Document re9G5BkG8RpnQY0qBMvnzY90r

United States Environmental Protection Agency Region 4 Water Protection Division NPDES Permitting & Enforcement Branch 61 Forsyth Street, SW Atlanta, Georgia 30303 Compliance Evaluation Inspection Report Copiah County Industrial Park NPDES Permit No. MS0032921 Facility Address: US Highway 51 North Gallman, MS 39083 Inspection Date: 8/4/2021 Inspectors: Tristan Odekirk, Environmental Engineer, EPA Region 4 Richard Elliot, P.E., Environmental Engineer, EPA Region 4 Rusty Lyons, MDEQ Inspection Report Prepared by: Tristan Odekirk September 9, 2021 Project ID: CV-MS0032921-08-04-2021 Approval Sheet Title: Compliance Evaluation Inspection Copiah County Industrial Park Approving Official: JAIRO CASTILLO Digitally signed by JAIRO CASTILLO Date: 2021.10.04 15:17:48 -04'00' Jairo Castillo, P.E., Chief Wastewater Enforcement Section Water Enforcement Branch 10/04/2021 Date Enforcement Officer: Odekirk, Tristan Digitally signed by Odekirk, Tristan Date: 2021.10.05 14:29:52 -04'00' Tristan Odekirk, Environmental Engineer Wastewater Enforcement Section Water Enforcement Branch 10/05/2021 Date Page 2 of 17 Table of Contents I. INTRODUCTION..................................................................................................................................................4 II. INSPECTION PROCEDURES ............................................................................................................................4 III. FACILITY DESCRIPTION .................................................................................................................................4 IV. FIELD EVALUATION........................................................................................................................................5 1. Permit ..............................................................................................................................................................5 2. Records/Reports ..............................................................................................................................................5 3. Operation & Maintenance ...............................................................................................................................5 4. Sludge Handling..............................................................................................................................................6 5. Sampling/Laboratory ......................................................................................................................................6 6. Flow Measurement..........................................................................................................................................6 7. Effluent and Receiving Waters .......................................................................................................................6 V. RECOMMENDATIONS.......................................................................................................................................6 ATTACHMENTS ......................................................................................................................................................6 1. Photo Log ........................................................................................................................................................6 Page 3 of 17 I. INTRODUCTION On August 4, 2021, representatives of the United States Environmental Protection Agency, Region 4 and the Mississippi Department of Environmental Quality (MDEQ) conducted a Compliance Evaluation Inspection (CEI) on the Copiah County Industrial Park Wastewater Treatment Plant (WWTP), owned and operated by the Copiah County Board of Supervisors. MDEQ is authorized to administer the National Pollutant Discharge Elimination System (NPDES) program pursuant to Section 402 of the Clean Water Act (CWA), 33 U.S.C. 1342, and issues NPDES permit number MS0032921 to the facility and its sewer collection system. The overall objective of these CEIs was to evaluate the condition and operational performance the WWTP and offer compliance assistance as needed. Participants in the inspection included: Name Tristan Odekirk Richard Elliott Russel Lyons Jason Hilliard Position EPA, Region 4 Inspector EPA, Region 4 Inspector MDEQ, contractor Copiah County Industrial Park, Operator Phone Number 404-562-9295 404-562-8691 601-572-7783 II. INSPECTION PROCEDURES This facility was targeted for inspection because it has been in Significant Non-Compliance (SNC) with its effluent parameters for 11 of the last 12 quarters. The parameters of concern are Total Nitrogen, Total Suspended Solids (TSS), Ammonia, E. Coli and Biochemical Oxygen Demand (BOD5) . The overall objective of this CEI was to evaluate the cause(s) of these violations and to evaluate compliance with the other requirements of the NPDES Permit. Specific tasks included conducting an opening conference, interview the operators, reviewing facility records, and conducting a site visit of the WWTF and an closing conference. III. FACILITY DESCRIPTION The Copiah County Industrial Park is located in US Highway 51 North Gallman, MS, and treats industrial wastewater (process and non-process). The facility has a design capacity of 0.3 MGD with the following treatment units: a screening headworks, two aeration basins, and a chlorine contact chamber. Wastewater enters the facility into a screening headworks. A comminutor removes debris to drying beds. After dosing with lime, wastewater is pumped to an aerator. From one aerator, waste sludge is pumped to the second aerator which is used as storage. After secondary clarification water is disinfected in a contact chamber. Following chlorination, the water passes through a cascade aerator and exits the facility. Inspectors toured and observed all treatment units. Sludge is disposed at a landfill. The treatment plant serves three sites, including a poultry hatchery and a commercial food store. The effluent discharges into an unnamed tributary of Copiah Creek, a traditional navigable water of the U.S. Page 4 of 17 IV. FIELD EVALUATION 1. Permit The permit became effective February 5, 2019 and expires January 31, 2024. The facility has experienced difficulty with consistently meeting the permit effluent limits for several parameters. EPA verified the permit information regarding the name, description of the facility, location of the permitted outfall, and the location of the receiving waters. 