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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION III 1650 Arch Street Philadelphia, Pennsylvania 19103-2029 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 03/24/2022 National Pollutant Discharge Elimination System (NPDES) NPDES CWA Pretreatment DELCORA Sewage Treatment Plant (STP) DELAWARE COUNTY REGIONAL WATER QUALITY CONTROL AUTHORITY (DELCORA) DELCORA 3201 W Front Street Chester, PA 19013-2320 39.82553 Longitude: -75.39399 Delaware County PA0027103 221320 SIC: 4952 3E22WN005A Site/Facility Representative(s): Irene Fitzgerald - Lab and Pretreatment Manager, DELCORA Phone: 610-876-5523 x 213 Email: fitzgeraldi@delcora.org EPA Inspectors: Aaron Thomson - EPA Inspector (3ED13) Phone: 215-814-2116 Email: Thomson.Aaron@epa.gov Ryan Shuart - EPA Inspector (3WD41) Phone: 215-814-2714 Email: Shuart.Ryan@epa.gov EPA Contractors: N/A Point of Contact State/Local Inspectors: N/A Report Preparer Signature/Date Supervisor Signature/Date Digitally signed by AARON AARON THOMSON THOMSON Date: 2022.06.21 13:38:22 -04'00' Aaron Thomson (3ED13) Four Penn Center Philadelphia, PA 19103 ZELMA MALDONADO Date: 2022.06.21 13:45:12 -04'00' Digitally signed by ZELMA MALDONADO Date Zelma Maldonado, Acting Chief, ES Section Date Four Penn Center Philadelphia, PA 19103 Unique Project#: 3E22WN005A DELAWARE COUNTY REGIONAL WATER QUALITY CONTROL AUTHORITY (DELCORA)/DELCORA Sewage Treatment Plant (STP) 03/24/2022 Table of Contents I. Introduction ................................................................................................................................. 3 A. Inspection Opening Conference ....................................................................................... 3 B. Weather and Precipitation Conditions.............................................................................. 3 II. Facility Activity/Walkthrough ................................................................................................... 3 III. Observations ............................................................................................................................. 4 IV. Records Review ...................................................................................................................... 20 V. Closing Conference.................................................................................................................. 20 VI. List of Attachments................................................................................................................. 21 Unique Project #: 3E22WN005A Page 2 of 21 DELAWARE COUNTY REGIONAL WATER QUALITY CONTROL AUTHORITY (DELCORA)/DELCORA Sewage Treatment Plant (STP) 03/24/2022 I. Introduction On March 24, 2022, an inspection team composed of staff from the U.S. Environmental Protection Agency ("EPA") Region III (hereinafter, "EPA Inspection Team") conducted a NDPES CWA Pretreatment of the DELCORA STP facility (hereinafter, "the facility"). 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. PA0027103 (hereinafter, the "Permit") and applicable State and Federal regulations. This inspection was conducted as part of a routine periodic inspection. A. Inspection Opening Conference The EPA Inspection Team arrived at the facility at est. 8:00 AM for the inspection. Inspectors met with the following facility representatives: Name Aaron Thomson Ryan Shuart Irene Fitzgerald Mike Krause Table 1: Inspection Attendee List Affiliation Telephone Email EPA Region III Inspectors and Contractors EPA 215-814-2116 Thomson.aaron@epa.gov EPA 215-814-2714 Shuart.ryan@epa.gov Site/Facility Representatives DELCORA 610-876-5523 fitzgeraldi@delcora.org Lab/Pretreatment x 213 Manager DELCORA (610) 876- Krausem@delcora.org Pretreatment 5523 Supervisor Inspector Aaron Thomson displayed their credentials to Ms. Irene Fitzgerald and Mr. Michael Krause 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 as Attachment #1. The EPA Inspection Team informed Ms. Fitzgerald that 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 cloudy, foggy and 46 degrees fahrenheit. II. Facility Activity/Walkthrough The facility has an approved pretreatment program, which is subject to the Federal Pretreatment Regulations 40 CFR Part 403. Unique Project #: 3E22WN005A Page 3 of 21 DELAWARE COUNTY REGIONAL WATER QUALITY CONTROL AUTHORITY (DELCORA)/DELCORA Sewage Treatment Plant (STP) 03/24/2022 Based on information supplied by Ms. Fitzgerald, DELCORA is currently rated for 44 million gallons per day (MGD). DELCORA is managed by a workforce of approximately 140 people during the day shift