Document 4JDb7b0M9gYR1ZBrQm2DYXd4V

U.S. ENVIRONMENTAL PROTECTION AGENCY REGION III WATER BRANCH, ENFORCEMENT AND COMPLIANCE ASSURANCE DIVISION CLEAN WATER ACT COMPLIANCE INSPECTION REPORT for Name of Facility: Potomac River Water Filtration Plant (WFP) Facility Address: 12200 River Road, Potomac, MD 20854 Mailing Address: 14501 Sweitzer Lane, Laurel, MD 20724 Report Prepared on: March 8, 2022 Date Report Final as of: Date By:___________________________________ Environmental Scientist (PG Environmental) Signature Digitally signed by PETER PETER GOLD GOLD Date: 2022.03.17 16:49:47 By: -04'00' , EPA Signature General Information Type of Inspection: Owner: Operator: Permittee: NPDES Permit No: NPDES Permit Effective Date: NPDES Permit Expiration Date: Receiving Water: Latitude and Longitude: Wastewater Treatment Facility CEI Washington Suburban Sanitary Commission Washington Suburban Sanitary Commission Washington Suburban Sanitary Commission MD0051586 December 12, 2019 November 30, 2024 Potomac River 39.038056, -77.255 On-Site Facility Inspection Overview On February 16, 2022, a representative from U.S. Environmental Protection Agency (EPA) Region III, and EPA's contract inspectors from PG Environmental and ERG (the EPA Inspection Team), conducted a compliance evaluation inspection at the Potomac River Water Filtration Plant (Facility) in Potomac, Maryland. Washington Suburban Sanitary Commission (WSSC) is identified as the Permittee and owns and operates the Facility. A representative from the Maryland Department of the Environment (MDE) attended the inspection. Approximate Entry Time: 9:30 AM (EST) Approximate Exit Time: 3:20 PM (EST) Unique Project Identifier (UPI): 3E22WN031A Unique Project Identifier: 3E22WN031A Page 1 of 15 Inspection Date: February 16, 2022 Potomac River Water Filtration Plant (MD0051586) Compliance Evaluation Inspection Report TABLE OF CONTENTS Page I. INTRODUCTION............................................................................................................................ 3 II. INSPECTION PROCESS ................................................................................................................ 3 Inspection Opening Conference .......................................................................................................3 Facility Site Walk.............................................................................................................................4 Records Review ...............................................................................................................................5 Summary of Observations................................................................................................................5 Closing Conference........................................................................................................................15 List of Attachments Appendix A: Photograph Log Appendix B: Exhibit Log o Exhibit 1 - Potomac River Water Filtration Plant Process Diagram o Exhibit 2 - EPA ICIS Data (December 1, 2019 through December 31, 2021) o Exhibit 3 - ICIS Spreadsheet Notes (January 1, 2021 through December 31, 2021) o Exhibit 4 - EPA ECHO Detailed Facility Report o Exhibit 5 - Fourth Quarter 2021 Consent Decree Status Report Appendix C: NPDES Permit No. MD0051586 Appendix D: Consent Decree Unique Project Identifier: 3E22WN031A Page 2 of 15 Inspection Date: February 16, 2022 Potomac River Water Filtration Plant (MD0051586) Compliance Evaluation Inspection Report I. INTRODUCTION On February 16, 2022, a representative from U.S. Environmental Protection Agency (EPA) Region III and EPA's contract inspectors from PG Environmental and ERG (hereinafter, collectively referred to as the EPA Inspection Team) inspected the Potomac River Water Filtration Plant (hereinafter, Facility) in Potomac, Maryland. A representative from the Maryland Department of the Environment (MDE) attended the inspection. Washington Suburban Sanitary Commission (WSSC) is identified as the Permittee and owns and operates the Facility. The primary purpose of the inspection was to review basic treatment processes at the Potomac River Water Filtration Plant, evaluate operations related to the waste stream, review the accuracy and reliability of the Permittee's self-monitoring and reporting program, and obtain information that will assist EPA in assessing the Permittee's compliance with the requirements of the Permit. The weather at the time of the inspection was mild and overcast. The Facility provides drinking water to residents, businesses, and industries in Montgomery County and Prince Georges County, Maryland. The Facility produces about 100 million gallons per day (MGD) of water for distribution and is rated to produce as much as 285 MGD. The majority of the solids from the flocculation and sedimentation processes for produced water are sent to an onsite solids handling facility which further processes solids and discharges to DC Water's collection system, and ultimately the Blue Plains Wastewater Treatment Plant (WWTP). Backwash from the Facility's granular media filters (along with any reservoir leakage, stormwater, or emergency bypass flow) is discharged through Outfall 001A. Outfall 001A discharges are covered under National Pollutant Discharge Elimination System (NPDES) Permit No. MD0051586 (hereinafter, the Permit; refer to Appendix