Document jNN0L4xGnnn48dmboK9b01V4O

EPA Region 5 Enforcement and Compliance Assurance Division INSPECTION REPORT Inspection Entry Date/Time Inspection Exit Date/Time Weather Media Statute(s)/Program(s) Type of Inspection 11/09/2022 09:00 AM (ET) Announced: Yes 11/09/2022 12:00 PM (ET) Access: Granted Sunny, 45 degrees Fahrenheit Water Clean Water Act, NPDES CEI - Compliance Evaluation Inspection Permittee Name Facility or Site Name Facility/Site Physical Address City, State, Zip Code County/Borough/Parish Facility GPS Coordinates Mailing Address (If different) City, State, Zip Code Scioto County Commissioners (South Webster WWTP) South Webster WWTP County Road 12 South Webster, OH 45682 Scioto County 38.81667, -82.73701 602 7th Street, Room 104 Courthouse Portsmouth, Ohio 45662 FRS ID 110009163172 Permit Number(s) (If Applicable) OH0041416 SIC and/or NAICS 4952 Regulatory Representatives Participating in Inspection: Title Name Inspector Anne Marie Vincent Organization EPA Region 5 Lead Inspector: Megan Zale Supervisor Review: Brooke Furio MEGAN ZALE EPA Region 5 Digitally signed by MEGAN ZALE Date: 2023.01.05 13:48:39 -05'00' zale.megan@epa.gov BROOKE FURIO EPA Region 5 Digitally signed by BROOKE FURIO Date: 2023.01.06 08:04:26 -05'00' furio.brooke@epa.gov (440) 250-1711 (440) 250-1705 SECTION I - INTRODUCTION Site Entry and Inspection Objectives 1 of 22 South Webster WWTP Inspection Date: November 9th, 2022 EPA Region 5 Lead Inspector, Megan Zale, arrived at the South Webster WWTP (the "Site" or "Facility"), located at County Road 12, South Webster, OH 45682, at 09:00 AM (ET) on 11/09/2022 for an announced inspection. EPA Region 5 Lead Inspector presented credentials to Ryan Smith and informed him that this was an EPA Region 5 inspection to determine compliance as authorized by Clean Water Act (CWA) Section 308 and implementing regulations. This report is based on information supplied by South Webster WWTP representatives, direct observations made by the EPA Region 5 inspectors, records and reports maintained by the permittee and other information including: photographs taken by EPA Region 5 inspectors, physical evidence collected by the EPA Region 5 inspectors, measurements taken by EPA Region 5 inspectors, verbal or written statements made by information supplied by South Webster WWTP representatives during or subsequent to the on-site Inspection, and materials, processes, data, photographs, or documents shown, demonstrated, or submitted to the EPA Region 5 inspectors by South Webster WWTP representatives during or subsequent to the on-site Inspection. In addition, information gathered prior to or subsequent to the Inspection from a review of EPA, State, and/or public records may be included in this report. Attendees Organization Attendee Name EPA Region 5 EPA Region 5 EPA Region 5 Scioto County Sanitary Engineers Scioto County Sanitary Engineers Megan Zale Anne Marie Vincent Danny Nguyen Ryan Smith Johnny McKenzie Title Lead Inspector Present in Opening Conf. Yes Inspector Yes Inspector Yes Treatment Coordinator Yes Present in Closing Conf. Yes Yes Yes Yes Backup operator, Lab Yes Yes tech Facility/Site Description EPA Region 5 lead inspector confirmed the following facility information: The Wastewater Treatment Plant (WWTP) was built by the Village of South Webster in 1999. The county took over ownership and operation of the South Webster WWTP in 2013. The county is planning to upgrade the 20year-old HMI system (computerized control system) for operating the plant because parts have become difficult to find for replacements. They are also planning to install a bar screen and wet well with a lift station at the headworks in the future, after disconnecting two package plants in the area (Tanglewood and Scaff-Staritt). The plant consists of two sequencing batch reactors (SBRs), one sludge holding tank/digester, and ultraviolet light disinfection. At the time of the inspection there was no physical bar screen or grit removal mechanism at the headworks of the plant to remove trash and debris. The SBR units continuously complete sequences