and 5 employees are present during the night. The pretreatment program is managed by Ms. Irene Fitzgerald and Mr. Michael Krause, the pretreatment manager and supervisor, respectively. They manage new IU applications and the accompanying preliminary site visits to ensure potential IUs are properly categorized. Additionally, they communicate with the township and use technology/social media to ensure new sources of wastewater discharge are identified. They also handle enforcement of their permits, either fining IU's for exceeding their limit, or discontinuing the site's permission to discharge to DELCORA. Inspector Thomson asked if any upgrades were being planned for the facility. Ms. Fitzgerald stated that, while the facility is currently rated for 44 MGD, the facility has received Delaware River Basin Commision (DRBC) approval (Attachment #2) to rerate the Western Regional Treatment Plant to 50 MGD, pending completion of an outfall extension into the Delaware River. During a site tour of the facility, led by Mr. Krause, Inspector Thomson observed composite samplers located at the influent/effluent sampling points, each containing a thermometer reading 4 degrees celsius. III. Observations A checklist was utilized during the review and is provided below. The checklist is divided into sections, with Observations listed under each section. Photographs were taken during the inspection by Inspector Thomson but were not included in this report. Visual Observations pertaining to each section are listed at the end of each section. Section 1. Background. (to be filled out before inspection) Where stream/river/tributary does the POTW discharge to? Delaware River, Chester, and Ridley Creeks As required by the approved program, list the frequency for: CIUs SNIUs Comments POTW Sampling of IUs POTW Inspection of IUs IU self-monitoring IU reporting In the last calendar year, indicate frequency of: POTW sampling of IUs POTW Inspection of IUs 1 1 Monthly/ Quarterly Monthly/ Quarterly 1+ 1+ 1 1 Monthly/ Quarterly Monthly/ Quarterly 1+ 1+ Average 2/year If 0 discharge, then semiannually Unique Project #: 3E22WN005A Page 4 of 21 DELAWARE COUNTY REGIONAL WATER QUALITY CONTROL AUTHORITY (DELCORA)/DELCORA Sewage Treatment Plant (STP) 03/24/2022 Pyromet Recycling - ceased operation in May 2021 and dismantled their production system - will continue to monitor If less than required by the approved program or less than 1/yr [403.8(f)(2)(v)], explain: Norquay, LLC - not sampled during the reporting period as they do not discharge industrial wastewater to DELCORA. Norquay submits semi-annual statements certifying all industrial wastewater is disposed of off-site, DELCORA reviews manifest during annual inspections List all the SIUs that were found to have not been sampled or not inspected at the last PCI or annual report. Indicate if they are NS (not sampled), NI (not inspected), or B (both not inspected and not sampled) Does the annual report indicate any new CIUs? List all visual observations pertaining to this section Pennsylvania Machine Works, Inc. (PMW) - not sampled during the reporting period as they do not discharge industrial wastewater to DELCORA. PMW submits semi-annual statements certifying all industrial wastewater is disposed of off-site, DELCORA reviews manifest during annual inspections Pyromet (B), Norquay (B), PMW (B) Yes No N/A Comments Quotients - June 2020 - Pharmaceutical DELCORA stated that it had experienced a CBOD passthrough event caused by high strength wastewater received from an IU in 2020. DELCORA stated that it did not notify EPA of the event. EPA asked DELCORA to review the pretreatment notification requirements in 40 CFR 403 and in its NPDES permit. Section 2. POTW sampling and inspection List the SIUs that were either not sampled or not inspected in the last 12 months [.403.8(f)(2)(v)] Indicate if they are NS (not sampled), NI (not inspected), or B (both not inspected and not sampled). Are pH, oil & grease, cyanide, volatile organics, total phenol, and sulfide collected by grab sample? List the number of grab samples Pyromet (B), Norquay (B), PMW (B) Yes No N/A Comments 1/per parameter Unique Project #: 3E22WN005A Page 5 of 21 DELAWARE COUNTY REGIONAL WATER QUALITY CONTROL AUTHORITY (DELCORA)/DELCORA Sewage Treatment Plant (STP) 03/24/2022 Are composite samples used for all other pollutants to evaluate compliance with: Categorical Standards? Local Limits? Is any unannounced sampling conducted? 