Document O17p8egqBzdmY515n7ZNvyGgp

REGION 5 Enforcement and Compliance Assurance Division Inspection Date: Time: Media: Statute (s)/Program(s): Type of inspection: Access: INSPECTION REPORT 3/22/22 Inspection Announced: No Entry: 8:50 AM (EST) Exit: 11:55 AM (EST) Water Clean Water Act, National Pollutant Discharge Elimination System (NPDES), Industrial CEI - Compliance Evaluation Inspection Granted Permittee Name: Facility or Site Name: Facility/Site Physical Address: (city, state, zip code) County/Parish: Louisville Wastewater Treatment Plant (WWTP) Louisville WWTP 2301 Ravenna Avenue NE Louisville, Ohio 44641 Stark Permit Number: SIC or NAICS: OH0026182 SIC 4952 Persons Participating in Inspection: Title Physical Scientist, EPA Environmental Engineer, EPA Utilities Operator Utilities Operator WWTP Operator Name Matthew Schulte Mark Conti Bruce Goebeler James Rothemer John Stubblefield Phone (312) 886-2405 (312) 353-4645 Email schulte.matthew@epa.gov retired rgoebeler@louisvilleohio.org jrothemer@louisvilleohio.org Present at Opening Conference Yes Present at Closing Conference Yes Yes Yes Yes Yes Yes Yes No Yes Page 1 of 31 Louisville WWTP Inspection Date(s): 3/22/2022 Lead Inspector: Matthew Schulte Schulte, Matthew Region 5 Digitally signed by Schulte, Matthew Date: 2022.05.17 09:54:50 -05'00' schulte.matthew@epa.gov Additional Persons Participating in Inspection: Mark Conti Region 5 Conti.mark@epa.gov Supervisor Review: Molly Smith MOLLY SMITH Region 5 Digitally signed by MOLLY SMITH Date: 2022.05.16 20:01:56 -05'00' smith.molly@epa.gov (312) 886-2405 (312) 353-4645 (312) 353-8773 SECTION I - INTRODUCTION Site Entry and Inspection Objectives Region 5 Lead Inspector, Matthew Schulte, and inspector Mark Conti arrived at Louisville WWTP (the "Site" or "Facility"), located at 2301 Ravenna Ave., Louisville, OH 44641, at 08:50 AM (EST) on 3/22/2022 for an unannounced inspection. Inspectors presented their credentials to Bruce Goebeler and informed the Facility that this was an EPA Region 5 inspection to determine compliance with the Clean Water Act (CWA) and the National Pollutant Discharge Elimination System (NPDES) permit program. The inspection was conducted under the authority of the CWA (NPDES) permit program and Section 308 of the CWA. The table above identifies the attendees that participated in the inspection. This report is based on information supplied by Facility representatives, observations made by the Region 5 inspectors, and records and reports maintained by the permittee and Region 5. These include the following: direct observations made by the Region 5 inspectors, photographs taken by Region 5 inspectors, physical evidence collected by Region 5 inspectors, measurements taken by Region 5 inspectors, verbal or written statements made or supplied by Facility representatives (the permittee) during or subsequent to the on-site inspection, and materials, processes, data, photographs, or documents shown, demonstrated, or submitted to the Region 5 inspectors by Facility representatives during or subsequent to the on-site inspection. In addition, information gathered prior to or subsequent to the inspection from a review of U.S. EPA, State, and public records may be included in this report. Facility/Site Description Region 5 Lead Inspector confirmed the following facility information: Page 2 of 31 Louisville WWTP Inspection Date(s): 3/22/2022 The Facility is a Wastewater Treatment Plant for Louisville, Ohio. The Facility is currently undergoing an upgrade of their facility which has been separated into three phases. Phase I involved the replacement of old clarifiers with two new ones and was completed in 2020. Phase II will involve additions to grit removal including new grit buildings, pumps, and blowers, along with new aeration diffusers, blowers, and piping. Phase II is expected to be completed in September of 2022. Phase III is currently planned to start in 2023 and will involve