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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION III Four Penn Center 1600 John F. Kennedy Boulevard Philadelphia, Pennsylvania 19103-2029 Report Title: Inspection Date(s): Regulatory Program(s): Type of Activity: Facility Name: Permittee(s): Facility Operator: Facility Address: Lat/Long: County/Parish: Permit Number: NAICS & SIC Codes: Unique Project #: Clean Water Act Compliance Inspection Report 07/14/2022 National Pollutant Discharge Elimination System (NPDES) Pretreatment - Publicly Owned Treatment Works Inspection Hanover Borough Wastewater Treatment Plant (WWTP) Hanover Borough Hanover Borough 44 Frederick Street, Hanover, PA 17331 39.799953/-76.98407 York PA0026875 221320/4952 3E22WN009A Facility Representative(s): Alan Redding - Lead Operator Phone: (717) 637-4112 Email: EPA Inspectors: Aaron Thomson (3ED13) Phone: 215-814-2116 Email: Point of Contact aredding@hanoverboroughpa.gov Thomson.aaron@epa.gov Report Preparer Signature/Date Supervisor Signature/Date AARON THOMSON Digitally signed by AARON THOMSON Date: 2022.09.09 10:17:10 -04'00' Aaron Thomson (3ED13) Date Four Penn Center - Philadelphia, PA 19103 Digitally signed by ZELMA ZELMA MALDONADO MALDONADO Date: 2022.09.09 11:44:13 -04'00' Zelma Maldonado, Acting Chief, ES Section Date Four Penn Center - Philadelphia, PA 19103 Pretreatment - Publicly Owned Treatment Works Inspection Hanover Borough Hanover Borough Wastewater Treatment Plant (WWTP) 07/14/2022 Table of Contents I. INTRODUCTION ..............................................................................................................................................................................3 A. INSPECTION OPENING CONFERENCE ..................................................................................................................................................... 3 II. FACILITY ACTIVITY/WALKTHROUGH .............................................................................................................................................3 II. OBSERVATIONS .............................................................................................................................................................................4 III. RECORDS REVIEW.......................................................................................................................................................................20 IV. CLOSING CONFERENCE ...............................................................................................................................................................20 V. LIST OF ATTACHMENTS ...............................................................................................................................................................20 Unique Project #: 3E22WN009A Page 2 of 21 I. Introduction Pretreatment - Publicly Owned Treatment Works Inspection Hanover Borough Hanover Borough Wastewater Treatment Plant (WWTP) 07/14/2022 On July 14, 2022, staff from the U.S. Environmental Protection Agency ("EPA") Region III (hereinafter, "EPA Inspection Team") conducted an on-site inspection of the Hanover Borough publicly owned treatment works (POTW) facility's (hereinafter, "the facility") pretreatment program. The purpose of the inspection was to observe the program's compliance with the Clean Water Act (CWA) and the applicable Federal Pretreatment Regulations. The facility's National Pollutant Discharge Elimination System (NPDES) permit (ID: PA0026875) has been included as Attachment 1. The inspection was conducted as part of a routine periodic inspection. A. Inspection Opening Conference EPA Inspector Aaron Thomson (Inspector Thomson) began the inspection of the facility at est. 11:00 AM. Inspector met with the following facility representatives: Name Aaron Thomson Alan Redding Tony Thomas Table 1: Inspection Attendee List Affiliation Telephone Email EPA Region III Inspectors and Contractors EPA 215-814-2116 Thomson.aaron@epa.gov Site/Facility Representatives Hanover Borough (717) 637-4112 aredding@hanoverboroughpa.gov Hanover Borough (717) 637-4112 tthomas@hanoverboroughpa.gov Inspector Thomson displayed their credentials to Mr. Redding at the outset of the inspection, and explained the purpose of the inspection was to observe compliance with the Federal Pretreatment Regulations. The EPA Inspector informed Mr. Redding that any information that the Facility deemed to be confidential business information ("CBI") should be identified to EPA during the inspection and it would be handled as CBI according to EPA's CBI procedures. Photographs were taken during the inspection by Inspector Thomson, and are provided in Attachment 2. Not all photographs taken during