Document baJ24KRMoR00YwqypN63VQQXO
U.S. ENVIRONMENTAL PROTECTION AGENCY REGION III WATER BRANCH, ENFORCEMENT
AND COMPLIANCE ASSURANCE DIVISION CLEAN WATER ACT
COMPLIANCE INSPECTION REPORT
for
Name of Facility: Central Hampshire Public Service District - Frenchburg WWTP Facility Location: 39.31629, -78.65705
Mailing Address: RR 1 Box 84, Augusta, WV 26704
Report Prepared on: 8/16/2021
Date
Report Final as of: 8/24/2021
Date
By:
, PG
Environmental Scientist (PG Environmental)
Signature
MARK By: ZOLANDZ
Signature
Digitally signed by MARK ZOLANDZ Date: 2021.08.24 13:17:42 -04'00'
, EPA
General Information
Type of Inspection: Owner: Operator: Permittee: NPDES Permit No: NPDES Permit Effective Date: NPDES Permit Expiration Date: Receiving Water: Latitude and Longitude:
Wastewater Treatment Facility CEI Central Hampshire Public Service District (PSD) Central Hampshire PSD Central Hampshire PSD WV0081850 June 1, 2020 April 27, 2025 Little Cacapon River 39.315994, -78.655858
On-Site Facility Inspection Overview
On June 17, 2021, representatives from U.S. Environmental Protection Agency (EPA) Region III and EPA's contract inspector from PG Environmental, (hereinafter referred to as EPA Inspection Team) conducted a compliance evaluation inspection at the Central Hampshire PSD Frenchburg Wastewater Treatment Plant (hereinafter, WWTP or Facility) in Frenchburg, WV. Central Hampshire PSD is identified as the Permittee and owns and operates the WWTP.
Approximate Entry Time: 10:00 AM (EDT) Approximate Exit Time: 1:15 PM (EDT)
Unique Project Identifier (UPI): 3E21WN034A
Unique Project Identifier: 3E21WN034A
Page 1 of 11
Inspection Date: June 17, 2021
Central Hampshire PSD Frenchburg WWTP (WV0081850) Compliance Evaluation Inspection Report
TABLE OF CONTENTS
I.
INTRODUCTION............................................................................................................................ 3
II. INSPECTION PROCESS ................................................................................................................ 3 Inspection Opening Conference .......................................................................................................3 Facility Site Walk.............................................................................................................................4 Records Review ...............................................................................................................................5 Summary of Observations................................................................................................................5 Permit Status and Effluent Exceedances.............................................................................5 Monitoring Requirements .................................................................................................10 Proper Operation and Maintenance...................................................................................10 Closing Conference........................................................................................................................11
APPENDIX LIST
Appendix A: Photograph Log Appendix B: Exhibit Log
o Exhibit 1 - EPA ICIS Data for Outlet 001 (April 1, 2018 through June 30, 2021) o Exhibit 2 - EPA ECHO Detailed Facility Report o Exhibit 3 - EPA ICIS Data for DMR Non-Receipt Violations (April 1, 2020 through June 30,
2021) o Exhibit 4 - EPA ICIS Data for Outlet IU01 (April 1, 2018 through June 30, 2021) o Exhibit 5 - EPA ICIS Data for Outlet IU02 (April 1, 2018 through June 30, 2021) o Exhibit 6 - EPA ICIS Data for Outlet IU03 (April 1, 2018 through June 30, 2021) o Exhibit 7 - EPA ICIS Data for Outlet IU04 (April 1, 2018 through June 30, 2021) o Exhibit 8 - "Frenchburg Maintenance" Forms (January 2021 through June 2021)
Appendix C: NPDES Permit No. WV0081850
Unique Project Identifier: 3E21WN034A
Page 2 of 11
Inspection Date: June 17, 2021
Central Hampshire PSD Frenchburg WWTP (WV0081850) Compliance Evaluation Inspection Report
I.
