Document MMj6moOEQ11mQjRJByGnrEYqL

U.S. Environmental Protection Agency Region 5 Purpose: Facility: Compliance Evaluation Inspection City of Washington Wastewater Treatment Plant 169 South 200 West Washington, Indiana 47501 NPDES Permit Number: IN0025658 Inspection Date: April 12 & 13, 2022 EPA Representatives: Rajen Patel, Environmental Engineer, 312-886-5741 Valerie Dooling, Environmental Engineer, 312-886-7167 Facility Representatives: Dave Rhoads, Mayor, City of Washington, 812-698-2435 David Dahl, City Council, City of Washington, 812-296-0096 Dirk Rhoads, Head Wastewater Treatment Operator, City of Washington, 812-486-9100 Matt Hooten, Lead Lab Technician, City of Washington, 812-698-1477 Sam Halbert - First shift operator, City of Washington, 812-486-9100 Chris Shelton, Certified Operator, Midwestern Engineering, 812-296-0113 Report Prepared by: Rajen Patel Water Enforcement and Compliance Assurance Branch, Section 2 patel.rajen@epa.gov RAJEN PATEL Digitally signed by RAJEN PATEL Date: 2022.06.08 15:34:43 -04'00' Inspector Signature: __________________________________ Approver Name and Title: Ryan Bahr, Section 2 Supervisor Water Enforcement and Compliance Assurance Branch Bahr, Ryan Digitally signed by Bahr, Ryan Approver Signature and Date: ____________________D_at_e:_2_02_2_.0_6._08_1_6_:5_1:_51_-_0_5'0_0_' BACKGROUND The purpose of this report is to describe, evaluate and document the City of Washington's (Washington) compliance with the Clean Water Act (CWA) and associated pretreatment regulations with respect to the Washington Wastewater Treatment Plant (WWTP) located at 169 South 200 West, Washington, Indiana 47501 (facility). There are two entities (the Approval Authority and the Control Authority) that have the responsibility to develop and implement the federal pretreatment program. An Approval Authority is either the state Director of a National Pollutant Discharge Elimination System (NPDES) in an authorized state with an EPA-approved pretreatment program or the EPA Regional Administrator in a state without an approved pretreatment program. A Control Authority is either a Publicly Owned Treatment Works (POTW) with an approved pretreatment program or the Approval Authority for any POTW that does not have an approved program. The State of Indiana and City of Washington POTW do not have an EPA-approved pretreatment program. EPA is the "Control Authority" in Indiana and has the enforcement authority pertaining to the pretreatment requirements at Washington. This POTW facility is authorized to discharge in accordance with effluent limitations, monitoring requirements and other conditions set forth in the National Pollutant Discharge Elimination System (NPDES) Permit (Permit) Number IN0025658 issued by the Indiana Department of Environmental Management (IDEM) on May 24, 2018. The facility discharges into Hawkins Creek flowing to the immediate south of the facility. Hawkins Creek connects to the White River just 2 miles west from the facility. The current permit is valid through June 30, 2023. EPA has developed nationally applicable pretreatment standards under CWA section 307(b) in its General Pretreatment Regulations for Existing and New Sources of Pollution at 40 CFR Part 403. Such pretreatment standards are directly applicable to indirect dischargers based on the processes conducted at the facilities and the applicability of those standards. The City of Washington currently operates a Class III, 4.2 million gallons per day (MGD) average daily volume wastewater treatment facility (with a peak daily volume of 5.7 MGD) consisting of aerated grit removal and two secondary treatment processes. The first process (oxidation ditch treatment train) consists of a comminutor/screening unit, pre-aeration tank, primary clarification, bio-roughing trickling filters, and tri-channel oxidation ditch. The second process; Sequential Batch Reactor (SBR treatment train) consists of screening and SBR tanks with fine bubble diffusers. This SBR train treats wastewater from Perdue Poultry Processing facility (to the immediate north of the facility) and a small amount of sanitary waste from the northwest corner of the city. The effluent of both treatment trains is combined prior to ultraviolet light (UV) disinfection and cascade post-aeration. The WWTP has an influent and effluent Parshall flume flow meter with ultrasonic level detectors on the oxidation ditch treatment train, an influent and effluent electromagnetic flow meter on the SBR treatment train, and a plant effluent (combined-treatment-train flows) electromagnetic flowmeter. Sludge is thickened by 2 gravity in a stilling well, digested in six (6) aerobic digesters, dewatered by centrifuge, and dried on five (5) drying beds before being disposed of in a landfill. SITE INSPECTION Opening Conference EPA representatives entered the facility at 2:20 pm on April 12, 2022. IDEM regional inspectors Holly Zurcher and Jeremy Ferguson joined the EPA team for this inspection. We were greeted by Chris Shelton, Certified Wastewater Treatment Operator, Midwestern Engineering. He then escorted us to a large conference room and introduced us to Mayor Dave Rhoads, Councilman David Dahl and the WWTF team: Dirk Rhoads, Head Wastewater Treatment Operator; Matt Hooten, Lead Lab Technician; and Sam Halbert; First Shift Operator. The staff work one shift each day, seven days per week. Midwest Engineering is contracted for larger projects, including identifying inflow and infiltration (I/I), and the WWTP hires contractors like electricians and welders for maintenance