Document MMrKbYYKJYdzbOn3gJoppD0Kx

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION III 1650 Arch Street Philadelphia, Pennsylvania 19103-2029 Report Title: Inspection Date(s): Regulatory Program(s): Type of Activity: Facility Name: Permittee(s): Facility Operator: Permittee Address: Facility Address: Facility Latitude: Facility Longitude: County/Parish: Permit No: NAICS Code: SIC: Unique Project #: Clean Water Act Compliance Inspection Report 08/25/2021 National Pollutant Discharge Elimination System (NPDES) Municipal Wastewater Treatment Slatington Wastewater Treatment Plant Slatington Borough Authority Slatington Borough Authority 125 South Walnut Street, Slatington, PA 18080 900 Railroad Street (Route 873), Slatington, PA 18080 40.760150 -75.607470 Lehigh County PA0020176 221320 4952 3E21WN141A Facility Representative(s): Point of Contact Kenneth Fulford Email: dolesluj@hotmail.com Duane Szczesny Email: dszczesny@slatington.org Joe Wechsler Email: jwechsler@slatington.org EPA Inspectors: Mike Greenwald EPA Region III Phone: (215) 814-2398 Email: Greenwald.Michael@epa.gov Kaitlin McLaughlin EPA Region III Phone: (215) 814-2393 Email: McLaughlin.Kaitlin@epa.gov State/Local Inspectors (see report body for list of additional inspectors): Patrick Musinski Email: pmusinski@pa.gov Report Preparer Signature/Date Supervisor Signature/Date Unique Project#: 3E21WN141A Mike Greenwald, Enforcement Officer NPDES Enforcement Section (3ED32) MARK ZOLANDZ Digitally signed by MARK ZOLANDZ Date: 2021.10.29 07:39:20 -04'00' Mark Zolandz, Acting Chief NPDES Enforcement Section (3ED32) Date 10/29/2021 Date Slatington Wastewater Treatment Plant 08/25/2021 Section Table of Contents Page I 3 A Inspection Opening Conference...................................................................... 3 B Weather and Precipitation Conditions............................................................. 3 II Facility Activity............................................................................................... 4 III Observations.................................................................................................... 4 IV Records Review............................................................................................... 10 V Closing Conference......................................................................................... 10 VI List of Attachments.......................................................................................... 11 Unique Project #: 3E21WN141A Page 2 of 11 Slatington Wastewater Treatment Plant 08/25/2021 I. Introduction On August 25, 2021, an inspection team composed of staff from the U.S. Environmental municipal wastewater inspection of the Slatington Wastewater Treatment Plant. The purpose of the inspection was to observe compliance with the Clean Water Act (CWA) and to verify compliance with the facility National Pollutant Discharge Elimination System (NPDES) Permit No. PA0020176 egulations. A. Inspection Opening Conference The EPA Inspection Team arrived at the site at est. 10:00 AM. Representatives from the Pennsylvania Department of Environmental Protection (PADEP) were in attendance. The following inspectors and representatives were present for the inspection: Name Mike Greenwald Kaitlin McLaughlin Kenneth Fulford Duane Szczesny Joe Wechsler Patrick Musinski Scott Confer Kelsey Glavich Table 1: Inspection Attendee List Affiliation Telephone Email EPA Region III Inspectors and Contractors EPA Region III (215) 814-2398 Greenwald.Michael@epa.gov EPA Region III (215) 814-2393 McLaughlin.Kaitlin@epa.gov Facility Representatives K.L. Fulford - dolesluj@hotmail.com Associates, Inc. Slatington Borough - dszczesny@slatington.org Operator Slatington Borough - jwechsler@slatington.org State or County Representatives PADEP - pmusinski@pa.gov PADEP - scconfer@pa.gov PADEP - kglavich@pa.gov Mike Greenwald and Kaitlin McLaughlin displayed their credentials to the site representatives at the outset of the inspection, and explained the purpose of the inspection was to observe compliance with its Permit. A copy of the Permit is provided in Attachment 1. B. Weather and Precipitation Conditions During the inspection, weather was clear. The closest 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. Unique Project #: 3E21WN141A Page 3 of 11 Slatington Wastewater Treatment Plant 08/25/2021 Table 2. Precipitation