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Report Title: Inspection Date(s): Regulatory Program(s): Type of Activity: Site/Facility Name: Permittee(s): Site/Facility Operator: Site/Facility Address: Lat/Long: County/Parish: Permit Number: NAICS & SIC Codes: Unique Project #: Clean Water Act Compliance Inspection Report August 13, 2024 National Pollutant Discharge Elimination System (NPDES) Pretreatment Compliance Inspection- Publicly Owned Treatment Works (POTW) Berwick Area Joint Sewer Authority WWTP Berwick Area Joint Sewer Authority Berwick Area Joint Sewer Authority 383 South Eaton Street, Berwick, PA 18603 40.039167, -76.266944 Columbia PA0023248 221320/4952 ECAD-474 Site/Facility Representative: Todd Heller, Pretreatment Administrator Phone: (570) 759-9411 Email: bajsa@verizon.net EPA Inspector: Monica Crosby, Inspector Phone: (410) 305-3029 Email: crosby.monica@epa.gov Point of Contact (Full list of Attendees in Table 1) Report Preparer Signature/Date Supervisor Signature/Date MONICA CROSBY Digitally signed by MONICA CROSBY Date: 2024.10.15 15:10:12 -06'00' Monica Crosby (3ED32) NPDES Section 1 Digitally signed by MARK MARK ZOLANDZ ZOLANDZ Date: 2024.10.16 08:23:25 -04'00' Mark Zolandz, Section Chief (3ED32) NPDES Section 1 Date Date Attachments Attachment 1 Attachment 2 Attachment 3 Attachment 4 Attachment 5 Attachment 6 Attachment 7 Berwick Area Joint Sewer Authority (PA0023248) Pretreatment Compliance Inspection NPDES Permit Berwick Ordinance Enforcement Response Plan Photograph Log Wise Permit K-Fab Permit Patriot Metals Permit DSB ID #: ECAD-474 Page 2 of 22 Inspection Date: August 13, 2024 Berwick Area Joint Sewer Authority (PA0023248) Pretreatment Compliance Inspection I. Inspection Summary On August 13, 2024, EPA contractor Chuck Durham and United States Environmental Protection Agency (EPA) Region 3 representatives Monica Crosby and Edward Simas (jointly referred to as the "Inspection Team") conducted an on-site Pretreatment Compliance Inspection (PCI) of the Berwick Area Joint Sewer Authority (hereinafter, the "Authority") Pretreatment Program (hereinafter, "PCI" or "inspection"). The purpose of the inspection was to observe Authority's Pretreatment Program's compliance with the Clean Water Act (CWA), the applicable Federal Pretreatment Regulations, and Authority's National Pollutant Discharge Elimination System (NPDES) permit ID: PA0023248 (hereinafter, "Permit") (Attachment 1). Prior to the PCI, the Pennsylvania Department of Environmental Protection (PADEP) was notified of the inspection. The PADEP did not send a representative to attend the PCI. The EPA Inspection Team did provide the Authority advanced notice of the PCI. Table 1: Inspection Attendee List Name Monica Crosby Edward Simas Chuck Durham Janel Yorks N/A Affiliation Telephone EPA Region 3 Inspectors and Contractors EPA (410) 305-3029 EPA (215) 814-2120 ERG 615-888-2928 Site/Facility Representatives Berwick Area Joint Sewer Authority (570) 759-9411 State or County Representatives No state representatives in attendance Email Crosby.Monica@epa.gov Simas.Edward@epa.gov Chuck.Durham@erg.com bajsa@verizon.net As part of the PCI, the Inspection Team reviewed the following nondomestic discharger files: K-Fab Inc. (categorical significant industrial user [SIU]) Wise Foods Inc. (non-categorical SIU) Patriot Metal Products (categorical SIU) As part of the inspection, the Inspection Team also conducted site visits at K-Fab Inc. ("K-Fab") and Wise Foods Inc. ("Wise). DSB ID #: ECAD-474 Page 3 of 22 Inspection Date: August 13, 2024 Berwick Area Joint Sewer Authority (PA0023248) Pretreatment Compliance Inspection II. Program Description The Authority owns and operates the Berwick wastewater treatment plant ("WWTP"). The WWTP is an aerobic extended aeration wastewater treatment plant that was constructed in the 1950s and has a hydraulic design capacity of 3.28 million gallons per day (MGD). The WWTP provides tertiary treatment of wastewater. The Authority's Sewer Ordinance was originally adopted on September 26, 1957, and its last amendment was adopted December 27, 1984 (Attachment 2). The NPDES Permit was effective January 1, 2020, and expires December 31, 2024. The WWTP discharges to the Shenandoah River. According to the Authority Representative, the Authority services Berwick Borough, Briar Creek Township, Briar Creek Borough, Mifflin Township, and Salem Township. IUs currently identified by the Control Authority (CA) 3 0 0 0 Yes III. Industrial User (IU) Characterization IU Type Discharging Significant Industrial Users 1 Discharging Non-Categorical SIUs (as defined by the CA) 2 Categorical Industrial Users (CIUs) 0 Middle Tier CIUs Zero-Discharging CIUs Non-significant CIU (NSCIU) Other Regulated IUs (e.g., permitted IUs) Describe: The Authority does not permit any non-significant industrial users. Waste Haulers IV. Findings Summary Table Finding C.4.1 - The permits are missing or partially missing record retention requirements. Finding C.4.2 - Two of the permits reviewed are missing certification statement requirements. Finding C.4.3 - Two of the permits are missing notification requirements for significant changes in discharge. Finding C.4.4 - Two of the permits refer to surchargeable thresholds as "limits." Finding C.4.5 - Two of the permits are missing statements