that cannot be done by WWTP staff. Complaints can be called in to the plant and the plant is on a SCADA system that can notify personnel of problems. All the lift stations are also on a remote call out system to let facility personnel know of issues. There is no formal training program for WWTP staff, but they participate in state conferences and other opportunities that arise. Due to the pandemic, there were not many opportunities for off-site training in 2020 and 2021. Mr. Shelton showed us the facility's hard notebook (kept in the laboratory) used to record weekly preventative maintenance (PM) evaluations on all lift stations and WWTP equipment by the staff. Any equipment malfunction and required repair is communicated to the facility's superintendent on the same day of finding. Repairs get done based on the budget allocation by the city. The EPA inspection team presented credentials to the facility representatives and began the opening conference at 2:30 pm on April 12. I explained to the representatives that EPA was performing a CWA compliance evaluation inspection of the facility operations and we would evaluate its wastewater discharges and take photos during the inspection. I informed the facility representatives that they would receive copies of the photographs collected during the inspection as an attachment to the inspection report. Mayor Rhoads stated that Washington has not had a replacement person in the Superintendent position since Scott Rainey's retirement last fall. The Mayor mentioned that he is aware of the 2021 effluent violations and current equipment needs at the WWTP. Mayor Rhoads also mentioned that the loss of three key POTW staff has been challenging in maintaining the POTW's operations. Mr. Patel asked, and Mayor Rhoades confirmed that the facility staff has not been in regular communication with its largest wastewater contributor, Perdue Foods, for the past year. Councilman Dahl stated that he has authorized the budget for purchases of the two large blowers for the SBRs and a large centrifuge conveyor for the sludge dewatering operation and conveyance. The Mayor stated that Dirk Rhoads has taken Dave Campbell's position (retired January 2022) as the head operator for the plant. Mr. Rhoads has Class II Operation Certification. Since Mr. Rainey's departure last fall, Washington has procured Chris Shelton's 3 services. Mr. Shelton has a Class IV Operation Certification and over 25 years of experience managing WWTP operations, and he attends to the WWTP's operational, and compliance needs on a more regular basis throughout the week. Mr. Shelton stated that Mr. Hooten has taken the role of managing day-to-day laboratory work (which was managed by Mr. Rhoads prior to Mr. Hooten's addition to the team). Facility Walk-Through The walkthrough of the WWTP began around 3 pm at the on-site laboratory. EPA mostly spoke with the Lead Lab Technician Matt Hooten. Laboratory: A new laboratory has been built inside a small one-story office type building that houses chemical storage/laboratory/administration offices. It was built at the time that phosphorus treatment was installed during spring of 2021. The old laboratory was housed in an old small one-story building located immediately south from the new building. Mr. Hooten stated that he manages the collection of two grab samples per shift; about 4 hours apart (9am, 1pm, 5pm, 9pm, 1am and 5am) for a total of 6 grab samples each day to make a 24-hour composite sample. The composite sample is analyzed during the first shift the following day. Mr. Shelton stated that a new 24-hour time-proportional autosampler has been purchased to replace the current 6-grab sample method. It will collect one sample each hour. The autosampler is expected to be installed and operational this summer. The ammonia and phosphorus samples are analyzed on a DR3900 Spectrometer, which has a data logger and shows the type of method used for the analysis. Dissolved Oxygen (DO) and pH probes are calibrated daily. EPA observed Mr. Hooten's documentation for sample collection and analysis and the 3-point pH meter calibration logs. Mr. Patel observed the calibration buffers, and they were not expired. Ms. Dooling observed the DO calibration logs. Mr. Hooten stated that DO calibration is done on a Hach HQ40d instrument but not recorded on the bench sheet; however, the pH calibration is recorded on the bench sheet (photos 6 and 7). He stated that the pH meters are calibrated five times per week. Bench sheets for the pH/DO correctly showed 15-minute holding times (photo 7). The EPA team also observed the bench sheets for Escherichia Coli (E.coli), DO, and Biochemical Oxygen Demand (BOD5 - photos 6 and 8). Mr. Hooten showed us the E. coli testing equipment and stated that the test is conducted for WWTP effluent and wetland samples. He stated that the incubator and refrigerator temperatures are checked daily. A Hach DRB200 instrument is used for Chemical Oxygen Demand (COD) and phosphorus analysis. He also mentioned that the WWTP lab conducts COD analysis for the waste waters from septic haulers. Mr. Ferguson noted that January through February 2022 BOD5 bench sheets regularly showed over-depletion and under-depletion. Mr. Rhoads and Mr. Hooten responded that they have changed the sample volume and have corrected the issue by consulting with Mr. Shelton. Mr. Ferguson confirmed that the March 2022 bench sheets had rectified this issue. 