Data Station Name Date SCHNECKSVILLE 1.7 ENE, PA US US1PALH0017 SCHNECKSVILLE 1.7 ENE, PA US US1PALH0017 SCHNECKSVILLE 1.7 ENE, PA US US1PALH0017 SCHNECKSVILLE 1.7 ENE, PA US US1PALH0017 SCHNECKSVILLE 1.7 ENE, PA US US1PALH0017 SCHNECKSVILLE 1.7 ENE, PA US US1PALH0017 8/20/21 8/21/21 8/22/21 8/23/21 8/24/21 8/25/21 Precipitation Amount (inches)1 T 0.00 0.53 2.65 T 0.0 II. Facility Activity 900 Railroad Street (Route 873), Slatington, PA 18080. The Permit identifies the permittee as Walnut Street, Slatington, PA 18080. The facility receives influent flows from a service area that includes Slatington Borough and adjacent municipalities, including Washington Township, Walnutport Borough, and Lehigh d LCA system is maintained by Slatington Borough through an agreement with the Authority. The adjacent municipalities perform operation and maintenance of their own pump stations and collection systems. The permitted capacity of the facility is 1.5 MGD, with an average flow of 0.7 MGD. The facility treatment process consists of a Hycor Helisieve and bar screens, two primary clarifiers, two trickling filters, two secondary clarifiers, and two chlorine contact tanks with being modified, as originally the facility had two anaerobic digesters and reed beds. The facility is in the process of modifying the anaerobic digesters into aerobic digesters, while the reed beds are not currently being utilized. Additional details are listed in the observations section of the report. III. Observations The inspection observations below are made pursuant to the requirements of the Permit. Photographs were taken during the inspection by Kaitlin McLaughlin and are provided in Attachment 2. Facility Operation The facility representatives stated that there are two full-time operators on-site. Operators are on-site Monday through Friday, on every other weekend, and on call through a 24/7 emergency hotline. The lead operator has a Class A,E, Wastewater & Subclass 1,2,3,4 1 Source: NOAA National Climatic Data Center (http://www.ncdc.noaa.gov/). Unique Project #: 3E21WN141A Page 4 of 11 Slatington Wastewater Treatment Plant 08/25/2021 certification. The second operator has a Class A,E, Wastewater & Subclass 2,3,4 certification. The facility also provided certificates for a backup operator (who the facility representatives indicated had operated the WWTP on several days that year), as well as for 3) or before January 1, 2009, Slatington Borough Authority shall have employed or cause to be employed two full time certified wastewater system operators and one full time laborer, dedicated to the operation of the STP [sewage treatment plant], to ensure proper operation of th The CO&A includes the following in section 3.d: On or before July 1, 2020, Slatington Borough Authority shall have employed or cause to be employed three full time certified wastewater system operators dedicated to the operation of the STP, to ensure proper Observation 1. The EPA Inspection Team observed that sufficient documentation had not been submitted to the State to demonstrate that three operators are employed full-time to ensure proper operation of the facility. The 2008 CO&A has not been terminated by the State and is considered ongoing in part due to this requirement not being fulfilled. The facility representatives stated that relevant documentation and hands-on training is provided to new operators, but there is not a formal training program in place at the facility. The facility representatives stated that current operation and maintenance plans and standard operating procedures (SOPs) utilized by the WWTP to ensure NPDES compliance have recently been updated and 2008 CO&A was to submit to PADEP a written Environmental Management System requirements for the EMS included, in part, detailed SOPs for all NPDES processes that affect permit compliance, schematics for processes, process control sampling, a wet weather operation strategy, a sampling and monitoring plan, a preventative maintenance plan, a safety plan, and a staffing plan, among other items. This EMS was submitted to PADEP on January 31, 2020. This EMS was not reviewed as part of this inspection. The facility currently does not have an electronic work order system. The operator keeps daily written logs onsite of all activities onsite, which includes notes regarding weather, sample collection, maintenance items, and orders