Document bB2aj0m8ZEprDwapX3nEoO0Z1
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 3
Four Penn Center 1600 JFK Blvd.
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/Longitude: County/Parish: General Permit No.: Site Permit No.: NAICS Code: Unique Project #:
Clean Water Act Compliance Inspection Report
05/15/2024
National Pollutant Discharge Elimination System
Domestic Wastewater (Non-Municipal)
WV Department of Agriculture (Guthrie Center)
WV Department of Agriculture (Guthrie Center)
WV Department of Agriculture (Guthrie Center)
419 Gus R Douglass Lane
Charleston, WV
38.44265, -81.68186
Kanawha County
WV0103110
WVG550262
531120
SIC: 6512
ECAD-512
("NPDES")
Site/Facility Representative(s):
Point of Contact
Janice Cottrell, Plant Operator
Phone: (304) 761-0277 Email: jcottrell@wvda.us
Wayne Fisher, Maintenance Mechanic
Phone: (304) 610-9738 Email: wfisher@wvda.us
EPA Inspectors:
Edward Simas, Lead Inspector, 3ED32
Phone: (215) 814-2120 Email: Simas.Edward@epa.gov
Dominic Cotton, Secondary Inspector, 3ED32
Phone: (215) 814-8979 Email: Cotton.dominic@epa.gov
State/Local Inspectors:
Morgan Agee, West Virginia Department of Environmental Protection ("WVDEP")
Phone: (681) 341-8979 Email: Morgan.l.agee@wv.gov
Mandie Simpson, WVDEP
Phone: (304) 210-4356 Email: Mandie.j.simpson@wv.gov
Report Preparer Signature/Date
Supervisor Signature/Date
EDWARD SIMAS
Digitally signed by EDWARD SIMAS Date: 2024.07.15 11:37:21 -04'00'
Edward Simas, Inspector NPDES Enforcement Section 1, (3ED32)
MICHAEL
Digitally signed by MICHAEL GREENWALD
GREENWALD 12:10:34 -04'00' Date: 2024.07.15
Michael Greenwald, Acting NPDES Section 1 Chief
NPDES Enforcement Section 1 (3ED32)
Date Date
Unique Project#: ECAD-512
WV Department of Agriculture (Guthrie Center) 05/15/2024
Section
Table of Contents
Page
I Introduction............................................................................ 3 A Inspection Opening Conference...................................................................... 3 B Weather and Precipitation Conditions............................................................. 3 C Summary of the Facility.................................................................................. 4
II Facility Activity.............................................................................................. 5
III Observations.................................................................................................... 5 - 11
IV Records Review............................................................................................... 11
V Closing Conference......................................................................................... 12
VI List of Attachments.......................................................................................... 13
Unique Project #: ECAD-512
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WV Department of Agriculture (Guthrie Center) 05/15/2024
I. Introduction
On May 15, 2024, an inspection team from the U.S. Environmental Protection Agency ("EPA") Region III (hereinafter, "EPA Inspection Team") conducted a domestic wastewater inspection of the West Virginia Department of Agriculture, Guthrie Center (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 NPDES WVDEP Permit No. WVG550262 (hereinafter, the "Permit") and applicable State and Federal regulations.