the inspection were included in this report. II. Facility Activity/Walkthrough The facility is a wastewater treatment plant, owned and operated by the Borough of Hanover, which has a hydraulic capacity of 7.28 million gallons per day and serves most of the Borough of Hanover, all of the Borough of McSherrystown and all of Conewago Township. According to Mr. Redding, the facility previously had a pretreatment officer, however the current Superintendent, Tim Mayer, is currently also acting as the pretreatment coordinator. Mr. Redding stated the Borough of Hanover is in the process of potentially hiring a new pretreatment coordinator. Currently, operators (such as Mr. Redding) conduct inspections of their permitted industrial users (IUs). The facility is operated seven days a week, with shifts from 7:00 am to 3:00 pm, manned by a crew of eleven. The facility utilizes a Scada alarm system, that operates and monitors continuously, to alert the crew should some failure occur during the periods that the plant is not manned. All plant processes are monitored by plant personnel. Samples of the flow are taken at each step in the plant. Process control analyses are done in the facility's laboratory, while all parameters reported to regulatory agencies are performed by an accredited commercial laboratory. The facility typically uses Labs Inc. out of New Oxford, PA for their sample analyses with a turn-around time of 2 weeks. Unique Project #: 3E22WN009A Page 3 of 21 Pretreatment - Publicly Owned Treatment Works Inspection Hanover Borough Hanover Borough Wastewater Treatment Plant (WWTP) 07/14/2022 Mr. Redding stated that the facility uses a third party, Gannett Fleming, to aid in their permit writing and to help prepare the facility's annual regulatory reports. The facility has five permitted industrial users, including four categorical industrial users (CIU) and one significant non-categorical user (SNIU). The four CIUs include Emeco Industries, Inc.; IWM International; McClarin Plastics, Inc.; R.H. Sheppard Company, INC; and the one SNIU is Utz Quality Foods, Inc. (Utz). As part of the inspection, a tour of both the facility's treatment plant and Utz, an IU of the facility, were led by Mr. Redding at Inspector Thomson's request. During the tour of the facility, Inspector Thomson observed both influent and effluent sampling points, including composite samplers with thermometers reading four degrees Celsius (Attachment 2 Photographs 1-4). During the tour of Utz, Mr. Redding led an inspection of Utz with Inspector Thomson, including a tour of the processes contributing to the wastewater discharge, a tour of the pretreatment process and a visit to Utz's effluent sampling point (Attachment 2 Photograph 5). While at Utz's effluent sampling point, Mr. Redding described how a sampling event would occur, concluding the tour of Utz. II.Observations A checklist was utilized during the review and is provided below. The checklist is divided into sections, with Observations listed under each section. Visual Observations pertaining to each section are listed at the end of each section. Unique Project #: 3E22WN009A Page 4 of 21 Pretreatment - Publicly Owned Treatment Works Inspection Hanover Borough Hanover Borough Wastewater Treatment Plant (WWTP) 07/14/2022 Section 1. Background. (to be filled out before inspection) Where stream/river/tributary does the POTW discharge to? South Branch Conewago Creek/Plum Creek As required by the approved program, list the frequency for: CIUs SNIUs Comments POTW Sampling of IUs POTW Inspection of IUs IU self-monitoring IU reporting In the last calendar year, indicate frequency of: POTW sampling of IUs POTW Inspection of IUs If less than required by the approved program or less than 1/yr [403.8(f)(2)(v)], explain: List all the SIUs that were found to have not been sampled or not inspected at the last PCI or annual report. Indicate if they are NS (not sampled), NI (not inspected), or B (both not inspected and not sampled) Does the annual report indicate any new CIUs? List all visual observations pertaining to this section 6 6 Attachment 3 1 1 Attachment 3 4 4 Attachment 3 4 4 Attachment 3 13 6+ 1 1 Attached Inspections Yes No N/A Comments According to Mr. Redding, the information listed on page 2 of Attachment 3 under "compliance monitoring in 2016" is not for 2016, but rather for the previous 12 months - Emeco and McClarin Plastics were not monitored in q4 2021, due to shutdown of operations due to covid Section 2. POTW sampling and inspection List the SIUs that were either not sampled or not inspected in the last 12 months [.403.8(f)(2)(v)] Indicate if they are NS (not sampled), NI (not inspected), or B (both not inspected and not sampled). Are pH, oil & grease, cyanide, volatile organics, total phenol, and sulfide collected by grab sample? List the number of grab samples Yes No N/A Comments 1/parameter (stated by Mr. Redding) Are composite samples used for all other pollutants to evaluate compliance with: Categorical Standards? Unique Project #: 3E22WN009A Page 5 of 21 Pretreatment - Publicly Owned Treatment Works Inspection Hanover Borough Hanover Borough Wastewater Treatment Plant (WWTP) 07/14/2022 Local Limits? Is any unannounced sampling conducted? Is POTW prepared to take samples on short notice (i.e., vehicles, personnel, preservatives, etc. available)? How much time normally elapses between sample collection and obtaining analytical results? 