U.S.  ENVIRONMENTAL PROTECTION  AGENCY
                            PENNSYLVANIA MINOR DISCHARGER
                            NPDES COMPLIANCE AUDIT 1983
MIDDLE ATLANTIC REGION-III  6th and Walnut Streets, Philadelphia, Pennsylvania 19106

-------
        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

-------
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

-------
                             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

-------
                    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

-------
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

-------
PENNSYLVANIA MINOR DISCHARGER
 NPDES COMPLIANCE AUDIT 1983
                                July 28, 1983

-------
                                  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.

-------
                             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.

-------
                             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.

-------
                             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.

-------
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.

-------
                           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.

-------
Appendix 1
  GRAPHS

-------
                   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

-------
                       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

-------
                         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

-------
Appendix 2




  TABLES

-------
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

-------
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

-------
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

-------
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

-------
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

-------
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

-------
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

-------
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

-------
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

-------
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

-------
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

-------
                                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/ .'•'. -

-------
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
 
-------
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

-------
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

-------
                              -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;

-------
                              -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.

-------
                                      -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

-------
                                      -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

-------