Document YGB80j0gwp23bQ3d8EmQkG1wk
Report Prepared by: Report Approved by:
NPDES Pretreatment Compliance Sampling Inspection Report
Trenton Renewable Power LLC 1600 Lamberton Road Trenton, New Jersey
NJ0218791
September 12-13, 2023
ROBERT
Digitally signed by ROBERT
MORRELL
_M_O__R_R_E__L_L________D_ate_: _20_23_.1_0._31_1_3:5_7_:38_-_04_'0_0'
Robert Morrell, Geologist
Monitoring Operations Section
Date: ________________
Digitally signed by PHILIP
PHILIP COCUZZA COCUZZA _________________D_at_e:_20_23_.1_1._01_0_5:5_6:_43_-0_4_'00_' Philip Cocuzza, Supervisor Monitoring Operations Section
Date: ________________
Trenton Renewable Power LLC NJ0218791
Inspection Date: September 12-13, 2023
Page 2 of 7
Trenton Renewable Power LLC NJ0218791
Inspection Date: September 12-13, 2023
1.0 OBJECTIVE
On September 12-13, 2023, at the request of the Water Compliance Branch, the United States Environmental Protection Agency (USEPA) conducted a National Pollutant Discharge Elimination System (NPDES) Pretreatment Compliance Sampling Inspection (CSI) at Trenton Renewable Power LLC in Trenton, New Jersey. The objective of the CSI was to gather information necessary to determine compliance with the general pretreatment requirements of 40 CFR Part 403 and the industrial user permit issued by the New Jersey Department of Environmental Protection (NJDEP).
2.0 KEY PARTICIPANTS
Listed below are key inspection participants and contact information, grouped by organization.
U.S. Environmental Protection Agency Robert Morrell, Geologist, Lead Inspector Morrell.robert@epa.gov, 732-906-6804 Thuan Tran, Physical Scientist Tran.thuan@epa.gov, 732-321-4455
Trenton Renewable Power LLC Brian Blair, General Manager wbrianblair@gmail.com, 856-693-6540
3.0 FACILITY DESCRIPTION
3.1 General Information
Trenton Renewable Power is located at 1600 Lamberton Road in Trenton, New Jersey. The facility is a food waste recycling and renewable energy company that converts food waste into methane and compost. The plant operates 24 hours per day, 7 days per week. There are 19 employees that work three shifts. The plant was designed to accept 450 tons of food waste per day. Currently, the facility processes approximately 260 tons per day. There are three 1.1 megawatt generators that use the methane produced on site. Approximately 2 megawatts of carbon-negative energy are produced per day. A large source of the food waste is agricultural waste at ports that has been rejected due to improper temperatures. Other sources include food waste and expired package products from grocery stores and warehouses.
Page 3 of 7
Trenton Renewable Power LLC NJ0218791
3.2 Process Information
Inspection Date: September 12-13, 2023
Food waste is delivered by truck to the facility and is separated from packaging materials using shredders, grinders, and magnets. The food waste is conveyed to a 480,000-gallon buffer tank. Water is added to the tank from one of three sources: the effluent from the Trenton Sewer Utility Wastewater Treatment Plant (WWTP), the influent to the WWTP, or two process water tanks. After mixing, the food waste is pumped to one of three thermophilic anaerobic digesters. The heat exchangers maintain the temperature at 52oC inside the digesters. The retention time in the digesters is approximately 30 days. After digestion, the sludge is conveyed to two centrifuges, where the sludge is dewatered. The solids are collected in a roll off container for disposal at a local landfill. The decant liquid wastewater is conveyed to the ammonia stripper and then an oil-water separator. The wastewater is then discharged through Outfall DSN 001L to the Trenton Sewer Utility WWTP.
Methane gas from the digesters is collected in a storage tank for use as fuel for the generators. Solids are currently sent to a local landfill for disposal. The facility plans to market the solids as compost in the future.