1/year when possible Is POTW prepared to take samples on short notice (i.e., vehicles, personnel, preservatives, etc. available)? ALS Environmental provides official results How much time normally elapses between sample in approximately 20 days, but supplies collection and obtaining analytical results? unofficial results to the facility within a few days Does the POTW use QA/QC procedures such as: Use of calibration and maintenance plan for sampling equipment? Training for sampler? Split Samples (field)? O.J.T. Not "normal" sop but do infrequently Training for analyst? Duplicate Samples (laboratory)? Method Blanks (laboratory)? Spiked Samples (laboratory)? List all visual observations pertaining to this section Section 3. IU Self-Monitoring and Reporting As currently conducted, list frequency for: IU Self-Monitoring IU reporting If less than required by the approved program, explain If IUs sample more frequently than required, do they report all sampling results to the POTW [403.12(g)(5)]? CIUs SNIUs As required As required Monthly Monthly Comments Will assess compliance for past 4 years to determine frequency necessary Yes No N/A Comments The facility is aware of sampling and testing that is done by their IU's, that is relevant, but not required by their control mechanism; the IU's Unique Project #: 3E22WN005A Page 6 of 21 DELAWARE COUNTY REGIONAL WATER QUALITY CONTROL AUTHORITY (DELCORA)/DELCORA Sewage Treatment Plant (STP) 03/24/2022 supply the test results as requested by the Facility List all new sources IUs: N/A Have the following been received by all IUs which became new sources in the last 12 months (403.12))? Baseline Monitoring Reports Compliance Schedule Milestone Reports 90-day Final Compliance Reports How does POTW verify the information in these reports Do any IUs discharge hazardous waste? If no, how does the POTW verify this? If yes, has the IU submitted the proper notifications? List all visual observations pertaining to this section Self-monitoring, influent sampling, asking labs directly for verification; use technology/social media to target new industries Inspections/Evaluation on Site/Each hauled tank is tested n/a The Facility accepts hauled waste from 270 different sites, each site is visited and tested before being allowed to obtain a permit/insurance to discharge at the facility, each load brought to facility is sampled and tested for COD and TSS. DELCORA stated that all SIUs in SNC over the previous reporting period, 2021, are hauled waste contributors that do not discharge via the collection system. For pollutants where grab samples are taken in accordance with 40 CFR 136, DELCORA will only take one grab sample instead of a series of grabs over the sample period as part of it SOP for the POTWs sampling of the SIUs. Section 4. IU File Evaluation IU Name Category (SNIU/CIU) List IUs below: Regulated parameters (include categorical standards & local limits) Qualawash Holding LLC (40 CFR 442.10) -TRANSPORTATION EQUIPMENT CLEANING POINT SOURCE CATEGORY Flow, FOG, pH, Antimony, Arsenic, Cadmium, Chromium, Copper, Lead, Mercury, Nickel, Selenium, Silver, Zinc, Unique Project #: 3E22WN005A Page 7 of 21 DELAWARE COUNTY REGIONAL WATER QUALITY CONTROL AUTHORITY (DELCORA)/DELCORA Sewage Treatment Plant (STP) 03/24/2022 Cyanide, Phenols, Benzene, Toluene, Ethylbenzene, Xylene, PCBs - include BOD5, TSS, and COD but no established limits Address 8 Route 130 Pedricktown, NJ 08067 4 Tanker truck cleaning bays. Primary Description of IU manufacturing/pretreatment processes materials being washed out are latex, resin, polymer and oil. WWTF has Equalization Tank, Clarifier, sludge settling/dewatering. IU Name Category (SNIU/CIU) Regulated parameters (include categorical standards & local limits) Address Description of IU manufacturing/pretreatment processes Liberty Electric Power, LLC (40 CFR 423) CIU - Steam Electric Power Generating Flow, pH, FOG, Antimony, Arsenic, Cadmium, Chromium, Copper, Lead, Mercury, Nickel, Selenium, Silver, Zinc, Cyanide, Phenols, PCBs, Benzene, Ethylbenzene, Toluene, Xylenes, Temperature, 126 priority pollutants found in cooling tower water mentioned in Appendix A of 40 CFR 423 - include BOD5, TSS, TDS, COD but no established limit 1000 Industrial Highway, Eddystone, PA 19022 Electric generation (blowdown/cleaning water) - oil/water separator for oily sump discharge, blowdown not pretreated IU Name Category (SNIU/CIU) Regulated parameters (include categorical standards & local limits) Address Description of IU manufacturing/pretreatment processes Eldredge, Inc. CIU - Residual Waste Treatment including Metals, Oils & Organic Treatments (40 CFR 437.20) Flow, pH, Oil and Grease, Cyanide, Antimony, Arsenic, Cadmium, Chromium, Cobalt, Copper, Lead, Mercury, nickel, Selenium, Silver, Tin, vanadium, Zinc, Bis(2ethylhexyl) phthalate, Carbazole, o-Cresol, pCresol, n-Decane, flouranthene, nOctadecane, 