Document 5LVwxMjRv5GjY02Re5KYad8J8

NPDES Compliance Inspection Report City of Othello Sewer Treatment Plant Othello, Washington Permit #: WA0022357 Inspection Date: May 5, 2021 Prepared by: Jon Klemesrud U.S. Environmental Protection Agency, Region 10 Enforcement & Compliance Assurance Division Water Enforcement & Field Branch Field, Data & Drinking Water Enforcement Section Signature/Date: Klemesrud, Jon Supervisor Signature/Date: Contreras, Peter Digitally signed by Klemesrud, Jon Date: 2021.07.26 15:13:18 -07'00' Digitally signed by Contreras, Peter Date: 2021.07.27 08:19:49 -07'00' NPDES WA0022357 City of Othello STP 2021 Inspection Report Contents I. Facility Information ............................................................................................................ 3 II. Inspection Information........................................................................................................ 4 III. Permit Information.............................................................................................................. 4 IV. Background ..................................................................................................................... 5 V. Inspection Chronology........................................................................................................ 5 VI. Opening Conference ........................................................................................................... 6 VII. Site Review ..................................................................................................................... 6 VIII. File Review ..................................................................................................................... 8 IX. Areas of Concern ................................................................................................................ 8 A. Effluent Limit Exceedances............................................................................................. 8 B. Facility Loading.....................................................................................8 C. Effluent Disinfection........................................................................................................ 9 D. Recording Elements of pH and Dissolved Oxygen Monitoring .................................... 10 X. Closing Conference........................................................................................................... 10 ATTACHMENT A - Aerial Image (Google Earth) ATTACHMENT B - May 3, 2018 Status Report ATTACHMENT C - March 12, 2021 Warning Letter ATTACHMENT D - April 7, 2021 Response to Warning Letter ATTACHMENT E - Photograph Log ATTACHMENT F - May 1, 2021 - December 1, 2017 Effluent Limit Exceedances Page 2 of 37 NPDES WA0022357 City of Othello STP 2021 Inspection Report (All details in this report were obtained through conversations with Jim Laird, Terry Clements, Sam Harris, Sam Bise, Geena Dorow, John Patrouch or from observations made during the inspection.) I. Facility Information Facility Name: City of Othello Sewer Treatment Plant (Othello STP) Facility Owner/Operator: City of Othello Physical Address: 2302 Cunningham Road Othello, Washington 99344 Lat/Long: 46.825201, -119.226015 Mailing Address: 500 E. Main Street Othello, Washington 99344 NAICS Code: SIC Code: 221320 (Sewage Treatment Facilities) 4952 (Sewerage Systems) Facility Contacts: Jim Laird, Lead Operator City of Othello Public Works Office Phone: (509) 488-6997 Email: jlaird@othellowa.gov Terry Clements, Director City of Othello Public Works Office Phone: (509) 488-6997 Email: tclements@othellowa.gov Shawn Logan, Mayor City of Othello Office Phone: (509) 488-5686 Email: slogan@othellowa.gov Sam Harris, Operations Staff City of Othello Public Works Office Phone (509) 488-6997 Email: sharris@othellowa.gov Sam Bise, Operations Staff City of Othello Public Works Office Phone (509) 488-6997 Email: sbise@othellowa.gov Genna Dorow, City Council Member City of Othello Page 3 of 37 NPDES WA0022357 City of Othello STP 2021 Inspection Report II. III. IV. John Patrouch, PE, Varela Engineering and Management Office Phone: (509) 328-6066 jpatrouch@varela-engr.com Permit Number: WA0022357 Receiving Water: Owl Creek Inspection Information Inspection Date: May 5, 2021 Inspectors: Jon Klemesrud, Inspector EPA Region 10, ECAD /FDDWES Other Individuals: Art Jenkins, PE, Permit Unit Supervisor Water Quality Program, Eastern Regional Office Washington Department of Ecology Arrival Time: 10:00 AM Departure Time: 12:45 PM Purpose: To determine facility compliance with the Clean Water Act and the State of Washington National