Document 4armVbQO1BeVeOwDZ5xXE45Zp
U.S. ENVIRONMENTAL PROTECTION AGENCY REGION III WATER BRANCH, ENFORCEMENT
AND COMPLIANCE ASSURANCE DIVISION CLEAN WATER ACT
COMPLIANCE INSPECTION REPORT
for
Name of Facility: H.P.S.D., LLC Sewage Plant Facility Address: 602 4-H Camp Road, Morgantown, WV 26508 Mailing Address: 466 Christy Street, Suite 2, Morgantown, WV 26505
Report Prepared on:
10/12/2023 Date
Jacob
Digitally signed by Jacob Albright
By: Albright
Date: 2023.10.12
13:15:08 -04'00'
,
Environmental Scientist (PG Environmental)
Signature
Report Final as of:
10/16/23
Date
JESSICA
Digitally signed by JESSICA DUFFY
By: DUFFY
Date: 2023.10.16 08:42:32 -04'00'
Signature
, EPA
General Information
Type of Inspection: Owner: Operator: Permittee: NPDES Permit No: NPDES Permit Effective Date: NPDES Permit Expiration Date: Receiving Water and/or MS4: Latitude and Longitude:
Wastewater Treatment Facility CEI H.P.S.D., LLC P&B Services, LLC H.P.S.D., LLC WV0105970 November 1, 2018 September 18, 2023 Booths Creek to the Monongahela River 39.57148, -79.974893
On-Site Facility Inspection Overview
On August 10, 2023, U.S. Environmental Protection Agency (EPA) Region III's contract inspector from PG Environmental, (hereinafter referred to as Inspector) inspected the H.P.S.D., LLC Sewage Plant (hereinafter, Facility or Plant) in Morgantown, West Virginia. H.P.S.D., LLC is identified as the Permittee and owns the Plant. P&B Services, LLC is the contracted company that operates the Plant. The Inspector was accompanied on the inspection by the Plant's Lead Operator and a state representative from the West Virginia Department of Environmental Protection (WVDEP).
Approximate Entry Time: 8:30 AM (EDT) Approximate Exit Time: 11:30 AM (EDT)
Unique Project Identifier (UPI): 3E23WN116A
Unique Project Identifier: 3E23WN116A
Page 1 of 10
Inspection Date: August 10, 2023
H.P.S.D., LLC Sewage Plant (WV0105970) 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 Permit Status and Effluent Exceedances.............................................................................5 Records Retention ............................................................................................................... 9 Proper Operation and Maintenance (O&M)........................................................................9 Closing Conference ........................................................................................................................10
Appendix A: Photograph Log
Appendix B: Exhibit Log o Exhibit 1 - EPA ECHO Exceedance Data (August 2018 through July 2023)
o Exhibit 2 - EPA ECHO Detailed Facility Report
Appendix C: NPDES Permit No. WV0105970
Unique Project Identifier: 3E23WN116A
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Inspection Date: August 10, 2023
H.P.S.D., LLC Sewage Plant (WV0105970) Compliance Evaluation Inspection Report
I.
INTRODUCTION
On August 10, 2023, U.S. Environmental Protection Agency (EPA) Region III's contract inspector from PG Environmental, (hereinafter referred to as Inspector) inspected the H.P.S.D., LLC Sewage Plant (hereinafter, Facility or Plant) in Morgantown, West Virginia. H.P.S.D., LLC is identified as the Permittee and owns the Plant. P&B Services, LLC is the contracted company that operates the Plant. The Inspector was accompanied on the inspection by the Plant's Lead Operator and a state representative from the West Virginia Department of Environmental Protection (WVDEP). The Permittee's activities are regulated under National Pollutant Discharge Elimination System (NPDES) Permit No. WV0105970 (hereinafter, Permit), which became effective on November 1, 2018 (refer to Appendix C). The Permit was originally set to expire on September 18, 2023; however, a new permit was issued on July 11, 2023, with a new effective date of September 1, 2023 (i.e., after the inspection). The inspection occurring on August 10, 2023, evaluated compliance with the requirements of the 2018 Permit.