surrounding applicable civil and criminal penalties. Finding D.2.1 - The Authority did not document the slug discharge control plan evaluation for the three SIUs. DSB ID #: ECAD-474 Page 4 of 22 Inspection Date: August 13, 2024 Berwick Area Joint Sewer Authority (PA0023248) Pretreatment Compliance Inspection IV. Findings Summary Table Finding E.2.1 - The Authority did not complete a thorough inspection of the manufacturing process at Wise. Finding E.6.1 - Patriot Metals failed to sample in the third quarter of 2023. Finding E.2.1 - The Authority did not complete a thorough inspection of the manufacturing process at Wise. Finding E.6.1 - Patriot Metals failed to sample in the third quarter of 2023. Finding E.6.2 - Wise is not collecting a representative sample. Finding E.6.3 - Improper Analysis of K-Fab's TTOs Finding F.1.1 - The Authority did not take enforcement action in all instances of SIU noncompliance. V. Evaluation The Inspection Team discussed the topics in Subsections A-G below regarding the pretreatment program with the Authority representatives. The Inspection Team also reviewed SIU files to assess the retention of required program documents and to generally evaluate overall program implementation. The following sections describe program areas of concern identified during the inspection process along with compliance assistance items, and associated references to 40 CFR Part 403. All compliance assistance items are included strictly for informational purposes and should not be construed as a formal order or instruction from EPA. DSB ID #: ECAD-474 Page 5 of 22 Inspection Date: August 13, 2024 A. Control Authority (CA) Pretreatment Program Modification 1. When was the last program modification? Did the CA notify the EPA of program modifications? (40 CFR 403.18) The Authority's Sewer Ordinance was originally adopted on September 26, 1957, and its last amendment was adopted December 27, 1984 (Attachment 2) to include streamline revisions. The Authority's Enforcement Response Plan (ERP) was created in June 1992, and last modified in September 2010 to include streamlining revisions. (Attachment 3). According to the Authority Representative, there have been no changes to the pretreatment program in the past five years. The Authority Representative stated that the local limits are coming up for review because the Permit is set to expire at the end of 2024. 2. Are there any contributing jurisdictions discharging wastewater to the POTW? Does the CA have an agreement in place that addresses pretreatment program responsibilities? According to the Authority Representative, the Authority services Berwick Borough, Briar Creek Township, Briar Creek Borough, Mifflin Township, and Salem Township. The Authority has an agreement in place with each of these contributing jurisdictions. Legal authority reviews are not typically evaluated as part of a PCI. Therefore, the Inspection Team did not review the agreement. B. IU Characterization 1. Describe the CA's procedure for identifying and locating IUs that might be subject to the pretreatment program. Has the CA identified and located all applicable IUs (non-categorical SIUs, CIUs, NSCIUs, etc.)? (40 CFR 403.8(f)(2)(i)) The Authority Representative stated that the Authority relies on industrial waste surveys or by calling the managers at potential industrial users. New facilities often fill out an application to connect to the Authority. 2. Has the CA identified the character and volume of pollutants contributed to the publicly owned treatment works (POTW) by IUs subject to the pretreatment program? (40 CFR 403.8(f)(2)(ii)) Yes, the Authority identified the character and volume of pollutants in SIU discharges through review Berwick Area Joint Sewer Authority (PA0023248) Pretreatment Compliance Inspection of the permit application, monitoring data provided by the permittee, annual oversight sampling of the SIUs by the Authority, as well as initial samples collected by the Authority. 3. Has the CA prepared and maintained a list of SIUs, as defined in 403.3(v)(1), along with the applicable SIU criteria? Does the list indicate whether the CA has made a determination that an SIU is a NSCIU, as defined in 403.3(v)(2), rather than an SIU? Have modifications to the list been submitted with annual reports? (40 CFR 403.8(f)(6)) Yes, the Authority maintains a current list of SIUs, which it submits in the annual reports to EPA Region 3. The Authority had not designated any SIUs as NSCIUs at the time of the inspection. C. Control Mechanism Evaluation 1. Has the CA issued individual or general control mechanisms to all SIUs? (40 CFR 403.8(f0(1)(iii)) The three SIUs whose files were reviewed during the inspection had been issued an individual permit. SIU permits are issued for five years. The Facility was not implementing any general permit options at the time of the inspection. 2. Do the applications for general control mechanism contain all of the following? (40 CFR 403.8(f)(1)(iii)(A)(2)) a. Contact info b. Production processes c. Types of wastes generated d. Location for monitoring e. Any request for waiver for pollutants not present per 40 CFR 403.12(e)(2) Not applicable (N/A). The Authority had not issued general control mechanisms at the time of the inspection. 