INTRODUCTION
On June 17, 2021, representatives from U.S. Environmental Protection Agency (EPA) Region III and EPA's contract inspector from PG Environmental, (hereinafter referred to as the EPA Inspection Team) inspected the Central Hampshire PSD Frenchburg Wastewater Treatment Plant (hereinafter, WWTP or Facility) in Frenchburg, WV. Central Hampshire PSD is identified as the Permittee and owns and operates the WWTP. The EPA Inspection Team was joined on the inspection by the Chief Operator. The primary purpose of the inspection was to review WWTP operations, to review the accuracy and reliability of the Permittee's self-monitoring and reporting program, and to obtain information that will assist EPA in assessing the Permittee's compliance with the requirements of the Permit. The weather at the time of the inspection was sunny and warm, with no precipitation.
The WWTP is an extended aeration treatment process with UV disinfection. Wasted sludge is placed into a sludge holding basin and hauled offsite by a septic hauler.
The WWTP has a permitted hydraulic capacity of 0.2 million gallons per day (MGD) and serves a population of approximately 2,000 people. The Permittee's activities are regulated under National Pollutant Discharge Elimination System (NPDES) Permit No. WV0081850 (hereinafter, Permit), which became effective on June 1, 2020 and is set to expire on April 27, 2025 (refer to Appendix C).
The Permittee is planning major upgrades to WWTP that will include the installation of new treatment facilities/replacement of existing treatment facilities (e.g., grit removal, biological reactors designed for nutrient removal, aerobic digesters, rotary sludge press). The Chief Operator stated that the Permittee's contract engineer is still in the design process and that funding for the upgrades has not been secured.
II. INSPECTION PROCESS
Inspection Opening Conference
The EPA Inspection Team arrived at the Facility at 10:00 AM (EDT) for the inspection. Stephen Clark of PG Environmental displayed his Clean Water Act inspector credential to the Chief Operator at the outset of the inspection and explained the purpose of the inspection was to observe compliance with the Permit. A copy of the Permit is provided in Appendix C. Table 1 describes the individuals that participated in the inspection.
Name Stephen Clark, Inspector
Table 1. Inspection Attendee List
Affiliation
Telephone
EPA Inspection Team
PG Environmental
(720) 789-8046
Email stephen.clark@pgenv.com
Amanda Pruzinsky, Inspector Chad Swick, Inspector Russell Riggs, Chief Operator
EPA Region III
(215) 814-5456
WVDEP
WVDEP
(304) 822-7266
Facility Representative
Central Hampshire PSD (304) 671-8133
pruzinsky.amanda@epa.gov chad.c.swick@wv.gov rtriggs5@yahoo.com
Unique Project Identifier: 3E21WN034A
Page 3 of 11
Inspection Date: June 17, 2021
Central Hampshire PSD Frenchburg WWTP (WV0081850) Compliance Evaluation Inspection Report
Facility Site Walk
As part of the process, the EPA Inspection Team visually observed the treatment train and site conditions in the presence of the Chief Operator. The wastewater process train consists of:
Influent pump station Mechanical bar screen (with bypass channel for manual bar rack) Splitter box Two aeration basins with integral clarifiers Secondary clarifier (added during a WWTP upgrade in 2004) UV disinfection Post-aeration basin Sludge holding basin
All influent wastewater flows to the Facility's onsite influent pump station. The pump station has two pumps that convey wastewater to the headworks building (refer to Appendix A, Photograph 1). The two pumps are alternated in lead and lag positions. The wet well is equipped with an auto dialer (the only telemetry installed at the Facility) to alert Facility personnel of high wet well levels.
The Chief Operator stated that the Facility serves a regional jail and juvenile center and that wastewater from these locations contains general trash and debris. Wastewater from these locations is conveyed through a sewage grinder prior to flowing to the publicly owned treatment works (POTW).
The Facility headworks consists of a micro strainer. The influent channel to the micro strainer has a secondary channel that contains a manual bar rack in the event the mechanical bar screen is taken offline. Screenings are captured in a trash receptables and disposed of at a landfill (refer to Appendix A, Photographs 2 through 4).
