U.S. ENVIRONMENTAL PROTECTION AGENCY
PENNSYLVANIA MINOR DISCHARGER
NPDES COMPLIANCE AUDIT 1983
MIDDLE ATLANTIC REGION-III 6th and Walnut Streets, Philadelphia, Pennsylvania 19106
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION III
6TH AND WALNUT STREETS
PHILADELPHIA. PENNSYLVANIA 19106
In Reply Refer To: 3WM52
MAR I 8 1983
Mr. C. T. Beechwood
Regional Water Quality Manager
PA Dept. of Environmental Resources
1875 New Hope Street
Norristown, PA 19401
Dear Mr. Beechwood:
This letter is to confirm our plans to visit your office on March 29
and 30, 1983. We may also want to return on April 1 if we are unable
to complete our reviews.
We plan to discuss with your staff the major facilities listed on the
most recent QNCR. Of particular concern are the following:
County
PA0026646 Antietam Valley Mun. Auth. Berks
PA0024180 Berks-Montgomery Mun. Auth. Montgomery
PA0026042 Bethlehem City Northampton
PA0026450 Bristol Twp. Authority Bucks
PA0025917 Chalfont - New Britain Jt. S.A. Bucks
PA0027103 DELCORA Delaware
PA0026531 Downingtown STP ' Chester
PA0026948 Falls Township Authority Bucks
PA0026247 Hatfield Twp. M.A. Montgomery
PA0026701 Morrisville Borough M.A. Bucks
PA0027421 Norristown Boro Montgomery
PA0020290 Quakertown Boro Bucks
PAOO26549 Reading City Berks
PA0027383 Southwest Delaware Co. M.A. Delaware
PA0027031 West Chester - Goose Creek Chester
PA0026018 West Chester - Taylor Run Chester
PA0011371 Baldwin Hardware Manuf. Corp. Berks
PA0022047 Crcmpton & Knowles Corp. Berks
PA0012823 PP & L Martins Creek Northampton
PA0013315 Publicker Dist. - Div. Continental Philadelphia
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We also plan to review the files for the following minor municipal facilities
which have been funded under public law 92-500 and have been certified
complete by the Corps of Engineers:
County
PA0070351 Amity Township M.A. Berks
PA0022543 Bally Municipal Authority Berks
PA0023540 Berks-Montgomery Mun. Auth. Berks
PA0024376 Boyertown Boro Berks
PA0070424 Caernarvon Berks
PA0024422 Lower Salford Township Montgomery
PA0070254 Lynn Township Sanitary Auth. Lehigh
PA0070271 Maidencreek Township M.A. Berks
PA0020699 Montgomery W & S Lycoming
PA0044776 Northwestern Chester County Chester
PA0024961 Oley Township M.A. Berks
PA0024074 Shoemakersville M.A. Berks
PA0020711 Topton Boro M.A. Berks
At random we selected the following minor facilities for file review during
our visit:
Primary Industrial Minors
PA0012033 Valley Paper Mills Modena Plant Chester
PA0012017 Allied Corp. - FXD Plant Philadelphia
PAOO11045 Pycofoam Corp., Nbrristown Montgomery
PA0012980 G.O. Carlson, Inc. - Viaduct Plant Chester
PA0051080 Thompson-CSF Components Corp. Montgomery
PA0012475 MET ED Portland Northampton
PA0050369 Unitog Company Bucks
Secondary Industrial Minors
PAOO70106 Exxon Company, Tuckerton Terminal Berks
PA0070416 Conrail-Beth Diesel Terminal Northampton
PA0050296 Monarch Development Corp. Montgomery
PA0050687 Bethayres Valley Apts. Montgomery
PA0029912 Embreeville State Hospital Chester
PA0070319 Reading-Berks Joint Fire Training Berks
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Municipal Minors
County
PA0020231 Hatfield Boro Montgomery
PA0028355 Eddystone Boro Delaware
PA0051004 Lower Salford Township Montgomery
PA0070149 Leesport Boro Berks
PAQ041742 Nazareth Boro Mun. Auth. Nbrthanpton
Our file review will also include the following federal facilities which
are in noncompliance either due to effluent violations or failure to submit
discharge monitoring reports:
PA0036447 Naval Ship Engineering Center Phila.
PA0046264 U.S. Array Corps Eng. - Blue Marsh Berks
Sincerely yours,
ORIGINAL SIGNED BY
JL DAVIS
Joseph Davis, Chief
Pennsylvania Section
Water Permits Branch
Water Management Division
cc: Walter Stanley, Norristown DER
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COMMONWEALTH OF PENNSYLVANJA
DEPARTMENT OF ENVIRONMENTAL RESOURCES
Post Office Box 2063
Harrisburg, Pennsylvania 17120
September 7, 1983
(717) 787-2666
Mr. Greene A. Jones, Director
Water Management Division
EPA Region III
Sixth and Walnut Streets
Philadelphia, PA 19106
Re: Minor Discharger
NPDES Compliance Audit - 1983
Dear Mr. Jones:
We have reviewed the 1983 Minor Discharger NPDES Compliance Audit
Report and have concluded that it represents a reasonable benchmark of minor
discharger compliance status at the time the audit was conducted.
Your August 17, 1983 transmittal letter accompanying the report requested
comments on the recommendations and other portions of the report. General
comments are as follows:
1. The sample size appears to be small for an accurate assessment for all categories
except P.L. 92-500 facilities where 100% of the facilities in the category
were reviewed. Only 5% of the unfunded publicly owned treatment works,
5% of the primary industries, and 2% of the secondary industries were reviewed.
2. The .summary indicates that the compliance percentage would increase if all
dischargers currently not submitting DMR's would begin to submit their
DMR's. The estimated compliance percentage for nonsubmitting dischargers
appears to be based on the compliance percentage for dischargers currently
submitting DMR's. We agree that Pennsylvania's compliance percentage
would increase but probably not as much as estimated in your report, since
our experience indicates that dischargers who fail to submit DMR's are also
more likely to have effluent violations.
3. The summary strongly suggests more enforcement effort against minor dischargers
who received P.L. 92-500 funding. Is this an indication of a change in EPA
priorities? Our current Memorandum of Agreement with EPA stresses major
dischargers and tends to de-emphasize all minors. Any additional enforcement
effort that we would spend on minor dischargers would take resources away
from the major dischargers.
4. Some of the cases reviewed did not have, or need NPDES permits. Two
examples are the Ortanna Sewage Treatment Plant in Hamiltonban Township,
Adams County which has spray irrigation, and the Youth Development CentS^
in Loysville, Perry County, which is connected to a municipal syste^'l?-/"-'':"i'*^*v* * ^>\ J
SE?131983
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Mr. Greene A. Jones, Director -2- September 7, 1983
5. Several of our regional offices have recently initiated programs to obtain
DMR's from those dischargers who are not submitting them. A review of
minor dischargers by these regions shows that some of these are now submitting
DRM's. We expect the remaining Regions to implement a similar program.
Comments on the specific recommendations are as follows:
1. The report recommends uniform implementation of the Compliance Monitoring
Strategy since the strategy addresses DMR review and follow-up. The Compliance
Monitoring Strategy has provided the basis for the 1983-84 fiscal year Regional
Program Plans which were implemented as of July 1, 1983. More detailed
Policies and Procedures based on this strategy are currently under development.
2. We agree that there are problems with some regional filing systems, and
plan to review these systems during the current fiscal year.
3. The report proposes a statewide review of DMR's versus permit limitations
since some dischargers are reporting against obsolete limits. We agree that
such a review would be useful, but it would also be very time consuming.
These can be reviewed as inspections are conducted, rather than all at one
time. Ideally, your Permit Compliance System (PCS) should be expanded to
include minor dischargers. PCS has the potential to eliminate the need for
manual logging, identify significant noncompliance, identify nonreporting
dischargers, and provide statistics that could have significantly reduced the
71 work days that your report indicates was spent by your staff on this audit.
k. This item recommended manual or computerized case histories. Complete
manual case histories for all dischargers are not feasible because of'the
large workload involved. Case histories can be compiled from the individual
case files on an as needed basis. The Department's Enforcement System is
still in the feasibility stage. Again, PCS would be helpful if extended to
minor dischargers.