4 Phosphorus Treatment: The 2018 permit included a new effluent limit of 1.0 mg/L for phosphorus. Mr. Shelton stated that the compliance schedule requires Washington to comply with the 1.0 mg/L for phosphorus limit no later than June 30, 2021. In February 2020, IDEM approved a construction permit for improvements to the existing treatment plant to achieve phosphorus removal. By March 2021, Washington added a poly-aluminum chloride storage room (housed in the new office building) with metering pumps designed to deliver polyaluminum chloride to the oxidation ditch treatment train (via the secondary clarifier splitter box) and the SBR treatment train (via a pump station) in order to chemically precipitate phosphorous. Mr. Patel asked, and Mr. Shelton confirmed that there is no spill containment area since the two polyethylene tanks (used as an alternate to each other) are double walled (photo 9). The team noted a control panel for the phosphorus treatment line in the same room (photo 10). In March of 2021, the facility began adding poly-aluminum chloride for phosphorus reduction, with a goal to comply with the 1.0 mg/l phosphorus limit by June 30, 2021. Mr. Shelton stated that he found an error in the labeling on the dosing control panel (photo 11). The facility didn't see any reduction in phosphorus for about eleven months (March 2021 through February 2022). He said that the facility had recently figured out the problem (February 2022) with the phosphorus removal chemical feed lines. There are two feeds lines from the chemical storage tanks to feed the two separate treatment trains in the plant (oxidation ditch treatment train and SBR treatment train). Mr. Shelton found out that the lines were backwards on the dosing units, and they had been trying to adjust dosing for the past 11 months without any results because the metering pumps were sending the poly-aluminum chloride incorrectly. Since correcting the dosage lines, the facility was in compliance for phosphorus for March 2022 (Attachment III lists effluent exceedance for all of 2021 and first 3 months of 2022). Oxidation Ditch Treatment Train (Old Plant): The EPA and IDEM team began the walkthrough of the plant with Mr. Rhoads and Mr. Shelton and continued discussion about the facility's general operations. Next, EPA observed the screening and grit removal in the headworks (photo 15). The facility measures its influent flow volume before the flow goes to the screening and grit removal (Parshall Flume - photo 14). The aerated grit removal unit has both influent and effluent Parshall flumes with ultrasonic level detectors. Comminutor/Screening at the headworks consists of an all-in-one grinder, fine screen, and auger compactor unit. The primary lift station has four submersible pumps that convey headworks effluent to the pre-aeration tank. Ms. Zurcher noticed a potential bypass pipe at the headwork leading towards the south side of the facility. Ms. Zucher and Mr. Shelton walked the length of the pipe into an area outside of the facility grounds and reported that it was a bypass pipe designed to transfer water from the headworks to Hawkins Creek. This pipe's inlet opens to a small pit type area adjacent to a sluice gate (photo 13). EPA observed that no water was flowing through the pipe at the time of the inspection and Mr. Shelton stated that the gate has been held in a closed position for past several years to block any headwaters from entering the pipe and discharging to Hawkins Creek. Mr. Patel asked but Mr. Shelton did not have the information on when this pipeline was removed from service We also observed a closed gate with a manual rake for picking up trash. There was stagnant water at the bottom. Mr. Shelton mentioned that this is an old process line and can still be 5 brought online as a backup for maintenance if the trash collector is offline. According to Ms. Zurcher, the grit collection was taken offline about 2 years ago. The tour continued to the headworks' pumphouse and control room. Mr. Rhoads stated that the augur was not in operation and hence the grit wasn't being conveyed to a dumpster located behind the pump house on the day of the inspection. He mentioned that a vacuum truck was scheduled to pick up the grit from the dumpster later that day. The tour proceeded towards the primary aeration tank for the raw wastewater. Mr. Shelton stated that the old plant influent samples are taken after the aeration basin right before the splitter for the primary clarifiers (photo 17). Ms. Dooling asked, and Mr. Shelton responded about the flow to the offsite equalization (EQ) basin. During heavy rainfall events, the WWTP personnel can direct some portion of the influent to the EQ Basin. Following a rainfall event, the wastewater in the EQ Basin is directed back to the headworks of the facility. The EPA team did not tour the EQ basin as a part of this inspection. Mr. Shelton stated that each primary clarifier receives 50% of the incoming wastewater flow. After the primary clarifiers, EPA proceeded to inspect the next treatment in the process trickling filters (photo 21). There are two trickling filters that had their nozzles cleaned recently as a part of facility's preventative maintenance program. These two identical filters discharge to the oxidation ditch (photos 22 through 26). A secondary lift station has four submersible pumps that convey trickling filter effluent to the aeration basin (oxidation ditch). Return Activated Sludge (RAS) is also pumped back to the oxidation ditch. Ms. Dooling observed black grease on the wall lining of the oxidation ditch (photo 23). The wastewater from the oxidation ditch is pumped to the two final (secondary) clarifiers, 1) one 50foot