Document M5B751o1d8EE3eMEorxN054z
EPA REGION 5 Enforcement and Compliance Assurance Division INSPECTION REPORT
Inspection Entry Date/Time Inspection Exit Date/Time Weather Media Statute(s)/Program(s) Type of Inspection
07/25/2023 08:00 AM (ET)
Announced: Yes
07/26/2023 08:45 AM (ET)
Access: Granted
Day 1 - Sunny, warm (day of physical inspection)
Water
Clean Water Act, NPDES, WWTP
Compliance Evaluation Inspection (CEI)
Permittee Name Facility or Site Name Facility/Site Physical Address City, State, Zip Code County/Borough/Parish Facility GPS Coordinates Mailing Address (If different) City, State, Zip Code
City of Marietta Marietta Wastewater Treatment Works 440 East Eighth Street Marietta, OH 45750 Washington County 39.40896, -81.43308
FRS ID
110039783552
Permit Number(s) (If Applicable) OH0026344
SIC and/or NAICS
4952
Regulatory Representatives Participating in Inspection:
Title
Name
Chemist
Ken Gunter
Organization U.S. EPA
Lead Inspector: Dean Maraldo
Supervisor Review: Ryan Bahr
[Signature]
DINO MARALDO
Digitally signed by DINO MARALDO Date: 2023.08.11 08:23:13 -05'00'
U.S. EPA REGION 5
Maraldo.Dean@epa.gov
(312) 353-2098
[Signature]
Digitally signed by RYAN
RYAN BAHR Date: 2023.08.11 BAHR
10:52:38 -05'00'
EPA REGION 5
bahr.ryan@epa.gov
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Marietta Wastewater Treatment Works Inspection Date(s):
07/25/2023 - 07/26/2023
SECTION I - INTRODUCTION
Site Entry and Inspection Objectives
I, U.S. EPA REGION 5 Lead Inspector, Dean Maraldo, arrived at the Marietta Wastewater Treatment Works ("Facility" or "Marietta WWTP"), located at 440 East Eighth Street, Marietta, OH 45750, at 08:00 AM (ET) on 07/25/2023 for an announced inspection. I met Steve Elliott (Wastewater Superintendent) and Ryan Boley (Operations Manager) upon entry and presented my inspector credentials to Steve Elliott and informed them that this was a U.S. EPA REGION 5 inspection to determine compliance as authorized by Clean Water Act (CWA) Section 308 and implementing regulations. U.S. EPA chemist Ken Gunter joined me on the inspection. This report is based on information supplied by Facility representatives, my direct observations, records and reports maintained by the permittee and other information including: photographs taken during the inspection, physical evidence collected, verbal or written statements made by information supplied by Facility representatives during or subsequent to the on-site Inspection, and materials, processes, data, photographs, or documents shown, demonstrated, or submitted to me by Facility representatives during or subsequent to the on-site Inspection. In addition, information gathered prior to or subsequent to the Inspection from a review of U.S. EPA, State, and/or public records may be included in this report.
Attendees Organization
U.S. EPA Region 5 U.S. EPA Region 5 City of Marietta City of Marietta
City of Marietta
Attendee Name
Dean Maraldo Ken Gunter Craig Johnson Ryan Boley
Steve Elliott
Title
Lead Inspector Chemist Operator Wastewater Operations Manager Superintendent
Present in Opening Conf. Yes Yes No Yes
Yes
Present in Closing Conf. Yes Yes No Yes
Yes
Facility/Site Description I began by reviewing the Facility description provided in the permit (excerpt below) and the Facility representatives either confirmed or corrected (in bold below) the information as described below. Unless noted otherwise, Facility responses were provided by Mr. Elliott.
Permit Fact Sheet Facility Description:
The City of Marietta WWTP was constructed in 1955 and is currently in the process of upgrading their facility, with construction scheduled to be complete July 31, 2019. Upgrades now complete.
The average design flow is 4.0 million gallons per day (MGD) and a peak hydraulic capacity of 9.0 MGD. Once construction is complete and two new, larger clarifiers are in operation, peak hydraulic capacity will be 11.0 MGD. Current peak is 11.4 MGD.
The City of Marietta WWTP serves the City of Marietta, Washington County subdivisions, and the Reno Water and Sewer District, a population of approximately 15,000.
The Marietta WWTP has the following treatment processes
Influent Pumping Bar Screen (course BS and wet well then perf plate fine screen) Grit Removal
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Marietta Wastewater Treatment Works Inspection Date(s):
07/25/2023 - 07/26/2023
Scum Removal Primary Sedimentation Pre-Aeration Activated Sludge Stabilization Secondary Clarification Ultraviolet Disinfection
Marietta WWTP has one (1) bypass at the head of the plant. During high flow events, flows are diverted to the 2.6 MG flow equalization basin, to be redirected back to the WWTP when flows subside. When the basin is full, excess flows are discharged directly to the Ohio River via a relief sewer, which will henceforth be monitored as Station 002.