2,4,6-Trichlorophenol, Phenols PCBs, Benzene, Ethylbenzene, Toulene, Xylenes - include BOD5, TSS, TDS, COD but no established limit 898 Fern Hill Road, West Chester, PA 19380 Residual Waste Treatment Unique Project #: 3E22WN005A Page 8 of 21 DELAWARE COUNTY REGIONAL WATER QUALITY CONTROL AUTHORITY (DELCORA)/DELCORA Sewage Treatment Plant (STP) 03/24/2022 IU Name ICS SDS - LLC Category (SNIU/CIU) SNIU Flow, FOG, pH, Antimony, Arsenic, Cadmium, Chromium, Copper, Lead, Regulated parameters (include categorical standards & local Mercury, Nickel, Selenium, Silver, Zinc, limits) Cyanide, PCBs, Benzene, Ethylbenzene, Toluene, Xylenes - include BOD5, TSS, COD but no established limit Address 267 Jefferson Street, Camden, NJ 08104 Description of IU manufacturing/pretreatment processes Post-Consumer food and beverage storage container recycling Section 5. A File Review Checklist IU Name: Qualawash Holding LLC Is the IU categorical (CIU), significant non-categorical CIU (SNIU), or other (O)? Yes No N/A Comments Is the IU properly categorized? The IU was covered by 40 CFR 442.16 and has submitted a pollutant management plan. Control Mechanism List if the file contains the following: Does the file contain regulatory items? List each, including IU permits, local limits, etc. Yes, electronic copies of required information were received including Permits, Enforcement documentation, SMRs, Inspection reports, Spill plans, and POTW monitoring events. an updated control mechanism application and/or survey questionnaire? Application is included in the Slug control plan document a current control mechanism Effective 11/2/18 to 10/31/22 documentation of how control mechanism limits and requirements were established. No Fact sheet was provided however the permit includes a description and the limitation determination rationale and regulatory notes Were local limits and/or categorical standards properly applied? The permit does not include a requirement to include a certification Unique Project #: 3E22WN005A Page 9 of 21 DELAWARE COUNTY REGIONAL WATER QUALITY CONTROL AUTHORITY (DELCORA)/DELCORA Sewage Treatment Plant (STP) 03/24/2022 statement of its intent to utilize a Pollutant Management Plan, see 40 CFR 442.16(b)(2) PMP in lieu of numeric If applicable, were production-based standards correctly applied? limits. 40 CFR 442 has concentration-based limitations. If applicable, was the combined waste stream formula correctly applied? CWT not used If applicable, were TTO requirements or alternatives correctly applied? No TOMP, only PMP Does the control mechanism include the following: sampling location and frequency? Part III of Permit sample type? Is the permit effective for 5 years or less? Part III of Permit Effective 11/2/18 to 10/31/22 POTW Inspections of IUs How many POTW inspections were conducted and documented in the last 12 months? Yes, date of inspection is 10/6/2021 Does the inspection report include the following information: Inspector name Irene Fitzgerald Inspection date/time 10/6/21 1:30PM Name of IU official contacted. Cover Page Review of manufacturing facilities Cover Page Verification of production data if needed Section V Identification of wastewater sources, flow and types of discharges (e.g. continuous, intermittent, batch). Section V Section X contains specific housekeeping questions but none about the Condition of pretreatment facilities pretreatment facilities; information about the pretreatment facilities included in the narrative response Evaluation of chemical storage areas Section VI Evaluation of need for spill/slug control plan at least every 2 years Section II Evaluation of spill/slug control procedures Section II Evaluation of housekeeping practices Throughout Inspection template Unique Project #: 3E22WN005A Page 10 of 21 DELAWARE COUNTY REGIONAL WATER QUALITY CONTROL AUTHORITY (DELCORA)/DELCORA Sewage Treatment Plant (STP) 03/24/2022 Evaluation of potential for hazardous waste discharge Section V Evaluation of self-monitoring equipment and techniques Section VIII Evaluation of lab procedures Section VII Evaluation of monitoring records Section I POTW Sampling of IUs How many sampling visits were conducted and documented in the last 12 months? 