C) and were the focus of the inspection. A Consent Decree was entered into by the Facility and the Potomac Riverkeeper, the Chesapeake Bay Foundation, and MDE on April 15, 2016, due to alleged violations of the Clean Water Act (CWA) and the Permit. The Consent Decree requires the Facility to make short-term operational changes and capital improvements with the goal of significantly reducing the solids loading discharged into the Potomac River by January 1, 2026, as well as achieve Permit effluent limits (refer to Appendix D). II. INSPECTION PROCESS Inspection Opening Conference The EPA Inspection Team arrived at the Facility at 9:30 AM (EST) for the inspection. Jake Albright of PG Environmental displayed his CWA inspector credential to Mr. Eric Liang and Mr. Hector Rojas, both Plant Engineering Section Managers, at the outset of the inspection and explained the purpose of the inspection was to observe compliance with the Permit. The EPA Inspection Team informed the Permittee 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. Table 1 describes the individuals that participated in the inspection. Unique Project Identifier: 3E22WN031A Page 3 of 15 Inspection Date: February 16, 2022 Potomac River Water Filtration Plant (MD0051586) Compliance Evaluation Inspection Report Table 1. Inspection Attendee List Name Affiliation Telephone Email EPA Region III Inspectors and Contractors Jake Albright PG Environmental (703) 956-1957 jake.albright@pgenv.com Angela Weisel EPA Region III (215) 814-2124 weisel.angela@epa.gov Michael Beck ERG (331) 643-9987 mike.beck@erg.com Renato Cuizon Maryland Department of the Environmental MDE (443)-829-9427 renato.cuizon1@maryland.gov Eric Liang, Section Manager, Plant Engineering Hector Rojas, Section Manager, Plant Engineering WSSC WSSC Facility Representative (301) 206-7399 (301) 206-7393 eric.liang@wsscwater.com hector.rojas@wsscwater.com Facility Site Walk As part of the inspection process, the EPA Inspection Team visually observed the treatment train and site conditions in the presence of the Facility representatives. The EPA Inspection Team began the site walk in the Facility's main administrative and operations building to observe operator certificates, logbooks, the onsite laboratory, and the Facility's supervisory control and data acquisition (SCADA) system (refer to Appendix A, Photograph 1). The EPA Inspection Team continued to the raw water compliance sampling location as well as the pipe gallery under the reservoirs in order to observe newly replaced effluent valves (refer to Appendix A, Photographs 2 through 5). The EPA Inspection Team then proceeded to the raw water intake and followed the produced water treatment train through to the dual media filters, including stopping to inspect Outfall 001A and the effluent monitoring station and sampling vault (Vault 47). Water Production The water production process consists of the following components: Raw water intake with bar screens and two raw water pump stations (refer to Appendix A, Photographs 6 and 7) Potassium permanganate addition (refer to Appendix A, Photograph 8) Four rapid mix tanks and flocculation basins (with coagulant addition and pH adjustment; refer to Appendix A, Photographs 9 and 10) Sedimentation basins (refer to Appendix A, Photograph 9) Dual granular media filters (refer to Appendix A, Photograph 12) Ultraviolet (UV) light and chlorine disinfection (refer to Appendix A, Photograph 13) Raw water is pulled from the Potomac River through the intake via Raw Water Pump Stations 1 and 2, which convey water to be processed to either the east or west treatment train. The Facility is capable of injecting potassium permanganate as needed after the intake for algae control and can inject carbon into the process in case of an emergency (e.g., a fuel spill entering the intake). From there, the water enters one of four rapid mixers where sulfuric acid can be added for pH adjustment, and poly aluminum chloride (PAC) is added as a coagulant. The Facility also has ferric sulfate on hand to use as coagulant if needed but was not using it at the time of the inspection. Following the rapid mix process, the water enters the sedimentation basins, followed by the dual media filters. Produced water is disinfected via UV light and chlorine prior to being distributed or stored for consumption. A Facility diagram is included in Appendix B, Exhibit 1. Unique Project Identifier: 3E22WN031A Page 4 of 15 Inspection Date: February 16, 2022 Potomac River Water Filtration Plant (MD0051586) Compliance Evaluation Inspection Report Process Solids and Effluent Streams Process wastewater effluent created and discharged onsite through Outfall 001A is composed of water from the dual media filter backwash cycles, filter to waste events (for maintenance or in case of emergency), water storage reservoir leakage, and stormwater runoff (refer to Appendix A, Photograph 5). The Facility can add sodium bisulfite at two locations to remove chlorine prior to discharge. Effluent is monitored in Vault 47, just upstream of Outfall 001A, prior to being discharged to the Potomac River (refer to Appendix A, Photographs 14 through 17). Settled solids from the flocculation and sedimentation processes are collected and sent to the onsite solids handling facility to be further processed. Discharges from the solids handling facility are conveyed to DC Water's