Document 2JoBKE74ogJQB8Ldw8YVmww35
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION 8 1595 Wynkoop Street Denver, CO 80202-1129 Phone 800-227-8917 www.epa.gov/region08
Ref: 8 Montana
CERTIFIED MAIL RETURN RECEIPT REQUESTED
Denny Larson Wild Horse Hot Springs P.O. Box 629 Hot Springs, Montana 59845
Re: Inspection Report for Wild Horse Hot Springs (MTU000713)
Dear Mr. Larson:
On June 13, 2022, representatives of the U.S. Environmental Protection Agency and Confederated Salish & Kootenai Tribes inspected the Wild Horse Hot Springs wastewater lagoon in Hot Springs, Montana, to evaluate compliance with the Clean Water Act and EPA regulations. The inspection was conducted under the authority of Section 308 of the Clean Water Act (Act). Enclosed is a report of the inspection.
Inspection findings are summarized within the enclosed inspection report in a table titled "Findings, Corrective Actions and Recommendations." Within thirty (30) days of receipt of this report, please provide the EPA with a summary of corrective actions taken to address each of the findings identified in the report and any information that may change the findings or content of the report. This summary should be sent to:
Lisa-kay Prideaux EPA Region 8 Prideaux.Lisakay@epa.gov
Wilhelmina Keenan CSKT Environmental Director Willie.keenan@CSKT.org
Please contact me at 406-457-2055 or Prideaux.lisakay@epa.gov if you have any questions regarding this letter or the enclosed report.
Sincerely,
Prideaux, LisaKay
Digitally signed by Prideaux, LisaKay Date: 2022.07.29 10:38:03 -06'00'
Lisa-kay Prideaux NPDES and Wetlands Enforcement Section Enforcement and Compliance Assurance Division
Enclosures: 1) NPDES Inspection Report 2) Photo Log
cc (electronic): The Honorable Tom McDonald, Chairman, CSKT (email) Wilhelmina Keenan, Environmental Director, CSKT (email) Evan Smith, Water Quality Regulatory Specialist, CSKT (email)
NPDES Inspection Report
National Database Information
Inspection Date: June 13, 2022
Inspection Type: Reconnaissance Inspection
Entry/Exit Time: 09:02 / 09:34
NPDES ID Number: MTU000713
NAICS Code: 713990 - All other Amusement & Recreation Industries
Inspection ID: 201906_MTU000713
Lead inspector and affiliation: Lisa-kay Prideaux, U.S. EPA Montana Operations Office
Inspector and affiliation:
Inspector and affiliation:
Facility Location Information
Site/Facility Name & Location: Wild Horse Hot Springs 175 Camp Aqua Road, Hot Springs, Montana Flathead Reservation 47.640435N; -114.572539W
Mail Report to: Dennis Larson P.O. Box 629 Hot Springs, MT 59845
Contact Information Facility Contacts:
Name(s)/Title Dennis Larson, Wild Horse Hot Springs, owner (not present) Vicky Tuer, Wild Horse Hot Springs, desk clerk (present)
Person/Company meeting definition of "Owner" Authorized Official(s)
Tribe Representative(s)
Indian Health Service Representative(s)
Dennis Larson, Owner, Wild Horse Hot Springs
Dennis Larson, Owner, Wild Horse Hot Springs Evan Smith, Water Quality Regulatory Specialist, Confederated Salish & Kootenai Tribes (present) None present
Permit Information
Is the permit on site and available? N/A Lagoon Category: N/A
Monitoring Frequency: N/A
Effective Date: Unpermitted
Expiration Date: Unpermitted Is the Facility under a
compliance schedule? N/A
Is correct contact information indicated on ICIS?
Indicate correct contact information:
Receiving Water(s): Wetland complex to the Little Bitterroot River Discharge point location (longitude, latitude): 47.640435N; -114.572539W
Wild Horse Hot Springs
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Regulatory Inspector's source of information: Aerial imagery, EPA records, facility personnel, and site review.