Pollutant Discharge Elimination System (NPDES) Waste Discharge Permit. Permit Information The City of Othello Sewer Treatment Plant ("Facility") is permitted under Washington Department of Ecology (Ecology) National Pollutant Discharge Elimination System (NPDES) Waste Discharge Permit # WA0022357. The Facility's permit became effective on October 1, 2020 and is due to expire on September 30, 2025. Prior to October 1, 2020, the facility was covered under the previous version of Permit # WA0022357 which was administratively continued after it expired on December 31, 2013. The 2020 permit includes a Compliance Schedule which requires disinfection of the effluent, several studies intended to characterize the receiving water (Owl Creek), determine groundwater impacts, characterize effluent parameters, and estimate the amount of collection system inflow and infiltration entering the treatment system. The permit contains interim discharge limits as well as final discharge limits that will become effective October 1, 2030. Background The City of Othello owns and operates the 80-acre facultative lagoon wastewater treatment system located on the western edge of the city limits. An aerial image is attached to this report (Attachment A) for a general footprint. The current 5 lagoon system has been in operation since 1981. The Page 4 of 37 NPDES WA0022357 City of Othello STP 2021 Inspection Report sanitary sewer collection system was installed in 1955. Othello has an estimated resident population of 8,386 (2019 U.S Census). The Facility has an average daily flow of 1.5 million gallons per day (MGD) and discharges continuously throughout the year. In addition to the municipal wastewater, the collection system receives a seasonal flow of 80,000 gallons per day (GPD) (approx.) from a single industrial user (local juice processor) SVZ, USA. The flow from SVZ, USA is primarily municipal wastewater but also includes food processing wastewater. Peak flow from SVZ occurs during the month of September, the collection agreement began in 2017. No septage is accepted at the Facility. According to EPA's Enforcement and Compliance History Online (ECHO), the Facility is in a significant non-compliance (SNC) status based on continued/historic effluent limit violations. The Facility was last inspected by Ecology on November 29, 2017. On May 3, 2018, Othello provided a status report (Attachment B) to address compliance concerns that were identified during the 2017 Ecology inspection. On March 12, 2021, the Facility was issued a Warning Letter (Attachment C) by Ecology for 6 months of permit violations for effluent limit exceedances of biochemical oxygen demand, TSS, pH, dissolved oxygen, and fecal coliform. On April 7, 2021 the Facility submitted a response to the March 12, 2021 Warning Letter (Attachment D). The response provided a summary of the reported violations, an explanation of the causes, and the steps planned to prevent future violations. V. Inspection Chronology This was an announced inspection. On April 26, 2021, I spoke with Mr. Jim Laird, Othello Public Works Lead Operator, I stated that I'd been asked to conduct an NPDES compliance inspection of the Othello STP, in coordination with Ecology. We agreed to meet at the Public Works Office on May 4, 2021, at 10:00am. We discussed that I would be joined on the inspection by Mr. Art Jenkins of Ecology. Once arrived at the Public Works Office on May 4th, 2021, Art Jenkins and I met with Facility representatives in the parking lot to begin the inspection. The inspection included an opening conference, a walk-through of the treatment system and in-house laboratory, a records review, and a closing conference. For the walk-through, we observed general operations, process flow, sampling locations, the inhouse laboratory and single outfall. We were allowed to inspect all areas requested. The record review occurred inside the small office building located at the Facility, portions of the record review occurred post-inspection. The closing conference occurred following our observation of the outfall and took place outside of the small office building. During the closing conference, I discussed my observations from the walkthrough and from the initial records review. I also provided a copy of EPA's Small Business Resource Information Sheet and an EPA WWTP Compliance Advisory Handout. Page 5 of 37 VI. VII. NPDES WA0022357 City of Othello STP 2021 Inspection Report Opening Conference The opening conference was held outside of the Public Works Office shortly after our arrival. In addition to Mr. Laird, we were also joined by facility representatives