After the micro strainer, wastewater then flows to a splitter box that directs flows to each aeration basin (refer to Appendix A, Photograph 5). The Chief Operator stated that the splitter box doesn't evenly split flows (Aeration Basin No. 2 receives approximately 60% of influent flows and Aeration Basin No. 1 receives approximately 40%). Operators manually clean the splitter box once per week. Operators place the removed material (e.g., grit) inside the containers and allow residual wastewater to drain back to the splitter box before disposal (refer to Appendix A, Photograph 6). Operators must shut down the influent pump station for approximately 45 minutes to clean the splitter box. The Chief Operator stated that the shutdown is typically performed early in the morning hours when influent flows are relatively low.
After the splitter box, flow is sent to one of two aeration basins with integral clarifiers (refer to Appendix A, Photographs 7 through 10). Returned activated sludge (RAS) is sent to the aeration basin via an air-lift system; the wasted activated sludge (WAS) is obtained from the RAS feed and sent to the sludge holding basin. The RAS feed is chlorinated due to filamentous bacteria issues.
Clarified wastewater from the integral clarifiers then flows to a circular secondary clarifier (refer to Appendix A, Photographs 11 through 13). The Chief Operator stated that the circular clarifier was added during a plant upgrade in 2004 because the design of the integral clarifiers created various sludge issues (e.g., washouts, poorly settling sludge). Sludge that settles in the circular secondary clarifier is returned to the headworks; a sludge blanket is not maintained. The skimmed wastewater flows through a chopper pump then to the sludge holding basin.
Clarified wastewater from the circular secondary clarifier then flows to the UV disinfection system which
Unique Project Identifier: 3E21WN034A
Page 4 of 11
Inspection Date: June 17, 2021
Central Hampshire PSD Frenchburg WWTP (WV0081850) Compliance Evaluation Inspection Report
consists of two banks with 24 bulbs each (refer to Appendix A, Photograph 14). The area that houses the banks is hosed and brushed weekly, and the jackets are cleaned monthly with a descaling agent. The jackets and bulbs are replaced annually.
Wastewater then flows through a Parshall flume with an ultrasonic flow meter then to the post-aeration basin to increase the dissolved oxygen (DO) concentrations (refer to Appendix A, Photographs 15 and 16).
Wastewater is then discharged from the post-aeration basin to the Little Cacapon River via Outlet 001 (refer to Appendix A, Photographs 17 through 20).
Solids are removed from the sludge holding basin (refer to Appendix A, Photograph 21) approximately once per week for disposal. The facility does not have solids processing equipment (e.g., belt filter press). Solids are hauled off by a contract septage hauler for disposal.
Records Review
The EPA Inspection Team conducted a records review to evaluate the Permittee's compliance with the Permit. Most of the records and reports required by the Permit were available for review prior to and after the inspection. The following were reviewed:
EPA Integrated Compliance Information System (ICIS) data during the period from April 1, 2018 through April 30, 2021 (the timeframe covered by ECHO's three-year compliance status plus April 2021)
Compliance sampling records/logs Daily operator logbook Hard-copy forms used to document runtimes for various equipment (e.g., pumps, blowers, mixers,
UV disinfection units) Generator maintenance logs Various maintenance logs for Facility equipment (e.g., rake motors, blowers, UV disinfection
units) Flow meter calibration report for effluent, RAS, and WAS flow meters (calibration performed on
May 26, 2021) Process control sampling logs Facility equipment O&M manuals Facility engineering drawings
Summary of Observations
The following section summarizes the EPA Inspection Team's observations relative to the Permittee's Permit requirements, including the status of certain treatment units, operation and maintenance practices, and the Permittee's monitoring and reporting documentation.
Permit Status and Effluent Exceedances
Section A.001 of the Permit defines discharge limitations and monitoring requirements for Outlet 001 discharges.
According to EPA's ICIS database, the Facility experienced 13 effluent limit exceedances from Outlet 001 between April 1, 2018 and June 30, 2021 (i.e., the timeframe covered by ECHO's three-year compliance history, plus April-June 2021; refer to Appendix B, Exhibit 1 and Table 2 below). Four of the exceedances occurred
Unique Project Identifier: 3E21WN034A
Page 5 of 11
Inspection Date: June 17, 2021
Central Hampshire PSD Frenchburg WWTP (WV0081850) Compliance Evaluation Inspection Report
under the current version of the Permit (effective June 1, 2020). Note that the current Permit does not contain a discharge limitation for total recoverable copper from Outlet 001; the Permittee is required to report only.