2 weeks Does the POTW use QA/QC procedures such as: Use of calibration and maintenance plan for sampling equipment? Training for sampler? Split Samples (field)? Training for analyst? Duplicate Samples (laboratory)? Method Blanks (laboratory)? Spiked Samples (laboratory)? in-house analyses are not used for regulatory List all visual observations pertaining to this section reporting, only for internal monitoring. Labs Inc. is used for analyses when regulatory reporting Section 3. IU Self-Monitoring and Reporting As currently conducted, list frequency for: CIUs SNIUs Comments IU Self-Monitoring IU reporting If less than required by the approved program, explain If IUs sample more frequently than required, do they report all sampling results to the POTW [403.12(g)(5)]? List all new sources IUs: Emeco 5 events, 4+ 21 IWM 10 events (Attachment 3) Emeco 5 reports, 4+ 21 IWM 10 reports (Attachment 3) Yes No N/A Comments n/a Have the following been received by all IUs which became new sources in the last 12 months (403.12))? Baseline Monitoring Reports Compliance Schedule Milestone Reports Unique Project #: 3E22WN009A Page 6 of 21 Pretreatment - Publicly Owned Treatment Works Inspection Hanover Borough Hanover Borough Wastewater Treatment Plant (WWTP) 07/14/2022 90-day Final Compliance Reports How does POTW verify the information in these reports Do any IUs discharge hazardous waste? If no, how does the POTW verify this? Inspecting IU/Sampling IU/sampling influent If yes, has the IU submitted the notifications? List all visual observations pertaining to this section Section 4. IU File Evaluation IU Name Category (SNIU/CIU) List IUs below: Regulated parameters (include categorical standards & local limits) Address Description of IU manufacturing/pretreatment processes Utz Quality Food, Inc. SNIU Not explicitly provided, prohibited discharge standards/local limits provided in Attachment 6 861 Carlisle Street, Hanover, PA 17331 Food Processing IU Name Category (SNIU/CIU) Regulated parameters (include categorical standards & local limits) Address Description of IU manufacturing/pretreatment processes Emeco Industries, Inc. CIU (40 CFR 433) Not explicitly provided, prohibited discharge standards/local limits provided in Attachment 6 850 Elm Avenue, Hanover, PA 17331 Metal finishing/recycled material processing (recycled metals/wood into furniture) IU Name Category (SNIU/CIU) Regulated parameters (include categorical standards & local limits) Address Description of IU manufacturing/pretreatment processes IWM International CIU (40 CFR 433) Not explicitly provided, prohibited discharge standards/local limits provided in Attachment 6 East Middle Street, Hanover, PA 17331 Wire mesh production IU Name Category (SNIU/CIU) Regulated parameters (include categorical standards & local limits) Address Description of IU manufacturing/pretreatment processes McClarin Plastics, Inc. CIU (40 CFR 433) Not explicitly provided, prohibited discharge standards/local limits provided in Attachment 6 60 Filbert Street, PA 17331 Thermoplastic/fiberglass reinforced plastic Unique Project #: 3E22WN009A Page 7 of 21 Pretreatment - Publicly Owned Treatment Works Inspection Hanover Borough Hanover Borough Wastewater Treatment Plant (WWTP) 07/14/2022 IU Name Category (SNIU/CIU) Regulated parameters (include categorical standards & local limits) Address Description of IU manufacturing/pretreatment processes R.H. Sheppard Company, Inc. CIU (40 CFR 433) Not explicitly provided, prohibited discharge standards/local limits provided in Attachment 6 101 Philadelphia Street, Hanover PA 17331 Manufacturer of steering systems/engine pumps Section 5.a File Review Checklist IU Name: Utz Is the IU categorical (CIU), significant non-categorical (SNIU), or other (O)? SNIU Yes No N/A Comments Is the IU categorized? Self-identified in industrial survey (Attachment 7 is an example of an industrial survey, survey for Utz not provided) and confirmed by facility via sampling Control Mechanism List if the file contains the following: Does the file contain regulatory items? List