Document evkNXOJQVMvdyy32Z5p4EENQ4

Region 6 Compliance Assurance and Enforcement Division INSPECTION REPORT Inspection Date(s): Media: Regulatory Program(s) Company Name: Facility Names: Facility Physical Locations: (city, state, zip code) Mailing address: (city, state, zip code) County/Parish: Facility Contact: 12/9-10/2024 Water Clean Water Act St. John The Baptist Parish 1. Woodland Treatment Plant 2. Reserve WWTP 3. Belle Point STP 4. River Road 1. 900 Woodland Drive, LaPlace, LA 2. North end of Cypress Rd near Hwy 61, La Place LA 3. Off U.S. Hwy 61 (Airline Hwy) behind East St. John High School, LaPlace, LA 4. 144 Water Plant Rd., LaPlace LA LaPlace, LA 70068 1811 West Airline Hwy LaPlace, LA 70068 St. John The Baptist Parish Clayton Faucheux Director of Public Works c.faucheux@stjohn-la.gov 985-652-9569 ext 1125 FRS Number: Identification/Permit Number: Media Number: NAICS: SIC: LA0064092, LA0127097, LA0065951, LA0069868 4952 Personnel participating in inspection: Michael Williams EPA/ 6EN-WMH Inspector 281-983-2150 Chris Whitaker LDEQ Inspector 504-736-7739 Pete Labeof LDEQ Inspector 985-532-3615 Reed Alexander St. John The Baptist Parish Asst. Utilities Director 985-651-6800 Koi Thompson St. John The Baptist Parish Wastewater Treatment Mgr. 985-379-6459 Michael Curtis Curtis Environmental President 985-653-0000 David Curtis Curtis Environmental Operation Manager 985-653-0000 EPA Lead Inspector Signature/Date MICHAEL WILLIAMS MICHAEL WILLIAMS 2025.03.17 14:18:10 -05'00' Michael D. Williams Date Supervisor Signature/Date ROBERTO BERNIER Date: 2025.03.18 07:38:20 -05'00' Digitally signed by ROBERTO BERNIER Roberto Bernier Date St John The Baptist Parish LA0064092, LA0127097, LA0065951, LA0069868 Inspection Date 12/9-10/2024 Section I - Introduction PURPOSE OF THE INSPECTION EPA Region 6 inspector, Michael Williams, arrived at the St. John The Baptist Parish Municipal Building at 12:52 pm on December 9, 2024, for unannounced National Pollutant Discharge Elimination System (NPDES) inspections at the Parish's wastewater treatment plants. During the opening conference, I met with Reed Alexander, Assistant Director of Utilities. Mr. Alexander was informed that this was an EPA lead compliance evaluation inspection to determine compliance with the facility's NPDES permits (LA0064092, LA0127097, LA0065951 & LA0069868) and facility operations and maintenance under the Clean Water Act (CWA). The inspections were conducted under the authority of the NPDES permit program, in accordance with the Federal CWA. The information presented in this report is based on the materials and information supplied by the St. John The Baptist Parish representatives, observations made during the inspection, and records or reports maintained by the permittee, permittee contract laboratory, the State of Louisiana and EPA. FACILITY DESCRIPTIONS The Woodland WWTP LA0064092 The Woodland Wastewater Treatment Plant (WWTP) utilizes an activated sludge process for wastewater treatment with a capacity of 3.3 mgd. Initially, the wastewater passes through a mechanical bar screen to remove large debris, followed by a grit chamber that removes heavier particles. After this, the water flows into two treatment tanks, each designed with three internal chambers. The aeration chamber receives the flow from the grit chamber and provides oxygenation to the water, promoting the breakdown of organic matter. The water then moves to the center clarifier, where solids are allowed to settle. Following clarification, the treated water is filtered through a sand filter to further remove any remaining particles. It then enters the chlorine chamber for disinfection before being discharged at Outfall 001 into Vicknair Canal thence to Maurepas Swamp, thence to Lake Maurepas. In addition to the primary treatment process, each tank is equipped with an internal digester where sludge