5. The recommendations from the Bureau of Water Quality Management's Enforce-
ment Strategy will not affect most of the minor dischargers since the strategy
gives emphasis to serious and willful violations. Most of the violations by
minor dischargers are not as serious and no more willful than violations by
major dischargers and would receive no additional attention.
We appreciate your recommendations and will continue to attempt to
develop methods for improving the compliance percentage for minor dischargers.
Your report indicates that your staff plans to discuss this further with us. Please
have your staff contact Ken Okorn at (717) 787-8184 to arrange for a meeting.
Sincerely,
LOUIS W. BERCHENI, Director
Bureau of Water Quality Management
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PENNSYLVANIA MINOR DISCHARGER
NPDES COMPLIANCE AUDIT 1983
July 28, 1983
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Summary
The audit performed during the months of March and April, 1983 resulted
in the following findings:
1. The State overall compliance rate for minor dischargers is
51%. Excluding non-submittal of Discharge Monitoring Reports (EMR1 s)
as a violation results in a 74% compliance rate.
2. P.L. 92-500 funded and operational minor facilities had a 55%
compliance rate. Since these are only recently constructed, an increased
effort by DER to get EMR's submitted would raise this rate to 58%.
Non-submittal of EMR's by this type of facility is inexcusable, and prompt
enforcement activities are called for. The justification for a con-
tinuance of federal funding of municipal treatment plants may well rest
upon the compliance record of the operational facilities in existence.
3. Primary industrial facilities show a 55% conpliance rate that
would be raised to 75% by the elimination of reporting violations.
4. Secondary industrial facilities show a 43% compliance rate that
would be raised to 75% by elimination of reporting violations.
5. Minor unfunded municipalities had a 48% compliance rate that would
be raised to 79% by the elimination of reporting violations. Compliance
with the reporting requirement of the permits would bring Pennsylvania's
minor facilities compliance rate in line with national goals and standings.
6. The federal facilities compliance rate, at 93%, is significantly
higher than the other categories. Only one federal facility did not
submit EMR1 s.
7. The condition and availability of the files reviewed varied from
excellent to poor. The recent shifting of files between Regions is not
the problem.
8. DER staff cooperation was excellent and is gratefully actaowledged.
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Recommendations
1. Uniform implementation of DER's Compliance Mbnitoring Strategy (QMS)
is recommended. Review of the files showed that, despite numerous in-
spections by DER personnel, the issue of non-submittal of EMR's was
not adequately addressed. The EMR logging procedures need review in all
Regions with additional resources allocation required in some cases.
2. A review of regional files control, files availability, and the
basic structure of the files system is recommended. Time spent looking
for lost files is non-productive. Discussions with DER staff indicated
that they too see a need for improvements in sane of the Regions.
3. A state-wide review of LMR versus permit limitations would be useful.
A number of permittees are reporting against obsolete or superseded
permit limitations and show up as in compliance while violating their
existing permit.
4. A log of DER activities (inspections, enforcement actions, etc.) for
each facility might be considered. The use of operations resources as
documented by inspection reports in the files indicated significant
differences between Regions, as well as within a given Region. Better
staff utilization would be possible if either manual or computerized
case histories were available to the managers to indicate the results
obtained for the resources expended.
5. Implementation of a uniform statewide enforcement strategy
(currently under development) should be given a high DER priority.
The resources used in developing and issuing a Part I and Part II permit,
and the funds spent to build and operate treatment plants, deserve proper
follow-up and enforcement of significant violations.
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Purpose of Audit
As outlined in the regional Minor NPDES Dischargers Compliance Strategy of
January 31, 1983, the Section was directed to schedule an audit no later than
February 28, 1983. The compliance rate of four classes of minor dischargers
were to be determined:
1) Funded POIWs - 100% (to establish reporting baseline)
2) Unfunded POIWs - 5%
3) Primary Industries - 5% other than coal mines
4) Secondary Industries - 2%
Due to the high costs both in resources and travel, it was decided to add three
more activities to be performed during each audit visit which would otherwise
be performed at another time:
1. Meetings with DER regional management to discuss any procedural or
managerial problems that may exist.
2. Audit the federal facilities to provide baseline data requested by
the Regional Administrator.
3. Perform the usual follow-up discussions regarding violators found on
the Quarterly ton-Compliance Report prior to taking federal enforcement
action. These discussions include field personnel as well as managers and
are a key activity in optimizing and coordinating the enforcement activities
of our respective agencies.
The total cost of the audit and related activities was $ 3,700 and 71 work
days.
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Audit Procedures
The procedures for this audit are specified in the following memoranda:
1. "Region III Strategy Minor NPDES Discharger Compliance," dated January
31, 1983, fron Chief, Water Permits Branch to Director, Water Management
Divi sion.
2. "Minor NPDES Discharger Strategy", dated February 24, 1983, from Chief,
PA Section to PA Section technical staff.
3. "PA Audit Yardsticks," dated May 5, 1983, from Chief, PA Section to PA
Section staff.
4. "Definition of Significant Nbncompliance," from Acting Director, Office
of Water Enforcement and Permits, to Acting Assistant Administrator,
Office of Water.
Permittees in the following categories were selected for audit according
to the procedures in Reference 1.
a. P.L. 92-500 funded POTW's, 100 percent of the minor facilities of
this class in each Region.
b. Unfunded POTW1s, approximately five percent of the minor facilities
of this class in each Region.
c. Primary industries, approximately five percent, other than coal mines,
of the minor facilities of this class in each Region.
d. Secondary industries, approximately two percent of the minor facilities
of this class in each Region.
e. All federal facilities in noncompliance were reviewed in the Regions.
A listing of funded facilities by Region was obtained from Grants. A
computer printout by Region was used to select categories b, c, d, and e.
The five percent sample for each Region was obtained for category b by
starting with the second minor unfunded POTW on the regional printout and then
selecting each twentieth candidate. The five percent sample for category c
was obtained in a similar manner by counting the primary industrial permittees.
For category d, each fiftieth candidate was selected for the audit. Review
of EPA files prior to the audit provided the candidates in category e.
During the audit it became obvious that a few of the candidates selected
were major dischargers, coal mine permittees, or other nonrepresentative
facilities. In those cases, the next facility of that class in that Region
was substituted. Three candidates were changed out of the 179 selected.
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Based on these procedures, separate lists of P.L. 92-500 funded POTW1s,
unfunded POTW1s, primary industries, secondary industries, and federal
facilities were developed for each Region. A letter was then sent to the
Regions prior to the audit visit by EPA. This letter provided a list by
category of facility files to be audited. In most cases, the Regions pulled
the files prior to our arrival for the audit. The main purposes of the audit
were to determine the compliance status of the audited facilities according
to the criteria of memos 3 and 4 and to determine the State response to the
violations.
1. A facility that was in compliance for the last six months of 1982 was
counted as in compliance.
2. Nonsubmittal of EMR1 s was counted as a violation unless all EMR1 s were
submitted for the last six months of the period from January 1982 until
December 1982.
3. A facility that exceeded the effluent criteria in memo four was described
as having significant effluent violations.
The selected files were reviewed at each Region by the EPA audit team.
Using a check sheet, each of the audited files was classified as being in
compliance, as missing EMR's, or as having effluent violations. In some
cases, there were missing EMR1 s and effluent violations. If sufficient
EMR data were available to establish significant effluent noncompliance,
then the permittee was classified as being in significant noncompliance.
If enough data were not available, the permittee was classified as having
missing EMR1s. If the violations found in the files were less than the
significant noncompliance criteria, the permittee was counted as in
compliance.
4. The findings were quality checked by interviewing the appropriate
operations staff. A significant number of compliance activities was
surfaced by this method that did not appear in the official files.
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Description of Data
Appendices 1 and 2 present the data obtained during the March through April
1983 EPA Audit of the Pennsylvania minor facilities files.
In the bar graphs (Appendix 1) the order of segments, reading from the bottom
up is always: compliance, effluent violations, and missing DMR1s. Figures
1-4 shew the compliance status of each class of facilities. Missing DMR's
are defined as a violation and included in the count. Figures 5-8 also show
the compliance status of each class of facilities but based upon submitted DMR' s
only. Figure 9 shows the DMR submittal status of violating federal facilities.
It should be noted that Regions 5 and 6 had no violating federal facilities.