diameter and 2) one 70-foot diameter clarifier, which receive 1/3 and 2/3 of the flow respectively. Phosphate is dosed at the splitter (photo 28). In mid-February this year, one of the sweeper arms broke on the 50-foot clarifier and it was not returning the sludge properly. Mr. Shelton stated that this may have caused a temporary spike in the ammonia levels in the effluent. This clarifier was fixed, cleaned, vacuumed and brought back online in late March. Despite its recent cleaning and servicing, the 50-foot clarifier had some algae built up in the center ring and on the effluent weirs (photo 31). The 70-foot clarifier was cleaned on the morning of the EPA inspection, and it did not show algae build up around its effluent weirs (photo 32). Mr. Rhoads stated that these final clarifiers were wasted only threetime last month and the facility's goal is to waste daily. The tour continued to the disinfection area of the facility. The facility had used traditional chlorine disinfection for many years. Mr. Shelton stated that the facility switched to using an Ultraviolet (UV) light bank (Trojan UV 3000 Plus) during early 2019 to comply with the permit requirements. There are two light banks, each bank has 8 rows of 8 lights for 64 lights per bank (photos 33 and 34). The two light banks operate in series. The UV system controller shows two rows that are not operational (photo 40). Mr. Rhoads stated that the HP Thompson company was here at the beginning of the season to perform the service on the UV lights. The UV lights run April 1st through October 31st. The electromagnetic flow meter is housed after the second UV 6 light bank (photo 35). The weir is adjustable to ensure that the light banks are submerged. The flow meter adjusts to the weir height. From the UV disinfection structure, EPA observed Outfall 001 to Hawkins Creek and the cascade aeration before Outfall 001 (Photos 37 and 38 ). EPA did not observe any rags at the Outfall 001 or in the cascade aeration. While near Outfall 001, EPA observed the DO meter, temperature meter and effluent flow meter (Photo 35). We observed some foam on the effluent discharge to Hawkins Creek (photo 39). There are two gates that regulate the flow of incoming water to the UV disinfection system; one is open and the other is closed (photo 41). Ms. Dooling asked, and Mr. Shelton stated that one is the pipe from the original plant that has since been sealed off, but the hole is still there. Mr. Patel requested records to show that it has in fact been sealed. Sludge Treatment Train: The Aerobic Sludge digestor consists of a 20-foot diameter stilling well for gravity thickening. The facility has two round shaped sludge digestors (photo 27) and four (4) square shaped sludge digestors (serving as "secondary digestors" - photos 52 through 56). Sludge from the primary clarifier is sent to the round sludge digesters. The two (2) round sludge digesters are not connected to each other. Mr. Patel asked, and Mr. Shelton clarified that water can be routed from the primary clarifiers to the secondary square digesters in the event primary sludge digestors are down for maintenance or repair. The tour then progressed to the square secondary digesters. We noticed foam on the surface of the square sludge digesters (photo 54). The square sludge digesters receive the wastewater after the sludge is digested in the two round digesters. Wastewater from the square digestors is pumped to the sludge centrifuge for dewatering and eventual land application. Mr. Shelton informed us that the mixers in square digesters 1 and 2 were not working at the time of the EPA inspection. He said that the new mixers are at the facility and would soon be installed. We ended our tour at the building that houses mechanical dewatering and a centrifuge conveyor for sludge disposal by trucks. The existing sludge processing unit is a temporary one while the permanent stationary system is being repaired. The temporary system consists of PRAESTOL Polymer used for sludge thickening which is supplied through a hose from an external tote into the centrifuge building for mixing with the sludge. We observed a minor spill and a dead bird around the polymer tote (photo 60). Mr. Shelton stated that the large centrifuge conveyor is offline since early December 2021 and Washington has contracted Merrell Brothers with a temporary belt press and trucking services to perform the daily dewatering and disposal offsite (photos 57 and 61). Mr. Shelton stated that they are waiting on the proper parts for piping connections and the facility expects the conveyor to be operational in a month. He showed us the new conveyor installed in place (photos 58 and 59) and the facility is waiting to complete the last step of connecting the flanges/piping. The conveyor is new, but it mistakenly arrived with a wrong 3" line, whereas the existing line is 6" in diameter. Wastewater from the sludge dewatering gets pumped back to the old plant's headworks for treatment. Currently, the wastewater is pumped (from the Merrell Brothers truck) using a hose to a manhole, which goes to headworks. 