each, including IU permits, local limits, etc. Attachment 27 an updated control mechanism application and/or survey questionnaire? a current control mechanism Attachment 7 Attachment 27 (8/1/2022- 7/31/2023) documentation of how control mechanism limits and requirements were established. Attachment 6 Were local limits and/or categorical standards applied? If applicable, were production-based standards correctly applied? If applicable, was the combined waste stream formula correctly applied? If applicable, were TTO requirements or alternatives correctly applied? In the inspector's opinion, is the sample frequency sufficient to determine compliance? Does the control mechanism include the following: sampling location and frequency? 27 pg 9 Unique Project #: 3E22WN009A Page 8 of 21 Pretreatment - Publicly Owned Treatment Works Inspection Hanover Borough Hanover Borough Wastewater Treatment Plant (WWTP) 07/14/2022 sample type? 27 pg 9 Is the permit effective for 5 years or less? Attachment 27 (8/1/2022- 7/31/2023) POTW Inspections of IUs How many POTW inspections were conducted and documented in the last 12 months? Does the inspection report include the following information: Inspector name Inspection date/time Name of IU official contacted. Review of manufacturing facilities Verification of production data if needed Identification of wastewater sources, flow and types of discharges (e.g. continuous, intermittent, batch). Condition of pretreatment facilities Evaluation of chemical storage areas Evaluation of need for spill/slug control plan at least every 2 years Evaluation of spill/slug control procedures Evaluation of housekeeping practices Evaluation of potential for hazardous waste discharge Evaluation of self-monitoring equipment and techniques Evaluation of lab procedures Evaluation of monitoring records POTW Sampling of IUs How many sampling visits were conducted and documented in the last 12 months? Does the sampling documentation include: Name of the sampling personnel sample date/time sample type sample location wastewater flow during sampling sample preservation chain of custody analytical methods used analysis date 1 (12/14/2021) Attachment 5 page 1 5 page 1 5 page 1 5 page 2 5 page 2 5 page 2 5 page 4 5 page 4 5 page 3 5 page 3 5 page 2 5 page 3, #7 5 page 5 Contractor, 5 page 5, A, #5 5 page 5 4 (Attachment 12) Chain of Custody (CoC) (Attachment 12) CoC CoC CoC CoC CoC Attachment 12 Sample Doc Page 2 (Attachment 12 Pages 2, 6, 9, 13, 17) Unique Project #: 3E22WN009A Page 9 of 21 Pretreatment - Publicly Owned Treatment Works Inspection Hanover Borough Hanover Borough Wastewater Treatment Plant (WWTP) 07/14/2022 name of analyst Attachment 12 all analytical data Attachment 12 Were all the regulated parameters monitored? Attachment 12 Were 40 CFR 136 analytical methods used? Attachment 12 IU Self-Monitoring and Reporting Has the IU submitted all required self-monitoring reports in the last 12 months? Attachment 3 Were all regulated parameters monitored at the required frequency? Attachment 3 Slug/Spill Control Have any slugs/spills been documented in the file? Did the POTW require development of a slug/spill control plan? Has the IU developed a slug/spill control plan? Attachment 8 When was the plan last updated? Does the slug/spill plan contain: Description of discharge practices 8 page 2, III Description of stored chemicals non-categorical, food processor Procedure to prevent slugs/spills 8 page 3, V Procedure to notify POTW of slugs/spills 8 page 2, IV Follow-up practices to minimize damage from slugs/spills 8 page 3, VI List all visual observations pertaining to this section Section 5.b File Review Checklist IU Name: Emeco Industries, Inc. Is the IU categorical (CIU), significant non-categorical CIU (SNIU), or other (O)? Yes No N/A Comments Is the IU categorized? Self-identified in industrial survey (Attachment 7 is an example of an industrial survey, survey for Emeco not provided) and confirmed by facility via sampling Control Mechanism List if the file contains the following: Does the file contain regulatory items? List each, including IU permits, local limits, etc. Attachment 13 Unique Project #: 3E22WN009A Page 10 of 21 Pretreatment - Publicly Owned Treatment Works Inspection Hanover Borough Hanover Borough Wastewater Treatment Plant (WWTP) 07/14/2022 an updated control mechanism application and/or survey questionnaire? Attachment 7 a current control mechanism Attachment 13 July 1, 2021- June 30, 2022 documentation of how control mechanism limits and requirements were established. Attachment 6 Were local limits and/or categorical standards applied? If applicable, were production-based standards correctly applied? If applicable, was the combined waste stream formula correctly