consisting of five cycles. Sludge wasting happens at end of each sequence. From the sludge holding tank, decant liquid flow goes to the on-site lift station, into the force main (combines with influent after the influent flow meter), then to one of the SBR units (a computer program controls which unit receives flow). Decant liquid from the SBRs goes through ultra-violet disinfection prior to discharge at the outfall. There are no industrial users or facilities that require pretreatment which are tributary to the WWTP. According to Ryan Smith, James Gulley (not present during the inspection), the primary operator of record for the South Webster WWTP, is on site 5 days a week for a minimum of four hours a day. Mr. Gulley is a Class III operator. Mr. Gulley's previous and expired professional operator's certificate was displayed in the WWTP office, but his most current operator certification/renewal card was not displayed on site. A printed hard copy 2 of 22 South Webster WWTP Inspection Date: November 9th, 2022 of the NPDES permit was not available on site, however, the permit is available electronically on the facility office computer. Operational parameters at the WWTP are monitored daily by the operator on site and computer-based adjustments to the operating parameters are made as needed. The flume and flow meter for effluent are inspected and calibrated annually by a contract company, Tru Flow Meters & Calibrations, LLC. The influent flow meter (Greyline Instruments Inc. DFM 5.1 doppler flow meter) is also calibrated annually. The most recent calibration was 10/26/2022. During the inspection the flume was observed to be clean and free of debris. Operators check the flow meters daily for operability. The field monitoring meters for pH, dissolved oxygen and temperature are calibrated by either Johnny McKenzie or James Gulley when they pick up the meters from the Wheelersburg WWTP prior to use at the South Webster Plant. No additional testing/sampling is done beyond permit parameters. Ryan Smith stated that the largest controlling factor impacting ammonia exceedances is the operational adjustment for how much sludge to waste. Sludge wasting is currently based on time at this plant. Mr. Smith stated that SBR1 was programmed to waste sludge at the end of the sequence for approximately 0.8 minutes. In addition, Mr. Smith also believes that the general sludge disposal problem that the county is experiencing across the whole system of plants is contributing to the ammonia exceedances at the plants including South Webster. South Webster WWTP can hold about a year of sludge, according to Mr. Smith, but the sludge hauling/disposal issues have slowed the sludge removal process for over a year. Sludge is transported to the Wheelersburg WWTP for processing. The county used to be able to remove sludge at the Wheelersburg Plant two times per week, but now can only send 1 box of sludge solids per month for landfill disposal due to the requirement to achieve a set "sludge to trash ratio" at the landfills. The WWTP is conducting time-based composite sampling, not flow-proportionate sampling. The new permit, effective October 1, 2022, removed the previous permit requirement for flow-proportionate composite sampling. The language in the new permit states, under Part II Other Requirements, Item G, "Composite samples shall be comprised of a series of grab samples collected over a 24-hour period. Such samples shall be collected at such times and locations, and in such a fashion, as to be representative of the facility's overall performance." as required by the permit. Copies of chains of custody for all collected samples are maintained at the Wheelersburg WWTP which serves as a centralized document retention location. The South Webster WWTP has an alarm system for essential equipment. The alarms register within the main Supervisory Control and Data Acquisition (SCADA) system which is monitored. However, the plant operators do not receive automatic system call outs alerting them to the specific alarms. Only an alarm for a total power failure at the