Document MMdXYrGQgbN1N0LM8pwno975V

U.S. ENVIRONMENTAL PROTECTION AGENCY REGION III CLEAN WATER ACT COMPLIANCE INSPECTION REPORT for Name of Facility: University of Maryland - College Park Campus Facility Address: 1101 Main Administration Building, 7901 Regents Drive, College Park, MD 20742 Mailing Address: Seneca Building, 4716 Pontiac Street, Suite 0103, College Park, MD 20742 Report Prepared on: June 25, 2021 Date By: , PG Environmental Scientist (PG Environmental) Signature Report Final as of: July 27, 2021 Date MARK By: ZOLANDZ Signature Digitally signed by MARK ZOLANDZ Date: 2021.07.27 10:47:02 -04'00' , EPA General Information Type of Inspection: Owner: Operator: Permittee: NPDES Permit No: NPDES Permit Effective Date: NPDES Permit Expiration Date: Receiving Water: Latitude and Longitude: Compliance Evaluation Inspection (non-contact cooling water, boiler blowdown, condensate, and stormwater discharges) University of Maryland University of Maryland University of Maryland MD0063801 November 1, 2012 October 31, 2017 (administratively extended) Paint Branch and associated tributaries (including Campus Creek and Guilford Run); eventually to Northeast Branch Anacostia River 38.989197 N, 76.945785 W On-Site Facility Inspection Overview On May 20, 2021, representatives from U.S. Environmental Protection Agency (EPA) Region III and EPA's contract inspector, PG Environmental, (hereinafter referred to the EPA Inspection Team) inspected the University of Maryland's College Park Campus (hereinafter, UMD or campus) in College Park, Maryland for discharges associated with non-contact cooling water, boiler blowdown, condensate, and stormwater. At the time of the inspection, UMD was identified as the Permittee and operator of the campus. The EPA Inspection Team was joined on the inspection by a representative from the Maryland Department of the Environment (MDE). Approximate Entry Time: 9:30 AM (EDT) Approximate Exit Time: 1:55 PM (EDT) Unique Project Identifier (UPI): 3E21WN104A UMD - College Park Campus (MD0063801) Compliance Evaluation Inspection Report TABLE OF CONTENTS Page I. INTRODUCTION ........................................................................................................................... 2 II. INSPECTION PROCESS ............................................................................................................... 2 Inspection Opening Conference.......................................................................................................2 Weather and Precipitation Conditions ............................................................................................. 3 Campus Site Walk............................................................................................................................ 3 Records Review ............................................................................................................................... 6 III. SUMMARY OF OBSERVATIONS................................................................................................ 6 Permit Observations and Effluent Exceedances .............................................................................. 7 Closing Conference........................................................................................................................12 Attachment A: Photograph Log Attachment B: Exhibit Log Exhibit 1: Campus Drainage Area and Outfall Maps Exhibit 2: 2017 Permit Renewal Application Exhibit 3: 2019 Permitted Discharge Percentage Data Study Results Exhibit 4: EPA ECHO Detailed Facility Report Exhibit 5: Campus ICIS Data (second quarter of 2016 and first quarter of 2021) Exhibit 6: Noncompliance Reports (2018 through the date of inspection) Exhibit 7: Illicit Discharge Report Examples Exhibit 8: Copper Mitigation Status Reports (first half of 2018 through the end of 2020) Exhibit 9: OWS Inspection Reports (CHP and Shuttle Bus Garage 2020) Attachment C: NPDES Permit No. MD0063801 Unique Project Identifier: 3E21WN104A 1 Inspection Date: May 20, 2021 UMD - College Park Campus (MD0063801) Compliance Evaluation Inspection Report I. INTRODUCTION On May 20, 2021, representatives from U.S. Environmental Protection Agency (EPA) Region III and EPA's contract inspector, PG Environmental, (hereinafter referred to the EPA Inspection Team) inspected the University of Maryland's College Park Campus (hereinafter, UMD or campus) in College Park, Maryland for discharges associated with non-contact cooling water, boiler blowdown, condensate, and stormwater. At the time of the inspection, UMD was identified as the Permittee and operator of the campus. The EPA Inspection Team was joined on the inspection by a representative from the Maryland Department of the Environment (MDE). The primary purpose of the inspection was to review the accuracy and reliability of UMD's self-monitoring and reporting program as well as the general