made, among other items. Daily logs were reviewed for June-August 2021. The facility representatives stated that major maintenance activities are contracted out. The facility conducts process efficiency testing. Monthly grab samples are being taken at the Trickling Filters, Primary Clarifiers, and Secondary clarifiers and analysis is being conducted for CBOD5 and TSS. Unique Project #: 3E21WN141A Page 5 of 11 Slatington Wastewater Treatment Plant 08/25/2021 The facility has an on-site lab, where the facility conducts analyses for pH, Total Residual Chlorine (TRC), and Dissolved Oxygen (DO). The pH and TRC analyses are conducted for the Permit effluent discharge monitoring requirements in Part A. The Hach Colorimeter test kit used for TRC analysis was replaced with a low range unit in response to previous inspection of the facility in 2016 (see Attachment 4). Flow measurements are recorded daily on bench sheets for the influent & effluent flows, as well as for all three of the pump stations. Samples for 5-Day Carbonaceous Biological Oxygen Demand (CBOD5), Total Suspended Solids (TSS), and Fecal Coliform testing are sent off-site to Suburban Testing Labs for analysis. Calibration records were provided for the Slatington Pump Station flow meter, as well as the influent and effluent flow meters, which were conducted by Moyer Instruments, Inc. on 7/1/2021. bench sheets. Collection System Maintenance The facility representatives stated that the Slatington Pump Station is inspected daily. The Slatington Pump Station is serviced by contractors. Walnutport Township and Washington Slatington Borough, and the facility representatives stated that the townships are responsible for their own pump stations. The foreman of the roadcrew is responsible for collection system maintenance. He also responds when Sanitary Sewer Overflows (SSOs) occur and prepares 1-hour notifications and 5-day reports. In a June 28, 2019 letter to EPA (see Attachment 5), Slatington Borough identified Infiltration and Inflow (I&I) projects completed between 2009 and 2011. Slatington Borough indicated that approximately 80% of the intra-Borough sewer collection system was rehabilitated, including replacement of 29,000 f manholes rehabilitated. The facility representatives stated that a preventative maintenance program is ongoing in the collection system, wherein 10% of the sewer system is closed-circuit televised annually over a 10-year period. Discharge Monitoring Reports The EPA Inspection Team reviewed Discharge Monitoring Report (DMR) data from a period of August 2016 to July 2021. Section A.1 of the Permit defines effluent discharge limitations, monitoring, and reporting requirements for Outfall No. 001. Observation 2. Three effluent limit discharge exceedances were identified at Outfall 001 for the time period of August 2016 to July 2021. These included exceedances of the 25 mg/L monthly average CBOD5 limit on 3/31/2018 (26 mg/L), on 2/29/2020 (28.1 mg/L), and on 2/28/2021 (31.9 mg/L). Unique Project #: 3E21WN141A Page 6 of 11 Slatington Wastewater Treatment Plant 08/25/2021 Sanitary Sewer Overflows The EPA Inspection Team requested a list of all SSOs that had occurred from 2019 to August 2021. Section B.I permittee shall at all times properly operate and maintain all facilities and systems of treatment and control (and related appurtenances) which are installed or used by the permittee to achieve compliance with the terms and conditions of this permit. Proper operation and maintenance includes, but is not limited to, adequate laboratory controls including appropriate quality assurance procedures. This provision also includes the operation of backup or auxiliary facilities or similar systems that are installed by the permittee, only when necessary to achieve compliance with the terms and conditions of Observation 3. Six SSOs in total were reported at the plant during the time period reviewed. SSOs occuring in the collection system are tracked and managed by a separate staff of Slatington Borough and were not reviewed as part of this inspection report. Facility representatives indicated that SSOs at the plant and the collection system are reported to the State as required. Four SSOs were identified as occuring at the Primary Clarifiers on 1/24/19, 4/13/20, 8/4/20, and 9/1/20. These overflow events are operator stated that a new software had been installed at the WWTP