South Webster WWTP would be sent out as a phone call alert directly to the operators. The facility has standby power for the treatment units on site. The standby power generator is operated on a set periodic cycle to ensure continued operability. Facility/Site Information Responsible Official WWTP Design Capacity & Average Daily Flow WWTP Approx. # of residents served Contributing (or shared) Jurisdictions James Gulley Design Flow is 0.150 MGD. Avg Flow is 0.127 MGD 300 N/A 3 of 22 South Webster WWTP Inspection Date: November 9th, 2022 Outfalls: (and do the numbers, locations, and receiving waters match the permit?) 1 outfall. OF 001 was not flowing at the time of inspection. Do you use in-house or contract out for laboratory analyses? (including for metals or WET testing?) At plant: pH, temperature, Dissolved Oxygen (DO). To Wheelersburg WWTP lab: Ammonia, Total Suspended Solids (TSS), Carbonaceous Biochemical Oxygen Demand (CBOD), Escherichia coli (E.coli), hardness. To MASI lab: everything else (including Total Kjeldahl Nitrogen (TKN), nitrate-nitrite and Total Phosphorus (TP) when needed). Do you accept waste No from septage haulers? If so, what problems have you experienced? Is there currently any n/a portion of the treatment train that is non-operational? Location(s) Location/Area/Sub-area Receiving stream Treatment Description Skull Creek SECTION II - OBSERVATIONS Location: Receiving stream Observation #: MZ2-OB-001 Date: 11/09/2022 EPA observed algal mats in the receiving stream. Location: Treatment Observation #: MZ2-OB-002 Date: 11/09/2022 EPA did not observe a wet thermometer in the influent autosampler's refrigerator. Location: Treatment Observation #: MZ2-OB-003 Date: 11/09/2022 There were no emergency numbers listed inside office/control room building at the time of the inspection Location: Treatment 4 of 22 South Webster WWTP Inspection Date: November 9th, 2022 Observation #: MZ2-OB-004 Date: 11/09/2022 EPA did not observe any type of trash screening mechanism at the WWTP's headworks. Location: Treatment Observation #: MZ2-OB-005 Date: 11/09/2022 EPA observed the operator's logbook on site which included on-site dates, times, identification of the operator, and activities completed. Location: Treatment Observation #: MZ2-OB-006 Date: 11/09/2022 EPA observed some vegetation growing in the SBRs Location: Treatment Observation #: MZ2-OB-007 Date: 11/09/2022 EPA noted that the current professional operator certificate for the operator of record was not on site at the time of the inspection. Location: Treatment Observation #: MZ2-OB-008 Date: 11/09/2022 According to the operator, the WWTP is conducting time-based composite sampling, not flow-proportionate sampling. The facility's new permit, effective October 1, 2022, requires time-based composite sampling, which replaced the previous permit requirement for flow-proportionate composite sampling. Location: Receiving stream Observation #: MZ2-OB-009 Date: 11/09/2022 Effluent composite sampler refrigerator did not have a wet thermometer. Refrigerator door was propped open to defrost the refrigerator which had iced over around the collection jug. The unit had a visible thermostat to control temperature. Location: Records Review - Facility logbook Observation #: MZ2-RR-001 Date: 1/5/2023 In follow-up communications after the site visit, on December 9, 2022, Ryan Smith emailed documents to EPA for the month of November 2022, including photos from the logbook. Logbook photos for the month of November 2022 do not show evidence that the facility is being visited five times per week, as required by its permit. They show the facility was visited only 8 days during the month. 