collection system and the Blue Plains WWTP. The solids handling facility was not a focus of the EPA inspection. Records Review The EPA Inspection Team conducted a records review to evaluate the Permittee's compliance with the Permit. Most of the records and reports required by the Permit were available for review prior to and after the inspection. Plant equipment operation and maintenance (O&M) manuals, laboratory standard operating procedures (SOPs) and calibration records were reviewed onsite. The Permittee's electronic discharge monitoring reports (eDMRs) and monthly operating reports (MORs) were obtained electronically and reviewed offsite after the onsite inspection. The following were reviewed: eDMRs and MORs (January 2021 through December 2021) Facility Data in EPA's Integrated Compliance Information System (ICIS) Database (December 1, 2019, and December 31, 2021) Weekly Discharge Sampling sheets (2019 through 2021) Discharge Exceedance Reports (January 2021 through December 2021) EPA's Enforcement and Compliance History Online (ECHO) Detailed Facility Report Consent Decree Status Reports (Third and Fourth Quarters 2021) Chain of custody for offsite laboratory samples (January 1, 2021, through December 31, 2021) Calibration records for raw water and effluent flowmeters Summary of Observations The following section summarizes the EPA Inspection Team's observations relative to the Permittee's Permit requirements, including the status of certain treatment units, operation and maintenance practices, and the Permittee's monitoring and reporting documentation. Discharge Limitations and Monitoring Requirements Section II.A of the Permit defines discharge limitations for Outfall 001A. Based on a review of EPA's ICIS database and the Facility's eDMR submittals, the EPA Inspection Team observed 135 effluent limit exceedances from Outfall 001A between December 1, 2019, and December 31, 2021 (refer to Appendix B, Exhibit 2 for the ICIS Data and Table 2 below for a summary of exceedances). Unique Project Identifier: 3E22WN031A Page 5 of 15 Inspection Date: February 16, 2022 Potomac River Water Filtration Plant (MD0051586) Compliance Evaluation Inspection Report Table 2. Outfall 001A Final Effluent Exceedances (December 2019 through December 2021) Permit # Monitoring Period End Date Parameter Name DMR Value Permit Limit Units Limit Type MD0051586 12/31/2021 Aluminum, total recoverable 4.2 4 mg/L Average monthly MD0051586 11/30/2021 Turbidity 874 150 NTU Max. Daily MD0051586 11/30/2021 Solids, total suspended 8266.575 4304 lbs/day Max. Daily MD0051586 11/30/2021 Solids, total suspended 147 60 mg/L Max. Daily MD0051586 11/30/2021 Solids, total suspended 33 30 mg/L Average monthly MD0051586 MD0051586 11/30/2021 11/30/2021 Aluminum, total recoverable Aluminum, total recoverable 9 8 mg/L Max. Daily 5 4 mg/L Average monthly MD0051586 10/31/2021 Turbidity 1000 150 NTU Max. Daily MD0051586 10/31/2021 Solids, total suspended 362 60 mg/L Max. Daily MD0051586 10/31/2021 Solids, total suspended 4373.246 2152 lbs/day Average monthly MD0051586 10/31/2021 Solids, total suspended 19635.62 4304 lbs/day Max. Daily MD0051586 10/31/2021 Solids, total suspended 78 30 mg/L Average monthly MD0051586 10/31/2021 Iron, total (as Fe)* 10.1 8 mg/L Max. Daily MD0051586 MD0051586 MD0051586 MD0051586 10/31/2021 10/31/2021 10/31/2021 10/31/2021 Aluminum, total recoverable Aluminum, total recoverable Aluminum, total recoverable Aluminum, total recoverable 19.6 405.93 7.3 1092.812 8 mg/L 287 lbs/day 4 mg/L 574 lbs/day Max. Daily Average monthly Average monthly Max. Daily MD0051586 9/30/2021 Turbidity 990 150 NTU Max. Daily MD0051586 9/30/2021 Solids, total suspended 18292.85 4304 lbs/day Max. Daily MD0051586 9/30/2021 Solids, total suspended 47 30 mg/L Average monthly MD0051586 9/30/2021 Solids, total suspended 322 60 mg/L Max. Daily MD0051586 9/30/2021 Solids, total suspended 2818.514 2152 lbs/day Average monthly MD0051586 MD0051586 9/30/2021 9/30/2021 Aluminum, total recoverable Aluminum, total recoverable 22.6 1283.779 8 mg/L 574 lbs/day Max. Daily Max. Daily MD0051586 8/31/2021 Turbidity 636 150 NTU Max. Daily MD0051586 8/31/2021 Solids, total suspended 4873.16 4304 lbs/day Max. Daily MD0051586 8/31/2021 Solids, total suspended 87 60 mg/L Max. Daily MD0051586 MD0051586 8/31/2021 8/31/2021 Aluminum, total recoverable Aluminum, total recoverable 10.7 592.8978 8 mg/L 574 lbs/day Max. Daily Max. Daily MD0051586 7/31/2021 Turbidity 1000 150 NTU Max. Daily MD0051586 7/31/2021 Solids, total suspended 35 30 mg/L Average monthly MD0051586 7/31/2021 Solids, total suspended 169 60 mg/L Max. Daily MD0051586 7/31/2021 Solids, total suspended 12641.82 4304 lbs/day Max. Daily MD0051586 7/31/2021 Solids, total suspended 2356.594 2152 lbs/day Average monthly Unique Project Identifier: 3E22WN031A Page 6 of 15 Inspection Date: February 16, 2022 Potomac River Water Filtration Plant (MD0051586) Compliance Evaluation Inspection Report Permit # MD0051586 MD0051586 MD0051586 MD0051586 MD0051586 MD0051586 MD0051586 MD0051586 MD0051586 MD0051586 MD0051586 MD0051586 MD0051586 MD0051586 MD0051586 MD0051586 MD0051586 MD0051586 MD0051586 MD0051586 MD0051586 MD0051586 MD0051586 MD0051586 MD0051586 MD0051586 MD0051586 MD0051586 MD0051586 MD0051586 MD0051586 MD0051586 MD0051586 MD0051586 MD0051586 Monitoring Period End Date 7/31/2021 7/31/2021 6/30/2021 6/30/2021 6/30/2021 6/30/2021 