Document qkV5GR6K0VXDpp2rMdN6Myj7R
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: Facility Name: Permittee(s): Facility Operator: Permittee Address: Facility Address: Facility Latitude: Facility Longitude: County/Parish: Permit No: NAICS Code: SIC: Unique Project #:
Clean Water Act Compliance Inspection Report 11/29/2022 National Pollutant Discharge Elimination System (NPDES) Wastewater Treatment Plant Naval Support Facility Indian Head (NSFIH) Naval Support Facility Indian Head (NSFIH) Naval Support Facility Indian Head (NSFIH) 3972 Ward Road, Suite 101, Indian Head, Maryland 20640-5157 3972 Ward Road, Suite 101, Indian Head, Maryland 20640-5157 38.596648 -77.179034 Charles County MD0020885 221320 4952 3E23WN015A
Facility Representative(s):
Point of Contact
Diana Rose
Email: diana.l.rose.civ@us.navy.mil
EPA Inspectors:
Kaitlin McLaughlin - EPA Region III
Phone: (215) 814-2393 Email: McLaughlin.Kaitlin@epa.gov
Michael Greenwald - EPA Region III
Phone: (215) 814-2398 Email: Greenwald.Michael@epa.gov
State/Local Inspectors (see report body for list of additional inspectors):
Greg Kolarik
Email: greg.kolarik@maryland.gov
Report Preparer Signature/Date
Supervisor Signature/Date
Kaitlin McLaughlin, Enforcement Officer NPDES Enforcement Section (3ED32)
Digitally signed by MARK
MARK ZOLANDZ ZOLANDZ
Date: 2023.02.03 16:57:52 -05'00'
Mark Zolandz, Section Chief NPDES Enforcement Section (3ED32)
2/2/2023 Date
2/3/2023
Date
Unique Project #: 3E23WN015A
Section
Naval Support Facility Indian Head (NSFIH) - Wastewater Treatment Plant 11/29/2022
Table of Contents
Page
I Introduction............................................................................ 3 A Inspection Opening Conference...................................................................... 3 B Weather and Precipitation Conditions............................................................. 3
II Facility Activity............................................................................................... 4 III Observations.................................................................................................... 4 IV Records Review............................................................................................... 6 V Closing Conference......................................................................................... 7 VI List of Attachments.......................................................................................... 7
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Naval Support Facility Indian Head (NSFIH) - Wastewater Treatment Plant 11/29/2022
I. Introduction
On November 29, 2022, an inspection team composed of staff from the U.S. Environmental Protection Agency ("EPA") Region III (hereinafter, "EPA Inspection Team") conducted a wastewater treatment plant ("WWTP") inspection of the Naval Support Facility Indian Head (NSFIH). 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. MD0020885 (hereinafter, the "Permit") and applicable State and Federal regulations.
A. Inspection Opening Conference
The EPA Inspection Team arrived at the facility at approximately 8:30 AM. Representatives from the Maryland Department of the Environment (MDE) were in attendance. The following inspectors and representatives were present for the inspection:
Name
Kaitlin McLaughlin Michael Greenwald
Linsey De La Rosa Hayden Dermanelian
William Fabey Chris Goddard Tara Meadows Kenneth Robitaille
Diana Rose Victoria Waranoski
Greg Kolarik
Table 1: Inspection Attendee List
Affiliation
Telephone
Email
EPA Region III Inspectors
EPA Region III 215-814-2393
McLaughlin.Kaitlin@epa.gov
EPA Region III 215-814-2398
Greenwald.Michael@epa.gov
Facility Representatives
NSFIH EV
956-975-7415
linsey.delarose.civ@us.navy.mil
NSWC
703-587-1681 hayden.dermanelian.civ@us.navy.mil
NSFIH EV
301-997-3776
william.b.fabey.civ@us.navy.mil
NSFIH EV
240-298-4376 christopher.j.goddard2.civ@us.navy.mil
NSFIH EV
202-718-0665
tara.l.meadows2.civ@us.navy.mil
NSFIH EV
202-718-0682 kenneth.r.robitaille.civ@us.navy.mil
NSFIH EV
301-744-2267
diana.l.rose.civ@us.navy.mil
NAVFAC EV 202-685-8056 victoria.m.waranoski.civ@us.nvy.mil
State or County Representatives
MDE
443-532-9020
greg.kolarik@maryland.gov
Kaitlin McLaughlin and Michael Greenwald displayed their credentials to the facility representatives 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 Attachment 1.