5 of 22 South Webster WWTP Inspection Date: November 9th, 2022 SECTION III - RECORDS REVIEW The South Webster WWTP has an office/control room on site where the operators maintain an on-site logbook. The logbook for South Webster was reviewed on site. Maintenance and repair activities are documented in the logbook. Daily operator entries in the logbook include dates, times on site, identification of the operator and the activities completed. A separate log sheet in the WWTP office is maintained to record daily temperature, DO and pH measurements as well as daily flow values. In follow-up communications after the site visit, Ryan Smith emailed documents to EPA for the month of November 2022, including photos from the logbook, daily discharge monitoring report forms, annual sewage sludge report forms, sanitary sewer overflow report forms, and internal laboratory chain of custody forms. SECTION IV - SAMPLING ACTIVITIES AND ANALYTICAL RESULTS No sampling was conducted. SECTION V - AREAS OF CONCERN Areas of Concern may not be in sequential order. The presentation of areas of concern does not constitute a formal compliance determination or violation. AOC Reference #: MZ2-OB-002 Location: Treatment Regulation and/or Permit Requirement Regulation: 40 CFR Part 136 Table II: Required Containers, Preservation Techniques, and Holding Times, footnote 18: "Aqueous samples must be preserved at 6 C."; Permit requirement: Part III Item 2.A: General Conditions - Facility Operation and Quality Control: "All wastewater treatment works shall be operated in a manner consistent with the following: A. At all times, the permittee shall maintain in good working order and operate as efficiently as possible all treatment or control facilities or systems installed or used by the permittee necessary to achieve compliance with the terms and conditions of this permit. Proper operation and maintenance also includes adequate laboratory controls and appropriate quality assurance procedures." AOC: No wet thermometer in influent composite sampler refrigerator. The computer panel for the automatic composite sampler did not appear to be set up to read the refrigerator temperature. AOC Reference #: MZ2-OB-004 Location: Treatment Regulation and/or Permit Requirement Part III Item 2.A: General Conditions - Facility Operation and Quality Control: "All wastewater treatment works shall be operated in a manner consistent with the following: A. At all times, the permittee shall maintain in good working order and operate as efficiently as possible all treatment or control facilities or systems installed or used by the permittee necessary to achieve compliance with the terms and conditions of this permit." AOC: Lack of any type of trash screening mechanism at headworks. 6 of 22 South Webster WWTP Inspection Date: November 9th, 2022 AOC Reference #: MZ2-OB-007 Location: Treatment Regulation and/or Permit Requirement N/A AOC: Current professional operator certificate for the operator of record was not on site AOC Reference #: MZ2-OB-009 Location: Treatment Regulation and/or Permit Requirement Regulation: 40 CFR Part 136 Table II: Required Containers, Preservation Techniques, and Holding Times, footnote 18: "Aqueous samples must be preserved at 6 C."; Permit requirement: Part III Item 2.A: General Conditions - Facility Operation and Quality Control: "All wastewater treatment works shall be operated in a manner consistent with the following: A. At all times, the permittee shall maintain in good working order and operate as efficiently as possible all treatment or control facilities or systems installed or used by the permittee necessary to achieve compliance with the terms and conditions of this permit. Proper operation and maintenance also includes adequate laboratory controls and appropriate quality assurance procedures." AOC: Effluent composite sampler refrigerator did not have a wet thermometer. Refrigerator door was propped open to defrost the refrigerator which had iced over around the collection jug. The unit had a visible thermostat to control temperature. AOC Reference #: N/A Location: N/A Regulation and/or Permit Requirement Permit requirement: Part III Item 2.A: General Conditions - Facility Operation and Quality Control: "All wastewater treatment works shall be operated in a manner consistent with the following: A. At all times, the permittee shall maintain in good working order and operate as efficiently as possible all treatment or control facilities or systems installed or used by