Document GK71mbMYY3ZJ3D8mQ2E8OX5bn

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 5 77 WEST JACKSON BOULEVARD CHICAGO, ILLINOIS 60604 Purpose: Clean Water Act Compliance Inspection Inspection Type: National Pollutant Discharge Elimination System (NPDES) Facility: Columbus Grove Wastewater Treatment Plant (WWTP) 113 East Sycamore Street, Columbus Grove, Ohio 45830 NPDES Permit Number: OH0024759 Facility Type: Wastewater Treatment Facility Date of Inspection: July 27, 2022 EPA Inspector(s): 1. Jessica Stromsdorfer, stromsdorfer.jessica@epa.gov 2. Ben Atkinson, atkinson.ben@epa.gov Other Attendees: 1. Bob Huff, Operator, cgwater@q1.net Additional Facility Contacts: 1. Bob Michaels, cgwater@q1.net 2. Jeff Vance, Village Administrator, cgadmin@q1.net Digitally signed by JESSICA JESSICA STROMSDORFER STROMSDORFER EPA Lead Inspector Signature: ______________________Da_te_: 2_02_2._10_.0_4 1_1_:53_:5_2 _-05_'0_0'____ Approver Name & Title: Molly Smith, Supervisor, Section 1, Water Enforcement and Compliance Assurance Branch MOLLY SMITH Digitally signed by MOLLY SMITH Date: 2022.10.04 13:39:48 -05'00' Approver Signature: _______________________________________________ Facility Notification: Unannounced Inspection Announced Inspection Regulations Relevant to Inspection: NPDES permit requirements at 40 C.F.R. 122.26 Arrival Time: Departure Time: 9:15 AM 11:00 AM approximately OPENING CONFERENCE Presented Credentials Stated authority and purpose of inspection Provided Small Business Resource Information Sheet Small Business Resource Information Sheet not provided. Reason: Not a small business Provided CBI warning to facility The following information was obtained through review of the facility NPDES Permit, and verbally from Representatives of the Columbus Grove WWTP, unless otherwise noted. Discussion: Upon arrival, inspectors met the Facility representative, Bob Huff, in the laboratory building, who has been the Facility's operator since 2006. He shares duties with another operator, named Bob Michaels. Mr. Huff and the inspectors discussed the background of the Facility. The Facility is the wastewater treatment plant for the town of Columbus Grove, Ohio. According to Mr. Huff, the town has about 2,150 residents. The plant influent consists mostly of domestic sewage and one industrial user connection. The system had previously struggled with sanitary and combined sewer overflows, but not since it separated its sewers about five years ago. Mr. Huff estimated that the plant receives about 250,000 gallons per day of influent. The treatment process includes grit removal, primary clarifiers, rock filter tanks, a final clarifier, and chlorine contact tanks. Mr. Huff explained that he takes the internal samples at the grit room and the final samples at the effluent location after the chlorine treatment. There is one outfall to Plum Creek, a 303(d) listed impaired waterway. According to Discharge Monitoring Reports (DMRs), the Facility has had effluent limit exceedances for ammonia, mercury, e. Coli, oil and grease, pH, and chlorine within the past three years. There also have been DMRs with missing parameter values during that timeframe. Mr. Huff explains that mercury has been an ongoing issue at the Facility and they have been unable to track down the source. According to the permit, the Facility is required to implement a pollutant minimization program (PMP) for mercury, which includes elements such as: Effluent limit compliance 2  Contact with local sources Providing public educational materials Submitting a PMP progress report When asked about the implementation of this program, Mr. Huff explained that he would need to check administrative records for any information regarding the PMP. In addition to mercury, the Facility has had historical issues with other effluent violations resulting in a Schedule of Compliance to be included in their 2018 NPDES permit. The NPDES permit schedule requires the Facility to complete: A. Evaluation for Reducing Discharges of Phosphorus; B. E. Coli Schedule; C. Long-Term Control Plan (LTCP) Post-Construction Compliance Monitoring; and D. LTCP Plan Completion Evaluation Report. According to online documentation with the Ohio EPA, the Facility has failed to complete items C and D of the NPDES permit schedule. When asked to provide documentation for completion of items A and B, Mr. Huff explained that he would need to check the administrative office for any records. The inspection team proceeded with a tour of the Facility. FACILITY WALKTHROUGH Observations: The inspection team first looked at the laboratory. Mr. Huff explained that the Facility does onsite sampling for pH, DO, temperature, and flow, but has an outside laboratory, Alloway, analyze other permitted parameters. Mr. Huff takes samples from an internal monitoring location and reuses containers to collect effluent for sampling (photo 3). The operator calibrates DO and pH samplers daily (photo 1), but inspectors observed that the pH buffer and storage solution were both expired. Additionally, the Facility was using distilled water, rather than deionized water. Inspectors then viewed the treatment equipment. Inspectors first viewed areas including the influent pump area, influent chamber, grit removal area, sludge pumps, and sludge drying beds (photos 4-11). Mr. Huff noted that grit and sludge are sent to a landfill. Next, the inspection team viewed the primary clarifiers. One of the clarifiers was out of order and the other had a thick film on the water (photo 12). According to Mr. Huff, both clarifiers run during normal operation. From the primary clarifiers, water is pumped to the roughing filters (photos 15, 16). Water enters either filter through the filter tank diverter, which inspectors observed had weeds growing inside of it (photo 14). Finally, water is sent through a final clarifier (phot0 21) then to a chlorine contact tank for disinfection (photos 17, 18). Inspectors observed algae and weeds growing in the first three cells. 3 After the final treatment step of disinfection, flow is measured at a weir (photo 19) and the operator collects samples from outfall 602 (photos 22, 23). The samples are all collected as grab samples. The effluent discharges west of the site into Plum creek. The outfall sign was visible but mostly obstructed by foliage (photos 27,28). Photos and/or Videos: were taken during the inspection. Included as Attachment A Field Measurements: were not taken during this inspection. CLOSING CONFERENCE Provided U.S. EPA point of contact to the facility Confirm CBI status at end of closing conference Requested documents: Most recent mercury PMP report NPDES Permit, Part I, C documents: o Phosphorus evaluation o E. Coli schedule status report o Long term control plan post construction compliance monitoring plan o Long term control plan completion evaluation report Any Sanitary Sewer Overflow (SSO) reports or notifications Last 3 months of DMRs Last 3 months of Alloway's lab reports Copy of NPDES permit Mr. Huff was unable to find records of the Mercury PMP report, NPDES Permit Part I, C documents, or SSO reports and notifications. Areas of Concern: Area of Concern Effluent Quality Sampling Procedures Reporting & Submissions Operation and Maintenance Other Finding NPDES Permit effluent limit exceedances All samples taken as grab samples; no composite samples taken All samples taken with reusable containers, instead of fresh containers Calibration using expired buffer solution and distilled water instead of deionized water Failure to submit full DMRs in June and May 2022 Missing reports required by NPDES permit (mercury PMP report; NPDES Permit Part I, C documents; SSO annual report) Weeds growing in chlorine tank and filter diverter Primary clarifier out of operation Obstructed outfall signage 4 APPENDICES AND ATTACHMENTS ATTACHMENT A: COLUMBUS GROVE WWTP PHOTO LOG 5