Document ExGKnbX3mdVy4rV4n8Nbv5DK0

CWA NPDES COMPLIANCE EVALUATION INSPECTION REPORT U.S. ENVIRONMENTAL PROTECTION AGENCY, REGION 5 Inspection Type: NPDES Surface Water Facility: U. S. Army Corps of Engineers, Berlin Lake, WWTP 7400 Bedell Road Berlin Lake, Ohio 44401 Operated by: Northstar Contracting, Inc. 11730 Harvard Ave. Cleveland, Ohio 44105 (216) 999-7595 Mailing Address: U. S. Army Corps of Engineers, Berlin Lake, WWTP 7400 Bedell Road Berlin Lake, Ohio 44401 Permit Number: OH0023671 Date of Inspection: June 9, 2021 EPA Representatives: Paul J. Novak Jr., Geologist, (440) 250-1714 Megan Zale, Environmental Scientist, (440) 250-1711 Jason Hewitt, Environmental Engineer, (312) 353-3114 Facility Representative: Jason Quinn, U. S. ACE, Resource Manager, (330) 275-0267 Kristen Hoesch, U. S. ACE, Operations Section Chief, (412) 395-7375 Waylon Reigle, U. S. ACE, Maintenance Leader, (330) 547-6714 Jason Mango, Supervisor, Northstar Contracting, Inc., (216) 999-7595 Amy Mango, Operator, Northstar Contracting, Inc., (216) 999-7595 Report Date: July 23, 2021 Report Prepared by: Paul J. Novak Jr. Digitally signed by Paul J. Novak Jr. Date: 2021.07.23 08:37:36 -04'00' Paul J. Novak Jr., (440) 250-1714, novak.paul@epa.gov Page 1 of 6 Report Approved by: MARK CONTI Digitally signed by MARK CONTI Date: 2021.07.23 09:14:17 -04'00' Mark Conti, (440) 250-1706, conti.mark@epa.gov Page 2 of 6 I. INTRODUCTION The U. S. Army Corps of Engineers' (USACE) Berlin Lake wastewater treatment plant (WWTP) is located on the east shore of Berlin Lake in Berlin Township, Mahoning County, Ohio. The WWTP serves the campground (around 300 campsites) and the USACE offices on-site. The USACE owns the WWTP but has contracted out the operation of the treatment units and the on-site laboratory to Northstar Contracting, Inc. II. FINDINGS A. Facility Background The facility was built in 1977. It operates year-round, although the campground operates May through September. During the other months the WWTP serves only the administration and maintenance buildings, which stay open all year long with about eight staff members. There is a total of nine restroom buildings, two have showers. There are two dump stations (for recreational vehicles) and three lift stations that send the wastewater to the WWTP. All three lift stations operate in series. Flow comes into the WWTP by forced main and by gravity (administration and maintenance buildings). Appendix 1 is a location map. B. Wastewater Treatment Plant The plant a minor discharger with a design average flow of 0.03 million gallons per day. Appendix 2 is a plant schematic as supplied by USACE staff. Flow into the plant passes through a Parshall flume and into a comminuter. If flow is too high, then flow is directed through a bar screen, and together with the flow from the comminutor it flows into a splitter box. From the splitter box flow is directed to two aeration tanks (run in parallel). Wastewater is then sent to a clarifier. After clarification, flow is directed to a diverter box and then to the sand filters. We did observe that one of the sand filters has been lifted out of its foundation and does receive flow via the diverter box (see photograph 7 in Appendix 3). We were told by USACE personnel that the sand filter tank was lifted out by frost action during the past winter. It is still used, but it is filled manually by a pump in the clarifier with a hose into the sand filter. USACE staff also told us it is not known if the tank is still level. After filtration the flow is then sent to the chlorination chamber for disinfection. Sodium hypochlorite is added for disinfection and sodium bisulfite is added for dechlorination. Neither of these chemicals are metered out according to wastewater flow. Wastewater is pumped from the chlorination chamber through the dechlorination box and then into a manhole where the final effluent samples are collected. From the manhole, effluent flows by gravity to Berlin Lake. Page 3 of 6 Solids are pumped out of the clarifier to either of the sludge holding tanks. Solids from the mud wells in the sand filters are also pumped to the sludge holding tanks. A contractor is used to haul out the solids to another WWTP. For