Figures 10-11 and figures 12-13 present regional and State wide averages,
respectively. Figure 14 illustrates an interesting observation. A check of
EPA's files after the audit visits showed that some DMR's were submitted to
EPA, but DER had no record of same. To present the best possible picture, we
had accepted a DMR log entry at the Regions as "DMR received" even though the
DMRs were not found in the files. Figure 14 shows that ten to twenty percent
of the DMRs get lost in DER1s administrative tracking and filing systems,
compared to EPA1s files.
The non-submittal of DMR's as shown in Figure 15, represents a significant
portion of the non-compliances. Some Regions are aggressively pursuing
these violators; others are not. Tables presenting the data used to
construct each figure are found in Appendix 2.
The data in Figures 1-8 and Tables 1-8 do not include federal facilities,
since the violating permittees only were audited. A suntnary of the federal
facilities compliance rate is somewhat complicated by the fact that the
original permits were written on a per outfall basis rather than one per
facility, as is the current practice. The State has consolidated some of
these permits during reissuance, but a few are still in existence. There are
currently fifty-two federal facility permits in Pennsylvania. Two are
major permittees and four are duplicates or no longer under the control
of federal agencies. Of the remaining forty-six facilities, three are in
non-compliance, a ninety-three percent compliance rate that is significantly
higher than that found for any of the other classes of minor dischargers.
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Appendix 1
GRAPHS
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FIGURE 1 P.L. 92.500 FACILITIES
100-r
z
a
3
r
u
L
6
STATE
\\\\\\
COMPLIANCE
EFFLUENT VIOLATIONS
MISSING DMRs
-------
FIGURE 2 PRIMARY FACILITIES
100
UJ
O
DC
UJ
Q.
3
REGION
6
STATE
\\\\\\
COMPLIANCE
EFFLUENT VIOLATIONS
MISSING DMRa
-------
FIGURE 3 SECONDARY FACILITIES
100-r
80
60 ..
ui
o
tt
UJ
a.
40 -.
20..
STATE
COMPLIANCE
EFFLUENT VIOLATIONS
MISSING DMRs
-------
FIGURE 4 MINOR MUNICIPALITIES
100
Z
Ul
o
QC
204-
STATE
\\\\\\
COMPLIANCE
EFFLUENT VIOLATIONS
MISSING OMRs
-------
FIGURE 5 P.L. 92-500 FACILITIES SUBMITTING DMR'S
100T
ao4
eor
o
oc
1U
a.
404-
20+
8 STATE
REGION
EFFLUENT VIOLATIONS
-------
FIGURE 5 P.L. 92-500 FACILITIES SUBMITTING DMR'S
100T
ao4
ear
Ul
a
ac
Ui
a,
40+
204.
6 STATE
REGION
COMPLIANCE
EFFLUENT VIOLATIONS
-------
FIGURE 6 PRIMARY FACILITIES SUBMITTING DMR'S
h-
Z
UJ
o
QC
UJ
0.
456 STATE
REGION
\\\\\\
COMPLIANCE
EFFLUENT VIOLATIONS
-------
FIGURE 7 SECONDARY FACILITIES SUBMITTING OMR'S
100-r
z eof
UJ
o
cc
UJ
Q.
40+
20+
6 STATE
REGION
\\X\\\
COMPLIANCE
FFLUENT VIOLATIONS
-------
FIGURE 8 MINOR MUNICIPALITIES SUBMITTING DMR'S
UJ
o
tr
ui
0.
20-
6 STATE
REGION
COMPLIANCE
EFFLUENT VIOLATIONS
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FIGURE 9 FEDERAL FACILITIES
IN NON-COMPLIANCE
100,.
80,.
I-
z
1U
o
cc
111
0.
60-.
40-
20-.
6
STATE
REGION
DMR'S SUBMITTED
DMR'S MISSING
NOTErIN REGION 5&6 NO FEDERAL FACILITIES WERE AUDITE
-------
FIGURE 10 AVERAGE OF REGIONAL FACILITIES
100T
aoi
e
-------
RQURE 11 AVERAGE OF REGIONAL FACILITIES SUBMITTING DMR'S
100T
80l
60+
UJ
o
oc
Ul
Q.
40+
20+
STATE
REGION
COMPLIANCE
EFFLUENT VIOLATIONS
-------
FIGURE 12 STATE AVERAGES OF FACILITIES
100-r
80+
Z
HI
O
cc
Ul
0.
P.L.
M
TOT.
TYPE OF FACILITY
\\\\\
[COMPLIANCE
EFFLUENT VIOLATIONS
MISSING DMR'S
P.L.-FJ-. 02-600 FACILITIES
P-PRIMARY FACILITIES
S-SECONDARY FACILITIES
M-MINOR MUNICIPALITIES
-------
FIGURE 13 STATE AVERAGES OF FACILITIES SUBMITTING DMR'S
100T
804-
60 +
z
Ul
o
oc
Ul
0.
40-h
204-
P.L.
M TOT.
\\\\\\
COMPLIANCE
FFLUENT VIOLATIONS
-------
FIGURE 14 FILE QUALITY
100-r
80-
60--
40-"
20"
% FILE QUALITY —
6
REGION
DER MISSING DMR'S-EPA FOUND DMR'S X 100
DER MISSING DMR'S
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FIGURE 15 MISSING DMR'S
100-r
Z
UJ
O
DC
UJ
Q.
60--
40-,
20--
5
6
REGION
-------
FIGURE 16 STATEWIDE SUMMARY
80
70
65
90
60
55
10
45
40
15
20
EFFLUENT
VIOLATIONS
30
35
FEDERAL FACILITIES NOT INCLUDED
-------
FIGURE 17 STATEWIDE SUMMARY
FACILITIES SUBMITTING DMR'S
95
85
80
70
65
90
60
10
40
15
EFFLUENT
VIOLATIONS
30
35
FEDERAL FACILITIES NOT INCLUDED
-------
FIGURE 18 FEDERAL FACILITIES
95
80
70
90
60
10
40
15
20
DMR'S MISSING
DMR'S SUBMITTED
30
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Appendix 2
TABLES
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Table 1 P.L. 92-500 Facilities
Region
1
2
3
4
5
6
State
Number
Facilities
13
8
15
6
14
8
64
Compliance
61.5
12.5
73.3
50
50
62.5
54.7 •
Facilities
Missing DMR's
7.7
12.5
20
16.7
21.5
25
18.8
Effluent
Violations
30.8
75
6.7
33.3
28.5
12.5
26.5
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Table 2 Primary Facilities
Region
1
2
3
4
5
6
State
Number
Facilities
6
2
4
2
4
4
22
Compliance
66.7
50
50
50
50
50
54.5
Facilities
Missing DMR's
33.3
50
0
50
25
25
27.3
Effluent
Violations
0
0
50
0
25
25
18.2
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Table 3 Secondary Facilities
Region
1
2
3
4
5
6
State
Number
Facilities
5
3
4
3
7
6
28
Compliance
20
100
50
33.3
28.6
50
42.9
Facilities
Missing DMR's
60
0
25
33.3
57.1
50
42.9
Effluent
Violations
20
0
25
33.3
14.3
0
14.2
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Table 4 Minor Municipalities
Region
1
2
3
4
5
6
State
Numbe r
Facilities
5
4
7
5
13
6
40
Compliance
40
75
28.6
80
38.5
50
47.5
Facilities
Missing DMR's
40
0
42.8
20
61.5
33
40
Effluent
Violations
20
25
28.6
0
0
17
12.5
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Table 5 P.L. 92-500 Facilities Submitting DMR's
Region
1
2
3
4
5
6
State
Number
Facilities
12
7
12
5
10
6
52
Gonpliance
66.7
14.3
91.7
60
70
83.7
67.5
Effluent
Violations
33.3
85.7
8.3
40
30
16.3
32.5
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Table 6 Primary Facilities Submitting DMR's
Region
1
2
3
4
5
6
State
Number
Facilities
4
1
4
1
3
3
16
Compliance
100
100
50
100
66.7
66.7
75
Effluent
Violations
0
0
50
0
33.3
33.3
25
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Table 7 Secondary Facilities Submitting EMR's
Region
1
2
3
4
5
6
State
Number
Facilities
2
3
3
2
3
3
16
Carpi iance
50
100
66.7
50
66.7
100
75
Effluent
Violations
50
0
33.3
50
33.3
0
25
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Table 8 Minor Municipalities
Region
1
2
3
4
5
6
State
Number
Facilities
3
4
4
4
5
4
24
Ocnpliance
66.7
75
50
100
100
75
79.2
Effluent
Violations
33.3
25
50
0
0
25
20.8
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Table 9 Federal Facilities
Region
1
2
3
4
5
6
State
Number
Facilities
1
1
2
4
0
0
8
Facilities
Submitting DMR's
100
100
100
75
87.5
Missing
EMR's
0
0
0
25
12.5
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Table 10 Average of Regional Facilities
Region
1
2
3
4
5
6
State
Number
Facilities
29
17
30
16
38
24
154
Compliance
50.2
47.1
56.6
56.3
42.1
54.2
50.7
Facilities
Missing DMR's
28.6
11.8
23.3
31.9
44.7
33.3
30.5
Effluent
Violations
21.2
41.1
20.1
11.8
13.2
12.5
18.8
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Table 11 Average of Regional Facilities Submitting DMR's
Region
1
2
3
4
5
6
State
Number
Facilities
21
15
23
12
21
16
108
Gcnpliance
71.3
53.3
73.9
75
76.2
81.3