The primary purpose of the inspection was to review the onsite Plant operations, the accuracy and reliability of the Permittee's self-monitoring and reporting program, and to obtain information that will assist EPA in assessing the Permittee's compliance with the requirements of the Permit. Periods of moderate to heavy precipitation were experienced during the inspection.
The Plant has two sequence batch reactors (SBRs), which handle the bulk of flows to the Plant. According to the Lead Operator, the Plant typically receives approximately 40,000 to 45,000 gallons per day (GPD) of flow, and the SBRs combined can handle about 50,000 GPD. The Plant is designed for 100,000 GPD. High influent volumes that are not able to be treated by the SBRs are directed to the Plant's Biologically Engineered Single Sludge Treatment (BESST TM) system, which provides extended aeration and clarification. The Lead Operator stated that the BESST TM system is utilized routinely under daily peak flow conditions.
A contract operator is onsite at the Facility for a few hours four to five days a week. The Facility has access to portable generators in case of a power failure.
II. INSPECTION PROCESS
Inspection Opening Conference
The Inspector arrived at the Plant at 8:30 AM (EDT) for the inspection. Jake Albright of PG Environmental presented his Clean Water Act inspector credential to the Lead Operator at the outset of the inspection and explained the purpose of the inspection was to observe compliance with the Permit. A copy of the Permit is provided in Appendix C. Table 1 describes the individuals that participated in the inspection.
Name Jake Albright, Inspector Allen Carpenter, Environmental Inspector
Patrick Lesmann, Lead Operator
Table 1: Inspection Attendee List
Affiliation
Telephone
EPA Region III Contract Inspector
PG Environmental
(703) 956-1957
State Representative
West Virginia Department
of Environmental
(304) 368-3960
Protection
Site/Facility Representative
P & B Services, LLC
(304) 641-0002
Email jake.albright@pgenv.com allen.l.carpenter@wv.gov pandbservicellc@gmail.com
Unique Project Identifier: 3E23WN116A
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Inspection Date: August 10, 2023
H.P.S.D., LLC Sewage Plant (WV0105970) Compliance Evaluation Inspection Report
Facility Site Walk
As part of the inspection process, the Inspector visually observed the treatment train and site conditions in the presence of the Lead Operator (refer to Appendix A, Photographs 1 through 14). The Inspector also visually inspected the outfall, located outside the Facility's northern fence line, as well as the receiving stream (Booths Creek). The wastewater treatment train consists of:
Influent flow box with manual bar screen Influent Equalization Basin Two SBRs (operated in parallel) Dual-train BESST TM system (extended aeration and clarification) Effluent Equalization Basin Ultraviolet (UV) light disinfection Backup tablet system for chlorine disinfection and dechlorination
Anaerobic Digester/Sludge Holding Tank
The Plant serves roughly 320 homes with approximately 1,000 residents in a subdivision outside of downtown Morgantown, WV. There are two lift stations in the subdivision's collection system that elevate the wastewater, which is then gravity-fed to the Plant.
Wastewater enters the influent flow box at the headworks, which is equipped with a manually raked screen box. The Facility is equipped with two screen boxes so one can be removed and cleaned while the other is in service (refer to Appendix A, Photographs 1 and 2). After screening, the flow enters the Influent Equalization Basin before being pumped to the SBRs (refer to Appendix A, Photograph 3). The Influent Equalization Basin has a pump float that is set to pump higher volumes of influent to the BESST TM system, as the Influent Equalization Basin fills.
The SBRs go through a 4.5-hour cycle consisting of fill, fill/react, react, settle, and decant/waste (refer to Appendix A, Photographs 4 and 5). Additionally, the waste activated sludge pumps send solids to the digester for 1 minute at the end of every cycle.
The BESST TM system has two parallel trains consisting of aeration, clarification, and an anoxic zone (refer to Appendix A, Photographs 6 and 7). The Lead Operator stated that solids are pumped from the BESST TM system to the digester for 2 to 5 minutes, once or twice per week.