3.3 Facility Self-Monitoring Information
Pretreatment wastewater samples are collected monthly in accordance with the industrial user permit issued by NJDEP. 24-hour composite samples are collected for the analysis of 5-day biochemical oxygen demand (BOD5), total suspended solids (TSS), total phosphorus, total ammonia, and metals. Grab samples are collected for pH, and oil and grease. Flow is monitored continuously.
4.0 EPA SAMPLING/INSPECTION ACTIVITIES
4.1 Sampling Activities
On September 12, 2023, an automatic composite sampler was set up at the effluent chamber for Outfall DSN 001L. The sampler was programmed to collect an aliquot of the effluent wastewater every 15 minutes for 24 hours. After 24 hours, the automatic composite sampler was disassembled, and the composite sample jug was mixed thoroughly before filling the sample containers. The 24-hour composite sample was analyzed for BOD5, TSS, total phosphorus, total ammonia, and metals (arsenic, cadmium, chromium, copper, lead, nickel, zinc, and mercury). During the 24-hour sampling survey, a grab sample was also collected at Outfall DSN 001L for oil and grease. A grab sample for pH was collected and analyzed in the field. The 24-hour flow was recorded from the totalizer and provided by the facility representative.
Page 4 of 7
Trenton Renewable Power LLC NJ0218791
Inspection Date: September 12-13, 2023
All sample containers, preservation techniques, and holding times were in accordance with U.S. EPA requirements specified in 40 CFR Part 136. All samples were placed in a cooler with wet ice and transported to the U.S. EPA Region 2 Laboratory in Edison, New Jersey.
The facility representative declined the EPA offer for split samples.
5.0 ANALYTICAL RESULTS
Trenton Renewable Power Pretreatment CSI - Outfall DSN 001L
September 12-13, 2023
Parameter
Discharge to POTW Discharge Limit Discharge Limit-
- Daily
Monthly
Maximum
Average
pH (su)
7.41
5.5 - 9.5 (range)
--
Flow (gpd)
89,280
Monitor only
--
BOD5 (mg/l)
380 L
Monitor only
365
TSS (mg/l)
122
Monitor only
303
Phosphorus (mg/l)
7.05
Monitor only
Monitor only
Ammonia (mg/l)
175
Monitor only
Monitor only
Oil and Grease (mg/l)
6.49 UL
100
Monitor only
Arsenic (mg/l)
Not detected
0.9
Monitor only
Cadmium (mg/l)
Not detected
0.03
Monitor only
Chromium (mg/l)
0.006
0.37
Monitor only
Copper (mg/l)
0.0472
0.47
Monitor only
Lead (mg/l)
Not detected
0.19
Monitor only
Nickel (mg/l)
Not detected
0.95
Monitor only
Zinc (mg/l)
0.218
2.60
Monitor only
Mercury (mg/l)
Not detected
0.01
Monitor only
U - The analyte was not detected at or above the reporting limit.
L - The reported value may be biased low.
6.0 FINDINGS
6.1 Sampling Result Findings
Analytical results indicate that all parameters did not exceed daily maximum discharge limitations in the industrial user permit during the 24-hour sampling survey.
The analytical result for BOD5 exceeded the monthly average limitation in the industrial user permit but the result was qualified due to toxicity of the sample toward the seed organisms. This is explained in more detail in the project narrative of the attached Laboratory Data Report.
Page 5 of 7
Trenton Renewable Power LLC NJ0218791
7.0 ATTACHMENTS
Photograph #1 Laboratory Data Report Chain of Custody / Field Data Form
Inspection Date: September 12-13, 2023
Page 6 of 7
Trenton Renewable Power LLC NJ0218791
Inspection Date: September 12-13, 2023
Photo #1: View of the pretreatment discharge location for Outfall DSN 001L.