The Marietta WWTP does have an approved pretreatment program. The Marietta WWTP has one (1) categorical users (Thermo Fischer Scientific) that discharge 0.05 MGD of flow; The Marietta WWTP has two (2) significant non-categorical users that discharge 0.197 MGD of flow; there are 8 non-significant industrial users.
The Marietta WWTP utilizes the following sewage sludge treatment processes:
Aerobic Digestion - Air Mechanical Dewatering - Centrifuge Gravity Thickening (no longer used) Polymer, Lime, Ferric-chloride Alum Addition (no longer use lime or ferric. Only use polymer) Landfill Treated sludge is disposed of in a municipal landfill or transferred to another NPDES permit holder (currently only to landfill)
Facility/Site Information
Next, I asked some background questions. Unless noted otherwise, Mr. Elliott provided the responses in the table below.
Background Question How do you manage your biosolids? Are there any plans for renovation or additional equipment to allow for increased wastewater flow?
Is there currently any portion of the treatment train that is non-operational? Do you accept waste from septage haulers? If so, what problems have you experienced? Do you use in-house or contract out for laboratory analyses? (including metals or WET testing)
Operation schedule (days of operation, # shifts/day, # operators/shift, coverage overnight, weekends & emergencies) Outfalls: (and do the numbers, locations, and receiving
Facility Response Dewater and landfill, do not fully digest Collection system work in Colegate area due to Sanitary Sewer Overflows ("SSOs"). (CT Consultants). Duck Creek sewershed SSO (Hazen and Sawyer is the firm), flow monitoring/lining No
Yes, and other NPDES facilities. No problems
Use two labs Alloway (metals, biochemical oxygen demand ("BOD"), ammonia), Microbac (bacteria); Enviroscience (toxicity). In house total suspended solids ("TSS"), pH, dissolved oxygen ("DO") 24 hour, 7 days; 1 operator 24/7; M-F one operator for pretreatment; 12-hour shifts
001; 002 (influent bypass wet weather)
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Marietta Wastewater Treatment Works Inspection Date(s):
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waters match the permit?) Contributing (or shared) Jurisdictions
WWTP Approx. # of residents served WWTP Design Capacity & Average Daily Flow
Responsible official CBI concerns?
Inspection Focus Areas and Locations
Inspection Area Interview Self Monitoring Operations and Maintenance Flow Monitoring CSO/SSO Review of Effluent Limit Exceedances Pretreatment Permit Compliance Schedule Review Bypasses Laboratory Review Physical Inspection
Description
Yes, Washington County; Reno Water and Sewer Association (mainly residential); Shawnee/Devola Subdivision 6,000 connections ~2.3 MGD, 4.0 MGD design; 11.4 MGD wet weather flow Ryan Boley submits DMRs No
Facility Office
Facility Laboratory Facility Wastewater Treatment Works
SECTION II - OBSERVATIONS
Location: Interview/Self Monitoring Observation #: DM1-OB-001
Date: 07/25/2023
Facility responses regarding Self Monitoring were provided by Ryan Boley, unless noted otherwise. I began by confirming that the influent and effluent samples are collected at locations specified in the permit and representative of the waste stream. Effluent composite samples are collected as flow proportioned (flow meter) composite samples after UV, and grab samples are collected after UV with a dipper. Ken Gunter asked if they also monitor E.coli before UV. Mr. Boley said they have in the past to investigate UV issues, but no longer. Influent samples are collected prior to the bar screen, and composite samples are collected from a flow proportioned composite sampler. Influent grab samples collected at the same location. Composites are collected three times per week (T, W, Th) along with bacteria grab samples. Monthly samples are collected the first Monday or Tuesday of the month.
Composite samples are cooled to <4C to properly preserve them during the compositing period and results are recorded in a log. A refrigerator is used for preserving composite samples and temperature is monitored with a thermometer which is changed out at least annually.
Operators use a dipper for bacteria sampling, collected in a pre-preserved sterile bottle. Samples are refrigerated, and then packed in ice for transport to the contract lab (Microbac). Samples normally collected
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Marietta Wastewater Treatment Works Inspection Date(s):
around 8 AM and to lab by noon.
07/25/2023 - 07/26/2023
Location: Interview/Operations and Maintenance
Observation #: DM1-OB-002
Date: 07/25/2023
Facility responses regarding Operations and Maintenance ("O&M") were provided by Steve Elliott, unless noted otherwise. I started by asking if all treatment units are currently operable. Mr. Elliott said they were operable.
I asked for a description of the organizational structure of the Facility. Mr. Elliott said that he reports to Director of Public Safety and Service. Other staff include Ryan Boley (Operations Manager), the technical administrative coordinator (Mike Miser), maintenance manager (plant and lift stations); plant operators (five, includes pretreatment operator); electrical instrumentation technician; and maintenance and general utility mechanics. The collection system staff includes two equipment operators, and wastewater service technicians (four). Total number of staff is 16. Three operators have class 1 certification, one operator has class 2 certification, and another operator is working towards initial certification.
The Facility maintains an O&M record system, including:
As-built drawings Maintenance history (electronic system "Antero AllMax" program) Repair history (Antero AllMax program) Paper and electronic instruction files for O&M of each item of major equipment O&M manual is available in Paper and electronic form.