Flows leaving both the SBRs and the BESST TM system are directed to the Effluent Equalization Basin and then to a single-bank UV system for disinfection (in operation at the time of the inspection; refer to Appendix A, Photograph 8). Effluent flow is measured following UV disinfection, via ultrasonic transducer (refer to Appendix A, Photograph 9). The Facility also frequently utilizes tablets for chlorine disinfection and dechlorination, in addition to and downstream of the UV system (in operation at the time of the inspection; refer to Appendix A, Photograph 10). Following disinfection, effluent flows via gravity to Outlet No. 001 and is discharged to Booths Creek (refer to Appendix A, Photographs 11 and 12).
As stated previously, solids from the SBRs and BESST TM system are wasted to the anaerobic digester (refer to Appendix A, Photograph 13). Digested solids are pumped out periodically and sent to the Morgantown Utility Board wastewater treatment plant for further processing.
A Plant flow diagram is included in Appendix A, Photograph 14.
Unique Project Identifier: 3E23WN116A
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Inspection Date: August 10, 2023
H.P.S.D., LLC Sewage Plant (WV0105970) Compliance Evaluation Inspection Report
Records Review
The Inspector conducted a records review to evaluate the Permittee's compliance with the Permit. Not all of the records and reports required by the Permit were available for review onsite (see Observation 2 in the Summary of Observations below). Plant equipment operation and maintenance (O&M) manuals were available and reviewed onsite. The following were reviewed:
Electronic Discharge Monitoring Report (eDMR) data during the period from August 1, 2018 through July 31, 2023
Contract laboratory chain of custodies and analytical reports (May through July 2023) Daily handwritten operational datasheets (February 2023 through date of inspection) Operations logbook (June 2023 through date of inspection)
SBR and BESST TM equipment O&M manuals
Summary of Observations
The following section summarizes the Inspector's observations relative to the Permit requirements, including the status of certain treatment units, O&M practices, the Permittee's monitoring and reporting documentation, and the Permittee's compliance with enforcement actions.
Permit Status and Effluent Exceedances
Section A.001 of the Permit defines effluent limitations and monitoring requirements for Outlet No. 001 discharges.
As part of the data review, the Inspector reviewed the Effluent Exceedances Report in EPA's Enforcement and Compliance History Online (ECHO) Database to compare reported values against effluent limitations defined in the Permit (refer to Appendix B, Exhibit 1).
According to EPA's ECHO database, the Plant experienced 109 effluent limit exceedances from Outlet No. 001 between August 1, 2018 and July 31, 2023 (refer to Appendix B, Exhibit 1 and Table 2 below). The highest number of exceedances occurred for ammonia nitrogen (77 exceedances).
EPA's ECHO database indicates the Plant was in a state of significant noncompliance (SNC) from Apil 1, 2020 through June 30, 2022 (refer to Appendix B, Exhibit 2).