6/30/2021 6/30/2021 6/30/2021 6/30/2021 6/30/2021 6/30/2021 5/31/2021 5/31/2021 5/31/2021 4/30/2021 3/31/2021 3/31/2021 3/31/2021 3/31/2021 3/31/2021 3/31/2021 3/31/2021 3/31/2021 3/31/2021 3/31/2021 3/31/2021 3/31/2021 3/31/2021 3/31/2021 2/28/2021 2/28/2021 2/28/2021 2/28/2021 1/31/2021 Parameter Name Aluminum, total recoverable Aluminum, total recoverable Turbidity Solids, total suspended Solids, total suspended Solids, total suspended Solids, total suspended Iron, total (as Fe)* Aluminum, total recoverable Aluminum, total recoverable Aluminum, total recoverable Aluminum, total recoverable Turbidity Solids, total suspended Solids, total suspended Turbidity Turbidity Turbidity Solids, total suspended Solids, total suspended Solids, total suspended Solids, total suspended Iron, total (as Fe)* Iron, total (as Fe)* Iron, total (as Fe)* Iron, total (as Fe)* Aluminum, total recoverable Aluminum, total recoverable Aluminum, total recoverable Aluminum, total recoverable Solids, total suspended Solids, total suspended Solids, total suspended Aluminum, total recoverable Turbidity DMR Value 867.8504 11.6 987 54 3184.451 350 19276.68 9.1 1534.735 4.9 292.9495 29.2 184 13342.7 264 348 1000 68 13766.63 3470 302165.9 180 346.9402 75.1 4.7 6539.873 159 12.5 885.8473 13845.61 9281.4 34 182 5.2 1000 Unique Project Identifier: 3E22WN031A Page 7 of 15 Permit Limit Units Limit Type 574 lbs/day Max. Daily 8 150 30 2152 60 4304 8 574 mg/L NTU mg/L lbs/day mg/L lbs/day mg/L lbs/day Max. Daily Max. Daily Average monthly Average monthly Max. Daily Max. Daily Max. Daily Max. Daily 4 mg/L Average monthly 287 lbs/day Average monthly 8 150 4304 8 150 150 50 2152 60 4304 30 287 8 4 574 8 mg/L NTU lbs/day mg/L NTU NTU NTU lbs/day mg/L lbs/day mg/L lbs/day mg/L mg/L lbs/day mg/L Max. Daily Max. Daily Max. Daily Max. Daily Max. Daily Max. Daily Average monthly Average monthly Max. Daily Max. Daily Average monthly Average monthly Max. Daily Average monthly Max. Daily Max. Daily 4 mg/L Average monthly 287 lbs/day Average monthly 574 4304 30 60 4 150 lbs/day lbs/day mg/L mg/L mg/L NTU Max. Daily Max. Daily Average monthly Max. Daily Average monthly Max. Daily Inspection Date: February 16, 2022 Potomac River Water Filtration Plant (MD0051586) Compliance Evaluation Inspection Report Permit # MD0051586 MD0051586 MD0051586 MD0051586 MD0051586 MD0051586 MD0051586 MD0051586 MD0051586 MD0051586 MD0051586 MD0051586 MD0051586 MD0051586 MD0051586 MD0051586 MD0051586 MD0051586 MD0051586 MD0051586 MD0051586 MD0051586 MD0051586 MD0051586 MD0051586 MD0051586 MD0051586 MD0051586 MD0051586 MD0051586 MD0051586 MD0051586 MD0051586 MD0051586 MD0051586 Monitoring Period End Date 1/31/2021 1/31/2021 1/31/2021 1/31/2021 12/31/2020 12/31/2020 11/30/2020 11/30/2020 11/30/2020 11/30/2020 11/30/2020 10/31/2020 10/31/2020 10/31/2020 10/31/2020 10/31/2020 10/31/2020 10/31/2020 10/31/2020 10/31/2020 10/31/2020 10/31/2020 10/31/2020 10/31/2020 9/30/2020 9/30/2020 9/30/2020 9/30/2020 9/30/2020 9/30/2020 9/30/2020 9/30/2020 8/31/2020 8/31/2020 8/31/2020 Parameter Name Solids, total suspended Solids, total suspended Aluminum, total recoverable Aluminum, total recoverable Turbidity pH Turbidity Solids, total suspended Aluminum, total recoverable Aluminum, total recoverable Aluminum, total recoverable Turbidity Solids, total suspended Solids, total suspended Solids, total suspended Solids, total suspended Iron, total (as Fe)** Iron, total (as Fe)** Iron, total (as Fe)** Iron, total (as Fe)** Aluminum, total recoverable Aluminum, total recoverable Aluminum, total recoverable Aluminum, total recoverable Turbidity Solids, total suspended Solids, total suspended Solids, total suspended Solids, total suspended Iron, total (as Fe)** Aluminum, total recoverable Aluminum, total recoverable Turbidity Solids, total suspended Solids, total suspended DMR Value 69 31 9.7 5.4 300 6.1 186 66 11.4 4.6 679.8828 1000 93 6431.891 123012.8 1760 332.9426 3690.364 52.8 4.9 423.9269 6.2 4920.152 70.4 189 37 2180.624 4438.235 69 8.2 4.2 8.3 927 2575.556 8567.523 Unique Project Identifier: 3E22WN031A Page 8 of 15 Permit Limit 60 30 8 Units mg/L mg/L mg/L Limit Type Max. Daily Average monthly Max. Daily 4 mg/L 150 NTU 6.5 SU 150 NTU 60 mg/L 8 mg/L Average monthly Max. Daily Minimum Max. Daily Max. Daily Max. Daily 4 mg/L Average monthly 574 150 30 2152 4304 60 287 574 8 4 287 lbs/day NTU mg/L lbs/day lbs/day mg/L lbs/day lbs/day mg/L mg/L lbs/day Max. Daily Max. Daily Average monthly Average monthly Max. Daily Max. Daily Average monthly Max. Daily Max. Daily Average monthly Average monthly 4 mg/L Average monthly 574 lbs/day Max. Daily 8 150 30 2152 4304 60 8 4 mg/L NTU mg/L lbs/day lbs/day mg/L mg/L mg/L Max. Daily Max. Daily Average monthly Average monthly Max. Daily Max. Daily Max. Daily Average monthly 8 150 2152 4304 mg/L NTU lbs/day lbs/day Max. Daily Max. Daily Average monthly Max. Daily Inspection Date: February 16, 2022 Potomac River Water Filtration Plant (MD0051586) Compliance Evaluation Inspection Report Permit # Monitoring Period End Date Parameter Name DMR Value MD0051586 8/31/2020 Solids, total suspended 104 MD0051586 8/31/2020 Solids, total suspended 37 MD0051586 8/31/2020 Iron, total (as Fe)** 708.8778 MD0051586 8/31/2020 Iron, total (as Fe)** 8.6 MD0051586 MD0051586 MD0051586 8/31/2020 8/31/2020 8/31/2020 Aluminum, total recoverable Aluminum, total recoverable Aluminum, total recoverable 