applied? If applicable, were TTO requirements or alternatives correctly applied? "Permittee does not have an approved toxic organic management plan (TOMP) in place as defined in 40 CFR 433.12 The Borough of Hanover will complete sampling for the TTO's once every six (6) months. This will meet EPA's requirement in lieu of industry sampling every six (6) months" Attachment 13 In the inspector's opinion, is the sample frequency sufficient to determine compliance? Does the control mechanism include the following: sampling location and frequency? Attachment 13 Page 6 sample type? Attachment 13 Page 6 Is the permit effective for 5 years or less? Attachment 13 July 1, 2021- June 30, 2022 POTW Inspections of IUs How many POTW inspections were conducted and documented in the last 12 months? 1 (12/13/2021) Does the inspection report include the following information: Inspector name Attachment 14 page 1 Inspection date/time 14 page 1 Name of IU official contacted. 14 page 1 Review of manufacturing facilities 14 page 2 Verification of production data if needed 14 page 2 Identification of wastewater sources, flow and types of discharges (e.g. continuous, intermittent, batch). 14 page 2 Unique Project #: 3E22WN009A Page 11 of 21 Pretreatment - Publicly Owned Treatment Works Inspection Hanover Borough Hanover Borough Wastewater Treatment Plant (WWTP) 07/14/2022 Condition of pretreatment facilities 14 page 4 Evaluation of chemical storage areas Evaluation of need for spill/slug control plan at least every 2 years 14 page 4 14 page 3 Evaluation of spill/slug control procedures 14 page 3 Evaluation of housekeeping practices 14 page 2 Evaluation of potential for hazardous waste discharge 14 page 3, #7 Evaluation of self-monitoring equipment and techniques 14 page 5 Evaluation of lab procedures Contractor, 5 page 5, A, #5 Evaluation of monitoring records 5 page 5 POTW Sampling of IUs How many sampling visits were conducted and documented in the last 12 months? 6 events - Attachment 3 Does the sampling documentation include: Name of the sampling personnel Attachment 17/18 CoC sample date/time 17/18 CoC sample type 17/18 CoC sample location 17/18 CoC wastewater flow during sampling sample preservation 17/18 CoC chain of custody 17/18 CoC analytical methods used 17/18 analysis page analysis date 17/18 analysis page name of analyst 17/18 analysis page all analytical data 17/18 analysis page Were all the regulated parameters monitored? 17/18 analysis page Were 40 CFR 136 analytical methods used? 17/18 analysis page IU Self-Monitoring and Reporting Has the IU submitted all required self-monitoring reports in the last 12 months? Attachment 3 Were all regulated parameters monitored at the required frequency? Slug/Spill Control Have any slugs/spills been documented in the file? Did the POTW require development of a slug/spill control plan? Has the IU developed a slug/spill control plan? Attachment 29 When was the plan last updated? Dec 13, 2021 Does the slug/spill plan contain: Description of discharge practices Unique Project #: 3E22WN009A Page 12 of 21 Pretreatment - Publicly Owned Treatment Works Inspection Hanover Borough Hanover Borough Wastewater Treatment Plant (WWTP) 07/14/2022 Description of stored chemicals 29 pg 10 Procedure to prevent slugs/spills 29 pg 3 29 pg 7 "if a spill has occurred, the following Procedure to notify POTW of slugs/spills people need to be notified" - number listed on page 2 Follow-up practices to minimize damage from slugs/spills 27 pg 4 List all visual observations pertaining to this section Section 5.c File Review Checklist IU Name: IWM International Is the IU categorical (CIU), significant non-categorical CIU (SNIU), or other (O)? Yes No N/A Comments Is the IU categorized? Self-identified in industrial survey (Attachment 7 is an example of an industrial survey, survey for Utz not provided) and confirmed by facility via sampling Control Mechanism List if the file contains the following: Does the file contain regulatory items? List each, including IU permits, local limits, etc. Attachment 19 an updated control mechanism application and/or survey questionnaire? a current control mechanism Attachment 7 Attachment 19 October 1, 2021 - September 30, 2022 documentation of how control mechanism limits and requirements were established. Attachment 6 Were local limits and/or categorical standards applied? If applicable, were production-based standards correctly applied? Attachment 19 If applicable, was the combined waste stream formula correctly applied? If applicable, were TTO requirements or alternatives correctly applied? Attachment 19 In the inspector's opinion, is the sample frequency sufficient to determine compliance? Unique Project #: 3E22WN009A Page 13 of 21 Pretreatment - Publicly Owned Treatment Works Inspection Hanover Borough Hanover Borough Wastewater Treatment Plant (WWTP) 07/14/2022 Does the control mechanism include the following: sampling location and frequency? 