Table 2. Outlet No. 001 Final Effluent Exceedances (August 1, 2018 through July 31, 2023)
Permit #
WV0105970
Monitoring Period End
Date 10/31/2018
Parameter Name Zinc, total recoverable
DMR Value
0.0772
Permit Limit
0.064
Units mg/L
Limit Type MO AVG
WV0105970 12/31/2018 Solids, total suspended
888.1
25
lbs/d
MO AVG
WV0105970 2/28/2019 Nitrogen, ammonia total (as N) 15.5 4
mg/L
MO AVG
WV0105970 2/28/2019 Nitrogen, ammonia total (as N) 15.5 8
mg/L
DAILY MX
WV0105970 2/28/2019 Nitrogen, ammonia total (as N) 13.0 6.7 lbs/d DAILY MX
WV0105970 2/28/2019 Nitrogen, ammonia total (as N) 13.0 3.3 lbs/d
MO AVG
WV0105970 10/31/2019 Solids, suspended percent removal 82 85 % MO AV MN
Unique Project Identifier: 3E23WN116A
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Inspection Date: August 10, 2023
H.P.S.D., LLC Sewage Plant (WV0105970) Compliance Evaluation Inspection Report
Permit #
WV0105970
WV0105970
WV0105970
WV0105970
WV0105970 WV0105970 WV0105970 WV0105970 WV0105970 WV0105970 WV0105970
WV0105970
WV0105970 WV0105970 WV0105970
WV0105970 WV0105970 WV0105970
WV0105970
WV0105970
WV0105970
WV0105970
WV0105970
WV0105970
WV0105970 WV0105970 WV0105970 WV0105970 WV0105970 WV0105970 WV0105970 WV0105970 WV0105970
WV0105970
Monitoring Period End
Date 11/30/2019
11/30/2019
2/29/2020
2/29/2020
2/29/2020 3/31/2020 4/30/2020 4/30/2020 4/30/2020 4/30/2020 4/30/2020
4/30/2020
4/30/2020 4/30/2020 4/30/2020
4/30/2020 5/31/2020 5/31/2020
5/31/2020
5/31/2020
5/31/2020
6/30/2020
6/30/2020
7/31/2020
7/31/2020 8/31/2020 8/31/2020 8/31/2020 8/31/2020 8/31/2020 8/31/2020 8/31/2020 9/30/2020
9/30/2020
Parameter Name
Flow, in conduit or thru treatment plant
Solids, suspended percent removal
Nitrogen, ammonia total (as N)
Nitrogen, ammonia total (as N)
Nitrogen, ammonia total (as N)
BOD, 5-day, 20 deg. C BOD, 5-day, 20 deg. C BOD, 5-day, 20 deg. C BOD, 5-day, 20 deg. C Solids, total suspended Nitrogen, ammonia total (as
N) Nitrogen, ammonia total (as
N) Nitrogen, ammonia total (as
N) Coliform, fecal general BOD, 5-day, percent
removal Solids, suspended percent
removal BOD, 5-day, 20 deg. C Nitrogen, ammonia total (as
N) Nitrogen, ammonia total (as
N) Nitrogen, ammonia total (as
N) Nitrogen, ammonia total (as
N) Nitrogen, ammonia total (as
N) Nitrogen, ammonia total (as
N) Nitrogen, ammonia total (as
N) Nitrogen, ammonia total (as
N) Oxygen, dissolved (DO) BOD, 5-day, 20 deg. C BOD, 5-day, 20 deg. C Solids, total suspended Solids, total suspended Coliform, fecal general Coliform, fecal general Nitrogen, ammonia total (as
N) Nitrogen, ammonia total (as
N)
DMR Value
43566*
81
3.8
10.7
10.7 32 71.2 26.7 71.2 39 12.2
4.6
12.2 1274 79
80 15.3 9.4
16.5
16.5
5.4
6
6
4.9
4.9 5.64 13.6 13.8 36.1 35.5 3448 3448 10.4
9.1
Unique Project Identifier: 3E23WN116A
Page 6 of 10
Permit Limit
Units
Limit Type
0.1
MGD
DAILY MX
85
%
MO AV MN
3.3
lbs/d
MO AVG
4
mg/L
MO AVG
8
mg/L
20
mg/L
40
mg/L
16.7
lbs/d
20
mg/L
30
mg/L
4
mg/L