74.1
Effluent
Violations
28.7
46.7
26.1
25
23.8
18.7
25.9
-------
Table 12 State Average of Facilities
Type Facility
P.L. 92-500
Primary
Secondary
Minor
Number
Facilities
64
22
28
40
Compliance
54.7
54.5
42.9
47.5
Facilities
Missing DMR's
18.8
31.9
42.9
40
Effluent
Violations
26.5
13.6
14.2
17.5
Municipalities
Total 154 50.7 30.5 18.8
-------
Table 13 State Average of Facilities Submitting EMR's
Type Facility
P.L. 92-500
Primary
Secondary
Minor
Number
Facilities
52
16
16
24
Compliance
67.5
75
75
79.2
Effluent
Violations
32.5
25
25
20.8
Municipalities
Total 108 74.1 25.9
-------
Table 14 File Quality
Region
1
2
3
4
5
6
DER MISSING
Files
122
43
78
75
211
59
EPA MISSING
Files
91
41
65
73
181
52
File
Quality
75
95
83
97
86
88
-------
Tiable 15 DMR Subnittal
Region
1
2
3
4
5
6
Number
EMR's
360
228
384
228
432
324
EMR's
Missing
122
43
78
75
211
59
Percent
Missing
34
19
20
33
49
18
-------
Appendix 3
LETTERS AND MHOS
-------
Region III Strategy - Minor HPDES Discharger Compliance
/;, ..-,9 ^ 3WJ31 1963
Charles W. Sffpp^^-'"' ^'-cx
Chief, Water Permits Branch
Greene A. Jones O \
Director, Water Management Division (3WMOO)
The following is a strategy for analyzing and improving compliance
rates of minor discharges in each State in Region III.
The approximate 13,300 minor dischargers can be divided into four categories:
1. POTW - completed facilities funded under PL 92-500 - included in the
Administrator's Accountability System - 116.
2. POTW - not funded under PL 92-500 - approximately 1360.
3. Primary Industry - a) approximately 940 non-coal mines.
b) approximately 5300 coal mines.
4. Secondary Industry - approximately 5600.
The general strategy to assess and improve the current compliance status
is as follows:
1. During December 1982, Water Permits Branch reviewed its files and
contacted the Delegated States to obtain compliance status of
completed POTWs funded under P.L. 92-500 for the Administrator's
Accountability System. An effort to have the States inspect or
otherwise evaluate 100Z of the completed facilities will be made.
2. Regional Counsel will review the MOAs, NPDES regulations, and existing
correspondence to determine Regional authority to request information
in Delegated States. This is to be done by February 15, 1983.
3. Concurrently with Regional Counsel review, Water Permits Section Chiefs
will contact the Delegated States to express our general interest in
minor dischargers and discuss their compliance and enforcement programs
in this area.
4. By February 28, 1983, Water Permits Branch will schedule audits, on a
random basis, of information in each Delegated State to determine com-
pliance status in the following manner:
a) Funded POTWs 100% (to establish reporting baseline)
b) Unfunded POTWs < 5Z
c) Primary Industries < 5Z other than coal mines
d) Secondary Industries *z 22
-------
-2-
Revlev of selected Regional files will commence immediately upon
selection,, and selected StatA files will be reviewed during our
normal audits. Where noncoopllance or nonreportlng is noted, the1
Delegated State_will be advised in writing, asked to follow up and,
report actions and results to «»• In the case of'serious violations,.
we can initiate enforcement' actions if the State fails to,achieve
compliance in a reasonable time, i.e. six months.
5. In those States where EPA still has priaacy, District of Columbia
and Federal Facilities in Delaware & Maryland, Water Permits Branch
staff will review our files and in instances of noncoapliance or
• nonreporting, will initiate direct contacts with the permittees,
' '' either by telephone or letter. There 'are approximately 100 dis—
r chargers in this category, and we. would expect to overview.25 of
then by March 1, 1983.
6. Once our initial assessments of the States' programs and compliance
.. rates are completed, specific strategies for each state and broad
categories of discharges will be developed or modified in cooperation
with the affected State. Broad categories are:
a) Funded POTWs
b) Non-coal mine primary industries
c) Coal Mines
d) Unfunded POTWs and secondary industries.
These strategies will be based on the information obtained during
our reviews plus the draft National Municipal Policy and Environmental
Management Reports as they are developed, and it is anticipated they
would be implemented through the SEA and §106 grant in FY84.
It is anticipated that EPA's expression of interest in the various areas will
be sufficient to cause a definite increase in the compliance rate of minor
dischargers in Region III. The information available.in the Regional Office
concerning current minor permittee compliance is very limited. This strategy
includes the use of statistically sound sampling to determine baseline status.
Enclosure
bcc: Len Mangiaracina Larry Banning
Fred Grant ' Joe Davis
Joe Galda Jeff Hass
Bill Bulman - Bob Collings
Stan Laskowski
Jim Burke
-------
Minor Facilities
Municipals
Non 92-500 92-500
Primary
Non-Coal Coal
Secondary
Total
TOTAL 1362 116 939 5336 5564 13317
-------
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Region 111 - 6th & Walnut Sts.
Philadelphia, Pa. 19106
SUBJECT- Minor NPDES Discharger Strategy
PROM- Joseph Davis
Chief, PA Section, WPB
TO:
DATE: FEB '• f:
PA Section Technical Staff
Appended you will find a Branch strategy for analyzing and improving rates
for minor dischargers in Pennsylvania. We must add another category:
4(e) Federal facilities 100%
(to establish a reporting baseline)
Be sure to note the February 28, 1983 deadline for scheduling audits. The
West Team is going out during the weeks of March 14 and March 21, 1983. I
would like to schedule Norristown during the week of March 28, 1983 and
Wilkes-Barre/Harrisburg during the weeks of April 4 and 11, 1983.
Please notify the Regional managers that, although we will be in the Region
for two to four days, most of the time will be used for looking at selected
files with minimum DER personnel participation. Only one day will be re-
quired for the usual enforcement discussions.
The merits of this method of operation are not a matter for discussion. We
will follow the strategy to the letter. Agency policy is not made at the
staff level, so let's make this work. It should be obvious to all that this
methodology will provide a good data base for future reporting of compliance
rates, and at the same time, we are performing our required NPDES overview
audits of the state-run program.
-------
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Region III - 6th & Walnut So.
Philadelphia, Pa. 19106
SUBJECT: PA Audit "Yardsticks"
DATE: MAY 5 .033
FROM: Joseph Davis
Chief, PA Section, WPB
TO: Section Staff
As we discussed, the following criteria will be used—without additional
judgements etc.—for establishing the compliance status of the audited
facilities:
1. Note any violation of the permit without excuses.
2. Note any violations at or greater than the level in the attached
draft definition of significant noncompliance.
3. A facility that was in conpliance on the last six DMR's is to be
counted in compliance. This could be July through December, or
August through January, or September through February. Prior violations
were obviously resolved. A comment should so note.
