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EPA REGION 10 Enforcement and Compliance Assurance Division INSPECTION REPORT Inspection Entry Date/Time Inspection Exit Date/Time Weather Media Statute(s)/Program(s) Type of Inspection 01/28/2025 9:16 AM (PT) Announced: Yes 01/28/2025 1:10 PM (PT) Access: Granted 55F, Sunny Water Clean Water Act, NPDES, WWTP Compliance Evaluation Inspection Permittee Name Facility Name Facility Physical Address City, State, Zip Code County Facility GPS Coordinates Lummi Indian Business Council Gooseberry Point WWTP 2156 Lummi View Drive Bellingham, Washington 98226 Whatcom 48.72023, -122.65417 FRS ID Permit Number SIC 110013724942 WA0025666 4952 (Sewerage Systems) Lead Inspector: RAYMOND ANDREWS Date: 2025.02.25 14:03:26 -08'00' Digitally signed by RAYMOND ANDREWS Raymond Andrews EPA Region 10 andrews.raymond@epa.gov (206) 553-4252 Supervisor Review: Contreras, Peter Peter Contreras EPA Region 10 Digitally signed by Contreras, Peter Date: 2025.02.25 15:20:47 -08'00' contreras.peter@epa.gov (206) 553-6708 Page 1 of 6 Gooseberry Point WWTP Permit # WA0025666 SECTION I - Opening Conference EPA REGION 10 Lead Inspector, Raymond Andrews, arrived at the Gooseberry Point WWTP ("Facility"), located at 2156 Lummi View Drive, Bellingham, Washington, at 9:16 AM (PT) on 01/28/2025 for an announced inspection. I presented my credentials to Daniel Jeffries, Lead Operator, and informed him I was there to conduct an inspection to determine the facility's compliance with the Clean Water Act (CWA) and its National Pollutant Discharge Elimination System (NPDES) permit, permit # WA0025666. This report is based on information supplied by Mr. Jeffries, my direct observations, and records and reports maintained by the permittee. In addition, information gathered prior to or after the Inspection from a review of EPA, State, and/or public records may be included in this report. This is the second of three inspections I conducted on Lummi Tribal wastewater treatment facilities. The Gooseberry Point Wastewater Treatment Plant's permit became effective on December 1, 2011, and expired on November 30, 2016. The facility's permit has been administratively extended since its expiration. The Gooseberry Point WWTP maintains the tribal laboratory that conducts the in-house analysis for specific parameters for all three facilities. Attendees Organization Attendee Name Title Present in Present in Opening Conf. Closing Conf. EPA Region 10 Raymond Andrews Lead Inspector Yes Yes Lummi Tribal Sewer Daniel Jeffries Lead Operator Yes Yes and Water District Facility Information Responsible Official? Jim Heigzman, District Manager, jimh@ltswd.com How many employees The Lummi Sewer and Water District ("District") shares three employees does the facility have? between its three facilities. Of the District's three employees, two hold level one certifications and the third is in training. What is the facility's There is an operator on site six hours per day Monday through Friday, and an operation schedule? hour per day on the weekends with a person on-call for holidays. What is the facility's The facility services approximately 3,000 residents. service population? What is the facility's design capacity and average daily flow? The facility has a design capacity of 0.375 million gallons per day (mgd), and an average daily flow of 0.300 mgd. What is the facility's primary flow measuring device? The facility uses two Magmeters to measure flow, one at the influent and one at the effluent. How often is the flow The manufacturer specifications state the magmeters do not require measuring device calibration. calibrated? What is the facility's The facility discharges directly into Puget Sound. receiving water? How many outfalls The facility has a single outfall. does the facility have? Page 2 of 6 Gooseberry Point WWTP Permit # WA0025666 How often is the outfall inspected? The outfall is not visually inspected because the outfall pipe is under water and extends approximately 100 yards into the Sound. Where do you sample The influent is sampled prior to the headworks. The effluent is sampled after influent? Effluent? UV disinfection at the last point before the effluent leaves the facility. Are water samples analyzed in-house or sent out to a contract laboratory? The facility analyzes total suspended solids (TSS), biological oxygen demand (BOD), fecal coliform, dissolved oxygen (DO), pH, and temperature in-house. A contract laboratory analyzes water samples for total Kjeldahl nitrogen (TKN), ammonia and total nitrate + nitrites (N+N). Laboratory