3. Are general control mechanisms only issued for IUs where all of the following is true? (40 CFR 403.8(f)(1)(iii)(A)(1)) a. Involve same/substantially similar types of operations b. Discharge the same type of waste c. Same effluent limitations d. Same or similar monitoring e. There are no CIU production-based standards, CIU mass limits, combined wastestream formula, or net/gross calculations DSB ID #: ECAD-474 Page 7 of 22 Inspection Date: August 13, 2024 Berwick Area Joint Sewer Authority (PA0023248) Pretreatment Compliance Inspection N/A. The Authority had not issued general control mechanisms at the time of the inspection. 4. Do both individual and general control mechanisms include the following, where applicable? (40 CFR 403.8(f)(1)(iii)(B)) a. Statement of duration (5 years max) b. Statement of non-transferability c. Applicable effluent limits (local limits, categorical standards, BMPs) d. Self-monitoring requirements Identification of pollutants to be monitored Sampling frequency Sampling locations/discharge points Appropriate sample types Reporting requirements Record-keeping requirements e. Statement of applicable civil and criminal penalties f. Compliance schedules g. Notice of slug loading or potential problems at POTW h. Notification of spills, bypasses, upsets, etc. i. Notification of significant change in discharge j. 24-hour notification of effluent violation k. Submit resampling results within 30-days l. Slug discharge control plan requirement, if required by POTW m. Certification statements n. Sampling/analysis requirements (Part 136 or alternative) o. Reporting of additional sampling p. 90-day compliance report The individual SIU permits reviewed as a component of the inspection included most, but not all, of the aforementioned provisions. Findings regarding the content of individual control mechanisms are provided below. The Authority had not issued general control mechanisms at the time of the inspection. Finding C.4.1 - The permits are missing or partially missing record retention requirements. The K-Fab and Patriot Metal permits are missing language requiring the permittees to retain and preserve records for at least three years. The Wise permit does not specify that the retention period may be extended at the request of EPA (Attachment 5). Regulatory Requirement The federal pretreatment regulations at 40 CFR 403.12(o) state that any Industrial User or POTW subject to the reporting requirements established in this section shall be required to retain for a DSB ID #: ECAD-474 Inspection Date: August 13, 2024 Page 8 of 22 Berwick Area Joint Sewer Authority (PA0023248) Pretreatment Compliance Inspection minimum of 3 years any records of monitoring activities and results and shall make such records available for inspection and copying by the Director and the Regional Administrator. Additionally, the retention period is extended during unresolved litigation or when requested by the Director or the [EPA] Regional Administrator. Finding C.4.2 - Two of the permits reviewed are missing certification statement requirements. The K-Fab and Patriot Metal permits are missing signatory requirements (Attachments 6 and 7). Regulatory Requirement The federal regulations at 40 CFR 403.12(l) outline the signatory requirements for Industrial User Reports. Finding C.4.3 - Two of the permits are missing notification requirements for significant changes in discharge. The K-Fab and Patriot Metal permits are missing language requiring the facilities to notify the Authority of any substantial change in the volume or character of pollutants in their discharge (Attachments 6 and 7). Regulatory Requirement The federal regulations at 40 CFR 403.8(j) require all Industrial Users to promptly notify the Control Authority in advance of any substantial change in the volume or character of pollutants in their Discharge, including the listed or characteristic hazardous wastes for which the Industrial User has submitted initial notification under 403.12(p). Finding C.4.4 - Two of the permits refer to surchargeable thresholds as "limits." The K-Fab and Patriot Metal permits state, "The limits for Bod and TSS are surchargeable limits, the permittee may exceed them, but then must pay a surcharge." The EPA Inspection Team communicated that surchargeable pollutants are better referred to as "thresholds" as limits imply enforcement will be taken, if exceeded (Attachments 6 and 7). The EPA Model Pretreatment Ordinance notes that Ordinances should clearly distinguish between surcharges and local limits. Regulatory Requirement Part 2.4 of EPA's Model Pretreatment Ordinance, dated January 2007, states, "Ordinances should clearly distinguish between surcharges and Local Limits. Surcharges are additional charges to recover the cost to treat wastewater that are typically assessed when discharge concentrations are above defined values, typically above domestic wastewater. Enforceable Local Limits for conventional pollutants are established where there is potential for these pollutants to be discharged to the POTW in quantities or concentrations that could exceed the POTW's plant capacity." Finding C.4.5 - Two of the permits are missing statements surrounding applicable civil and criminal penalties. DSB ID #: ECAD-474 Inspection Date: August 13, 2024 Page 9 of 22 Berwick Area Joint Sewer Authority (PA0023248) Pretreatment Compliance