condition and status of permitted outfalls. The weather at the time of the inspection was sunny and warm, with no precipitation. Various buildings and operations on the campus discharge non-contact cooling water, boiler blowdown, condensate, and stormwater through 12 permitted outfalls to Paint Branch and its various tributaries, including Campus Creek and Guilford Run. UMD representatives noted at the time of the inspection that a 13th outfall, Outfall 017, was not an actual outfall and does not discharge. They also explained that Outfalls 001 and 018 do not regularly flow and they believed Outfall 018 was only connected to a single sump pump, which would not necessarily be a covered discharge under the Permit. Campus drainage area and outfall maps are included in Appendix B, Exhibit 1. The primary sources of treatment on campus related to the permitted outfalls were stormwater best management practices (BMPs) and, in some cases, oil/water separators (OWSs), which are installed mostly at parking garages and the Central Heating Plant (CHP; not all OWSs are in permitted areas). According to the flow diagram in UMD's application for permit renewal (MDE Form 2C), submitted in 2017, the municipal water supply is treated through carbon filters and pH adjusted prior to entering the boilers at the CHP (refer to Appendix B, Exhibit 2). The application was reviewed following the inspection and was not discussed in detail with UMD representatives onsite. Non-contact cooling water, boiler blowdown, and condensate discharges at the campus are regulated under National Pollutant Discharge Elimination System (NPDES) Permit No. MD0063801 (hereinafter, Permit), which became effective on November 1, 2012, and has been administratively extended since October 31, 2017 (refer to Attachment C). The Permit allows for stormwater discharges from Permitregulated outfalls; however, regulations related to stormwater management and pollution prevention on campus are primarily contained in UMD's municipal separate storm sewer system (MS4) permit and its permit for industrial stormwater discharges. The 12 active permitted outfall locations also discharge runoff from sources and areas covered under UMD's MS4 and industrial stormwater programs. UMD representatives explained that issues observed at the outfalls may not be regulated under NPDES Permit No. MD0063801 and need to be investigated to determine which of the campus's permits is applicable. They stated that they have had a number of issues at Permit-regulated outfalls related to sediment and pollutant discharges from construction sites, which would fall under the MS4 program. II. INSPECTION PROCESS Inspection Opening Conference The EPA Inspection Team arrived on campus at 9:30 a.m. (EDT) for the inspection. Jake Albright of PG Environmental displayed his Clean Water Act inspector credential to UMD representatives at the outset of the inspection and explained that the purpose of the inspection was to observe compliance with the Permit. The EPA Inspection Team explained that any information that the Facility deemed to be Unique Project Identifier: 3E21WN104A 2 Inspection Date: May 20, 2021 UMD - College Park Campus (MD0063801) Compliance Evaluation Inspection Report confidential business information ("CBI") should be identified to EPA representatives during the inspection and it would be handled as CBI according to EPA's CBI procedures. Table 1 describes the individuals that participated in the inspection. Name Table 1: Inspection Attendee List Affiliation Telephone EPA Region III Inspectors and Contractors Email Jake Albright PG Environmental (703) 956-1957 Jake.Albright@pgenv.com Kaitlin McLaughlin EPA Region III (215) 814-2393 McLaughlin.Kaitlin@epa.gov Maryland Department of the Environment Oladapo John MDE (443) 250-6883 oladapo.john@maryland.gov Maureen Kotlas, Executive Director Scott Lupin, Associate Director Jason Baer. Assistant Director of Environmental Affairs Kaitlyn Peterson, Environmental Specialist, Office of Environmental Affairs Facility Representatives UMD, Department of Environmental Safety, (301) 405-3960 Sustainability, & Risk UMD, Department of Environmental Safety, Sustainability, & Risk UMD, Department of Environmental Safety, (301) 405-3163 Sustainability, & Risk UMD, Department of Environmental Safety, Sustainability, & Risk (301) 405-8604 mkotlas@umd.edu jbaer123@umd.edu Kpeter13@umd.edu Weather and Precipitation Conditions During the inspection, the weather was warm and sunny. National Oceanic and Atmospheric Administration (NOAA) National Weather Service precipitation data for the date of the inspection and 5 days prior are provided in the Table 2 below: Station Name TAKOMA PARK 0.6 NNW, MD US TAKOMA PARK 0.6 NNW, MD US TAKOMA PARK 0.6 NNW, MD US TAKOMA PARK 0.6 NNW, MD US TAKOMA PARK 0.6 NNW, MD US TAKOMA PARK 0.6 NNW, MD US Table 2. Precipitation Data Date 05/15/2021 05/16/2021 05/17/2021 