19 pg 6 sample type? 19 pg 6 Attachment 19 October 1, Is the permit effective for 5 years or less? 2021 - September 30, 2022 POTW Inspections of IUs How many POTW inspections were conducted and documented in the last 12 months? Does the inspection report include the following information: Inspector name Inspection date/time Name of IU official contacted. Review of manufacturing facilities Verification of production data if needed Identification of wastewater sources, flow and types of discharges (e.g. continuous, intermittent, batch). Condition of pretreatment facilities Evaluation of chemical storage areas Evaluation of need for spill/slug control plan at least every 2 years Evaluation of spill/slug control procedures Evaluation of housekeeping practices Evaluation of potential for hazardous waste discharge Evaluation of self-monitoring equipment and techniques Evaluation of lab procedures Evaluation of monitoring records POTW Sampling of IUs How many sampling visits were conducted and documented in the last 12 months? Does the sampling documentation include: Name of the sampling personnel sample date/time sample type sample location wastewater flow during sampling sample preservation chain of custody analytical methods used 1 (12/14/2021) Attachment 20 page 1 20 page 1 20 page 1 20 page 2 20 page 2 20 page 2 20 page 4 20 page 4 20 page 3 20 page 3 20 page 2 20 page 3, #7 20 page 5 Contractor, 20 page 5, A, #5 20 page 5 9 - Attachment 3 Attachment 35/36 CoC 35/36 CoC 35/36 CoC 35/36 CoC 35/36 CoC 35/36 CoC 35/36 analysis page Unique Project #: 3E22WN009A Page 14 of 21 Pretreatment - Publicly Owned Treatment Works Inspection Hanover Borough Hanover Borough Wastewater Treatment Plant (WWTP) 07/14/2022 analysis date 35/36 analysis page name of analyst 35/36 analysis page all analytical data 35/36 analysis page Were all the regulated parameters monitored? 35/36 analysis page Were 40 CFR 136 analytical methods used? 35/36 analysis page IU Self-Monitoring and Reporting Has the IU submitted all required self-monitoring reports in the last 12 months? Attachment 3 Were all regulated parameters monitored at the required frequency? Slug/Spill Control Have any slugs/spills been documented in the file? Did the POTW require development of a slug/spill control plan? Has the IU developed a slug/spill control plan? Attachment 28 When was the plan last updated? Does the slug/spill plan contain: Description of discharge practices 28 section 3.2 Description of stored chemicals 28 section 4 Procedure to prevent slugs/spills 28 section 2.3/6.1/6.2/9 Procedure to notify POTW of slugs/spills 28 section 1.3/1.5/1.6/1.7 Follow-up practices to minimize damage from slugs/spills 28 section 6.3 List all visual observations pertaining to this section Section 5.d File Review Checklist IU Name: McClarin Plastics, Inc. Is the IU categorical (CIU), significant non-categorical CIU (SNIU), or other (O)? Yes No N/A Comments Self-identified in industrial survey (Attachment 7 is Is the IU categorized? an example of an industrial survey, survey for Utz not provided) and confirmed by facility via sampling Control Mechanism List if the file contains the following: Does the file contain regulatory items? List each, including IU permits, local limits, etc. Attachment 21 Unique Project #: 3E22WN009A Page 15 of 21 Pretreatment - Publicly Owned Treatment Works Inspection Hanover Borough Hanover Borough Wastewater Treatment Plant (WWTP) 07/14/2022 an updated control mechanism application and/or survey questionnaire? Attachment 7 a current control mechanism Attachment 21 August 1, 2021 - July 31, 2022 documentation of how control mechanism limits and requirements were established. Attachment 6 Were local limits and/or categorical standards applied? If applicable, were production-based standards correctly applied? If applicable, was the combined waste stream formula correctly applied? If applicable, were TTO requirements or alternatives correctly applied? Attachment 21 In the inspector's opinion, is the sample frequency sufficient to determine compliance? Does the control mechanism include the following: sampling location and frequency? 21 pg 6 sample type? Is the permit effective for 5 years or less? 21 pg 6 Attachment 21 August 1, 2021 - July 31, 2022 POTW Inspections of IUs How many POTW inspections were conducted and documented in the last 12 months? 1 (12/13/2021) Does the inspection report include the following information: Inspector name Attachment 22 page 1 Inspection date/time 5 page 1 Name of IU official contacted. 