the current season Charlie Hoffman's Septic Systems is the contractor and that firm hauls the sludge to the Alliance WWTP. USACE receives only a haulage ticket from the hauler and no information from the Alliance WWTP. Flow is monitored at the WWTP influent by a Parshall flume and ultrasonic meter (see Photographs 1 and 2, in Appendix 3). We were told by Northstar Contracting staff that the ultrasonic meter has never been calibrated and that checks against the flume are infrequently done. U. S. ACE personnel told us that when Berlin Lake levels are high, and the plant effluent can't flow from the effluent manhole into the lake they effectively shut down the campground by locking the doors to the restrooms. We collected a grab sample at the effluent manhole to check for parameters. Appendix 5 contains a table showing our results. Appendix 7 is a table of Ohio EPA Berlin Lake violations for the past three years. C. Laboratory The operator on-site collects all samples as grabs, those parameters that are required to be composites are collected as three separate grabs and then composited. The operator on duty told us that she or the operator of record (Mr. Craig Prater, Northstar Contracting), records the time of the first aliquot as the time of the sample on the chain-of-custody form. Samples are only collected during 7:00 a.m. to 3:00 p.m., six days per week. The plant is not staffed on Sundays. Samples are only collected when the final effluent pump is running. We observed that flow is not recorded when samples are being collected and are not collected proportioned to flow (the permit at Part II.3.F, requires samples be collected in proportion to flow). The laboratory on site is operated by Northstar Contracting. Disolved oxygen, ammonia, residual chlorine, and pH are analyzed on-site. We were told by Northstar Contracting staff that a Hach HQ440D meter is used for these measurements and that residual chlorine is analyzed on-site using a Hach DR300. However, when I examined the Hach website the HQ440D meter is not capable of performing the ammonia measurement, but the DR300 is. We observed an expired bottle of ammonia standard present in the lab. We were also told that there is no spare pH probe for the Hach HQ440D meter but that there are parts for ammonia and dissolved oxygen measurements. All other permit parameters are analyzed by Ream & Haager Environmental Laboratory, Inc., 179 W. Broadway St., Dover, Ohio, 44622. Page 4 of 6 We observed that the refrigerator used to store samples was also being used to store food (see Photograph 16 in Appendix 3). There was no temperature log or thermometer to monitor the refrigerator's temperature. After we returned from our lunchbreak, we observed the cooler that contained the facility's samples sitting out by itself on the grass by a loop in the drive with nobody around it (see photographs 14 and 15 in Appendix 3). Northstar Contracting staff told us that it was indeed the sample cooler which typically is put on the grass area outside of the WWTP fence. D. Sewer System The sewer system runs throughout the campground connecting nine restroom facilities (two with showers), and two dump stations (for trailers and RVs). There are three lift stations operated in series. Appendix 4 is a map of the sewer system. One of the lift stations was completely rebuilt in 2018 (see photographs 19 and 20 in Appendix 3). This is the last lift station in the series and the new construction also included a small amount sewer pipe. The two remaining lift stations and sewer system are original to the establishment of the facility (see photographs 17 and 18 in Appendix 3). The sewer system is vitreous clay pipe. U. S. ACE personnel present told us that they feel that during rain events that inflow and infiltration into the sewer system causes the hydraulic overloads at the WWTP. E. Issues of Concern The damage to one of the sand filters from frost action (Ohio EPA identified this as a violation) has potentially compromised this unit's function. The repeated violations of the facility's NPDES permit parameters is of concern especially those that occurred in June of 2020, when the campground was shut down due to high lake levels (see documents