7 Sequential Batch Reactor (SBR) Treatment Train: The tour continued to the SBR headworks located on the north side of the plant which was not in operation at the time of this inspection. Three submersible pumps convey raw sewage flow from the headworks located just north of the new administration building, where effluent from the Perdue Poultry Processing facility and a small amount of sanitary waste from the northwest corner of the city enters the SBR treatment train. Mr. Shelton stated that the headworks has been offline since last fall because the SBR system is offline. He also mentioned that there is a provision for overflow to flow into a diversion manhole, which is connected to the main plant lift station. Since the SBR train is offline, the entire plants influent is routed through the oxidation ditch train. Mr. Shelton stated that Aqua Aerobics constructed the SBR (AquaSBR) and had recently estimated approximately $1.5 million to repair nine diffusors and other SBR auxiliaries to bring the SBR back to normal operation. There are total of twelve diffusers in the SBR and 3 were in working condition at the time of inspection. There are two main sludge pumping stations that have faulty valves and corroded pumping assembly that make them inoperable since late November last year. Mr. Shelton took us to the SBR control room to inspect the corroded SBR splitter valve (photo 46) and damaged sludge line valve (photo 47) that opens the sludge for wasting. Mr. Shelton added that a large volume of untreated idle water in the SBR for the past six months has created a major equipment repair challenge for Washington, that is costly and burdening the only functioning treatment train - the oxidation ditch. He also mentioned that the lack of adequate preventative maintenance at the SBR may have resulted in the heavy scum buildup that the EPA team observed at the headworks (photos 42 through 44). Ms. Dooling noted that there is missing influent data from the middle of June 2021 through first half of July 2021 for the SBR influent. Mr. Rhoads could not definitively state the rationale for the missed influent data. He speculated that it could have been one of the times that the pump hoses at the SBR headworks went down. He stated that hoses have been going down periodically. Some hoses have been purchased but not installed. The hoses would clog and cut suction, which leads to a high-pressure alarm on the blower going off and trigger a facility response. Mr. Rhoads also mentioned that there have been intermittent issues on the SBR pumps. When Mr. Shelton joined the WWTP team last November, these pumps were not operational. He experimented with the SBR pumps and would shut down the SBR pumps when he left for the day. He stated that the SBR pumps and auger were causing problems in the past. The auger had been down since IDEM's last inspection (December 2020). The auger got fixed a couple of months ago. All pumps work now (one pump got repaired and two were newly installed). Mr. Rhoads stated that the SBR blowers and augers are working now. Mr. Halbert temporarily turned on the SBR blowers to show the air mixing in one of the SBR reactors for a few minutes at the inspection. Since nine out of the twelve diffusors are not working, the facility is not using the SBR until all diffusors are functioning. Mr. Shelton stated that the city has asked Midwestern Engineering to prepare a bid for the SBR repair job. 8 Mr. Shelton escorted us to the SBR control room where we saw a large control panel with controls for wasting, influent and effluent (photo 48) flow measurement. He explained that these controls communicate with the SCADA system. On the new blower for the SBR (photo 49), we observed some oil residue on the ground pad. Mr. Rhoads stated that the new blower started leaking oil when it was turned on initially and the facility contained the blower pad area with an oil-dry to prevent it from releasing onto the facility grounds. Two of the three blowers (photo 50) were functioning at the time of the inspection. Mr. Shelton mentioned that the facility is working to repair the one offline blower this summer; however, Washington's 2021 annual pretreatment report to IDEM mentions early 2023 for the SBR system to come back online. Ms. Zurcher noted an open manhole near the SBR system (photo 51). Facility staff was unsure of the duration the manhole was left open. Ms. Zurcher mentioned that an open manhole could pose a safety hazard. Mr. Shelton stated that the manhole site might be the site of an autosampler installation to help the facility determine its waste activated sludge (WAS) rate. Closing Conference We began the closing conference at 1:30 pm with Councilman Dahl and Operator Mr. Halbert. Ms. Zurcher and Mr. Ferguson of IDEM were present at the closing conference. We discussed the following areas of concern: 1. Permit Part II.B.1.e - Management Requirements For Facility Operation, Maintenance and Quality Control, requires that the permittee is responsible for providing adequate funding for and oversight of the wastewater treatment plant and collection system to ensure proper operation, maintenance, management, and supervision. Washington has had routine equipment failures including the SBR blowers, diffusors, sludge dewatering centrifuge conveyor, and secondary clarifier's sweeper arms. 2. Federal General Pretreatment regulations 403.17 (d) prohibits bypass (intentional diversions of waste streams from any portion(s) of the industrial user's facility treatment facility. The wastewater treatment bypass at the old plant headworks (where the facility has the ability to open the sluice gate at headworks) could be used to discharge wastewater without any treatment, through a pipe which opens towards Hawkins Creek. 3. Permit Part III.B.1.c.6 requires that the Permittee shall have the legal authority to impose fees, if necessary to offset the costs incurred by the Permittee for administrating the pretreatment program requirements. It was explained that Washington City Council had tried to adjust the surcharge commensurate with the industrial user's discharge volumes and pollutant loading in 2019, but ultimately the fees had not been adjusted in the last 30 years. 