Document pBY0Qz5vp90DN3n6yMa3JZZGE

ELECTRONIC MAIL CONFIRMATION OF RECEIPT EMAIL REQUESTED Wes Byne Utilities Director City of Augusta 452 Walker Street, Suite 200 Augusta, Georgia 30901 wbyne@augustaga.gov Dear Wes Byne: The U.S. Environmental Protection Agency, Region 4 conducted a Compliance Evaluation Inspection (CEI) on the City of Augusta's James B. Messerly Water Pollution Control Plant (WPCP) on July 9, 2024. The objective of the inspection was to assess the City of Augusta's (Augusta) compliance with the Clean Water Act and the National Pollutant Discharge Elimination System permit, and to evaluate the general condition of the WPCP. The inspection results have been summarized in the enclosed CEI Report. The EPA appreciates Augusta's and ESG Operations Incorporated cooperation and courtesy during the inspection. If you have specific questions about the inspection report, please contact Mr. Andrew Gunderson at Gunderson.Andrew@EPA.gov. Please verify receipt of this letter and report by emailing Mr. Gunderson at the email address provided. Sincerely, JAIRO CASTILLO Digitally signed by JAIRO CASTILLO Date: 2024.08.20 13:19:28 -04'00' Jairo Castillo, P.E., Chief Wastewater Enforcement Section Water Enforcement Branch ENCLOSURES City of Augusta James B. Messerly WPCP Report cc: Johanna D. Smith P.E. Program Manager Georgia Department of Natural Resources, Environmental Protection Division Johanna.Smith@dnr.ga.gov Eddy Basilio Environmental Compliance Specialist III Georgia Department of Natural Resources, Environmental Protection Division Edwina.Basilio@dnr.ga.gov Percy Nolan Project Manager ESG Operations Incorporated pnolan@esginc.net Page 2 of 16 United States Environmental Protection Agency Region 4 Enforcement and Compliance Assurance Division Water Enforcement Branch 61 Forsyth Street, SW Atlanta, Georgia 30303 Compliance Evaluation Inspection Report City of Augusta's James B. Messerly WPCP 1820 Barnard Parkway, Augusta, GA 30906 NPDES Permit Number: GA0037621 Project No. CV-GA0037621-070924 Date of Inspection: July 9, 2024 Inspectors: Andrew Gunderson, EPA Region 4 William Joyner, EPA Region 4 Edwina Basilio, GA EPD Inspection Report Prepared by: Andrew Gunderson Title and Approval Sheet Title: City of Augusta's James B. Messerly WPCP Compliance Evaluation Inspection Report Project No. CV-GA0037621-070924 Approving Official: JAIRO Digitally signed by JAIRO CASTILLO CASTILLO Date: 2024.08.20 13:19:55 -04'00' _____________________________________ Jairo Castillo, P.E., Chief Wastewater Enforcement Section Water Enforcement Branch Enforcement Officer: ANDREW Digitally signed by ANDREW GUNDERSON G__U__N__D___E_R__S_O___N___-_04_'_00_'______________ Date: 2024.08.20 12:58:24 Andrew Gunderson, Environmental Scientist Wastewater Enforcement Section Water Enforcement Branch Page ii of 16 COMPLIANCE EVALUATION INSPECTION REPORT City of Augusta's James B. Messerly WPCP Compliance Evaluation Inspection Report Project # CV-GA0037621-070924 Table of Contents 1. Introduction................................................................................................................................... 1 2. Participants................................................................................................................................... 1 3. Facility Description ....................................................................................................................... 1 4. Inspection Procedures.................................................................................................................. 4 5. Findings & Conclusions................................................................................................................. 4 A. Permit Review......................................................................................................................... 4 B. Records and Reports................................................................................................................. 4 C. Flow Measurement................................................................................................................... 5 D. Sampling/Laboratory ............................................................................................................... 5 E. Site Visit (Operation and Maintenance) ...................................................................................... 6 F. Sludge Handling ......................................................................................................................... 6 G. Effluent/Receiving Water ......................................................................................................... 