approximately one year prior to regulate the Slatington Pump Station to ensure flow changes would be more gradual during wet weather and prevent sudden surges in the system. The operator also stated that the facility had its effluent lines re-lined approximately five years prior to prevent bottlenecks. An SSO occurred at the Reed Beds on 5/13/19 and was described on rainwater from the under-construction digester to the reed beds. An SSO occurred at the digester on 10/25/19 and was described on the Clarifiers Section B.I permittee shall at all times properly operate and maintain all facilities and systems of treatment and control (and related appurtenances) which are installed or used by the permittee to achieve compliance with the terms and conditions of this permit. Proper operation and maintenance includes, but is not limited to, adequate laboratory controls including appropriate quality assurance procedures. This provision also includes the operation of backup or auxiliary facilities or similar systems that are installed by the Unique Project #: 3E21WN141A Page 7 of 11 Slatington Wastewater Treatment Plant 08/25/2021 permittee, only when necessary to achieve compliance with the terms and conditions of this pe Section A.III.B.1(Reporting of Monitoring Results) shall effectively monitor the operation and efficiency of all wastewater treatment and control facilities, and the quantity and quality of the discharge(s) as specified in this permit. 40 CFR 122.41(e) and 40 CFR 122.4 Observation 4. The EPA Inspection Team observed several occurrences of solids and sludge accumulation past the weir of Primary Clarifier #2. At the time of the inspection, the operator stated that these were due to a past rain event. See Photographs DSCN2157 and DSCN2159. Observation 5. The EPA Inspection Team observed uneven flows being distributed over the weir of the Secondary Clarifier #1. See Photographs DSCN2174 and DSCN2176. Observation 6. The EPA Inspection Team noted that the sludge blanket depth was not being recorded on daily logs for the clarifiers. The operator noted that these measurements are taken one to two times daily. Observation 7. The previous EPA Inspection Report from December 14, 2016 noted that the primary clarifiers in the system are not drained and cleaned. The facility representatives stated at the time of the 2021 EPA inspection that they do not perform this practice. Trickling Filters The facility representatives stated that past BOD exceedances have been in part due to winter weather causing reduced efficiency of the Trickling Filters. The operator noted that covers for the Trickling Filters are being designed by Ebert Engineering, but the implementation of these are dependent on funding. Digesters and Reed Beds The facility representatives stated that the two digester tanks are in the process of being modified into permanent aerobic digesters. At the time of the inspection, the primary digester was in operation, while the secondary digester was being utilized as a holding tank and the facility representatives stated it was empty. The facility representatives noted that the secondary digester will be used temporarily if the primary digester tank is in need of maintenance. permittee shall at all times properly operate and maintain all facilities and systems of treatment and control (and related appurtenances) which are installed or used by the permittee to achieve compliance with the terms and conditions of this permit. Proper operation and maintenance includes, but is not limited to, adequate laboratory controls including appropriate quality assurance procedures. This provision also includes the operation of backup or auxiliary facilities or similar systems that are installed by the permittee, only when necessary to achieve compliance with the terms and conditions of Unique Project #: 3E21WN141A Page 8 of 11 Observation 8. Slatington Wastewater Treatment Plant 08/25/2021 On April 30, 2018, a Water Quality Management Permit was issued by PADEP to approve the modification of the conversion of the existing primary anaerobic sludge digester into an aerobic digester (See Attachment 6). In a June 28, 2019 letter to EPA, the Slatington Borough Authority Solicitor noted that bids for the project to convert the primary digester had been awarded and a company was providing project management, including developing operational procedures