Table 2. Summary of Effluent Exceedances at Outlet 001 (April 1, 2018 through May 31, 2021)
NPDES ID
Monitoring Period End
Date
Parameter Name
DMR Permit Value Limit
Units
Type
WV0081850 5/31/2018
Ammonia Nitrogen
20.1
3.3
lbs./day Avg. Monthly
WV0081850 5/31/2018
Ammonia Nitrogen
20.1
6.7
lbs./day Max. Daily
WV0081850 5/31/2018
Ammonia Nitrogen
27.3
2
mg/L Avg. Monthly
WV0081850 5/31/2018 WV0081850 3/31/2019 WV0081850 3/31/2019
Ammonia Nitrogen Fecal Coliform Fecal Coliform
27.3
4
807
200
2,419.6 400
mg/L #/100mL #/100mL
Max. Daily
Monthly Geometric
Mean
Max. Daily
WV0081850 10/31/2019 Copper, Total Recoverable 12.8 0.02
mg/L Avg. Monthly
WV0081850 10/31/2019 Copper, Total Recoverable 12.8
WV0081850 4/30/2020 Total Suspended Solids
84
WV0081850 5/31/2021
Ammonia Nitrogen
27.4
0.031 85 3.3
mg/L Percent lbs./day
Max. Daily
Percent Removal
Avg. Monthly
WV0081850 5/31/2021
Ammonia Nitrogen
27.4
6.7
lbs./day Max. Daily
WV0081850 5/31/2021
Ammonia Nitrogen
33.6
2
mg/L Avg. Monthly
WV0081850 5/31/2021
Ammonia Nitrogen
33.6
4
mg/L
Max. Daily
Section C.5 of the Permit states, "The permittee shall submit monthly according to the enclosed format, a Discharge Monitoring Report (DMR) indicating in terms of concentration and/or quantities the values of the constituents listed in Section A analytically determined to be in the plant effluent(s)."
Section C.6 of the Permit states, "The required DMRs shall be received no later than 25 days [emphasis added] following the end of the reporting period."
EPA's Enforcement and Compliance History Online (ECHO) has identified the Facility to be in significant noncompliance (SNC) for April 1, 2020 through March 31, 2021 for "Failure to Report DMR - Not Received" (refer to Appendix B, Exhibit 2). According to EPA's ICIS database for this time period and Outlet 001, the Permittee has been reporting DMR data for Outlet 001 and the database does not identify DMR non-receipt violations. EPA's ICIS database identifies DMR non-receipt violations for industrial users IU01, IU02, and IU03 for this time period (refer to Appendix B, Exhibit 3). The violations are identified for reporting DMRs with the No Data Indicator (NODI) Code "E," "Failed to Sample/Required Analysis Not Conducted" and for reporting late DMRs.
Unique Project Identifier: 3E21WN034A
Page 6 of 11
Inspection Date: June 17, 2021
Central Hampshire PSD Frenchburg WWTP (WV0081850) Compliance Evaluation Inspection Report
Section A.IU01 of the Permit defines discharge limitations and monitoring requirements for NonSignificant Industrial User IU01 (Living Water Auto Spa) and states, "During the period beginning 6/1/2020 and lasting through midnight 4/27/2025 the permittee is authorized to accept the discharge from Outlet Number(s) IU01 (Pretreatment - Non Significant Industrial User)" and that "Such discharges shall be limited and monitored by the permittee as specified [in the table] below."