is further processed. The solids from the digester are dewatered using one of the eleven drying beds, completing the treatment cycle. The Reserve WWTP LA0127097 The Reserve Wastewater Treatment Plant (WWTP) is a lagoon-based system with a treatment capacity of 5.0 million gallons per day (mgd). It serves the Reserve residential area, including its commercial businesses and industrial park. The system is designed with several key components to efficiently treat wastewater. The treatment process begins at the headworks, which are equipped with eight fine mesh screens to remove large debris and prevent clogging of downstream equipment. From there, wastewater flows into four oxidation ponds, each of which is equipped with surface aerators to promote aerobic treatment. These aerators introduce oxygen into the water, facilitating the breakdown of organic material by microorganisms. 2 St John The Baptist Parish LA0064092, LA0127097, LA0065951, LA0069868 Inspection Date 12/9-10/2024 After undergoing treatment in the oxidation ponds, the effluent flows into the final treatment cell. From this point, the water is directed to a chlorine contact chamber where it undergoes disinfection to eliminate pathogens. Once disinfected, the treated effluent is pumped and discharged into the Mississippi River. Belle Point STP LA0065951 The Belle Point Sewage Treatment Plant (STP) is currently in the process of being decommissioned. During the inspection, the demolition of the plant's tanks was actively underway. Since 2021, the influent that was previously processed at Belle Point has been redirected to the Reserve Wastewater Treatment Plant (WWTP) for treatment. The decommissioning efforts include dismantling the existing infrastructure and ceasing operations at the Belle Point facility, as all wastewater is now being handled by the Reserve WWTP. River Road WWTP LA0069868 The River Road Wastewater Treatment Plant (WWTP) utilizes a 4.5 million gallon per day (mgd) activated sludge treatment process to treat wastewater. The system begins with a mechanical bar screen, which is used to remove large debris from the influent. The wastewater then flows into four aeration basins, where oxygen is introduced to support the growth of microorganisms that break down organic matter. After aeration, the water flows to two clarifiers, where the solids settle out of the wastewater. The clarified water is then directed to a chlorine contact chamber for disinfection before discharging to outfall 001 into Haydel Canal: thence into the Mississippi River. The plant also includes two digesters that process the residual sludge. In these digesters, the sludge undergoes biological treatment, which stabilizes the material. Once stabilized, the sludge is dewatered using a belt press, reducing its volume and preparing it for final disposal. Section II- Observations This inspection revealed the following observations: Woodland Treatment Plant LA0064092 Specific Observations: x During the inspection, several significant issues were identified at the wastewater treatment plant. The grit chamber was not functioning, which prevented the proper removal of heavier particles from the incoming flow. As a result, the flow received minimal screening before being discharged into the aeration chambers. Both clarifiers were non-operational due to a lack of power, causing the flow to move through the clarifiers by gravity, rather than the intended mechanical process. The sand filters were also out of service, further hindering the treatment process. Furthermore, the chlorine disinfection system was not operating as designed, with chlorine being manually adjusted instead of being automatically injected in proportion to the flow rate. These issues indicate a significant disruption in the plant's ability to properly treat wastewater. x St. John the Baptist Parish is currently in the process