Page 7 of 7
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Region 2 Laboratory
2890 Woodbridge Avenue Edison , New Jersey 08837
732-906-6886 Phone 732-906-6165 Fax
September 27, 2023
Bob Morrell Monitoring & Assessment Branch LSASD/MAB Edison, NJ 08837
RE: Trenton Renewable Power LLC - 2309019 Enclosed are the results of analyses for samples received by the laboratory on 09/13/2023. The signature below reflects the laboratory's approval of the reported results. If you have any questions concerning this report, please refer to Project Number 2309019 and contact the laboratory. Sincerely,
John R. Bourbon Chief, LSASD/LB
Project Narrative:
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Region 2 Laboratory
Final Report Project: Trenton Renewable Power LLC - 2309019
Project Number: 2309019
The National Environmental Laboratory Accreditation Conference Institute (TNI) is a voluntary environmental laboratory accreditation association of State and Federal agencies. TNI established and promoted a National Environmental Laboratory Accreditation Program (NELAP) that provides a uniform set of standards for the generation of environmental data that are of known and defensible quality. The EPA Region 2 Laboratory is NELAP accredited. The Laboratory tests that are accredited have met all the requirements established under the TNI Standards.
Condition Comments
None
Comment(s):
The "Sample Analysis Date and Time" is included in the results section for any analyte with a prescribed holding time of 72 hours or less.
Biochemical Oxygen Demand (BOD) Analysis: Sample 2309019-02 exhibited toxicity toward the seed organisms used for BOD. This is demonstrated by increasing BOD values as sample dilution increases. Only the result for the largest sample dilution is being reported instead of the average of all acceptable dilutions; the average is used when the sample does not exhibit toxicity. Since an even higher sample dilution may have produced a higher BOD result, the sample was qualified with an "L" to indicate the result is biased low.
Oil and Grease Analysis: Sample 2309019-01 was not successfully analyzed using the SPE method. The sample clogged the SPE disk with only a fraction of the sample passing through. A separatory funnel extraction based on method 1664 was also attempted in which an emulsion formed which did not break. The sample is qualified with an L due to failing MS recovery.
Data Qualifier(s):
U- The analyte was not detected at or above the Reporting Limit. J- The identification of the analyte is acceptable; the reported value is an estimate. K- The identification of the analyte is acceptable; the reported value may be biased high. L- The identification of the analyte is acceptable; the reported value may be biased low. NJ- There is presumptive evidence that the analyte is present; the analyte is reported as a tentative identification. The reported value is an estimate.
U.S.E.P.A Region 2 Laboratory
NOTE: The results recorded in this report relate only to the samples as received on the date and at the time noted Reported: 9/27/2023
Page 1 of 11
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Region 2 Laboratory
Final Report Project: Trenton Renewable Power LLC - 2309019