2 Sampling Events occurred Does the sampling documentation include: Name of the sampling personnel COC sample date/time COC sample type COC, Grab sample location wastewater flow during sampling COC All sample were grab samples and do no list flow data sample preservation COC chain of custody analytical methods used Lab Report analysis date Lab Report name of analyst Lab Report all analytical data Were all the regulated parameters monitored? Lab Report Were 40 CFR 136 analytical methods used? Lab Report IU Self-Monitoring and Reporting Has the IU submitted all required self-monitoring reports in the last 12 months? Were all regulated parameters monitored at the required frequency? Slug/Spill Control Have any slugs/spills been documented in the file? Did the POTW require development of a slug/spill control plan? Has the IU developed a slug/spill control plan? When was the plan last updated? 9/21/2020 SPCC plan received was an older version from 2017 Does the slug/spill plan contain: Description of discharge practices Section II Description of stored chemicals Section II Procedure to prevent slugs/spills Section III Part 9 Procedure to notify POTW of slugs/spills Section III Part 12 Unique Project #: 3E22WN005A Page 11 of 21 DELAWARE COUNTY REGIONAL WATER QUALITY CONTROL AUTHORITY (DELCORA)/DELCORA Sewage Treatment Plant (STP) 03/24/2022 Follow-up practices to minimize damage from slugs/spills Section III Part 12 All information was provided. Qualawash's permit does not include a requirement to include a certification statement of its intent List all visual observations pertaining to this section to utilize a Pollutant Management Plan, see 40 CFR 442.16(b)(2). Condition of the pretreatment facilities was not included as a question on the Inspection template. Section 5. B File Review Checklist IU Name: Liberty Electric Power, LLC Is the IU categorical (CIU), significant non-categorical CIU (SNIU), or other (O)? Yes No N/A Comments Is the IU properly categorized? Control Mechanism List if the file contains the following: Does the file contain regulatory items? List each, including IU permits, local limits, etc. an updated control mechanism application and/or survey questionnaire? Yes, electronic copies of required information were received including Permits, Enforcement documentation, SMRs, Inspection reports, Spill plans, and POTW monitoring events. Application dated 10/29/21 reviewed a current control mechanism documentation of how control mechanism limits and requirements were established. Were local limits and/or categorical standards properly applied? If applicable, were production-based standards correctly applied? Effective 5/1/21 to 4/30/25 No Fact sheet was provided however the permit includes a description and the limitation determination rationale and regulatory notes Concentration based limits If applicable, was the combined waste stream formula correctly applied? CWT not used If applicable, were TTO requirements or alternatives correctly applied? PMP Does the control mechanism include the following: sampling location and frequency? Part III of Permit Unique Project #: 3E22WN005A Page 12 of 21 DELAWARE COUNTY REGIONAL WATER QUALITY CONTROL AUTHORITY (DELCORA)/DELCORA Sewage Treatment Plant (STP) 03/24/2022 sample type? Part III of Permit Is the permit effective for 5 years or less? Effective 5/1/21 to 4/30/25 POTW Inspections of IUs How many POTW inspections were conducted and documented in the last 12 months? Does the inspection report include the following information: Inspector name Inspection date/time Name of IU official contacted. Review of manufacturing facilities Verification of production data if needed Identification of wastewater sources, flow and types of discharges (e.g. continuous, intermittent, batch). Condition of pretreatment facilities Evaluation of chemical storage areas Evaluation of need for spill/slug control plan at least every 2 years Evaluation of spill/slug control procedures Evaluation of housekeeping practices Evaluation of potential for hazardous waste discharge Evaluation of self-monitoring equipment and techniques Evaluation of lab procedures Evaluation of monitoring records POTW Sampling of IUs How many sampling visits were conducted and documented in the last 12 months? Does the sampling documentation include: Name of the sampling personnel sample date/time sample type sample location Yes date of inspection is 9/15/2021 Irene Fitzgerald & Meg O'Donnel 9/15/21 10:15 AM Cover Page Cover Page Section IV Section IV Section X contains specific housekeeping questions but none about the pretreatment facilities; information about the pretreatment facilities included in the narrative response Section VI Section II Section II Throughout Inspection template Section V Section VIII Section VII Section I 2 - most recent supplied 9/19/21 COC COC COC, Grab & Composite COC Unique Project #: 3E22WN005A Page 13 of 21 DELAWARE COUNTY