Document 9J0MXQ6OBr1xYmnxQaBBGyN26

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION III Four Penn Center Philadelphia, Pennsylvania 19103-2029 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 07/20/2022 National Pollutant Discharge Elimination System (NPDES) Pre-Treatment - POTW Inspection Pine Creek Wastewater Treatment Plant Pine Creek Wastewater Treatment Plant Pine Creek Municipal Authority 429 8th Street Jersey Shore, PA 17740 41.175639 Longitude: -77.315517 Clinton County PA0027553 22132 SIC: 4952 3E22WN016A Site/Facility Representative(s): Tammy Cochran Phone: 570-398-7897 Operations Manager Email: pcmadesk@aol.com Email: Point of Contact EPA Inspector: Garth Connor Phone: 215-814-3209 EPA Inspector Email: Connor.garth@epa.gov Report Preparer Signature/Date Supervisor Signature/Date Digitally signed by GARTH GARTH CONNOR CONNOR Date: 2022.09.21 11:29:46 -04'00' Garth Connor, ESS (ED13) Date EPA Region 3 - Philadelphia, PA 19103 Digitally signed by ZELMA ZELMA MALDONADO MALDONADO Date: 2022.09.21 12:39:13 -04'00' Zelma Maldonado Date ESS Acting Section Chief - EPA Region 3 Unique Project#: 3E22WN016A Pine Creek Wastewater Treatment Plant - Pre-Treatment Report 07/20/2022 Table of Contents Section Page I Introduction............................................................................ 3 A Inspection Opening Conference...................................................................... 3 B Weather and Precipitation Conditions............................................................. 3 C Summary of the Facility.................................................................................. 4 II Site Activity..................................................................................................... 4 III Observations.................................................................................................... 4 IV Records Review............................................................................................... 5 V Closing Conference......................................................................................... 5 VI List of Attachments.......................................................................................... 6 Unique Project #: 3E22WN016A Page 2 of 7 Pine Creek Wastewater Treatment Plant - Pre-Treatment Report 07/20/2022 I. Introduction On July 20, 2022, Garth Connor, hereafter "EPA inspector", an inspector from the Enforcement Support Section (ESS) of the U.S. Environmental Protection Agency ("EPA") Region III Office in Philadelphia, Pennsylvania, conducted an onsite Pre-Treatment Inspection at the Pine Creek Wastewater Treatment Plant facility (hereinafter, "Pine Creek", "the Facility"). This wastewater treatment plant is managed by the Pine Creek Municipal Authority (PCMA) and is located at 429 8th Street in Jersey Shore, Clinton County, Pennsylvania. PCMA operates the plant for the residents and businesses in some parts of that community, and it also manages a pre-treatment program for its industrial users. The Facility receives wastewater from the communities of Pine Creek Township, Avis Township and Wayne Township. The PCMA also has separate administrative offices that are located at 985 Railroad Street in Avis, Pennsylvania. The Facility discharges its wastewater to a small unnamed tributary of the West Branch of the Susquehanna River. The purpose of the inspection was to observe compliance with the Pre-Treatment regulations of the Clean Water Act (CWA) and to verify their compliance with the applicable industrial user regulations. The Pennsylvania Department of Environmental Protection was invited to the inspection but chose not to attend. A. Inspection Opening Conference The EPA Inspector arrived at the facility at about 10:00 AM for this inspection and met with the following facility representatives: Name Garth Connor Tammy Cochran Table 1: Inspection Attendee List Affiliation Telephone EPA Region III Inspector EPA - Phila. Office 215-814-3209 Site/Facility Representatives PCMA - Operations 570-398-7897 Manager Email Connor.garth@epa.gov pcmadesk@aol.com Garth Connor displayed his inspector credentials to Ms. Tammy Cochran in the PCMA's administrative offices at the start of the inspection, and explained that the purpose of the inspection was to observe the Facility's compliance with the pre-treatment regulations of the Clean Water Act. The EPA Inspector informed the Pine Creek staff that any information that the Facility deemed to be Confidential Business Information ("CBI") should be identified to the EPA inspector during the inspection and it would be handled as CBI according to EPA's CBI procedures. Weather and Precipitation Conditions During the inspection, the weather was mostly sunny with temperatures in the 70's Unique Project #: 3E22WN016A Page 3 of 7 Pine Creek Wastewater Treatment Plant - Pre-Treatment Report 07/20/2022 C. Summary of the Site/Facility Pine Creek has an EPA-approved pre-treatment program for its Industrial Users (IUs), and it currently has three significant IUs within its jurisdiction. Pine Creek had one more notable IU several years ago, but Woolrich, the outdoor clothing manufacturer, closed their operations at their local plant after over 100 years in that community and moved their operations elsewhere. The three IUs still operating in Pine Creek are Wayne Township Landfill, First Quality Products and Nutek Disposables Inc. (Nutek). Nutek and First Quality Products have the same corporate owner, and they operate in