DAILY MX
MO AVG DAILY MX MO AVG MO AVG MO AVG
MO AVG
3.3
lbs/d
MO AVG
8
mg/L
DAILY MX
400
#/100mL
DAILY MX
85
%
MO AV MN
85
%
MO AV MN
10
mg/L
MO AVG
3.3
lbs/d
DAILY MX
4
mg/L
DAILY MX
2
mg/L
MO AVG
1.7
lbs/d
MO AVG
2
mg/L
MO AVG
4
mg/L
DAILY MX
4
mg/L
DAILY MX
2
mg/L
MO AVG
6
mg/L
INST MIN
10
mg/L
MO AVG
8.3
lbs/d
MO AVG
25
lbs/d
MO AVG
30
mg/L
MO AVG
200
#/100mL
MO GEOMN
400
#/100mL
DAILY MX
3.3
lbs/d
DAILY MX
1.7
lbs/d
MO AVG
Inspection Date: August 10, 2023
H.P.S.D., LLC Sewage Plant (WV0105970) Compliance Evaluation Inspection Report
Permit #
WV0105970 WV0105970 WV0105970 WV0105970 WV0105970 WV0105970 WV0105970 WV0105970 WV0105970 WV0105970 WV0105970 WV0105970 WV0105970 WV0105970 WV0105970 WV0105970 WV0105970 WV0105970 WV0105970 WV0105970 WV0105970 WV0105970 WV0105970 WV0105970 WV0105970 WV0105970 WV0105970 WV0105970
Monitoring Period End
Date 9/30/2020 9/30/2020 10/31/2020 10/31/2020 10/31/2020 10/31/2020 11/30/2020 12/31/2020 12/31/2020 12/31/2020 12/31/2020 1/31/2021 1/31/2021 1/31/2021 1/31/2021 2/28/2021 2/28/2021 2/28/2021 2/28/2021 3/31/2021 3/31/2021 3/31/2021 3/31/2021 4/30/2021 4/30/2021 4/30/2021 4/30/2021 5/31/2021
Parameter Name
Nitrogen, ammonia total (as N)
Nitrogen, ammonia total (as N)
BOD, 5-day, 20 deg. C Nitrogen, ammonia total (as
N) Nitrogen, ammonia total (as
N) Nitrogen, ammonia total (as
N) Nitrogen, ammonia total (as
N) Nitrogen, ammonia total (as
N) Nitrogen, ammonia total (as
N) Nitrogen, ammonia total (as
N) Nitrogen, ammonia total (as
N) Nitrogen, ammonia total (as
N) Nitrogen, ammonia total (as
N) Nitrogen, ammonia total (as
N) Nitrogen, ammonia total (as
N) Nitrogen, ammonia total (as
N) Nitrogen, ammonia total (as
N) Nitrogen, ammonia total (as
N) Nitrogen, ammonia total (as
N) Nitrogen, ammonia total (as
N) Nitrogen, ammonia total (as
N) Nitrogen, ammonia total (as
N) Nitrogen, ammonia total (as
N) Nitrogen, ammonia total (as
N) Nitrogen, ammonia total (as
N) Nitrogen, ammonia total (as
N) Nitrogen, ammonia total (as
N) BOD, 5-day, 20 deg. C
DMR Value 34.1 34.1 11.8
6.3 2.3 6.3 6.3 10.7 10.7 27.5 27.5 12.5 25.1 25.1 8.1 15.9 12.1 31.9 31.9 39.2 13.2 24.0 39.2 32.4 13.8 13.8 32.4 11.3
Unique Project Identifier: 3E23WN116A
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Permit Limit
Units
Limit Type
4
mg/L
DAILY MX
2
mg/L
10
mg/L
2
mg/L
MO AVG MO AVG MO AVG
1.7
lbs/d
MO AVG
4
mg/L
DAILY MX
4
mg/L
MO AVG
3.3
lbs/d
MO AVG
6.7
lbs/d
DAILY MX
4
mg/L
MO AVG
8
mg/L
DAILY MX
6.7
lbs/d
DAILY MX
4
mg/L
MO AVG
8
mg/L
DAILY MX
3.3
lbs/d
MO AVG
6.7
lbs/d
DAILY MX
3.3
lbs/d
MO AVG
4
mg/L
MO AVG
8
mg/L
DAILY MX
4
mg/L
MO AVG
3.3
lbs/d
MO AVG
6.7
lbs/d
DAILY MX
8
mg/L
DAILY MX
8
mg/L
DAILY MX
3.3
lbs/d
MO AVG
6.7
lbs/d
DAILY MX
4
mg/L
10
mg/L
MO AVG MO AVG
Inspection Date: August 10, 2023
H.P.S.D., LLC Sewage Plant (WV0105970) Compliance Evaluation Inspection Report
Permit #
