Document B8KEZw00zeE4yDGLdkxVYb79m

Report Title: Inspection Date(s): Regulatory Program(s): Type of Activity: Site/Facility Name: Permittee(s): Site/Facility Operator: Site/Facility Address: Latitude/Longitude: County/Parish: Permit Number: NAICS/SIC Code: DSB-ID #: Clean Water Act Compliance Inspection Report 06/11/2024 National Pollutant Discharge Elimination System (NPDES) Wastewater Locust Lake State Park Wastewater Treatment Plant Commonwealth of PA, DCNR, Bureau of State Parks, Locust Lake DCNR Locust Lake Road Barnesville, PA 18214 40.7831/- 76.1183 Schuylkill County PA0032131 221320/4952 ECAD-5497 Site/Facility Representative(s): Katherine Macaluso Phone: (570) 573-6471 Lester Miller Phone: (570) 467-8404 EPA Inspectors: Steven Maslowski Phone: (215) 814-2371 Monica Crosby Phone: (410) 305-3029 Email: kamacaluso@pa.gov Email: lestmiller@pa.gov Point of Contact Email: maslowski.steven@epa.gov Email: crosby.monica@epa.gov Report Preparer Signature/Date Supervisor Signature/Date Steve Maslowski, Inspector (3ED33) U.S. EPA Region 3 JESSICA Digitally signed by JESSICA DUFFY DUFFY Date: 2024.08.16 08:12:48 -04'00' Jessica Duffy NPDES Section 2 Chief (3ED33) U.S. EPA Region 3 August 15, 2024 Date Date Locust Lake State Park Wastewater Inspection June 11, 2024 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.................................................................................................... 6 IV Records Review............................................................................................... 7 V Closing Conference......................................................................................... 8 VI List of Attachments.......................................................................................... 8 DSB-ID #: ECAD-5497 Page 2 of 14 Locust Lake State Park Wastewater Inspection June 11, 2024 I. Introduction On June 11, 2024, an inspection team composed of staff from the U.S. Environmental Protection Agency (EPA) Region 3 (hereinafter, "EPA Inspection Team") conducted a wastewater inspection of Locust Lake State Park's Wastewater Treatment Plant (hereinafter, "Facility"). The purpose of the inspection was to observe compliance with the Clean Water Act (CWA) and to verify compliance with the Facility's Pennsylvania National Pollutant Discharge Elimination System (NPDES) Permit No. PA0032131 (hereinafter, the "Permit") and applicable State and Federal regulations. The Permit is included as Attachment A. A. Inspection Opening Conference The EPA Inspection Team arrived at the site at approximately 11:00 AM for the inspection. Inspectors met with the following site representatives: Name Monica Crosby Steven Maslowski Brian Tolton Robert Sweeney Joe Herbstritt Stephanie Coontess Lester Miller Josh Swoltley Rex Bradish Katherine Macaluso Table 1: Inspection Attendee List Affiliation Telephone Email EPA Region III Inspectors Inspector (410) 305-2930 Crosby.monica@epa.gov Inspector (215) 814-2371 Maslowski.steven@epa.gov Inspector In-Training (215) 814-3291 Site Representatives DCNR-Parks (570) 467-2404 DCNR-FDC (717) 787-9290 DCNR-FDC (717) 783- 33329 DCNR- Tuscarora and (570) 4672404 Locust Lake Parks DCNR-Region 4 (215) 453-5011 DCNR-Region 4 (570) 406-9198 WWTP Operator (570) 573-6471 tolton.brian@epa.gov robsweeney@pa.gov joherbstri@pa.gov scoontess@pa.gov lestmiller@pa.gov jswoltley@pa.gov rbradish@pa.gov kamacaluso@pa.gov Steve Maslowski and Monica Crosby displayed their credentials to Facility representatives at the outset of the inspection, and explained the purpose of the inspection was to observe compliance with its Permit. B. Weather