5 page 1 Review of manufacturing facilities 5 page 2 Verification of production data if needed 5 page 2 Identification of wastewater sources, flow and types of discharges (e.g. continuous, intermittent, batch). 22 page 2 Condition of pretreatment facilities 22 page 4 Evaluation of chemical storage areas 22 page 3 Evaluation of need for spill/slug control plan at least every 2 years 22 page 3 Evaluation of spill/slug control procedures 22 page 3 Evaluation of housekeeping practices 22 page 2 Evaluation of potential for hazardous waste discharge 22 page 3, #7 Evaluation of self-monitoring equipment and techniques 22 page 5 Evaluation of lab procedures Contractor, 5 page 5, A, #5 Unique Project #: 3E22WN009A Page 16 of 21 Pretreatment - Publicly Owned Treatment Works Inspection Hanover Borough Hanover Borough Wastewater Treatment Plant (WWTP) 07/14/2022 Evaluation of monitoring records 5 page 5 POTW Sampling of IUs How many sampling visits were conducted and documented in the last 12 months? 6 - Attachment 3 Does the sampling documentation include: Name of the sampling personnel Attachment 37/38 CoC sample date/time 37/38 CoC sample type 37/38 CoC sample location 37/38 CoC wastewater flow during sampling sample preservation 37/38 CoC chain of custody 37/38 CoC analytical methods used 37/38 analysis page analysis date 37/38 analysis page name of analyst 37/38 analysis page all analytical data 37/38 analysis page Were all the regulated parameters monitored? 37/38 analysis page Were 40 CFR 136 analytical methods used? 37/38 analysis page IU Self-Monitoring and Reporting Has the IU submitted all required self-monitoring reports in the last 12 months? Were all regulated parameters monitored at the required frequency? Slug/Spill Control Have any slugs/spills been documented in the file? Did the POTW require development of a slug/spill control plan? Has the IU developed a slug/spill control plan? Attachment 23 pg 8 When was the plan last updated? 7/18/22 Does the slug/spill plan contain: Description of discharge practices Description of stored chemicals Procedure to prevent slugs/spills Procedure to notify POTW of slugs/spills 23 pg 8 (contact info on page 2) Follow-up practices to minimize damage from slugs/spills List all visual observations pertaining to this section 23 pg 8 Does not include all information required in spill plan Section 5.e Unique Project #: 3E22WN009A Page 17 of 21 Pretreatment - Publicly Owned Treatment Works Inspection Hanover Borough Hanover Borough Wastewater Treatment Plant (WWTP) 07/14/2022 File Review Checklist IU Name: R.H. Sheppard Company, Inc. Is the IU categorical (CIU), significant non-categorical CIU (SNIU), or other (O)? Yes No N/A Comments Is the IU categorized? Self-identified in industrial survey (Attachment 7 is an example of an industrial survey, survey for Utz not provided) and confirmed by facility via sampling Control Mechanism List if the file contains the following: Does the file contain regulatory items? List each, including IU permits, local limits, etc. an updated control mechanism application and/or survey questionnaire? a current control mechanism Attachment 7 Attachment 23 August 1, 2021 - July 31 2022 documentation of how control mechanism limits and requirements were established. Attachment 6 Were local limits and/or categorical standards applied? If applicable, were production-based standards correctly applied? If applicable, was the combined waste stream formula correctly applied? If applicable, were TTO requirements or alternatives correctly applied? In the inspector's opinion, is the sample frequency sufficient to determine compliance? Does the control mechanism include the following: sampling location and frequency? 23 pg 6 sample type? Is the permit effective for 5 years or less? 23 pg 6 Attachment 23 August 1, 2021 - July 31 2022 POTW Inspections of IUs How many POTW inspections were conducted and documented in the last 12 months? 1 (12/17/2021) Does the inspection report include the following information: Inspector name Attachment 25 page 1 Inspection date/time 25 page 1 Unique Project #: 3E22WN009A Page 18 of 21 Pretreatment - Publicly Owned Treatment Works Inspection Hanover Borough Hanover Borough Wastewater Treatment Plant (WWTP) 07/14/2022 Name of IU official contacted. 25 page 1 Review of manufacturing facilities 25 page 2 Verification of production data if needed 25 page 2 Identification of wastewater sources, flow and types of discharges (e.g. continuous, intermittent, batch). 