Appendix 6). We also observed several places where bolts were missing from the railing anchor points for the handrails around treatment units. The unattended sample cooler that we found during our inspection potentially compromises the chain-of-custody for the samples (and integrity of the data derived from the analyses). The absence of quality control like the sample refrigerator temperature is also of concern for the on-site laboratory. U. S. ACE personnel told us that there are plans to include a budget request for fiscal year 2022 for, a complete replacement of the WWTP, but at the time of our inspection that request had not been submitted. Page 5 of 6 Appendices 1. Location Map 2. WWTP Schematic 3. Photographs 4. Sewer System Map 5. U. S. EPA Sampling Results 6. Ohio EPA Notice of Violation and U. S. ACE Response 7. Table of Ohio EPA Berlin Lake Violations Page 6 of 6 Appendix 1 Appendix 2 Appendix 3 US Army Corps of Engineers - Berlin Lake EPA Inspection 6/9/2021 All photos taken by Megan Zale, NPDES Inspector-in-Training, U.S. EPA Camera: Nikon Coolpix 1: DSCN0179 Description: Influent flume Location: WWTP Camera Direction: ground Date/Time: 6/9/2021 10:32 Page 1 Berlin Lake 6/9/2021 2: DSCN0180 Description: Calibration devices for flume Location: WWTP Camera Direction: ground Date/Time: 6/9/2021 10:36 3: DSCN0181 Description: Bar screen, comminutor, outlet hole in upper left Location: WWTP Camera Direction: northeast Date/Time: 6/9/2021 10:52 Page 2 Berlin Lake 6/9/2021 4: DSCN0182 Description: Aeration tank Location: WWTP Camera Direction: southwest Date/Time: 6/9/2021 11:12 5: DSCN0183 Description: Clarifier Location: WWTP Camera Direction: ground Date/Time: 6/9/2021 11:12 Page 3 Berlin Lake 6/9/2021 6: DSCN0184 Description: Clarifier Location: WWTP Camera Direction: ground Date/Time: 6/9/2021 11:48 7: DSCN0185 Description: sand filters units (in foreground), note unit at left has been lifted out of the ground Location: WWTP Camera Direction: southwest Date/Time: 6/9/2021 11:48 Page 4 Berlin Lake 6/9/2021 8: DSCN0186 Description: Chlorination tank Location: WWTP Camera Direction: ground Date/Time: 6/9/2021 11:48 9: DSCN0187 Description: Dechlorination pit Location: WWTP Camera Direction: ground Date/Time: 6/9/2021 11:48 Page 5 Berlin Lake 6/9/2021 10: DSCN0188 Description: Sampling manhole, outlet to Berlin Lake at top (at bottom) of manhole Location: WWTP Camera Direction: ground Date/Time: 6/9/2021 11:51 11: DSCN0189 Description: Clarifier pump used to transfer effluent to damaged sand filter Location: WWTP Camera Direction: ground Date/Time: 6/9/2021 11:59 Page 6 Berlin Lake 6/9/2021 12: DSCN0190 Description: first sludge tank Location: WWTP Camera Direction: southwest Date/Time: 6/9/2021 12:01 13: DSCN0191 Description: empty sludge tank Location: WWTP Camera Direction: southwest Date/Time: 6/9/2021 12:01 Page 7 Berlin Lake 6/9/2021 14: DSCN0192 Description: Unattended lab cooler with samples Location: outside of WWTP gates Camera Direction: east Date/Time: 6/9/2021 13:15 15: DSCN0193 Description: Unattended lab cooler with samples Location: outside of WWTP gates Camera Direction: ground Date/Time: 6/9/2021 13:15 Page 8 Berlin Lake 6/9/2021 16: DSCN0194 Description: Lab refrigerator, note food and drinks Location: WWTP Lab Camera Direction: southwest Date/Time: 6/9/2021 13:19 17: DSCN0195 Description: Oak Lift Station Location: Camera Direction: Date/Time: 6/9/2021 14:24 Page 9 Berlin Lake 6/9/2021 18: DSCN0196 Description: Aspen Lift Station Location: Camera Direction: Date/Time: 6/9/2021 14:33 19: DSCN0197 Description: Maplewood Lift Station Location: Camera Direction: Date/Time: 6/9/2021 14:45 Page 10 Berlin Lake 6/9/2021 20: DSCN0198 Description: Maplewood Lift Station Location: Camera Direction: Date/Time: 6/9/2021 14:46 Page 11 Berlin Lake 6/9/2021 Appendix 4 Appendix 5 U. S. EPA Sample Results from U. S. EPA Berlin Lake WWTP collected on June 9, 2021 at 3:40 p.m. pH 7.44 standard Units conductivity 1110 S/cm dissolved oxygen 8.93 mg/l Measurements taken with YSI model 556 meter, with model 5565 pH probe installed Northstar Contracting staff read 1.922 gpm on readout for influent sonic meter at time of sampling Appendix 6 REPLY TO ATTENTION OF