05/18/2021 05/19/2021 05/20/2021 Precipitation Amount (inches)1 0.00 0.00 0.01 0.00 0.00 0.00 Campus Site Walk As part of the process, the EPA Inspection Team visually observed areas of the campus in the vicinity of the permitted outfalls as well as the status and condition of the outfalls themselves at the time of the inspection. The majority of regulated discharges occurring at the outfalls permitted under NPDES Permit No. MD0063801 are from boiler blowdown and condensate from the CHP and campus-wide steam delivery system. Cooling towers and chillers used to cool various buildings across campus also contribute 1 Source: NOAA National Climatic Data Center (http://www.ncdc.noaa.gov/). Unique Project Identifier: 3E21WN104A 3 Inspection Date: May 20, 2021 UMD - College Park Campus (MD0063801) Compliance Evaluation Inspection Report to flow at most outfalls. Most of these sources discharge into the campus's storm sewer prior to being conveyed to the outfalls. UMD representatives stated that non-contact cooling water, boiler blowdown, and condensate discharges only account for a small percentage of the overall volume being discharged from the permitted outfalls (i.e., most volume is stormwater runoff). As stated previously, runoff that is regulated under the MS4 and industrial stormwater programs is also discharged from the same outfalls. UMD provided data from a study conducted in 2019 that indicate the percent of discharges considered to be from sources permitted under NPDES Permit No. MD0063801 is about 11.8% from Outfalls 002,003, 004, 005, 007, 010, 012, 014, 016, and 019 (refer to Appendix B, Exhibit 3). As noted previously, UMD representatives stated that Outfall 017 was not an actual outfall, and 001 and 018 do not regularly discharge. The following locations were visited on the day of the inspection: Outfall 007(approx. 11:30 a.m.) Outfall 007 drains areas and buildings in the southeast part of campus. UMD's permit renewal application states approximately 40,708 gallons per day (GPD) of CHP blowdown/condensate are discharged through the outfall on average. The EPA Inspection Team observed moisture at the outfall; the receiving water appeared clear in the vicinity of Outfall 007 (refer to Appendix A, DSCN 5027 and DSCN 5029). Outfall 005(approx. 11:38 a.m.) Outfall 005 drains areas and buildings, west to east, through the central portion of campus. UMD representatives stated Outfall 005 has the largest drainage area, accounting for about one third of the campus. UMD's permit renewal application states approximately 135,363 GPD of CHP blowdown/condensate are discharged through the outfall on average. The EPA Inspection Team observed moisture/flow at the outfall (refer to Appendix A, DSCN 5030). The receiving water was cloudy in the vicinity of Outfall 005 (refer to Appendix A, DSCN 5030 and DSCN 5034). UMD representatives stated that the cloudiness was likely from sediment-laden runoff coming from various campus construction projects, including the School of Public Policy and the Purple Line project. UMD representatives stated they routinely identify these types of issues through the MS4 program and notify the applicable contractors; however, the issues persist. They noted that the Office of Environmental Affairs has few effective mechanisms available to escalate enforcement. Outfall 016 (approx. 11:47 a.m.) The outfall drains areas and buildings in a small portion of the eastern-central part of campus. The drainage area includes a portion of the CHP as well as off-campus commercial establishments (e.g., restaurant). UMD's permit renewal application states approximately 29,857 GPD of CHP blowdown/condensate are discharged through the outfall on average. The EPA Inspection Team observed the receiving water appeared clear in the vicinity of Outfall 007 (refer to Appendix A, DSCN 5036). Outfall 001 (approx. 11:55 a.m.) The outfall drains areas and buildings in a small portion of the eastern-central part of campus. The drainage area includes an off-campus hotel. UMD's permit renewal application estimates no discharges of CHP blowdown/condensate occur at the outfall. UMD representatives stated that they sample Outfall 001 from a manhole about 650-700 feet southwest of the discharge location to avoid getting samples influenced by runoff from the hotel. The EPA Inspection Team observed the receiving water appeared clear in the vicinity of Outfall 001 (refer to Appendix A, DSCN 5041 and DSCN 5043). Outfalls 002, 003, and 004 (approx. 