A. Inspection Opening Conference
The EPA Inspection Team arrived at the facility at 1:00PM for the inspection. Inspectors met with the following facility representatives:
Name Edward Simas Dominic Cotton
Janice Cottrell Wayne Fisher
Morgan Agee Mandie Simpson
Table 1: Inspection Attendee List
Affiliation
Telephone
Email
EPA Region III Inspectors and Contractors
Lead Inspector
(215) 814-
Simas.Edward@epa.gov
2120
Secondary Inspector (215) 814-
Cotton.Dominic@epa.gov
2046
Site/Facility Representatives
Plant Operator
(304) 761-
jcottrell@wvda.us
0277
Maintenance
(304) 610-
wfisher@wvda.us
Mechanic
9738
State or County Representatives
State Inspector
(681) 341-
Morgan.l.agee@wv.gov
8979
State Inspector
(304) 210-
Mandie.j.simpson@wv.gov
4356
Edward Simas and Dominic Cotton displayed their credentials to Ms. Cottrell ("plant operator") 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 in Attachment 2. The EPA Inspection Team informed the plant operator 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, the weather was hot and humid with scattered showers. National Oceanic and Atmospheric Administration (NOAA) National Weather Service precipitation data for the date of the inspection and 5 days prior are provided in Table 2 below:
Unique Project #: ECAD-512
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WV Department of Agriculture (Guthrie Center) 05/15/2024
Table 2. Precipitation Data
Station Name
Date
Sissonville 1 SW, WV US USC00468191 Sissonville 1 SW, WV US USC00468191 Sissonville 1 SW, WV US USC00468191 Sissonville 1 SW, WV US USC00468191 Sissonville 1 SW, WV US USC00468191 Sissonville 1 SW, WV US USC00468191
5/10/2024 5/11/2024 5/12/2024 5/13/2024 5/14/2024 5/15/2024
Precipitation Amount (inches)1
0.06 0.11 0.10 0.00 0.08
0.20
C. Summary of the Site/Facility
The WV Department of Agriculture, Guthrie Center operates a wastewater treatment plant that is designed for an average of 18,000 GPD of flow and receives wastewater from an estimated 10 - 15 residential houses in the area. The plant operator is unaware of the exact number of connections to the plant. The general permit allows the facility to discharge treated sewage into the Fisher Branch of the Pocatalico River. The Permit applies to sewage treatment and systems of domestic sewage only with a design capability of 50,000 gallons per day or less. The facility has one operator (the plant operator previously discussed) that is class S certified and one maintenance mechanic (Mr. Wayne Fisher) that services the facility. The facility has a single rectangular tank that is divided into the influent sludge, aeration, and clarifier chambers. A pump station is located about a mile southeast of the facility. Following the clarifier, wastewater flows through a chlorine contact chamber before discharging to Outfall 001. During the inspection, the plant operator stated that chlorine tablets are added every other day as the facility only has an operator every other day. According to a call with the plant operator on June 24, 2024, there is now an operator every day at the plant. It is unclear if the chlorine tablets are still added every other day. The plant has staff on site daily Monday - Friday from 8:00AM - 4:00PM. The plant operates 24/7 and does not have staff outside of working hours. The plant also does not have a remote alarm system, and an operator must be within viewing and hearing distance of the plant to notice an alarm. The plant also does not have any backup electrical power available.
The plant operator also stated the collection system infrastructure is dated. The facility lined one of the worst manholes ("Manhole 3") located around the nearby lake recently. It is unclear as to the status of the rest of the plant's manholes. The plant also does not have a digital method of calculating flow. Flow is calculated manually through time clocks for the past two years at the plant. Prior to using the time clocks, the plant utilized a third-party service that was producing inaccurate data (Attachment 3 & Photo P5150092). BOD and Fecal Coliform bench records are
1 Source: NOAA National Climatic Data Center (http://www.ncdc.noaa.gov/).
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WV Department of Agriculture (Guthrie Center) 05/15/2024
located in Attachment 5. The plant does not have a sludge hauling schedule, however it hires "Stans Backhoe and Ditch Service" to haul the sludge as needed. The latest sludge invoice is dated September 28, 2023 and is the most recent. The plant does not currently have a schedule for wasting sludge. In the past - sludge used to be wasted every other day, with the plant down about 10-15 minutes to accomplish this. However, the plant diverged from this schedule recently due to servicing a blockage in the wasted sludge tank pipe. It is unclear what the current frequency is for wasting sludge. . The plant operator receives training from Cedar Lakes every two years. This is the same facility that gave the plant operator her class S wastewater license. The plant operator documents pump operation time and flow data in her bench sheets (P5150091). A third-party company, "Sturm Environmental Services", samples and analyses all other parameters within the Permit.
II. Facility Activity
During the inspection, the EPA Inspection Team observed the entire plant and collection system. This includes: the pump station, influent sludge chamber, aeration chamber, clarifier, chlorine contact chamber, and Outfall 001. The inspection observations were made pursuant to the requirements of the Permit. The observations from the inspection are described in detail below in the Observations section. Photographs were taken during the inspection by Dominic Cotton, and are provided in Attachment 1.