4. Ndnsutmittal of DMR's is to be counted as a violation in both systems
(during the period of January 1982 - December 1982) unless eleven other
DMR's show full compliance. The assumption is made that this is a
clerical or Postal Service error and we'll give the permittee the bene-
fit of the doubt.
Repeating, then, we'll have three sets of numbers: in compliance, in
nonccmpliance and in significant nonccmpliance.
A chart format is the next issue to be resolved. This can be developed
after we know the approximate statistics based on the preceding.
-------
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON. D.C. 20460
OFFICE OF
MEMORANDUM WATER
SUBJECT: Definition of Significant Noncompliance
FROM: Martha Prothro, Acting Director
Office of Water Enforcement and Permits
TO: Bruce Barrett, Acting Assistant Administrator
Office of Water
Attached for your signature is the definition of significant
noncompliance for use in evaluating NPDES permit violations. This
fulfills the requirement in the Administrator's accountability
system that a procedure ba developed to identify those permit
violations which are of sufficient magnitude and/or duration to be
considered of major concern to the regulatory agency. The defini-
tion will be used to report national levels of compliance in the
NPDES program and to evaluate the progress of the NPDES program. It
does not (indeed, could not) affect in any way the requirements of
statute or regulations which apply to 1TPDZ3 permit holders.
BACKGROUND
The first draft of the definition was developed by the
Enforcement Division of this Office (Memorandum August 11, 1981),
based on discussions with the EPA regional offices and N'PDES States.
A work group of compliance managers from the EPA regional offices
developed the definition from State and EPA comments. A draft was
also presented to the Compliance Task Force of ASIWPCA which
endorsed the general definition.
The EPA work group established the following guidelines for the
definition of significant noncompliance: (1) it should be simple to
use; (2) it must be acceptable to States and program reviewers; and
(3) it should be reasonably flexible. We have attempted to incor-
porate these concerns throughout the draft definition. For example,
the draft definition could be used in manual or computerized
screening of Discharge Monitoring Reports and Compliance Schedule
Reports. The definition's criteria for evaluating violations are
the same for major and minor facilities, for interim and final
permit limits, and for mass loading and concentration based effluent
limits. Separate criteria are used, however, to define significant
noncompliance for schedule violations for municipals and non-
municipals because of the special circumstances involving funding
of municipal treatment facilities.
-------
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
OFFICE OF
WATER
MEMORANDUM
SUBJECT: Definition of Significant Noncompliance
for the NPDES Program
FROM: Frederic A. Eidsness, Jr.
Assistant Administrator for Water (WH-556)
TO: Regional Administrators
State NPDES Program Directors
Over the past few years, the compliance personnel of various
Regions and States have expressed concern about the Agency's
emphasis on reportin-j and resolving instances of noncompliance
which are of minor importance. "Minor" violations of NPDES require-
ments, although important in one sense, do not always reflect the
real gains of the NPDES program. It is important, given the large
number of NPDES permittees and the limited enforcement/compliance
resources, that we focus our efforts to resolve truly serious prob-
lems. Therefore, in cooperation with EPA Regions and NPDES States,
we have developed the definition of significant noncompliance as an
administrative tool for providing this focus. The Office of Legal
and Enforcement Counsel has also cooperated in and concurred with
the development of this guidance.
Attached is the draft definition of significant noncompliance.
This definition will be used to identify those permit violations
which are of sufficient magnitude and/or duration to be considered
of major concern to the regulatory agency, to report national levels"
of compliance in the NPDES program, and to evaluate the progress of
the NPDES program.
Previously, separate definitions were used to prepare the
Quarterly Noncompliance Report (QNCR), to report national non-
compliance levels and to review the progress of the NPDES program.
Unfortunately, these separate definitions produced different levels
of compliance and frequently included violations which were insigni-
ficant. The definition of significant noncompliance should resolve
these previous problems because: 1) the definition will be used for
all reporting of noncompliance in the NPDES program; and, 2) the
definition allows the regulatory agency to list all instances of
noncompliance which are considered to be of major concern.
-------
The definition represents a consensus of the comments received
from NPDES States and EPA Regional offices. We wish to thank you
all for your time and cooperation in developing this definition.
Many commenters recommended that we modify the NPDES
regulations pertaining to reporting noncompliance (40 CRF 122.18)
to incorporate this definition. These modifications have been
included in the draft regulations which will receive public
comment. The definition of significant noncompliance will become
final when the final regulations are published. In the interim
period, you may wish to compare the compliance levels obtained using
the definition of significant noncompliance with those obtained
using the current QNCR regulations. This experience should assist
the transition between definitions and provide a basis for valuable
comments on the draft definition.
The Permit Compliance System is being updated to include
automated methods to screen self-monitoring data for instances of
significant noncompliance. These methods will be based on the
definition of significant noncompliance. We will advise you when
this option is available.
Attachment
cc: Regional Counsel
Water Management Division Directors
-------
DEFINITION OF SIGNIFICANT NONCOMPLIANCE
IN THE NPDES PROGRAM
A definition of significant noncompliance is needed for the
NPDES program to provide consistent information on the compliance
status of permitted facilities and to evaluate changes in compliance
status. This definition will be used as part of the administrative
procedure for screening NPDES self-monitoring data and reporting
instances of noncompliance which are of major concern to the
r.^yulatory agency.
It is important to note that any violation of an NPDES permit
is a violation of the Clean Water Act (CWA) for which the permittee
is strictly liable. The designation of "significant noncompliance"
indicates a violation is of sufficient magnitude and/or duration to
be considered among the regulatory agency's priorities for regula-
tory review and/or response. An agency's decision as to what
enforcement action, if any, should be taken in such cases must be
based on an analysis of all of the facts and relevant legal
provisions involved in any particular case.
The categories of significant noncompliance are: violations of
requirements resulting from previous enforcement action, violations
of permit effluent limits, and violations of permit compliance
schedules. Any unauthorized discharge or bypass considered signifi-
cant by the NPDES Program Director (or Designee) will also be
reported as significant noncompliance. Additionally, the Director
of an NPDES program may designate any instance of noncompliance
which he/she considers to be significant.
The regulatory agency reserves the right to take any action
against NPDES permit violations as prescribed by the CWA regardless
oE whether it is or can be defined as significant noncompliance.
This right also applies to any procedures or policies developed to
implement the definition of significant noncompliance.
I. Violations of Previous Enforcement Actions
Violation of a requirement imposed in an enforcement action
such as a consent decree or administrative order, except as noted
below, is considered to be significant noncompliance.
-------
II. Violations of Compliance Schedules
Schedule violations, including portions of 309(a)(5)(A) orders
which pertain to compliance schedules, can be classified as "signi-
ficant" for both POTWs and non-POTWs. Assessing the status of
compliance of non-POTWs is a relatively straightforward matter
because there are fewer variables involved in their construction pro-
grams than for POTWs. For those POTWs which rely upon the Federal
construction grants process to assist in funding, the entire grant
process (including planning, design, and construction) must be
reviewed to determine if the municipal facility is making acceptable
or unacceptable progress. If a POTW facility is making unacceptable
progress, its noncorapliance is considered significant. For POTWs not
in the Federal grants process and non-POTWs, schedule violations
which have not been resolved (returned to compliance with schedule
requirements) within 90 days are considered to be significant
noncompliance.
III. Violations of Permit Effluent Limits
Cases of significant noncompliance for permit effluent limits
are defined according to the magnitude and/or duration of the
violation. Effluent violations should be evaluated on a parameter-
by-parameter and outfall-by-outfall basis. Three subcategories
have been created for effluent violations, as follows:
a. Effluent Criteria for Single Events and Short-Term
Limits
Single event violations (i.e., of daily maximum limits) and
short term violations (i.e., of seven-day averages) are discre-
tionary with respect to their designation as significant noncorapli-
ance. Generally, however, any permit violation is significant
which has the potential to cause or has actually caused adverse
environmental effects, (e.g., fish kills, oil sheens) or poses a
human health hazard (e.g., spills of carcinogenic, radioactive or
mutagenic substances). The Director also may consider the
significance of violations detected during compliance inspections
by using a single event criterion.