I requested copies of chapters 2, 5, 9, 12, 13, 14 of the O&M manual, relating to plant operations, disinfection, and lab procedures.
I asked if the Facility experiences any sludge wasting issues. Mr. Elliott said they do not.
Mr. Boley described routine process monitoring, including daily 30-minute settleometer testing, along with routine testing for alkalinity, ammonia, nitrates nitrites; and daily primary sludge and waste activated sludge testing; temperature, dissolved oxygen and pH monitoring.
I asked about treatment bypasses. Mr. Boley said river levels of 28.3 feet or higher can trigger a bypass at Outfall 002. At 32.9 feet they must activate the high river pump station to force discharge to the river. Mr. Elliott added that the high river pump station was installed around 2019 and only used a few times. In February 2022 the high river pump station failed, resulting in flooding of the UV system and bacteria violations.
I asked about alarm systems for essential equipment. Mr. Boley said they have a SCADA system, and alarms are triggered by pump faults, amperages, gates/valve faults, high flow at the bar screen, the internal bypass (at 8 MGD sustained for a couple minutes, which may have happened overnight according to Mr. Elliott), and UV faults. Outfall 002 also has flow alarms (SCADA shows how much flow and the number of occurrences).
Routine and preventive maintenance schedules are provided by a computer program (Antero AllMax), which creates weekly work orders. Operators also maintain a written logbook which documents all plant activities daily.
I asked if the Facility maintains an inventory of spare parts, either at the Facility or close by, sufficient to keep all treatment units operational. Mr. Boley said they have a spreadsheet inventory of spare parts. Mr. Elliott added that this is something that will go into the computer program eventually.
For standby power, there are two generators at plant (each dedicated to certain portions of plant), and two
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Marietta Wastewater Treatment Works Inspection Date(s):
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large portable generators for lift stations. One lift station has permanent backup power (Harmar Pump Station largest station). All generators are test run weekly, per work orders. Lately, power loss is not an issue according to Mr. Elliott.
Location: Interview/Flow Monitoring Observation #: DM1-OB-003
Date: 07/25/2023
Influent and effluent flow measuring devices are professionally calibrated, at least annually, accruing to Mr. Elliott.
Mr. Boley provided a list of all flow meters at the Facility, including the mag meters used to measure influent and effluent flow (See Appendix 2 - Document Log). Mr. Elliott added that effluent flow is measured over a parshall flume and flow measuring devices are calibrated annually.
Location: Interview/CSO/SSO
Observation #: DM1-OB-004
Date: 07/25/2023
I began with a question about combined sewers. I asked if any portion of the Facility's sewage collection system is combined with the storm water collection system. Mr. Elliott said he was not aware of any combined sewers.
I then turned to sanitary sewer overflows and asked if they experienced any backups or overflows in the sanitary sewer collection system, including pump stations, manholes and piping, over last year. The Facility experienced three SSOs in January 2023, with flows to receiving waters (two to a tributary to the Muskingum River, and one directly to the Muskingum River). No SSOs since the January 2023 events. Mr. Elliott provided copies of a list of SSO locations, SSO reports, and annual reports since 2020, per my request. (See Appendix 2 - Document Log).
The sanitary sewer collection system includes 89 miles of sanitary conveyance and 13 lift stations.
I asked if there was a sewer/basement backup complaint log. Mr. Elliott said there was and that there is not a significant basement backup problem in the system. Mr. Boley recalled only one basement backup complaint on South Street due to high flow and plant failure.
I asked if there were any lift stations with chronic SSOs/basement backups. Mr. Boley said there were not, but the Duck Creek lift station pump sometimes clogs, but does not result in overflows.
I concluded the SSO discussion with a question about pending improvement projects in collection system.
Mr. Boley mentioned potential projects in the Duck Creek sewershed, including slip lining main lines (first phase), followed by a possible flow study to make sure lining worked and to develop better design criteria for Duck Creek lift station renovation project. Mr. Elliott added that they are working on funding for lining now, and the rest is "to be determined". I received a copy of the work plan for the Duck Creek sewershed (See Appendix 2 - Document Log).
Mr. Boley then described planned sewer improvements in the Colegate Drive area, including inflow and infiltration improvements, flow monitoring, and smoke testing. He said that there is more inflow than infiltration in this area and the remedy is to be determined. I received a copy of the scope of services for planned sewer work in the Colegate Drive area (See Appendix 2 - Document Log). The city expects to receive further recommendations for work in this area from its consultant (CT consultants) in August 2023.
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Marietta Wastewater Treatment Works Inspection Date(s):
07/25/2023 - 07/26/2023
Location: Interview/Review of Effluent Limit Exceedances
Observation #: DM1-OB-005
Date: 07/25/2023
I reviewed the list of permit effluent limit exceedances with the Facility representatives. (See Appendix 2 - Document Log, for summary of effluent limit exceedances). The causes of recent exceedances are described below.
E.coli effluent limit exceedance during last week of July 2023, (See Appendix 2 - Document Log, for copy of the notice to OEPA). Cause unknown.