and Precipitation Conditions During the inspection, weather was mostly sunny. National Oceanic and Atmospheric Administration (NOAA) National Weather Service precipitation data for the date of the inspection and five days prior are provided in Table 2 below: DSB-ID #: ECAD-5497 Page 3 of 14 Locust Lake State Park Wastewater Inspection June 11, 2024 Table 2. Precipitation Data Station Name Date MAHANOY CITY 2 N, PA USC00365344 MAHANOY CITY 2 N, PA USC00365344 MAHANOY CITY 2 N, PA USC00365344 MAHANOY CITY 2 N, PA USC00365344 MAHANOY CITY 2 N, PA USC00365344 MAHANOY CITY 2 N, PA USC00365344 06/06/24 06/07/24 06/08/24 06/09/24 06/10/24 06/11/24 Precipitation Amount (inches)1 0 0.31 0 0 0 0 C. Summary of the Site Pennsylvania Department of Conservation and Natural Resources (DCNR) owns and operates Locust Lake State Park Wastewater Treatment Plant. The Facility is an activated sludge treatment plant that serves Locust Lake State Park and its campground. The Facility has one (1) outlet that is discharges into Locust Creek, a tributary to the Little Schuylkill River, and ultimately to the Schuylkill River. The Facility's coverage under the Permit became effective on May 1, 2019, and expired on April 30, 2024. The permit has been administratively extended. II. Site Activity The observations from the inspection are described in detail below in the Observations section. Photographs captured during the inspection were taken by Brian Tolton and are provided in Attachment B. At the time of the inspection, the Facility operator described the treatment process (Attachment B, Photo 1). The Facility was first constructed in the 1960s. It treats about 3,000 gal/day, reaching upwards of 8,000 gal/day on the weekends during peak season. Flow feeds into the collection systems from the campground bathrooms and shower. The flow coming into the wastewater treatment plant (WWTP) comes into the comminutor (grinder) and moves through the flume with flow meter, then into the aeration tank, and clarifier (Attachment B, Photos 2- 8 & 18). Sludge is moved from the aeration tank to the digester through the return activated sludge (RAS) pipe. From the clarifier, wastewater flow is sent through the siphon tank. According to Mr. Miller, the siphon was supposed to provide additional aeration. From the siphon tank, the wastewater flow goes to two sand beds, the chlorine contact tank, and is then discharged. Algae was observed on the sides of the aeration tank (Attachment B, Photos 9, 11, & 12). The aeration tank is 18 feet deep. The blowers are adjusted to control dissolved oxygen (DO) in the tank. According to Ms. Macaluso, the Facility was using rabbit food and supplemented with 1 Source: NOAA National Climatic Data Center (http://www.ncdc.noaa.gov/). DSB-ID #: ECAD-5497 Page 4 of 14 Locust Lake State Park Wastewater Inspection June 11, 2024 carbon sources (Attachment B, Photos 13, 14, 15, & 20) to stimulate bacterial growth in the plant in the spring months. The Facility then turned to hog food, but at the time of the inspection, they were experiencing problems with the hog food forming grease balls that were observed in the aeration tank. The hog food was fed into the comminutor instead of the aeration tank, and the grease balls were formed. From aeration, flow feeds into the clarifier (Attachment B, Photos 18 & 19). Poor settling and excess solids were observed in the clarifier. Algae was observed growing on the sides of the skimmer in the clarifier (Attachment B, Photo 26 ). Ms. Macaluso says she uses spray from potable water to push sludge from the clarifier to the sludge holding tank. Locust Lake has had 35 