WV0105970 WV0105970 WV0105970 WV0105970 WV0105970 WV0105970 WV0105970 WV0105970 WV0105970 WV0105970 WV0105970 WV0105970 WV0105970 WV0105970 WV0105970 WV0105970 WV0105970 WV0105970 WV0105970 WV0105970 WV0105970 WV0105970 WV0105970 WV0105970 WV0105970 WV0105970 WV0105970 WV0105970
Monitoring Period End
Date 5/31/2021 5/31/2021 5/31/2021 5/31/2021 6/30/2021 6/30/2021 6/30/2021 6/30/2021 7/31/2021 7/31/2021 7/31/2021 7/31/2021 8/31/2021 8/31/2021 8/31/2021 8/31/2021 9/30/2021 9/30/2021 10/31/2021 10/31/2021 10/31/2021 10/31/2021 11/30/2021 11/30/2021 1/31/2022 1/31/2022 1/31/2022 1/31/2022
Parameter Name
Nitrogen, ammonia total (as N)
Nitrogen, ammonia total (as N)
Nitrogen, ammonia total (as N)
Nitrogen, ammonia total (as N)
Nitrogen, ammonia total (as N)
Nitrogen, ammonia total (as N)
Nitrogen, ammonia total (as N)
Nitrogen, ammonia total (as N)
Nitrogen, ammonia total (as N)
Nitrogen, ammonia total (as N)
Nitrogen, ammonia total (as N)
Nitrogen, ammonia total (as N)
BOD, 5-day, 20 deg. C Nitrogen, ammonia total (as
N) Nitrogen, ammonia total (as
N) Nitrogen, ammonia total (as
N) Nitrogen, ammonia total (as
N) Nitrogen, ammonia total (as
N) BOD, 5-day, 20 deg. C Nitrogen, ammonia total (as
N) Nitrogen, ammonia total (as
N) Nitrogen, ammonia total (as
N) Nitrogen, ammonia total (as
N) Nitrogen, ammonia total (as
N) Nitrogen, ammonia total (as
N) Nitrogen, ammonia total (as
N) Nitrogen, ammonia total (as
N) Nitrogen, ammonia total (as
N)
DMR Value 24.5
9.9 24.5 9.9 23.8 23.8 6.8 6.8 12.6 48.6 48.6 12.6 9.6 3.9 8.5 8.5 7.3 7.3 17.4 15.1 15.1 2.7 19.0 19.0 53.6 53.6 16.9 16.9
Unique Project Identifier: 3E23WN116A
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Permit Limit
4 1.7 2 3.3 2 4 1.7 3.3 1.7 2 4 3.3 8.3 2 3.3 1.7 2 4 10 1.7 3.3 2 3.3 6.7 4 8 3.3 6.7
Units
mg/L lbs/d mg/L lbs/d mg/L mg/L lbs/d lbs/d lbs/d mg/L mg/L lbs/d lbs/d mg/L lbs/d lbs/d mg/L mg/L mg/L lbs/d lbs/d mg/L lbs/d lbs/d mg/L mg/L lbs/d lbs/d
Limit Type
DAILY MX MO AVG MO AVG DAILY MX MO AVG DAILY MX MO AVG DAILY MX MO AVG MO AVG DAILY MX DAILY MX MO AVG MO AVG DAILY MX MO AVG MO AVG DAILY MX MO AVG MO AVG DAILY MX MO AVG MO AVG DAILY MX MO AVG DAILY MX MO AVG DAILY MX
Inspection Date: August 10, 2023
H.P.S.D., LLC Sewage Plant (WV0105970) Compliance Evaluation Inspection Report
Monitoring
Permit # Period End
Parameter Name
Date
WV0105970
2/28/2022
Nitrogen, ammonia total (as N)
WV0105970
3/31/2022
Nitrogen, ammonia total (as N)
WV0105970
4/30/2022
Nitrogen, ammonia total (as N)
WV0105970
6/30/2022
Nitrogen, ammonia total (as N)
WV0105970
7/31/2022
Nitrogen, ammonia total (as N)
WV0105970 9/30/2022 Oxygen, dissolved (DO)
WV0105970 10/31/2022 BOD, 5-day, 20 deg. C
WV0105970 11/30/2022 BOD, 5-day, 20 deg. C
WV0105970 11/30/2022
BOD, 5-day, percent removal
WV0105970 2/28/2023
Solids, total suspended
WV0105970 2/28/2023
Solids, suspended percent removal
WV0105970 3/31/2023
Solids, suspended percent removal
*This appears to be a data entry error, as the reported
The actual value is unclear.