Section E.4 of the Permit states, "Should any of the permittee's industrial users fail to comply with the specific terms and conditions pertaining to that specific industrial user in this permit, the permittee shall immediately contact said industrial user and identify the violation causing the noncompliance with the permit. The permittee shall take all reasonable, escalating enforcement steps, up to and including disallowing the continued acceptance of the nondomestic wastewater from the industrial user, to keep the industrial user compliant with the terms and conditions of the permit. Also, the permittee shall immediately inform the Agency of any current noncompliance by industrial users by attaching a written summary of these violations, the cause of each violation, and the steps taken to prevent their recurrence with the submitted Discharge Monitoring Reports."
According to EPA's ICIS database, the Facility experienced two effluent limit exceedances from Outlet IU01 between April 1, 2018 and June 30, 2021 (refer to Appendix B, Exhibit 4 and Table 3 below). These exceedances did not occur under the current version of the Permit. Additionally, for the monitoring periods ending on April 30, 2021 and May 31, 2021, the Permittee reported the NODI Code "E," "Failed to Sample/Required Analysis Not Conducted" (refer to Appendix B, Exhibit 3).
Note that the previous version of the Permit identifies Non-Significant Industrial User IU01 as "Washco Services Inc., Car Wash."
Table 3. Summary of Effluent Exceedances at Outlet IU01 (April 1, 2018 through April 30, 2021)
NPDES ID
Monitoring Period End
Date
Parameter Name
DMR Permit Value Limit
Units
Type
WV0081850 2/28/2019 Total Suspended Solids 1,200 300
mg/L
Max. Daily
WV0081850 5/31/2019
Oil and Grease
32
30
mg/L
Max. Daily
Section A.IU02 of the Permit defines discharge limitations and monitoring requirements for NonSignificant Industrial User IU02 (Potomac Edison First Energy) and states, "During the period beginning 6/1/2020 and lasting through midnight 4/27/2025 the permittee is authorized to accept the discharge from Outlet Number(s) IU02 (Pretreatment - Non Significant Industrial User)" and that "Such discharges shall be limited and monitored by the permittee as specified [in the table] below."
According to EPA's ICIS database, the Facility experienced one effluent limit exceedance from Outlet IU02 between April 1, 2018 and June 30, 2021 (refer to Appendix B, Exhibit 5 and Table 4 below). The exceedance did not occur under the current version of the Permit.
Unique Project Identifier: 3E21WN034A
Page 7 of 11
Inspection Date: June 17, 2021
Central Hampshire PSD Frenchburg WWTP (WV0081850) Compliance Evaluation Inspection Report
Table 4. Summary of Effluent Exceedances at Outlet IU02 (April 1, 2018 through May 31, 2021)
NPDES ID
Monitoring Period End
Date
Parameter Name
DMR Permit Value Limit
Units
Type
WV0081850 3/31/2019
Lead, Total
0.098 0.05
mg/L
Max. Daily
Section A.IU03 of the Permit defines discharge limitations and monitoring requirements for NonSignificant Industrial User IU03 (West Virginia Department of Highways Augusta Station) and states, "During the period beginning 6/1/2020 and lasting through midnight 4/27/2025 the permittee is authorized to accept the discharge from Outlet Number(s) IU03 (Pretreatment - Non Significant Industrial User)" and that "Such discharges shall be limited and monitored by the permittee as specified [in the table] below."
According to EPA's ICIS database, the Facility experienced five effluent limit exceedances from Outlet IU03 between April 1, 2018 and June 30, 2021 (refer to Appendix B, Exhibit 6 and Table 5 below). One exceedance occurred under the current version of the Permit. Additionally, for the monitoring period ending on April 30, 2020, the Permittee reported the NODI Code "E," "Failed to Sample/Required Analysis Not Conducted" (refer to Appendix B, Exhibit 3).