III. Observations
Reporting & Monitoring Data
(1) Section B.3 "Other Requirements" of the Permit states, "All required monitoring and reporting shall be submitted electronically to the Division of Water & Waste Management within 25 days of the end of the reporting period. Additional information pertaining to effluent monitoring and reporting can be found in Section III of Appendix A of this permit."
(2) Appendix A.III. Monitoring and Reporting: 1. Representative Sampling, Sample Type and Sampling Period of the Permit states, "Samples and measurements taken for the purpose of monitoring shall be representative of the monitored activity and during normal operation. "Grab" samples are required for all regulated pollutant parameters."
Observation 1:
The facility had a total of 38 effluent limit exceedances according to EPA's ("Enforcement and Compliance History Online") public website from 6/30/2019 to 6/30/2023 at Outfall 001. This included: (3) BOD, 5-day, 20 deg C, (3) Chlorine, total residual, (17) Coliform, fecal general, (3) Flow, in conduit or thru treatment plant, (1) Nitrogen, ammonia total [as N], (7) Oxygen, dissolved [DO], (1) pH, and (3) Solids, total suspended exceedances. Attachment 3 summarizes the effluent limit exceedances in "Effluent Limit Exceedances" tab. Table 3 summarizes this below.
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WV Department of Agriculture (Guthrie Center) 05/15/2024
Table 3. NPDES Permit No. WVG550262 effluent exceedances from 6/30/2019 - 6/30/2023
Monitoring Period End
Date 6/30/2023 6/30/2023 3/31/2023 12/31/2022 12/31/2022 9/30/2022 9/30/2022 9/30/2022 9/30/2022 9/30/2022 6/30/2022 6/30/2022
6/30/2022
3/31/2022 12/31/2021
6/30/2021
3/31/2021 3/31/2021 3/31/2021 9/30/2020 9/30/2020 9/30/2020 6/30/2020 6/30/2020 6/30/2020 6/30/2020 3/31/2020 3/31/2020 3/31/2020 12/31/2019 12/31/2019 12/31/2019
Parameter Name
Oxygen, dissolved [DO] BOD, 5-day, 20 deg. C Oxygen, dissolved [DO]
pH Solids, total suspended Oxygen, dissolved [DO] Solids, total suspended Coliform, fecal general Coliform, fecal general Coliform, fecal general Oxygen, dissolved [DO] BOD, 5-day, 20 deg. C Flow, in conduit or thru
treatment plant Oxygen, dissolved [DO] Oxygen, dissolved [DO] Flow, in conduit or thru
treatment plant Coliform, fecal general Coliform, fecal general Coliform, fecal general Coliform, fecal general Coliform, fecal general Coliform, fecal general Oxygen, dissolved [DO] BOD, 5-day, 20 deg. C Coliform, fecal general Coliform, fecal general Coliform, fecal general Coliform, fecal general Coliform, fecal general Solids, total suspended Coliform, fecal general Coliform, fecal general
DMR Value
4.81 7 5 5.8 42
4.73 50 2419.6 2419.6 2419.6 4.38 6.2
0.0187
4.76 5.11
0.0245
1203.3 1203.3 1203.3 2419.6 2419.6 2419.6 3.14
6.5 2419.6 2419.6 1553.1 1553.1 1553.1
32 2419.6 2419.6
Permit Limit
6 5 6 6 30 6 30 200 500 400 6 5
0.018
6 6
0.018
200 500 400 200 500 400
6 5 400 500 200 500 400 30 400 200
Units
mg/L mg/L mg/L SU mg/L mg/L mg/L MPN/100mL MPN/100mL MPN/100mL mg/L mg/L
MGD
mg/L mg/L
MGD
MPN/100mL MPN/100mL MPN/100mL MPN/100mL MPN/100mL MPN/100mL
mg/L mg/L MPN/100mL MPN/100mL MPN/100mL MPN/100mL MPN/100mL mg/L MPN/100mL MPN/100mL
Limit Type
INST MIN MO AVG INST MIN INST MIN MO AVG INST MIN MO AVG MO GEOMN INST MAX DAILY MX INST MIN MO AVG
DAILY MX
INST MIN INST MIN
DAILY MX
MO GEOMN INST MAX DAILY MX MO GEOMN INST MAX DAILY MX INST MIN MO AVG DAILY MX INST MAX MO GEOMN INST MAX DAILY MX MO AVG DAILY MX MO GEOMN
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12/31/2019 9/30/2019 9/30/2019 6/30/2019 6/30/2019 6/30/2019
Coliform, fecal general Flow, in conduit or thru
treatment plant Chlorine, total residual Nitrogen, ammonia total
[as N] Chlorine, total residual Chlorine, total residual
WV Department of Agriculture (Guthrie Center) 05/15/2024
2419.6 500
MPN/100mL
INST MAX
0.144 0.018
MGD
DAILY MX
0.0295 0.028
mg/L
MO AVG
4.92
3
mg/L
MO AVG
0.07 0.028 0.07 0.057
mg/L mg/L
MO AVG DAILY MX
Observation 2:
The permittee did not sample and analyze 25 permitted parameters for the monitoring end date period of 3/31/2024 (Attachment 3 - "Discharge Monitoring Reports 2019-2024"). The 25 permitted parameters are included in Table 4 below.