Operations Division DEPARTMENT OF THE ARMY U.S. ARMY CORPS OF ENGINEERS, PITTSBURGH DISTRICT 1000 LIBERTY AVENUE PITTSBURGH PA 15222-4186 November 5, 2020 SUBJECT: Notice of Violation Response - NPDES OH0023671 Mill Creek Recreation Area at Berlin Lake Via Email Ms. Brianne Workman District Representative Ohio Environmental Protection Agency, Northeast District Office 50 West Town Street Columbus, Ohio 43216-1049 Dear Ms. Workman: The United States Army Corps of Engineers, Pittsburgh District, is in receipt of the Notice of Violation (NOV), dated October 8, 2020, for the Berlin Lake wastewater treatment facility (WWTF) located at 2030 Bonner Road, Deerfield, Ohio 44411. Upon receipt of this NOV, we promptly engaged with our WWTF operator to address the instances of noncompliance noted in the NOV. In the immediate term, we are analyzing existing data to determine if we can correlate high campground occupancy to the compliance issues noted in the NOV. Our campground is currently closed. If a correlation can be identified, we will recommend temporary closure of a percentage of campsites for the upcoming recreation season to restore permit compliance while we determine the reasoning behind any numeric exceedances. From a long-term perspective, we will review our contract with the current operator, and identify WWTF maintenance requirements and potential upgrades in our next fiscal year (FY) budget package request (2022). The FY22 budget package will request an A/E Contractor to assess the WWTF and provide recommendations to rehabilitate, repair, replace, or eliminate the WWTF in view of projected future use at Berlin Lake's Mill Creek Recreation Area. Please contact Jess Hall at Jessica.G.Hall@usace.army.mil or 412-395-7586 if you have any questions or recommendations. Sincerely, Kathy M. Griffin Chief, Operations Division -2- CF: Jess Hall, USACE Jason Quinn, USACE Waylon Reigle, USACE Mike DeWine, Governor Jon Husted, Lt. Governor Laurie A. Stevenson, Director October 8, 2020 TRANSMITTED ELECTRONICALLY Jason Quinn U.S. Army Corps of Engineers 7400 Bedell Road Berlin Center, Ohio 44401 Re: USACE Berlin Lake WWTP Notice of Violation (NOV) NOV NPDES Mahoning County 3PN00000 Subject: Notice of Violation Dear Mr. Quinn: On September 18, 2020, Ohio EPA, Division of Surf ace Water (DSW), conducted a compliance review of the U.S. Army Corps of Engineers, Berlin Lake Wastewater Treatment Plant (WWTP), located at 7400 Bedell Road, in Berlin Center, Ohio. The goal of the review was to determine your facility's compliance with Ohio's environmental laws and regulations as found in Chapter 6111 of the Ohio Revised Code (ORC), and the terms and conditions of the USACE Berlin Lake WWTP National Pollutant Discharge Elimination System (NPDES) permit No. 3PN00000*FD, effective on November 1, 2016. Violations Ohio EPA, DSW f ound the f ollowing violation of Ohio's environmental laws and regulations, and we recommend that you promptly address the violation. Please pay special attention to the Violation Description and Requested Action associated with each violation listed below as they describe what exactly is in violation and the requested action to address the violation. 1. ORC 6111.04(C): No person to whom a permit has been issued shall place or discharge, or cause to be placed or discharged, in any waters of the state any sewage, sludge, sludge materials, industrial waste, or other wastes in excess of the permissive discharges specified under an existing permit without f irst receiving a permit f rom the director to do so. NPDES Permit, Part I A: Final Outfall 001, Effluent Limits and Monitoring Requirements NPDES Part III 15: Authorized Discharges: All discharges authorized herein shall be consistent with the terms and conditions of this permit. The discharge of any pollutant identif ied in this permit more f requently than, or at a level in excess of , that authorized by this permit shall constitute a violation of the terms and conditions of this permit. (a) Violation Description: The facility has reported violations of the final effluent limit for Total Suspended Solids (TSS) in May and June of 2020. Northeast District Office 50 W. Town St. Suite 700 P.O. Box 1049 Columbus, OH 