Document 858rOrn550vpK83LrrJz5K0EZ

Participating Personnel: Report Submitted By: Approved By: NPDES Compliance Sampling Inspection Report Vessup POTW Nazareth Estate 10 Red Hook Qtr. Saint Thomas, USVI 00802 Permit Number: VI0020133 Inspection date: 12 NOV 2021 US Environmental Protection Agency Neal R. Johansen, Physical Scientist Kathleen M. Foley, Physical Scientist Vessup POTW DeShaun Estrill, Operations Supervisor Digitally signed by Johansen, Johansen, Neal Neal Date: 2021.12.15 11:09:27 _______________-_05_'00_' ___________ Neal R. Johansen, Physical Scientist PHILIP Digitally signed by PHILIP COCUZZA _C_O_C__U_Z_Z_A_______D-0_a5t'_e0:0_2' 0_21_.1_2.1_5_10_:3_6:0_1___ Phil Cocuzza, Chief Monitoring Operations Section Vessup Public Owned Treatment Works VI0020133 Saint Thomas, USVI November 12, 2021 1.0 OBJECTIVE On November 12, 2021, at the request of the United States Environmental Protection Agency (US EPA), a National Pollution Discharge Elimination System (NPDES) Compliance Sampling Inspection (CSI) was conducted at the Vessup Public Owned Treatment Works (POTW) in Saint Thomas, US Virgin Islands. The objective of the CSI was to determine the facility's compliance with the requirements and limitations of TPDES permit number VI0020133. 2.0 KEY PARTICIPANTS Listed below are key inspection participants and contact information, grouped by organization. U.S. Environmental Protection Agency Neal R. Johansen, Physical Scientist (732) 321-6691 Kathleen M. Foley, Physical Scientist (732) 321-6790 Vessup POTW DeShaun Estrill, Operations Supervisor, Phone: (340) 643-0423 3.0 FACILITY DESCRIPTION 3.1 General Information Vessup POTW is located at Nazareth Estate 10 Red Hook Quarter on Saint Thomas Island, US Virgin Islands. The actual facility location can better be described as, at the corner of Vessup Lain and Red Hook Road, on Saint Thomas Island. The facility is a small Public Owned Treatment Works. It is a circular structure that began operations about fifty years ago. The facility has intermittent staffing depending on the time of day and influent volume requirements. The specific North American Industrial Classification System (NAICS) code is 221320, for Sewage Treatment Facilities. The facility has two structures on a small amount of land with limited parking. It has three fulltime employees that report to the facility as needed. The plant's most recent permit became effective on 01 October 2016. The permit expired on 30 September 2021, with no letter of extension on file. 3.2 Process Information The plant has an average water outflow that varies throughout the day and per influent level requirements. During the time of inspection, the plant was being operated as a batch plant due to a failed list pump. An external list pump was being used to move influent from influent well up to the plant for processing. This external pump must be Page 2 of 21 Vessup Public Owned Treatment Works VI0020133 Saint Thomas, USVI November 12, 2021 manually activated by plant employees. The permit requires monitoring of the daily maximum discharge with reporting of weekly and monthly average flow. The maximum daily allowable discharge is 0.10 Million Gallons Daily (MGD). The permitted discharge location for outfall 001 is to Vessup Bay (Red Hook Subwatershed). Outfall 001 is required to be monitored during its constant discharge. Influent water enters the plant system and is passed through a simple screening process. At this point excess grease is manually removed for landfill disposal at Bovoni Landfill. The screened inlet water is then pumped to the plant's processing structure. The screened wastewater is pumped to an aeration tank and digester, an additional aeration tank can be used as required. The wastewater is then sent to a clarifier in the center of the structure. It is then pumped through a chlorination tank and discharged through outfall 001. Storm water runoff from the facility is untreated, and gravity flows to the Vessup Bay. 3.3 Facility Self-Monitoring Information The wastewater from the Vessup POTW is analyzed on site by staff for flow, temperature, dissolved oxygen, pH and chlorine. The remaining parameters are analyzed by the USVI Waste Management Authority Laboratory for Biological Oxygen Demand (BOD5), Total Suspended Solids (TSS), phosphorus, and enterococci bacteria. They are an EPA certified laboratory and are located at the Mangrove Lagoon on Landfill road Estate Bovoni, Saint Thomas, USVI 00802. Plant personnel collect grab samples and conduct onsite analysis during batch processing. They collect an enterococci bacteria sample twice a day. Laboratory results are issued monthly on the Discharge Monitoring Reports (DMR) as required by permit number VI0020133. 4.0 EPA SAMPLING / INSPECTION ACTIVITIES 4.1 Sampling Activities Grab samples were collected from outfall 001 and the influent chamber. The samples were analyzed onsite for, pH, chlorine, temperature, and dissolved oxygen. Total flow for the 24-hour time period was obtained from the facility personnel. Additional grab samples were collected from the influent and effluent outfall 001. These samples were delivered to the USEPA Edison, New Jersey Laboratory. They were analyzed for BOD5, TSS, and phosphorous. Enterococci bacteria samples were collected at two different times and delivered to Ocean Systems Laboratory located at 6194 Estate Frydenhoj #43, Saint Thomas, USVI 00802. Due to collection time restrictions these samples were collected first on 08 November 2021 and the second on 09 November 2021. All sample containers, preservation techniques, conformed to USEPA Page 3 of 21 Vessup Public Owned Treatment Works VI0020133 Saint Thomas, USVI November 12, 2021 requirements specified in 40 CFR Part 136. A chain-of-custody was created on site for all samples and signed over to laboratory personnel upon delivery. The complete analytical data package is attached with the report. 