phosphorous effluent violations since June 2019. The Facility is not sure where the source of phosphourous pollutant is coming from. Mr. Miller speculated the additional phosphorus was coming from cleaning products. Ferric chloride was observed in an unlabeled drum being used to drip feed into the clarifier (Attachment B, Photo 17). According to Ms. Macaluso, the facility was feeding the ferric chloride into the aeration tank, but it did not provide the desired results, so they moved the drum to the clarifier and got better results. A vac-truck comes in and hauls off the sludge once a year, with the most recent hauling of sludge being November 2023. No sampling of the sludge is conducted prior to it being hauled off site by Biros Septic (Attachment B, Photo 56). Decant water is returned to the aeration tank. The sludge return runs when the aerator blowers run (Attachment B, Photo 47). From the clarifiers, flow enters the siphon tank (Attachment B, Photos 27, 28, & 29). Grease balls were observed in the siphon tank. The operator, Ms. Macaluso stated that the tank is hosed out every day. Pipes were observed in the siphon tank that facility personnel weren't sure what their function was but suspected they were overflow pipes. The siphon tank had two overflow pipes that led to the sand filters. The two sludge drying beds are used alternating one off and the other on (Attachment B, Photos 33, 34, 35,36, 37, 38, & 39). Ms. Macaluso stated they use one as the drying bed while they are cleaning out the other. They then switch back to the cleaned drying bed while they clean out the other. The drying beds are alternated about once per month. In winter, there is only one drying bed in use since the flow is minimal. Ms. Macaluso stated they cleaned out the south dry bed the week prior to the inspection. Mr. Miller stated the sand beds have not been replaced since 1992 and was unsure how deep the sand filters are. The drying beds flood infrequently but don't overflow. There's a capped overflow pipe, the facility opens the cap and lets it flow out when the bed floods to prevent overflow. Only one sand bed has an overflow pipe. Mr. Miller stated when they notice the filter with no overflow pipe getting full, they switch it over to the filter with the overflow pipe. From the sand filters, the flow moves to the chlorine contact tank (Attachment B, Photos 40, 42, & 43). The inspectors could not observe the bottom of the tank. The chlorine contact tank DSB-ID #: ECAD-5497 Page 5 of 14 Locust Lake State Park Wastewater Inspection June 11, 2024 is 12 feet deep. Algae was observed on the sides of the tank (Attachment B, Photo 44). Sodium hypochloride is drip-fed into a blue bucket, then it feeds into the chamber for contact time (Attachment B, Photos 41 & 42). There was no lid on the drum of sodium hypochloride. During the winter, chlorine tables are used. There is no dechlorination at the Facility. As part of the inspection, the Operator explained the sampling process, and the EPA Inspection Team observed the Facility's lab bench that is used for sample collection (Attachment B, Photo 48, 49, 50, 51, & 52). The facility did not have a composite sampler. The sample was collected into a 500 ml poly bottle and filled 4/5th full. The pH meter was calibrated with 7, 4, and 10 buffer solutions, in this order. Samples are taken to CWM Environmental to be analyzed. Flow is measured via a flow meter that is positioned in the plant lab (Attachment B, Photos 54 & 55). The flow meter at the effluent was out of calibration. The outfall was observed. The pipe was rusted at the headwall (Attachment B, Photos 59, 60, & 