Document 3N8Z27NNEpG6GL32br2gKY1Ka

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY New England Regional Laboratory Laboratory Services and Applied Science Division 11 Technology Drive, North Chelmsford, MA 01863 Report Memorandum Drafted Date: 11/16/2021 Finalized Date: 01/4/2022 Subject: Pretest Observation Report - The Metropolitan District Hartford Water Pollution Control Facility From: Alysha Murphy, Environmental Scientist Field Services Branch (FSB) /ADM/ Tyler Kotsifas, Environmental Scientist FSB /TLK/ Through: Jerry Keefe, Team Leader, FSB /JCK/ Laboratory Services and Applied Science Division To: Christine Sansevero, Chief, Air Compliance Section Enforcement and Compliance Assurance Division Facility Information: A. Facility Name: B. Facility Location: C. Facility Contact: D. ICIS-Air #: The Metropolitan District Hartford Water Pollution Control Facility (MDC) 240 Brainard Road, Hartford, CT 06114 Thomas Tyler, Director of Facilities CT0000000900303405 Background Information: A. Date of inspection: October 27,2021 B. US EPA Representative(s): William Osbahr, Alysha Murphy, Tyler Kotsifas C. Inspection Purpose: Follow-up Inspection - Pretest Meeting for proposed emission testing for ECAD Disclaimer: Unless otherwise noted, this report describes conditions at the facility/property as observed by EPA inspector(s), and/or through records provided to and/or information reported to EPA inspector(s) by facility representatives and as understood by the inspector(s). This report may not capture all operations or activities ongoing at the time of the inspection. This report does not make final determinations on potential areas of concern. Nothing in this report affects EPA's authorities under federal statutes and regulations to pursue further investigation or action. Observation Notes: Inspection Participants: Name William Osbahr Alysha Murphy Tyler Kotsifas Jeff Bowers Craig Scott Ryon Jagoda Glenn Casells Charlie Albert Leigh Gammie Title Stack Testing Coordinator Environmental Scientist Environmental Scientist Project Manager, Operating Parameters, Process Operations Regulatory Compliance Inspection Operating Parameters, Process Operations Site Operator Site Operator Emission Testing and Reporting Organization USEPA USEPA USEPA MDC MDC MDC MDC MDC Gammie Air On October 27, 2021, EPA representatives Mr. Osbahr, Ms. Murphy, and Mr. Kotsifas (EPA Team) attended a pretest meeting at The Metropolitan District Hartford Water Pollution Control Facility (MDC). EPA Team arrived onsite at 0840 hrs. The EPA Team presented credentials to Mr. Bowers, Mr. Scott, and Mr. Gammie and Mr. Osbahr initiated the pretest meeting Observations: During the opening conference Mr. Bowers gave a description of the plant operations. He described the gravity process, the centrifuge process, and Multiple Hearth Incinerators (MHI) operations. He stated that the goal for MDC is to maintain approximately 30% solids in their sludge fed to the incinerator. Mr. Bower stated that MDC operates the MHIs on a 24/7 schedule. He further stated that the plant only operates 2 of the 3 MHIs at any given time and that MDC receives a large portion of their sludge from other regional sewage facilities. Mr. Bowers explained that the plant uses approximately 450 psi steam to run a generator which yields 32% of the electrical power for the plant. Mr. Bowers described in detail the dry ash conveyor system which is used in concert with 2 silos. Overall, MDC removes 2-3 trucks a day yielding approximately 800 ton per month. The EPA team discussed the testing protocol and schedule. MDC representatives generated a draft hard copy at the start of the visit. Mr. Gammie stated that the protocol was generated from the past protocol from the fall of 2019. Mr. Bowers stated that he would work on finalizing the protocol with Mr. Gammie. Mr. Osbahr stated the EPA would review the protocol and reach out ot MDC with comments. Mr. Scott asked if the monitoring plan that MDC has been working on and has submitted would be reviewed in time for testing on the week of November 29, 2021. Mr. Osbahr recommended that Mr. Scott reach out to Christine Sansevero regarding its review. The group completed the opening conference and toured the facility. The group toured the sludge processing building, facility control room, and the SCADA control room. The Group toured the stack locations. Mr. Osbahr explained that the 3 stack locations appeared to be the same configuration that existed in the fall of 2019. Mr. Osbahr pointed out what appeared to be newly rusted penetrations in the stack. Mr. Bowers stated that all penetrations will be fixed prior to emissions testing. The group toured the facility camera systems. The group then held a closing conference. Mr. Osbahr stated that he would get back to MDC regarding the proposed dates. Mr. Scott stated that MDC was considering a three-week period starting on approximately November 29, 2021. Mr. Osbahr explained some of the possible means by which EPA would cover testing including remote observations. Mr. Osbahr said the EPA team would review internally how best to cover testing. Mr. Osbahr again recommended that MDC reach out to Ms. Sansevero regarding the monitoring plan. He stated that he was aware of an ongoing review but didn't know the present status. The EPA Team left the facility at 1140 hrs.