25 page 2 Condition of pretreatment facilities 25 page 3 Evaluation of chemical storage areas Evaluation of need for spill/slug control plan at least every 2 years 25 page 3 Evaluation of spill/slug control procedures Evaluation of housekeeping practices 25 page 2 Evaluation of potential for hazardous waste discharge Evaluation of self-monitoring equipment and techniques Evaluation of lab procedures 25 page 4 Contractor, 25 page 4, A, #5 Evaluation of monitoring records 25 page 5 POTW Sampling of IUs How many sampling visits were conducted and documented in the last 12 months? 6 - Attachment 3 Does the sampling documentation include: Name of the sampling personnel Attachment 39/40 CoC sample date/time 39/40 CoC sample type 39/40 CoC sample location 39/40 CoC wastewater flow during sampling sample preservation 39/40 CoC chain of custody 39/40 CoC analytical methods used 39/40 analysis page analysis date 39/40 analysis page name of analyst 39/40 analysis page all analytical data 39/40 analysis page Were all the regulated parameters monitored? 39/40 analysis page Were 40 CFR 136 analytical methods used? 39/40 analysis page IU Self-Monitoring and Reporting Has the IU submitted all required self-monitoring reports in the last 12 months? Attachment 3 Were all regulated parameters monitored at the required frequency? Slug/Spill Control Have any slugs/spills been documented in the file? Unique Project #: 3E22WN009A Page 19 of 21 Pretreatment - Publicly Owned Treatment Works Inspection Hanover Borough Hanover Borough Wastewater Treatment Plant (WWTP) 07/14/2022 Did the POTW require development of a slug/spill control plan? Has the IU developed a slug/spill control plan? Attachment 26 When was the plan last updated? May 2015 Does the slug/spill plan contain: Description of discharge practices Description of stored chemicals Attachment 26 Section 4 Procedure to prevent slugs/spills Attachment 26 Section 6 Procedure to notify POTW of slugs/spills 26 Section 5 and Appendix B Follow-up practices to minimize damage from slugs/spills Attachment 26 Section 6 List all visual observations pertaining to this section Mr. Redding provided Inspector Thomson with a chart listing significant non-compliance (SNC) for each IU from 2018-2021. Inspector Thomson observed zinc exceedances from New York Wire in 2019, 2020 and 2021 as well as solids exceedances from New York Wire in 2019. Mr. Redding stated that none of the occurrences caused a disruption to the facility's operations or caused the facility's discharge to exceed regulated parameters. According to Mr. Redding, the zinc issue at New York Wire has been resolved. III. Records Review As part of the inspection, the Inspector Thomson requested the documentation listed in Attachment 9, sent to Tony Thomas via email on 7/12/22 after a telephone conversation between Mr. Thomas and Inspector Thomson, noting that the dates and ID numbers listed in the document are not accurate. Inspector Thomson requested that the documents be provided within two weeks of the inspection, by 7/29/22. Starting on 8/4/22 and ending on 8/26/22, Mr. Redding sent Inspector Thomson a series of emails including all attachments, except the photo log (Attachment 2), in this report. IV.Closing Conference After the facility inspection, 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. V. List of Attachments Attachment 1. NPDES Permit 2017 Attachment 2. Photo Log Attachment 3. Summary Tables 2018 Attachment 4. PRETREATMENT SAMPLING 2022 Attachment 5. INSPECTION 21 PLANT 3 Unique Project #: 3E22WN009A Page 20 of 21 Pretreatment - Publicly Owned Treatment Works Inspection Hanover Borough Hanover Borough Wastewater Treatment Plant (WWTP) 07/14/2022 Attachment 6. Prohibited discharge standards. - National Categorical Pretreatment Standards Attachment 7. INDUSTRIAL WASTE SURVEY Attachment 8. Utz Spill Prevention Plan Attachment 9. Copy of Copy of SNC Calculations (Rev February 4 2022) Attachment 10. Upcoming NPDES CWA Pretreatment Inspection 7_14 info Attachment 11. UTZ 2020 Attachment 12. UTZ 2021 Attachment 13. PERMIT 21-22 EMECO Attachment 14. INSPECTION 21 EMECO Attachment 15. EMECO 2020 Attachment 16. EMECO 2020 #2 Attachment 17. EMECO 2021 Attachment 18. EMECO 2021 #2 Attachment 19. IWM PERMIT 21-22 NEW Attachment 20. IWM Inspection 2021 Attachment 21. 2021-2022 Permit McClarin Attachment 22. McClarin INSPECTION 2021 Attachment 23. McClarin Emergency Action Plan (EAP) (Filbert) Attachment 24. Sheppard PERMIT 21-22 Attachment 25. Sheppard INSPECTION 21 Attachment 26. RH Sheppard ppc plan rev 8 Attachment 27. Utz PERMIT 22-23 Attachment 28. IWM Spill Plan - ICP 2022 Update_05-03-2022 Attachment 29. Emeco Spill Plan Attachment 30. UTZ 2021 Attachment 31. SHEPPARD 2021 Attachment 32. McClarin 2021 Attachment 33. EMECO 2021 Attachment 34. IWM 2021 Attachment 35. IWM 2021 Attachment 36. IWM 2021 #2 Attachment 37. McClarin 2021 Attachment 38. McClarin 2020 Attachment 39. SHEPPARD 2021 Attachment 40. SHEPPARD 2020 Unique Project #: 3E22WN009A Page 21 of 21