4.1 1268.781 15.4 MD0051586 6/30/2020 Turbidity 724 MD0051586 6/30/2020 Solids, total suspended 5124.117 MD0051586 6/30/2020 Solids, total suspended 65 MD0051586 6/30/2020 Solids, total suspended 456 MD0051586 6/30/2020 Solids, total suspended 32723.36 MD0051586 6/30/2020 Iron, total (as Fe)* 911.8428 MD0051586 6/30/2020 Iron, total (as Fe)* 12.7 MD0051586 MD0051586 MD0051586 MD0051586 6/30/2020 6/30/2020 6/30/2020 6/30/2020 Aluminum, total recoverable Aluminum, total recoverable Aluminum, total recoverable Aluminum, total recoverable 402.9305 2475.573 5.1 34.5 MD0051586 5/31/2020 Turbidity 727 MD0051586 5/31/2020 Solids, total suspended 169 MD0051586 5/31/2020 Solids, total suspended 2295.604 MD0051586 5/31/2020 Solids, total suspended 14275.54 MD0051586 5/31/2020 Iron, total (as Fe)* 629.8914 MD0051586 MD0051586 5/31/2020 5/31/2020 Aluminum, total recoverable Aluminum, total recoverable 10.9 920.8413 MD0051586 4/30/2020 Turbidity 500 MD0051586 4/30/2020 Solids, total suspended 155 MD0051586 4/30/2020 Solids, total suspended 2594.553 MD0051586 4/30/2020 Solids, total suspended 22463.13 MD0051586 4/30/2020 Iron, total (as Fe)* 819.8587 MD0051586 4/30/2020 Aluminum, total recoverable 1150.802 MD0051586 1/31/2020 Turbidity 236 MD0051586 1/31/2020 Solids, total suspended 2449.578 MD0051586 MD0051586 1/31/2020 1/31/2020 Aluminum, total recoverable Aluminum, total recoverable 329.9431 583.8994 Unique Project Identifier: 3E22WN031A Page 9 of 15 Permit Limit 60 30 574 8 4 Units mg/L mg/L lbs/day mg/L mg/L Limit Type Max. Daily Average monthly Max. Daily Max. Daily Average monthly 574 lbs/day Max. Daily 8 150 2152 30 60 4304 574 8 287 mg/L NTU lbs/day mg/L mg/L lbs/day lbs/day mg/L lbs/day Max. Daily Max. Daily Average monthly Average monthly Max. Daily Max. Daily Max. Daily Max. Daily Average monthly 574 lbs/day Max. Daily 4 mg/L Average monthly 8 150 60 2152 4304 574 8 mg/L NTU mg/L lbs/day lbs/day lbs/day mg/L Max. Daily Max. Daily Max. Daily Average monthly Max. Daily Max. Daily Max. Daily 574 150 60 2152 4304 574 574 150 2152 287 lbs/day NTU mg/L lbs/day lbs/day lbs/day lbs/day NTU lbs/day lbs/day Max. Daily Max. Daily Max. Daily Average monthly Max. Daily Max. Daily Max. Daily Max. Daily Average monthly Average monthly 574 lbs/day Max. Daily Inspection Date: February 16, 2022 Potomac River Water Filtration Plant (MD0051586) Compliance Evaluation Inspection Report Permit # MD0051586 MD0051586 MD0051586 MD0051586 MD0051586 MD0051586 Monitoring Period End Date 12/31/2019 12/31/2019 12/31/2019 12/31/2019 12/31/2019 12/31/2019 Parameter Name Solids, total suspended Solids, total suspended Solids, total suspended Aluminum, total recoverable Aluminum, total recoverable Aluminum, total recoverable DMR Value 3526.392 19567.63 102 11.7 475.918 2244.613 Permit Limit 2152 4304 60 8 287 574 Units lbs/day lbs/day mg/L mg/L lbs/day lbs/day Limit Type Average monthly Max. Daily Max. Daily Max. Daily Average monthly Max. Daily Footnote (8) in Section II.A of the Permit states, "The effluent limitations for Total Iron as Fe shall be applicable during the periods when iron compound(s) are used in water treatment processes for the drinking water production." * The elevated iron levels reported in March, June, and October 2021, as well as in April, May, and June 2020 would not be considered effluent limit exceedances because ironbased compounds were not being added to the treatment process. This is documented in the ICIS data notes (refer to Appendix B, Exhibit 3). These 10 values are not included in the total number of exceedances referenced above (135). ** The ICIS data notes state, "On August 10, 2020 the Plant initiated low dosage blending of ferric sulfate, an iron-based coagulant, with the primary coagulant, polyaluminum chloride. Until that date, a ferric based coagulant had not been used in the water treatment process at the Plant since November 2, 2018." Thus, the elevated levels of iron observed in August, September, and October 2020 would be considered effluent limit exceedances. These 7 values are included in the total number of exceedances referenced above. According to EPA's ECHO Detailed Facility Report, violations were identified for the Facility in the fourth quarter of 2019 and first quarter of 2020, and the Facility was in a state of Significant Noncompliance (SNC) between the second quarter of 2020 through the end of 2021 (refer to Appendix B, Exhibit 4). Facility staff stated that they believed most exceedances were caused by elevated pollutant levels occurring in the source water. They believe Potomac River water coming into the plant's intake has elevated concentrations of iron and aluminum as well as increased total suspended solids and turbidity, particularly during high flow events in the river due to storms. As stated previously, the Facility has been under a Consent Decree with the Potomac Riverkeepers, Chesapeake Bay Foundation, and MDE since April 15, 2016, to minimize solids loading to the river and meet effluent limits. Facility representatives stated that the Facility completed a project about a year prior to the inspection to replace leaky effluent valves on the produced water reservoirs (refer to Appendix A. Photograph 3), which resulted in the elimination of about 20 MGD of leakage from being discharged through Outfall 001A. In addition, according to Facility representatives and the Facility's