Mr. Clements, Mrs. Dorow, Mr. Harris, and Mr. Bise. We had our initial introductions, I provided a business card and presented my EPA credentials to the group. I discussed the purpose and expectations of the inspection. During the opening conference, Mr. Laird provided general information about current Facility operations and recent improvement projects. Mr. Laird has been an operator at the WWTP for approximately 15 years, he holds a current Level II wastewater treatment certification that expires on December 31, 2021. In addition to Mr. Laird, wastewater operations are currently supported by Mr. Harris and Mr. Bise. The Facility is also in an agreement with Mrs. Dorow, an Othello Council Member who hold a Level IV certification and is assisting in recent planning and updates. According to the Facility, Ecology's Andy O'Neil (Technical Assistance Provider) and Diana Washington (Permit Manager) are also contacted as needed for support relating to operations and compliance. Site Inspection Following the opening conference, we drove to the headworks of the treatment system to being our facility walk-through. Photographs taken during the walk-through used in this inspection report, including a complete photo log appears in Attachment E. For the entire walk-through, we were joined by Mr. Laird, Mr. Clements, Mrs. Dorow, Mr. Harris, and Mr. Bise. Facility consultant Mr. John Patrouch of Varela Engineering and Management (Varela) arrived shortly after beginning the walk-through and was present throughout the remainder of the inspection. According to the Facility, Varela, as well as Esvelt Environmental Engineering has been contracted to focus on improvements capable of meeting the interim discharge limits associated with the new permit. Wastewater collection and treatment at the Facility consist of the following processes: 1. Gravity flow collection to a splitter box at the headworks 2. Two primary lagoons (Pond 1a and Pond 1b) 3. Open channel with a coarse screening 4. Cascade aeration channel (concrete step aerator) 5. Two secondary treatment/facultative lagoons (Pond 2 and Pond 3) 6. Polishing pond (Pond 4) 7. Chlorine contact chamber (inactive) 8. Discharge to Owl Creek via underground pipe (outfall 001) Our walk-through began at the headworks, the Facility had an influent flow rate of 1.1 MGD. Flow is recorded via a Teledyne ISCO 4210 Ultrasonic Flow Meter (Photo 1 and Photo 2). The influent meter was recently calibrated/certified on March 24, 2021 by Whitney Equipment Company Inc. (WECI). Influent composite samples required by the permit are taken by a ISCO 3710 refrigerated sampler (Photo 3) located near the headworks. Page 6 of 37 NPDES WA0022357 City of Othello STP 2021 Inspection Report Influent flow is routed to a splitter box which distributes flow to two primary lagoons (Pond 1a and Pond 1b) (Photo 4). The primary lagoons discharge to an open channel (Photo 5) with a coarse screen/grate located at the end of channel near the headworks (Photo 6). According to the facility, screenings are manually collected off the screen and open channel at least once a day if not more frequently. Removed screenings are collected in covered bins and sent to the local landfill. After screening, flow can be directed back to the primary lagoons or can enter the cascade aeration channel (concrete step aerator) (Photo 7) to the two facultative secondary treatment lagoons (Pond 2 and Pond 3). Pond 3 gravity flows into the final polishing lagoon (Pond 4). According to the facility, the lagoon system has a retention time of approximately 180 days. From Pond 4, water is routed to an unused chlorine contact chamber (Photo 8). According to the Facility, water passes through the chamber but is not disinfected. The Facility has not disinfected their effluent in over 15 years due to the chlorination equipment having been removed after portions were no longer operable. Effluent composite samples are taken by an ISCO refrigerated sampler (Photo 9) at the end of the chlorine contact chamber. Effluent is then discharged to Owl Creek through an underground pipe (Photo 10). Owl Creek discharges into Lower Crab Creek approximately 10 miles downstream of the discharge point. Effluent flow is recorded by an ISCO 4230 Bubbler Flow Meter (Photo 11), at the time of inspection effluent flow metered at 0.72 MGD. The effluent flow meter was also calibrated/certified on March 24, 2021 by Whitney Equipment Company Inc. (WECI). The Facility has an in-house laboratory setup in a small office building near the chlorine contact chamber and west of Pond 3. Disolved Oxygen (DO) and pH are analyzed in-house by Facility staff. The on-site laboratory