REGIONAL WATER QUALITY CONTROL AUTHORITY (DELCORA)/DELCORA Sewage Treatment Plant (STP) 03/24/2022 wastewater flow during sampling sample preservation COC chain of custody analytical methods used Lab Report analysis date Lab Report name of analyst Lab Report all analytical data Were all the regulated parameters monitored? Lab Report Were 40 CFR 136 analytical methods used? Lab Report IU Self-Monitoring and Reporting Has the IU submitted all required self-monitoring reports in the last 12 months? Were all regulated parameters monitored at the required frequency? Slug/Spill Control Have any slugs/spills been documented in the file? Did the POTW require development of a slug/spill control plan? Has the IU developed a slug/spill control plan? When was the plan last updated? 11/30/2021 SPCC plan signed and dated, the document supplied contains revisions and comments intended for a newer version Does the slug/spill plan contain: Description of discharge practices Description of stored chemicals Discharge Process Storage Tanks and Material Inventory Procedure to prevent slugs/spills Pre-Release Planning Procedure to notify POTW of slugs/spills Spill Response Follow-up practices to minimize damage from slugs/spills Response Procedures List all visual observations pertaining to this section All information was provided. Condition of the pretreatment facilities was not included as a question on the Inspection template. Section 5. C File Review Checklist IU Name: Is the IU categorical (CIU), significant non-categorical (SNIU), or other (O)? Unique Project #: 3E22WN005A Eldredge, Inc CIU Page 14 of 21 DELAWARE COUNTY REGIONAL WATER QUALITY CONTROL AUTHORITY (DELCORA)/DELCORA Sewage Treatment Plant (STP) 03/24/2022 Yes No N/A Comments Is the IU properly categorized? 40 CFR 437.20 Control Mechanism List if the file contains the following: Does the file contain regulatory items? List each, including IU permits, local limits, etc. an updated control mechanism application and/or survey questionnaire? Yes, electronic copies of required information was received including Permits, Enforcement documentation, SMRs, Inspection reports, Spill plans, and POTW monitoring events. 12/30/19 a current control mechanism documentation of how control mechanism limits and requirements were established. Were local limits and/or categorical standards properly applied? Effective 6/1/20 to 5/31/24 No Fact sheet was provided however the permit includes a description and the limitation determination rationale and regulatory notes If applicable, were production-based standards correctly applied? concentration-based limitations. If applicable, was the combined waste stream formula correctly applied? CWT not used If applicable, were TTO requirements or alternatives correctly applied? PMP Does the control mechanism include the following: sampling location and frequency? Part III of Permit sample type? Part II of Permit Is the permit effective for 5 years or less? Effective 6/1/20 to 5/31/24 POTW Inspections of IUs How many POTW inspections were conducted and documented in the last 12 months? Does the inspection report include the following information: Inspector name Inspection date/time Name of IU official contacted. Review of manufacturing facilities Verification of production data if needed Identification of wastewater sources, flow and types of discharges (e.g. continuous, intermittent, batch). Yes date of inspection is 6/14/2021 Irene Fitzgerald & Meg O'Donnell 6/14/21 11:40 AM Cover Page Cover Page Section V Section V Unique Project #: 3E22WN005A Page 15 of 21 DELAWARE COUNTY REGIONAL WATER QUALITY CONTROL AUTHORITY (DELCORA)/DELCORA Sewage Treatment Plant (STP) 03/24/2022 Section X contains specific housekeeping questions but none about the pretreatment Condition of pretreatment facilities facilities; information about the pretreatment facilities included in the narrative response Evaluation of chemical storage areas Evaluation of need for spill/slug control plan at least every 2 years Section VI Section II Evaluation of spill/slug control procedures Evaluation of housekeeping practices Section II Throughout Inspection template Evaluation of potential for hazardous waste discharge Section V Evaluation of self-monitoring equipment and techniques Section VIII Evaluation of lab procedures Section VII Evaluation of monitoring records Section I POTW Sampling of IUs How many sampling visits were conducted and documented in the last 12 months? 