B. Weather and Precipitation Conditions
The closest National Oceanic and Atmospheric Administration (NOAA) National Weather Service precipitation data for the date of the inspection and 5 days prior are provided in Table 2 below.
Table 2. Precipitation Data
Station Name
Date
ALEXANDRIA 6.6 WNW, VA US US1VAFX0081 ALEXANDRIA 6.6 WNW, VA US US1VAFX0081
11/24/22 11/25/22
Precipitation Amount (inches)1 0.00
0.11
1 Source: NOAA National Climatic Data Center (http://www.ncdc.noaa.gov/).
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Naval Support Facility Indian Head (NSFIH) - Wastewater Treatment Plant 11/29/2022
ALEXANDRIA 6.6 WNW, VA US US1VAFX0081 ALEXANDRIA 6.6 WNW, VA US US1VAFX0081 ALEXANDRIA 6.6 WNW, VA US US1VAFX0081 ALEXANDRIA 6.6 WNW, VA US US1VAFX0081 ALEXANDRIA 6.6 WNW, VA US US1VAFX0081 ALEXANDRIA 6.6 WNW, VA US US1VAFX0081
11/26/22
0.04
11/27/22
0.00
11/28/22
0.19
11/29/22
0.00
11/30/22
0.21
12/1/22
0.08
II. Facility Activity
NSFIH is a naval base which consists of various industrial activities including explosive and propellant manufacturing, research, development, assembly, and testing. The facility discharges industrial wastewater, stormwater, and various process wastewaters.
The facility implements a wastewater program and is regulated under the Permit, which became effective on September 1, 2021 and expires on August 31, 2026. The Permit requires NSFIH to submit several special condition report submittals. Those submittals include: Effluent Biomonitoring Study Plan and Toxic Chemical Testing Plan, Effluent Biomonitoring Study Report, Effluent Toxic Chemical Testing Report, Wastewater Capacity Management Plan, Flow Capacity Report, and Per-and Polyflourinated Alkyl Substances Plan and Report.
The WWTP is a sequencing batch reactor (SBR) plant which has a design flow of 0.5 million gallons per day (MGD) and an average flow of 0.36 MGD. The WWTP discharges through outfall 001A to the Potomac River which is designated as Use II (non-shellfish harvesting) water and is protected for estuarine and marine aquatic life.
The inspection included discussions with wastewater staff, file reviews, and field visits. The EPA Inspection Team conducted additional on-site interviews and reviewed a portion of the facility's records. Additional records were reviewed offsite.
Observations based on both the offsite compliance review and the field visits are documented in the sections below.
III. Observations
The inspection began on Tuesday, November 29, 2022 at approximately 10:30 AM in Building 289 with a records review and interview questions. The inspection observations below are made pursuant to the requirements of the Permit. Photographs were taken during the inspection by a facility representative Linsey De La Rosa and are provided in Attachment 2. The Photograph Log referenced throughout this inspection report is designated as Controlled Unclassified Information.
The EPA Inspection Team conducted a walkthrough of the WWTP with facility representatives, starting at approximately 12:30 PM. The time stamps on all photographs dated 11/29/2022 are an hour delayed. The walkthrough started at the influent of the WWTP, where the EPA Inspection Team observed the rock trap (Photograph Log, Page 2), the diversion valve (Photograph Log, Page 3), 125,000 gallon diversion tank (Photograph Log, Page 4 and Page 5),
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Naval Support Facility Indian Head (NSFIH) - Wastewater Treatment Plant 11/29/2022
and influent channel (Photograph Log, Page 6). At the influent channel there is an automatic influent composite sampler (Photograph Log, Page 34) and a grit removal system.
Observation 1.
At the time of the inspection, the EPA Inspection Team observed the grit chamber auger was offline. The area where the auger had been attached appeared to be rusted (Photograph Log, Page 7 and Page 8). Facility representatives had installed a temporary hose to remove grit and stated that a replacement auger has been ordered. The removed auger was located by the rock trap (Photograph Log, Page 10).
From the influent flow channel, wastewater is pumped to a splitter box. Before flow is split, there is an influent flow meter (Photograph Log, Pages 11-13) and pH meter (Photograph Log, Page 15). Flow is then split and continues through the plant through two parallel SBRs (Photograph Log, Page 16). Flow then moves through denitrification filters (Photograph Log, Page 17 and 18) and UV treatment (Photograph Log, Page 19 and Page 20).
The EPA Inspection Team then moved to the effluent channel. In the effluent channel, there is a flow meter (Photograph Log, Page 21), pH meter (Photograph Log, Page 22), and dissolved oxygen (DO) meter (Photograph Log, Page 23).
