Document RpBG1Laoa6XqqrXm1Jv46Ndnv

EPA REGION 5 Enforcement and Compliance Assurance Division INSPECTION REPORT Inspection Entry Date/Time Inspection Exit Date/Time Weather Media Statute(s)/Program(s) Type of Inspection 08/22/2023 12:00 PM (ET) Announced: No 08/22/2023 04:00 PM (ET) Access: Granted Sunny, mid-70s Water Clean Water Act, NPDES Compliance Evaluation Inspection (CEI) Permittee Name Facility or Site Name Facility/Site Physical Address City, State, Zip Code County/Borough/Parish Facility GPS Coordinates Delta WWTP Delta WWTP 516 Locust St Delta, OH 43515 Fulton 41.568224, -84.001861 FRS ID 110006322247 Permit Number(s) (If Applicable) OH0020974 SIC and/or NAICS 4952 Lead Inspector: Megan Zale Supervisor Review: Brooke Furio MEGAN ZALE EPA Region 5 Digitally signed by MEGAN ZALE Date: 2023.10.11 08:50:38 -04'00' zale.megan@epa.gov BROOKE FURIO EPA Region 5 Digitally signed by BROOKE FURIO Date: 2023.10.13 05:47:43 -04'00' furio.brooke@epa.gov [Date] (440) 250-1711 [Date] (440) 250-1705 SECTION I - INTRODUCTION Site Entry and Inspection Objectives EPA Region 5 Lead Inspector, Megan Zale, arrived at the Delta WWTP (the "plant" or "facility"), located at 516 Locust St, Delta, OH 43515, at 12:00 PM (ET) on 08/22/2023 for an unannounced inspection. EPA Region 5 Lead Inspector presented credentials to Facility and informed them that this was an EPA Region 5 inspection to determine compliance as authorized by Clean Water Act (CWA) Section 308 and implementing regulations. This report is based on information supplied by Delta WWTP representatives, direct observations made by the EPA Region 5 inspector, records and reports maintained by the permittee and other information including: photographs taken by EPA Region 5 inspector(s), physical evidence collected by the EPA Region 5 inspector(s), 1 of 16 Delta WWTP Inspection Date(s): 08/22/2023 measurements taken by EPA Region 5 inspector(s), verbal or written statements made by information supplied by Delta WWTP representatives during or subsequent to the on-site Inspection, and materials, processes, data, photographs, or documents shown, demonstrated, or submitted to the EPA Region 5 inspector(s) by Delta WWTP representatives during or subsequent to the on-site Inspection. In addition, information gathered prior to or subsequent to the Inspection from a review of EPA, State, and/or public records may be included in this report. Attendees Organization EPA REGION 5 Village of Delta Village of Delta Village of Delta Attendee Name Megan Zale Frank D'Ambrosia Andy Glenn Chris Maier Title Lead Inspector Operator of Record Village Administrator Present in Opening Conf. Yes Yes Yes Yes Present in Closing Conf. Yes Yes Yes Yes Facility/Site Description EPA Region 5 lead inspector confirmed the following facility information: Wastewater treatment at the facility begins with a bar screen at the influent. The bar screen is was not in operation at the time of the inspection, but was repaired afterward, and photos sent to EPA on September 25, 2023. The wastewater flow then goes to a wet well, through a vortex grit remover, treated with aluminum sulfate to assist with phosphorous removal, and then to 3 batch reactors. The facility uses a sequencing batch reactor system, in which equalization, aeration, and clarification are completed in each tank; the facility has 3 batch reactor tanks used in sequence. The wastewater flow then flows to a primary and secondary sludge digester and then through ultraviolet disinfection, post-aeration, and then effluent is measured with an ultrasonic flow meter and v-notch weir and then discharged to Bad Creek. The facility has a SCADA system but at the time of inspection, it did not have alarms that reach out remotely to the staff (the plant alarms were localized). The operator stated that the SCADA system was expected to be finished being upgraded to include alarms by the end of September 2023. The SCADA system was upgraded after the inspection in late September to include the remote alarms. There is a 2-million-gallon combined sewer overflow (CSO) storage basin at the plant that was finished being built in 2017. During rain events, some of the wastewater flow is routed to the CSO storage basin to be treated later. The CSO basin has four aerators and an ultrasonic sensor for level measurement. The plant's design capacity is 0.725 million gallons per day (MGD) and the average flow is 0.25 MGD. Sludge from the plant is hauled to Wood County landfill once a year; 40 to 80 dry tons are hauled per year. The plant has an on-site generator