was last accredited for the analyzed parameters by Quality Control Services in Portland, Oregon on April 13, 2021. In preparation for the Facility's new disinfection system, the inhouse laboratory also received accreditation for their spectrophotometer, used for monitoring/reporting Total Residual Chlorine. Calibration reagents were current. The DO meter is calibrated daily, and the pH meter undergoes a 3-point calibration prior to each use. Calibration records are documented a corresponding notebook for each device. According to the Facility, effluent pH and DO is monitored three times a day until continuous monitoring equipment is installed as part of a disinfection system upgrade project. The project is scheduled for installation in September 2021. Mr. Laird stated that the Facility has received written approval from Ecology Permit Manager Dianna Washington for this interim frequency of pH and DO monitoring. Remaining monitoring parameters required 2/week or monthly by the permit (i.e. TSS, BOD5, Total Ammonia, Fecal Coliform) are analyzed by a local laboratory, Kuo Testing Laboratories located in Othello. Kuo Testing laboratories is Ecology certified laboratory. Monitoring results are submitted by the Facility to Ecology's Water Quality Permitting and Reporting Information System (PARIS). Page 7 of 37 NPDES WA0022357 City of Othello STP 2021 Inspection Report VIII. IX. File Review Following our walk-through of the lagoons system and on-site laboratory, I reviewed the following records and documents as part of this inspection: Operator Certification - James Laird - Group II certification # 7019, expiration of 12/31/21 Operation and Maintenance (O&M) Manual - last modified in March 1995, the manual was not reviewed at the time of inspection, but verified it was on-site. Plant Flow Plan (Diagram) DO/pH Bench Sheet Data Calibration Certification Laboratory Results and Discharge Monitoring Reports (DMRs) for months selected at random: January 2021, September 2020, March 2019, December 2018. Receiving Water Study: Trace Metals QAPP (Permit Condition S9. E.1) Design Basis, Plans & Specifications for Disinfection System (Permit Condition S9.A.1) Receiving Water Temperature Study QAPP (Permit Condition S9.D.1) Cyanide and Mercury Source Tracing in the Collection System QAPP (Permit Condition S11.A) Areas of Concern The following areas of concern were noted as part of this inspection: A. Effluent Limit Exceedances Part S1. A. of the permit states, "the discharge of any of the following pollutants more frequently than, or at a level in excess of, that identified an authorized by this permit violates the terms and conditions of this permit" According to Ecology's Water Quality Permitting and Reporting Information System (PARIS), since the last compliance inspection on November 29, 2017, the Facility has reported 284 effluent limit exceedances. Primarily the exceedances for pH, Fecal Coliform, biochemical oxygen demand (BOD) and total suspended solids (TSS). A summary of the reported effluent limit exceedances (May 1, 2021 - December 1, 2017) appears in Attachment F. According to the Facility, the cause of many of the exceedances are due to ongoing issues with infiltration/inflow (I/I). It is estimated that 200,000 gallons a day enter the treatment plant which has been diluting the treatment process. To evaluate/address (I/I), Othello contracted with American Leak Detection in February 2020 to conduct smoke testing of the collection system. 31 issues were identified from the testing that would allow stormwater in the sewer system. On March 24, 2021, the Facility signed a contract with Planned and Engineered Construction, Inc for a sewer lining project in an effort to reduce the I/I. A copy of the contract was provided during the inspection, allocated funds for the sewer lining project amounted to $893,602.16. Page 8 of 37 NPDES WA0022357 City of Othello STP 2021 Inspection Report To limit TSS and pH exceedances, the Facility is exploring purchasing a surface agitator/diffuser to be used within Pond 4 and/or algaecide dosing. An ABASCO baffle curtain has been purchased for the effluent of Pond 4. The cost of the baffle was approximately $4,660 and Mr. Laird stated that it would hopefully be delivered in the coming week. The Facility is also in the process of obtaining quotes for installation of baffles and solar powered surface agitators for the primary lagoons (Pond 1a and Pond 1b) in an attempt to improve BOD and TSS removal. To address fecal coliform exceedances, the Facility has contracted for a new disinfection system (chlorination/dechlorination) to be operational by September 30, 2021 (a permit requirement). The project also includes continuous monitoring equipment for effluent chlorine residual, pH, and dissolved oxygen. B. Facility Loading Part S4.A of the Permit states that the flows or waste loads for the permitted facility must not exceed a Maximum Month Design Flow (MMDF) of 7.5 MGD and the maximum month influent loading for TSS and BOD of 2600 lb/day. According to Ecology's Water Quality Permitting and Reporting Information System (PARIS), since the last compliance inspection on November 29, 2017, the Facility has reported 8 facility design loading exceedances. The events are summarized in the table below: Date 01/01/2020 01/01/2020 12/01/2019 07/01/2019 07/01/2019 07/01/2019 06/01/2019 08/01/2018 Reported Value 3772 lbs/day (Average Monthly BOD) 2684 lbs/day (Average Monthly TSS) 2856 lbs/day (Average Monthly TSS) 3701 lbs/day (Average Monthly TSS) 2742 lbs/day (Average Monthly BOD) 14.593 MGD (Flow) 5340 lbs/day (Average Monthly BOD) 2723 lbs/day (Average Monthly TSS) C. Effluent Disinfection Part S5. of the permit states "the permittee must at all times properly operate and maintain all facilities and systems of treatment and control (and related appurtenances) that are installed to achieve compliance with the terms and conditions of this permit. As stated earlier in this report, effluent has not been disinfected in over 15 years and the chlorination equipment has been removed after it was no longer operable. The concern is that the Facility was designed/engineered for chlorination within the chlorine contact chamber as a method of disinfection and the process hasn't been operable resulting in fecal coliform effluent limit exceedances (as documented in Area of Concern A). Page 9 of 37 NPDES WA0022357 City of Othello STP 2021 Inspection Report According to the Facility, a new disinfection system including chlorination and dechlorination) is scheduled/contracted to be installed and operational by September 30, 2021. Part S.9.A of the permit states: "the permittee must begin disinfecting discharge by September 1, 2021 to the system and submit an electric notice of completion to Ecology when it is finished." D. Recording Elements of pH and Disolved Oxygen Monitoring Within Part S3. of the permit, it states for each measurement or sample taken, the Permittee must record: "1. The date, exact place, method, and time of sampling or measurement. 2. The individual who performed the sampling or measurement. 3. The dates the analyses were performed. 4. The individual who performed the analyses. 5. The analytical techniques or methods used. 6. The results of all analyses." At the time of inspection, it was noted that for pH and Dissolved Oxygen monitoring, the Facility was only recording the value and date of the monitoring/analyses. We discussed the permit requirement at the time of inspection and the Facility stated that they will begin recording all of the required monitoring elements moving forward. X. Closing Conference Following the walk-through of the Facility, a closing conference was held with Mr. Laird, Mr. Clements, Mrs. Dorow, Mr. Harris, and Mr. Bise. I discussed my inspection observations including Area of Concern A, C, D. I then thanked all representatives for their time and cooperation with the inspection. Page 10 of 37 NPDES WA0022357 City of Othello STP 2021 Inspection Report ATTACHMENT A Aerial Image (Google Earth) Page 11 of 37 NPDES WA0022357 City of Othello STP 2021 Inspection Report ATTACHMENT B May 3, 2018 Status Report Page 12 of 37 NPDES WA0022357 City of Othello STP 2021 Inspection Report Page 13 of 37 NPDES WA0022357 City of Othello STP 2021 Inspection Report Page 14 of 37 NPDES WA0022357 City of Othello STP 2021 Inspection Report ATTACHMENT C March 12, 2021 Warning Letter Page 15 of 37 NPDES WA0022357 City of Othello STP 2021 Inspection Report March 12, 2021 STATE OF WASHINGTON DEPARTMENT OF ECOLOGY 4601 N. Monroe Street Spokane, Washington 99205-1295 (509) 329-3400 The Honorable Shawn Logan City of Othello 500 East Main Street Othello, WA 99344 RE: Warning Letter for National Pollutant Discharge Elimination System Permit WA0022357 Dear Mayor Logan: The City of Othello is out of compliance with National Pollutant Discharge Elimination System (NPDES) permit WA0022357 that was issued August 21, 2020. For the past six months, the City of Othello has had numerous discharge monitoring report (DMR) violations, permit limit exceedances, and unreported or missing samples. Additionally, the City has failed to follow the requirements in Section S3 of their NPDES permit by not reporting violations to Ecology. Below is an explanation of the violations. 