TSS effluent limit exceedances February 2022: Mr. Boley said the exceedances likely occurred due to a flood affecting the UV treatment system.
E.coli effluent limit exceedances from February 20, 2022 to May 2022 - due to lack of UV treatment, resulting from February 2022 flooding event.
December 2022 E.coli effluent limit exceedances likely due to issue with contract lab, according to Mr. Boley.
E.coli violations in January, March, April, May, and July 2023 due to UV system failures according to Mr. Boley. Bulbs not working at times with frequent major and minor system errors and alarms.
Mr. Boley added that since December 2022 the lab issues are resolved and attributed recent bacteria effluent limit exceedances to UV system issues. Mr. Boley also mentioned that Ohio EPA's compliance assistance staff visited in December 2022 and concluded that bacteria effluent limit exceedances are likely due to UV system "manufacturers issues".
The city is trying to get the UV system vendor (Enaqua) to evaluate and fix the UV system.
Location: Interview/Pretreatment Observation #: DM1-OB-006
Date: 07/25/2023
I conducted a brief interview regarding the city's pretreatment program. The inspection did not include a pretreatment audit.
The city has an approved POTW pretreatment program. The Facility pretreatment operator, Craig Johnson, provided the responses below, unless noted otherwise.
The number of POTW industrial users subject to pretreatment standards? 11.
Are all industries aware of their responsibility to comply with applicable standards? Yes, all in compliance.
Are all categorical industries submitting the required semiannual report? Yes.
Has the POTW submitted an annual pretreatment report? Yes (See Appendix 2 - Document Log).
Has the POTW taken enforcement actions against noncomplying industrial users? Yes, some notices of violation and fines. Mr. Johnson showed a recent example from Marietta Memorial Hospital, with an associated fine (May 2023). I asked if they ever issued a pretreatment order. Mr. Boley said they had not.
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Marietta Wastewater Treatment Works Inspection Date(s):
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The city conducts annual inspections for significant industrial users, all other industrial users ("IUs") are inspected every three years.
No recent incidents involving IUs causing pass through or interference.
Location: Interview/Records Review and Compliance Schedules
Observation #: DM1-OB-007
Date: 07/25/2023
We reviewed compliance schedules under the permit (pages 14-17). Responses were provided by Steven Elliott:
1. Pretreatment compliance schedule: all done, in compliance. 2. Bypass monitoring: all done, in compliance. 3. High Flow Treatment Optimization: could not complete, due to lack of high wet weather flows related to
river flow. Provided copies of related documents (See Appendix 2 - Document Log).
All noncompliance which may endanger health or the environment, including all violations of daily limits, were orally reported within 24 hours and followed up with a letter to Ohio EPA within 5 days.
Location: Interview/Bypasses Observation #: DM1-OB-008
Date: 07/25/2023
Mr. Boley explained that full treatment bypasses occur at Outfall 002, a collection system hydraulic relief bypass prior to entry into the plant. Bypasses occur when the Ohio and Muskingum River are up (~28.3 feet) and any flows unable to reach the plant due to capacity (including full EQ basin) are routed to Outfall 002 to the Ohio River. Outfall 002 data is included in Discharge Monitoring Reports ("DMRs") (gallons, duration, and occurances). See Appendix 2 - Document Log, for latest example of DMR documenting bypass from Outfall 002 on January 3, 2023).
Mr. Boley also described an internal partial treatment bypass (also referred to by Facility staff as "internal hydraulic relief") in the wastewater treatment train, occuring when plant flows reach 8 MGD. The partial bypass directs flow around primary treatment (grit removal, pre-aeration, primary settling tanks, and the biological and anoxic selector system), directly to activated sludge, secondary clarification, and UV disinfection.
I requested a list of internal bypass events since January 1, 2023. Since the internal bypasses are not included in DMRs the Facility did not have a list of recorded bypass events. However, Mr. Johnson provided copies of flow charts, annotated with flow peaks, including dates and times, representing internal bypass events (when flows > 8MGD) from January 1, 2023 to July 25, 2023. The annotated charts document 25 internal bypass events since January 1, 2023 (See Appendix 2 - Document Log).
Location: Physical Inspection
Observation #: DM1-OB-009
Date: 07/25/2023
Weather: warm and sunny
The physical inspection of the Facility began at 2:05 PM ET, at the on-site laboratory. Craig Johnson led the lab tour along with Ryan Boley.
pH area: Ken Gunter noted that the pH calibration process did not including bracketing of the permit compliance range, and recommended calibrations including pH buffers 4 thru 10. Mr. Gunter also recommended pH bench sheets include the ID number for the specific pH probe in use.
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Marietta Wastewater Treatment Works Inspection Date(s):
07/25/2023 - 07/26/2023
TSS area: Ken Gunter recommend documenting weight to constant weight measurements.
The physical inspection of the Facility wastewater treatment system began at 2:45 PM ET, led by Mr. Boley. Observations are noted in the Photo Log (Appendix 1). We concluded the physical inspection at 3:45 PM ET on 7/25/23 and agreed to return the next morning (7/26/23) at 7:30 AM ET to conclude the inspection with a closing conference.