Inspection The K-Fab and Patriot Metal permits are missing a statement of applicable civil and criminal penalties for violation of pretreatment standards and requirements (Attachments 6 and 7). Regulatory Requirement The federal regulations at 40 CFR 403.8(f)(1)(B)(5) requires that individual and general control mechanisms contain a statement of applicable civil and criminal penalties for violation of Pretreatment Standards and requirements, and any applicable compliance schedule. Such schedules may not extend the compliance date beyond applicable federal deadlines. Finding C.4.6 - Vague Description of sampling location Part 1.A of K-Fab's permit describes the sampling location/Outfall 001 as "near the powder coating line." The EPA Inspection Team observed the sampling location/outfall to be inside the blue tank that sits southwest of the powder coating line (Attachment 4, Photo 15 and Attachment 6). Regulatory Requirement The federal regulations at 40 CFR 403.8(f)(1)(B)(4) requires that individual and general control mechanisms contain self-monitoring, sampling, reporting, notification and recordkeeping requirements, including an identification of the pollutants to be monitored, sampling location, sampling frequency, and sample type. D. Application of Pretreatment Standards and Requirements 1. Does the CA apply all applicable pretreatment standards? (40 CFR 403.8(f)(1)(ii) and 403.8(5)) Yes; based on the files reviewed, the Authority has generally applied all applicable pretreatment standards to its SIUs. 2. Has the CA evaluated the need for SIUs to develop slug discharge control plans? (40 CFR 403.8(f)(2)(vi)) According to the Authority representatives, none of the three SIUs have been specifically asked to complete a slug discharge control plan. Finding D.2.1 - The Authority did not document the slug discharge control plan evaluation for the three SIUs. The Inspection Team reviewed the IU permit and corresponding files for Wise, K-Fab, and Patriot Metal and there were no requirements for a slug discharge control plan to be developed. Regulatory Requirement The federal pretreatment regulations at 40 CFR 403.8(f)(2)(vi) require that the control authority evaluates whether each industrial user needs a plan or other action to control slug discharges. DSB ID #: ECAD-474 Page 10 of 22 Inspection Date: August 13, 2024 Berwick Area Joint Sewer Authority (PA0023248) Pretreatment Compliance Inspection E. Compliance Monitoring 1. Has the CA inspected and independently sampled each SIU at least once a year? Middle tier CIUs at least once every two years? Sample once during term of CIU control mechanism if CIU sampling waived for pollutants not present? (40 CFR 403.8(f)(2)(v), 403.12(e)(2), 403.12(e)(2)) Yes, according to the Authority Representative, the Authority conducts inspections and sampling events at each SIU at least once per year. The Authority will inspect more frequently if a situation arises that calls for increased inspection frequency. The Authority did not have any CIUs designated as middle tier CIUs and had not issued waivers for pollutants not present. 2. Has the CA used proper sampling and analysis procedures (40 CFR Part 136) and inspection procedures? Were the procedures done with sufficient care to produce evidence admissible in enforcement proceedings or in judicial actions? (40 CFR 403.8(f)(2)(v) and (vii), 403.12(g)(5)) In general, according to the information reviewed during the inspection, the Authority uses proper sampling, analysis, and inspection procedures, except where noted below. Finding E.2.1 - The Authority did not complete a thorough inspection of the manufacturing process at Wise. During the inspection of Wise, the Authority inspected the point of discharge, the chemical storage area, and the sampling location. However, the Authority did not inspect Wise's manufacturing process to confirm that there have been no changes that would affect its discharge to the Authority. Regulatory Requirement According to the federal pretreatment regulations at 40 CFR 403.8(f)(2)(v), the Control Authority is required to randomly sample and analyze the effluent from industrial users and conduct surveillance activities in order to identify, independent of information supplied by industrial users, occasional and continuing noncompliance with pretreatment standards. 3. Has the CA kept records for three years including the following? (40 CFR 403.12(o)) a. Period compliance reports and other reports/notices b. All monitoring records including: sample date, place, method, time, personnel; analysis date, personnel, method; results c. BMP compliance documentation d. Other monitoring records Based on the files reviewed, the Authority maintains records for at least three years. DSB ID #: ECAD-474 Page 11 of 22 Inspection Date: August 13, 2024 Berwick Area Joint Sewer Authority (PA0023248) Pretreatment Compliance Inspection 4. Has the CA evaluated, at least once per year, whether NSCIUs continue to meet the criteria of an NSCIU? (40 CFR 403.8(f)(2)(v)(b), 403.3(v)(2)) N/A. The Authority was not implementing the option to classify industries as NSCIUs at the time of the inspection. 