Table 4. NPDES Permit No. WVG550262 No Sample/Analysis
Outfall # Monitoring Period End Date
Parameter Name
DMR Value
1
3/31/2024
Oxygen, dissolved [DO]
No Data
1
3/31/2024
BOD, 5-day, 20 deg. C
No Data
1
3/31/2024
BOD, 5-day, 20 deg. C
No Data
1
3/31/2024
BOD, 5-day, 20 deg. C
No Data
1
3/31/2024
BOD, 5-day, 20 deg. C
No Data
1
3/31/2024
BOD, 5-day, 20 deg. C
No Data
1
3/31/2024
pH
No Data
1
3/31/2024
pH
No Data
1
3/31/2024
Solids, total suspended
No Data
1
3/31/2024
Solids, total suspended
No Data
1
3/31/2024
Solids, total suspended
No Data
1
3/31/2024
Solids, total suspended
No Data
1
3/31/2024
Solids, total suspended
No Data
1
3/31/2024
Nitrogen, ammonia total [as N]
No Data
1
3/31/2024
Nitrogen, ammonia total [as N]
No Data
1
3/31/2024
Nitrogen, ammonia total [as N]
No Data
1
3/31/2024
Nitrogen, ammonia total [as N]
No Data
1
3/31/2024
Nitrogen, ammonia total [as N]
No Data
1
3/31/2024
Flow, in conduit or thru treatment plant No Data
1
3/31/2024
Chlorine, total residual
No Data
1
3/31/2024
Chlorine, total residual
No Data
1
3/31/2024
Chlorine, total residual
No Data
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WV Department of Agriculture (Guthrie Center) 05/15/2024
Observation 3:
The permittee may not have analyzed flow "representative" of the monitored activity during normal operations. Table 3 above notes three outlier flows of "144,000 gal/day", "24,500 gal/day", and "18,700 gal/day". These flows would all exceed the designed capacity of the plant at "18,000 gal/day".
Observation 4:
The plant operator stated that a previous third-party analyzing flow reported "No Discharge" in all parameters within three different monitoring periods including: 1/12/2024, 10/16/2023, and 1/5/2021. Table 5 below reports the 75 parameters. The plant operator states the facility discontinued with the third party about two years ago, and that she manually monitors flow utilizing a bucket and time clocks at the facility. However, substitutes for her often do not understand how to analyze the flow resulting in the inaccurate data for 2023 and 2024.