1. Effluent Limit Violations Between October 2020 and February 28, 2021, the City of Othello generated approximately 31 permit violations in the WQWebDMR databse for BOD5, TSS, pH, dissolved oxygen and fecal coliform. Section S1.A of the permit authorizes the discharge of municipal wastewater at the permitted location subject to compliance with effluent limitations set in the permit. 2. Reporting Noncompliance Section S3.F of the City of Othello's permit requires the facility to notify Ecology immediately when they violate or are unable to comply with permit conditions. They must follow up with a written report within five days that includes the description of the noncompliance and its cause and actions taken to prevent reoccurrence of noncompliance. The City of Othello has not reported permit violations to Ecology as required by Section S3.F. Each failure to report noncompliance constitutes a separate violation of the permit. Contact with the Facility The Department of Ecology had the following communications with the City of Othello regarding the permit violations. 9/29/2020 - Email from Ecology to facility discussing BOD samples and testing. 12/01/2020 - Email from Ecology to facility including permit language on reporting noncompliance and making notes on DMRs when violations occur. 03/11/2021 - Ecology email reponse to facility regarding February 2021 violations and reporting noncompliance. Page 16 of 37 The Honorable Shawn Logan City of Othello March 12, 2021 Page 2 of 4 NPDES WA0022357 City of Othello STP 2021 Inspection Report Within 30 days from receipt of this warning letter, please provide the following to Ecology: 1. Submit a written report explaining the cause of the violations identified in this letter. 2. Identify the steps taken to prevent future violations. Send the report electronically to Rob Buchert, Senior Compliance Specialist at rbuc461@ecy.wa.gov or by mail at Water Quality Program, Department of Ecology, 4601 N. Monroe Street, Spokane, Washington 99205-1265. This warning letter is to make you aware of the importance the Department of Ecology places on the legal implications of noncompliance with the limits, monitoring requirements, and terms and/or conditions established in your permit. Continued noncompliance will result in formal enforcement action by Ecology. Formal enforcement action may include Notice of Violation, Administrative Order, and Penalties of up to $10,000 per day per violation. Please contact the Region's wastewater operator technical assistance provider, Andy O'Neill at (509) 710-3676 or aone461@ecy.wa.gov if you need technical assistance or have questions about operator certification. Please contact me at (509) 209-1586 or Rob.Buchert@ecy.wa.gov if you have questions regarding this warning letter or Ecology's enforcement process. Sincerely, Rob Buchert Senior Compliance Specialist Water Quality Program Eastern Regional Office RB:sj cc. Terry Clements, City of Othello Jim Laird, City of Othello Shawn Obrien, City of Othello Diana Washington, PE, Ecology Permit Manager Eastern Region Andy O'Neill, Ecology Technical Assistance Eastern Region Art Jenkins, PE, Water Quality Permit Unit Supervisor Eastern Region Page 17 of 37 The Honorable Shawn Logan City of Othello March 12, 2021 Page 3 of 4 Table 1: Violations from October 2020 - February 2021 Monitoring Monitoring Monitoring Unit Month Point Parameter October 2020 001 BOD5 lbs/day 001 BOD5 mg/L 001 BOD5 Percent 001 Dissolved Oxygen mg/L 001 Fecal Coliform #/100 ml 001 pH s.u. 001 pH s.u. 001 November 2020 001 001 001 001 001 001 001 TSS pH pH pH pH pH pH BOD5 Percent s.u. s.u. s.u. s.u. s.u. s.u. Percent Statistical Base Avg. monthly Avg. monthly Avg. monthly Daily Sample Value Entered 400.678 37.3111 62.8 - Weekly geometric mean Daily sample 1113.91 - Daily sample - Avg. Monthly Daily sample Daily sample Daily sample Daily sample Daily sample Daily sample Daily sample 76 9.1 9.1 9.2 9.1 9.1 9.1 77.83 NPDES WA0022357 City of Othello STP 2021 Inspection Report Limit Type of Violation 390 Permit limit exceedance 30 Permit limit exceedance 85 Permit limit exceedance - Frequency of sampling violation 540 Permit limit exceedance - Frequency of sampling violation - Frequency of sampling violation 85 Permit limit exceedance 9 Permit limit exceedance 9 Permit limit exceedance 9 Permit limit exceedance 9 Permit limit exceedance 9 Permit limit exceedance 9 Permit limit exceedance 85 Permit limit exceedance Page 18 of 37 City of Othello March 12, 2021 Page 4 of 4 Monitoring Month December 2020 Monitoring Point Monitoring Parameter 001 TSS 001 BOD5 001 Dissolved Oxygen 001 Fecal Coliform 001 pH 001 