Document v1RJGqReN7LO02m6maOgZ329w

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 3 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): Site/Facility Operator: Facility Address: Lat/Long: County/Parish: Permit Number: NAICS & SIC Codes: Unique Project #: Clean Water Act Compliance Inspection Report September 12-13, 2023 National Pollutant Discharge Elimination System (NPDES) Pretreatment Compliance Inspection- Publicly Owned Treatment Works (POTW) Trout Run Water Pollution Control Center (TRWPCC) Upper Merion Township Upper Merion Sanitary and Stormwater Authority 900 Mancill Mill Road, King of Prussia, PA 19406-1175 40.11057, -75.407951 Montgomery PA0026131 221320/4952 3E23WN068A Facility Representative: Point of Contact Janet Serfass-Hiriak, MIPP Administrator Phone: (610) 205-8506 Email: jserfass-hiriak@umtownship.org EPA Inspector: Jim Kline, Inspector Phone: (304) 234-0263 Email: kline.james@epa.gov Report Preparer Signature/Date Supervisor Signature/Date James Kline Digitally signed by James Kline Date: 2023.11.16 15:12:47 -05'00' Jim Kline (3ED32) Date NPDES Section MARK ZOLANDZ Date: 2023.11.17 07:27:58 -05'00' Digitally signed by MARK ZOLANDZ Mark Zolandz, Section Chief (3ED32) Date NPDES Section Pretreatment Compliance Inspection - Trout Run WPCC Table of Contents TABLE OF CONTENTS ..................................................................................................................................... 2 I. INTRODUCTION......................................................................................................................................... 3 A. TRWPCC - OPENING CONFERENCE ................................................................................................................................... 3 B. TRWPCC - BACKGROUND INFORMATION.......................................................................................................................... 3 C. TRWPCC - INDUSTRIAL PRETREATMENT PROGRAM FILE REVIEW ................................................................................ 4 II. IU INSPECTION- ARKEMA, INC. ........................................................................................................... 5 A. ARKEMA, INC. - OPENING CONFERENCE..................................................................................................................... 5 B. ARKEMA, INC. - BACKGROUND INFORMATION ................................................................................................................ 5 C. ARKEMA, INC. - OBSERVATIONS....................................................................................................................................... 6 III. CLOSING CONFERENCES ........................................................................................................................ 7 IV. LIST OF ATTACHMENTS .......................................................................................................................... 7 Unique Project #: 3E23WN068A Page 2 of 7 Pretreatment Compliance Inspection - Trout Run WPCC I. Introduction On September 12-13, 2023, Inspector Jim Kline (Inspector Kline) from the U.S. Environmental Protection Agency (EPA) Region 3, National Pollutant Discharge Elimination System (NPDES) Section conducted an onsite Pretreatment Compliance Inspection (PCI) of the Trout Run Water Pollution Control Center (hereinafter "TRWPCC" or the "Facility") Pretreatment Program. TRWPCC is located at 900 Mancill Mill Road in King of Prussia, PA 19406. The purpose of the inspection was to observe the TRWPCC pretreatment program's compliance with the Clean Water Act (CWA), the applicable Federal Pretreatment Regulations, and the Facility's National Pollutant Discharge Elimination System (NPDES) permit ID: PA0026131 (See Attachment #1). Prior to the PCI, the Pennsylvania Department of the Environment ("PADEP") was notified of the inspection. The PADEP did not send a representative to attend the PCI. Inspector Kline did provide TRWPCC advanced notice of the PCI. All information included in this report is the result of observations made by Inspector Kline, statements made by TRWPCC and/or ARKEMA, Inc. representatives, materials shown to Inspector Kline by TRWPCC and/or ARKEMA, Inc. representatives, and/or documents provided by TRWPCC and/or ARKEMA, Inc. representatives to Inspector Kline at the time of, or subsequent to, the inspection. A. TRWPCC - Opening Conference Inspector Kline