Document Z41yBDjRNmaMQqQ6y2dMO7KMJ

n. EA~UnitedS!ales ~ Environmental Prot&tion ,..,.. AgencY Region 6 Compliance Assurance and Enforcement Division INSPECTION REPORT Inspection Date(s): 1-~edia: Regulatory Program(s) Company Name: Facility Name: Facility Physical Location: (citv, state, zip code) Mailing_ address: (city, state, zip code) County/Parish: Facility Contact: March 11-13,2019 Water CWA . Total Environmental Solutions, Inc. (TESI) Multiple~ see attached spreadsheet Multiple- see attached spreadsheet PO Box 14059 Baton Rouge, LA 70898 Gayle Davidson gdavidsoQ@tesi-usa.com I Compliance Manager FRS Number: Identification/Permit Number: Media Number: NAICS: SIC: 11 0009924403 LA0074853 4952 --'- . Personnel participating in ins oection: Rachel Matthews EPA-R6/EN-WM Lawrence Messmer TESI Michael Thompson Geo Engineers (consultant) Earl Haves ("Fig") TESI Scott Pierce LDEQ Carrick Boffey LDEQ Shane Miller LDEQ Life Scientist Operations Manager Associate Environmental Engineer Lead Operator Enforcement Inspector Inspector 214-665-8589 337-316-2925 225-933-8842 225-219-3723 337,262-5584 337-262-5584 EPA Lead Inspector Signature/Date Supervisor Signature/Date --; Rachel Matthews A l I ( 'A/IA.J/Yfr.f/f/~ Carol Peters-W<!gnon 1~-;o~// bate / -1((b/1 c; Date 6ENFORM019-R6 (10/6/14) 1 TESI- STP Site Inspections 3/2019 Section I -INTRODUCTION PURPOSE OF THE INSPECTION EPA Region 6 inspector, Rachel Matthews, arrived at a designated meeting location, on March 12, 2019, with several TESI staff for a meeting regarding the 2017 Consent Decree Modification, Civil Action No. 6:98-0687 (CD) information as well as a briefing before heading to the first of several Sewer Treatment Plants (STP) operated by TESI. I met with Mr. Lawrence Messmer, Mr. Michael Thompson, and Mr. Earl Hayes to discuss the purpose of the inspections in regard to the ongoing tracking of the CD requirements as well as to review several sites that TESI is requesting to remove from the CD. The inspections were conducted under the authority of the CD and the National Pollutant Discharge Elimination System (NPDES) permit program in accordance with the Federal CWA. This report is based on information supplied by TESI, observations made by me, and records and reports maintained by the permittee, the State of Louisiana, and/or the U.S. EPA. FACILITY DESCRIPTION Six (6), of twelve (12), facilities that were requested to be removed from the CD were inspected. In addition, 12 more STPs operated by TESI and listed in the CD were inspected in regard to the schedule of compliance as well as requests for extensions. All of the STPs are covered under a Louisiana Pollutant Discharge Elimination System (LPDES) permit, with permit numbers listed in the location descriptions spreadsheet. See Appendix 1. Section II- OBSERVATIONS Areas for observation included various Schedules of Compliance referenced in the CD and associated plans submitted as part of the CD requirements. The CD requires a final "Specific Process Control Plan" for all mechanical facilities, which includes information regarding sludge managment. However, prior to the development of a "Specific Process Control Plan", sludge is to be managed in accordance with the "Holistic Process Control Plan for Mechanical STPs" that is spelled out in the CD. For Mechanical Facilities without a Specific Process Control Plan: Sludge wasting requirements in the CD are based on the blanket level as well as solids settleability. The CD includes a response to malfunctions regarding excessive solids buildup in excess of target levels suspected to be caused by a power or mechanical malfunction. The Long-Term Compliance Plan (LTCP) of the CD includes a "Holistic Process Control Plan for Mechanical STPs". The following are the sludge wasting requirements of that section: 3. Holistic Process Control Plan for Mechanical STPs. TESI shall implement a Holistic Process Control Plan for Mechanical STPs as an interim measure until the STPspecific Process Control Plans for Mechanical STPs, required in Paragraph 4, are completed and implemented for each Mechanical STP. TESI has submitted and EPA and LDEQ have reviewed the Holistic Process Control Plan for Mechanical STPs attached hereto as Attachment 2, and determined that the attachment fulfills the requirements for a Holistic Process Control Plan for Mechanical STPs set forth in this Paragraph. TESI shall implement the attached Holistic Process Control Plan for Mechanical STPs in its entirety beginning on the Effective Date of the Consent Decree Modification. Any future modifications of the Holistic Process Control Plan for 2