of decommissioning the Woodland Wastewater Treatment Plant (WWTP) and redirecting the influent to the Reserve WWTP 3 St John The Baptist Parish LA0064092, LA0127097, LA0065951, LA0069868 Inspection Date 12/9-10/2024 (LA0127097) as part of efforts to comply with the Louisiana Department of Environmental Quality (LDEQ) compliance order WE-C-22-00702, issued on November 16, 2022. The order includes a compliance schedule that the parish is working to meet. However, according to the most recent quarterly report submitted to LDEQ, the parish is currently three months behind schedule. Despite the ongoing decommissioning efforts, the parish is still required to meet the established discharge limits and monitoring requirements for the Woodland WWTP until the influent transfer is completed and LDEQ formally terminates permit LA0064092. Reserve WWTP LA0127097 Specific Observations x No major issues were observed with the overall operations of the Reserve Wastewater Treatment Plant (WWTP). However, it was noted that the chlorine is not being injected in proportion to the flow at the discharge point. Instead, the facility manually adjusts the chlorine feed rate for disinfection, which may not provide the precise control needed for disinfection treatment. Belle Point STP LA0065951 Specific Observation x Notice of Termination has not been submitted for permit LA0065951. The facility has ceased operation since 2021. River Road WWTP LA0069868 Specific Observations x During the inspection, several operational issues were identified at the facility. Both the bar screen and grit chamber were out of service, which impacted the initial stages of treatment. Only one clarifier was online, but its mechanical arm was malfunctioning by not rotating, preventing proper operation. The belt press was down, and the facility was relying on a mobile belt press to dewater solids from the digester. x It was also observed that the chlorine chamber was filled with solids, which could impede its function. Furthermore, a hydraulic surge was occurring due to the reduced treatment capacity, particularly during peak flow periods, which further compromised the facility's ability to manage wastewater effectively. Contract Laboratory for St. John the Baptist Parish Specific Observations x Curtis Environmental, the contracted laboratory for St. John the Baptist Parish, is responsible for conducting discharge monitoring analysis. However, the laboratory failed to follow the required procedures for Biochemical Oxygen Demand (BOD) testing and reporting. Specifically, the lab did not check or document the pH and chlorine levels, as required by Standard Methods 5210 B. Since both pH and chlorine levels can significantly affect microbial growth, they must be measured and adjusted before conducting the BOD test. Failure to perform this critical step invalidates the test results. As a result, St. John the Baptist Parish was unable to report valid BOD results from November 2022 to November 2024. x Additionally, while St. John the Baptist Parish collects and monitors chlorine and pH levels more frequently than required, the Curtis Environmental is only reports the values obtained on the days 4 St John The Baptist Parish LA0064092, LA0127097, LA0065951, LA0069868 Inspection Date 12/9-10/2024 when composite sampling is conducted for St. John the Baptist Parish. The parish monitors chlorine and pH levels daily. (See Attachment B) Section III- Areas of Concern This inspection revealed the following areas of concern: x St. John the Baptist Parish has not adhered to the requirements outlined in Section B, General Conditions, of their LPDES Permits LA0064092 and LA0069868. Specifically, the permit stipulates that the permittee must at all times properly operate and maintain all facilities and treatment systems installed or used to ensure compliance with permit conditions. However, the