2. Records/Reports Discharge Monitoring Reports (DMRs) and records were checked for agreement with NPDES selfmonitoring program requirements regarding sampling documentation, equipment calibration, and reporting of parameter concentrations and loadings. The self-monitoring records, including the chain of custody records, calibration sheets, laboratory bench sheets, and commercial laboratory results, were maintained for a minimum of three years. Spot checking of NPDES monitoring data elements was conducted and the data reviewed was found to be consistent and accurately reported. 3. Operation & Maintenance The facility is operated by a class 4 operator. The operator is present in the facility only 3 days a week. Headworks Water enters the facility through an old, now inoperable lift station (Photo 1) which, at the time of inspection, was filled with trash and debris. From the lift station the water is then screened (photo 2). EPA observed inoperable drying beds with plants overgrown (Photo 3), and water bypassed screening. Lime was injected to the water (Photo 4) before it was sent to a new pump station (Photo 5). Aeration tank 2 At the time of the inspection, only aeration tank 2 was operational (Photo 6). The aeration tank influent was dark reddish-brown color (Photo 7). The aeration mixer was missing paddles (Photo 8). The secondary clarifier influent had a significant amount of trash and vegetative growth (Photo 9). The clarifiers weirs were overgrown with algae. Maintenance equipment was strewn about the walkway (Photo 10). Aeration tank 1 Aeration tank 1 (Photo 11) is used as storage for waste sludge from aeration tank 2. When wasting is needed sludge is routed from aeration tank 2, through the new pump station, to aeration tank 1. Water in aeration tank 1 is brown and the tank has heavy vegetative growth (Photos 12 and 13). Water in the clarifier has significant algae growth (Photo 14). Chlorine contact chambers Chlorine contact chambers had significant solids and foam (Photos 15, 16, and 17). Using an on-site sludge judge the operator showed that sludge depth reached at least 2 feet in the chlorine contact chamber (Photos 18 and 19). SO is added to the effluent for dechlorination. Page 5 of 17 4. Sludge Handling Sludge is periodically pumped into aerator #1 for stabilization. When the aerator is full a vacuum truck is used to transport waste sludge to a landfill. 5. Sampling/Laboratory All NPDES required samples are collected by the operator. All laboratory analyses are conducted by a commercial laboratory: Waypoint Analytical 235 Highpoint Dr Ridgeland, MS 39157 601-957-2676 The commercial laboratory was not evaluated. 6. Flow Measurement Flow is measured by a 22-1/2 V-notch weir (Photos 20). No staff gauge was available onsite for water flow measurement. 7. Effluent and Receiving Waters Following the plant's V-notch weir, effluent goes through cascade aeration before being discharged through outfall 001. Dark reddish-brown coloration, foam, and solids were visible in the effluent chamber (Photo 21). V. RECOMMENDATIONS As described previously, the operation and maintenance of the plant need significant improvements. EPA recommendations are as follow: a. The headworks and the old lift station should be cleaned of debris and trash. b. The screening device in the headworks should be repaired as soon as possible. c. Plant growth on aeration tanks should be removed. d. Weirs on aeration tanks should be cleaned. e. Sludge should be removed from the chlorine contact basin. f. Install measurement gauge on effluent weir for accurate flow measurement and calibrate annually. ATTACHMENTS 1. Photographic Log Page 6 of 17 Photographic Log Photo 1: Old Influent lift station. Inoperable and filled with trash and debris. Photo 2: Facility headworks. Area is overgrown and cleaning mechanism inoperable. Page 7 of 17 Photo 3 :Overgrown drying beds. Photo 4: Lime dosing following headworks. Page 8 of 17 Photo 5: New pump station. Photo 6: Aeration tank 2 from new pump station. Page 9 of 17 Photo 7: Influent pipe from pump station to aeration tank 2. Photo 8: Aerator in aeration tank 2. Return sludge pipe. Page 10 of 17 Photo 9: Suspended trash and vegetative growth in aeration tank 2. Photo 10: Water hose laid out on aeration tank 2 walkway. Page 11 of 17 Photo 11: Aeration tank 1 and manholes leading to chlorine contact chambers. Photo 12: Heavy vegetative growth and water coloration in aeration tank 1. Page 12 of 17 Photo 13: Vegetative growth and aerator in aeration tank 1. Photo 14: Vegetative and algae growth in aeration tank 1. Page 13 of 17 Photo 15:Chlorine contact chamber 1. Photo 16: Foam and solids after chlorine contact chamber 1. Page 14 of 17 Photo 17: Solids after chlorine contact chamber 2. Photo 18: Sludge judge from chlorine contact chamber 1. Page 15 of 17 Photo 19: Sludge judge from chlorine contact chamber 2. Photo 20: Effluent v-notch weir. Page 16 of 17 Photo 20: Effluent v-notch weir. Solids visible in effluent. END OF REPORT Page 17 of 17