1 Sampling Events occurred Does the sampling documentation include: Name of the sampling personnel COC sample date/time COC sample type COC, Grab sample location wastewater flow during sampling COC All sample were grab samples and do no list flow data sample preservation COC chain of custody analytical methods used Lab Report analysis date Lab Report name of analyst Lab Report all analytical data Were all the regulated parameters monitored? Lab Report Were 40 CFR 136 analytical methods used? Lab Report IU Self-Monitoring and Reporting Has the IU submitted all required self-monitoring reports in the last 12 months? Were all regulated parameters monitored at the required frequency? Unique Project #: 3E22WN005A Page 16 of 21 DELAWARE COUNTY REGIONAL WATER QUALITY CONTROL AUTHORITY (DELCORA)/DELCORA Sewage Treatment Plant (STP) 03/24/2022 Slug/Spill Control Have any slugs/spills been documented in the file? Did the POTW require development of a slug/spill control plan? Has the IU developed a slug/spill control plan? When was the plan last updated? 10/31/2015 SPCC plan signed and dated Does the slug/spill plan contain: Description of discharge practices C 1.1 Potential Sources... Description of stored chemicals Sections A & C Procedure to prevent slugs/spills Section C Procedure to notify POTW of slugs/spills Section C Follow-up practices to minimize damage from slugs/spills Sections C & D List all visual observations pertaining to this section All information was provided. Condition of the pretreatment facilities was not included as a question on the Inspection template. Section 5. D File Review Checklist IU Name: ICS SDS - LLC Is the IU categorical (CIU), significant non-categorical (SNIU), or other (O)? SNIU Yes No N/A Comments Is the IU properly categorized? Control Mechanism List if the file contains the following: Does the file contain regulatory items? List each, including IU permits, local limits, etc. Yes, electronic copies of required information was received including Permits, Enforcement documentation, SMRs, Inspection reports, Spill plans, and POTW monitoring events. an updated control mechanism application and/or survey questionnaire? 3/5/19 a current control mechanism Effective 5/1/19 to 4/30/23 documentation of how control mechanism limits and requirements were established. No Fact sheet was provided however the permit includes a description and the limitation Unique Project #: 3E22WN005A Page 17 of 21 DELAWARE COUNTY REGIONAL WATER QUALITY CONTROL AUTHORITY (DELCORA)/DELCORA Sewage Treatment Plant (STP) 03/24/2022 determination rationale and regulatory notes Were local limits and/or categorical standards properly applied? If applicable, were production-based standards correctly applied? concentration-based limitations. If applicable, was the combined waste stream formula correctly applied? CWT not used If applicable, were TTO requirements or alternatives correctly applied? PMP Does the control mechanism include the following: sampling location and frequency? Part III of Permit sample type? Part III of Permit Is the permit effective for 5 years or less? Effective 5/1/19 to 4/30/23 POTW Inspections of IUs How many POTW inspections were conducted and documented in the last 12 months? Yes, date of inspection is 12/13/2021 Does the inspection report include the following information: Inspector name Michael Krause Inspection date/time 12/13/21 10:00 AM Name of IU official contacted. Cover Page Review of manufacturing facilities Cover Page Verification of production data if needed Section V Identification of wastewater sources, flow and types of discharges (e.g. continuous, intermittent, batch). Section V Section X contains specific housekeeping questions but none about the Condition of pretreatment facilities pretreatment facilities; information about the pretreatment facilities included in the narrative response Evaluation of chemical storage areas Section VI Evaluation of need for spill/slug control plan at least every 2 years Section II Evaluation of spill/slug control procedures Section II Evaluation of housekeeping practices Throughout Inspection template Evaluation of potential for hazardous waste discharge Section V Evaluation of self-monitoring equipment and techniques Section VIII Unique Project #: 3E22WN005A Page 18 of 21 DELAWARE COUNTY REGIONAL WATER QUALITY CONTROL AUTHORITY (DELCORA)/DELCORA Sewage Treatment Plant (STP) 03/24/2022 Evaluation of lab procedures Section VII Evaluation of monitoring records Section I POTW Sampling of IUs How many sampling visits were conducted and documented in the last 12 months? 