5. Has the CA required, received, and analyzed reports and other notices from SIUs? (40 CFR 403.8(f0(2)(iv)) a. Self-monitoring reports b. BMRs and 90-day compliance reports c. Compliance schedules reports d. Notice of slug loading or potential problems at POTW e. Notification of spills, bypasses, upsets, etc. f. Notification of significant change in discharge g. 24-hour notification of effluent violation h. Resampling results within 30-days i. Other reports/notifications required by the CA Yes. Based on the files reviewed during the inspection, the Authority has been requiring, receiving, and analyzing required reports. 6. Have SIUs monitored to demonstrate continued compliance and re-sampled after violation(s)? (40 CFR 403.12(g)(1) & (2)) Based on the files reviewed, the SIUs have monitored to demonstrate continued compliance and resampled after violations, with the exception below Finding E.6.1 - Patriot Metals failed to sample in the third quarter of 2023. Patriot Metals failed to sample in the third quarter of 2023. The Authority requested Patriot to sample twice in the fourth quarter of 2023 and did not follow up with a Notice of Violation. Regulatory Requirement 40 CFR 403.12(g)(1) requires that self-monitoring reports contain the results of sampling and analysis of the Discharge, including the flow and the nature and concentration, or production, and mass where requested by the Control Authority, of pollutants contained therein which are limited by the applicable Pretreatment Standards. Finding E.6.2 - Wise is not collecting a representative sample. The EPA Inspection Team and the Authority Representative verified the permitted sampling location at Wise (Attachment 4, Photo 12). The EPA Inspection Team observed a manhole on the street DSB ID #: ECAD-474 Inspection Date: August 13, 2024 Page 12 of 22 Berwick Area Joint Sewer Authority (PA0023248) Pretreatment Compliance Inspection leading to the sampling. The Authority Representative confirmed that three houses are joining into the sample point. The EPA Inspection Team communicated that therefore, any samples collected at this point are not representative of Wise's daily operations. Regulatory Requirement 40 CFR 403.12(b)(5)(ii) requires Industrial Users to collect samples that are representative of daily operations. Finding E.6.3 - Improper Analysis of K-Fab's TTOs Thorough review of K-Fab's sample data for TTOs, the EPA Inspection Team discovered the following: The TTO lab analytical for 2023 and 2024 noted that the "analysis of 2-chloroethyl vinyl ether was performed from a sample that was field preserved to pH <2 with HCI. Acid preservation is not allowed for this parameter by the test method or for NPDES compliance per 40 CFR Part 136." The TTO lab analytical for 2023 and 2024 noted that "Analysis of acrolein and/or acrylonitrile was performed from a sample that was field preserved to pH < 2, which is less than the pH range of 4-5 specified in the test method and required for NPDES compliance per 40CFR Part 136." The lab analytical for the TTO sample that was collected on February 6, 2024, noted that the "analysis of acrolein was performed from an unpreserved sample outside of the 3-day holding time required by the test method and for NPDES compliance per 40CFRPart 136 for unpreserved samples." The TTO lab analytical for the sample that was collected on February 6, 2024, noted that the "analysis of acrylonitrile was performed from an unpreserved sample outside of the 3-day holding time required by the test method and for NPDES compliance per 40CFRPart 136 for unpreserved samples." Regulatory Requirement 40 CFR 136(8) outlines the guidelines establishing test procedures for the analysis of pollutants. Included in this section are the federal requirements for sample preservation, storage, holding times, and testing methods. 7. Has the CA ensured CIUs report on all regulated pollutants at least once every 6 months? (40 CFR 403.12(e)(1) & (g)(1)) Yes, based on the files reviewed, the Authority has ensured that its two CIUs report on all regulated pollutants at least once every six months. 8. Has the CA ensured non-categorical SIUs self-monitor and report at least once every 6 months with a description of the nature, concentration, and flow of the pollutants required to be reported by the Control Authority? (40 CFR 4.312(h) & (g)(1)) Yes. Based on the files reviewed, the Authority has ensured that its non-categorical SIU self-monitors and reports at least once every six months. DSB ID #: ECAD-474 Inspection Date: August 13, 2024 Page 13 of 22 Berwick Area Joint Sewer Authority (PA0023248) Pretreatment Compliance Inspection 9. Has the CA required self-monitoring reports from CIUs to be signed and certified? (40 CFR 403.12(b)(6), 403.12(l)) Finding E.9.1- The CIUs do not appear to be providing certification statements with their selfmonitoring reports. Based on the files reviewed, the Authority requires self-monitoring reports from its CIUs. However, the CIU permits are missing certification statement requirements and the monitoring reports reviewed did not include a certification statement. Regulatory Requirement The federal regulations at 40 CFR 403.12(l) outline the signatory requirements for Industrial User Reports. 