Document mmq7L4oeNaoV7oL7q5oZ0B08b

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION III 1650 Arch Street Philadelphia, Pennsylvania 19103-2029 Report Title: Inspection Date(s): Regulatory Program(s): Type of Activity: Site/Facility Name: Permittee(s): Site/Facility Operator: Site/Facility Address: Latitude: County/Parish: Permit Number: NAICS Code: Unique Project #: Clean Water Act Compliance Inspection Report 08/26/2020 National Pollutant Discharge Elimination System (NPDES) NPDES - CWA - Pretreatment Audit Pottsville Main STP GREATER POTTSVILLE AREA SEW AUTHSCHUYLKILL CNTY LAUX JAMES W 1050 ROUTE 61 SOUTH POTTSVILLE, PA 17901 40.677868 Longitude: -76.188832 Schuylkill PA0043885 221320 SIC: 4952 3E21WN044A Site/Facility Representative(s): Tim Yingling - Executive Director (GPASA) Phone: (570) 622-0513 Email: gpasa@comcast.net Joseph Spotts - Environmental H&S Manager - Yuengling Phone: 570-622-0153x1556 Email: Jspotts@yuengling.com EPA Inspectors: Aaron Thomson - Inspector (3ED13) Phone: 215-814-2116 Email: Thomson.aaron@epa.gov Point of Contact EPA Contractors: n/a State/Local Inspectors: n/a Report Preparer Signature/Date Supervisor Signature/Date Digitally signed by AARON AARON THOMSON THOMSON Date: 2021.10.29 11:06:53 -04'00' Aaron Thomson 3ED13 Date 1650 Arch Street, Philadelphia 19103 JAMES BENNETT Digitally signed by JAMES BENNETT Date: 2021.11.01 08:09:26 -04'00' Jim Bennet 3ED13 Date Unique Project#: 3E21WN044A GREATER POTTSVILLE AREA SEW AUTHSCHUYLKILL CNTY/Pottsville Main STP 8/26/2021 Section Table of Contents Page I Introduction............................................................................ 3 A Inspection Opening Conference...................................................................... 3 B Weather and Precipitation Conditions............................................................. 3 C Summary of the Facility.................................................................................. 3 II Site Activity..................................................................................................... 4 III Observations.................................................................................................... 5 IV Records Review............................................................................................... 6 V Closing Conference......................................................................................... 6 VI List of Attachments.......................................................................................... 7 Unique Project #: 3E21WN044A Page 2 of 7 GREATER POTTSVILLE AREA SEW AUTHSCHUYLKILL CNTY/Pottsville Main STP 8/26/2021 I. Introduction On August 26, 2021, an inspection team composed of staff from the U.S. Environmental Protection Agency ("EPA") Region III (hereinafter, "EPA Inspection Team") conducted a NPDES CWA Pretreatment Audit of the Pottsville Main STP facility (hereinafter, "the facility"). The purpose of the inspection was to observe compliance with the Clean Water Act (CWA) and to verify compliance with the facility's National Pollutant Discharge Elimination System (NPDES) Permit No. PA0043885 (hereinafter, the "Permit") and applicable State and Federal regulations (Attachment 3). A. Inspection Opening Conference The EPA Inspection Team arrived at 401 N. Centre Street, a GPASA office that contains records of the facility, at est. 11:00 A.M. for the inspection. Inspectors met with the following facility representatives: Name Aaron Thomson Timothy Yingling Tyler Heffner Table 1: Inspection Attendee List Affiliation Telephone Email EPA Region III Inspectors and Contractors 215-814-2116 Thomson.aaron@epa.gov Site/Facility Representatives GPASA (570) 622-0513 gpasa@comcast.net GPASA (570) 622-0513 gpasa@comcast.net EPA Inspector Aaron Thomson displayed their credentials to Mr. Yingling and Mr. Heffner at the outset of the inspection, and explained the purpose of the inspection was to observe compliance with its Permit. A copy of the Permit is provided in Appendix A. The EPA Inspection Team informed Mr. Yingling that any information that the Facility deemed to be confidential business information ("CBI") should be identified to EPA representatives during the inspection and it would be handled as CBI according to EPA's CBI procedures. B. Weather and Precipitation Conditions During the