pH 001 pH 001 pH 001 pH January 2021 001 TSS 001 BOD5 001 Fecal Coliform February 2021 001 TSS 001 BOD5 001 Fecal Coliform 001 TSS Unit Percent Percent mg/L #/100 ml s.u. s.u. s.u. s.u. s.u. Percent Percent #/100 ml Percent Percent #/100 ml Percent NPDES WA0022357 City of Othello STP The Honorable Shawn20L21oIgnsapnection Report Statistical Base Daily sample Avg. Monthly Daily sample Value Entered 60.775 79.3875 - Weekly geometric mean Daily sample 2419 - Single sample 9.1 Single sample 9.1 Single sample 9.1 Single sample - Avg. monthly Avg. monthly Weekly geometric mean Avg. monthly Avg. monthly Weekly geometric mean Avg. monthly 67.53 78.7 1440 78.4 81.8 2419 79.8 Limit Type of Violation 85 Permit limit exceedance 85 Permit limit exceedance - Frequency of sampling violation 540 Permit limit exceedance - Frequency of sampling violation 9 Permit limit exceedance 9 Permit limit exceedance 9 Permit limit exceedance - Frequency of sampling violation 85 Permit limit exceedance 85 Permit limit exceedance 540 Permit limit exceedance 85 Permit limit exceedance 85 Permit limit exceedance 540 Permit limit exceedance 85 Permit limit exceedance Page 19 of 37 NPDES WA0022357 City of Othello STP 2021 Inspection Report ATTACHMENT D April 7, 2021 Response to Warning Letter Page 20 of 37 NPDES WA0022357 City of Othello STP 2021 Inspection Report March 12, 2021 STATE OF WASHINGTON DEPARTMENT OF ECOLOGY 4601 N. Monroe Street Spokane, Washington 99205-1295 (509) 329-3400 The Honorable Shawn Logan City of Othello 500 East Main Street Othello, WA 99344 RE: Warning Letter for National Pollutant Discharge Elimination System Permit WA0022357 Dear Mayor Logan: The City of Othello is out of compliance with National Pollutant Discharge Elimination System (NPDES) permit WA0022357 that was issued August 21, 2020. For the past six months, the City of Othello has had numerous discharge monitoring report (DMR) violations, permit limit exceedances, and unreported or missing samples. Additionally, the City has failed to follow the requirements in Section S3 of their NPDES permit by not reporting violations to Ecology. Below is an explanation of the violations. 1. Effluent Limit Violations Between October 2020 and February 28, 2021, the City of Othello generated approximately 31 permit violations in the WQWebDMR databse for BOD5, TSS, pH, dissolved oxygen and fecal coliform. Section S1.A of the permit authorizes the discharge of municipal wastewater at the permitted location subject to compliance with effluent limitations set in the permit. 2. Reporting Noncompliance Section S3.F of the City of Othello's permit requires the facility to notify Ecology immediately when they violate or are unable to comply with permit conditions. They must follow up with a written report within five days that includes the description of the noncompliance and its cause and actions taken to prevent reoccurrence of noncompliance. The City of Othello has not reported permit violations to Ecology as required by Section S3.F. Each failure to report noncompliance constitutes a separate violation of the permit. Contact with the Facility The Department of Ecology had the following communications with the City of Othello regarding the permit violations. 9/29/2020 - Email from Ecology to facility discussing BOD samples and testing. 12/01/2020 - Email from Ecology to facility including permit language on reporting noncompliance and making notes on DMRs when violations occur. 03/11/2021 - Ecology email reponse to facility regarding February 2021 violations and reporting noncompliance. Page 21 of 37 The Honorable Shawn Logan City of Othello March 12, 2021 Page 2 of 4 NPDES WA0022357 City of Othello STP 2021 Inspection Report Within 30 days from receipt of this warning letter, please provide the following to Ecology: 1. Submit a written report explaining the cause of the violations identified in this letter. 2. Identify the steps taken to prevent future violations. Send the report electronically to Rob Buchert, Senior Compliance Specialist at rbuc461@ecy.wa.gov or by mail at Water Quality Program, Department of Ecology, 4601 N. Monroe Street, Spokane, Washington 99205-1265. This warning letter is to make you aware of the importance the Department of Ecology places on the legal implications of noncompliance with the limits, monitoring requirements, and terms and/or conditions established in your permit. Continued noncompliance will result in formal enforcement action by Ecology. Formal enforcement action may include Notice of Violation, Administrative Order, and Penalties of up to $10,000 per day per violation. Please contact the Region's wastewater