fourth quarter 2021 Consent Decree Status Report (refer to Appendix B, Exhibit 5), the Permittee had advertised bids for sedimentation process upgrades in December 2021 and gravity thickener expansion in January 2022. The report also indicates construction started on solids handling building upgrades in May 2021. A detailed timeline for all projects to be completed was not provided; however, the Consent Decree requires all long-term projects to be completed by January 1, 2026. Unique Project Identifier: 3E22WN031A Page 10 of 15 Inspection Date: February 16, 2022 Potomac River Water Filtration Plant (MD0051586) Compliance Evaluation Inspection Report In addition to the exceedances documented in the ICIS data, the EPA Inspection Team also observed numerous other daily maximum exceedances to be reported in the ICIS spreadsheet notes (refer to Appendix B, Exhibit 3). These were confirmed with values documented in the Permittee's MORs. Table 3 provides a summary of the 144 observed exceedances for January 1, 2021, through December 31, 2021. Although not reviewed, it is likely additional exceedances were also presented this way in 2020 and 2019. It is unclear if any of these additional exceedances had been factored into the calculations that support state and federal electronic reporting databases. Based on a review of the Permittee's Discharge Exceedance Reports, it appeared as though the Permittee had been providing MDE with written notice of these exceedances. Table 3. Additional Daily Maximum Exceedances at Outfall 001A Documented in ICIS Notes and MORs (January 1, 2021, through December 31, 2021) Permit # Monitoring Date Parameter Name DMR Value Permit Limit Units MD0051586 11/23/2021 Aluminum, total recoverable 8.1 8 mg/L MD0051586 11/3/2021 Turbidity 184 150 NTU MD0051586 11/2/2021 Turbidity 463 150 NTU MD0051586 10/25/2021 Aluminum, total recoverable 12.2 8 mg/L MD0051586 10/23/2021 Aluminum, total recoverable 16.9 8 mg/L MD0051586 10/22/2021 Aluminum, total recoverable 14.8 8 mg/L MD0051586 10/19/2021 Aluminum, total recoverable 15.0 8 mg/L MD0051586 10/13/2021 Aluminum, total recoverable 13.1 8 mg/L MD0051586 10/5/2021 Aluminum, total recoverable 10.5 8 mg/L MD0051586 10/4/2021 Aluminum, total recoverable 15.5 8 mg/L MD0051586 10/23/2021 Aluminum, total recoverable 857.9 574 lbs/day MD0051586 10/22/2021 Aluminum, total recoverable 826.3 574 lbs/day MD0051586 10/19/2021 Aluminum, total recoverable 771.0 574 lbs/day MD0051586 10/13/2021 Aluminum, total recoverable 715.0 574 lbs/day MD0051586 10/4/2021 Aluminum, total recoverable 861.8 574 lbs/day MD0051586 10/26/2021 Solids, total suspended 346 60 mg/L MD0051586 10/25/2021 Solids, total suspended 267 60 mg/L MD0051586 10/23/2021 Solids, total suspended 68 60 mg/L MD0051586 10/19/2021 Solids, total suspended 262 60 mg/L MD0051586 10/18/2021 Solids, total suspended 76 60 mg/L MD0051586 10/13/2021 Solids, total suspended 139 60 mg/L MD0051586 10/6/2021 Solids, total suspended 66 60 mg/L MD0051586 10/4/2021 Solids, total suspended 141 60 mg/L MD0051586 10/26/2021 Solids, total suspended 19296 4304 lbs/day MD0051586 10/25/2021 Solids, total suspended 15242 4304 lbs/day MD0051586 10/19/2021 Solids, total suspended 13467 4304 lbs/day MD0051586 10/18/2021 Solids, total suspended 4937 4304 lbs/day MD0051586 10/13/2021 Solids, total suspended 7586 4304 lbs/day MD0051586 10/4/2021 Solids, total suspended 7840 4304 lbs/day MD0051586 10/31/2021 Turbidity 813 150 NTU MD0051586 10/29/2021 Turbidity 215 150 NTU MD0051586 10/28/2021 Turbidity 273 150 NTU MD0051586 10/27/2021 Turbidity 317 150 NTU MD0051586 10/26/2021 Turbidity 270 150 NTU MD0051586 10/24/2021 Turbidity 862 150 NTU MD0051586 10/23/2021 Turbidity 202 150 NTU MD0051586 10/19/2021 Turbidity 269 150 NTU MD0051586 10/18/2021 Turbidity 874 150 NTU MD0051586 10/17/2021 Turbidity 908 150 NTU Unique Project Identifier: 3E22WN031A Page 11 of 15 Inspection Date: February 16, 2022 Potomac River Water Filtration Plant (MD0051586) Compliance Evaluation Inspection Report Permit # MD0051586 MD0051586 MD0051586 MD0051586 MD0051586 MD0051586 MD0051586 MD0051586 MD0051586 MD0051586 MD0051586 MD0051586 MD0051586 MD0051586 MD0051586 MD0051586 MD0051586 MD0051586 MD0051586 MD0051586 MD0051586 MD0051586 MD0051586 MD0051586 MD0051586 MD0051586 MD0051586 MD0051586 MD0051586 MD0051586 MD0051586 MD0051586 MD0051586 MD0051586 MD0051586 MD0051586 MD0051586 MD0051586 MD0051586 MD0051586 MD0051586 MD0051586 MD0051586 MD0051586 MD0051586 MD0051586 MD0051586 MD0051586 MD0051586 MD0051586 MD0051586 MD0051586 MD0051586 MD0051586 Monitoring Date 10/15/2021 10/12/2021 10/11/2021 10/8/2021 10/7/2021 10/6/2021 10/5/2021 10/4/2021 10/3/2021 9/27/2021 9/23/2021 9/22/2021 9/21/2021 9/23/2021 9/22/2021 9/22/2021 9/21/2021 9/27/2021 9/22/2021 9/28/2021 9/27/2021 9/26/2021 9/25/2021 9/24/2021 9/23/2021 9/21/2021 9/20/2021 9/4/2021 8/17/2021 8/14/2021 8/14/2021 8/13/2021 7/7/2021 7/7/2021 7/7/2021 7/1/2021 7/7/2021 7/1/2021 7/22/2021 7/9/2021 7/8/2021 7/7/2021 7/5/2021 6/29/2021 6/18/2021 6/29/2021 6/18/2021 6/26/2021 6/24/2021 6/18/2021 6/9/2021 6/8/2021 6/24/2021 6/18/2021 Parameter Name Turbidity Turbidity Turbidity Turbidity Turbidity Turbidity Turbidity Turbidity Turbidity Aluminum, total recoverable Aluminum, total recoverable Aluminum, total recoverable Aluminum, total recoverable Aluminum, total recoverable Aluminum, total recoverable Solids, total