12:11 p.m.) These three outfalls drain areas and buildings in a large portion of the northern and central parts of campus. Of the three, Outfall 003 has the largest drainage area (refer to Appendix A, DSCN 5044 for a Unique Project Identifier: 3E21WN104A 4 Inspection Date: May 20, 2021 UMD - College Park Campus (MD0063801) Compliance Evaluation Inspection Report photograph of a chiller/cooling unit in the Outfall 003 area). All three outfall structures are located on the west bank of Paint Branch in the northeastern part of campus. Outfall 004 is upstream of 003, which is upstream of 002. UMD's permit renewal application states approximately 25,007 GPD, 154,673 GPD, and 93,108 of CHP blowdown/condensate are discharged through the Outfalls 002, 003, and 004, respectively, on average. The application also lists a remote boiler/chiller plant as a source for Outfall 004 but does not provide an estimated average daily flow. All three outfalls had flow at the time of the inspection. In each case, the discharge appeared to be clear (refer to Appendix A, DSCN 5045, DSCN 5048 , DSCN 5053, DSCN 5054, and DSCN 5055). Outfall 019 (approx. 12:35 p.m.) Outfall 019 drains areas and buildings in the northern part of campus including the Eppley Recreation Center area (refer to Appendix A, DSCN 5066) and Cambridge Community area. UMD's permit renewal application states approximately 32,384 GPD of CHP blowdown/condensate are discharged through the outfall on average. The EPA Inspection Team observed moisture/flow at the outfall. Red clay and sediment were observed deposited in the receiving water at the outfall and approximately 50 feet downstream (refer to Appendix A, DSCN 5058, DSCN 5059, and DSCN 5062). UMD representatives stated that the deposits were likely from sediment-laden runoff coming from a residential dorm and dining hall construction project located between the Cambridge Community area and the football stadium. UMD representatives stated they routinely identify these types of issues through the MS4 program and notify the applicable contractors; however, the issues persist. They noted that the Office of Environmental Affairs has few effective mechanisms available to escalate enforcement. Outfall 018 (approx. 12:42 p.m.) UMD representatives explained they believed the outfall was only connected to a single basement sump pump at the School of Public Health (refer to Appendix A, DSCN 5064). UMD's permit renewal application estimates 1,522 GPD of CHP blowdown/condensate discharges occur at the outfall on average. This seems to contradict the statement from UMD representatives that the outfall is only connected to a sump pump. It is unclear if the source had been investigated or evaluated since the permit application was submitted in 2017. The permit application was provided after the inspection and not discussed in detail with UMD representatives onsite. The EPA Inspection Team observed the outfall was obstructed by vegetation but did not appear to be discharging at the time of the inspection. (refer to Appendix A, DSCN 5064). Outfall 010 (approx. 12:55 p.m.) Outfall 010 drains areas and buildings in the northwest corner of campus and discharges to Campus Creek. UMD's permit renewal application states approximately 4,448 GPD of CHP blowdown/condensate are discharged through the outfall on average. The EPA Inspection Team observed moisture at the outfall; the receiving water appeared clear in the vicinity of Outfall 010 (refer to Appendix A, DSCN 5067 and DSCN 5069). Outfall 012 (approx. 1:05 p.m.) Outfall 012 drains areas and buildings in the southwest portion of campus and discharges to Guilford Run. UMD's permit renewal application states approximately 17,207 GPD of CHP blowdown/condensate are discharged through the outfall on average. The EPA Inspection Team observed moisture/flow at the outfall (refer to Appendix A, DSCN 5074). The receiving water was cloudy in the vicinity of Outfall 012 (refer to Appendix A, DSCN 5074 and DSCN 5075). UMD representatives stated that the cloudiness was likely from sediment-laden runoff coming from the Purple Line project. UMD representatives stated they routinely identify these types of issues through the MS4 program and notify the applicable contractors; however, the issues persist. They noted that the Office of Environmental Affairs has few effective mechanisms available to escalate enforcement. Unique Project Identifier: 3E21WN104A Inspection Date: May 20, 2021 5 UMD - College Park Campus (MD0063801) Compliance Evaluation Inspection Report Outfall 014 (approx. 1:15 p.m.) Outfall 014 drains areas and buildings in the northwest corner of campus and discharges to Campus Creek. UMD's permit renewal application states approximately 14,722 GPD of CHP blowdown/condensate are discharged through the outfall on average. The EPA Inspection Team observed moisture/flow at the outfall; the receiving water appeared clear in the vicinity of Outfall 014 (refer to Appendix A, DSCN 5078). Records Review The EPA Inspection Team also conducted a records review to further evaluate the Permittee's compliance with the Permit. Most of the records and reports required by the Permit were provided electronically while the EPA Inspection team was onsite and reviewed offsite after the inspection. The following documents were reviewed: Maps