parish has failed to meet this obligation. During the inspection, it was observed that several systems were neither maintained nor operated as designed, which resulted in noncompliance with permit limitations. At the Woodland Treatment Facility (Permit LA0064092), key components such as the grit chamber, clarifiers, sand filters, chlorine flow injection system, and drying bed were found to be out of service. Similarly, at the River Road WWTP (LA0069868), critical equipment, including the bar screen, grit chamber, one clarifier, the mechanical skim arm on another clarifier, and the belt press, were also out of service. x St. John The Baptist Parish has failed to comply with Section C. Monitoring and Records of their LPDES Permit LA0064092, LA0127097 and LA0069868. The monitoring results must be conducted according to test procedures approved under 40 CFR Part 136. The monitoring and reporting of BOD from the months of November 2022 thru November 2025 were not conducted according to the procedures approved. x St. John the Baptist Parish has failed to comply with the requirements outlined in Section C, Monitoring and Records, specifically Section 8, Additional Monitoring by the Permittee, of their LPDES permits. According to the permit, the permittee is required to conduct and report additional monitoring as part of their routine compliance. However, the contract laboratory, Curtis Environmental, only reports the chlorine and pH values on the designated bi-weekly composite sampling days. These values are recorded on the chain of custody form submitted to Curtis Environmental Services. In addition, the parish operators collect and analyze chlorine and pH levels daily, following the approved method. While they record the maximum and minimum values of these measurements on the daily logs, the results of the additional monitoring are not being reported, as required by the permit. The failure to report these additional monitoring results constitutes a permit noncompliance, potentially impacting the parish's ability to demonstrate full compliance with all permit conditions. 5 Section IV - LIST OF APPENDICES St John The Baptist Parish LA0064092, LA0127097, LA0065951, LA0069868 Inspection Date 12/9-10/2024 x Appendix A - Photos x Appendix B - St. John the Baptist Parish Daily pH and Cl2 records x Appendix C - Curtis Environmental Services BOD SOP & Bench Sheets 6  ^:ZW >>>> /Z WZZ>Z hE/d^dd^Es/ZKEDEd>WZKdd/KE'Ez WZZ>Z >ZZ ^:ZW >W WZZEZ ZW ^:Z ^ > tZZd' hE/d^dd^Es/ZKEDEd>WZKdd/KE'Ez WZZ>Z >ZZ ^:ZW >W WZZEZ ZW ^:Z ^ > tZZd^ hE/d^dd^Es/ZKEDEd>WZKdd/KE'Ez WZZ>Z >ZZ ^:ZW >W WZZEZ ZW ^:Z ^ > tZZdZ hE/d^dd^Es/ZKEDEd>WZKdd/KE'Ez WZZ>Z >ZZ ^:ZW >W WZZEZ ZW ^:Z ^ > tZZdKZ hE/d^dd^Es/ZKEDEd>WZKdd/KE'Ez WZZ>Z >ZZ ^:ZW >W WZZEZ ZW ^:Z ^ > tZZd Z hE/d^dd^Es/ZKEDEd>WZKdd/KE'Ez WZZ>Z >ZZ ^:ZW >W WZZEZ ZW ^:Z ^ > tZZdZ Z hE/d^dd^Es/ZKEDEd>WZKdd/KE'Ez WZZ>Z >ZZ ^:ZW >W WZZEZ ZW ^:Z ^ > ZttdW^ hE/d^dd^Es/ZKEDEd>WZKdd/KE'Ez WZZ>Z >ZZ ^:ZW >W WZZEZ ZW ^:Z ^ > ZttdW>ZZ hE/d^dd^Es/ZKEDEd>WZKdd/KE'Ez WZZ>Z >ZZ ^:ZW >W WZZEZ ZW ^:Z ^ > WZ^dW ZZ hE/d^dd^Es/ZKEDEd>WZKdd/KE'Ez WZZ>Z >ZZ ^:ZW >W WZZEZ ZW ^:Z ^ > WZ^dW ZZ hE/d^dd^Es/ZKEDEd>WZKdd/KE'Ez WZZ>Z >ZZ ^:ZW >W WZZEZ ZW ^:Z ^ > ZZZttdWKZ^ ^ hE/d^dd^Es/ZKEDEd>WZKdd/KE'Ez WZZ>Z >ZZ ^:ZW >W WZZEZ ZW ^:Z ^ > ZZZttdWKZ^' hE/d^dd^Es/ZKEDEd>WZKdd/KE'Ez WZZ>Z >ZZ ^:ZW >W WZZEZ ZW ^:Z ^ > ZZZZ hE/d^dd^Es/ZKEDEd>WZKdd/KE'Ez WZZ>Z >ZZ ^:ZW >W WZZEZ ZW ^:Z ^ > ZZZttdW hE/d^dd^Es/ZKEDEd>WZKdd/KE'Ez WZZ>Z >ZZ ^:ZW >W WZZEZ ZW ^:Z ^ > ZZZZ hE/d^dd^Es/ZKEDEd>WZKdd/KE'Ez WZZ>Z >ZZ ^:ZW >W WZZEZ ZW ^:Z ^ > ZZZttdWZZ hE/d^dd^Es/ZKEDEd>WZKdd/KE'Ez WZZ>Z >ZZ ^:ZW >W WZZEZ ZW ^:Z ^ > ZZZttdWZZ hE/d^dd^Es/ZKEDEd>WZKdd/KE'Ez WZZ>Z >ZZ ^:ZW >W WZZEZ ZW ^:Z ^ > ZZZttdW Appendix B St. John the Baptist Parish Daily pH and Cl2 records Appendix C Curtis Environmental Services Standard Operating Procedures for BOD & BOD Bench Sheets