4.2 Inspection Activities On the day of the sampling inspection, a short opening conference and safety brief was conducted with the facility Operations Supervisor Mr. DeShaun Estrill. The inspectors presented identification and credentials, and explained the nature of the inspection. Mr. DeShaun Estrill then provided a tour and explanation of the facility and its features. Grab samples were collected, and measurements were also gathered from the influent changer and effluent of outfall 001. Multiple DMR's covering the months of April 2019 and April 2020 were examined while the inspection team was onsite. 5.0 ANALYTICAL RESULTS Vessup Public Owned Treatment Works, Saint Thomas, USVI CSI November 12, 2021 Parameter Units Permit Limit EPA Result Compliance Result pH S.U. 7 to 8.3 7.47 Compliance Temperature C 32 30.0 Compliance Flow MGD 0.10 1.074 Noncompliance Chlorine, Free g/L 7.5 to 13 420 Noncompliance Disolved Oxygen mg/L 5.5 5.0 Noncompliance Biological Oxygen Demand (BOD5) mg/L 30 9.68 J Compliance BOD5 Percent Removal % 85 98.8 J Compliance Total Suspended Solids (TSS) mg/L 30 10 U Compliance TSS Percent Removal % 85 93.7 U Compliance Phosphorous g/L 50 1150 Noncompliance Enterococci Sample 1 #/100 mL 110 < 1 Compliance Enterococci Sample 2 #/100 mL 110 410 Noncompliance U: Not detected value is the reporting limit J: The report value is an estimate due to sample being received outside of holding time 6.0 FINDINGS 6.1 Sampling Result Findings The DMR's examined did not show any reporting errors and appear to be submitted in the required time frame. However, because the phosphorous detector was down at the VI WMA Laboratory the facility was not collecting phosphorous samples. Page 4 of 21 Vessup Public Owned Treatment Works VI0020133 Saint Thomas, USVI November 12, 2021 Laboratory results indicate that the effluent limitations of TPDES Permit Number VI0020133 page 4 are not being met. The facility is failing to meet its phosphorous removal requirement and is exceeding the maximum allowed chlorine discharge. However, this inspector has never seen a permit limitation of phosphorous and chlorine in the g/mL level. It is normally in the mg/mL level. Mr. Estrill was asked about this and he indicated that he was talking to the permit writers about the very low limit requirement. The second enterococci sample failed inspection. The disolved oxygen requirement is also below the minimum standard. The plant is exceeding the allowable daily discharge of 0.10 MGD. However, the flowmeter for the facility is damaged and is providing an inaccurate measurement, so it cannot be truly stated that the facility is exceeding its discharge limitation. The plant appears to be in poor condition due to being far past its life expectancy. The plant was also severely damaged by hurricane Erma. The Operations Supervisor needs to run the plant as a batch plant due to these damages and cannot run it as a continuous flow plant. There are planes to replace the plant with a new plant, but the dates for this replacement are not set. 7.0 ATTACHMENTS Photographs (#1- #4) Laboratory Data Report Chain of Custody Page 5 of 21 Vessup Public Owned Treatment Works VI0020133 Photo #1: Influent PHOTO LOG Saint Thomas, USVI November 12, 2021 Photo #2: Effluent Outfall 001 Page 6 of 21 Vessup Public Owned Treatment Works VI0020133 Photo #3: Vessup Plant Saint Thomas, USVI November 12, 2021 Photo #4: Vessup Plant Topside Page 7 of 21 Vessup Public Owned Treatment Works VI0020133 Saint Thomas, USVI November 12, 2021 Page 8 of 21 Vessup Public Owned Treatment Works VI0020133 Saint Thomas, USVI November 12, 2021 Page 9 of 21 Vessup Public Owned Treatment Works VI0020133 Saint Thomas, USVI November 12, 2021 Page 10 of 21 Vessup Public Owned Treatment Works VI0020133 Saint Thomas, USVI November 12, 2021 Page 11 of 21 Vessup Public Owned Treatment Works VI0020133 Saint Thomas, USVI November 12, 2021 Page 12 of 21 Vessup Public Owned Treatment Works VI0020133 Saint Thomas, USVI November 12, 2021 Page 13 of 21 Vessup Public Owned Treatment Works VI0020133 Saint Thomas, USVI November 12, 2021 Page 14 of 21 Vessup Public Owned Treatment Works VI0020133 Saint Thomas, USVI November 12, 2021 Page 15 of 21 Vessup Public Owned Treatment Works VI0020133 Saint Thomas, USVI November 12, 2021 Page 16 of 21 Vessup Public Owned Treatment Works VI0020133 Saint Thomas, USVI November 12, 2021 Page 17 of 21 Vessup Public Owned Treatment Works VI0020133 Saint Thomas, USVI November 12, 2021 Page 18 of 21 Vessup Public Owned Treatment Works VI0020133 Saint Thomas, USVI November 12, 2021 Page 19 of 21 Vessup Public Owned Treatment Works VI0020133 Saint Thomas, USVI November 12, 2021 Page 20 of 21 Vessup Public Owned Treatment Works VI0020133 Saint Thomas, USVI November 12, 2021 Page 21 of 21