-------
b. Effluent Criteria for the Magnitude and Duration of
Monthly Average Permit Limits
Significant noncompliance for monthly average limitations is
based on exceeding Technical Review Criteria (TRC) (magnitude) for a
specified time period (duration). The TRC's are for two groups:
Group I - Inorganic and Oxygen
Demanding Pollutants TRC=1.4
(such as BOD, COD, TSS,
nutrients)
Group II - Toxic Pollutants TRC=1.2
(such as heavy metals, cyanide,
and organics)
The duration is evaluated for any consecutive six months. For
all permittees, significant noncompliance is exceedance of the TRC
for the monthly average for any two months in a six-month period.
c. Effluent Criteria for Chronic Violations
In some cases, a permittee .will constantly violate the monthly
average permit limit but not exceed the TRC. These chronic viola-
tions would be considered significant noncompliance if the monthly
average permit limit were exceeded any four months in a six-month
period.
-------
GROUP I - Inorganic and Oxygen Demanding Pollutants TRO1.4
Oxygen Demand Minerals
Biochemical Oxygen Demand Calcium
Chemical Oxygen Demand Chloride
Total Oxygen Demands Fluoride
Total Organic Carbon Magnesium
Other • Sodium
Potassium
Solids Sulfur
Sulfate
Total Suspended Solids (Residues) Total Alkalinity
Total Dissolved Solids (Residues) Total Hardness
Other Other Minerals
Nutrients
Metals
Phosphorus Compounds
Nitrogen Compounds Aluminum
Other Cobalt
Iron
Detergents and Oil Vanadium
MBAS
NTA
Oil and Grease
Other detergents or algicides
Group II - Toxic Pollutants TRC=1.2
Heavy Metals (all forms)
Antimony
Arsenic
Beryllium
Cadmium
Chromium
Copper
Lead
Nickel
Mercury
Selenium
Silver
Thallium
Zinc
Inorganic (nonconventional)
Cyanide
Total Residual Chlorine
All Organics except those specifically listed in Group I.
The criteria for fecal coliforra violations are discretionary.
-------
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REG10N m
6TH AND WALNUT STREETS
PHILADELPHIA. PENNSYLVANIA 19106
In Reply Refer To: 3WM52
UA* 1 S 1983
Mr. C. T. Beechwood
Regional Water Quality Manager
PA Dept. of Environmental Resources
1875 New Hope Street
Nbrristown, PA 19401
Dear Mr. Beechwood:
This letter is to confirm our plans to visit your office on March 29
and 30, 1983. We may also want to return on April 1 if we are unable
to conplete our reviews.
We plan to discuss with your staff the major facilities listed on the
most recent QNCR. Of particular concern are the following:
County
PA0026646 Antietam Valley Mun. Auth. Berks
PA0024180 Berks-Montgomery Mun. Auth. Montgomery
PA0026042 Bethlehem City Northampton
PA0026450 Bristol Twp. Authority Bucks
PA0025917 Chalfont - New Britain Jt. S.A. Bucks
PA0027103 DELCORA Delaware
PA0026531 Downingtown STP Chester
PA0026948 Falls Township Authority Bucks
PA0026247 Hatfield Twp. M.A. Montgomery
PA0026701 Morrisville Borough M.A. Bucks
PA0027421 Norristown Boro Montgomery
PA0020290 Quakertown Boro Bucks
PA0026549 Reading City Berks
PA0027383 Southwest Delaware Co. M.A. Delaware
PA0027031 West Chester - Goose Creek Chester
PA0026018 West Chester - Taylor Run Chester
PA0011371 Baldwin Hardware Manuf. Corp. Berks
PA0022047 Cronpton & Knowles Corp. Berks
PA0012823 PP & L Martins Creek Northampton
PA0013315 Publicker Dist. - Div. Continental Philadelphia
-------
We also plan to review the files for the following minor municipal facilities
which have been funded under public law 92-500 and have been certified
complete by the Corps of Engineers:
County
PA0070351 Amity Township M.A. Berks
PA0022543 Bally Municipal Authority Berks
PA0023540 Berks-Montgomery Mun. Auth. Berks
PAOO24376 Boyertcwn Boro Berks
PA0070424 Caernarvon Berks
PA0024422 Lower Salford Township Montgomery
PA0070254 . Lynn Township Sanitary Auth. Lehigh
PA0070271 .. Maidencreek Township M.A. Berks
PA0020699 Montgomery W & S Lycoming
PA0044776 Northwestern Chester County Chester
PA0024961 Oley Township M.A. Berks
PA0024074 Shoemakersville M.A. Berks
PA0020711 Topton Boro M.A. Berks
At random we selected the following minor facilities for file review during
our visit:
Primary Industrial Minors
PAOO12033 ^Valley Paper Mills Modena Plant Chester
PA0012017 iXAllied Corp. - FXD Plant Philadelphia
PAOO11045 ./Pycofoam Corp., Norristown Montgomery
PA0012980 iSG.O. Carlson, Inc. - Viaduct Plant Chester
PA0051080 v~ Thompson-CSF Components Corp. Montgomery
J?A00124?5 £>£lMST ED Portland tffrJ&sz. • — Northampton—
PA0050369 \/Unitog Company Bucks
Secondary Industrial Minors
PA0070106 v Exxon. Company, Tuckerton Terminal Berks
PA0070416 i^Conrail-Beth Diesel Terminal Northampton
PA0050296 v/Monarch Development Corp. Montgomery
PA0050687 i^Bethayres Valley Apts. Montgomery
PA0029912 i/ Embreeville State Hospital Chester
PA0070319 V Reading-Berks Joint Fire Training Berks
-------
Municipal Minors
PA0020231
PA0028355
PA0051004
PA0070149
PA0041742
V Hatfield Boro
{/"Eddys-tone Boro
/"Lcwer Salford Township
\^
\
.
-------
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION III
Gn-i AND WALNUT STREETS
PHILADELPHIA. PENNSYLVANIA lO'CG
In Reply Refer To: 3WM52
Mr. Lawrence A. Pawlush
Regional Water Quality Manager
PA Dept. of Environmental Resources
90 East Union Street - 2nd Floor
P.O. Box 659
Wilkes-Barre, PA 18701
Dear Mr. Pawlush:
This letter will confirm our planned visit to your office on April 5, 6
and 7, 1983.
We plan to discuss with your staff the following major facilities listed
on the most recent QNCR.
PA0028576
PA0026221
PA0020168
PA0026921
PA0027065
PA0027090
PA0029017
PA0026492
PA0012742
PA0044920
PA0012963
PA0008231
PA0010987
Clarks Summit - S. Abington Jt
Sanitary Authority
Dallas Area Mun. Auth.
Stroudsburg Boro
Greater Hazleton Joint S.A.
Lackawanna River Basin S-A.
Lackawanna River Basin S-A.
Schuylkill Haven Mun. Auth.
Scranton City S.A.
Atlas Powder Co.
Lehighton Electronics Inc.
Packaging Corp. of America
Penn Dye & Finishing Co., Inc.
Tobyhanna Army Depot
County
Lackawanna
Luzerne
Monroe
Luzerne
Lackawanna
Lackawanna
Schuylkill
Lackawanna
Schuylkill
Carbon
Monroe
Schuylkill
Monroe
We also plan to review the files for the following municipalities which
have been funded under public law 92-500 and which are certified by the
Corps of Engineers as being complete:
PA0042048
PA0021873
PA0020915
PA0046272
Conygam Boro Authority
Jim Thorpe Mun. Authority
Pine Grove Boro Authority
Porter-Tower Joint Authority
Luzerne
Carbon
Schuylkill
Schuylkill
-------
PA0043044
PA0042951
PA0023736
PA0020940
PA0046353
Ringtown Boro
Tremont Municipal Authority
Tri Boro Municipal Authority
Tunkhannock Boro M.A.
Waymart M.A.
County
Schuylkill
Schuylkill
Susquehanna
Wyoming
Wayne
At random we selected the following minor facilities for file review:
Primary Industrial Minors
/ County .
PA0008907
00702^03
PA0060381
PA0070009
PA0060194
PA0041076
PA0020494
PA0029025
PA0060330
PA0070386
Harte Company, Inc
i|-T£X nrt-i-^> f*.