Project Number: 2309019
Reporting Limit(s):
The Laboratory was able to achieve the appropriate limit for each analyte requested.
Field ID DSN 001L-Grab DSN 001L-24Hr.-Comp
SUMMARY REPORT FOR SAMPLES
Laboratory ID 2309019-01 2309019-02
Matrix Aqueous Aqueous
Date Sampled 09/12/2023 15:12 09/13/2023 12:37
Date Received 09/13/2023 14:30 09/13/2023 14:30
U.S.E.P.A Region 2 Laboratory
NOTE: The results recorded in this report relate only to the samples as received on the date and at the time noted Reported: 9/27/2023
Page 2 of 11
Analysis Ammonia [As N] Biochemical Oxygen Demand Mercury Metals ICP TAL NPDES/DW Oil & Grease Phosphorus Residue, Non-Filterable
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Region 2 Laboratory
Final Report Project: Trenton Renewable Power LLC - 2309019
Project Number: 2309019
SUMMARY REPORT FOR METHODS
Method EPA 350.1 SOP C-80 Rev 2.8 SM 5210B SOP C-21 Rev 2.8 EPA 245.1 SOP C-110 Rev 2.8 EPA 200.7 SOP C-109 Rev 3.7 EPA 1664A SOP C-126 Rev 1.7 EPA 365.1 SOP C-68 Rev 2.8 SM 2540D SOP C-33 Rev 3.8
Certification
NELAP NELAP NELAP NELAP NELAP NELAP NELAP
Matrix
Aqueous Aqueous Aqueous Aqueous Aqueous Aqueous Aqueous
U.S.E.P.A Region 2 Laboratory
NOTE: The results recorded in this report relate only to the samples as received on the date and at the time noted Reported: 9/27/2023
Page 3 of 11
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Region 2 Laboratory
Final Report Project: Trenton Renewable Power LLC - 2309019
Project Number: 2309019
Analyte
Field ID: DSN 001L-Grab GC Oil & Grease
Field ID: DSN 001L-24Hr.-Comp Metals ICP Arsenic Cadmium Chromium Copper Lead Nickel Zinc Mercury CVAA Mercury Sanitary Ammonia [As N] Biochemical Oxygen Demand Phosphorus Total Suspended Solids
Result
Qualifier
Reporting Limit
Units Batch
Sample ID: 2309019-01
Date and Time of Analysis*
---
U L
6.49
mg/L B309090
Sample ID: 2309019-02
---
U
8.00
ug/L B309052
---
U
3.00
ug/L B309052
6.03
5.00
ug/L B309052
47.2
10.0
ug/L B309052
---
U
8.00
ug/L B309052
---
U
20.0
ug/L B309052
218
20.0
ug/L B309052
---
U
0.050
ug/L B309063
175
5.00
mg/L B309079
380
L
2.00
mg/L B309068 09/19/2023 08:20
7.05
0.500
mg/L B309078
122
10.0
mg/L B309046
U.S.E.P.A Region 2 Laboratory
NOTE: The results recorded in this report relate only to the samples as received on the date and at the time noted Reported: 9/27/2023
Page 4 of 11
Analyte
Batch B309090 Blank (B309090-BLK1)
Oil & Grease
LCS (B309090-BS1) Oil & Grease
LCS Dup (B309090-BSD1) Oil & Grease
Matrix Spike (B309090-MS1) Oil & Grease
Matrix Spike (B309090-MS2) Oil & Grease
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Region 2 Laboratory
Final Report Project: Trenton Renewable Power LLC - 2309019
Project Number: 2309019
GC - Quality Control
Result
Reporting Limit
Units
Spike
Source
%REC
Level
Result %REC Limits
RPD
RPD Limit
--- U
5.00 mg/L
40.5
5.00 mg/L
40.00
101
78-114
38.9
5.00 mg/L
40.00
97.2
78-114
4.03
20
Source: 2309012-02
--- U
5.75 mg/L
45.98
4.00
NR
78-114
Source: 2309019-01
--- U
6.67 mg/L
53.33
ND
78-114
U.S.E.P.A Region 2 Laboratory
NOTE: The results recorded in this report relate only to the samples as received on the date and at the time noted Reported: 9/27/2023