7 6. Discussion ..................................................................................................................................... 7 COMPLIANCE EVALUATION INSPECTION REPORT City of Augusta's James B. Messerly WPCP Compliance Evaluation Inspection Report Project # CV-GA0037621-070924 1. Introduction On July 9, 2024, representatives of the United States Environmental Protection Agency, Region 4 and the Georgia Department of Natural Resources, Environmental Protection Division (GA EPD) conducted a Compliance Evaluation Inspection (CEI) on the James B. Messerly Water Pollution Control Plant (WPCP), owned and operated by the City of Augusta, Georgia (Augusta/The City). The inspection was conducted under the authority of Section 308 of the Clean Water Act (CWA), as amended. This report provides a summary of the inspection. 2. Participants Name Andrew Gunderson William Joyner Edwina Basilio Ricky Adams Joseph Molock Percy Nolan Matt Erickson Organization EPA Region 4 (Lead) EPA Region 4 GA EPD ESG Operations (Project Manager) ESG Operations (Operations Manager) ESG Operations (Plant Manager/Regional Manager) ESG Operations (Lab/IPP Supervisor) Contact Information Gunderson.Andrew@epa.gov Joyner.William@epa.gov Edwina.Basilio@dnr.ga.gov Not supplied Not supplied percy.nolan@inframark.com merickson@esginc.net 3. Facility Description The City of Augusta's James B. Messerly Plant is an activated sludge wastewater treatment plant that is combined with a constructed wetland area. The WPCP consists of an influent pump station with two JWC fine screens, grit/grease removal system, equalization basin, 8 primary clarifiers (one operating at the time of inspection), secondary aeration with anoxic zones, 4 secondary clarifiers, return activated sludge pumps, chlorine disinfection, 6 aerobic sludge digesters, sludge belt filter presses, and constructed wetland with 12 cells. Facility personnel stated that dechlorination takes place within the constructed wetlands via evaporation. No chemical dechlorination is utilized onsite. The grit/grease removal system was observed offline during the inspection due to the pumps being nonoperational. A bypass pump has been placed within this section of the facility to divert high flows to the constructed wetlands. The facility is located at 1820 Doug Barnard Parkway, Augusta GA, 30906. The facility is currently permitted under NPDES permit number GA0037621 to discharge 46.1 million gallons per day (MGD) from outfall 001 to Butler Creek. Butler Creek is located within the Savannah River Basin. The facility was constructed in 1968 and is owned by the City of Augusta, with the City contracting out facility, and laboratory operations to ESG Operations, Inc. ESG Operations, Inc. Page 1 of 16 has been contracted at the facility since 2010. ESG Operations also manages the pre-treatment program for the City. Adjacent to the facility's Doug Barnard Parkway location is Phinizy Swamp Nature Park, which houses the constructed wetlands for the facility. These wetlands are open to the public and consist of 12 wetland cells over a 30-acre area. A final aeration pond is located at the end of the wetlands prior to discharge to Butler Creek (photo #10). The facility's composite sampler is located at a dock over the outfall of the creek. Primary clarifiers Anoxic Zone/Aeration Secondary clarifiers EQ basins Primary clarifiers Influent receiving Septic hauler receiving Machinal Bar Screens Primary Grit Removal Bypass pump. Chlorine Contact Chamber and Discharge to wetlands Secondary clarifiers Facility office and laboratory Anoxic Zone/Aeration Digesters Sludge dewatering Aeration Figure 1: Aerial View of the James B. Messerly Water Pollution Control Plant Page 2 of 16 COMPLIANCE EVALUATION INSPECTION REPORT City of Augusta's James B. Messerly WPCP Compliance Evaluation Inspection Report Project # CV-GA0037621-070924 Controlled access to wastewater treatment facility Wetlands equalization basin Wastewater treatment operations Public access to wetlands treatment area Final aeration pond Effluent composite sampler Outfall 001 Figure 2: Aerial View of the James B. Messerly Water Pollution Control Plant's wetland treatment Page 3 of 16 The facility accepts septic system waste as well as grease hauled from area restaurants. Septic system waste is directly discharge into a containment area located near the headworks (photo #3). Three main lines enter the facility at the headworks. An 84-inch line from the downtown Augusta area, an additional line from a local industrial complex, and a line from the Spirit Creek Wastewater Treatment Plant. The Spirit Creek facility is located at 1101 Bennock Mill Rd, Augusta, GA 30906, and operates under a Georgia NPDES permit GA0047147 with no discharge. All