Document NE6eBGp0OQgXOyNzZoZ033G48

Report Title: Inspection Date(s): Regulatory Program(s): Type of Activity: Site/Facility Name: Permittee(s): Site/Facility Operator: Site/Facility Address: Latitude: County/Parish: Permit Number: NAICS Code: Unique Project #: Clean Water Act Compliance Inspection Report 09/27/2023 National Pollutant Discharge Elimination System (NPDES) Industrial Wastewater Eagle Valero GWCU Dunne Manning Realty LP Eagle Valero GWCU 37 Pottstown Pike Uwchlan, PA 19425 40.073611 Longitude: -75.683889 Chester PA0245119 811111 SIC: 7538 3E23WN123A Site/Facility Representative(s): Point of Contact Ben Andes, Synergy Environmental Inc. Phone: 484-369-5000 Email: bandes@synergyenvinc.com EPA Inspectors: Angela Weisel Phone: 215-814-2124 Shane McAleer Phone: 215-814-5616 Email: Weisel.angela@epa.gov Email: Mcaleer.shane@epa.gov Report Preparer Signature/Date Supervisor Signature/Date Weisel, Angela Digitally signed by Weisel, Angela Date: 2023.11.14 09:10:37 -05'00' Angela Weisel, Inspector NPDES Enforcement Section (3ED32) MARK ZOLANDZ Digitally signed by MARK ZOLANDZ Date: 2023.11.14 11:20:16 -05'00' Mark Zolandz, Section Chief NPDES Enforcement Section (3ED32) Unique Project#: 3E23WN123A 11/14/2023 Date 11/14/2023 Date Eagle Valero GWCU 09/27/2023 Table of Contents Section Page I Introduction................................................................................................................. 3 A Inspection Opening Conference...................................................................... 3 B Weather and Precipitation Conditions............................................................ 3 C Summary of the Facility.................................................................................. 4 II Facility Activity............................................................................................... 5 III Observations.................................................................................................... 6 IV Records Review............................................................................................... 9 V Closing Conference......................................................................................... 9 VI List of Attachments.......................................................................................... 10 Attachment A - Permit No. PA0245119 Attachment B - Photograph Log Attachment C - Exhibit Log Unique Project #: 3E23WN123A Page 2 of 10 I. Introduction Eagle Valero GWCU 09/27/2023 On September 27, 2023, an inspection team composed of staff from the U.S. Environmental Protection Agency ("EPA") Region III (hereinafter, "EPA Inspection Team") conducted an Industrial Wastewater Inspection of the Eagle Valero GWCU facility (hereinafter, "the facility") located at 37 Pottstown Pike, Uwchlan, PA, 19425. The purpose of the inspection was to observe compliance with the Clean Water Act (CWA) and to verify compliance with the facility's National Pollutant Discharge Elimination System (NPDES) Permit No. PA0245119 (hereinafter, the "Permit") and applicable State and Federal regulations. The permit became effective on September 1, 2019 and shall expire on August 31, 2024. A. Inspection Opening Conference The EPA Inspection Team arrived at the facility at est. 10:20 AM for the inspection. Inspectors met with the following facility representative: Name Angela Weisel Shane McAleer Ben Andes Table 1: Inspection Attendee List Affiliation Telephone Email EPA Region III Inspectors and Contractors Lead EPA Inspector 215-814-2124 Weisel.angela@epa.gov EPA Inspector 215-814-5616 McAleer.shane@epa.gov Site/Facility Representatives Synergy 484-369-5000 bandes@synergyenvinc.com Environmental Inc. Angela Weisel displayed her credentials to the facility representative 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 A. The EPA Inspection Team informed the facility representativethat any information that the facility deemed to be 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. B. Weather and Precipitation Conditions During the inspection, weather was overcast. 