Page 5 of 11
Analyte
Batch B309052
Blank (B309052-BLK1) Arsenic Cadmium Chromium Copper Lead Nickel Zinc
LCS (B309052-BS1) Arsenic Cadmium Chromium Copper Lead Nickel Zinc
LCS Dup (B309052-BSD1) Arsenic Cadmium Chromium Copper Lead Nickel Zinc
Matrix Spike (B309052-MS1) Arsenic Cadmium Chromium Copper Lead Nickel Zinc
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Region 2 Laboratory
Final Report Project: Trenton Renewable Power LLC - 2309019
Project Number: 2309019 Metals ICP - Quality Control
Result
Reporting Limit
Units
Spike
Source
%REC
Level
Result %REC Limits
RPD
RPD Limit
--- U
8.00 ug/L
--- U
3.00 ug/L
--- U
5.00 ug/L
--- U
10.0 ug/L
--- U
8.00 ug/L
--- U
20.0 ug/L
--- U
20.0 ug/L
203
8.00 ug/L
200.0
201
3.00 ug/L
200.0
203
5.00 ug/L
200.0
200
10.0 ug/L
200.0
206
8.00 ug/L
200.0
204
20.0 ug/L
200.0
210
20.0 ug/L
200.0
102
85-115
101
85-115
102
85-115
100
85-115
103
85-115
102
85-115
105
85-115
206
8.00 ug/L
200.0
203
3.00 ug/L
200.0
205
5.00 ug/L
200.0
203
10.0 ug/L
200.0
208
8.00 ug/L
200.0
206
20.0 ug/L
200.0
212
20.0 ug/L
200.0
103
85-115
1.20
20
102
85-115
1.16
20
103
85-115
0.891
20
101
85-115
1.05
20
104
85-115
0.811
20
103
85-115
0.957
20
106
85-115
0.921
20
Source: 2309019-02
202
8.00 ug/L
194
3.00 ug/L
204
5.00 ug/L
254
10.0 ug/L
199
8.00 ug/L
209
20.0 ug/L
425
20.0 ug/L
200.0
ND
200.0
ND
200.0
6.03
200.0
47.2
200.0
2.85
200.0
13.3
200.0
218
101
80-120
96.9
80-120
98.8
80-120
103
80-120
97.9
80-120
97.9
80-120
104
80-120
U.S.E.P.A Region 2 Laboratory
NOTE: The results recorded in this report relate only to the samples as received on the date and at the time noted Reported: 9/27/2023
Page 6 of 11
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Region 2 Laboratory
Final Report Project: Trenton Renewable Power LLC - 2309019
Project Number: 2309019 Metals ICP - Quality Control
Analyte
Batch B309052
Matrix Spike Dup (B309052-MSD1) Arsenic Cadmium Chromium Copper Lead Nickel Zinc
Result
Reporting Limit
Units
Spike
Source
%REC
Level
Result %REC Limits
RPD
RPD Limit
Source: 2309019-02
205
40.0 ug/L
198
15.0 ug/L
204
25.0 ug/L
250
50.0 ug/L
199
40.0 ug/L
211
100 ug/L
429
100 ug/L
200.0
ND
103
80-120
1.56
10
200.0
ND
99.0
80-120
2.19
10
200.0
ND
102
80-120 0.0196
10
200.0
47.2
102
80-120
1.45
10
200.0
ND
99.4
80-120 0.0403
10
200.0
13.3
99.0
80-120
1.06
10
200.0
218
106
80-120
0.934
10
U.S.E.P.A Region 2 Laboratory
NOTE: The results recorded in this report relate only to the samples as received on the date and at the time noted Reported: 9/27/2023
Page 7 of 11
Analyte
Batch B309063 Blank (B309063-BLK1)
Mercury
LCS (B309063-BS1) Mercury
LCS Dup (B309063-BSD1) Mercury
Matrix Spike (B309063-MS1) Mercury
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Region 2 Laboratory
Final Report Project: Trenton Renewable Power LLC - 2309019
Project Number: 2309019 Mercury CVAA - Quality Control
Result
Reporting Limit
Units
Spike
Source
%REC
Level
Result %REC Limits
RPD
RPD Limit
--- U
0.050 ug/L
0.997
0.050 ug/L
1.000
99.7
85-115
1.04
0.050 ug/L
1.000
104
85-115
4.22
20
Source: 2309019-02
0.997
0.050 ug/L
1.000
0.023
97.4
80-120
U.S.E.P.A Region 2 Laboratory
NOTE: The results recorded in this report relate only to the samples as received on the date and at the time noted Reported: 9/27/2023