10. Has the CA received notification of hazardous waste discharges? (40 CFR 403.12 (j) & (p)) No, the Authority representative stated that the Authority has not received notification of hazardous waste discharges from any of the SIUs. F. Enforcement 1. Has the CA implemented its enforcement response plan (ERP)? (40 CFR 403.8(f)(5)) No, based on the files reviewed by the Inspection Team and responses from the Authority representatives during the interview, the Authority has not taken enforcement action in accordance with its ERP in all instances of SIU noncompliance. Finding F.1.1 - The Authority did not take enforcement action in all instances of SIU noncompliance. The Authority representatives stated that they did not issue a Notice of Violation to Patriot Metal for their missed sampling in the third quarter of 2023. In addition, according to Wise's sampling data, there were 18 exceedances between January 2023 and June 2024. Parameters exceeded include oil and grease (O&G), total suspended solids (TSS), and biochemical oxygen demand (BOD). The Authority has responded to these exceedances by issuing NOVs. According to the Authority's Enforcement Response Plan, a recurring exceedance of local discharge limits is to be followed up with an Administrative Order with a fine. Regulatory Requirement The federal regulations at 40 CFR 403.8(f)(1) require the control authority to implement its legal authority, including the authority to enforce pretreatment program requirements. The federal regulations at 40 CFR 403.8(f)(5) require the control authority to develop and implement DSB ID #: ECAD-474 Inspection Date: August 13, 2024 Page 14 of 22 an enforcement response plan. Berwick Area Joint Sewer Authority (PA0023248) Pretreatment Compliance Inspection Part VII. of the control authority's ERP states that a first offense for there being no sample available should be an NOV. 2. Does the CA evaluate both numeric and narrative criteria for significant non-compliance (SNC) and annually publish a list of IUs in SNC? (40 CFR 403.8(f)(2)(viii)) Yes, the Authority evaluates SNC according to the definition in its SUO. The Authority publishes a list of SIUs in SNC in Press Enterprise. 2.a Were any SIUs in SNC in the past year? Include name of industry, type of SNC, and current compliance status. No, the Authority did not have any SIUs in SNC in the last year. 3. Has the CA developed IU compliance schedules? (40 CFR 403.8(f)(1)(iv)(A)) The Authority has the legal authority to develop and implement compliance schedules. There were no SIUs under a compliance schedule at the time of the Inspection. 4. Has the CA ensured CIU compliance within 3 years of standards effective date (or less than 3 years where required by standard)? (40 CFR 403.6(b)) N/A. The Authority has not identified any new CIUs or CIUs subject to a new categorical standard. 5. Has the CA ensured CIUs submit complete baseline monitoring reports (BMRs) and 90-day compliance reports within the required time frames? (40 CFR 403.12(b) & (d)) The Authority has ensured that its CIUs submit complete baseline monitoring reports. None of the CIUs have had to develop compliance reports. G. Additional Evaluations DSB ID #: ECAD-474 Page 15 of 22 Inspection Date: August 13, 2024 1. Hauled Waste Berwick Area Joint Sewer Authority (PA0023248) Pretreatment Compliance Inspection The Authority accepts hauled waste at the WWTP. The Authority does not accept any hauled waste from hospitals. For hauled waste, each company has a permit and may have multiple truckers. A sample is collected from each truck load for pH. Samples are randomly sent to an accredited lab for Biochemical Oxygen Demand (BOD), Total Suspended Solids (TSS), and occasionally for metals. 2. Dental Mercury Program The Authority Representative stated that there are four (4) dentists within its service area, and they have all submitted the required certification statement, pursuant to EPA's Dental Amalgam Rule. 3. Fats, Oils, and Grease (FOG) Program According to the Authority representatives, there are approximately 30 restaurants in its service area, but there could be more, and they are required to have grease traps. The Authority used to inspect the restaurants once a year, but now is conducting inspections less frequently. DSB ID #: ECAD-474 Page 16 of 22 Inspection Date: August 13, 2024 Berwick Area Joint Sewer Authority (PA0023248) Pretreatment Compliance Inspection Attachment 1 Industrial User Site Visit Data Sheets DSB ID #: ECAD-474 Page 17 of 22 Inspection Date: August 13, 2024 Berwick Area Joint Sewer Authority (PA0023248) Pretreatment Compliance Inspection IU SITE VISIT DATA SHEET INSTRUCTIONS: Record observations made during the IU site visit. Provide as much detail as possible. Name of industry: Wise Foods Inc. Address of industry: 229 Raseley Street, Berwick, PA 18603 Date of visit: 8/13/2024 Time of visit: 10:30 AM - 12:00 PM Name of inspectors: Janel Yorks (Authority) Chuck Durham (Eastern Research Group) Monica Crosby and Edward Simas (EPA Region 3) Provide the name(s) and title(s) of industry representative(s) Name Title Chris Greenly Maintenance Manger Terry Boyer Plant Manager The EPA Inspection Team presented their credentials to Mr. Terry Bower, Plant Manager, and Chris Greenly, Maintenance Planner, at the outset of the inspection (hereinafter, collectively "Wise Representatives"). The Wise Representatives stated that the pretreatment coordinator was out on vacation and Wise does not currently have a secondary pretreatment coordinator; the person that previously held this position retired and they haven't yet found a replacement. IU Permit Number: 22-P1 Exp. Date: August 26, 2027 IU Classification: Non-categorical SIU Please provide the following documentation: 1. Nature of operation: The facility is a local food processing facility that began in 1921 and specializes in potato and corn products. 