Photo(s) 1. MRTA0255.JPG 2. MRTA0259.JPG 3. MRTA0260.JPG 4. MRTA0261.JPG 5. MRTA0252.JPG 6. MRTA0253.JPG 7. MRTA0254.JPG 8. MRTA0256.JPG 9. MRTA0257.JPG
10. MRTA0258.JPG 11. MRTA0263.JPG 12. MRTA0262.JPG 13. MRTA0264.JPG 14. MRTA0265.JPG 15. MRTA0266.JPG 16. MRTA0267.JPG
SECTION III - RECORDS REVIEW Records may not be in sequential order. Record: Laboratory Analysis Reports Ref #: DM1-RR-001 Reviewed By: Dean Maraldo and Ken Gunter
AOC: Yes Reviewed Date: 07/25/2023
Ken Gunter and I reviewed recent laboratory chains of custody ("COCs") and bench sheets. Mr. Gunter noted the following issues:
COC inconsistencies (lack of signatures, location of transfer).
In House TSS: SOP includes calibration of balance, but no mention of certification or certain class standards, and lacks reweighing standard methods. Bench sheet for TSS lacks re-weight and confirmation that oven maintained 103-105 degree temp, or the length of time the sample is in oven.
pH SOP: should include verification of buffer standard expiration. Bench sheet should also include collection time, analysis time, and who performed test (same issue for dissolved oxygen bench sheet). Buffers should bracket compliance range, for example 4, 10 pH buffers would bracket the Facility's pH permit compliance range.
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Marietta Wastewater Treatment Works Inspection Date(s):
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SECTION IV - SAMPLING ACTIVITIES AND ANALYTICAL RESULTS No sampling was conducted.
SECTION V - AREAS OF CONCERN
Areas of Concern may not be in sequential order. The presentation of Areas of Concern does not constitute a formal compliance determination or violation.
AOC Reference #: DM1-OB-004
Location: Interview/SSOs
Regulation and/or Permit Requirement
Permit Part I, B.2.c: all sanitary sewer overflows are prohibited.
AOC:
The Facility experienced three SSOs in January 2023, with flows to receiving waters (two to a tributary to the Muskingum River, and one directly to the Muskingum River).
Additional Notes: Facility reported 58 SSO occurrences (Outfall 300) in DMRs from January 1, 2019 to June 30, 2023.
AOC Reference #: DM1-OB-005
Location: Interview/Review of Effluent Limit Exceedances
Regulation and/or Permit Requirement
Permit Part I.A.1: final effluent limitations and monitoring requirements.
AOC:
Permit effluent limit exceedances. The causes of recent exceedances are described below.
E.coli effluent limit exceedance during last week of July 2023, (See Appendix 2 - Document Log, for copy of notice to OEPA). Cause unknown.
TSS effluent limit exceedances February 2022: Mr. Boley said the exceedances likely occurred due to a flood effecting the UV treatment system.
E.coli effluent limit exceedances from February 20, 2022 to May 2022 - due to lack of UV treatment, resulting from flooding event.
December 2022 E.coli effluent limit exceedances likely due to issues with contract lab, according to Mr. Boley.
E.coli violations in January, March, April, May, and July 2023 due to UV system failures according to Mr. Boley. Bulbs were not working at times with frequent major and minor system errors and alarms.
AOC Reference #: DM1-OB-007
Location: Interview/Records Review and Compliance Schedules
Regulation and/or Permit Requirement
Permit Part I.C.C: compliance schedule for high flow treatment optimization.
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Marietta Wastewater Treatment Works Inspection Date(s):
07/25/2023 - 07/26/2023
AOC:
High Flow Treatment Optimization requirement not complete pursuant to permit compliance schedule, due to lack of high wet weather flows related to river flow.
AOC Reference #: DM1-OB-008
Location: Interview/Bypasses
Regulation and/or Permit Requirement
Permit Part III.11: Unauthorized bypasses
AOC:
Bypasses occur when the Ohio and Muskingum River are up (~28.3 feet) and any flows unable to reach the plant due to capacity (including full EQ basin) are routed to Outfall 002 to the Ohio River. Outfall 002 data is included in Discharge Monitoring Reports ("DMRs") (gallons, duration, and occurances). See Appendix 2 - Document Log, for latest example of DMR documenting bypass from Outfall 002 on January 3, 2023).
Mr. Boley also described an internal partial treatment bypass (also referred to by Facility staff as "internal hydraulic relief") in the wastewater treatment train, occuring when flows reach 8 MGD. The partial bypass directs flow around primary treatment (grit removal, pre-aeration, primary settling tanks, and the biological and anoxic selector system), directly to activated sludge, secondary clarification, and UV disinfection.
Mr. Johnson provided copies of flow charts annotated with flow peaks, including dates and times, representing internal bypass events (when flows > 8MGD) from January 1, 2023 to July 25, 2023. The annotated charts document 25 internal bypass events since January 1, 2023.