inspection, weather was sunny with a high of 93 degrees Fahrenheit. C. Summary of the Site/Facility The facility is a sewage treatment plant controlled by the Greater Pottsville Sewer Authority (GPASA). The facility has a permitted flow capacity of 8.2 MGD and services the City of Pottsville and the Boroughs of Port Carbon, Palo Alto, Mechanicsville, and Mount Carbon and portions of the Townships of Norwegian, North Manheim and East Norwegian. The facility discharges to the Schuylkill River. Unique Project #: 3E21WN044A Page 3 of 7 GREATER POTTSVILLE AREA SEW AUTHSCHUYLKILL CNTY/Pottsville Main STP 8/26/2021 II. Site Activity Inspector Thomson asked Mr. Yingling to describe the treatment process. Wastewater enters the headworks and passes through a bar screen and grit classifier before entering a splitter box. The influent sampler is located before the wastewater stream enters the splitter box. The stream is split between two identical trains, where it will enter the primary clarification chamber, then an aeration chamber and then a final clarifier. The streams then combine and enter a disinfectant chamber where sodium hypochlorite is added to the stream. The effluent sampling point is located at the end of the disinfectant chamber. Supernatant from the final clarifier will be returned to the aeration tanks, and additional sludge is moved to a sludge processing building including a thickener, anaerobic digestors with a methane flare chamber and a belt filter press. The resulting waste is hauled to a landfill by Disposal Management Services, Inc out of Coal Township, PA. Inspector Thomson requested that Mr. Yingling describe the sampling procedures at the facility. Mr. Yingling stated that, in regard to sampling, facility employees collect samples in sample bottles provided by Hawk Mountain Labs, out of Hazelton, PA, who is also used to analyze the samples. Facility employees are trained to sample with on-the-job training. According to Mr. Yingling, the facility currently has three permitted industrial users (IUs). These include two Yuengling brewery sites as well as Honeywell, a film processing facility. Mr. Yingling stated that, although the IU's may do their own internal testing, they also use third party labs to provide sample bottles/sample analysis as required by their permit. Honeywell also uses Hawk Mountain Labs, Yuengling uses Suburban Testing Labs out of Reading, PA. The Yuengling sites report sample results to the facility monthly, and Honeywell reports quarterly. Inspector Thomson asked Mr. Yingling to describe any issues the facility has faced with their IUs, in relation to their discharge to the facility. Mr. Yingling stated that Yuengling, specifically the mill creek site, discharges wastewater to the facility that is over BOD and TSS local limits, however, the facility can handle the BOD/TSS. The facility accepts the wastewater discharge from Yuengling and surcharges Yuengling for the additional BOD/TSS on a mass base (Attachment 4). Inspector Thomson asked Mr. Yingling to describe the processes that contribute to the wastewater stream for the Yuengling Mill Creek site, the IU that was chosen for a site visit during the audit. Mr. Yingling provided Inspector Thomson with process diagrams and stated that the main brewing processes all contribute to a wastewater stream that is collected, monitored, and treated before being discharged to the facility. During the inspection, the EPA Inspection Team observed: the facility's treatment plant and Yuengling's pretreatment plant. The inspection observations were made pursuant to the requirements of the Permit. The observations from the inspection are described in detail below in the Observations section. Photographs were taken during the inspection by Inspector Thomson, Unique Project #: 3E21WN044A Page 4 of 7 GREATER POTTSVILLE AREA SEW AUTHSCHUYLKILL CNTY/Pottsville Main STP 8/26/2021 and are provided in Attachment 2, however, not all photographs taken during the inspection are included. III. Observations After the opening conference, Mr. Yingling met Inspector Thomson at the facility for a tour of the treatment process. They were joined by James Loux, GPASA Plant Superintendent, for the tour of the facility. First, Inspector Thomson was escorted to the effluent sampling point at the end of the disinfectant chamber (Photographs 1, 2). At Inspector