4. Permit Part III.B.1.a.5 - Program Development Requirement - A user of the POTW, whether or not the user is subject to national categorical standards or state, local, or any other national pretreatment standard or requirement, shall not allow the introduction of 9 the pollutant into the POTW at a flow rate or pollutant concentration that could cause interference in the POTW. 40 Code of Federal Regulations (CFR) 403.5 (a)(1) states that an industrial user may not introduce any pollutants into the POTW which cause Pass Through or Interference and 40 CFR 403.5 (b)(4) states that an industrial user may not introduce to the POTW any pollutant, including oxygen demanding pollutants, that is released in a Discharge at a flow rate or pollutant concentration which will cause Interference with the POTW. Washington has not been in regular communication with its industrial users to ensure that wastewater loading does not create pass through or cause interference at the POTW. In addition to the above areas of concerns, Mr. Patel discussed the benefits of having an Asset Management Plan for its POTW. Having such a plan in place could help Washington allocate and set-aside funds for the WWTP's capital improvement projects based on priority of repairs/replacement. It also helps establish an efficient preventative maintenance plan, housekeeping, and management program to reduce costs associated with repairs/replacement and to extend infrastructure assets' useful operating life. The EPA team received the following documentations during the closing conference: 1. Facility's Piping Site Plan from October 2006 2. SBR influent flow and Food-to-Mass Ratio (F/M) data for 2021 3. Food-to-Mass Ratio and NH3-N data for the old plant train from 1/1/21 to 4/8/22 4. Square sludge digesters daily sludge inventory data from 10/28/21 through 4/8/22 5. Biosolids generated for the period 1/1/21 through 3/31/22 6. Merrell Brothers sludge handing data from 12/2/21 through 4/11/22 7. Washington WWTP violations for the period 1/1/21 through 3/31/22 We ended the closing conference and departed the facility at 2:30 pm. Upon reviewing the above listed documents received after the inspection, EPA identified an additional area of concern. The SBR system is designed to treat a maximum of an average 13.3 mg/L of ammonia-nitrogen in its influent according to the Aqua SBR Design Summary (attachment V). For an eight-month period in 2021 (February through September), the SBRs average ammonia-nitrogen influent levels were at 42.5 mg/L (attachment IV), which is substantially higher than the design capacity. List of Attachments I. Inspection photographs II. Site Map III. Effluent exceedances (January 2021 through March 2022) IV. 2021 Influent Pollutant loading to the Old Plant Train and SBR Train V. Aqua SBR Design Summary VI. WWTP Piping Site Plan 10 Wastewater Treatment Facility, 169 South 200 West, Washington, IN EPA Inspection April 12-13, 2022 All photos taken by Valerie Dooling, Environmental Engineer, U.S. EPA Camera: RICOH WG-4 GPS All times in Central Time Zone 1: WASH0154 Description: Laboratory equipment and refrigerator Location: Laboratory Date/Time: April 12, 2022, 1:33pm 2: WASH0155 Description: Calibration and Sampling Analysis area Location: Laboratory Date/Time: April 12, 2022 - 1:39pm 3: WASH0156 Description: Eye washing station Location: Laboratory Date/Time: April 12, 2022 - 1:40pm 4: WASH0157 Description: Sample preservation refrigerator Location: Laboratory Date/Time: April 12-13, 2022 - 1:40pm 5: WASH0158 Description: Sampling analysis area Location: Laboratory Date/Time: April 12, 2022 - 1:41pm 6: WASH0159 Description: pH bench sheet Location: Laboratory Date/Time: April 12, 2022 - 1:56pm 7: WASH0160 Description: pH/DO bench sheet Location: Laboratory Date/Time: April 12, 2022 - 1:59pm 8: WASH0161 Description: E. coli bench sheet Location: Laboratory Date/Time: April 12, 2022 - 2:01pm 9: WASH0162 Description: Poly-aluminum chloride storage tanks - double walled polyethylene - Phosphorus treatment tanks Location: New one-story building that houses lab/chemical storage/offices Date/Time: April 12, 2022 - 2:06pm 10: WASH0163 Description: Control Panel for Phosphorus treatment dosage Location: New one-story building that lab/chemical storage/officies Date/Time: April 12, 2022 - 2:07pm 11: WASH0164 Description: Metering pumps for Phosphorus treatment dosing Location: New one-story building that houses lab/chemical storage/offices Date/Time: April 12, 2022 - 2:09pm 12: WASH0165 Description: Aerated Grit Chamber Location: Old plant headworks Date/Time: April 12, 2022 - 2:15pm 13: WASH0166 Description: Bypass concrete channel with pipe at the bottom that drains to the ditch just south of the headworks. Location: Old plant headworks Date/Time: April 12, 2022 - 2:18pm 14: WASH0167 Description: Parshall Flume and flow measurement device Location: Old plant headworks Date/Time: April 12, 2022 - 2:24pm 15: WASH0168 Description: Aerated Grit Chamber Location: Old plant headworks Date/Time: April 12, 2022 - 2:25pm 16: WASH0169 Description: Raw sewage pre-aeration Location: Aeration basin Date/Time: April 12, 2022 - 2:35pm 17: WASH0170 Description: Spiltter after aeration basin - before the two primary clarifiers Location: Aeration basin spillter tank Date/Time: April 12, 2022 - 2:35pm 18: WASH0171 Description: Primary clarifiers Location: Standing near