AOC Reference #: DM1-OB-009
Location: Physical Inspection/Laboratory
Regulation and/or Permit Requirement
Permit Part III.5 - Sampling and Analytical Method; and 40 CFR 136: Test Procedures for the Analysis of Pollutants
AOC:
pH area: Ken Gunter noted that pH calibration process did not including bracketing of the permit compliance range, and recommended calibration including pH buffers 4 thru 10. Mr. Gunter also recommended pH bench sheets include the ID number for the specific pH probe in use.
TSS area: Ken Gunter recommend documenting weight to constant weight measurements.
AOC Reference #: DM1-OB-009
Location: Physical Inspection/Effluent Autosampler
Regulation and/or Permit Requirement
Permit Part III.3.A - Facility Operation and Quality Control. At all times, the permittee shall maintain in good working order and operate as efficiently as possible all treatment or control facilities or systems installed or used by the permittee necessary to achieve compliance with the terms and conditions of this permit. Proper operation and maintenance also includes adequate laboratory controls and appropriate quality assurance procedures.
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Marietta Wastewater Treatment Works Inspection Date(s):
07/25/2023 - 07/26/2023
AOC:
Observed growth inside the effluent autosampler tubing (see Photo Log image MRTA0264.JPG). Tubing normally replaced twice per year.
AOC Reference #: DM1-OB-009
Location: Physical Inspection/Effluent Flume
Regulation and/or Permit Requirement
Permit Part III.5 - Sampling and Analytical Method. Samples and measurements taken as required herein shall be representative of the volume and nature of the monitored flow.
AOC:
Observed flow sensor off center of flume (see Photo Log image MRTA0265.JPG). Ryan Boley said the off-center sensor placement was due to turbulence in the center of flume.
AOC Reference #: DM1-OB-009
Location: Physical Inspection/Outfall 002
Regulation and/or Permit Requirement
Permit Part II.V - Outfall signage. The permittee shall maintain a permanent sign on the Ohio River at each outfall that is regulated under this NPDES permit. This includes final outfalls and bypasses. The sign shall include, at a minimum, the name of the establishment to which the permit was issued, the Ohio EPA permit number, and the outfall number and a contact telephone number.
AOC:
Outfall 002 to the Ohio River could not be observed due to heavy vegetation (see Photo Log image MRTA0267.JPG, capturing location of Outfall 002, obscured by riverbank vegetation, and the outfall manhole). No outfall sign was observed for Outfall 002.
SECTION VI - CLOSING CONFERENCE AND FOLLOW UP
Closing Conference
I held a closing conference for the inspection with Facility personnel at 07:45 AM (ET) on 07/26/2023. During the closing conference, I discussed the observations and preliminary Areas of Concern identified during the inspection. Observations and Areas of Concern have not yet been evaluated for a formal compliance determination.
Steve Elliott asked if labs are allowed to average dilution water for BOD. Ken Gunter said he would look into it and get back to him. Steve Elliott asked about next steps. I reviewed U.S. EPA's general enforcement process and provided an estimated timeframe for completion of the inspection report. We concluded the closing conference and the inspection at 8:45 AM ET on 07/26/2023 and departed the Facility.
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Marietta Wastewater Treatment Works Inspection Date(s):
07/25/2023 - 07/26/2023
Communication Log
Type
Email
From
Steve Elliott
To
Dean Maraldo
Email Email Email Email
Ryan Boley
Dean Maraldo
Dean Maraldo Ken Gunter
Steve Elliott
Ryan Boley
Steve Elliott and Ryan Boley Ken Gunter
Date
Description
7/26/2023 transmitting attachment
7/27/2023
7/27/2023 8/2/2023
Request for copies of documents received (high flow optimization) Request for copies of documents received Transmitting lab Procedures
8/3/2023
Acknowledgement of email above, and update on lab procedures
Attachment(s)
Notice of Exceedance of Daily Max Discharge Limit to OEPA (1/25/2019) NA
Copies of high flow optimization records Copy of Standard Method 5210B and Standard Method 4500 HB NA
SECTION VII - LIST OF APPENDICES 1. Photo Log 2. Document Log
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Marietta Wastewater Treatment Works Inspection Date(s):
APPENDIX 1: PHOTO LOG
07/25/2023 - 07/26/2023
Influent pump station
07/25/2023 02:48 PM
No CBI
Physical Inspection
Bar screens cleaned weekly.
No PII
MRTA0252.JPG Photographer: Dean Maraldo 39.40851, -81.43356666
Grit removal
07/25/2023 02:51 PM
No CBI
Physical Inspection
Grit dewatering system (Vortex).
No PII
MRTA0253.JPG Photographer: Dean Maraldo 39.40873833, -81.433145
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Marietta Wastewater Treatment Works Inspection Date(s):
07/25/2023 - 07/26/2023
Grit collector 07/25/2023 02:52 PM Physical Inspection
No CBI
No PII
MRTA0254.JPG Photographer: Dean Maraldo 39.40874499, -81.43314666
Influent sampler
07/25/2023 02:54 PM
No CBI
Physical Inspection
Manufacturer: Manning Env. Inc.