arrived at TRWPCC at 12:30PM on Tuesday September 12, 2023. Upon arrival, Inspector Kline presented his credentials to Ms. Janet Serfass-Hiriak, Municipal Industrial Pretreatment Program (MIPP) Administrator. Inspector Kline proceeded to conduct an Opening Conference with Ms. Serfass-Hiriak. Inspector Kline informed Ms. Serfass-Hiriak that any information that TRWPCC deemed to be confidential business information ("CBI") should be identified to Inspector Kline during the inspection and it would be handled as CBI according to EPA's CBI procedures. Inspector Kline informed Ms. Serfass-Hiriak that photographs would be taken during the inspection (photographs are provided in Attachment #9 of this report). B. TRWPCC - Background Information TRWPCC is a wastewater treatment plant, owned and operated by Upper Merion Township. Upper Merion Township also oversees operations of a second wastewater treatment plant which is the Matsunk WPCC. The Matsunk WPCC was not subject to this inspection. According to the PADEP-issued NPDES Permit, TRWPCC has a hydraulic capacity of 6 million gallons per day. Average discharge of TRWPCC is approximately 2.75 million gallons per day. TRWPCC discharges to the Schuylkill River and Trout Creek. The NPDES permit was effective December 1, 2021, and expires November 30, 2026. The TRWPCC services the western half of Upper Merion Township and has a jurisdictional agreement with Tredyffrin Township. Inspector Kline requested and received a copy of the Upper Merion Township Sanitary Sewer Extensions Map (See Attachment #2). Unique Project #: 3E23WN068A Page 3 of 7 Pretreatment Compliance Inspection - Trout Run WPCC Inspector Kline asked when the last time TRWPCC evaluated their local limits for the Pretreatment Program. Ms. Serfass-Hiriak stated the local limits were approved in January 2023 and currently is reflected in each individual IU Permit. Inspector Kline asked Ms. Serfass-Hiriak if TRWPCC was current with all EPA annual reporting requirements. Ms. Serfass-Hiriak stated TRWPCC is current and has not been late with annual reporting. The most recent Annual Report that TRWPCC submitted was in 2022 (See Attachment #3). Ms. Serfass-Hiriak stated TRWPCC does not accept hauled-in wastes. According to Ms. Serfass-Hiriak, all sludges generated at TRWPCC are transported by a contracted third-party and disposed in a landfill at Pioneer Crossing in Berks County. Inspector Kline asked Ms. Serfass-Hiriak if TRWPCC had a Fats Oil and Grease (FOG) Program. Ms. SerfassHiriak stated the Township has a collection system division which includes FOG. Ms. Serfass-Hiriak added the FOG Program is funded by sewer tap fees. C. TRWPCC - Industrial Pretreatment Program File Review Inspector Kline conducted an Industrial Pretreatment Program File Review at TRWPCC. According to Ms. Serfass-Hiriak, TRWPCC has three permitted industrial users (IUs). The IUs are: ARKEMA, Inc., Charles River Laboratories, and Childrens Hospital of Philadelphia (CHOP). According to Ms. Serfass-Hiriak, all IU Permits are either a two- or three-year permit. Ms. Serfass-Hiriak stated they are in the process of evaluating a possible IU, Induct EV. Inspector Kline asked Ms. Serfass-Hiriak how TRWPCC identifies potential industrial users. Ms. Serfass-Hiriak stated she works closely with the Township Codes Department and reviews building permit applications and searches for new tenants within their service area. Ms. Serfass-Hiriak stated that once a facility has been identified as having the potential to be a permitted facility, an industrial discharge survey form would be sent to the location. Ms. Serfass-Hiriak provided a copy of the survey form that is mailed out to the location (See Attachment #4). Inspector Kline asked Ms. Serfass-Hiriak if IU inspections and/or sampling are conducted. Ms. Serfass-Hiriak stated each IU is inspected annually. Ms. Serfass-Hiriak added all three IUs are sampled by the Township three times a year (one time is announced and two times are unannounced). Sampling is conducted on behalf of Upper Merion Township by M.J. Reider Associates, Inc. Ms. Serfass-Hiriak stated each IU is required to sample monthly and provide the analytical reports to her. Inspector Kline asked Ms. Serfass-Hiriak if any of the three IUs had any permit parameter exceedances in the past three years. Ms. Serfass-Hiriak stated three of their permitted IUs had either an exceedance, late or incomplete reporting. According to Ms. Serfass-Hiriak, First