Aeration Splitter - looking towards the clarifiers Date/Time: April 12, 2022 - 2:35pm 19: WASH0172 Description: View of final clarifiers Location: Aeration basin Date/Time: April 12, 2022 - 2:37pm 20: WASH0173 Description: Primary clarifier Location: Edge of the Primary clarifier Date/Time: April 12, 2022 - 2:42pm 21: WASH0174 Description: Trickling filter Location: Edge of the Trickling filter Date/Time: April 12, 2022 - 2:45pm 22: WASH0175 Description: Oxidation ditch Location: On the top platform of the Oxidation ditch Date/Time: April 12, 2022 - 2:48pm 23: WASH0176 Description: Oxidation ditch Location: On the top platform of the Oxidation ditch Date/Time: April 12, 2022 - 2:48pm 24: WASH0177 Description: Oxidation ditch Location: On the top platform of the Oxidation ditch Date/Time: April 12, 2022 - 2:48pm 25: WASH0178 Description: Oxidation ditch Location: On the top platform of the Oxidation ditch Date/Time: April 12, 2022 - 2:50pm 26: WASH0179 Description: Oxidation ditch Location: On the top platform of the Oxidation ditch Date/Time: April 12, 2022 - 2:51pm 27: WASH0180 Description: Round sludge digester Location: On a platform of the sludge digestor Date/Time: April 12, 2022 - 2:53pm 28: WASH0181 Description: Phosphate dosing at the spliter Location: Secondary splitter Date/Time: April 12, 2022 - 3:00pm 29: WASH0182 Description: Phosphate dosing at the spliter Location: Secondary splitter Date/Time: April 12, 2022 - 3:00pm 30: WASH0183 Description: 50-foot secondary clarifier Location: Secondary clarifier Date/Time: April 12, 2022 - 3:00pm 31: WASH0184 Description: 50-foot secondary clarifier. Note filter flies and alagae. Location: Secondary clarifier Date/Time: April 12, 2022 - 3:02pm 32: WASH0185 Description: 70-foot secondary clarifier. This clarifier was cleaned on the day of the inspection. Location: Secondary clarifier Date/Time: April 12, 2022 - 3:02pm 33: WASH0186 Description: First light bank at disinfection point Location: UV disinfection Date/Time: April 12, 2022 - 2:10pm 34: WASH0187 Description: Spare UV light bank Location: UV disinfection Date/Time: April 12, 2022 - 3:10pm 35: WASH0188 Description: Effluent flow meter Location: UV disinfection Date/Time: April 12, 2022 - 3:13pm 36: WASH0189 Description: Effluent sample location. Long pole for the collection of the effluent grab sample. Location: Discharge point Date/Time: April 12, 2022 - 3:18pm 37: WASH0190 Description: Effluent from the treatment plant flowing towards the Hawkins Creek. Location: Effluent Discharge Date/Time: April 12, 2022 - 3:18pm 38: WASH0191 Description: View upstream of the effluent discharge Location: Effluent discharge Date/Time: April 12, 2022 -3:18pm 39: WASH0192 Description: Effluent discharge point flowing towards the Hawkins Creek. Note foam on surface of the discharge water. Location: Effluent discharge point Date/Time: April 12, 2022 - 3:19pm 40: WASH0193 Description: Display showing light banks. Black squares are non-operational and red are failing. Location: UV disinfection Date/Time: April 12, 2022 - 3:19pm 41: WASH0194 Description: Pipe from influent that is sealed off (from older design). Upstream of the UV disinfection. Location: UV disinfection Date/Time: April 12, 2022 42: WASH0195 Description: Closed gate at the SBR headworks/influent point. Note scum buildup on surface. Location: SBR headworks Date/Time: April 12, 2022 - 3:33pm 43: WASH0196 Description: Other side of gate on photo 42 Location: SBR headworks Date/Time: April 12, 2022 - 3:33pm 44: WASH0197 Description: Closed gate at SBR headworks at the same location as Photos 42 and 43. Location: SBR headworks Date/Time: April 12, 2022 - 3:33pm 45: WASH0198 Description: SBR 1 - view from the ground Location: SBR - Northwest corner of the facility Date/Time: April 12, 2022 46: WASH0199 Description: Corrosion on the SBR splitter valves Location: SBR Control room and pumphose Date/Time: April 12, 2022 - 3:40pm 47: WASH0200 Description: Corrosion on the SBR sludge line valve Location: SBR Control room and Pumphose Date/Time: April 12, 2022 - 3:41pm 48: WASH0201 Description: SBR controls for wasting, influent and effluent - connected to SCADA system Location: SBR Control room and Pumphose Date/Time: April 12, 2022 - 3:42pm 49: WASH0202 Description: New SBR blower. Note oily residue under blower. Location: Adjacent to the SBR Date/Time: April 12, 2022 50: WASH0203 Description: Three SBR blowers. Middle blower with red and white encasing has been repaired and is functional. Right most blower with blue and white encasing is not functional. Location: Adjacent to the SBR Date/Time: April 12, 2022 - 3:44pm 51: WASH0204 Description: Open manhole near SBR. Potential site of sampler to help optimize WAS. Location: Adjacent to the SBR Date/Time: April 12, 2022 - 3:48pm 52: WASH0205 Description: Primary square digesters for the SBR. Currently used as secondary digesters for the oxidation ditch Location: Just east of the SBR Date/Time: April 12, 2022 - 3:49pm 53: WASH0206 Description: Square digester 4 Location: Square digesters Date/Time: April 12, 2022 - 3:52pm 54: WASH0207 Description: Square digester 4. Note foam on surface. Location: Square digester Date/Time: April 12, 2022 - 3:53pm 55: WASH0208 Description: Digesters 4 (bottom left), 2 (top left) and 1 (top right). Digesters 1 and 2 have malfunctioning mixers. Location: Square digesters Date/Time: April 12, 2022 - 4:00pm 56: WASH0209 Description: Same as photo 55 Location: Square digesters Date/Time: April 12, 2022 - 4:00pm 57: WASH0210 Description: Belt press rented from Merrell