Page 8 of 11
Analyte
Batch B309046 Blank (B309046-BLK1)
Residue, Non-Filterable
LCS (B309046-BS1) Residue, Non-Filterable
LCS Dup (B309046-BSD1) Residue, Non-Filterable
Duplicate (B309046-DUP1) Residue, Non-Filterable
Batch B309068 Blank (B309068-BLK1)
Biochemical Oxygen Demand
LCS (B309068-BS1) Biochemical Oxygen Demand
LCS (B309068-BS2) Biochemical Oxygen Demand
LCS (B309068-BS3) Biochemical Oxygen Demand
Matrix Spike (B309068-MS1) Biochemical Oxygen Demand
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Region 2 Laboratory
Final Report Project: Trenton Renewable Power LLC - 2309019
Project Number: 2309019 Sanitary - Quality Control
Result
Reporting Limit
Units
Spike
Source
%REC
Level
Result %REC Limits
RPD
RPD Limit
--- U
10.0 mg/L
96.0
10.0 mg/L
96.70
99.3
85-115
95.0
10.0 mg/L
96.70
98.2
85-115
1.05
20
Source: 2309019-02
112
10.0 mg/L
122
8.55
20
--- U
2.00 mg/L
413
mg/L
396.0
104 84.6-115.4
397
mg/L
396.0
100 84.6-115.4
407
mg/L
Source: 2309019-02
693
2.00 mg/L
396.0
396.0
380
103 84.6-115.4
79.1
75-125
U.S.E.P.A Region 2 Laboratory
NOTE: The results recorded in this report relate only to the samples as received on the date and at the time noted Reported: 9/27/2023
Page 9 of 11
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Region 2 Laboratory
Final Report Project: Trenton Renewable Power LLC - 2309019
Project Number: 2309019 Sanitary - Quality Control
Analyte
Batch B309068 Matrix Spike Dup (B309068-MSD1)
Biochemical Oxygen Demand
Batch B309078 Blank (B309078-BLK1)
Phosphorus
Blank (B309078-BLK2) Phosphorus
LCS (B309078-BS1) Phosphorus
LCS Dup (B309078-BSD1) Phosphorus
Matrix Spike (B309078-MS1) Phosphorus
Matrix Spike (B309078-MS2) Phosphorus
Batch B309079 Blank (B309079-BLK1)
Ammonia [As N]
Result
Reporting Limit
Units
Spike
Source
%REC
Level
Result %REC Limits
RPD
RPD Limit
Source: 2309019-02
634
2.00 mg/L
396.0
380
64.2
75-125
8.89
200
--- U
0.0500 mg/L
--- U
0.0500 mg/L
8.67
0.250 mg/L
8.450
103
90-110
8.71
0.250 mg/L
8.450
103
90-110
0.5
20
Source: 2309011-01
1.44
0.0500 mg/L
1.000
0.484
96
90-110
Source: 2309019-02
7.55
0.500 mg/L
1.000
7.05
50
90-110
--- U
0.100 mg/L
U.S.E.P.A Region 2 Laboratory
NOTE: The results recorded in this report relate only to the samples as received on the date and at the time noted Reported: 9/27/2023
Page 10 of 11
Analyte
Batch B309079 Blank (B309079-BLK2)
Ammonia [As N]
LCS (B309079-BS1) Ammonia [As N]
LCS Dup (B309079-BSD1) Ammonia [As N]
Matrix Spike (B309079-MS1) Ammonia [As N]
Matrix Spike (B309079-MS2) Ammonia [As N]
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Region 2 Laboratory
Final Report Project: Trenton Renewable Power LLC - 2309019
Project Number: 2309019 Sanitary - Quality Control
Result
Reporting Limit
Units
Spike
Source
%REC
Level
Result %REC Limits
RPD
RPD Limit
--- U
0.100 mg/L
7.79
0.100 mg/L
8.340
93
90-110
7.70
0.100 mg/L
8.340
92
90-110
1
20
Source: 2309011-01
4.89
0.100 mg/L
5.000
0.161
95
90-110
Source: 2309019-02
167
5.00 mg/L
5.000
175
NR
90-110
U.S.E.P.A Region 2 Laboratory
NOTE: The results recorded in this report relate only to the samples as received on the date and at the time noted Reported: 9/27/2023
Page 11 of 11