Table 5. Summary of Effluent Exceedances at Outlet IU03 (April 1, 2018 through April 30, 2021)
NPDES ID
Monitoring Period End
Date
Parameter Name
DMR Permit Value Limit
Units
Type
WV0081850 9/30/2018
Zinc, Total
0.74
0.5
mg/L
Max. Daily
WV0081850 12/31/2018
Zinc, Total
0.74
0.5
mg/L
Max. Daily
WV0081850 2/28/2019 Total Suspended Solids 404
300
mg/L
Max. Daily
WV0081850 2/28/2019
Zinc, Total
0.74
0.5
mg/L
Max. Daily
WV0081850 5/31/2021 Total Suspended Solids 352
300
mg/L
Max. Daily
Section A.IU04 of the Permit defines discharge limitations and monitoring requirements for NonSignificant Industrial User IU04 (Hampshire County High School) and states, "During the period beginning 6/1/2020 and lasting through midnight 4/27/2025 the permittee is authorized to accept the discharge from Outlet Number(s) IU04 (Pretreatment - Non Significant Industrial User)" and that "Such discharges shall be limited and monitored by the permittee as specified [in the table] below."
According to EPA's ICIS database, the Facility experienced 25 effluent limit exceedances from Outlet IU04 between April 1, 2018 and June 30, 2021 (refer to Appendix B, Exhibit 7 and Table 6 below). None of these exceedances occurred under the current version of the Permit. Note that the current version of the Permit does not contain a discharge limitation for Total Kjeldahl Nitrogen from Outlet IU04; the Permittee is required to report only.
Unique Project Identifier: 3E21WN034A
Page 8 of 11
Inspection Date: June 17, 2021
Central Hampshire PSD Frenchburg WWTP (WV0081850) Compliance Evaluation Inspection Report
Table 6. Summary of Effluent Exceedances at Outlet IU04 (April 1, 2018 through April 30, 2021)
NPDES ID
Monitoring Period End
Date
Parameter Name
DMR Permit Value Limit
Units
Type
WV0081850 04/30/2018 Nitrogen, Kjeldahl Total 305 100 mg/L Max. Daily
WV0081850 05/31/2018 Nitrogen, Kjeldahl Total 328 100 mg/L Max. Daily
WV0081850 06/30/2018 Nitrogen, Kjeldahl Total 176 100 mg/L Max. Daily
WV0081850 7/31/2018 Nitrogen, Kjeldahl Total 161 100 mg/L Max. Daily
WV0081850 8/31/2018 Nitrogen, Kjeldahl Total 174 100 mg/L Max. Daily
WV0081850 09/30/2018 Nitrogen, Kjeldahl Total 256 100 mg/L Max. Daily
WV0081850 10/31/2018 Nitrogen, Kjeldahl Total 120 100 mg/L Max. Daily
WV0081850 11/30/2018 Nitrogen, Kjeldahl Total 102 100 mg/L Max. Daily
WV0081850 12/31/2018 Nitrogen, Kjeldahl Total 148 100 mg/L Max. Daily
WV0081850 02/28/2019 Nitrogen, Kjeldahl Total 220 100 mg/L Max. Daily
WV0081850 03/31/2019 Nitrogen, Kjeldahl Total 256 100 mg/L Max. Daily
WV0081850 04/30/2019 Nitrogen, Kjeldahl Total 274 100 mg/L Max. Daily
WV0081850 05/31/2019 Nitrogen, Kjeldahl Total 351 100 mg/L Max. Daily
WV0081850 07/31/2019 Nitrogen, Kjeldahl Total 343 100 mg/L Max. Daily
WV0081850 08/31/2019 Nitrogen, Kjeldahl Total 237 100 mg/L Max. Daily
WV0081850 09/30/2019 Nitrogen, Kjeldahl Total 268 100 mg/L Max. Daily
WV0081850 10/31/2019 Nitrogen, Kjeldahl Total 215 100 mg/L Max. Daily
WV0081850 11/30/2019 Nitrogen, Kjeldahl Total 231 100 mg/L Max. Daily
WV0081850 12/31/2019 Nitrogen, Kjeldahl Total 282 100 mg/L Max. Daily
WV0081850 01/31/2020 Nitrogen, Kjeldahl Total 389 100 mg/L Max. Daily
WV0081850 02/29/2020 Nitrogen, Kjeldahl Total 544 100 mg/L Max. Daily
WV0081850 03/31/2020 Nitrogen, Kjeldahl Total 564 100 mg/L Max. Daily
WV0081850 04/30/2020 Nitrogen, Kjeldahl Total 611 100 mg/L Max. Daily
WV0081850 05/31/2020
pH
3.96
5
s.u.