61). III.Observations NPDES Permit Effluent Exceedances Requirement: Part A.1.A of the Permit defines effluent discharge limitations, monitoring, and reporting requirements for Outfall No. 001. Permit citation: "Based on the anticipated wastewater characteristics and flows described in the permit application and its supporting documents and/or amendments, the following effluent limitations and monitoring requirements apply." Observation 1: According to EPA's Integrated Compliance Information System effluent data, the Frances Slocum State Park WWTP has had 71 effluent violations between March 2019 and October 2023 (Refer to Table 3). Table 3: Effluent Violations from June 2019 to December 2023 Monitoring Period End Date 12/31/2023 Parameter Phosphorus, total [as P] 11/30/2023 Phosphorus, total [as P] Value Type MO AVG MO AVG Reported Value/Units 6.54 mg/l 4.92 mg/l Percent Exceed 227% 146% Limit Value/Units <=2 mg/l <=2 mg/l DSB-ID #: ECAD-5497 Page 6 of 14 Locust Lake State Park Wastewater Inspection June 11, 2024 Monitoring Period End Date 11/30/2023 Parameter Chlorine, total residual 10/31/2023 Phosphorus, total [as P] 10/31/2023 Chlorine, total residual 09/30/2023 09/30/2023 Oxygen, dissolved [DO] Phosphorus, total [as P] 09/30/2023 Chlorine, total residual 08/31/2023 08/31/2023 08/31/2023 Oxygen, dissolved [DO] Nitrogen, ammonia total [as N] Phosphorus, total [as P] 08/31/2023 Chlorine, total residual 07/31/2023 Oxygen, dissolved [DO] Value Type MO AVG MO AVG INST MAX INST MIN MO AVG MO AVG INST MIN MO AVG MO AVG MO AVG INST MIN Reported Value/Units .46 mg/l 5.3 mg/l 1.47 mg/l 2.25 mg/l 5.49 mg/l .45 mg/l 2.1 mg/l 13 mg/l 4.06 mg/l .59 mg/l 1.07 mg/l Percent Exceed 12% 165% 23% 63% 175% 10% 65% 32% 103% 44% 82% Limit Value/Units <=.41 mg/l <=2 mg/l <=1.2 mg/l >=6 mg/l <=2 mg/l <=.41 mg/l >=6 mg/l <=9.87 mg/l <=2 mg/l <=.41 mg/l >=6 mg/l 07/31/2023 pH 5.65 >=6 INST su su MIN DSB-ID #: ECAD-5497 Page 7 of 14 Locust Lake State Park Wastewater Inspection June 11, 2024 Monitoring Period End Date 07/31/2023 07/31/2023 Parameter Nitrogen, ammonia total [as N] Phosphorus, total [as P] 07/31/2023 Coliform, fecal general 06/30/2023 06/30/2023 Oxygen, dissolved [DO] Phosphorus, total [as P] 05/31/2023 Phosphorus, total [as P] 04/30/2023 Phosphorus, total [as P] 04/30/2023 Chlorine, total residual 03/31/2023 Phosphorus, total [as P] 03/31/2023 Chlorine, total residual 02/28/2023 Phosphorus, total [as P] 01/31/2023 Phosphorus, total [as P] 01/31/2023 Chlorine, total residual Value Type MO AVG MO AVG INST MAX INST MIN MO AVG MO AVG MO AVG MO AVG MO AVG MO AVG MO AVG MO AVG MO AVG Reported Value/Units 12.64 mg/l Percent Exceed 28% Limit Value/Units <=9.87 mg/l 7.2 260% <=2 mg/l mg/l >2,420 #/100ml 99,999% <=1,000 #/100ml 3.26 46% >=6 mg/l mg/l 4.26 113% <=2 mg/l mg/l 4.16 108% <=2 mg/l mg/l 2.7 35% <=2 mg/l mg/l .55 34% <=.41 mg/l mg/l 5.04 152% <=2 mg/l mg/l .6 46% <=.41 mg/l mg/l 4.42 121% <=2 mg/l mg/l 5.39 170% <=2 mg/l mg/l .83 102% <=.41 mg/l mg/l DSB-ID #: ECAD-5497 Page 8 of 14 Locust Lake State Park Wastewater Inspection June 11, 2024 Monitoring Period End Date 12/31/2022 Parameter Phosphorus, total [as P] 11/30/2022 Phosphorus, total [as P] 10/31/2022 Phosphorus, total [as P] 09/30/2022 Phosphorus, total [as P] 09/30/2022 Chlorine, total residual 08/31/2022 Phosphorus, total [as P] 07/31/2022 Phosphorus, total [as P] 07/31/2022 Chlorine, total residual 06/30/2022 Phosphorus, total [as P] 06/30/2022 Chlorine, total residual 06/30/2022 BOD, carbonaceous [5-day, 20 C] Value Type MO AVG MO AVG MO AVG MO AVG MO AVG MO AVG MO AVG INST MAX MO AVG MO AVG MO AVG Reported Value/Units 3.64 mg/l 3.17 