suspended Solids, total suspended Solids, total suspended Solids, total suspended Turbidity Turbidity Turbidity Turbidity Turbidity Turbidity Turbidity Turbidity Turbidity Aluminum, total recoverable Solids, total suspended Turbidity Turbidity Aluminum, total recoverable Aluminum, total recoverable Solids, total suspended Solids, total suspended Solids, total suspended Solids, total suspended Turbidity Turbidity Turbidity Turbidity Turbidity Aluminum, total recoverable Aluminum, total recoverable Aluminum, total recoverable Aluminum, total recoverable Solids, total suspended Solids, total suspended Solids, total suspended Solids, total suspended Solids, total suspended Solids, total suspended Solids, total suspended Unique Project Identifier: 3E22WN031A Page 12 of 15 DMR Value 161 727 820 167 339 199 194 852 850 2.6 10.8 10.9 8.82 697 649 276 70 1284 16449 242 257 447 987 181 333 394 361 397 9.07 72 258 601 8.43 756 74 75 6639 4718 346 628 214 549 542 17.5 13.6 964 846.4 64 120 180 77 258 6826 11202 Permit Limit 150 150 150 150 150 150 150 150 150 8 8 8 8 574 574 60 60 4304 4304 150 150 150 150 150 150 150 150 150 8 60 150 150 8 574 60 60 4304 4304 150 150 150 150 150 8 8 574 574 60 60 60 60 60 4304 4304 Units NTU NTU NTU NTU NTU NTU NTU NTU NTU mg/L mg/L mg/L mg/L lbs/day lbs/day mg/L mg/L lbs/day lbs/day NTU NTU NTU NTU NTU NTU NTU NTU NTU mg/L mg/L NTU NTU mg/L lbs/day mg/L mg/L lbs/day lbs/day NTU NTU NTU NTU NTU mg/L mg/L lbs/day lbs/day mg/L mg/L mg/L mg/L mg/L lbs/day lbs/day Inspection Date: February 16, 2022 Potomac River Water Filtration Plant (MD0051586) Compliance Evaluation Inspection Report Permit # MD0051586 MD0051586 MD0051586 MD0051586 MD0051586 MD0051586 MD0051586 MD0051586 MD0051586 MD0051586 MD0051586 MD0051586 MD0051586 MD0051586 MD0051586 MD0051586 MD0051586 MD0051586 MD0051586 MD0051586 MD0051586 MD0051586 MD0051586 MD0051586 MD0051586 MD0051586 MD0051586 MD0051586 MD0051586 MD0051586 MD0051586 MD0051586 MD0051586 MD0051586 MD0051586 MD0051586 MD0051586 MD0051586 MD0051586 MD0051586 MD0051586 MD0051586 MD0051586 MD0051586 MD0051586 MD0051586 MD0051586 MD0051586 MD0051586 MD0051586 MD0051586 Monitoring Date 6/9/2021 6/8/2021 6/30/2021 6/28/2021 6/27/2021 6/23/2021 6/22/2021 6/18/2021 6/17/2021 6/16/2021 6/7/2021 4/7/2021 3/24/2021 3/23/2021 3/17/2021 3/16/2021 3/6/2021 3/5/2021 3/3/2021 3/24/2021 3/23/2021 3/17/2021 3/16/2021 3/6/2021 3/5/2021 3/3/2021 3/24/2021 3/23/2021 3/17/2021 3/15/2021 3/6/2021 3/3/2021 3/24/2021 3/23/2021 3/17/2021 3/15/2021 3/6/2021 3/3/2021 3/23/2021 3/22/2021 3/16/2021 3/15/2021 3/14/2021 3/6/2021 3/5/2021 3/4/2021 3/2/2021 1/28/2021 1/27/2021 1/15/2021 1/16/2021 Parameter Name Solids, total suspended Solids, total suspended Turbidity Turbidity Turbidity Turbidity Turbidity Turbidity Turbidity Turbidity Turbidity Turbidity Aluminum, total recoverable Aluminum, total recoverable Aluminum, total recoverable Aluminum, total recoverable Aluminum, total recoverable Aluminum, total recoverable Aluminum, total recoverable Aluminum, total recoverable Aluminum, total recoverable Aluminum, total recoverable Aluminum, total recoverable Aluminum, total recoverable Aluminum, total recoverable Aluminum, total recoverable Solids, total suspended Solids, total suspended Solids, total suspended Solids, total suspended Solids, total suspended Solids, total suspended Solids, total suspended Solids, total suspended Solids, total suspended Solids, total suspended Solids, total suspended Solids, total suspended Turbidity Turbidity Turbidity Turbidity Turbidity Turbidity Turbidity Turbidity Turbidity Aluminum, total recoverable Aluminum, total recoverable Aluminum, total recoverable Aluminum, total recoverable DMR Value 5794 13564 333 703 170 870 813 398 810 907 836 330 25.5 28.1 10.5 11.2 28.9 14.5 21.4 1472.3 1698.4 654.7 640.6 1523.3 1102.3 1428 322 120 155 69 474 361 18592 7253 9664 4555 24984 24089 1000 1000 693 986 578 189 1000 1000 279 8.14 9.72 9.28 9.73 Permit Limit 4304 4304 150 150 150 150 150 150 150 150 150 150 8 8 8 8 8 8 8 574 574 574 574 574 574 574 60 60 60 60 60 60 4304 4304 4304 4304 4304 4304 150 150 150 150 150 150 150 150 150 8 8 8 8 Units lbs/day lbs/day NTU NTU NTU NTU NTU NTU NTU NTU NTU NTU mg/L mg/L mg/L mg/L mg/L mg/L mg/L lbs/day lbs/day lbs/day lbs/day lbs/day lbs/day lbs/day mg/L mg/L mg/L mg/L mg/L mg/L lbs/day lbs/day lbs/day lbs/day lbs/day lbs/day NTU NTU NTU NTU NTU NTU NTU NTU NTU mg/L mg/L mg/L mg/L Unique Project Identifier: 3E22WN031A Page 13 of 15 Inspection Date: February 16, 2022 Potomac River Water Filtration Plant (MD0051586) Compliance Evaluation Inspection Report Special Plan and Report Submittals Section II.B(2) of the Permit states, "No later than three months from MDE's publication of a tentative determination of a proposed permit (02-DP-1055), the permittee shall submit the Study Plans for effluent biomonitoring as well as toxic chemical testing and obtain approval from the Department. For further details, refer to Special Condition II.D.1 for Effluent Biomonitoring Study Plan and Special Condition II.F.1 for Effluent Toxic Chemical Testing Study Plan." Additionally, the Section II.B(2) of the Permit states, "After MDE's approval of the Effluent Biomonitoring Study Plan, the permittee shall perform the effluent biomonitoring study and submit the results in a comprehensive report to the Department as per requirements of the Special