adjoining locations. Ms. Cochran has worked as the Manager of the Industrial Pre-treatment Program at Pine Creek for many years, and she is quite familiar with all three of these IUs and their manufacturing operations. The EPA inspector picked Nutek as the IU to be visited in the Pine Creek jurisdiction for the second part of this inspection. Nutek produces and then packages various containers and types of disinfecting wipes from large rolls of material at this plant. Nutek is physically located in the nearby town of McElhattan, Pennsylvania. II. Site Activity During the inspection, the EPA Inspector first discussed the details of the Pine Creek industrial pre-treatment program with Ms. Cochran, the PCMA Operations Manager, in an Opening Conference at the PCMA administrative offices. Ms. Cochran manages the PreTreatment program for Pine Creek, and she explained to the EPA inspector that she issues 5-year discharge permits to all three of their IUs. They regularly sample and inspect all three of their industrial users once each year to make certain that they're all operating within their permit limits. Each of the IUs also performs regular self-monitoring of their own wastewater discharges. See Attachment #1 - Inspection Photographs for photographs of the IU inspection. The EPA inspector was accompanied by both Nutek and Pine Creek staff and he walked through the entire Nutek manufacturing plant to see the different segments of their industrial manufacturing process. The inspection observations were made pursuant to the requirements of the Pre-Treatment regulations of the Clean Water Act. III. Observations The EPA inspector started the inspection at Nutek in a large conference room with Ms. Cochran and Bob Wahlers, Nutek's Facility Maintenance Manager, and he described the nature of a pre-treatment inspection. Ms. Cochran explained to the EPA inspector that Nutek does twice a month self-monitoring of its wastewater, and it does monthly reporting of the sampling Unique Project #: 3E22WN016A Page 4 of 7 Pine Creek Wastewater Treatment Plant - Pre-Treatment Report 07/20/2022 results. In order to make the anti-septic and disinfectant wipes, Nutek blends tree-based paper with a polyethylene (oil-based) fiber. The company produces long rolls of these blended sheets of wipes, and then cuts them into much smaller sizes and packages them to make their actual finished products. Photograph #1 shows some of the Nutek products from a display case in their front lobby. Photograph #2 shows the Nutek flow meter operating near their wastewater sampling location in the Nutek plant. The wastewater that is contaminated with disinfectant in their manufacturing process, is separated and is hauled elsewhere. This wastewater is not currently discharged to the Pine Creek wastewater plant. Ms. Cochran explained to the EPA inspector that this type of wastewater could possibly have a negative impact on the health of the microorganisms at the Pine Creek wastewater treatment plant. Photograph #3 shows the actual sampling location in the floor of the plant next to the flow meter. IV. Records Review During this inspection, the EPA Inspector filled out a POTW Pre-Treatment Inspection Checklist, and that document is attached (Attachment #2 - POTW Inspection Checklist). He was also given an electronic copy of the Nutek IU permit which includes all the parameter limits and sampling requirements for Nutek's wastewater discharges (Attachment #3 - Nutek IU Permit). Nutek does twice a month sampling of its wastewater, and it also does monthly reporting of the results to Ms. Cochran. Pace Laboratories in Williamsport, Pennsylvania does the sampling analysis, and the results of a recent sampling event is attached (Attachment #4 - Recent Sampling Results). The results of the recent quarterly sampling were reviewed by the EPA inspector and showed that all of results of the limited parameters are well below Nutek's permit limits. V. Closing Conference After the facility inspection at Nutek, the EPA Inspector met with the Pine Creek and Nutek staff at a conference room at the Nutek facility for a closing conference. The EPA Inspector shared preliminary observations with the facility personnel. Nutek staff did inform the EPA inspector at the closing conference that several of his inspection photos showing the production machinery/equipment in the Nutek manufacturing process may be CBI, and those photos should not be part of the EPA's inspection report. The EPA Inspector reiterated to the Nutek staff that all the preliminary observations discussed were not compliance determinations. Any and all preliminary observations shared are subject to further investigation by EPA staff upon the additional review of records and documentation. Additional observations may be contained in this inspection report and its attachments that were not identified at the time of the closing conference after EPA reviewed additional materials that were sent following the onsite inspection. Unique Project #: 3E22WN016A Page 5 of 7 Pine Creek Wastewater Treatment Plant - Pre-Treatment Report 07/20/2022 The inspection concluded at approximately 1 PM, and the EPA inspector then left the Facility. Unique Project #: 3E22WN016A Page 6 of 7 Pine Creek Wastewater Treatment Plant - Pre-Treatment Report 07/20/2022 VI. List of Attachments Attachment #1: Inspection Photographs Attachment #2: Industrial User's Checklist Attachment #3: Nutek's IU Permit Attachment #4: Nutek's Sampling Results Unique Project #: 3E22WN016A Page 7 of 7