No PII
MRTA0255.JPG Photographer: Dean Maraldo 39.40862, -81.43329666
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Marietta Wastewater Treatment Works Inspection Date(s):
07/25/2023 - 07/26/2023
Fine screen 07/25/2023 02:57 PM Physical Inspection
No CBI
No PII
MRTA0256.JPG Photographer: Dean Maraldo 39.40844166, -81.43280166
Primary settling tanks (3)
MRTA0257.JPG
07/25/2023 03:00 PM
No CBI
No PII Photographer: Dean Maraldo
Physical Inspection
39.40856666, -81.43308333
One tank out of service due to low flows. 2' sludge measured in primary, about 2' preferred, 3' max.
16 of 22
Marietta Wastewater Treatment Works Inspection Date(s):
07/25/2023 - 07/26/2023
Biological anoxic selector
MRTA0258.JPG
07/25/2023 03:08 PM
No CBI
No PII Photographer: Dean Maraldo
Physical Inspection
Geographic Coordinates NA
Biological anoxic selector stirs wastewater prior to secondary.
Activated sludge aeration tanks (3)
07/25/2023 03:12 PM
No CBI
Physical Inspection
One tank out of service due to low flows.
No PII
MRTA0259.JPG Photographer: Dean Maraldo 39.40941166, -81.43398833
17 of 22
Marietta Wastewater Treatment Works Inspection Date(s):
07/25/2023 - 07/26/2023
Final clarifiers (2)
MRTA0260.JPG
07/25/2023 03:16 PM
No CBI
No PII Photographer: Dean Maraldo
Physical Inspection
39.40942166, -81.43535166
Installed in 2019. No significant growth or O&M issues observed.
EQ basin
07/25/2023 03:19 PM
No CBI
Physical Inspection
2.6 MGD capacity. Used infrequently.
No PII
MRTA0261.JPG Photographer: Dean Maraldo 39.40938333, -81.43574166
18 of 22
Marietta Wastewater Treatment Works Inspection Date(s):
07/25/2023 - 07/26/2023
UV system
MRTA0262.JPG
07/25/2023 03:23 PM
No CBI
No PII Photographer: Dean Maraldo
Physical Inspection
39.40943833, -81.43491166
2 channel system. One channel offline due to low flows. Photo of UV-2.
Effluent sampler
MRTA0263.JPG
07/25/2023 03:26 PM
No CBI
No PII Photographer: Dean Maraldo
Physical Inspection
39.409815, -81.434935
Manufacturer: Manning Env., Inc. Noted thermometer to measure cooler temps.
19 of 22
Marietta Wastewater Treatment Works Inspection Date(s):
07/25/2023 - 07/26/2023
Effluent sampler tubing
MRTA0264.JPG
07/25/2023 03:26 PM
No CBI
No PII Photographer: Dean Maraldo
Physical Inspection
39.409815, -81.434935
Observed growth inside effluent tubing. Tubing replaced twice per year.
Effluent Parshall flume
MRTA0265.JPG
07/25/2023 03:31 PM
No CBI
No PII Photographer: Dean Maraldo
Physical Inspection
39.409815, -81.434935
Observed flow sensor off center of flume. Ryan Boley said this was due to turbulence in the center of flume.
20 of 22
Marietta Wastewater Treatment Works Inspection Date(s):
07/25/2023 - 07/26/2023
Outfall 001 (Ohio River)
07/25/2023 03:37 PM
No CBI
Physical Inspection
Outfall flow appeared clear.
No PII
MRTA0266.JPG Photographer: Dean Maraldo 39.408595, -81.43433833
Manhole for Outfall 002 (Ohio River)
MRTA0267.JPG
07/25/2023 03:39 PM
No CBI
No PII Photographer: Dean Maraldo
Physical Inspection
39.40898, -81.43503333
Actual outfall to the Ohio River could not be observed due to vegetation. No outfall sign was observed (permit requires 2'x2' sign including permit number telephone number, etc. for each outfall and bypass on the Ohio River).