43216-1049 www.epa.ohio.gov (614) 644-3020 (614) 644-3184(fax) USACE BERLIN LAKE WWTP OCTOBER 8, 2020 PAGE 2 OF 2 (b) Additional Information: As a result of the final effluent limit violations cited above, the facility is in Significant NonCompliance (SNC) for exceeding the limit by more than 40% during two months out of the last 6-month time period. (c) Additional Information: In addition, the facility has reported effluent limit exceedances for TSS and CBOD on repeated occasions over the past five years, which has resulted in a repeated SNC status. (d) Requested Action: Please comply with the numeric effluent limits outlined in your NPDES permit. Conclusion Within 30 days of receipt of this letter, please provide documentation of the actions taken and/or will be taken to resolve the violations cited above. If circumstances delay resolution of violations, the U.S. Army Corps of Engineers shall submit written correspondence describing the steps that will be taken and dates when compliance will be achieved. The correspondence can include but is not limited to updated policies, procedures, and photographs, as appropriate, and should be submitted electronically me at Brianne.workman@epa.ohio.gov. Failure to comply with Chapter Applicable Chapter 6111 of the ORC and rules promulgated thereunder may result in an administrative or civil penalty. Please note that the submission of any requested information to respond to this letter does not constitute waiver of the Ohio EPA's authority to seek administrative or civil penalties as provided in Chapter 6111.09 of the ORC. As a precautionary response to COVID-19, Ohio EPA is currently operating with most staff working remotely. During this time, we will not be issuing hard-copy mail. The attached letter is an official response from Ohio EPA that will be maintained as a public record. Should you have any questions, please contact me at (330) 963-1179 and/or Brianne.Workman@epa.ohio.gov. Sincerely, Brianne Workman District Representative Division of Surface Water Northeast District Office BW/cs ec: Jessica Hall, USACE (Jessica.G.Hall@usace.army.mil) Waylon Reigle, USACE (Waylon.j.Reigle@usace.army.mil) Denise Harnishfeger, Operator of Record (d.harnishfeger@cityofhubbard.com) Scott Sheerin, Ohio EPA, DSW, CO Dean Stoll, Ohio EPA, DSW, NEDO Chris Moody, Ohio EPA, DSW, NEDO Joseph Trocchio, Ohio EPA, DSW, NEDO Jason.Quinn@usace.army.mil Appendix 7 Permit No. 3PN00000*FD 3PN00000*FD 3PN00000*FD 3PN00000*FD 3PN00000*FD 3PN00000*FD 3PN00000*FD 3PN00000*FD 3PN00000*FD 3PN00000*FD 3PN00000*FD 3PN00000*FD 3PN00000*FD 3PN00000*FD 3PN00000*FD 3PN00000*FD 3PN00000*FD 3PN00000*FD 3PN00000*FD 3PN00000*FD 3PN00000*FD 3PN00000*FD 3PN00000*FD 3PN00000*FD Reporting period August 2018 August 2018 August 2019 August 2019 August 2019 May 2019 June 2019 June 2019 June 2019 August 2018 June 2019 June 2019 June 2019 May 2018 May 2018 May 2018 May 2019 May 2019 May 2019 May 2019 May 2020 May 2020 May 2020 May 2020 Station 001 001 001 001 001 001 001 001 001 001 001 001 001 001 001 001 001 001 001 001 001 001 001 001 Reporting Code 80082 80082 80082 80082 80082 80082 50060 00610 00610 00530 00530 00530 00530 00530 00530 00530 00530 00530 00530 00530 00530 00530 00530 00530 Parameter CBOD 5 day CBOD 5 day CBOD 5 day CBOD 5 day CBOD 5 day CBOD 5 day Chlorine, Total Residual Nitrogen, Ammonia (NH3) Nitrogen, Ammonia (NH3) 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 Solids Total Suspended Solids Total Suspended Solids Total Suspended Solids Limit Type 30D Conc 7D Conc 30D Conc 7D Conc 7D Qty 7D Conc 1D Conc 30D Qty 7D Qty 7D Conc 30D Qty 7D Conc 7D Qty 30D Conc 7D Conc 7D Conc 30D Conc 7D Conc 7D Conc 7D Qty 30D Conc 7D Conc 7D Conc 7D Conc Limit 10.0 15.0 10.0 15.0 1.71 15.0 0.019 0.228 0.341 18.0 1.37 18.0 2.05 12.0 18.0 18.0 12.0 18.0 18.0 2.05 12.0 18.0 18.0 18.0 Reported Value mg/L 15.7 41. 11.54 37.2 1.83043 24.4 1. 1.05545 4.17334 19. 94.3345 25. 374.715 17.75 19. 40. 36.25 62. 71. 3.22482 28.75 54. 34. 25. Violation Date 8/1/2018 8/1/2018 8/1/2019 8/15/2019 8/15/2019 5/22/2019 6/3/2019 6/1/2019 6/1/2019 8/22/2018 6/1/2019 6/8/2019 6/1/2019 5/1/2018 5/8/2018 5/15/2018 5/1/2019 5/8/2019 5/15/2019 5/15/2019 5/1/2020 5/8/2020 5/15/2020 5/22/2020