Observation 2.
At the time of the inspection, the pH meter was off and the DO meter display screen indicated that the sensor was missing. Facility representatives stated that pH and DO are manually sampled two times per day.
Flow then moves over the effluent weir (Photograph Log, Page 24) and samples are automatically collected for the 24 hour composite sampler (Photograph Log, Page 25).
From the effluent channel, the EPA Inspection team moved to the sludge thickener (Photograph Log, Page 28), sludge pumphouse (Photograph Log, Page 29), and sludge holding tanks (Photograph Log, Pages 30, 31, and 33). The plant hauls thickened sludge to the Mattawoman water reclamation plant in Charles County. NSFIH has a 3,500 gallon capacity sewage truck (Photograph Log, Page 32). Facility representatives stated that sludge is hauled approximately 10 times per month.
The EPA Inspection Team then observed the on-site lab and reviewed documentation stored in the lab. In addition to the on-site lab, NSFIH utilizes several additional labs that are contracted for lab chemistry, microbacterial, biomonitoring, PCBs, and PFAS.
The facility representatives stated that there are five full-time operators on-site. Operators are onsite seven days a week from the hours of 7 AM to 7 PM.
NSFIH has several pump stations and lift stations that transport wastewater to the WWTP. The EPA Inspection Team observed pump station 7 (Photograph, Pages 36-38).
Observation 3. At the time of the inspection, there were five sanitary sewage overflows (SSOs) in 2022. More details are provided below in Table 3.
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Naval Support Facility Indian Head (NSFIH) - Wastewater Treatment Plant 11/29/2022
Date January 4 & 5, 2022
Location Lift Stations 1, 5, 10, and 13
March 18, 2022
Lift Station 5
April 11, 2022 Lift Station 10
August 1, 2022
Lift Station 5
November 16, 2022
B3153 at the Sewage Plant
Table 3: SSO List
Volume
Description
~11,600 gallons A heavy snowfall caused power outages lasting several
days, 4 lift stations overflowed during the power
outages including 3 with emergency generators that
failed.
~200 gallons
A flexible hose used temporarily to bypass the lift
station while the station is under repair split. The hose
was repaired.
~300 gallons
A failed circuit breaker cut off power to the lift
station's control panel. The power failure alarm will be
moved to ensure it will indicate if there is power to the
control panel.
~250 gallons
An estimated 250 gallons of dilute raw sewage
overflowed and soaked into the ground leading into a
ditch due to a pump mechanical failure. The water
consisted mostly of industrial cooling water with boiler
blowdown, reverse osmosis reject water and raw
sewage. The overflow was discovered at 2:15 pm and
was stopped by 3:00 pm by turning on a second pump.
~2000 gallons
An estimated 2000 gallons of partially treated sewage
overflowed from building 3153. Two pumps failed
causing the overflow. The actual cause of the pump
failure is under investigation. The pump failure
allowed the below grade portion of the building to fill
with wastewater. The wastewater flowed out of the
building when operators reported to work and opened
the door to the building at 6:30 am. The overflow
stopped after using the pumper truck and a portable
sump pump to transfer wastewater from the building to
the headworks of the sewage plant. The portable sump
pump will remain in service at the site until the main
pumps are back in service. Lime was spread in the area
of the spill.
IV. Records Review
EPA requested and received copies of the following documents:
Current WWTP site map Pump Station Inspection Sheets Operator licenses 3 years of SSOs Lab information Permit Special Condition Submittals WWTP Process Flow Diagram
Records pertaining to the inspection report are attached, with additional records being kept on file.
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Naval Support Facility Indian Head (NSFIH) - Wastewater Treatment Plant 11/29/2022
V. Closing Conference
After the facility walkthrough, the EPA Inspection Team met with the site representatives for a closing conference. The EPA Inspection Team shared preliminary observations with the site representatives. The EPA Inspection Team reiterated to the site 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 approximately 2:30 PM.
The WWTP inspection was the first inspection of a three-part CWA inspection of NSFIH. The third and final inspection of NSFIH was concluded on December 1, 2022. At the conclusion of the third inspection, the EPA Inspection Team met with site representatives for a comprehensive closing conference. The EPA Inspection Team shared preliminary observations with the site representatives and reiterated the above information.
The final closing conference concluded at approximately 3:00 PM on December 1, 2022.
VI. List of Attachments
Attachment 1. Attachment 2. Attachment 3.
NPDES Permit Photograph Log SWPPP
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