Hudspeth county Merco
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TNRCC Compliance Review Inspection Report MERCO site
3/17/99

Compliance Report Page 4

Above is a photo copy of TNRCC Compliance Review Inspection Report for the MERCO site dated March 17, 1999. The excerpted paragraphs are from page 4 & 5 of the report. The text of those paragraphs are detailed below.

Below are links to the scanned images of the TNRCC Compliance Review Inspection Report. The gif images of each page of the report average about 20kb.

Page 1, Page 2,
Page 3, Page 4, Page 5,

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G. OTHER COMMENTS:
(x) Applicable ( ) N/A

In September 1998 and November 1998, New York City Department of Environmental Protection (New York City DEP) certified to MERCO Joint Venture (MERCO) shipments of biosolids from Bowery Bay WWTP and North River WWTP as meeting PSRP requirements. MERCO land applied the biosolids from Bowery Bay WWTP from September 29, 1998 to October 5, 1998. New York City DEP notified MERCO on December 3, 1998 that they received nine containers from Bowery Bay that did not meet PSRP as previously reported. On January 26, 1999, MERCO informed New York City DEP that there was a discrepancy between the monthly PSRP certification for November 1998 and the weekly certification for November 16, 1998 to November 22, 1998. New York City DEP confirmed the error to MERCO that the biosolids from North River WWTP should not have been certified as meeting PSRP. (See Attachment 3 and Attachment 4)

In both incidents, MERCO took samples from the land applied biosolids and analyzed it from fecal coliform. All samples met the fecal coliform requirement or less than 2 million CFU.

The regional office is concerned that New York city DEP is not reporting to MERCO in a timely fashion when there are discrepancies with the PSRP certification.

On March 17, 1999, Tom Gillane, Operations Manager for MERCO was informed that the regional office is concerned with New York City DEP reporting procedures. During the exit interview, Mr. Gillane was informed that the regional office is recommending that all biosolids from New York City be lime stabilized by MERCO regardless of their PSRP certification.

H. REGIONAL OFFICE ACTION TAKEN:
(x) Applicable ( )N/A

The regional office is recommending to MERCO to lime stabilize all biosolids received from New York City DEP regardless of PSRP certification. In addition, the regional office will be notifying EPA Region 2 of these two incidents involving New York City DEP and the possible noncompliance with 40CFR 503 requirements. A copy of the notification to EPA Region 2 will also be sent to EPA Region 6 for their information.

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