Table 5: NPDES Permit No. WVG550262 "No Data" Reported
Outfall #
Monitoring Period End Date
Parameter Name
DMR Value
1 12/31/2023 Oxygen, dissolved [DO] 1 12/31/2023 BOD, 5-day, 20 deg. C 1 12/31/2023 BOD, 5-day, 20 deg. C 1 12/31/2023 BOD, 5-day, 20 deg. C 1 12/31/2023 BOD, 5-day, 20 deg. C 1 12/31/2023 BOD, 5-day, 20 deg. C 1 12/31/2023 pH 1 12/31/2023 pH 1 12/31/2023 Solids, total suspended 1 12/31/2023 Solids, total suspended 1 12/31/2023 Solids, total suspended 1 12/31/2023 Solids, total suspended 1 12/31/2023 Solids, total suspended 1 12/31/2023 Nitrogen, ammonia total [as N] 1 12/31/2023 Nitrogen, ammonia total [as N] 1 12/31/2023 Nitrogen, ammonia total [as N] 1 12/31/2023 Nitrogen, ammonia total [as N]
No Discharge No Discharge No Discharge No Discharge No Discharge No Discharge No Discharge No Discharge No Discharge No Discharge No Discharge No Discharge No Discharge No Discharge No Discharge No Discharge No Discharge
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WV Department of Agriculture (Guthrie Center) 05/15/2024
1 12/31/2023 Nitrogen, ammonia total [as N] 1 12/31/2023 Flow, in conduit or thru
treatment plant 1 12/31/2023 Chlorine, total residual 1 12/31/2023 Chlorine, total residual 1 12/31/2023 Chlorine, total residual 1 12/31/2023 Coliform, fecal general 1 12/31/2023 Coliform, fecal general 1 12/31/2023 Coliform, fecal general 1 9/30/2023 Oxygen, dissolved [DO] 1 9/30/2023 BOD, 5-day, 20 deg. C 1 9/30/2023 BOD, 5-day, 20 deg. C 1 9/30/2023 BOD, 5-day, 20 deg. C 1 9/30/2023 BOD, 5-day, 20 deg. C 1 9/30/2023 BOD, 5-day, 20 deg. C 1 9/30/2023 pH 1 9/30/2023 pH 1 9/30/2023 Solids, total suspended 1 9/30/2023 Solids, total suspended 1 9/30/2023 Solids, total suspended 1 9/30/2023 Solids, total suspended 1 9/30/2023 Solids, total suspended 1 9/30/2023 Nitrogen, ammonia total [as N] 1 9/30/2023 Nitrogen, ammonia total [as N] 1 9/30/2023 Nitrogen, ammonia total [as N] 1 9/30/2023 Nitrogen, ammonia total [as N] 1 9/30/2023 Nitrogen, ammonia total [as N] 1 9/30/2023 Flow, in conduit or thru
treatment plant 1 9/30/2023 Chlorine, total residual 1 9/30/2023 Chlorine, total residual 1 9/30/2023 Chlorine, total residual 1 9/30/2023 Coliform, fecal general 1 9/30/2023 Coliform, fecal general 1 9/30/2023 Coliform, fecal general 1 12/31/2020 Oxygen, dissolved [DO] 1 12/31/2020 BOD, 5-day, 20 deg. C
No Discharge
No Discharge
No Discharge No Discharge No Discharge No Discharge No Discharge No Discharge No Discharge No Discharge No Discharge No Discharge No Discharge No Discharge No Discharge No Discharge No Discharge No Discharge No Discharge No Discharge No Discharge No Discharge No Discharge No Discharge No Discharge No Discharge
No Discharge
No Discharge No Discharge No Discharge No Discharge No Discharge No Discharge No Discharge No Discharge
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1 12/31/2020 BOD, 5-day, 20 deg. C 1 12/31/2020 BOD, 5-day, 20 deg. C 1 12/31/2020 BOD, 5-day, 20 deg. C 1 12/31/2020 BOD, 5-day, 20 deg. C 1 12/31/2020 pH 1 12/31/2020 pH 1 12/31/2020 Solids, total suspended 1 12/31/2020 Solids, total suspended 1 12/31/2020 Solids, total suspended 1 12/31/2020 Solids, total suspended 1 12/31/2020 Solids, total suspended 1 12/31/2020 Nitrogen, ammonia total [as N] 1 12/31/2020 Nitrogen, ammonia total [as N] 1 12/31/2020 Nitrogen, ammonia total [as N] 1 12/31/2020 Nitrogen, ammonia total [as N] 1 12/31/2020 Nitrogen, ammonia total [as N] 1 12/31/2020 Flow, in conduit or thru
treatment plant 1 12/31/2020 Chlorine, total residual 1 12/31/2020 Chlorine, total residual 1 12/31/2020 Chlorine, total residual 1 12/31/2020 Coliform, fecal general 1 12/31/2020 Coliform, fecal general 1 12/31/2020 Coliform, fecal general
No Discharge No Discharge No Discharge No Discharge No Discharge No Discharge No Discharge No Discharge No Discharge No Discharge No Discharge No Discharge No Discharge No Discharge No Discharge No Discharge
No Discharge
No Discharge No Discharge No Discharge No Discharge No Discharge No Discharge
Operation and Maintenance
Appendix A.II. Operation and Maintenance: 1. Proper Operation and Maintenance of the Permit states, "The permittee shall at all times properly operate and maintain all facilities and systems of treatment and control (and related appurtenances) which are installed or used by the permittee to achieve compliance with the conditions of the permit...."