removing old clarifiers no longer in operation, a new centrifuge for sludge treatment, and additional chlorine contact. SECTION II - OBSERVATIONS Observations may not be in sequential order. Unique Identifying No. MS5-OB-001 MS5-OB-002 MS5-OB-003 MS5-OB-004 Observation Facility is currently undergoing Phase II of their plant construction projects which involves new grit removal equipment, upgrades to SCADA, and aeration piping and diffusers which they expect to finish in September 2022. Facility collects samples Monday-Friday (except holidays) using a Hach Sigma SD900 for 24-hour flow proportioned composite sampling. Facility receives discharge from a significant industrial user (SIU) Allegheny Technologies (ATI). ATI discharges water softener backwash to the Louisville WWTP which the Facility states is the cause of their total dissolved solids (TDS) exceedances. ATI is in the process of closing down its operations with a majority of processes shutting down in June 2022, which the Facility expects with resolve their TDS issues. Phase III of the Facilities Construction Plan will include removing the old clarifiers no longer in operation, adding a centrifuge to replace sludge press building, and adding addition chlorine contact. Expected completion for Phase III is late 2023. Area of Concern? No No Yes No SECTION III - RECORDS REVIEW Records may not be in sequential order. No. MS5-RR-001 MS5-RR-002 Record Permit is currently expired, but has been administratively continued due to Facility submitting a renewal application. Renewal application was not submitted 180 days prior to their current NPDES permit expiration date. Quarterly site inspections are performed by Richard Goebeler Area of Concern? Yes No Page 3 of 31 Louisville WWTP Inspection Date(s): 3/22/2022 SECTION V - AREAS OF CONCERN The presentation of areas of concern does not constitute a formal compliance determination or violation. No. MS5-OB-003 Facility receives discharge from a significant industrial user (SIU) Allegheny Technologies (ATI). ATI discharges water softener backwash to the Louisville WWTP which the Facility states is the cause of their total dissolved solids (TDS) exceedances. TDS limits are listed in Part I, A of Facility's NPDES Permit. According to Facility, ATI is in the process of closing down its operations with a majority of processes shutting down in June 2022, which the Facility expects with resolve their TDS issues. The City of Louisville does not have an Ohio EPA-approved industrial pretreatment program. MS5-OB-005 Samples taken for orthophosphate are not filtered immediately. MS5-RR-001 NPDES Permit Part II, Item U - samples for orthophosphate are required to be filtered using a 0.45-micron filter within 15 minutes of when grab samples are taken Permit is currently expired, but has been administratively continued due to Facility submitting a renewal application on April 29, 2021. Renewal application was not submitted 180 days prior to their current NPDES permit expiration date of August 31, 2021. "In order to receive authorization to discharge beyond the above date of expiration, the permittee shall submit such information and forms as are required by the Ohio EPA no later than 180 days prior to the above date of expiration." - Facility NPDES Permit: Page 1 SECTION VI - CLOSING CONFERENCE AND FOLLOW UP Closing Conference The Lead Inspector held a closing conference with Facility personnel on 3/22/2022 for the inspection. During the closing conference, the Lead Inspector discussed the observations and Areas of Concern identified during the inspection. Observations and Areas of Concern have not yet been evaluated for a formal compliance determination. Follow Up The following items were requested by the inspector at the time of the inspection: NPDES permit application; Discharge Monitoring Reports Stormwater Pollution Prevention Plan (SWWPP) Page 4 of 31 Louisville WWTP Inspection Date(s): 3/22/2022 Unique Identifying