Quality was one of the three IUs. Ms. SerfassHiriak added that First Quality was a formerly permitted IU which has moved from the area and is no longer a permitted IU. Inspector Kline asked if TRWPCC took enforcement actions for any of these permit violations. Ms. Serfass-Hiriak stated according to their Enforcement Response Plan, they sent a Notice of Violation for the incident and assessed monetary penalties. Ms. Serfass-Hiriak provided the following information (this information was also reporting in the 2020, 2021 and 2022 Annual Reports to the EPA): IU First Quality CHOP Violation Late Reporting Incomplete Reporting Date 2/1/2023 2/1/2023 Enforcement Action NOV/Penalty NOV/Penalty Unique Project #: 3E23WN068A Page 4 of 7 First Quality First Quality Charles River Laboratories Charles River Laboratories Late Reporting Copper & Zinc exceedance Copper & Zinc exceedance Copper & Zinc exceedance Pretreatment Compliance Inspection - Trout Run WPCC 9/14/2022 9/14/2022 10/21/2021 9/1/2020 NOV/Penalty NOV/Penalty NOV/Penalty NOV/Penalty Inspector Kline requested and received a copy of the TRWPCC Enforcement Response Plan (See Attachment #5). Inspector Kline completed the Field Audit Checklist with input from Ms. Serfass-Hiriak (See Attachment #6). Inspector Kline requested and received a copy of the IU Permit issued to ARKEMA, Inc. (See Attachment #7). Inspector Kline requested and received the 2022 Inspection Report for ARKEMA, Inc. (See Attachment #8). As part of the PCI, Inspector Kline selected ARKEMA, Inc. for the IU tour portion of the inspection. Inspector Kline decided that ARKEMA, Inc. would be inspected on September 13, 2023. This concluded the PCI for the day. II. IU Inspection- ARKEMA, Inc. A. ARKEMA, Inc. - Opening Conference Inspector Kline and Ms. Serfass-Hiriak arrived at ARKEMA, Inc. located at 900 First Ave in King of Prussia (See Attachment #9- Photographs #1 & #2) at 10:00 AM. Inspector Kline presented his credentials to Mr. William (Bill) Gares, HESS Manager, and Mr. Richard Fasano, Senior HES Lead Specialist at the outset of the inspection. Inspector Kline conducted an Opening Conference. During the Opening Conference, Inspector Kline informed both Mr. Gares and Mr. Fasano that any information that either individual deemed to be confidential business information ("CBI") should be identified to Inspector Kline during the inspection and it would be handled as CBI according to EPA's CBI procedures. During the inspection, neither Mr. Gares nor Mr. Fasano identified CBI. Photographs were taken during the inspection by Inspector Kline and are provided in Attachment #9. Inspector Kline explained that the purpose of the inspection was to observe the TRWPCC Pretreatment Program's compliance with the Clean Water Act (CWA) and the applicable Federal Pretreatment Regulations. The inspection was conducted as part of a routine periodic inspection. B. ARKEMA, Inc. - Background Information Inspector Kline asked Mr. Gares and Mr. Fasano to provide a brief historical description of their facility and what ARKEMA, Inc. does at this location. According to Mr. Fasano, ARKEMA, Inc. develops specialty chemicals and polymers. Mr. Gares stated this facility is strictly for research and development, and that no manufacturing is conducted here. Mr. Gares added manufacturing occurs in their facilities located in Texas, Alabama, Virginia and two other Pennsylvania locations (West Chester and Birdsboro). Mr. Fasano added the ARKEMA, Inc. Headquarters is co-located on this campus. Unique Project #: 3E23WN068A Page 5 of 7 Pretreatment Compliance Inspection - Trout Run WPCC Inspector Kline asked, in addition to the IU Permit issued by Upper Merion Township, whether ARKEMA, Inc. has other permits or generates hazardous wastes. Mr. Gares stated this location is a large quantity generator (LQG) of hazardous wastes. Mr. Gares stated in addition to generating hazardous wastes, ARKEMA, Inc. has a radiation license issued by the PADEP. Inspector Kline asked Mr. Gares and Mr. Fasano how many employees are at the ARKEMA, Inc. location. Mr. Flanders stated there are approximately 700 full-time employees on campus, with roughly 140 working in research and development and the remainder in the business office. Inspector Kline asked what ARKEMA, Inc. operating hours are. Mr. Gares stated there are various crews with differing shifts, but overall hours of operation are 7:15AM until 5:15PM with daily boiler operations and security