Observation 5:
The facility's diffuser heads appear to be worn out, and aeration was observed to be unevenly distributed throughout the aeration chamber (Photo P5150057 - P5150059). The plant operator stated that the heads will be replaced in the future. The diffuser pump was also out of service for three days about 2-3 weeks before the inspection.
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WV Department of Agriculture (Guthrie Center) 05/15/2024
Appendix A I. 3 "Duty to Mitigate" of the Permit states, "The permittee shall take all reasonable steps to minimize or prevent any discharge in violation of this permit, which has a reasonable likelihood of adversely affecting human health or the environment."
Observation 6:
Airline pipe is not welded into tank, leaving a gap and allowing the potential for untreated sewage to funnel out of this area at a high water level. There are already signs of discharge out of the tank (Photo: P5150079, P5150080).
The is a hole in the piping entering into the influent sludge chamber. Staining is present indicating wastewater has flowed out of tank (Photo: P5150050, P5150062).
Appendix A. I. Management Conditions: 12. Water Quality states, "This discharge shall not cause or materially contribute to: distinctly visible floating or settable solids, suspended solids, scum, foam or oily slicks;..."
Observation 7: The clarifier appeared cloudy. Floating solids can be seen in multiple locations (Photos P5150064 - P5150065, P5150067 - P5150072).
Algal overgrowth can be seen surrounding piping and skimmers (Photo P5150066).
Large amounts of suspended sludge appeared to be leaving the contact chamber (Photos P5150081 - P5150082, P5150086 - P5150089).
Part B. 26 "Other Requirements" of the Permit states, "Treatment system utilizing steel tanks shall be required to provide Cathodic Protection and institute a proper Operation & Maintenance (O&M) program, including compliance testing every three (3) years performed by a WV Certified Class D or E Tester. In lieu of the required testing, the anode pack(s) must be inspected yearly and replaced as necessary to prevent pre-mature corrosion of the treatment plant."
Observation 8: Cathodic protection was stripped away from the wastewater tank (Photo P5150077 - P5150078).
IV. Records Review
Prior to the opening conference, the EPA Inspection Team reviewed documentation including:
Discharge Monitoring Reports from June 2019 - June 2024 WVDEP 2024 inspection report and 2021 inspection report.
The EPA Inspection Team requested bench and analysis data from 2022 - 2024 as well as the most recent sludge hauling documentation. This information was requested during the inspection on 5/15/2024 and after the inspection on 6/7/2024. The following was provided as a result of the request:
Bench data for all parameters from 2022 - 2024. Bench data including percent MLSS ("Mixed liquor suspended solids"), percentage return activated sludge ("RAS") solids
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from bench jar testing 2021 - 2023, and pump/flow data from 2021 - 2023 was provided on 6-21-2024 (9-18-23 data in Photo P5150090) Laboratory analyses from 2022 - 2024 provided on 6-18-2024. 2022 - 2024 pH calibration records. Facility provided 2022 records on 6/25/2024 and the 2024 calibration records on 6/21/2024 (Attachment 4) Sludge Hauling Records (Invoice provided on 6/24/2024 - Attachment 6)
V. Closing Conference
After the facility walk, 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 that were not identified at the time of the closing conference after EPA reviewed additional materials following the inspection. The inspection concluded at 4:45PM.
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VI. List of Attachments
WV Department of Agriculture (Guthrie Center) 05/15/2024
Attachment 1: Attachment 2: Attachment 3: Attachment 4: Attachment 5:
Photo Log Sewage 2020 GP Final 2022 - 2024 pH Calibration Data BOD and Fecal Bench Data Sludge Hauling Invoice
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