No. MS5-FU-001 MS5-FU-002 Follow Up Item Discharge monitoring reports (DMRs) for the last several months starting with October 2021. Current permit is expired. Permit application has been submitted. SECTION VII - LIST OF APPENDICES Appendix 1 - Photo Log Page 5 of 31 REGION 5 Enforcement and Compliance Assurance Division Facility Name & Location: Louisville Wastewater Treatment Plant 2301 Ravenna Avenue Northeast, Louisville, OH 44641 Date Photograph Was Taken: 3/22/2022 Photo No.: 1 Time: 9:51 AM Direction Photo Taken: Photo Description: Sampling pole used to collect samples at outfall 001. Photographer: Mark Conti Camera: Canon PowerShot SD1400 IS (S/N 212065043406) File: Louisville IMG_0001.JPG Page 6 of 31 Louisville WWTP Inspection Date(s): Facility Name & Location: Louisville Wastewater Treatment Plant 2301 Ravenna Avenue Northeast, Louisville, OH 44641 Date Photograph Was Taken: 3/22/2022 Photo No.: 2 Time: 9:51 AM Direction Photo Taken: Down Photo Description: Sample location 001 Photographer: Mark Conti 3/22/2022 Camera: Canon PowerShot SD1400 IS (S/N 212065043406) File: Louisville IMG_0002.JPG Page 7 of 31 Louisville WWTP Inspection Date(s): Facility Name & Location: Louisville Wastewater Treatment Plant 2301 Ravenna Avenue Northeast, Louisville, OH 44641 Date Photograph Was Taken: 3/22/2022 Photo No.: 3 Time: 9:52 AM Direction Photo Taken: Photo Description: Connection for level sensor and high level float for raw water Photographer: Mark Conti 3/22/2022 Camera: Canon PowerShot SD1400 IS (S/N 212065043406) File: Louisville IMG_0003.JPG Page 8 of 31 Louisville WWTP Inspection Date(s): Facility Name & Location: Louisville Wastewater Treatment Plant 2301 Ravenna Avenue Northeast, Louisville, OH 44641 Date Photograph Was Taken: 3/22/2022 Photo No.: 4 Time: 9:57 AM Direction Photo Taken: Photo Description: Hach Sigma 900 flow proportioned sampler for outfall 601 monitoring. Photographer: Mark Conti 3/22/2022 Camera: Canon PowerShot SD1400 IS (S/N 212065043406) File: Louisville IMG_0004.JPG Page 9 of 31 Louisville WWTP Inspection Date(s): Facility Name & Location: Louisville Wastewater Treatment Plant 2301 Ravenna Avenue Northeast, Louisville, OH 44641 Date Photograph Was Taken: 3/22/2022 Photo No.: 5 Time: 9:57 AM Direction Photo Taken: Photo Description: Instructions for taking a sample and using Hach Sigma 900 at outfall 601. Photographer: Mark Conti 3/22/2022 Camera: Canon PowerShot SD1400 IS (S/N 212065043406) File: Louisville IMG_0005.JPG Page 10 of 31 Louisville WWTP Inspection Date(s): Facility Name & Location: Louisville Wastewater Treatment Plant 2301 Ravenna Avenue Northeast, Louisville, OH 44641 Date Photograph Was Taken: 3/22/2022 Photo No.: 6 Time: 9:58 AM Direction Photo Taken: Photo Description: Influent Magmeter Photographer: Mark Conti 3/22/2022 Camera: Canon PowerShot SD1400 IS (S/N 212065043406) File: Louisville IMG_0006.JPG Page 11 of 31 Louisville WWTP Inspection Date(s): Facility Name & Location: Louisville Wastewater Treatment Plant 2301 Ravenna Avenue Northeast, Louisville, OH 44641 Date Photograph Was Taken: 3/22/2022 Photo No.: 7 Time: 10:03 AM Direction Photo Taken: Photo Description: Influent pump readings with raw sewage rate and totalized flow. Photographer: Mark Conti 3/22/2022 Camera: Canon PowerShot SD1400 IS (S/N 212065043406) File: Louisville IMG_0007.JPG Page 12 of 31 Louisville WWTP Inspection Date(s): Facility Name & Location: Louisville Wastewater Treatment Plant 2301 Ravenna Avenue Northeast, Louisville, OH 44641 Date Photograph Was Taken: 3/22/2022 Photo No.: 8 Time: 10:08 AM Direction Photo Taken: Photo Description: Hydro International Tea Cup and Grit Snail for grit removal. Not operational yet. Photographer: Mark Conti 3/22/2022 Camera: Canon PowerShot SD1400 IS (S/N 212065043406) File: Louisville IMG_0008.JPG Page 13 of 31 Louisville WWTP Inspection Date(s): Facility Name & Location: Louisville Wastewater Treatment Plant 2301 Ravenna Avenue