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 #: 3E23WN123A Page 3 of 10 Table 2. Precipitation Data Station Name Date UNIONVILLE 1.4 NNE, PA US, US1PACN0037 UNIONVILLE 1.4 NNE, PA US, US1PACN0037 UNIONVILLE 1.4 NNE, PA US, US1PACN0037 UNIONVILLE 1.4 NNE, PA US, US1PACN0037 UNIONVILLE 1.4 NNE, PA US, US1PACN0037 UNIONVILLE 1.4 NNE, PA US, US1PACN0037 9/22/2023 9/23/2023 9/24/2023 9/25/2023 9/26/2023 9/27/2023 Eagle Valero GWCU 09/27/2023 Precipitation Amount (inches) 0 0.4 0.35 0.3 0.25 0.15 C. Summary of the Facility The facility is a groundwater pump and treat system located at 37 Pottstown Pike, Chester Springs, PA 19425. The facility is owned by Dunne Manning Realty LP and operated by Eagle Valero GWCU; however, the system is managed by contractors from Synergy Environmental Inc. ("Synergy"). The treatment system is located inside of a small trailer on the property and is maintained twice a month during regular business hours, with additional visits occuring on an as- needed basis. Synergy has five employees that are trained to maintain the system, and typically only one or two employees would be needed to conduct the regularly scheduled operation and maintenance checks. There is a telemetry system installed onsite to alert site personnel if any issues occur. The treatment system was installed to treat groundwater contaminated by no. 2 fuel oil in 2005. Groundwater is collected from the area of the release and pumped up through one of three wells before passing through an oil-water separator. With gravity, water flows into a storage tank before entering through two bag filters and two carbon filters. Air is injected with a Mazzi air injector before being discharged to a nearby storm sewer drain, Outfall 001, which discharges to an unnamed tributary to Pickering Creek. At the time of the inspection, the system was offline, and all pumps had been temporarily removed. To turn the system back on, the facility representative stated that the pumps could be reinstalled, and up and running within a few days. The facility representative stated that the system has been shut down since April 2023 to address compliance issues. The facility would like to shut down the system but would need to continue sampling until there is confirmation that the groundwater is no longer contaminated at the site. The system was also temporarily shut down from September 2021 to May 2022 to address compliance issues. Unique Project #: 3E23WN123A Page 4 of 10 II. Facility Activity and Walkthrough Eagle Valero GWCU 09/27/2023 As part of the inspection process, the EPA Inspection Team visually observed the facility conditions in the presence of the facility representative. The primary purpose of the inspection was to assist EPA in assessing the facility's compliance with Permit requirements. The observations from the inspection are described in detail below in the Observations section. Photographs were taken during the inspection by Shane McAleer of EPA, and are provided in Attachment B, Photograph Log. Documents used to support the observations in this report are included in Attachment C, Exhibit Log. The EPA Inspection Team began the walk-through by entering the 8ft by 16ft box trailer on the property (refer to Attachment B, Photographs 001 - 003). There are three groundwater well pumps that bring water into the system (refer to Attachment B, Photographs 007 - 008). Since the system was offline at the time of the inspection, the pumps were removed and stored in a bag within