that powers the entire plant and is automatically activated. The operator of record is Frank D'Ambrosia, Class III certified, and is on site for 20 hours/week (Monday through Friday 7am to 11am), as required by Ohio regulations for a Class II plant. Chris Maier is on site 40 hours/week and is working on his operator certifications. The facility's in-house laboratory is used to analyze Ammonia, e. coli, total dissolved solids, total suspended solids, CBOD, dissolved oxygen, temperature and pH. The facility uses BoJhun Laboratory in Fostoria, Ohio for all other sample analyses. The operator stated that the plant's historic ammonia exceedances are due to high flows at the plant being low in bacteria and throwing the SBR units out of balance. Additionally, he stated that the plant's historic total suspended solids and ammonia exceedances were caused by the retention time in the SBR units being reduced during high flow events, which reduces their efficacy. 2 of 16 Delta WWTP Inspection Date(s): 08/22/2023 Plans for improvements besides the SCADA system and bar screen are replacing actuators on two of the four influent pumps (the staff said they expect them in November), and replacing a wall in the post-aeration tank (the staff stated this will occur when they change to winter operation in November). The site representatives stated that a goal for 2024 is an assessment by the engineering firm Jones & Henry to determine long-term plans for improvements. SECTION II - OBSERVATIONS DELTA WWTP Observation #: MZ2-OB-001 Date: 08/22/2023 Weather: Sunny, mid-70s During the inspection, the facility operator stated that the plant does not have alarms in its SCADA system that are sent out remotely to plant staff, only localized alarms. The SCADA system was upgraded in late September to include the remote alarms. EPA communicated with the operator on September 25, 2023. DELTA WWTP Observation #: MZ2-OB-002 Date: 08/22/2023 Weather: Sunny, mid-70s The facility's automatic bar screen was not operating at the time of inspection. The Village had the bar screen repaired in September, 2023, as evidenced by photos sent to EPA on September 25, 2023. DELTA WWTP Observation #: MZ2-OB-003 Date: 08/22/2023 Weather: Sunny, mid-70s The operator stated that the plant's historic ammonia and total suspended solids exceedances are due to high flows at the plant being low in bacteria and throwing the SBR units out of balance. Additionally, he stated that the retention time in the SBR units is reduced during high flow events, which reduces their efficacy. SECTION III - RECORDS REVIEW Records may not be in sequential order. Record: DMR Reports Ref #: MZ2-RR-004 Reviewed By: Megan Zale AOC: No Reviewed Date: 09/24/2023 Discharge monitoring reports for January through June 2023 Record: Laboratory Analysis Reports Ref #: MZ2-RR-003 Reviewed By: Megan Zale AOC: No Reviewed Date: 09/24/2023 Laboratory analysis reports: 5 reports in April 2023, 2 reports in May 2023, 4 reports in June 2023. 3 of 16 Delta WWTP Inspection Date(s): 08/22/2023 Record: Other - Flow Records Ref #: MZ2-RR-002 Reviewed By: Megan Zale AOC: No Reviewed Date: 08/22/2023 Flow records recorded from SCADA for January through August 2023. Record: Other - Laboratory Chain of Custody Forms Ref #: MZ2-RR-001 Reviewed By: Megan Zale AOC: No Reviewed Date: 08/22/2023 Laboratory Chain of Custody Forms for dates: 4/4/2023 (2 forms), 4/20/2023 (3 forms), 5/11/2023, 5/25/2023, 6/8/2023, 6/22/2023, 6/23/2023, 8/16/2023 SECTION IV - SAMPLING ACTIVITIES AND ANALYTICAL RESULTS No sampling was conducted. SECTION V - AREA OF CONCERN Area(s) of Concern may not be in sequential order. The presentation of Area(s) of Concern does not constitute a formal compliance determination or violation. AOC Reference #: MZ2-OB-003 Regulation and/or Permit Requirement According to NPDES permit OH0020974 Part III. 3. A. "All wastewater treatment works shall be operated in a manner consistent with the following: At all times, the permittee shall maintain in good working order and operate as efficiently as possible all treatment or control facilities or systems installed or used by the permittee necessary to achieve compliance with the terms and conditions of this permit. Proper operation and maintenance also includes adequate laboratory controls and appropriate quality assurance procedures..." AOC: The operator stated that the plant's historic ammonia and total suspended solids (TSS) exceedances are due to high flows at the plant being low in bacteria and throwing the SBR units out of balance. Additionally, he