Inst. Min.
WV0081850 05/31/2020 Nitrogen, Kjeldahl Total 673 100 mg/L Max. Daily
Unique Project Identifier: 3E21WN034A
Page 9 of 11
Inspection Date: June 17, 2021
Central Hampshire PSD Frenchburg WWTP (WV0081850) Compliance Evaluation Inspection Report
Monitoring Requirements
Section A.001 of the Permit states, "Samples taken in compliance with the monitoring requirements specified above shall be taken at the following location(s): Effluent BOD5 samples shall be collected at a location immediately preceding disinfection. All other effluent samples shall be collected at, or as near as possible to, the point of discharge."
According to the Chief Operator, effluent biochemical oxygen demand (BOD) samples are collected at Outlet 001 after disinfection and that he does not ask the laboratory to seed the sample during analysis.
The Facility's effluent flow meter and Parshall flume are located upstream of the postaeration basin.
Appendix A, Section III.3 of the Permit states, "Samples shall be taken, preserved and analyzed in accordance with the latest edition of 40 CFR Part 136, unless other test procedures have been specified elsewhere in this permit." Table II in 40 CFR 136 requires BOD and TSS samples to be preserved by cooling to 6C.
The Chief Operator stated that he collects influent composite samples by placing grab samples taken each hour in a common bucket. The bucket was not being placed on ice or refrigerated during the 8-hour composite period. The influent composite sample is later placed on ice after it is transferred to the bottle that is provided to the laboratory. Note that the Chief Operator stated that effluent composite samples are collected in a similar manner but refrigerated starting at the beginning of the collection period.
Proper Operation and Maintenance
Appendix A, Part II.1 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 this permit. Proper operation and maintenance also includes adequate laboratory controls, and appropriate quality assurance procedures. Unless otherwise required by Federal or State law, this provision requires the operation of back-up auxiliary facilities or similar systems which are installed by the permittee only when the operation is necessary to achieve compliance with the conditions of the permit."
The EPA Inspection Team made multiple observations related to operations and maintenance at the Facility:
One of the diffusers in Aeration Basin No. 2 did not appear to be evenly distributing air to the aeration basin. The Chief Operator stated that debris accumulates on the diffusers and that the diffusers are pulled from the aeration basins and cleaned annually.
Green-colored vegetative material which appeared to be duckweed was present on the surface of the aeration basins (refer to Appendix A, Photographs 7 and 9). The Chief Operator stated did not know the source of the potential duckweed.
Sludge and what appeared to be duckweed were present on the surface of the integral clarifiers (refer to Appendix A, Photographs 8 and 10). The clarifiers have a baffle that surrounds the effluent weir.
Unique Project Identifier: 3E21WN034A
Page 10 of 11
Inspection Date: June 17, 2021
Central Hampshire PSD Frenchburg WWTP (WV0081850) Compliance Evaluation Inspection Report
Biological growth was present on the weirs for the integral clarifiers (refer to Appendix A, Photographs 8 and 10). The Chief Operator stated that the weir is scrubbed weekly; the EPA Inspection Team observed that this activity was not documented on the "Frenchburg Maintenance" form (refer to Appendix B, Exhibit 8). It was unclear if this activity was documented in another format.
Biological growth was present on the weir for the circular secondary clarifier (refer to Appendix A, Photographs 11 through 13). The Chief Operator stated that the weir is scrubbed weekly; the EPA Inspection Team observed that this activity was routinely documented on the "Frenchburg Maintenance" form (refer to Appendix B, Exhibit 8).
Closing Conference
After the Facility site walk, the EPA Inspection Team met with the Chief Operator for a closing conference and shared its preliminary observations. The EPA Inspection Team reiterated that all preliminary observations discussed were not compliance determinations. Any and all preliminary observations shared were subject to further investigation by the EPA Inspection Team 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 the additional review of materials following the inspection.
The inspection concluded at approximately 1:15 PM (EDT).
Unique Project Identifier: 3E21WN034A
Page 11 of 11
Inspection Date: June 17, 2021