the trailer. The system operated on a continual, 24/7 basis with shutdowns occurring during system maintenance. The well pumps are controlled by a float switch making the pump work on and off based on the water level in the well, and the discharge from the system was in a batch fashion controlled by floats in the equalization tank. When water reached a certain level in the tank, the system would discharge until the water level reached the low float level. Water enters the system through the "manifold" (refer to Attachment B, Photograph 004). Next, water goes through the oil-water separator (refer to Attachment B, Photographs 005 - 006 and 011 - 012). The oil-water separator is cleaned out as needed, and waste from the oil-water separator is stored in a drum outside of the trailer for disposal (refer to Attachment B, Photographs 021 - 022). Water is then gravity fed into a 130-gallon equalization tank for settling (refer to Attachment B, Photographs 009 - 010). A pump transfers water to the bag filter system (refer to Attachment B, Photograph 013). There are two bag filter housing units, and the facility recently changed the bag filter size from 25 m to 5 m in December 2022. Bag filters are replaced two times a month by Synergy as well. Next, there are two carbon filter units (refer to Attachment B, Photographs 015 - 017) before reaching the air injection point (refer to Attachment B, Photograph 018). The final effluent is discharged to a nearby storm sewer drain, which ultimately discharges to an unnamed tributary to Pickering Creek (refer to Attachment B, Photographs 024 - 026). The effluent sampling point can be observed inside the trailer as well (refer to Attachment B, Photograph 019). III.Observations The inspection observations below are made pursuant to the requirements of the Permit. Unique Project #: 3E23WN123A Page 5 of 10 Eagle Valero GWCU 09/27/2023 NPDES Permit Effluent Exceedances Part A.1.A of the Permit defines effluent discharge limitations, monitoring, and reporting requirements for Outfall No. 001: "Based on the anticipated wastewater characteristics and flows described in the permit application and its supporting documents and/or amendments, the following effluent limitations and monitoring requirements apply." Observation 1. According to ECHO effluent data, Eagle Valero has had 56 effluent violations between December 2020 and April 2023 (refer to Table 3). The facility representative explained that since they could not meet effluent limits, the system was shut down in April of 2023. The facility representative explained that they would like to eventually terminate their permit. Table 3: Effluent Violations from December 2020 to April 2023 Monitoring Period Date 12/31/2020 Parameter Description pH 12/31/2020 12/31/2020 12/31/2020 1/31/2021 1/31/2021 1/31/2021 Solids, total suspended Iron, dissolved (as Fe) Iron, dissolved (as Fe) Iron, dissolved (as Fe) Iron, dissolved (as Fe) Benzene 3/31/2021 3/31/2021 6/30/2021 Solids, total suspended Solids, total suspended Oxygen, dissolved (DO) Limit Type INST MIN MO AVG DAILY MX MO AVG DAILY MX MO AVG DAILY MX DAILY MX MO AVG INST MIN DMR Value 5.49 DMR Value Unit SU 7.9 mg/L 5.4 mg/L 3.8 mg/L 5.2 mg/L 2.6 mg/L 0.00074 mg/L 12 mg/L 12 mg/L 5.7 mg/L Limit Value 6 Limit Value Unit SU 5 mg/L 0.3 mg/L 0.3 mg/L 0.3 mg/L 0.3 mg/L 0.0005 mg/L 10 mg/L 5 mg/L 6 mg/L % Exceedance 58 1700 1167 1633 767 48 20 140 5 Unique Project #: 3E23WN123A Page 6 of 10 7/31/2021 8/31/2021 8/31/2021 9/30/2021 9/30/2021 9/30/2021 Solids, total suspended Solids, total suspended Solids, total suspended Solids, total suspended Solids, total suspended Oil & grease 9/30/2021 9/30/2021 6/30/2022 7/31/2022 7/31/2022 Iron, dissolved (as Fe) Iron, dissolved (as Fe) Solids, total suspended Solids, total suspended Benzene 