flow from the Spirit Creek facility is treated within the James B. Messerly Plant. The facility's current wastewater plant operational staff are as follows: Five - Georgia Wastewater Treatment Class 1 Operator Two - Georgia Wastewater Treatment Class 2 Operators Three - Georgia Wastewater Treatment Class 3 Operators Five - Laboratory Technicians 4. Inspection Procedures. The overall objective of this CEI was to evaluate the condition and operational performance of the WPCP and Augusta's self-monitoring program and to offer compliance assistance as needed. Specific tasks included conducting an opening conference, interviewing WPCP staff, reviewing WPCP laboratory records, conducting a site visit throughout the existing WPCP, and a closing conference. 5. Findings & Conclusions A. Permit Review City of Augusta's NPDES permit for the WPCP has an effective date of June 1, 2019, and expired on May 31, 2024. The NPDES permit lists and describes the outfall as Outfall 001 to Butler Creek. The NPDES permit contains Effluent Limitations and Monitoring Requirements table for Outfall 001 at the WPCP's current capacity of 46.1 MGD. The facility was operating under the administrative continued permit until a new permit is issued by the State of Georgia. B. Records and Reports The EPA's Enforcement Compliance History Online (ECHO) shows that the STP was in NonCompliance (NC) or Significant Non-Compliance (SNC) for effluent limit exceedances as listed: Flow - exceeded February 2023 Disolved Oxygen (DO) - exceeded April 2022, SNC for Nitrogen Ammonia Total - exceeded July 2021, April 2022, January 2023, and February 2023. SNC for Carbonaceous Biochemical Oxygen Demand 5-day (CBOD5) - exceeded April 2022, and July 2022. Page 4 of 16 COMPLIANCE EVALUATION INSPECTION REPORT City of Augusta's James B. Messerly WPCP Compliance Evaluation Inspection Report Project # CV-GA0037621-070924 Recent Discharge Monitoring Reports (DMRs) were reviewed onsite. All reviewed paperwork, including the analytical results for the May 2024 Discharge Monitoring Report (DMR) met permit required retention times and was well organized. C. Flow Measurement Upon entry to the facility's online operations system, the plant's influent flow reading was 35.5 mgd and the effluent flow showed 0 mgd. System programmers were onsite attempting to update the digital operation system. The influent flow and effluent flow meters appeared in good condition. The effluent flow meter and was displaying a flow rate of 40.3 MGD at 12:00pm (photo #8). The City of Augusta contracts with Macktec Incorporated for calibration of influent and effluent ultrasonic flow meters. The effluent flow meter was noted to have a sticker which had faded and illegible calibration date. The City subsequently supplied documentation showing a recent effluent flow meter calibration had been completed by Macktec Incorporated on 6/3/24. The facility appears to be heavily influenced by inflow and infiltration as overflows at the facility's headworks (photo #1) have been reported. In 2023 the following overflows at the facility's headworks were reported to the State of Georgia: June 23, 2023 July 10, 2023 August 30, 2023 December 17, 2023 538,589 gallons 69,453 gallons 6,663,720 gallons 313,005 gallons No influent overflows at the facility's headworks have been reported to GA EPD for 2024. Additionally, a bypass pump has been installed within the primary grit removal area to bypass high flows directly to the constructed wetlands area (photo #11). The City of Augusta manages collect system maintenance separately from the ESG Operations, Inc. contracted services. D. Sampling/Laboratory The laboratory at this facility analyzes samples for the following parameters: Flow, pH, Carbonaceous Biochemical Oxygen Demand 5-day (CBOD5), Dissolved Oxygen (DO), Total Suspended Solids (TSS), Chlorine Total Residual (TCR), Ammonia Total, and Fecal Coliform Bacteria. All Permit parameters are sampled at outfall 001, at the end of the constructed wetlands, except Fecal Coliform. Fecal Coliform samples are collected prior to the facility's discharge into the constructed wetlands. The facility contracts with CSRA Analytical Laboratories Inc. to analyze Total Nitrogen, Total Phosphorus, and metals. The facility also contracts with Eurofins Laboratory for additional services when needed. The following observations were made in the laboratory: Page 5 of 16  Two containers of 10 pH buffers were noted to be out of date. These buffers were removed from storage and disposed of during the inspection (photos #16 & #17). Composite sampler was operational and set up to sample (photo #9). Effluent composite sampler showed temperature within acceptable range. Chlorine buffers were