contact information. Edge Analytical 805 Orchard Drive Suite 4 Bellingham, Washington 98225 (360) 715-1212 How are biosolids managed? Biosolids are processed through a digester and are then picked up by a 3rd party contractor and disposed of on an as-needed basis. Does the facility have The facility uses a supervisory control and data acquisition (SCADA) system to a failure alarm? How monitor the facility. If the system detects a failure, it sends an automated is an alarm alarm message to the on-call operator. addressed? Does the facility have The entire facility is on back-up power. The back-up power automatically back-up power? activates if the system detects a loss of main power. What is the facility's overflow/emergency capacity? The facility does not have an emergency or overflow capacity. Are there any industrial users? The facility does not have any industrial users. Are there shared or contributing jurisdictions? There are no shared jurisdictions. Does the facility accept waste from septage haulers? The facility does not accept waste from septage haulers. Has the facility had In 2021, there was an overflow in the UV chamber. The wastewater was any bypasses or pumped out into the Puget Sound and EPA was notified. hydraulic overloads in the past 5-years? Has the facility been renovated or upgraded in the last 5-years? In 2021, the facility added a digester, additional primary and secondary clarifiers, a rotary screen for solids, and a grit classifier to the headwork. Are there any plans to Currently, the District has no plans to upgrade the system. renovate or upgrade the facility? SECTION II - Observations There were no observations made of operations that were an Area of Concern. 3 of 6 SECTION III - Records Review Records may not be in sequential order. Record: Other - Operations and Maintenance Plan Ref #: RA1-RR-005 Reviewed By: Raymond Andrews Gooseberry Point WWTP Permit # WA0025666 AOC: Yes Reviewed Date: 01/28/2025 At the time of the inspection, I requested to review the facility's Operations & Maintenance (O&M) Plan. The facility did not have an O&M Plan. Record: Other - EPA's Integrated Compliance Information System (ICIS) Database AOC: Yes Ref #: RA1-RR-004 Reviewed By: Raymond Andrews Reviewed Date: 02/13/2025 Post inspection, I reviewed information submitted by the facility to EPA's Integrated Compliance Information System (ICIS) Database for the time period from February 2020 through January 2025. I found the facility was late in submitting DMR data and exceeded effluent limitations 455 times over a nine-month period. Tables showing the late DMR data and effluent exceedances are included in Appendix 2. Data in ICIS shows the facility was under an Administrative Compliance Order (ACO) which was initiated in 2002 and closed in 2022; however, ICIS also indicated EPA never received the facility's Annual Reports for 2020 and 2021 or the construction compliance schedule required by the ACO. Since the ACO has been closed, I do not consider these as areas of concern. Record: DMR Reports AOC: No Ref #: RA1-RR-003 Reviewed By: Raymond Andrews Reviewed Date: 02/13/2025 Post inspection, I reviewed facility Discharge Monitoring Reports (DMRs) from January 2022 through December 2024. I did not note any areas of concern. Record: Other - Emergency Response and Public Notification Plan AOC: Yes Ref #: RA1-RR-002 Reviewed By: Raymond Andrews Reviewed Date: 01/28/2025 At the time of inspection, I reviewed the facility's Emergency Response and Public Notification Plan (ERPN). The Gooseberry Point facility uses the same ERPN plan as the Sandy Point facility, which I inspected first. After my inspection of the Sandy Point facility, the contacts were updated. However, the other areas of concern were still present. The plan was undated, and it did not explain how notification of the public would be carried out. The Plan did not explain how emergency operations would be carried out. Record: Other - Quality Assurance Plan AOC: Yes Ref #: RA1-RR-001 Reviewed By: Raymond Andrews Reviewed Date: 01/28/2025 At the time of the inspection, I reviewed the Quality Assurance Plan (QAP), dated March 7, 2016. The QAP needs an update. There is no indication the QAP was reviewed annually. The QAP was not prepared in the required format. The QAP did not contain the minimum requirements, I.e., it was missing: Details on the number of samples, type of sample containers, preservation of samples, holding times, analytical methods, analytical detection and quantitation limits for each target compound, type and number of quality assurance field samples, precision and accuracy requirements, sample preparation requirements, sample shipping methods, and laboratory data delivery requirements. Map(s) indicating the location of each sampling point. Qualification and training of personnel. Name(s), address(es) and telephone number(s) of the laboratories used by the Permittee. 