Northeast, Louisville, OH 44641 Date Photograph Was Taken: 3/22/2022 Photo No.: 9 Time: 10:23 AM Direction Photo Taken: South Photo Description: Aeration Tank. Photographer: Mark Conti 3/22/2022 Camera: Canon PowerShot SD1400 IS (S/N 212065043406) File: Louisville IMG_0009.JPG Page 14 of 31 Louisville WWTP Inspection Date(s): Facility Name & Location: Louisville Wastewater Treatment Plant 2301 Ravenna Avenue Northeast, Louisville, OH 44641 Date Photograph Was Taken: 3/22/2022 Photo No.: 10 Time: 10:23 AM Direction Photo Taken: South Photo Description: Screen after aeration tank. Photographer: Mark Conti 3/22/2022 Camera: Canon PowerShot SD1400 IS (S/N 212065043406) File: Louisville IMG_0010.JPG Page 15 of 31 Louisville WWTP Inspection Date(s): Facility Name & Location: Louisville Wastewater Treatment Plant 2301 Ravenna Avenue Northeast, Louisville, OH 44641 Date Photograph Was Taken: 3/22/2022 Photo No.: 11 Time: 10:32 AM Direction Photo Taken: South Photo Description: Clarifier #1 Photographer: Mark Conti 3/22/2022 Camera: Canon PowerShot SD1400 IS (S/N 212065043406) File: Louisville IMG_0011.JPG Page 16 of 31 Louisville WWTP Inspection Date(s): Facility Name & Location: Louisville Wastewater Treatment Plant 2301 Ravenna Avenue Northeast, Louisville, OH 44641 Date Photograph Was Taken: 3/22/2022 Photo No.: 12 Time: 10:33 AM Direction Photo Taken: down/south Photo Description: Clarifier #1 weirs. Photographer: Mark Conti 3/22/2022 Camera: Canon PowerShot SD1400 IS (S/N 212065043406) File: Louisville IMG_00012.JPG Page 17 of 31 Louisville WWTP Inspection Date(s): Facility Name & Location: Louisville Wastewater Treatment Plant 2301 Ravenna Avenue Northeast, Louisville, OH 44641 Date Photograph Was Taken: 3/22/2022 Photo No.: 13 Time: 10:38 AM Direction Photo Taken: East Photo Description: Chlorine contact basin. Photographer: Mark Conti 3/22/2022 Camera: Canon PowerShot SD1400 IS (S/N 212065043406) File: Louisville IMG_0013.JPG Page 18 of 31 Louisville WWTP Inspection Date(s): Facility Name & Location: Louisville Wastewater Treatment Plant 2301 Ravenna Avenue Northeast, Louisville, OH 44641 Date Photograph Was Taken: 3/22/2022 Photo No.: 14 Time: 10:45 AM Direction Photo Taken: Photo Description: Siemens HydroRanger 200 ultrasonic level monitor for outfall 001. Last calibrated 06/21. Photographer: Mark Conti 3/22/2022 Camera: Canon PowerShot SD1400 IS (S/N 212065043406) File: Louisville IMG_0014.JPG Page 19 of 31 Louisville WWTP Inspection Date(s): Facility Name & Location: Louisville Wastewater Treatment Plant 2301 Ravenna Avenue Northeast, Louisville, OH 44641 Date Photograph Was Taken: 3/22/2022 Photo No.: 15 Time: 10:46 AM Direction Photo Taken: down Photo Description: 001 Grab Sampling Location. Photographer: Mark Conti 3/22/2022 Camera: Canon PowerShot SD1400 IS (S/N 212065043406) File: Louisville IMG_0015.JPG Page 20 of 31 Louisville WWTP Inspection Date(s): Facility Name & Location: Louisville Wastewater Treatment Plant 2301 Ravenna Avenue Northeast, Louisville, OH 44641 Date Photograph Was Taken: 3/22/2022 Photo No.: 16 Time: 10:46 AM Direction Photo Taken: Photo Description: Transducer for head measurements at 001 (center) and chemical feed for chlorination (white plastic pipe) Photographer: Mark Conti 3/22/2022 Camera: Canon PowerShot SD1400 IS (S/N 212065043406) File: Louisville IMG_0016.JPG Page 21 of 31 Louisville WWTP Inspection Date(s): Facility Name & Location: Louisville Wastewater Treatment Plant 2301 Ravenna Avenue Northeast, Louisville, OH 44641 Date Photograph Was Taken: 3/22/2022 Photo No.: 17 Time: 10:47 AM Direction Photo Taken: South Photo Description: EQ pond. Less than 2600 gallons per minute flows into pond over a weir. Photographer: Mark Conti 3/22/2022 Camera: Canon PowerShot SD1400 IS (S/N 212065043406) File: Louisville IMG_0017.JPG Page 22 of 31 Louisville WWTP Inspection Date(s): Facility Name & Location: Louisville Wastewater Treatment Plant 2301 Ravenna Avenue