of Drainage Areas to Permitted Outfalls EPA Integrated Compliance Information System (ICIS) data (second quarter 2016 through first quarter 2021) eDMRs (first quarter 2018 through first quarter 2021) UMD Noncompliance Reports (first quarter 2018 through first quarter 2021) Copper Mitigation Status Reports (first half of 2018 through end of 2020) 2017 Permit Renewal Application 2019 Permitted Discharge Percentage Data Study Results Illicit Discharge Investigation Reports (2018 through March 2021) CHP and Shuttle Bus Garage OWS (January 2020 through December 2020) UMD Stormwater Pollution Prevention Plan (2020) UMD Spill Prevention Control and Countermeasure Plan (2019) EPA's Enforcement Compliance History Online (ECHO) database shows the campus in a state of significant noncompliance for failure to submit eDMRs between the third quarter of 2018 and the fourth quarter of 2020 (refer to Attachment B, Exhibit 4). UMD representatives stated this was an error in the database system, and they were able to provide the eDMR submittal packages uploaded to MDE's reporting system between the first quarter of 2018 and the first quarter of 2021. Due to the volume of data provided, the submittal packages have not been included in this report but will be kept on file with EPA Region III and available for review. UMD's 2017 permit renewal application only provides average daily volume estimates for CHP Boiler discharges at each outfall. According to UMD representatives at the time of the inspection, there are also cooling towers and heat exchangers that can contribute to flow at most outfalls. It is unclear why these sources were not included in the application. The application was reviewed following the inspection and not discussed in detail with UMD representatives onsite. III. SUMMARY OF OBSERVATIONS The following section summarizes the EPA Inspection Team's observations relative to the Permit requirements, including the status of certain treatment units, operation and maintenance practices, and monitoring and reporting documentation. Unique Project Identifier: 3E21WN104A 6 Inspection Date: May 20, 2021 UMD - College Park Campus (MD0063801) Compliance Evaluation Inspection Report Permit Observations and Effluent Exceedances Part I.A.1 of the Permit defines effluent limitations and monitoring requirements for all permitted outfalls. According to EPA's ICIS database, the campus experienced 18 effluent limit exceedances from multiple outfalls between the second quarter of 2016 and first quarter of 2021 (refer to Attachment B, Exhibit 5). Most reported exceedances were pH and total chlorine exceedances with one oil and grease exceedance (see Table 2). Table 2. Summary of Effluent Exceedances (all outfalls; 2nd quarter 2016 through 1st quarter 2021) Permit # Monitoring Period End Date Outfall No. Parameter Name DMR Value Permit Limit Units Limit Type MD0063801 MD0063801 MD0063801 MD0063801 MD0063801 MD0063801 MD0063801 MD0063801 MD0063801 MD0063801 MD0063801 MD0063801 MD0063801 MD0063801 MD0063801 MD0063801 MD0063801 MD0063801 3/31/2021 3/31/2021 3/31/2021 3/31/2020 3/31/2020 12/31/2019 12/31/2019 6/30/2018 6/30/2018 12/31/2017 9/30/2017 9/30/2017 3/31/2017 6/30/2016 6/30/2016 6/30/2016 6/30/2016 6/30/2016 005 pH 9.09 8.5 s.u. Daily Max. 005 Chlroersiindeu,atlotal 0.13 0.019 mg/L Daily Max. 016 Oil & Grease 32.3 15 mg/L Daily Max. 012 Chlroersiindeu,atlotal 0.13 0.011 mg/L Monthly Average 012 Chlroersiindeu,atlotal 0.27 0.019 mg/L Daily Max. 003 pH 8.58 8.5 s.u. Daily Max. 005 pH 9.11 8.5 s.u. Daily Max. 003 pH 9.43 8.5 s.u. Daily Max. 004 pH 9.46 8.5 s.u. Daily Max. 005 pH 8.59 8.5 s.u. Daily Max. 019 Chlroersiindeu,atlotal 0.13 0.011 mg/L Monthly Average 019 Chlorine, total 0.27 residual 0.019 mg/L Daily Max. 002 pH <=11.1 8.5 s.u. Daily Max. 003 Chlroersiindeu,atlotal 4.6 004 Chlroersiindeu,atlotal 14.5 005 Chlroersiindeu,atlotal 24 014 Chlroersiindeu,atlotal 1.39 0.019 0.019 0.019 0.019 mg/L mg/L mg/L mg/L Daily Max. Daily Max. Daily Max. Daily Max. 016 Chlroersiindeu,atlotal 3.2 0.019 mg/L Daily Max. UMD representatives stated at the time of the inspection that most exceedances experienced over the 5 years prior to the inspection were the result of illicit discharges from construction sites and were ultimately regulated by the MS4 program. UMD provided noncompliance reports for 2018 through the date of inspection which reflect the onsite discussion (refer to Attachment B, Exhibit 6). It should be noted that the oil and grease exceedance experienced in the first quarter of 2021 and the chlorine exceedance experienced in the first quarter of 2020 were both thought to be anomalies or the result of laboratory error. UMD provided a noncompliance report for two temperature excursions experienced in the August 2018 that were not represented in the ICIS data (refer to Attachment B, Unique Project Identifier: 3E21WN104A 7 Inspection Date: May 20, 2021 UMD - College