the permittee necessary to achieve compliance with the terms and conditions of this permit. Proper operation and maintenance also includes adequate laboratory controls and appropriate quality assurance procedures." AOC: 38 effluent limit exceedances were reported in the facility's discharge monitoring reports for ammonia at outfall 001 between January 2017 and January 2022. AOC Reference #: MZ2-RR-001 Location: Records review - Facility logbook Regulation and/or Permit Requirement Ohio Administrative Code 3745-7-04 The Class II facility staffing requirement is 5 days a week for a minimum of 20 hours per week. AOC: 7 of 22 South Webster WWTP Inspection Date: November 9th, 2022 In follow-up communications after the site visit, on December 9, 2022, Ryan Smith emailed documents to EPA for the month of November 2022, including photos from the logbook. Logbook photos for the month of November 2022 do not show evidence that the facility is being visited five times per week, as required by its permit. They show the facility was visited only 8 days during the month. SECTION VI - CLOSING CONFERENCE AND FOLLOW UP Closing Conference The EPA Region 5 Lead Inspector held a closing conference with Facility personnel at 11:36 AM (ET) on 11/09/2022 for the inspection. During the closing conference, EPA Region 5 Lead Inspector discussed the observations and Areas of Concern identified during the inspection. Observations and Areas of Concern have not yet been evaluated for a formal compliance determination. EPA inspectors told facility representatives: Emergency numbers should be displayed on site Algal mats observed in receiving stream Some vegetation observed in SBRs Facility representatives informed EPA inspectors: They will hang up list of emergency numbers Despite algal mats in receiving stream, facility is not losing sludge. They clean trash out of stream regularly. Vegetation in SBRs not a hindrance to plant performance. SBR design makes it difficult to deal with vegetation mats. Have to raise the wastewater level in the units to remove vegetation. There is always a little bit of scum in sludge holding tanks but no mats. Decant liquid from the sludge holding tank flows to the on-site lift station, to the force main (combines with influent), then to one of the SBR units (the computer controls which unit receives flow) Plant can run on one SBR if needed. There are Inflow/Infiltration issues in the village, with a lot of downspouts tied in. The County is planning to address this in the future after other issues are addressed. There are no flow volume capacity problems as the facility is not close to its operational design capacity volume. Follow Up In follow-up communications after the site visit, on December 9, 2022, Ryan Smith emailed documents to EPA for the month of November 2022, including photos from the logbook, daily discharge monitoring report forms, annual sewage sludge report forms, sanitary sewer overflow report forms, and internal laboratory chain of custody forms. Communication Log In follow-up communications after the site visit, on December 9, 2022, Ryan Smith emailed documents to EPA for the month of November 2022, including photos from the logbook, daily discharge monitoring report forms, annual sewage sludge report forms, sanitary sewer overflow report forms, and internal laboratory chain of custody forms. SECTION VII - LIST OF APPENDICES 1. Photo Log 8 of 22 South Webster WWTP Inspection Date: November 9th, 2022 9 of 22 South Webster WWTP Inspection Date: November 9th, 2022 APPENDIX 1: PHOTO LOG HMI System Control Panel 11/09/2022 09:23 AM WWTP office building DSCN0331.JPG Photographer: Megan Zale No CBI No PII Flow meter in influent force main 11/09/2022 09:30 AM At WWTP, south of office building DSCN0332.JPG Photographer: Megan Zale No CBI No PII 10 of 22 South Webster WWTP Inspection Date: November 9th, 2022 Influent force main 11/09/2022 09:31 AM At WWTP, south of office building DSCN0333.JPG Photographer: Megan Zale No CBI No PII Influent composite sampler readout screen 11/09/2022 09:32 AM At WWTP, south of office building