023 Most up to date: PPC, ERP, and O&M. Requested to specify if the language for multiple of these plans is included in a combined document. Documentation from the survey conducted that marked the stormwater outfall 002 further downstream from the intended outfall location directly next to Outfall 001. Most current list and map of all industries located at the CAN DO facility and specification on which discharge to your facility vs. Greater Hazleton SA. All routine/repair maintenance work orders and any inspection logs written from 3/1/23-4/1/23 and 2/23/24-3/11/2024. A copy of the last PADEP inspection report. Any communications with PADEP regarding effluent exceedances, changes to waste stream, or increased loading of approved/new pollutants dating back to 2019. Ms, Nichols sent information to the EPA Inspection Team on April 4, 2024. Most of the documents requested were provided, however, the routine/repair maintenance work orders and any inspection logs written from 3/1/23-4/1/23 and 2/23/24-3/11/2024 were missing. Sample checklists and inspection logs were provided but were not filled out for the requested timeframe. After the EPA Inspection, PADEP conducted an inspection of the facility on March 20, 2024 (Attachment 4). Ms. Nichols provided the inspection report as part of the requested documents package. An incident was reported to PADEP by an observer of the receiving stream to which the facility discharges. Logs reviewed by PADEP indicated that the upset occurred some time between February 29 and March 1, 2024. EPA was originally scheduled to conduct their inspection on February 28, 2024, but rescheduled due to Ms, Nichols' request to postpone due to the WWTP office building being under construction. Email correspondence of this request is attached as Attachment 5. Unique Project #: ECAD-524 Page 9 of 11 CAN DO Inc. Humboldt 03/11/2024 As a result of the March 20, 2024, PADEP inspection, PADEP issued 2 violations for (1) failure to report a pollution incident to DEP and (2) Discharge of floating materials, scum, sheen, foam, oil, grease or substances that produced an observable change to the receiving stream. PADEP requested daily effluent composite samples and status updates until the facility returns to compliance. According to the PADEP inspection report, the facility suspected the upset was caused by one of its industries in the park. The specific industry was not indicated. V. Closing Conference After the facility walk, the EPA Inspection Team met with the facility representatives for a closing conference. The EPA Inspection Team shared preliminary observations with the facility. The EPA Inspection Team reiterated to the facility representatives that all preliminary observations discussed were not compliance determinations. Any and 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. The inspection concluded at approximately 3 PM. Unique Project #: ECAD-524 Page 10 of 11 CAN DO Inc. Humboldt 03/11/2024 VI. List of Attachments Attachment 1: Attachment 2: Attachment 3: Attachment 4: Attachment 5: Attachment 6: Attachment 7: Attachment 8: Attachment 9: Attachment 10: Attachment 11: Photograph Log List of Industries from CAN DO Website Humboldt Industrial Park map 3.20.2024 PADEP Inspection with Violations CAN DO Inc. Email Requesting EPA CEI Postponement 2.22.24 CAN DO Inc. PA0060046 NPDES PERMIT Stormwater Outfall Topographic Map Email PADEP 5.9.22 - Storm Outfall Location PPC Plan Recommendation-Explanation from DEP WWTP Emergency Response Plan O&M Manual CAN DO WWTP - July 2009 Unique Project #: ECAD-524 Page 11 of 11