2. Number of 650 Number of 3 Hours of Monday - Friday; 24 hrs/day employees: shifts: operation: 3. Wastestream flow(s) discharged to the POTW: Process water is generated from washing corn, before grinding, cleaning equipment, and as part of a weekly facility washdown. Additionally, some water is used as cooling water for equipment. Wise sends discharge from the abovementioned sources, as well as sanitary waste, to the Authority on a continuous basis. According to the Wise Representatives, any waste generated from their potato products, starch recovery, and weekend cleaning are not sent to the Authority; Wise has their own treatment plant and their own NPDES permit to treat that waste. Sanitary: NA Process: 130,000 gpd Combined: NA 4. Describe any significant changes in process or flow: Not determined. 5. Type of pretreatment system (Describe): Prior to sending waste to the Authority, a solids seperator is used; any corn mash that is generated is sent to a compactor and then shipped to local farmers for animal feed. DSB ID #: ECAD-474 Page 18 of 22 Inspection Date: August 13, 2024 Berwick Area Joint Sewer Authority (PA0023248) Pretreatment Compliance Inspection X Continuous flow Batch Combined 6. Process area description (identify raw materials and processes used): Not determined, the process is estimated to be about 60-65% potato and 30-35% corn based. 7. Chemical storage area As part of the inspection, the EPA Inspection Team observed the facility's chemical storage area. The EPA Inspection Team observed several jugs to be open and/or without secondary containment and staining surrounding the open containers. The EPA Inspection Team also observed acids and bases to be stored together. (Attachment 4, Photos 4 and 5). This area was located adjacent to a floor drain (Attachment 4, Photo 7). Furthermore, the EPA Inspection Team observed the chemical totes to be stored side-by-side within the chemical storage area (Attachment 4, Photo 6). The EPA Inspection Team communicated to the Wise Representatives that it would be beneficial to provide space between the totes, so that if there is a chemical spill, there is ample space to clean it up. Any floor drains? Yes Any spill control Yes measures? 8. Are hazardous wastes drummed and labeled? NA 9. Does the IU have hazardous waste manifests? NA 10. Solid waste production and disposal: Prior to sending waste to the Authority, a solids separator is used; any corn mash that is generated is sent to a compactor and then shipped to local farmers for animal feed. 11. Description of sample location and methods: The Wise Representatives stated their sampling location is on the corner of Susquehanna and Coughlin. Samples are collected and sent to Pace Analytical for testing. The Wise Representatives stated that Pace Analytical comes to their facility daily to take 24-hour composite samples. The Authority samples using the company's sampler. The EPA Inspection Team and the Authority Representative verified the permitted sampling location (Attachment 4, Photo 12). The EPA Inspection Team observed a manhole on the street leading to the sampling location. The Authority Representative confirmed that three houses are joining into the sample point. The EPA Inspection Team communicated that this is therefore not representative of Wise's process and their sample location would need to be changed. At the sampling location, the EPA Inspection Team observed Wise's flow meter, which was last calibrated in June of 2024, as well as the composite sampler (Attachment 4, Photos 13 and 14). The EPA Inspection Team also observed the thermometer inside the sample fridge to be at 7 degrees C. The thermometer was last calibrated in June 2020 and was due for calibration in June 2021. Notes: When asked about recent exceedances of Wise's Oil and Grease and pH limits, the Wise Representatives stated they were unsure what is causing the exceedances, but issues are usually generated on the process side. The Wise Representatives couldn't speak to whether a corrective action log exists that would document suspected causes to their exceedances. DSB ID #: ECAD-474 Inspection Date: August 13, 2024 Page 19 of 22 Berwick Area Joint Sewer Authority (PA0023248) Pretreatment Compliance Inspection IU SITE VISIT DATA SHEET INSTRUCTIONS: Record observations made during the IU site visit. Provide as much detail as possible. Name of industry: K-Fab, Inc. Address of industry: 2100 Dickson Street, Berwick, PA 18603 Date of visit: 8/13/2024 Time of visit: 1:30 - 2:45 PM Name of inspectors: Janel Yorks (Authority) Chuck Durham (Eastern Research Group) Monica Crosby and Edward Simas (EPA Region 3) Provide the name(s) and title(s) of industry representative(s) Name Title Jason Hart Plant Manager IU Permit Number: 23-28-2 Exp. Date: July 30, 2028 IU Classification: Categorical SIU Please provide the following documentation: 1. Nature of operation: The facility fabricates steel, cast iron, alloy, aluminum, and stainless steel. 