21 of 22
Marietta Wastewater Treatment Works Inspection Date(s):
07/25/2023 - 07/26/2023
APPENDIX 2: DOCUMENT LOG
Documents Received and Attached to Report
Document Name List of Flow Meters Sanitary Sewer Overflow Annual Report (2020-2022), 5-day reports Workplans for sewer work in Duck Creek and Colegate areas Pretreatment Program Annual Report Certification 2022 Bypass DMRs (1/2023, 2/2022, 5/2022, 6/2022) Internal Bypass Event Summary January 1, 2023 - July 25, 2023 Non-compliance Notification for Exceedance of a Daily Maximum Discharge Limit (12/2022 - 4/2023) Lab procedures and forms SSO locations Sewer customer breakdown Effluent Limit Exceedance Summary (7/1/2018-5/31/2023)
Contains
CBI or
PII
Date Received
No
7/25/2023
No
7/25/2023
No
7/25/2023
No
7/25/2023
No
7/25/2023
No
7/25/2023
No
7/25/2023
Pages 2 95 22 9 4 7 4
No
7/25/2023
7
No
7/25/2023
2
No
7/25/2023
1
No
Provided by EPA 1
Documents Received and Not Attached to Report
Document Name High Flow Optimization Plan files Facility O&M Plan Chapters 2, 5, 9, 12, 13, 14) DMRs (January 1, 2019 - July 20, 2023) Operations Lab Sheet (July 2022 - Jul 2023) Laboratory Records (Microbac and Alloway) (July 2022 - Jul 2023) Chain of Custodies (Alloway) Oct-Dec 2022 Operator Daily Logs (July 2022 - Jul 2023)
Contains
CBI or
PII
Date Received
No
7/25/2023
No
7/25/2023
No
7/25/2023
No
7/25/2023
No
7/25/2023
No
7/25/2023
No
7/25/2023
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Effluent Limit Exceedances Report OH0026344: MARIETTA WWTP, MARIETTA, OH 45750 Monitoring Period Date Range: 07/01/2018 to 05/31/2023
Exceedance Details
Monitoring Period Date 1/31/2019 1/31/2019 2/28/2019 8/31/2019 8/31/2019 10/31/2020 10/31/2020 11/30/2021 11/30/2021 12/31/2021 12/31/2021 2/28/2022 2/28/2022 2/28/2022 2/28/2022 3/31/2022 3/31/2022 4/30/2022 4/30/2022 5/31/2022 5/31/2022 6/30/2022 6/30/2022 10/31/2022 12/31/2022 12/31/2022 1/31/2023 1/31/2023 3/31/2023 3/31/2023 4/30/2023 4/30/2023 5/31/2023
Outfall 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1
Parameter Description Coliform, fecal MF, MFC broth, 44.5 C Coliform, fecal MF, MFC broth, 44.5 C Solids, total suspended E. coli, MTEC-MF E. coli, MTEC-MF E. coli, MTEC-MF E. coli, MTEC-MF Coliform, fecal MF, MFC broth, 44.5 C Coliform, fecal MF, MFC broth, 44.5 C Coliform, fecal MF, MFC broth, 44.5 C Coliform, fecal MF, MFC broth, 44.5 C Solids, total suspended Solids, total suspended Coliform, fecal MF, MFC broth, 44.5 C Coliform, fecal MF, MFC broth, 44.5 C Coliform, fecal MF, MFC broth, 44.5 C Coliform, fecal MF, MFC broth, 44.5 C Coliform, fecal MF, MFC broth, 44.5 C Coliform, fecal MF, MFC broth, 44.5 C E. coli, MTEC-MF E. coli, MTEC-MF E. coli, MTEC-MF E. coli, MTEC-MF E. coli, MTEC-MF Coliform, fecal MF, MFC broth, 44.5 C Coliform, fecal MF, MFC broth, 44.5 C Coliform, fecal MF, MFC broth, 44.5 C Coliform, fecal MF, MFC broth, 44.5 C Coliform, fecal MF, MFC broth, 44.5 C Coliform, fecal MF, MFC broth, 44.5 C Coliform, fecal MF, MFC broth, 44.5 C Coliform, fecal MF, MFC broth, 44.5 C E. coli, MTEC-MF
Limit Type WK GEOMN MO GEOMN WKLY MAX MO GEOMN WK GEOMN MO GEOMN WK GEOMN WK GEOMN MO GEOMN MO GEOMN WK GEOMN MO AVG WKLY MAX MO GEOMN WK GEOMN MO GEOMN WK GEOMN WK GEOMN MO GEOMN WK GEOMN MO GEOMN WK GEOMN MO GEOMN WK GEOMN WK GEOMN MO GEOMN MO GEOMN WK GEOMN MO GEOMN WK GEOMN MO GEOMN WK GEOMN WK GEOMN
DMR Value 780
444 1130
1087
313.7
dmr_value_q ualifier T T = T T T T T T T T = = T T T T T T T T T T = T T T T T T T T =
DMR Value Unit #/100mL #/100mL kg/d MPN/100mL MPN/100mL MPN/100mL MPN/100mL #/100mL #/100mL #/100mL #/100mL kg/d kg/d #/100mL #/100mL #/100mL #/100mL #/100mL #/100mL MPN/100mL MPN/100mL MPN/100mL MPN/100mL MPN/100mL #/100mL #/100mL #/100mL #/100mL #/100mL #/100mL #/100mL #/100mL MPN/100mL
Limit Value 2000 1000 614 126 284 126 284 2000 1000 1000 2000 411 614 1000 2000 1000 2000 2000 1000 284 126 284 126 284 2000 1000 1000 2000 1000 2000 1000 2000 284
% Exceedance Limit Violation Limit Violation 27 Limit Violation Limit Violation Limit Violation Limit Violation Limit Violation Limit Violation Limit Violation Limit Violation 8 84 Limit Violation Limit Violation Limit Violation Limit Violation Limit Violation Limit Violation Limit Violation Limit Violation Limit Violation Limit Violation 283 Limit Violation Limit Violation Limit Violation Limit Violation Limit Violation Limit Violation Limit Violation Limit Violation 10
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