into a Standard Operating Procedure (SOP) (see Attachment 5). The facility representatives provided verification of completion of work dated 1/13/20, which indicated that general construction was completed for the primary aerobic digester conversion project (see Attachment 7). At the time of the inspection, it did not appear that upgrades to the secondary digester had commenced. A memo prepared by Rettew Associates on November 30, 2012 (see Attachment 8) indicated that A report prepared by Schreiter Engineering Associates, Inc. dated September 2015 (see Attachment 9) indicated that the secondary digester tank h acceptable condition. The lid is severely tilted does not float properly is not used, but is scheduled to have the lid removed due to safety concerns, and that the project is funded and will go to bid. The facility representatives also indicated that there are not plans at this time to convert the secondary digester to an aerobic digester, as there is adequate capacity in the primary digester. At the time of the inspection, the operator stated that the reed beds are not currently being used and that all sludge is hauled offsite. The operator stated sludge is hauled offsite on Monday, Wednesday, and Friday, and records were provided of this activity for June-August 2021. The operator stated that the reed beds were not being used due to a number of considerations, including that the cost of hauling sludge was not prohibitive, the reed beds require consistent replanting when being operated, and that the leachate in the underdrain is pumped to the headworks which can increase the organic loading on the plant. Outfall 001 effluent is discharged to the Lehigh River through Outfall 001. The outfall was under water at the time of the inspection. oil, grease, scum, foam, sheen, and substances which produce color, taste, turbidity or settle to form deposits in concentrations or amounts sufficient to be, or creating a danger of being, inimical to the water uses to be protected or to human, animal, plant or aquatic Unique Project #: 3E21WN141A Page 9 of 11 Observation 9. Slatington Wastewater Treatment Plant 08/25/2021 The EPA Inspection Team observed that the outfall was difficult to access as it was overgrown with vegetation. The facility representatives indicated that the vegetation is not removed in order to limit public access to the outfall. IV. Records Review EPA requested and received copies of the following documents: Current WWTP process schematic Operator certifications Operator daily logs/round sheets for June 2021, July 2021 and August 2021 Most recent calibration records for NPDES compliance equipment (flow meters, pH meters, DO meters, etc.) Bench sheets for June 2021, July 2021, and August 2021 Sewage Sludge Management/Disposal Records for June 2021, July 2021 and August 2021 List of SSOs that have occurred from 2019-2021 Efficiency Testing and any other process control records for June 2021, July 2021, and August 2021 A copy of the report tilted: "Long Term Analysis for Disposal of Sludge" prepared by Schreider Engineering Associates, Inc. (SEA), dated September 2015 Records pertaining to the inspection report are attached, with additional records being kept on file. V. Closing Conference After the site walk, the EPA Inspection Team met with the site representatives for a closing conference. The EPA Inspection Team shared preliminary observations with the site representatives. The EPA Inspection Team reiterated to the site representatives that all preliminary observations discussed were not compliance determinations. Any and all preliminary observations shared were subject to further investigation by EPA 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 EPA reviewed additional materials following the inspection. The inspection concluded at approximately 2:00 PM. Unique Project #: 3E21WN141A Page 10 of 11 Slatington Wastewater Treatment Plant 08/25/2021 V. List of Attachments Attachment 1. Attachment 2. Attachment 3. Attachment 4. Attachment 5. Attachment 6. Attachment 7. Attachment 8. Attachment 9. NPDES Permit Photograph Log State CO&A dated 2008 EPA Inspection Report from December 14, 2016 CO&A response letter from June 28, 2019 WQM Permit for Digester Modification Verification of digester general construction completion Rettew Memo, 2012 Schreiter Digester Report, 2015 Unique Project #: 3E21WN141A Page 11 of 11