mg/l 3.32 mg/l 3.61 mg/l .55 mg/l 6.23 mg/l 7.21 mg/l 1.5 mg/l 3.82 mg/l .44 mg/l <18.7 mg/l Percent Exceed 82% 59% 66% 81% 34% 212% 261% 25% 91% 7% 34% Limit Value/Units <=2 mg/l <=2 mg/l <=2 mg/l <=2 mg/l <=.41 mg/l <=2 mg/l <=2 mg/l <=1.2 mg/l <=2 mg/l <=.41 mg/l <=14 mg/l 04/30/2022 Chlorine, total .57 residual MO mg/l AVG 12% <=.51 mg/l DSB-ID #: ECAD-5497 Page 9 of 14 Locust Lake State Park Wastewater Inspection June 11, 2024 Monitoring Period End Date 12/31/2021 11/30/2021 10/31/2021 10/31/2021 09/30/2021 08/31/2021 08/31/2021 08/31/2021 07/31/2021 06/30/2021 02/28/2021 01/31/2021 11/30/2020 Parameter Phosphorus, total [as P] Phosphorus, total [as P] Phosphorus, total [as P] Chlorine, total residual Phosphorus, total [as P] Phosphorus, total [as P] Chlorine, total residual Coliform, fecal general Phosphorus, total [as P] Phosphorus, total [as P] Coliform, fecal general Coliform, fecal general Phosphorus, total [as P] Value Type MO AVG MO AVG MO AVG MO AVG MO AVG MO AVG MO AVG INST MAX MO AVG MO AVG GEO MEAN INST MAX MO AVG Reported Value/Units 2.09 mg/l 2.67 mg/l 2.09 mg/l .66 mg/l 2.88 mg/l 4.19 mg/l .54 mg/l 7,600 #/100ml 3.75 mg/l 2.52 mg/l 421 #/100ml 2,800 #/100ml 2.67 mg/l Percent Exceed 5% 34% 5% 29% 44% 110% 6% 660% 88% 26% 111% 180% 34% Limit Value/Units <=2 mg/l <=2 mg/l <=2 mg/l <=.51 mg/l <=2 mg/l <=2 mg/l <=.51 mg/l <=1,000 #/100ml <=2 mg/l <=2 mg/l <=200 #/100ml <=1,000 #/100ml <=2 mg/l DSB-ID #: ECAD-5497 Page 10 of 14 Locust Lake State Park Wastewater Inspection June 11, 2024 Monitoring Period End Date 10/31/2020 09/30/2020 08/31/2020 08/31/2020 07/31/2020 07/31/2020 10/31/2019 09/30/2019 09/30/2019 08/31/2019 08/31/2019 08/31/2019 08/31/2019 Parameter Phosphorus, total [as P] Phosphorus, total [as P] Oxygen, dissolved [DO] Phosphorus, total [as P] Oxygen, dissolved [DO] Phosphorus, total [as P] Oxygen, dissolved [DO] Oxygen, dissolved [DO] Phosphorus, total [as P] Oxygen, dissolved [DO] Phosphorus, total [as P] Coliform, fecal general Coliform, fecal general Value Type MO AVG MO AVG INST MIN MO AVG INST MIN MO AVG INST MIN INST MIN MO AVG INST MIN MO AVG GEO MEAN INST MAX Reported Value/Units 2.98 mg/l 5.91 mg/l 4.51 mg/l 7.6 mg/l 4.58 mg/l 2.42 mg/l <6 mg/l <6 mg/l 4.348 mg/l <6 mg/l 3.314 mg/l 1,960 #/100ml 1,960 #/100ml Percent Exceed 49% 196% 25% 280% 24% 21% 99,999% 99,999% 117% 99,999% 66% 880% 96% Limit Value/Units <=2 mg/l <=2 mg/l >=6 mg/l <=2 mg/l >=6 mg/l <=2 mg/l >=6 mg/l >=6 mg/l <=2 mg/l >=6 mg/l <=2 mg/l <=200 #/100ml <=1,000 #/100ml DSB-ID #: ECAD-5497 Page 11 of 14 Locust Lake State Park Wastewater Inspection June 11, 2024 Monitoring Period End Date 07/31/2019 06/30/2019 06/30/2019 06/30/2019 06/30/2019 06/30/2019 Parameter Oxygen, dissolved [DO] Nitrogen, ammonia total [as N] Phosphorus, total [as P] Coliform, fecal general Coliform, fecal general BOD, carbonaceous [5-day, 20 C] Value Type INST MIN MO AVG MO AVG GEO MEAN INST MAX MO AVG Reported Value/Units .1 mg/l 16.46 mg/l 3.143 mg/l 2,300 #/100ml 2,300 #/100ml 16.46 mg/l Percent Exceed 98% 67% 57% 1,050% 130% 18% Limit Value/Units >=6 mg/l <=9.87 mg/l <=2 mg/l <=200 #/100ml <=1,000 #/100ml <=14 mg/l Representative Sampling Requirement: Part III.A.1 of the Permit states, "Samples and measurements taken for the purpose of monitoring shall be representative of the monitored activity (40 CFR 122.41(j)(1)). Representative sampling includes the collection of samples, where possible, during periods of adverse weather, changes in treatment plant performance and changes in treatment plant loading. If possible, effluent samples must be collected where the effluent is well mixed near the center of the