stated that the retention time in the SBR units is reduced during high flow events, which reduces their efficacy. However, upon reviewing data from discharge monitoring reports, high flow events do not seem to correlate with high TSS/ammonia. The plant's design capacity is 0.725 million gallons per day (MGD) and the average flow is 0.25 MGD. There is also a 2-million-gallon overflow capacity. A lot of the exceedances are during approximately 0.3 to 0.4 MGD. Other times no exceedances during those higher events. SECTION VI - CLOSING CONFERENCE AND FOLLOW UP Closing Conference The EPA Region 5 Lead Inspector held a closing conference with Facility personnel at 04:00 PM (ET) on 08/22/2023 for the inspection. During the closing conference, EPA Region 5 Lead Inspector discussed the 4 of 16 Delta WWTP Inspection Date(s): 08/22/2023 observations and Area(s) of Concern identified during the inspection. Observations and Area(s) of Concern have not yet been evaluated for a formal compliance determination. EPA spoke with facility representatives about the lack of remote SCADA alarms for the plant, the inoperable automatic bar screen, and the plant's ammonia and total suspended solids exceedances. SECTION VII - LIST OF ATTACHMENTS 1. Photo Log 5 of 16 Delta WWTP Inspection Date(s): ATTACHMENT 1: PHOTO LOG 08/22/2023 Facility Log Book 08/22/2023 01:02 PM Facility Log Book No CBI No PII DSCN0613.JPG Photographer: Megan Zale Laboratory refrigerator for samples 08/22/2023 01:09 PM No CBI Laboratory refrigerator for samples No PII DSCN0614.JPG Photographer: Megan Zale 6 of 16 Delta WWTP Inspection Date(s): 08/22/2023 Influent sluice gate 08/22/2023 01:14 PM Influent sluice gate No CBI No PII DSCN0615.JPG Photographer: Megan Zale Wet well 08/22/2023 01:17 PM Wet well No CBI No PII DSCN0616.JPG Photographer: Megan Zale 7 of 16 Delta WWTP Inspection Date(s): 08/22/2023 Bar screen 08/22/2023 01:19 PM Bar screen No CBI No PII DSCN0617.JPG Photographer: Megan Zale Influent flow meter 08/22/2023 01:20 PM Influent flow meter No CBI No PII DSCN0618.JPG Photographer: Megan Zale 8 of 16 Delta WWTP Inspection Date(s): 08/22/2023 Sequencing batch reactor 1 08/22/2023 01:34 PM No CBI Sequencing batch reactor 1 No PII DSCN0621.JPG Photographer: Megan Zale Sequencing batch reactor 2 08/22/2023 01:35 PM No CBI Sequencing batch reactor 2 No PII DSCN0622.JPG Photographer: Megan Zale 9 of 16 Delta WWTP Inspection Date(s): 08/22/2023 Sequencing batch reactor 2 08/22/2023 01:35 PM No CBI Sequencing batch reactor 2 No PII DSCN0623.JPG Photographer: Megan Zale Sequencing batch reactor 3 08/22/2023 01:35 PM No CBI Sequencing batch reactor 3 No PII DSCN0624.JPG Photographer: Megan Zale 10 of 16 Delta WWTP Inspection Date(s): 08/22/2023 Post aeration tank 08/22/2023 01:39 PM No CBI No PII Post aeration tank (dissolved oxygen addition) DSCN0625.JPG Photographer: Megan Zale V-notch weir 08/22/2023 01:41 PM No CBI No PII V-notch weir for effluent flow measurement DSCN0626.JPG Photographer: Megan Zale 11 of 16 Delta WWTP Inspection Date(s): 08/22/2023 Secondary sludge digester 08/22/2023 01:48 PM Secondary sludge digester No CBI No PII DSCN0627.JPG Photographer: Megan Zale Sludge drying bags 08/22/2023 01:50 PM Sludge drying bags No CBI No PII DSCN0628.JPG Photographer: Megan Zale 12 of 16 Delta WWTP Inspection Date(s): 08/22/2023 Primary/first sludge digester 08/22/2023 01:51 PM No CBI Primary/first sludge digester No PII DSCN0629.JPG Photographer: Megan Zale Sludge storage 08/22/2023 01:54 PM No CBI Sludge storage (holds 150 to 200 dry tons) No PII DSCN0630.JPG Photographer: Megan Zale 13 of 16 Delta WWTP Inspection Date(s): 08/22/2023 Outfall signage 08/22/2023 01:57 PM Coordinates: Outfall signage No CBI No PII DSCN0631.JPG Photographer: Megan Zale 41.56686666, -84.00167166 Outfall 001 08/22/2023 01:57 PM Coordinates: Outfall 001 No CBI No PII DSCN0632.JPG Photographer: Megan Zale 41.56682666, -84.001685 14 of 16 Delta WWTP Inspection Date(s): 08/22/2023 Outfall 001 effluent in receiving stream 08/22/2023 01:58 PM No CBI Coordinates: Outfall 001 effluent in receiving stream No PII DSCN0633.JPG Photographer: Megan Zale 41.56683, -84.00166333 Downstream sample location 08/22/2023 02:01 PM No CBI Downstream sample location No PII DSCN0634.JPG Photographer: Megan Zale 15 of 16 Delta WWTP Inspection Date(s): 08/22/2023 CSO basin 08/22/2023 02:05 PM CSO basin No CBI No PII DSCN0635.JPG Photographer: Megan Zale Upstream sample location 08/22/2023 02:27 PM Upstream sample location No CBI No PII DSCN0637.JPG Photographer: Megan Zale 16 of 16