Park Campus (MD0063801) Compliance Evaluation Inspection Report Exhibit 6). Specifically, the report states, "During the monthly NPDES sampling event on August 30, 2018, the discharge temperature at Outfall #005 and Outfall #016 was measured at 95.2 F and 98.9 F, respectively. For Outfall #005, the upstream temperature was determined to be 92.8 F and the downstream temperature was 93.1 F. For Outfall #016, the temperature observed upstream was 86.8 F, while the downstream temperature was 92.5 F." The report also states that the excursion was investigated and found to be due to a broken steam line in the area. The line was reported to be repaired on August 30, 2018. At the time of the inspection, UMD representatives stated that the steam generation and delivery system was aging, and UMD is currently exploring a future project on campus that will upgrade the on-campus power plant and steam system. Part I.A.1 of the Permit states, "There shall be no discharge of floating solids or persistent foam in other than trace amounts. Persistent foam is foam that does not dissipate within one half-hour of point of discharge." Cloudiness and evidence of sediment deposits were observed at multiple outfalls during the campus walk. Specifically: The receiving water in the vicinity of Outfall 005 was cloudy (refer to Appendix A, DSCN 5030 and DSCN 5034). UMD representatives stated that the cloudiness was likely from sediment-laden runoff coming from various campus construction projects, including the School of Public Policy and the Purple Line project. The EPA Inspection Team observed red clay and sediment deposited in the receiving water at Outfall 019 and approximately 50 feet downstream (refer to Appendix A, DSCN 5058, DSCN 5059, and DSCN 5062). UMD representatives stated that the deposits were likely from sediment-laden runoff coming from a residential dorm and dining hall construction project located between the Cambridge Community area and the football stadium. The receiving water was cloudy in the vicinity of Outfall 012 (refer to Appendix A, DSCN 5074 and DSCN 5075). UMD representatives stated that the cloudiness was likely from sediment-laden runoff coming from the Purple Line project. UMD representatives stated they routinely identify these types of issues through the MS4 program and notify the applicable contractors; however, the issues persist. They noted that the Office of Environmental Affairs has few effective mechanisms available to escalate enforcement. UMD did provide several examples of illicit discharge reports that show issues have been identified and communicated to contractors in the past (refer to Attachment B, Exhibit 7). Part I.U of the Permit (Compliance Schedule for Total Copper) states the following: 1. Every six months, the permittee shall submit to the Department a status report detailing current plans for meeting the Total Copper limits in Special Condition A.1. This report is due six months after the effective date of the permit and every six months thereafter until the effective date of the permit limits. The plans may include alternative treatment technologies or other discharge options which will result in compliance with the final discharge limitations. 2. Within 24 months of the effective date the permittee shall complete an Engineering Alternatives Analysis. The analysis shall review each building to identify and prioritize contributing sources and options for eliminating those sources from the storm sewer system. The permittee shall provide a copy of the analysis to the Department within 30 days of its completion. 3. Within 48 months of the effective date the permittee shall complete an Engineering Design Plan. The plan shall specify the designs of building specific corrective measures called for in the Unique Project Identifier: 3E21WN104A 8 Inspection Date: May 20, 2021 UMD - College Park Campus (MD0063801) Compliance Evaluation Inspection Report completed Engineering Alternatives Analysis. The permittee shall provide a copy of the plan to the Department within 30 days of its completion. 4. Within 50 months of the effective date of this permit, the permittee shall complete a Compliance Plan detailing how the permittee intends to comply with the copper limits within 72 months of the effective date. The permittee must state in their plan either that the discharge will be brought into compliance or that the discharge will be eliminated, as follows: a. If the permittee will bring the discharge into compliance with the permit limits, the plan must detail how the permittee will reach the permit limits within 72 months of the effective date. If the permittee is eligible to have the permit limits revised, per Special Condition U.5, below, the plan must detail how the permittee will reach the revised permit limits within 72 months of the effective date. b. If the permittee will eliminate the discharge, the plan must state