Condition II.D, and "After MDE's approval of the Effluent Toxic Chemical Testing Plan, the permittee shall perform the effluent toxic chemical testing and submit the results in a comprehensive report to the Department as per requirements of the Special Condition II.F." The EPA Inspection Team requested the Effluent Biomonitoring Study Plan, Effluent Toxic Chemical Testing Plan, and associated reports verbally at the time of the inspection and in writing following the inspection; however, these documents had not been provided at the time this report was completed. Facility representatives explained they believed the plans had been completed, and that the plans and all associated documentation were held in WSSC's offsite lab facility. Monitoring and Reporting Section III.A.3 of the Permit states, "Analytical and sampling methods shall conform to test procedures for the analysis of pollutants as identified in 40 CFR Part 136 - "Guidelines Establishing Test Procedures for the Analysis of Pollutants." The EPA Inspection Team observed multiple instances on the Facility's Weekly Discharge Sampling sheets where the 15-minute hold time for pH analysis was exceeded. These dates include August 1, 2021, September 5, 2021, and October 23, 2021 (refer to Appendix A, Photographs 18 through 20). Section III.A.5.a. of the Permit states, "The permittee shall calibrate and maintain all monitoring and analytical instrumentation to ensure accuracy of measurements." The EPA Inspection Team observed the thermometers used to monitor ambient conditions in the raw water and Outfall 001A effluent composite samplers were not kept in solution. The thermometers were observed laying on their sides inside the sampler within direct contact to the metal holding bracket (refer to Appendix A, Photographs 3 and 16). Section III.A.6 of the Permit states, "For each measurement or sample taken pursuant to the requirements of the permit, the permittee shall record the following information: a. the date, exact place and time of sampling or measurement; b. the person(s) who performed the sampling or measurement; c. the dates analyses were performed; d. the person(s) who performed each analysis; e. the analytical techniques or methods used; and f. the results of such analyses." The EPA Inspection Team observed whiteout had been applied to multiple areas for corrections in the Facility's Weekly Discharge Sampling sheets (refer to Appendix A, Photographs 21 and 22 for examples). Proper Operation and Maintenance Title 40 of the Code of Federal Regulation (CFR), Chapter 122.41 applies to all NPDES permits and 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 Unique Project Identifier: 3E22WN031A Page 14 of 15 Inspection Date: February 16, 2022 Potomac River Water Filtration Plant (MD0051586) Compliance Evaluation Inspection Report the terms and conditions of this permit. Proper operation and maintenance include, 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." Section III.B.3.a of the Permit states, all waste collection, control, treatment and disposal facilities shall be "operated efficiently to minimize upsets and discharges of excessive pollutants." Section III.B.3.c of the Permit states, "Facility maintenance work, which adversely affects or may adversely affect the discharge quality shall be scheduled during non-critical water quality periods." The EPA Inspection Team observed that the launders separating treatment components in Sedimentation Basin 3A and 3B had significant corrosion with paint peeling, rust, and flakes of material observed floating on the surface of the basins (refer to Appendix A, Photograph 11). At the time of the inspection, Facility representatives were unsure of the total severity of the corrosion of the launders but stated that a replacement project for the launders with a non-corrodible material had been planned. Operator Certification Section III.B.3.b of the Permit states, "The permittee shall provide an adequate operating staff qualified to carry out the operation, maintenance, and testing functions required to ensure compliance with this permit. Superintendents and operators must be certified by the Board of Waterworks and Waste Systems Operators located at Montgomery Park Business Center, 1800 Washington Boulevard, STE- 410, Baltimore, Maryland 21230 in accordance with Title 12 of Environmental Article, Annotated Code of Maryland." The EPA Inspection Team observed at least two of the displayed operator certifications had expired. Facility representatives explained that one of the operators (Jacob Burdette) had completed his exam and was waiting on a new certificate to arrive and the other (Hector Rojas) had yet to take the exam (refer to Appendix A, Photographs 23 and 24). Closing Conference After the Facility site walk, the EPA Inspection Team met with the WSSC Section Managers for a closing conference and shared preliminary observations. The EPA Inspection Team reiterated that all preliminary observations discussed were not compliance determinations. Any and all preliminary observations shared were subject to further investigation by the EPA Inspection Team 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 the additional review of materials following the inspection. The inspection concluded at approximately 3:20 PM (EST). Unique Project Identifier: 3E22WN031A Page 15 of 15 Inspection Date: February 16, 2022