4 of 6 SECTION IV - Sampling Activity No sampling was conducted. Gooseberry Point WWTP Permit # WA0025666 SECTION V - Areas of Concern Areas of Concern may not be in sequential order. The presentation of Areas of Concern does not constitute a formal compliance determination or violation. AOC Reference #: RA1-RR-004 Records Review: Other - EPA's Integrated Compliance Information System (ICIS) Database Permit Requirement Part I.B.1 of the Permit states, in part, "The permittee must limit and monitor discharges from outfall 001 as specified in Table 1...The permittee must comply with the effluent limits in the tables at all times..." AOC: The facility exceeded effluent limitations 455 times over a nine-month period. The effluent exceedances are list in a table in Appendix 2. AOC Reference #: RA1-RR-004 Records Review: Other - EPA's Integrated Compliance Information System (ICIS) Database Permit Requirement Part III.B of the Permit states, in part, "The Permittee must summarize monitoring results each month on the Discharge Monitoring Report (DMR) form..." AOC: The facility was late in submitting DMR data. The late data is in a table in Appendix 2. AOC Reference #: RA1-RR-002 Records Review: Other - Emergency Response and Public Notification Plan Permit Requirement Part II.E.1.c of the Permit states, at a minimum, the ERPN must, in part, "Ensure immediate notification to the public..." AOC: The Emergency Response and Public Notification (ERPN) plan did not explain how notification of the public would be carried out. AOC Reference #: RA1-RR-002 Records Review: Other - Emergency Response and Public Notification Plan Permit Requirement Part II.E.1.e of the Permit states, at a minimum, the ERPN must, "Provide emergency operations." AOC: The Plan did not explain how emergency operations would be carried out. AOC Reference #: RA1-RR-001 Records Review: Other - Quality Assurance Plan Permit Requirement Part II.C of the Permit states, in part, "The Permittee must also certify to EPA that the QAP is being implemented and is reviewed with staff annually. Annual reviews will be registered with EPA by submittal of the staff attendance sheet used for the review sessions, along with a cover letter confirming the QAP review and identifying the enclosed attendance record. The annual QAP review letter and attendance sheet must be submitted with the January DMR of each subsequent year." AOC: There was no documentation the QAP was reviewed annually. 5 of 6 AOC Reference #: RA1-RR-001 Gooseberry Point WWTP Permit # WA0025666 Records Review: Other - Quality Assurance Plan Permit Requirement Part II.C.6 of the Permit states, "Throughout all sample collection and analysis activities, the Permittee must use the EPA-approved QA/QC and chain-of-custody procedures described in the most recent versions of Requirements for Quality Assurance Project Plans (EPA/QA/R-5) and Guidance for Quality Assurance Project Plans (EPA/QA/G-5). The QAP must be prepared in the format that is specified in these documents." AOC: The QAP was not prepared per the reference documents "Requirements for Quality Assurance Project Plans (EPA/QA/R-5)" and "Guidance for Quality Assurance Project Plans (EPA/QA/G-5)". AOC Reference #: RA1-RR-001 Records Review: Other - Quality Assurance Plan Permit Requirement Part II.C.7 of the Permit states, "At a minimum, the QAP must include the following: a) Details on the number of samples, type of sample containers, preservation of samples, holding times, analytical methods, analytical detection and quantitation limits for each target compound, type and number of quality assurance field samples, precision and accuracy requirements, sample preparation requirements, sample shipping methods, and laboratory data delivery requirements. b) Map(s) indicating the location of each sampling point. c) Qualification and training of personnel. d) Name(s), address(es) and telephone number(s) of the laboratories used by or proposed to be used by the Permittee." AOC: The QAP was missing all elements required in Part II.C.7 of the Permit. AOC Reference #: RA1-RR-005 Records Review: Other - Operations and Maintenance Plan Permit Requirement Part II.B of the permit states, in part, "...by 180 days after the effective date of this permit, the Permittee must