DMR Value
Permit Limit
4.2
4
7.8
4
4.8
4
3
2
2.1
2
5.7
6
11.2
10
25.3
20
84.29
85
39
30
83.33
85
78.45
85
value equates to more
Units
mg/L
mg/L
mg/L
mg/L
mg/L mg/L mg/L mg/L
% mg/L
%
% than 43 billion
Limit Type
MO AVG
MO AVG
MO AVG
MO AVG
MO AVG INST MIN MO AVG MO AVG MO AV MN MO AVG MO AV MN
MO AV MN gallons of flow.
Records Retention
Section D.7 of the Permit states, "The permittee shall maintain all records and reports of all monitoring required by Section D of this permit for five (5) years after the date of monitoring or reporting. Records should include copies of all required reports; and records of all data used to complete these reports."
Compliance monitoring data, contract laboratory chains of custody, and contract laboratory reports covering the period of time prior to P&B Services taking over as contract operator (i.e., prior to February 2023) were not available. At the time of the inspection, the Lead Operator explained that the majority of this information was likely retained by the Facility's contract laboratory (Pace). Following the inspection, on August 24, 2023, the Lead Operator sent an email stating that he had been added to the Pace system for accessing historical records. No additional records were requested or provided after the inspection.
Proper Operation and Maintenance (O&M)
Part II of Appendix A 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 also includes adequate laboratory controls, and appropriate quality assurance procedures. Unless otherwise required by Federal or State law, this provision requires the operation of back-up auxiliary facilities or similar systems which are installed by the permittee only when the operation is necessary to achieve compliance with the conditions of the permit."
The Lead Operator stated that prior to P&B Services being hired, some of the treatment components in the Plant were not being operated properly, leading to many of the recurring exceedances shown in Table 2. Specifically, he stated that many of the dynamic operational set points within the Plant were likely left static for long periods of
Unique Project Identifier: 3E23WN116A
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Inspection Date: August 10, 2023
H.P.S.D., LLC Sewage Plant (WV0105970) Compliance Evaluation Inspection Report
time under the previous operator. This included processes related to air distribution and solids management.
The Lead Operator stated that since P&B took over in February/March 2023, they have performed regular O&M activities such as draining and cleaning tanks and taking a more active approach to managing air delivery in the Plant.
Plant operators were not documenting pH meter calibration. The Lead Operator stated that operators perform a three-point calibration prior to conducting compliance analyses for pH; however, calibration time and results were not recorded.
Part III.3 of Appendix A of the Permit states, "Samples shall be taken, preserved and analyzed in accordance with the latest edition of 40 CFR Part 136, unless other test procedures have been specified elsewhere in this permit."
Plant operators were not documenting sample and analysis times for pH, dissolved oxygen, and chlorine analyses to show that they were conducted within a 15-minute holding time.
Closing Conference
After the Plant site walk, the Inspector met with the Lead Operator for a closing conference and shared preliminary observations. The Inspector reiterated to the Lead Operator that all preliminary observations discussed were not compliance determinations. Any and all preliminary observations shared were subject to further investigation by the Inspector and 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 the additional review of materials following the inspection.
The inspection concluded at approximately 11:30 AM (EDT).
Unique Project Identifier: 3E23WN116A
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Inspection Date: August 10, 2023