7/31/2022 Benzene 8/31/2022 8/31/2022 8/31/2022 8/31/2022 Solids, total suspended Solids, total suspended Iron, dissolved (as Fe) Benzene 9/30/2022 9/30/2022 9/30/2022 9/30/2022 10/31/2022 Solids, total suspended Solids, total suspended Iron, dissolved (as Fe) Iron, dissolved (as Fe) Solids, total suspended MO AVG DAILY MX MO AVG MO AVG DAILY MX DAILY MX DAILY MX MO AVG DAILY MX MO AVG DAILY MX MO AVG MO AVG DAILY MX DAILY MX DAILY MX MO AVG DAILY MX DAILY MX MO AVG MO AVG 7.5 mg/L 11 mg/L 9.5 mg/L 8 mg/L 16 mg/L 15 mg/L 5.9 mg/L 2.98 mg/L 50 mg/L 6.9 mg/L 0.0007 mg/L 0.00066 mg/L 25 mg/L 29 mg/L 0.322 mg/L 0.00056 mg/L 12.5 mg/L 15 mg/L 7.79 mg/L 5.475 mg/L 23.5 mg/L Eagle Valero GWCU 09/27/2023 5 mg/L 50 10 mg/L 10 5 mg/L 90 5 mg/L 60 10 mg/L 60 10 mg/L 50 0.3 mg/L 1867 0.3 mg/L 893 10 mg/L 400 5 mg/L 38 0.0005 mg/L 40 0.0005 mg/L 32 5 mg/L 400 10 mg/L 190 0.3 mg/L 7 0.0005 mg/L 12 5 mg/L 150 10 mg/L 50 0.3 mg/L 2497 0.3 mg/L 1725 5 mg/L 370 Unique Project #: 3E23WN123A Page 7 of 10 10/31/2022 10/31/2022 10/31/2022 11/30/2022 11/30/2022 11/30/2022 11/30/2022 12/31/2022 12/31/2022 12/31/2022 12/31/2022 12/31/2022 Solids, total suspended Iron, dissolved (as Fe) Iron, dissolved (as Fe) Solids, total suspended Solids, total suspended Iron, dissolved (as Fe) Iron, dissolved (as Fe) Solids, total suspended Solids, total suspended Iron, dissolved (as Fe) Iron, dissolved (as Fe) Benzene 1/31/2023 1/31/2023 1/31/2023 1/31/2023 1/31/2023 Solids, total suspended Solids, total suspended Iron, dissolved (as Fe) Iron, dissolved (as Fe) Benzene 2/28/2023 2/28/2023 2/28/2023 3/31/2023 Solids, total suspended Iron, dissolved (as Fe) Iron, dissolved (as Fe) Iron, dissolved (as Fe) DAILY MX DAILY MX MO AVG DAILY MX MO AVG DAILY MX MO AVG DAILY MX MO AVG DAILY MX MO AVG DAILY MX DAILY MX MO AVG MO AVG DAILY MX DAILY MX MO AVG MO AVG DAILY MX MO AVG 30 mg/L 20.6 mg/L 10.97 mg/L 11 mg/L 9.65 mg/L 9.89 mg/L 9.865 mg/L 25 mg/L 16.5 mg/L 3.46 mg/L 3.27 mg/L 0.00063 mg/L 39 mg/L 19.5 mg/L 1.79 mg/L 3.46 mg/L 0.00085 mg/L 6.05 mg/L 3.934 mg/L 7.05 mg/L 1.3518 mg/L Eagle Valero GWCU 09/27/2023 10 mg/L 200 0.3 mg/L 6767 0.3 mg/L 3557 10 mg/L 10 5 mg/L 93 0.3 mg/L 3197 0.3 mg/L 3188 10 mg/L 150 5 mg/L 230 0.3 mg/L 1053 0.3 mg/L 990 0.0005 mg/L 26 10 mg/L 290 5 mg/L 290 0.3 mg/L 497 0.3 mg/L 1053 0.0005 mg/L 70 5 mg/L 21 0.3 mg/L 1211 0.3 mg/L 2250 0.3 mg/L 351 Unique Project #: 3E23WN123A Page 8 of 10 3/31/2023 Iron, dissolved (as DAILY 2.63 mg/L 0.3 Fe) MX 4/30/2023 Solids, total MO 7.55 mg/L 5 suspended AVG 4/30/2023 Iron, dissolved (as MO 7.885 mg/L 0.3 Fe) AVG 4/30/2023 Iron, dissolved (as DAILY 7.97 mg/L 0.3 Fe) MX Eagle Valero GWCU 09/27/2023 mg/L 777 mg/L 51 mg/L 2528 mg/L 2557 IV. Records Review The EPA Inspection Team reviewed documentation including: eDMR reports, operation and maintenance records, most recent Self- Inspection Reports, and flow records. Documents were sent to the EPA Inspection Team after the inspection and received on September 27, 2023 and October 11, 2023. A copy of these attachments is provided under Attachment C, Exhibit Log. V. Closing Conference After the facility walk, the EPA Inspection Team met with the facility representative for a closing conference. The EPA Inspection Team shared preliminary observations with the facility. The EPA Inspection Team reiterated to the facility representative 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 11:15 AM. Unique Project #: 3E23WN123A Page 9 of 10 VI. List of Attachments Eagle Valero GWCU 09/27/2023 Attachment A: Permit No. PA0245119 Attachment B: Photograph Log Attachment C: Exhibit Log Exhibit 1: Discharge Monitoring Reports 2021 to 2023 Exhibit 2: Operation and Maintenance Records Exhibit 3: Sampling and System Readings Exhibit 4: Flow Table Unique Project #: 3E23WN123A Page 10 of 10