Bros. Wastewater from belt press is directed to headworks. Location: Sludge centrifuge building Date/Time: April 12-13, 2022 - 4:06pm 58: WASH0211 Description: Sludge centrifuge and new conveyor with 3" connection. Current piping is 6" line. Location: Sludge centrifuge building Date/Time: April 12, 2022 - 4:09pm 59: WASH0212 Description: End of centrifuge conveyor - currently not in operation Location: Sludge centrifuge building Date/Time: April 12, 2022 - 4:10pm 60: WASH0213 Description: Praestol polymer used for sludge belt operation. Note spilled chemical and dead bird in spilled area. Location: Just outside the sludge centrifuge building Date/Time: April 12, 2022 - 4:11pm 61: WASH0214 Description: End of the trailer that houses temporary sludge belt press Location: Outside of sludge centrifuge building Date/Time: April 12, 2022 - 4:13pm Sequential Batch Reactor 4 Square Sludge Digestors Attachment II - Site Map - Aerial view from Google Washington WWTP, 169 South 200 West, Washington, IN 47501 Two Identical Trickling Filters Oxidation Ditch New Office lab/chemical bldg 2 Round Sludge Digestors Primary Clarifiers Sludge Dewatering and Disposal bldg.. 50-feet and 70feet secondary (final) clarifiers Old Laboratory and office bldg Outfall 001 Ultraviolet (UV) Disinfection System Headworks - Grit Removal and Pump station "UUBDINFOU***&GGMVFOU&YDFFEBODFT 5 )'0 5 (1,45 ,1,45 , 5 +,!#5 45 1(5 1$4 11/05 +0%,5 0),5 *2&,5 %,5 )0#/5 5 )'0 5 '1,45 ,1,45 - 5 +.!#5 45 1'5 1#45 11/05 +0%,5 0),5 )2%,5 %,5 )0#/5  )5 )5 5 )5 "5 )5 5 )5 "5 25 535 25 "5 )525 35 25 35 25 35 25 35 + 5 %5 %5 #/5 35#/5 %5 %5 #/5 $/5 %5 %5 #/5 #/5 )525 %5  )5 )5  5 )5 "5 )5 5 )5 "5 25 535 25 "5 )525 35 25 35 25 35 25 35 )525 + 5 %5 %5 $/5 35#/5 %5 %5 #/5 #/5 %5 %5 #/5 #/5 %5 Attachment IV - IV.2021 Influent Pollutant loading to the Old Plant Train and SBR Train CBOD5 (mg/L) Influent from Monthly Reports TSS (mg/L) Ammonia as Nitrogen (mg/L) Phosphorus (mg/L) SBR Design Influent Date AS Design Capacity (per Construction Permit App) Combined SBR Average AS 165 Combine SBR d Average AS 117 297 Combined Combined SBR Average AS SBR Average 13.3 43 5 Feb-21 55 172 113.5 65 91 78 12.6 20.4 17 0.95 0.84 0.9 Mar-21 56 222 139 55 119 87 15.22 33.65 24 2.8 2.5 2.7 Apr-21 65 227 146 101 99 100 24.6 34.4 30 4 3.68 3.8 May-21 94 271 182.5 83 98 90.5 30.2 38.31 34 1.6 1.3 1.5 Jun-21 83 322 202.5 78 115 96.5 21.8 45.8 34 2 3.29 2.6 Jul-21 82 213 147.5 100 93 96.5 23.92 35.9 30 2.03 1.3 1.7 Aug-21 140 275 207.5 120 141 130.5 35.9 47.04 41 2.6 1.18 1.9 Sep-21 117 261 189 113 96 104.5 32.35 43.4 38 3 1.8 2.4 8 Month Avrage 42.5 mg/l BOD5 273 TSS 117 TKN 52.2 Nh3-N 13.3 SBR Design Effluent mg/l BOD 20 TSS 20 NH3-N 1.26 WWTP Design Influent mg/l CBOD 165 TSS 297 NH3-N 43 P 5 . . Attachment V - AquaSBR Design Summary AquaBR - Sequencing Batch Reactor Pr.oJect: Waahlngton WWrP, IN optlon: Plan and Specs Design Dulp4d by Ta'lll4rll Knapp on Tl1.11r1day,.A.11g111t JO, 2006 Design# 24776 DESIGN INFLUENT CONDITIONS Avg. Design Flow = 1.23 MG/Day Max. Dealgn Flow = 1.85 MG/Day Peak Hydraullc Flow = 2.592 MG/Day Blo/Cheinlcal Oxygen Demand: Total Suapended Sollda: Total KJeldahl Nitrogen: lllac. BODS TSS TKN NH3-N = 4649.4 CM/Day = 6993 CM/Day = 9797.8 CM/Day (with advancing cycles) Cone. 111gn 273 117 52.2 Mass lba.lDax 2800.5 1200.2 535.5 13.3 136.4 KG/Dax 1270.3 544.4 242.9 61.9 SITE CONDITIONS Ambient Air Temperature: Influent Waate Te111peraturea: Elavatlon (Mean Sea Level): Maximum 85 F 29.4 C 68 F 20 C 500 FT 152.4 M Minimum 30 F -1.1 C 50 F 10 C Dealgn 85 F 29.4 C 68 F 20 C EFFLUENT OBJECTIVES Blo/Cheinlcal Oxygen Demand: Total Suapended Sollda: Ammonia Nitrogen: BOD5 TSS NH3-N Cone. man 20 20 1.26 Mase lba./Dar 205.2 205.2 12.9 KG/Day 93.1 93.1 5.9 BASIN SIZING CALCULATIONS 1. Maaa of Blo-Sollda necaaaary for treatment (Iba IILSS) Based upon an F/M ratio of 0.082/Day, the mass of mixed liquor suspended solids (MLSS) is: lbs. MLSS= (lbs. BOD5/Day) / (F/M)= 34134.3 lbs. MLSS = (15483.1 KG) 2. Total Reactor Volume at Low Level (Vlwl0T) Based upon an MLSS concentration of 3500 mg/I measured at the lowest water level, the total React Volume at low water level (Vlwl) is: Vlwl-T= lbs. MLSS/(MLSS mg/Ix 8.34 lbs./GAL)= 1.169 MG-Total= 156334.8 CF-Total = (4426.9 CM-Total) 3. Reactor Volume for each Basin at Low Level (Vlwl/baeln) The AquaSBR shall utilize a 2 reactor system. The resultant unit volume for each reactor at the minimum water depth is: VlwVBasin= (Vlwl-T)/(Number of Reactors)= 0.585 MG/Basin= 78167.4 CF/Basin= (2213.5 CM/Basin) Aqua-Aerobic System, Inc. CONFIDENTIAL Printed On: 8/23l200910:41:31 All Paga 5 of 13 -- j i I I I I I Attachment VI _ WWTP Piping Site Plan .... -----, --=---, 458.31" 0 INV. 460.5' V. 4 8.79' I 0 I I \ EXISTING TRICKl.lNG FILTERS N<>, 2 MAINTENANCE SUILOING 1i;:j I ' I I ' \ ii I I I ITEM TOP OF INFLUENT ,.. 4-73.S' I ,.. 465.0' ,.. 465.0' ,.. 465.0' ,.. '\.62.0' I 460.0' ,s I I I\. \I I I NOTES: I.) SITE IPING SHALL BE S SPECIFIED I i;9 PIPING SHALL AVE A MINIMUM 2.) pG FOLLOWS, = .oe,: a = .40% CON;T 'fY; 6," 0.1 6. = .617. DPoIPPIP- E E- ISTING s II .\ (S) 4" UNDERDRAINS IN I EACH BED I \ LEGEND PROPOSED PIPING EXISTING SEWER EXISTING WATEA MAIN EXISTING STORMSEWER EXISTING GAS MAIN EXISTING TANK DRAIN EXISTING POWER POLE EXISTIN,...,, MANHOLE ' 0 PROPOSED MANHOLE EXISTING YARD HYDRANT EXISTING VALVE PROPOSED VALVE DNEO: RECORD OEEDR ECORD 63, 67, ::GaeE 1137 332 "'-;. f% Il'a(. QJ'< - 'f-fs= 18887 \ l '?,. --'.'Ao J 10/06/06 DATE OCTOBE.::;: 2006 DESIGN OLD/SLH DRAWN SLHIADS \l,C O<cCK 20062.3 PIPING SITE PLAN I \I Fl NUBER 11