noted to be in date and were appropriate for wastewater sampling usage. All equipment and glassware appeared clean. Laboratory bench sheets and calibration records appeared appropriately documented and orderly. Operators log appeared detailed and orderly. The following laboratory/sampling equipment was observed: o YSI Pro 20i o EcoSense pH100A o Hach AS950 Composite Sampler E. Site Visit (Operation and Maintenance) A WPCP site visit started at the headworks and ended within the constructed wetlands area. Based on the configuration of the site the treatment areas were reviewed in a nonlinear manner. The following components were observed: Both JWC fine screens and mechanical bar screens appears clean and operating as designed (photo #2). Anoxic zones showed vegetative growth around mixers (photo #4). The chlorine building appeared clean and well maintained. High flows into the facility resulted in an 18-inch 14mgd pump to be installed into the primary grit removal area. During high flows This pump sends process water directly into the constructed wetlands, bypassing most mechanical treatment of the facility. The pump is triggered when the plant flow reaches approximately 70mgd (photo #11). Primary grit removal was non-operational (photo #12). Staff gauge appeared clean. Potable water leak was noted under slab of machinal building (photo #13). Only one primary clarifier appeared operational. The remaining 7 clarifiers were nonoperational and appeared to have broken chains and bent paddles. Significate sludge accumulation and plant growth was noted within the non-operational clarifiers (photos #6 & #7). One septic truck was observed discharging into system. Solids from clarifier maintenance were noted to be left outside of containment area (photo #5). The sludge digesters had failing brick walls round the structures (photo #15). The roof of Digester #5 had caved inward (Photo #14). F. Sludge Handling ESG Operations mechanically dewater sludge onsite and contacts with Big Dog Disposal to haul the sludge to the Richmond County Landfill. In 2023 the facility reported 5,001.43 tons of Page 6 of 16 COMPLIANCE EVALUATION INSPECTION REPORT City of Augusta's James B. Messerly WPCP Compliance Evaluation Inspection Report Project # CV-GA0037621-070924 biosolids being removed and transported from the facility. All equipment within the sludge press area appeared operational and the space was maintained clean to prevent odor and vectors. G. Effluent/Receiving Water The effluent from Outfall 001 appeared to be clear and void of solids. The receiving waterbody (Butler Creek) was accessible via a dock positioned at the end of the constructed wetlands. 6. Discussion The City of Augusta's WPCP is operations is stressed from Inflow and Infiltration resulting in exceedances in the permitted design of 46.1 MGD. This stress is evident from the installation of the bypass pump with the primary grit removal area, overflow at the facility headworks, and seven non-operational clarifiers due to major mechanical damage. Additionally, the digester units show signs of structural deterioration with large areas of missing brick and collapsed roof structure. END OF REPORT Page 7 of 16 Appendix A: Photographic Log Photo 1: Headworks of facility Photo 2: Mechanical bar screens. Page 8 of 16 Photographs City of Augusta's James B. Messerly WPCP Compliance Evaluation Inspection Report Project # CV-GA0037621-070924 Photo 3: Septic hauler receiving area. Photo 4: Vegetation growth around mixer in Anoxic zones. Page 9 of 16 Photo 5: Solids from clarifier maintenance outside of containment. Photo 6: Seven non-operational clarifiers were observed with solids buildup. Page 10 of 16 Photographs City of Augusta's James B. Messerly WPCP Compliance Evaluation Inspection Report Project # CV-GA0037621-070924 Photo 7: Damaged chain and paddle on primary clarifier. Photo 8: Effluent flowmeter Page 11 of 16 Photo 9: Outfall 001 dock with sign and sampler. Photo 10: Constructed wetlands final aeration basin. Page 12 of 16 Photographs City of Augusta's James B. Messerly WPCP Compliance Evaluation Inspection Report Project # CV-GA0037621-070924 Photo 11: Bypass Pump at primary grit removal to divert flow to constructed wetlands. Photo 12: Primary Grit removal was offline at the time of the inspection. Page 13 of 16 Photo 13: Location of drinking water leak under concrete slap Photo 14: Digester #5 roof collapsed. Page 14 of 16 Photographs City of Augusta's James B. Messerly WPCP Compliance Evaluation Inspection Report Project # CV-GA0037621-070924 Photo 15: Digesters structures missing bricks. Photo 16: Expired pH buffer, expired on 12/2022. Page 15 of 16 Photo 17: Expired pH buffer, expired on 09/2022. Page 16 of 16