2. Number of 12 Number of shifts: 1 Hours of Monday - Friday; 8 hrs/ employees: operation: day 3. Wastestream flow(s) discharged to the POTW: Process water is generated from the facility's wash station, as well as its rinse station where leftover material is rinsed off (Attachment 4, Photos 19, 20, 23, and 24). According to the K-Fab Representative, Simple Green is added to the Wash Station to remove any oils that may be transferred from human contact. A mix of chemical water and wash water is used for larger materials. Sanitary: Not Process: 275,000 (per permit application Combined: Not provided provided dated 11/22/2022) 4. Describe any significant changes in process or flow: NA 5. Type of pretreatment system (Describe): Prior to being pumped to Authority, flow is adjusted for pH and neutralization. pH is calibrated weekly using 4, 7, and 10 buffers. The EPA Inspection Team observed the 4 and 7 buffers to be expired in May 2020. The date was scratched out and had a note to "refill" with no date specified. At the time of the inspection, the K-Fab Representative presented an email order for new pH buffers. K-Fab reports pH values between 5.5 - 9 and thus, it appears K-Fab should also be calibrating pH with a 3 buffer. DSB ID #: ECAD-474 Page 20 of 22 Inspection Date: August 13, 2024 Berwick Area Joint Sewer Authority (PA0023248) Pretreatment Compliance Inspection Continuous flow Batch Combined 6. Process area description (identify raw materials and processes used) Parts are cleaned and then sealed to prevent rusting. Following this, the Facility applies a powder coating. Finally, parts are placed in a curing oven. 7. Chemical storage area: The EPA Inspection Team observed K-Fab's chemical storage area. All chemicals were stored under cover and no floor drains were observed (Attachment 4, Photos 17 and 18). Any floor drains? No Any spill control measures? Yes; secondary containment 8. Are hazardous wastes drummed and labeled? The facility does not generate any hazardous waste. 9. Does the IU have hazardous waste manifests? NA 10. Solid waste production and disposal: The K-Fab representative stated that the wash station is cleaned once a year. Residual material from cleaning the wash station is left to dry and then taken to landfill as non-hazardous waste (Attachment 4, Photo 26). 11. Description of sample location and methods: The K-Fab Representative stated that pH is monitored 24/7 using a pH meter (Attachment 4, Photo 16). K-Fab uses Pace Analytical Services to sample for metals each quarter. Part 1.A of the facility's permit describes the sampling location/Outfall 001 as "near the powder coating line." The EPA Inspection Team observed the sampling location/outfall to be inside the blue tank that sits southwest of the powder coating line (Attachment 4, Photo 15). DSB ID #: ECAD-474 Page 21 of 22 Inspection Date: August 13, 2024 Notes: Berwick Area Joint Sewer Authority (PA0023248) Pretreatment Compliance Inspection 1. Finding - Vague description of sampling location. Part 1.A of the permit describes Outfall 001 as "near the powder coating line." The EPA Inspection Team observed the outfall to be inside the blue tank that sits southwest of the powder coating line (Attachment 4, Photo 15). 2. Finding - Sample location not included in self-monitoring reports. 40 CFR 403.8 requires that self-monitoring samples and report include the sample location, sampling frequency, and sample type. K-Fab's self-monitoring samples for 2023 and the first half of 2024 do not appear to include sample location. 3. Finding - Improper analysis of TTOs The TTO lab analytical for 2023 and 2024 noted that the "analysis of 2-chloroethyl vinyl ether was performed from a sample that was field preserved to pH <2 with HCI. Acid preservation is not allowed for this parameter by the test method or for NPDES compliance per 40 CFR Part 136." The TTO lab analytical for 2023 and 2024 noted that "Analysis of acrolein and/or acrylonitrile was performed from a sample that was field preserved to pH < 2, which is less than the pH range of 4-5 specified in the test method and required for NPDES compliance per 40CFR Part 136." The lab analytical for the TTO sample that was collected on February 6, 2024, noted that the "analysis of acrolein was performed from an unpreserved sample outside of the 3-day holding time required by the test method and for NPDES compliance per 40CFRPart 136 for unpreserved samples." The TTO lab analytical for the sample that was collected on February 6, 2024, noted that the "analysis of acrylonitrile was performed from an unpreserved sample outside of the 3-day holding time required by the test method and for NPDES compliance per 40CFRPart 136 for unpreserved samples." 4. Finding - Expired pH Buffers According to the K-Fab Representative, pH is adjusted for neutralization, prior to sending flow to the Authority. pH is calibrated weekly using 4, 7, and 10 buffers. The EPA Inspection Team observed the 4 and 7 buffers to be expired in May 2020. The date was scratched out and has a note to "refill" with no date specified. At the time of the inspection, the K-Fab Representative presented an email order for new pH buffers. K-Fab reports pH values between 5.5 - 9 and thus, it appears K-Fab should also be calibrating pH with a 3 buffer. DSB ID #: ECAD-474 Page 22 of 22 Inspection Date: August 13, 2024