DSCN0334.JPG Photographer: Megan Zale No CBI No PII 11 of 22 South Webster WWTP Inspection Date: November 9th, 2022 Influent sampler refrigerator 11/09/2022 09:32 AM At WWTP, south of office building DSCN0335.JPG Photographer: Megan Zale No CBI No PII Sludge holding tank/digester 11/09/2022 09:40 AM WWTP facility, south of office building DSCN0336.JPG Photographer: Megan Zale No CBI No PII 12 of 22 South Webster WWTP Inspection Date: November 9th, 2022 Sludge holding tank/digester 11/09/2022 09:41 AM WWTP facility, south of office building DSCN0337.JPG Photographer: Megan Zale No CBI No PII SBR1 in decant phase. Decanter in upper right corner of photo. 11/09/2022 09:41 AM WWTP facility, south of office building DSCN0338.JPG Photographer: Megan Zale No CBI No PII 13 of 22 South Webster WWTP Inspection Date: November 9th, 2022 SBR2 in mix fill phase 11/09/2022 09:44 AM WWTP facility, south of office building DSCN0339.JPG Photographer: Megan Zale No CBI No PII SBR2 decanter 11/09/2022 09:44 AM WWTP facility, south of office building DSCN0340.JPG Photographer: Megan Zale No CBI No PII 14 of 22 South Webster WWTP Inspection Date: November 9th, 2022 Decant pump station DSCN0341.JPG 11/09/2022 10:03 AM Photographer: Megan Zale WWTP facility, south of office building No CBI No PII Notes: Everything from maintenance building, including toilet, flows here. Effluent composite sampler DSCN0342.JPG 11/09/2022 10:04 AM Photographer: Megan Zale WWTP facility, west of office building No CBI No PII Notes: Sigma 900 model. The refrigerator had iced over, and staff was defrosting it during the inspection to remove the ice build-up. 15 of 22 South Webster WWTP Inspection Date: November 9th, 2022 Effluent composite sampler readout screen 11/09/2022 10:05 AM WWTP facility, west of office building DSCN0343.JPG Photographer: Megan Zale No CBI No PII Effluent flow meter with flume 11/09/2022 10:07 AM WWTP facility, west of office building DSCN0344.JPG Photographer: Megan Zale No CBI No PII 16 of 22 South Webster WWTP Inspection Date: November 9th, 2022 UV treatment system controls 11/09/2022 10:12 AM WWTP facility, west of office building DSCN0345.JPG Photographer: Megan Zale No CBI No PII UV treatment system DSCN0346.JPG 11/09/2022 10:14 AM Photographer: Megan Zale WWTP facility, west of office building No CBI No PII Notes: UV treatment occurs before effluent sampler. 17 of 22 South Webster WWTP Inspection Date: November 9th, 2022 Outfall 001 11/09/2022 10:17 AM Skull Creek, northwest of WWTP facility DSCN0347.JPG Photographer: Megan Zale No CBI No PII Flow pathway from outfall towards the receiving stream 11/09/2022 10:18 AM Skull Creek, northwest of WWTP facility Notes: Algal mats observed DSCN0348.JPG Photographer: Megan Zale No CBI No PII 18 of 22 South Webster WWTP Inspection Date: November 9th, 2022 Flow pathway from the outfall towards the receiving stream 11/09/2022 10:18 AM Skull Creek, northwest of WWTP facility Notes: Algal mats observed DSCN0349.JPG Photographer: Megan Zale No CBI No PII Downstream sample location in the receiving stream 11/09/2022 10:20 AM Skull Creek, north of Outfall 001 DSCN0350.JPG Photographer: Megan Zale No CBI No PII 19 of 22 South Webster WWTP Inspection Date: November 9th, 2022 Downstream between outfall and downstream sample location 11/09/2022 10:22 AM Skull Creek, north of Outfall 001 DSCN0351.JPG Photographer: Megan Zale No CBI No PII Discharge pipes from the abandoned reservoir adjacent to outfall 001. 11/09/2022 10:23 AM Skull Creek, north of WWTP facility DSCN0352.JPG Photographer: Megan Zale No CBI No PII 20 of 22 South Webster WWTP Inspection Date: November 9th, 2022 Upstream sample location in receiving stream 11/09/2022 10:24 AM Skull Creek, east of Outfall 001 DSCN0353.JPG Photographer: Megan Zale No CBI No PII Operator logbook for South Webster WWTP 11/09/2022 10:51 AM WWTP office DSCN0354.JPG Photographer: Megan Zale No CBI No PII 21 of 22 South Webster WWTP Inspection Date: November 9th, 2022 Daily measurement log 11/09/2022 10:52 AM WWTP office DSCN0355.JPG Photographer: Megan Zale No CBI No PII 22 of 22