that the permittee will eliminate the discharge within 72 months of the effective date. To eliminate the discharge, the permittee must demonstrate to the Department's satisfaction that copper containing waste streams are no longer being discharged to State waters and provide supporting documents to show that the waste streams have been re-piped. This certification of discharge elimination should be done when the discharge is eliminated and no later than 72 months after the effective date. c. If the permittee is eligible to have the permit limits removed, per Special Condition U.5, below, the permittee is not required to submit a Compliance Plan. 5. Within 50 months of the effective date of this permit, the permittee may apply for a permit modification to revise or remove the permit limit(s) based on any combination of the following options allowed under COMAR 26.08: a. Site-Specific Criterion: Per COMAR 26.08.02.03-2C., the permittee shall submit to the Department complete documentation of the proposed site-specific criterion as part of the application for a permit modification. b. Chemical or Biological Translator: The permittee shall complete all studies supporting use of the translator under COMAR 26.08.04.02-3C, paragraphs (1), (3) and (4) for biological translators or under COMAR 26.08.04.02-4C, paragraphs (1), (3) and (4) for chemical translators and submit the results to the Department as part of the application for a permit modification. c. Mixing Zone Study: As part of the application for a permit modification, the permittee shall include the proposed dilution calculation and appropriate demonstration, using dye studies or simulation models, that the dilution calculation is applicable during periods of ambient stream conditions, flow rates; and distances specified in COMAR 26.08.02.05. d. Additional Data: As part of the application for a permit modification, the permittee may submit any new or additional data which demonstrates that there is no reasonable potential for violation of applicable water quality standards. Alternatives for making such a demonstration include, but are not limited to, the following: i. collection of effluent data using analytical methods which have lower detection levels; ii. collection of data using techniques designed to minimize the effects of contamination on sample results; and iii. collection of data utilizing alternate monitoring locations to show compliance with water quality standards. e. Removal of Waste Streams: The permittee must demonstrate to the Department's satisfaction that copper containing waste streams are no longer being discharged. Adequate demonstration to the Department should include applicable supporting documents of the re-piping of these waste streams; and appropriate certification. Unique Project Identifier: 3E21WN104A 9 Inspection Date: May 20, 2021 UMD - College Park Campus (MD0063801) Compliance Evaluation Inspection Report UMD representatives stated that they have been enacting a mitigation plan and scheduling and completing significant projects to eliminate copper sources and minimize total copper exceedances throughout campus. UMD provided copper mitigation status reports from the first half of 2018 through the end of 2020 (refer to Attachment B, Exhibit 8). However, it appears the 2019 reports were inadvertently left out of the data set. The reports indicate UMD has identified significant sources of copper and enacted projects to mitigate or eliminate them, including, but not limited to, replacing the corroded dehumidifier unit at the campus pool, replacing dated cooling towers and heat exchangers during major renovation projects, and routing sources of copper discharge from the storm sewer system to the sanitary sewer. However, even with these projects in place, UMD representatives stated they believed they will continue to exceed the Permit's total copper limits because the total copper levels in the potable water system (provided by WSSC Water) are higher than the Permit limits. Part I.A.1 of the Permit includes a monthly average total copper concentration limit of 9.0 ug/L and a daily maximum concentration of 13.0 ug/L. UMD representatives stated that the potable water supply, which is used as source water for the boilers and cooling towers has an average total copper concentration of 200 to 300 parts per billion (or 200 to 300 ug/L). Table 3 shows effluent total copper concentrations measured at each outfall from the first quarter of 2020 through first quarter of 2021. Data dating back to the second quarter of 2016 is available in Appendix B, Exhibit 5. These exceedances are not flagged as violations in ICIS. Table 3. Effluent Total Copper Concentrations Measured at Each Outfall from the First Quarter of 2020 through First Quarter of 2021 Monitoring Period End Date Outfall Parameter Monthly Average Daily Max ConcUennittrsation 03/31/2020 001-A Copper, total NODI