2 Sampling Events occurred Does the sampling documentation include: Name of the sampling personnel COC sample date/time COC sample type COC, Grab sample location wastewater flow during sampling COC All sample were grab samples and do no list flow data sample preservation COC chain of custody analytical methods used Lab Report analysis date Lab Report name of analyst Lab Report all analytical data Were all the regulated parameters monitored? Lab Report Were 40 CFR 136 analytical methods used? Lab Report IU Self-Monitoring and Reporting Has the IU submitted all required self-monitoring reports in the last 12 months? Were all regulated parameters monitored at the required frequency? Slug/Spill Control Have any slugs/spills been documented in the file? Did the POTW require development of a slug/spill control plan? Has the IU developed a slug/spill control plan? When was the plan last updated? No Date Indicated/Signature On ICS-SDS Spill Response Plan Provided Does the slug/spill plan contain: Description of discharge practices Section 1. A Description of stored chemicals Section 1. B Procedure to prevent slugs/spills Section 1. D, E & F Procedure to notify POTW of slugs/spills Section 1. C Follow-up practices to minimize damage from slugs/spills Section 1. G Unique Project #: 3E22WN005A Page 19 of 21 DELAWARE COUNTY REGIONAL WATER QUALITY CONTROL AUTHORITY (DELCORA)/DELCORA Sewage Treatment Plant (STP) 03/24/2022 List all visual observations pertaining to this section All information was provided. Condition of the pretreatment facilities was not included as a question on the Inspection template. IV. Records Review As part of the inspection, prior to the inspection, the EPA Inspection Team requested the documentation listed in Attachment #14. Per discussion between Ms. Fitzgerald and Inspector Thomson prior to the inspection, of the IU's selected for file review, Covanta was replaced with Liberty Electric and the time periods of documents requested "over 3 years" were reduced to 2 years. It may also be noted that Quotient Sciences was not included in the file review section, although supplied documents were reviewed and attached. Records relevant to the inspection report are attached and listed below. During the file review, Inspector Thomson observed the following IU's were in significant noncompliance (SNC); Eldredge, Inc.; Delaware County Solid Waste Authority (DCSWA); Refresco Beverages US, Inc.; and Quotient Sciences. Ms. Fitzgerald stated Eldredge, Inc., a waste disposal/recycling facility, changed their process is unable to meet regulated parameters and stopped discharging to the facility at the end of March 21, 2022. Eldredge had TRC violations of the octadecane monthly concentration limit in October 2020-March 2021 as well as TRC/Chronic violations of the zinc monthly concentration limit during October 2020-March 2021 and January 2021-June 2021. DCSWA was in SNC during September 2021 for failure to monitor, and a fine was issued. Refresco Beverages US, Inc. had TRC violations of the FOG concentration limit during January 2021-June 2021, April 2021-September 2021 and July 2021December 2021 as well as chronic violations of the FOG concentration limit during April 2021September 2021 and July 2021-December 2021, all of which were met with a fine by the facility. Quotient Sciences had a TRC violation of the acetone monthly concentration limit during October 2020 - March 2021 for which a penalty was issued. Additionally, although not in SNC, Qualawash has been asked to cease discharge to the facility due to high oil and grease in their discharge, until Qualawash can identify and fix their elevated oil and grease levels. V. Closing Conference After the facility inspection, the EPA Inspection Team met with the facility representatives for a closing conference. The EPA Inspection Team shared preliminary observations with the facility. The EPA Inspection Team reiterated to the facility representatives 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 Unique Project #: 3E22WN005A Page 20 of 21 DELAWARE COUNTY REGIONAL WATER QUALITY CONTROL AUTHORITY (DELCORA)/DELCORA Sewage Treatment Plant (STP) 03/24/2022 that were not identified at the time of the closing conference after EPA reviewed additional materials following the inspection. The inspection concluded at 2:00 PM VI. List of Attachments Attachment #1 - PADEP-final permit 4-1-2021 - Consolidated Attachment #2 - DELCORA Re-rate 1992-018CP-3 Attachment #3 - NPDES Violations Reported Attachment #4.A-#4.Y - DMRs Attachment #5.A-#5.K - Inspections Attachment #6.A-#6.E - IU Permits Attachment #7.A-#7.S - NOVs Attachment #8.A-#8.J - SMRs Attachment #9.A-#9.L - SNC & Fines Attachment #10.A-#10.E - Spill Plans Attachment #11.A-#11.S - VMR Attachment #12 IUs List Unique Project #: 3E22WN005A Page 21 of 21