Areas Evaluated During Inspection
Permit
Effluent/Receiving Waters
Records/Reports
Flow Measurement
Facility Site Review
Monitoring Program
Collection System Review
Lagoon Self- Inspections
Compliance Schedule
Discharge Monitoring Reports
Lift Station Operation and Maintenance
Preventive and Emergency Operation and Maintenance
Report Review and Signature Drafter Signature/Name
Address/Phone Number
U.S. EPA Region 8, Montana Operations Office 10 West 15th Street, Suite 3200 Helena, Montana 59626
Lisa-kay Prideaux Management Signature/Name
Boeglin, Michael
Digitally signed by Boeglin, Michael Date: 2022.07.29 08:32:33 -06'00'
Michael Boeglin
406-457-5022 Address/Phone Number U.S. EPA Region 8 1595 Wynkoop Street 8ENF-W-NW Denver, Colorado 80202 303-312-6250
Date 07.26.2022 Date 07.29.2022
Wild Horse Hot Springs
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Inspection Narrative and Site Description
On Monday, June 13, 2022, U.S. Environmental Protection Agency (EPA) inspector Lisa-kay Prideaux, and the Water Quality Regulatory Specialist for the Confederated Salish Kootenai Tribes, Evan Smith, conducted an unannounced inspection to evaluate compliance with the Clean Water Act and EPA regulations. The inspection commenced at approximately 09:00, when Lisa-kay and Evan arrived at the facility, presented credentials and identification, and asked to meet with the owner. Vicky Tuer, Wild Horse Hot Springs desk clerk stated that Mr. Dennis Larson was the owner and that he was not on-site at the time. EPA asked if we could have her answer some questions and show us around the site. Ms. Tuer called Mr. Larson to receive permission to assist us in our inspection. Throughout the inspection, observations and photograph descriptions were documented. All photographs taken during the inspection are included in the attached photo log.
The Wild Horse Hot Springs (facility) is a 10-acre site with on-site cabins, RV spots, public restrooms/changing rooms, and 14 hot pools. Water for the pools is provided by 3 on-site wells flowing at approximately 1,200 gallons per minute. All water from the wells is conveyed to the pools, public restrooms, and outdoor showers only. No water or sewer is provided to the on-site cabins or RV pads. Sewer from the public restrooms goes to an on-site septic and leach field system.
The hot pools range in size and temperature; the hot well water is approximately 120C, with the cooler water coming in at approximately 90C. Each pool receives water from the well, or combination of wells through a pipe(s) (photo 509), then flows out through an overflow pipe (photo 509); there is no chemical treatment of the water. The mineral type and content naturally occuring in the water is the attraction for the facility. The overflow water from the pools enters into a piping system which discharges to a ditch entering a large wetland complex (photo 510). Overflow water from the wells (water not used in the pools) is also discharged through the same ditch into the wetland complex (photo 511). The wetland complex is connected to the Little Bitterroot River to the east of the facility. At the time of the inspection, some of the pools were being cleaned. The process for cleaning was explained as draining the pool by taking the pool overflow pipe riser off, the pool is power washed with a hose and brushed down then the riser is replaced so the pool fills again. No chemicals are used during the cleaning process. Half of the pools are cleaned each day.
During the closing conference, Ms. Tuer provided a brochure with a list of the minerals (photo 508). I explained a report of the inspection and photo documentation would be mailed to Mr. Larson.
Findings, Corrective Actions and Recommendations
Finding #1: The Wild Horse Hot Springs is discharging without a permit. Specifically, the facility has an established point source which discharges pollutants into navigable waters.
Clean Water Act Requirements: x The Clean Water Act states it is unlawful to discharge any pollutant from a point source into navigable waters, unless a permit is obtained. x Section 502 of the Clean Water Act defines the term "point source" as any discernible, confined and discrete conveyance, including but not limited to any pipe, ditch, channel, tunnel, conduit, well, discrete fissure, container, rolling stock, concentrated animal feeding operation, or vessel or other floating craft, from which pollutants are or may be discharged.
Wild Horse Hot Springs
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x Section 502 of the Clean Water Act defines the term "discharge of a pollutant" as any addition of any pollutant to navigable waters from any point source.
x Section 502 of the Clean Water Act defines the term "pollutant" as dredged spoil, solid waste, incinerator residue, sewage, garbage, sewage sludge, munitions, chemical wastes, biological materials, radioactive materials, heat, wrecked or discarded equipment, rock, sand, cellar dirt and industrial, municipal, and agricultural waste discharged into water.
Discharge Location: x The point source discharge is located at 47.640411N; -114.572531W x The facility discharges into a wetland complex which is directly connected to the Little Bitterroot River, which connects to the Flathead River.
Corrective Action: Within 30 days of receipt of this report, Wild Horse Hot Springs is required to submit an application for coverage under the National Pollutant Elimination Discharge System (NPDES) permit program.
Wild Horse Hot Springs
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