provide written notice to EPA that an operations and maintenance plan for the wastewater treatment facility has been developed and implemented. The plan must be kept up to date as changes occur in operation and maintenance of the wastewater treatment facility. The plan must be retained on site and made available upon request to EPA." AOC: The facility did not have an O&M Plan. SECTION VI - Closing Conference I held a closing conference with Mr. Jeffries 1:10 PM (PT) on 01/28/2025 for the inspection. During the closing conference, I discussed the observations and Areas of Concern identified during the inspection. Observations and Areas of Concern have not yet been evaluated for a formal compliance determination. SECTION VII - List of Appendices 1. Photo Log 2. Document Log 6 of 6 APPENDIX 1: Photo Log Emergency Response and Public Notification Plan 01/28/2025 10:22 AM No CBI No PII 48.73446708, -122.64995295 Page 1 of ERPN Plan IMG-2025012810220422478403.jpg Photographer: Raymond Andrews Emergency Response and Public Notification Plan 01/28/2025 10:22 AM No CBI No PII 48.73481651, -122.64983842 Page 2 of ERPN Plan IMG-20250128102223222374002.jpg Photographer: Raymond Andrews Fecal coliform Bench sheet 01/28/2025 11:01 AM No CBI 48.72017288, -122.65440978 No PII IMG-2025012811013213258999.jpg Photographer: Raymond Andrews PH Bench Sheet 01/28/2025 11:01 AM No CBI 48.72017288, -122.65440978 No PII IMG-2025012811015915964625.jpg Photographer: Raymond Andrews DO and Temp Bench Sheet 01/28/2025 11:02 AM No CBI 48.72017288, -122.65440978 No PII IMG-2025012811021021056172.jpg Photographer: Raymond Andrews Influent Auto Sampler IMG-20250128110639639109207.jpg 01/28/2025 11:06 AM No CBI No PII Photographer: Raymond Andrews 48.72020074, -122.65444511 The influent sampler takes flow proportional samples. Note: The back-up thermometer is to the left of the collection jar. Influent Entry Point 01/28/2025 11:07 AM No CBI No PII 48.72018713, -122.65449924 Influent enters plant though the three pipes. IMG-2025012811072772792174.jpg Photographer: Raymond Andrews Influent headworks screens 01/28/2025 11:08 AM No CBI 48.72029661, -122.65473908 No PII IMG-20250128110834834117198.jpg Photographer: Raymond Andrews Two Primary Clarifiers IMG-202501281111251125102954.jpg 01/28/2025 11:11 AM No CBI No PII Photographer: Raymond Andrews 48.72017425, -122.65447494 The clarifier on the left is not currently in operation because the capacity is not needed. Stabilization Basin 01/28/2025 11:13 AM No CBI 48.7201118, -122.65502426 No PII IMG-20250128111304134127078.jpg Photographer: Raymond Andrews Third Secondary Clarifier IMG-202501281116581658119208.jpg 01/28/2025 11:16 AM No CBI No PII Photographer: Raymond Andrews 48.71990485, -122.65523274 The third secondary clarifier is a new upgrade. All three clarifiers may be used if the additional capacity is needed. UV Disinfection Chamber 01/28/2025 11:18 AM No CBI 48.72018986, -122.65448633 No PII IMG-202501281118491849119591.jpg Photographer: Raymond Andrews Effluent Auto Sampler IMG-20250128112105215119225.jpg 01/28/2025 11:21 AM No CBI No PII Photographer: Raymond Andrews 48.72002605, -122.65563574 The effluent sampler and takes flow proportional samples. Note: The back-up thermometer is to the left of the collection jar. APPENDIX 2: Areas of Concern Tables Month Feb 2023 Feb 2023 Mar 2023 Aug 2023 Oct 2023 Oct 2023 Dec 2023 Dec 2023 Jan 2024 Jan 2024 Jan 2024 Feb 2024 Feb 2024 May 2024 Oct 2024 Parameter TSS Solids, susp % rmv Solids, susp % rmv BOD, 5-day, % rmv BOD, 5-day, % rmv Solids, susp % rmv BOD, 5-day, % rmv Solids, susp % rmv BOD, 5-day, 20C BOD, 5-day, % rmv Solids, susp % rmv BOD, 5-day, % rmv Solids, susp % rmv Solids, susp % rmv BOD, 5-day, % rmv Effluent Exceedances DMR Value 32 76 71 81 80 81 79 82 95 70 48 77 76 79 84 Permit Limit 30 85 85 85 85 85 85 85 94 85 85 85 85 85 85 Unit mg/L % % % % % % % lb/d % % % % % % Limit Type Mo Avg Mo Av Mn Mo Av Mn Mo Av Mn Mo Av Mn Mo Av Mn Mo Av Mn Mo Av Mn Mo Avg Mo Av Mn Mo Av Mn Mo Av Mn Mo Av Mn Mo Av Mn Mo Av Mn # Violations 28 28 31 31 31 31 31 31 31 31 31 29 29 31 31 Monitoring Period End Date December 31, 2021 May 31, 2021 November 30, 2020 August 31, 2020 August 31, 2020 August 31, 2020 Late DMR Parameters DMR Due Date January 10, 2022 June 10, 2021 December 10, 2020 September 10, 2020 September 10, 2020 September 10, 2020 Parameter Temp, water C Oil & Grease Oil & Grease Oxygen, dissolved Oil & Grease Solids, total dissolved DMR Value Received Date January 17, 2022 June 16, 2021 December 15, 2020 October 16, 2020 October 16, 2020 October 16, 2020