discharge conveyance and at the approximate mid-depth point, where the turbulence is at a maximum and the settlement of solids is minimized. (40 CFR 122.48, 25 Pa. Code 92a.61)" Observation 2: Part A: II. Composite Sample. The composite must be flow-proportional; either the volume of each induvial sample is proportional to discharge flow rates, or the sampling interval is proportional to the flow rates over the time period used to produce the composite. At the time of the Inspection, the Facility was taking grab samples using a 500 mL poly bottle from the end of the chlorine contact tank. There was no DSB-ID #: ECAD-5497 Page 12 of 14 Locust Lake State Park Wastewater Inspection June 11, 2024 indication that the samples taken were flow proportional or time proportional composites. Proper Operation and Maintenance Requirement: Part B.E.2 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 includes, 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. (40 CFR 122.41(e))" Observation 3: The EPA Inspection Team observed algae build up in the clarifier (Attachment B, Photo 26). Observation 4: Observation 5: Observation 6: Observation 7: At the time of the inspection, there was algae build up in the aeration tank (Attachment B, photos 9, 11, &12). The EPA inspection Team observed algae build up in the chlorine contact tank (Attachment B, Photo 45). At the time of the inspection, there was no lid on the chlorine poly drum containing ferric chloride and sodium hypochloride (Attachment B, Photos 17 & 41). At the time of the inspection, there was no log for chemicals stored on site. Observation 8: At the time of the inspection, there were weeds and leaf litter in one of the one of two sand beds (Attachment B, Photos 34, 35, & 38). Records Keeping Requirement: III. A. 2. Except for records of monitoring information required by this permit related to the permittee's sludge use and disposal activities which shall be retained for a period of at least 5 years, all records of monitoring activities and results (including all original strip chart recordings for continuous monitoring instrumentation and calibration and maintenance records), copies of all reports required by this permit, and records of all data used to complete the application for this permit shall be retained by the permittee for 3 years from the date of the sample measurement, report or application. The 3-year period shall be extended as requested by DEP or the EPA Regional Administrator. DSB-ID #: ECAD-5497 Page 13 of 14 Locust Lake State Park Wastewater Inspection June 11, 2024 Observation 9: At the time of the inspection, EPA requested waste manifest for removal of solids. These documents were not submitted to EPA. IV.Records Review As part of the inspection, the EPA Inspection Team reviewed the following documentation: Operator's daily worksheet, last six (6) months of discharge monitoring reports, the Operator's certification, and the Permit. V. Closing Conference After the site walk, the EPA Inspection Team met with the Facility representatives for a closing conference. The EPA Inspection Team shared preliminary observations with the Facility. The EPA Inspection Team reiterated to the Facility representatives that all preliminary observations discussed were not compliance determinations. Any and all preliminary observations shared were subject to further investigation by 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 EPA reviewed additional materials following the inspection. The inspection concluded at 12:40p.m. VI. List of Attachments Attachment A: Attachment B: Permit Photograph Log DSB-ID #: ECAD-5497 Page 14 of 14