Northeast, Louisville, OH 44641 Date Photograph Was Taken: 3/22/2022 Photo No.: 18 Time: 10:53 AM Direction Photo Taken: North Photo Description: Pressed sludge storage. Photographer: Mark Conti 3/22/2022 Camera: Canon PowerShot SD1400 IS (S/N 212065043406) File: Louisville IMG_0018.JPG Page 23 of 31 Louisville WWTP Inspection Date(s): Facility Name & Location: Louisville Wastewater Treatment Plant 2301 Ravenna Avenue Northeast, Louisville, OH 44641 Date Photograph Was Taken: 3/22/2022 Photo No.: 19 Time: 11:02 AM Direction Photo Taken: Photo Description: repeat of photo #20. Too dark, flash did not occur on camera. Photographer: Mark Conti 3/22/2022 Camera: Canon PowerShot SD1400 IS (S/N 212065043406) File: Louisville IMG_0019.JPG Page 24 of 31 Louisville WWTP Inspection Date(s): Facility Name & Location: Louisville Wastewater Treatment Plant 2301 Ravenna Avenue Northeast, Louisville, OH 44641 Date Photograph Was Taken: 3/22/2022 Photo No.: 20 Time: 11:02 AM Direction Photo Taken: Photo Description: Outfall 001 Hach auto sampler. Photographer: Mark Conti 3/22/2022 Camera: Canon PowerShot SD1400 IS (S/N 212065043406) File: Louisville IMG_0020.JPG Page 25 of 31 Louisville WWTP Inspection Date(s): Facility Name & Location: Louisville Wastewater Treatment Plant 2301 Ravenna Avenue Northeast, Louisville, OH 44641 Date Photograph Was Taken: 3/22/2022 Photo No.: 21 Time: 11:02 AM Direction Photo Taken: Photo Description: Outfall 001 auto sampler precision check and setup date. Photographer: Mark Conti 3/22/2022 Camera: Canon PowerShot SD1400 IS (S/N 212065043406) File: Louisville IMG_0021.JPG Page 26 of 31 Louisville WWTP Inspection Date(s): Facility Name & Location: Louisville Wastewater Treatment Plant 2301 Ravenna Avenue Northeast, Louisville, OH 44641 Date Photograph Was Taken: 3/22/2022 Photo No.: 22 Time: 11:08 AM Direction Photo Taken: Photo Description: Totes of aluminum sulfate solution for phosphorous removal and metering pump. Added to channel before screen ahead of clarifiers. Photographer: Mark Conti File: Louisville IMG_0022.JPG 3/22/2022 Camera: Canon PowerShot SD1400 IS (S/N 212065043406) Page 27 of 31 Louisville WWTP Inspection Date(s): Facility Name & Location: Louisville Wastewater Treatment Plant 2301 Ravenna Avenue Northeast, Louisville, OH 44641 Date Photograph Was Taken: 3/22/2022 Photo No.: 23 Time: 11:20 AM Direction Photo Taken: North Photo Description: Stormwater Outfall Furthest East. Photographer: Mark Conti 3/22/2022 Camera: Canon PowerShot SD1400 IS (S/N 212065043406) File: Louisville IMG_0023.JPG Page 28 of 31 Louisville WWTP Inspection Date(s): Facility Name & Location: Louisville Wastewater Treatment Plant 2301 Ravenna Avenue Northeast, Louisville, OH 44641 Date Photograph Was Taken: 3/22/2022 Photo No.: 24 Time: 11:21 AM Direction Photo Taken: South Photo Description: Stormwater outfall catch basin for outfall furthest east Photographer: Mark Conti 3/22/2022 Camera: Canon PowerShot SD1400 IS (S/N 212065043406) File: Louisville IMG_0024.JPG Page 29 of 31 Louisville WWTP Inspection Date(s): Facility Name & Location: Louisville Wastewater Treatment Plant 2301 Ravenna Avenue Northeast, Louisville, OH 44641 Date Photograph Was Taken: 3/22/2022 Photo No.: 25 Time: 11:23 AM Direction Photo Taken: North Photo Description: Location of collapsed stormwater outfall west of previous outfall. Photographer: Mark Conti 3/22/2022 Camera: Canon PowerShot SD1400 IS (S/N 212065043406) File: Louisville IMG_0025.JPG Page 30 of 31 Louisville WWTP Inspection Date(s): Facility Name & Location: Louisville Wastewater Treatment Plant 2301 Ravenna Avenue Northeast, Louisville, OH 44641 Date Photograph Was Taken: 3/22/2022 Photo No.: 26 Time: 11:25 AM Direction Photo Taken: Northwest Photo Description: Catch basin for collapsed stormwater outfall depicted in photo 25. Photographer: Mark Conti 3/22/2022 Camera: Canon PowerShot SD1400 IS (S/N 212065043406) File: Louisville IMG_0026.JPG Page 31 of 31