Secondary Industrial Minors
v Wyoming County Commissioners
"""Cove Ski Village *•&&>&
S Blue Ridge School District
v/ PA State Police - Swiftwater
Station
Minor Municipals
t/Lehighton Boro
i/Clarks Green
v Hawley Area Authority
[/' Shenandoah Mun. Authority
Luzerne
''Scli
Wyoming ' i
c=>- Schuylkill ~\
Susquehanna
Monroe
Carbon
Lackawanna
Wayne
Schuylkill
Our file review will also include the following federal facilities which
are in noncompliance either due to effluent violations or failure to
submit discharge monitoring reports:
PA0010987
• / Tobyhanna Army Depot
Tobyhanna Army Depot
Sincerely yours,
ORIGIN A« SIGNED BY
Joseph Davis, Chief
PA Section
Water Permits Branch
Water Management Division
cc: Paul J. Koval, Wilkes-Barre, DER
iner/dl :T(
3WM52 /,.'
Monroe1
Monroe
&,-
v-n I
Y"&-
-------
I
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION III
6TH AND WALNUT STREETS
PHILADELPHIA. PENNSYLVANIA 19106
In Reply Refer To: 3WM52
!/,AR < 3 liwo
Mr. James T. Flesher
Acting Water Quality Manager
PA Dept. of Environemntal Resources
407 South Cameron Street
Harrisburg, PA 17120
Dear Mr. Flesher:
As you know, we will be visiting your office on April 12, 13 and 14, 1983.
We plan to discuss with your staff the following major facilities which
were listed on the QNCR.
1. Altoona City Auth. - East PA0027014
2. Altoona City Auth. - West PA0027022
3. Qiambersburg Borough PA0026051
4. Ephrata Borough PA0027405
5. Hampden Township Sewer Auth. PA0028746
6. Hanover Boro Authority PA0026875
7. Lancaster City Sewer Auth. - North PA0026719
8. Lancaster City Sewer Auth. - South PA0026743
9. Lititz Sewer Authority PA0020320
10. Myerstown Boro Sewer Authority PA0021075
11. Palmyra Boro Authority PA0024287
12. Penn Township PA0037150
13. Swatara Township Authority PA0026735
14. Tyrone Boro PA0026727
15. Washington Twp. Mun. Authority PA0080225
16. York City Sewer Authority PA0026263
17. Appleton Papers PA0008265
18. Bethlehem Steel - Steelton PA0008303
19. Consolidated Rail Corp. - Enola PA0009229
20. Itt - Grinnell PA0080195
21. Holly Milk Co-operative PA0044911
22. Lancaster Metal Science Corp. PA0080063
23. Musselman's, MFP, Inc. PA0008770
24. United Piece Dye Works PA0009172
25. Wyeth Laboratories, Inc. PA0013862
26. Letterkenny Army Depot PA0010502
-------
We also plan to review the files of those minor municipal facilities which
have been funded under Public Law 92-500. In these cases construction has
been certified as completed by the Corps of Engineers.
Public Law 92-500 Minor Municipal Facilities
1. Freedom Township W.S.A.
2. McVeytown Boro
3. Millerstown Mun. Auth.
4. Mt. Union Mun. Auth.
5. New Oxford Mun. Auth.
6. N. Lancaster County Auth.
7. Petersburg Boro
8. Reading Twp. Mun. Auth.
9. S. Middleton TVp. Mun. Auth.
10. Thompsontown Mun. Auth.
11. York Springs Mun. Auth.
12. Alexandria Boro, Porter
Township S.W.
13. Annville Township
14. Antrim Twp. Mun. Auth.
15. Hamiltonban Township
/PA0110361
•/PA0028993
1/PA0021849
/PA0020923
"PA0080438
V/-PA0111350
/ PA0036889
/PA0044113
i/ PA0111422
»/• PA0043567
^ PA0043443
/PA0021806
V/PA0080519
I/PA0040304
Blair County
Mifflin County
Perry County
Huntington County
Adams County
Lancaster County
Huntington County
Adams County
Cumberland County
Juniata County
Adams County
Huntington County
Lebanon County
Franklin County
Adams County
At random, we selected the following minor facilities for file review during
our visit:
Primary Industry Minor Facilities
1. Kiniberly-Clark Corp.
Mt. Holly
2. National Standard Co.
3. Bowen McLaughlin York Co.
4. Safe Harbor
iXfA0008150
t^">PA0009253
1/PA0032379
Cumberland County
Lancaster County
York County
Lancaster County
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W3" ^
y tA • £,
-"
Secondary Industrial Minor Facilities
3.
4.
5.
6.
Mt. Pannell Fisheries
CAF..Cprp... Ghormian Plant
Walnut Steam Heat Plant
Minuet Manor Motel &
Restaurant
Mt. View Elementary School
Youth Development Center
l/ PAQ042030
V-PAQ009059
1/^0008427
/PA0032891
/PA0030201
V/PA0030261
Franklin County
Adams County—
Dauphin County
Blair County
Franklin County
Perry County
-T^y^&2x6>fi&!^/S<£^^
2-. 6ROFFS POTATO r/. Municipal Minor Facilities ^~^
1.
2.
3.
4.
5.
6.
7.
Roaring Springs Boro
Newport Borb. Mun. Auth.
Mt.- Holly Springs Boro Auth.
Upper Allen Twp. Auth.
Bellyood Boro
Burnhain Boro Sewer Plant
Hampden Twp. Sewer Auth.
iXPA0020249
^/PA0021237
/ PA0023183
i^PA0024902
/ PA0028240
•/PA0038920
V PA0080314
1.
2.
Letterkenny Army Depot
US Army Seven Points
Federal Facilities
'""^ /PA0010502
/ PA0039748
Sincerely yours,
ORIGINAL SIGNED .;V
J. DAVi?
Joseph Davis, Chief
Pennsylvania Section
Water Permits Branch
Water Management Division
Blair County'
Perry County
Cumberland County
Cumberland County
Blair County
Mifflin County
Cumberland County
Franklin County
Huntington County
Symbol
3WM52
Su
•v/ .'•'. -
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1 SS/v $ UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
-
REGION 'I!
' or-: AND VvALN'JT STREETS
In Reply Refer To: 3WM52
Mr. William P. Parsons
Regional Water Quality Manager
PA Dept. of Environmental Resources
200 Pine Street
Williamsport, PA 17701
Dear Mr. Parsons:
As you know, we will be visiting your office on March 24, 1983 and March
25, 1983. We plan to discuss with your staff the major facilities
listed on the most recent QNCR. The following table is a listing of
those facilities.
Facilities- On--QN€R
1.
2.
3.
4.
5.
6.
7.
8.
9.
10.
11.
12.
13.
14.
PA0043681
PA0020486
PA0023248
PA0027375
PA0025933
PA0020273
PA0037966
PA0026557
PA0026239
PA0021687
PA0009024
PA0009300
PA0010031
PA0008800
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At random, we selected the following minor facilities for file review during
our visit.
1. PA0009661
2. PA0035467
1.
2.
v/ 3.
/4.
5.
PA0013871
PA0014575
PA0033316
PA0031381
PAD 11 1406
1. PA0020338
2. PA0023582
3. PA0028100
4. PA0043419
5. PA0111414
Primary Industrial Minor'Facilities
Radiation Process
Creative Playthings
Secondary Industrial Minor Facilities
fl
Protein Co.
i/Jersey Shore Water
i/ Pine Crest Village
X State Correctional
tXMaria Joseph Manor
Municipal Minor Facilities
^/Kulpmont Boro _.
//Freeburg Boro -
iXturbiotvllle Boro
•^Coudersport Boro
i/McEwensville Municipal Authority w
Our file review will also include federal facilities which are in
noncompliance. This noncompliance may be due to effluent violations or
failure to submit discharge monitoring reports.
Federal Facilities In Noncompliance
1. PA0039241
2. PA0040371
3. PA0046094
4. PA0060062
,
i/ All
enwood Prison Camp Sewer Area
* *
U.S'. Penitentiary, Lewisburg - // ?
a - Hammond Lake - Ives Run ST ///
.S. Dept. Labor Red Rock- Job Cor // 3
- • •
We look forward to our visit and our meeting with you and your staff.