coverage around the clock. Inspector Kline asked Mr. Gares and Mr. Fasano to describe wastewater treatment system at ARKEMA, Inc. Mr. Fasano stated the system consists of three 14,000-gallon concrete cells. Mr. Fasano added these cells provide capacity and can contain spills or releases thus preventing any slugs from being sent to TRWPCC. Inspector Kline asked if ARKEMA, Inc. discharges hazardous wastes to the cells. Mr. Fasano stated no hazardous wastes are discharged to the cells and that training is provided to employees to ensure what can go down the drain. Inspector Kline requested the wastewater pretreatment process flow diagram and the previous three years of analytical sample results. Both Mr. Gares and Mr. Fasano stated a diagram would be sent to Inspector Kline after the inspection. Inspector Kline asked who conducts the analytical analysis for sampling. Mr. Fasano stated sample collection is conducted by ARKEMA, Inc. staff and analysis is conducted by a thirdparty lab, Eurofins Lancaster Laboratories. Once the lab completes analysis, a report is sent to Mr. Patrick Cornell, Senior HES Specialist at ARKEMA, Inc. Mr. Cornell reviews the report and sends a copy to Ms. Serfass-Hiriak. Mr. Fasano stated that typically one cell (14,000-gallons) is discharged daily to TRWPCC. Inspector Kline asked how long it takes the lab to return the analytical report. Mr. Fasano stated roughly two weeks. On September 20, 2023, Inspector Kline received an e-mail from Mr. Cornell, which included the wastewater pretreatment flow diagram (See Attachment #10) and a spreadsheet of analytical test results from January 2019 until August 2023 (See Attachment #11). C. ARKEMA, Inc. - Observations Inspector Kline requested and received a layout-map of the campus (See Attachment #12). Inspector Kline requested to tour the ARKEMA, Inc. campus. Accompanying Inspector Kline on the tour were: Ms. SerfassHiriak, Mr. Gares and Mr. Fasano. Observation #1: The first building visited was Building #12. Inspector Kline observed several smallscale operations within rooms 12-130, Hydrogen Peroxide Lab and 12-150, Fluorochemicals. Inspector Kline observed that these areas appeared neat and orderly. Observation #2: Inspector Kline toured Building #14, which is the High Bay Lab which includes extruders and ovens. Inspector Kline observed that these areas appeared neat and orderly. Observation #3: Inspector Kline toured Building #3, which is the Pilot Plant. Inspector Kline observed a 55-gallon drum of latex material. Mr. Gares stated the material was product and this area typically uses ten of these drums a month and that once used, all are non-hazardous wastes. Inspector Kline observed that these areas also appeared neat and orderly. Unique Project #: 3E23WN068A Page 6 of 7 Pretreatment Compliance Inspection - Trout Run WPCC Observation #4: The final stop was at Building #13, which is the Wastewater Treatment Area (See Attachment #9- Photo #3). Inspector Kline observed three concrete 14,000-gallon wastewater treatment tanks (See Attachment #9- Photos #4 and #5). Inspector Kline observed the pH calibration Log (See Attachment #9- Photo #6) and the discharge log (See Attachment #9- Photo #7). Both logs were kept inside Building #13. This concluded the physical inspection portion of the ARKEMA, Inc. III. Closing Conferences After the inspections of ARKEMA, Inc. Inspector Kline conducted a closing conference. Attending the closing conference were Ms. Serfass-Hiriak, Mr. Gares and Mr. Fasano. Inspector Kline shared preliminary observations about Arkema, Inc. Inspector Kline reiterated that all preliminary observations discussed were not compliance determinations. 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. Inspector Kline and Ms. Serfass-Hiriak left ARKEMA, Inc. at approximately 2:00PM. Inspector Kline conducted similar daily closing conferences with Ms. Serfass-Hiriak at the end of each inspection day concerning the TRWPCC Industrial Pretreatment Program. IV. List of Attachments Attachment 1. NPDES Permit Attachment 2. UMT Sewer Map Attachment 3. 2022 Annual Report Attachment 4. Industrial Discharge Survey Form Attachment 5. TRWPCC ERP Attachment 6. Checklist Attachment 7. IU Permit- ARKEMA Attachment 8. 2022 Inspection Report- ARKEMA Attachment 9. Photographs Attachment 10. Wastewater Pretreatment Flow Diagram- ARKEMA Attachment 11. Analytical Test Results- ARKEMA Attachment 12. Campus Map- ARKEMA Unique Project #: 3E23WN068A Page 7 of 7