Thomson's request, Mr. Loux described how both grab samples and composite samples would be collected from this point. While there was no observable thermometer in the composite sampler's refrigerator, the control panel on the composite sampler read 40.1 degrees Fahrenheit at the time of the inspection. Inspector Thomson was then escorted to the influent sampling point (Photographs 3, 4), and Mr. Loux described how sampling would occur, and the control panel for the composite sampler read 40.9 degrees Fahrenheit at the time of the inspection (Photograph 5). From this point, Inspector Thomson was escorted through each step of the treatment process, ending in the facility's lab. While in the lab, Inspector Thomson requested Mr. Loux describe typical sensor calibration operating procedures, and Mr. Loux stated that pH/DO sensors are calibrated daily with each use, and Inspector Thomson observed calibration logs and unexpired buffer containers confirming what Mr. Loux described (Photograph 6). After a tour of the facility, Inspector Thomson and Mr. Yingling met at the Yuengling Mill Creek site for a tour of the IU, where they were joined by Joe Spotts, the EH&S Manager for Yuengling. Inspector Thomson asked Mr. Spotts to describe the pretreatment process at the IU. Mr. Spotts began to lead Inspector Thomson on a tour of the process, while describing the process. Mr. Spotts stated that wastewater from the plant's brewing processes is collected and treated in a series of pretreatment tanks that are continuously monitored by a Skada system which includes magnetic sensors and a telephone enabled warning system. While wastewater production is reliant on production hours, wastewater is collected and monitored and will not be discharged to the facility until it is confirmed there are no exceedances for permitted parameters. Wastewater is collected from brewing processes and enters the first pump station leading to screens for grit removal. The wastewater stream then enters the second pump station and is pumped into a pH controlled conditioning tank for adjusting pH. From there, wastewater is pumped into an anaerobic digestor, which can be recirculated back to the pH adjustment tank if necessary. Sludge from the digestor is dewatered and hauled as waste by Disposal Management Services, Inc. After touring the pretreatment process, Inspector Thomson was led to the influent and effluent composite samplers (Photograph 7). A digital thermometer reading 35.8 degrees Fahrenheit was observed in the effluent composite sampler fridge (Photograph 8). Mr. Spotts then led Inspector Thomson to the effluent grab sample location (Photographs 9, 10) where he Unique Project #: 3E21WN044A Page 5 of 7 GREATER POTTSVILLE AREA SEW AUTHSCHUYLKILL CNTY/Pottsville Main STP 8/26/2021 then described how a typical discharge event would occur/would be sampled. This concluded the tour of the IU. IV. Records Review Inspector Thomson requested to review analytical reports and documents including control mechanisms, weekly sampling events and DMRs from the past 3 years. Inspector Thomson did not observe any exceedances. Inspector Thomson completed the Pretreatment Checklist with input from Mr. Yingling (Attachment #1). V. Closing Conference After the facility walk, the EPA Inspection Team met with the facility representatives for a closing conference. The EPA Inspection Team shared preliminary observations with the facility. The EPA Inspection Team reiterated to the facility representatives that all preliminary observations discussed were not compliance determinations. Any and all preliminary observations shared were subject to further investigation by EPA upon the additional review of records and documentation. Additional observations may be contained in this inspection report that were not identified at the time of the closing conference after EPA reviewed additional materials following the inspection. The inspection concluded at 3:00 PM. Unique Project #: 3E21WN044A Page 6 of 7 GREATER POTTSVILLE AREA SEW AUTHSCHUYLKILL CNTY/Pottsville Main STP 8/26/2021 VI. List of Attachments Attachment 1: Attachment 2: Attachment 3: Attachment 4: Attachment 5: Attachment 6: Pottsville Pretreatment Checklist Pottsville Photo Log Facility Permit Yuengling Surcharge Formula Yuengling Sampling Event Docs Yuengling Diagrams Unique Project #: 3E21WN044A Page 7 of 7