Sincerely yours,
/(1 /' 4 ^
/, . / <->
i to,/ A
Joseph/Davis, Chief
Pennsylvania Section
Water Permits Branch
Water Management Division
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In Reply Refer Tb:
8 J963
Mr. Stephen F. Pedersen, Water Quality Manager
Pennsylvania Bepartnsnt of Environmental Resources
600 Kbssman Building
100 Ebrbes Avenue
Pittsburgh, PA 15222
Dear Mr. Pedersen:
As you know, we will be visiting your office on March 14, 1983
through March 17, 1983. We plan to discuss with your staff
the major facilities listed on the most recent CNCR. The
following table is a listing of those facilities.
Major Facilities on QNCR
Canonsburg-Houston Joint Authority
Hanpfield Township Municipal Authority
City of Johnstown
Latrobe Municipal Authority
Monaca Borough Municipal Authority
Montour Township Municipal Authority
Mt. Pleasant Municipal Authority
New Brighton Sanitary Authority
Muncipality of Penn Hills
Pleasant Hills Authority
Shade-Central City
Washington-E.Washington Authority
Duquesne Light Philips
Duquesne Slag Product Go.
Mill Service, Inc. Yukon Plant
Pennsylvania Electric Corpany Homer City
Pennsylvania Electric Germany Bruce Mansfield
ftobertshaw Fulton Cccpany New Station
Shenango Incorporated Neville Coke & Iron
U. S. Steel Corporation Duquesne Works
1.
2.
3.
4.
5.
6.
7.
o
tw •
9.
10.
11.
11.
13.
14.
15.
16.
17.
18.
19.
20.
PA25941
PA38181
PA26034
PA26069
PA20125
PA28801
PA21148
PA26026
PA26395
PA27464
PA25810
PA26212
PA01619
PA0427S
PA27715
PA05037
PA27481
PA02305
PA02437
PA04464
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-2-
We also plan to review the files of those minor municipal
facilities which have been funded under Public Law 92-500. In
these cases construction has been certified as conpleted by the
Corps of Engineers.
Public Law 92-500 Minor Municipal Facilities
PA3S792
PA45926
PA46230
PA?0140
PA36609
PA23159
PA23673
PA42749
PA24481
10.PA21407
11.PA41441
12.PA22331
Mams Township
Allegheny Township
Carmichaels - Cumberland Joint Authority
Clyxner Borough
Conway Itonicipal Authority
Cresent S. Heights
Gallitzin Borough
Jenner Area Joint Sewer Authority
Meyersdale - "
Qoro Point Marion Sanitary Authority
Somerset Township - Wells CK Area
West Elizabeth
Vanport Township Ifttnicipal Authority
Unity lownship Municipal Authority
At randan, we selected the following minor facilities for
file review during our visit.
('"•/•
Primary Industrial Minor facilities ^ /. -
1. PA5673 •' Union Canp Co.
2. PA43C8;.-'^ Eidemiller Enterprises
3. PA2593-" 7 Teledyne-Scottdale
4. PA3000 •>'" II. H. Robertson -v
5. PA0761 *- Baboock & Wilcox ~ ''<:-< '-» -<.<*• I*J~^
14.PA92247;
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-3-
1. PA00621" •'"
2. PA92002-
3. PA92045 •<-
4. E&32152 .--
5. PA33871 '••
6. PA90417 I-'
7. PA34762 -
S. PA93114 i'-
1. PA20656 •
2. PA22365<-r
3. PA2452C •-
4. PA25500 - r
5. PA27651 -
6. PA29700.-'
7. PA37818 *-• C
\/ B. PA39489 - ;
107
11. PA92355 - - '"
12. PA110469- -r
Seoonday Industrial Minor Facilities
B & O Railroad — ~
Covenant Qiristian QiurcJi
Stantoi Enterprises
Hills of Mingo Mobile Estates
Mars Associates
Albert F. Milauskas
Chio Ttownslup Elementary Scixaol
Indiana Co. Housing Authority
Municipal Minor Facilities C, _«.,. v -.-
Mewell Municipal Authority
Perryopolis Municipal Authority
^£u^ianna Doro
Lilly Boro
Vfest Newton Boro
New Eagle Boro 2.yt>'£ - t'/c-
Saltsburg Boro
Garrett Boro
North Strabane Ttwnship
Richland Township
Bellevernon Municipal Authority
Boro of Patton
/r
V,'e lock ferward to our visit and our meeting with you and
your staff.
Sincerely,
ORIGINAL SIGNED BY
J. DAVIS
Joseph Davis, Chief
Pennsylvania Section
Water Management Division
-------
UNITED STATES ENVIRONMENT
"V~" +*' " ' - REGION ;!!
- -,ac't /
X ,' .-• 5TH AND vVALfiU~ :
' '' PHILADELPHIA. PEV•.=••".
In Reply Refer^.To>" 3WM52
Mr. James E. Erb
Regional Water Quality Manager
PA Dept. of Environmental Resources
1012 Water Street
Meadville, PA 16335
Dear Mr. Erb:
As you know, we will be visiting your office on March 22, 1983 and
March 23, 1983. We plan to discuss with your staff the major facilities
listed on the most recent QNCR. The following table is a listing of
those facilities.
Major Facilities On QNCR
1.. PA0026697 Butler Area STP Authority
2. PA0028223 City of Corry
3. PA002457-1. . Cranberry Twp. S &- W- Authority .
4. PA0021792 Edinboro Borough Municipal Authority
5. PA0026832 Ellwood City Borough STP
6. PA0020257 Grove City Borough
7. PA0027511 New Castle Sanitary Authority
8. PA0026204 City of Oil City
9. PA0020346 Punxsutawney Municipal Sewage
10. PA0023213 Ridgway Municipal Authority
11. PA0003026 Abex Corporation
12. PA0006343 Armco Steel Corporation
13. PA0000183 • General Electric Co. - Erie
14. PA0033367 Gunnison Brothers, Inc.
15. PA0001970 Koppers Company Inc. - Oil City
We also plan to review the files of those minor municipal facilities which
have been funded under public law 92-500. In these cases construction has
been certified as completed by the Corps of Engineers.
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-2r
Public Law 92-500 Minor Municipal Facilities
1. PA0028941
2. PA0046426
3. PA0028274
4. PA0046418
5. PA0041831
6. PA0024511
7. PA0029122
8. PA0036064
Evansburg Municipal Sanitary Auth.
Franklin Township Sanitary Authority
New Wilmington
Middleboro Municipal Authority
Northwest Crawford County
Redbank Valley Municipal Authority
Saxonburg Area Authority
Washington Township W & S.A.
At random we selected the following minor facilities for file review during
our visit.
Primary-industrial Minor Facilities
Air Products & CHem
Reactive Metals & Alloys
Rockwell Intl - Truck Axle
Gallaghers Laundromat
Secondary IndustrialJlinor Facilities
Architectual Div - Penndot
Kev_in L. Martin
- Jack's Development Co.
R.K. Campground
Robison School
Pymatuning Labs
Municipal Minor Facilities
Jenks Township
Mount Jewett Boro
Port Allegheny
Brockway Boro
Middleboro Municipal Authority
Bloomfield Township
Our file review will also Include federal facrlttfes which are in
noncompliance. This noncompliance may be due to effluent violations or
failure to submit discharge monitoring reports.
1.
2.
3.
4.
1.
2.
3.
4.
5.
6.
1.
2.
3.
4.
5.
6.
PA0001252
PA0014494
PA0003174
PA0003646
PA0032778
PA01 00692
PA0031780
PA0035017
PA0101214
PA0033821
PA0020133
PA0023451
PA0025739
PA0028428
PA0046418
PA01 00960
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-3-
Federal Facilities In Noncompliance
1.
2.
3.
4.
5.
6.
7.
PA0024970
PA0025097
PA0025534
PA0025542
PA0025551
PA0037117
PA0043834
U.S. Corps of Eng. - Shenn
U.S. Corps of Eng. ^ Woodcock
U.S. Forest Service - Kiasutha
U.S. Forest Service - Kinzua Beach
U.S. Forest Service Dewdrop Camp-
Blue Jay Center, USDA
U.S. Army - COE r Shenango Beach
We look forward to our vtsit and our meeting with your staff.
Sincerely yours,
ORIGINAL SIGNED BY
J. DAVIS
Joseph Davis, Chief
Pennsylvania Section
Water Permits Branch
Water Management Division
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