C NODI C ug/L 03/31/2020 002-A Copper, total 13.53 15.5 ug/L 03/31/2020 003-A Copper, total 13.53 15.5 ug/L 03/31/2020 004-A Copper, total 13.53 15.5 ug/L 03/31/2020 005-A Copper, total 13.53 15.5 ug/L 03/31/2020 007-A Copper, total 13.53 15.5 ug/L 03/31/2020 010-A Copper, total 13.53 15.5 ug/L 03/31/2020 012-A Copper, total 13.53 15.5 ug/L 03/31/2020 014-A Copper, total 13.53 15.5 ug/L 03/31/2020 016-A Copper, total 13.53 15.5 ug/L 03/31/2020 018-A Copper, total NODI C NODI C ug/L 03/31/2020 019-A Copper, total 13.53 15.5 ug/L 06/30/2020 001-A Copper, total NODI C NODI C ug/L 06/30/2020 002-A Copper, total 10.2 16.3 ug/L 06/30/2020 003-A Copper, total 10.2 16.3 ug/L 06/30/2020 004-A Copper, total 10.2 16.3 ug/L 06/30/2020 005-A Copper, total 10.2 16.3 ug/L 06/30/2020 007-A Copper, total 10.2 16.3 ug/L 06/30/2020 010-A Copper, total 10.2 16.3 ug/L 06/30/2020 012-A Copper, total 10.2 16.3 ug/L 06/30/2020 014-A Copper, total 10.2 16.3 ug/L 06/30/2020 016-A Copper, total 10.2 16.3 ug/L 06/30/2020 018-A Copper, total NODI C NODI C ug/L 06/30/2020 019-A Copper, total 10.2 16.3 ug/L 09/30/2020 001-A Copper, total NODI C NODI C ug/L 09/30/2020 002-A Copper, total 16.8 20.7 ug/L Unique Project Identifier: 3E21WN104A 10 Inspection Date: May 20, 2021 UMD - College Park Campus (MD0063801) Compliance Evaluation Inspection Report Monitoring Period End Date 09/30/2020 09/30/2020 09/30/2020 09/30/2020 09/30/2020 09/30/2020 09/30/2020 09/30/2020 09/30/2020 09/30/2020 12/31/2020 12/31/2020 12/31/2020 12/31/2020 12/31/2020 12/31/2020 12/31/2020 12/31/2020 12/31/2020 12/31/2020 12/31/2020 12/31/2020 03/31/2021 03/31/2021 03/31/2021 03/31/2021 03/31/2021 03/31/2021 03/31/2021 03/31/2021 03/31/2021 03/31/2021 03/31/2021 03/31/2021 Outfall 003-A 004-A 005-A 007-A 010-A 012-A 014-A 016-A 018-A 019-A 001-A 002-A 003-A 004-A 005-A 007-A 010-A 012-A 014-A 016-A 018-A 019-A 001-A 002-A 003-A 004-A 005-A 007-A 010-A 012-A 014-A 016-A 018-A 019-A Parameter Copper, total Copper, total Copper, total Copper, total Copper, total Copper, total Copper, total Copper, total Copper, total Copper, total Copper, total Copper, total Copper, total Copper, total Copper, total Copper, total Copper, total Copper, total Copper, total Copper, total Copper, total Copper, total Copper, total Copper, total Copper, total Copper, total Copper, total Copper, total Copper, total Copper, total Copper, total Copper, total Copper, total Copper, total Monthly Average 16.8 16.8 16.8 16.8 NODI C 16.8 16.8 16.8 NODI C 16.8 NODI C 30.6 30.6 30.6 30.6 30.6 30.6 30.6 30.6 30.6 NODI C 30.6 NODI C 20.67 20.67 20.67 20.67 20.67 20.67 20.67 20.67 20.67 NODI C 20.67 Daily Max 20.7 20.7 20.7 20.7 NODI C 20.7 20.7 20.7 NODI C 20.7 NODI C 38.6 38.6 38.6 38.6 38.6 38.6 38.6 38.6 38.6 NODI C 38.6 NODI C 26.7 26.7 26.7 26.7 26.7 26.7 26.7 26.7 26.7 NODI C 26.7 Concentration Units ug/L ug/L ug/L ug/L ug/L ug/L ug/L ug/L ug/L ug/L ug/L ug/L ug/L ug/L ug/L ug/L ug/L ug/L ug/L ug/L ug/L ug/L ug/L ug/L ug/L ug/L ug/L ug/L ug/L ug/L ug/L ug/L ug/L ug/L Part I.P.1 of the Permit states, "The permittee shall inspect all oil-water separators, grease interceptors, and grit traps on a monthly basis to confirm that they are operating properly." UMD representatives stated that OWSs located at the CHP and the shuttle bus garage are in areas covered under the Permit. Records provided by UMD show that OWS inspections are not always being conducted monthly as required by the permit (refer to Attachment B, Exhibit 9). Specifically, during 2020, the two OWSs at the shuttle bus garage were not inspected in April, May, September, October, November, or December. The CHP has three OWSs (air compressor, underground, and fuel oil dike). The following inspection gaps were observed in 2020: Underground and Fuel Oil Dike OWSs were not inspected between January 30, 2020 and April 3, 2020. No inspections were conducted in November 2020 (gap between October 30 and December 3). UMD representatives explained that each department was responsible for inspecting their own OWSs. They also stated that there are several grease traps on campus, but they are connected to the sanitary sewer. Unique Project Identifier: 3E21WN104A Inspection Date: May 20, 2021 11 UMD - College Park Campus (MD0063801) Compliance Evaluation Inspection Report Closing Conference After the campus site walk, the EPA Inspection Team met with UMD representatives for a closing conference and shared preliminary observations. The EPA Inspection Team reiterated that all preliminary observations discussed were not compliance determinations. Any and all preliminary observations shared were subject to further investigation by the EPA Inspection Team 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 the additional review of materials following the inspection. The inspection concluded at approximately 1:55 PM (EDT). Unique Project Identifier: 3E21WN104A 12 Inspection Date: May 20, 2021