operator technical assistance provider, Andy O'Neill at (509) 710-3676 or aone461@ecy.wa.gov if you need technical assistance or have questions about operator certification. Please contact me at (509) 209-1586 or Rob.Buchert@ecy.wa.gov if you have questions regarding this warning letter or Ecology's enforcement process. Sincerely, Rob Buchert Senior Compliance Specialist Water Quality Program Eastern Regional Office RB:sj cc. Terry Clements, City of Othello Jim Laird, City of Othello Shawn Obrien, City of Othello Diana Washington, PE, Ecology Permit Manager Eastern Region Andy O'Neill, Ecology Technical Assistance Eastern Region Art Jenkins, PE, Water Quality Permit Unit Supervisor Eastern Region Page 22 of 37 The Honorable Shawn Logan City of Othello March 12, 2021 Page 3 of 4 Table 1: Violations from October 2020 - February 2021 Monitoring Monitoring Monitoring Unit Month Point Parameter October 2020 001 BOD5 lbs/day 001 BOD5 mg/L 001 BOD5 Percent 001 Dissolved Oxygen mg/L 001 Fecal Coliform #/100 ml 001 pH s.u. 001 pH s.u. 001 November 2020 001 001 001 001 001 001 001 TSS pH pH pH pH pH pH BOD5 Percent s.u. s.u. s.u. s.u. s.u. s.u. Percent Statistical Base Avg. monthly Avg. monthly Avg. monthly Daily Sample Value Entered 400.678 37.3111 62.8 - Weekly geometric mean Daily sample 1113.91 - Daily sample - Avg. Monthly Daily sample Daily sample Daily sample Daily sample Daily sample Daily sample Daily sample 76 9.1 9.1 9.2 9.1 9.1 9.1 77.83 NPDES WA0022357 City of Othello STP 2021 Inspection Report Limit Type of Violation 390 Permit limit exceedance 30 Permit limit exceedance 85 Permit limit exceedance - Frequency of sampling violation 540 Permit limit exceedance - Frequency of sampling violation - Frequency of sampling violation 85 Permit limit exceedance 9 Permit limit exceedance 9 Permit limit exceedance 9 Permit limit exceedance 9 Permit limit exceedance 9 Permit limit exceedance 9 Permit limit exceedance 85 Permit limit exceedance Page 23 of 37 City of Othello March 12, 2021 Page 4 of 4 Monitoring Month December 2020 Monitoring Point Monitoring Parameter 001 TSS 001 BOD5 001 Dissolved Oxygen 001 Fecal Coliform 001 pH 001 pH 001 pH 001 pH 001 pH January 2021 001 TSS 001 BOD5 001 Fecal Coliform February 2021 001 TSS 001 BOD5 001 Fecal Coliform 001 TSS Unit Percent Percent mg/L #/100 ml s.u. s.u. s.u. s.u. s.u. Percent Percent #/100 ml Percent Percent #/100 ml Percent NPDES WA0022357 City of Othello STP The Honorable Shawn20L21oIgnsapnection Report Statistical Base Daily sample Avg. Monthly Daily sample Value Entered 60.775 79.3875 - Weekly geometric mean Daily sample 2419 - Single sample 9.1 Single sample 9.1 Single sample 9.1 Single sample - Avg. monthly Avg. monthly Weekly geometric mean Avg. monthly Avg. monthly Weekly geometric mean Avg. monthly 67.53 78.7 1440 78.4 81.8 2419 79.8 Limit Type of Violation 85 Permit limit exceedance 85 Permit limit exceedance - Frequency of sampling violation 540 Permit limit exceedance - Frequency of sampling violation 9 Permit limit exceedance 9 Permit limit exceedance 9 Permit limit exceedance - Frequency of sampling violation 85 Permit limit exceedance 85 Permit limit exceedance 540 Permit limit exceedance 85 Permit limit exceedance 85 Permit limit exceedance 540 Permit limit exceedance 85 Permit limit exceedance Page 24 of 37 NPDES WA0022357 City of Othello STP 2021 Inspection Report ATTACHMENT E Photograph Log All photographs taken by Jon Klemesrud on May 5, 2021 Nikon Coolpix AW100 Page 25 of 37 NPDES WA0022357 City of Othello STP 2021 Inspection Report Photo Log - Othello STP Photo #:01 (DSCN2108) Description: Photo of the ISCO 4210 Flow Meter control panel and recording log. Flow was reading 1.1MGD at the time of the photo. Photo #:02 (DSCN2110) Description: Facing east, photo of the influent weir and flow meter. Photo #:03 (DSCN2109) Description: Near the headworks, photo of ISCO 3710 refrigerated influent sampler. Photo #:04 (DSCN2113) Description: Facing west, photo of primary lagoon (Pond 1a) in foreground. Page 26 of 37 NPDES WA0022357 City of Othello STP 2021 Inspection Report Photo Log- Othello STP Photo #:05 (DSCN2111) Description: Facing east, photo of the open channel that receives wastewater from the two primary lagoons. Photo #:06 (DSCN2112) Description: Facing south, photo of manual coarse screen located at the end of the open channel. Photo #:07 (DSCN2114) Description: Facing west, photo of the cascade aeration channel (concrete step aerator). Photo #:08 (DSCN2116) Description: Facing north, photo of the chlorine contact chamber. Page 27 of 37 NPDES WA0022357 City of Othello STP 2021 Inspection Report Photo Log- Othello STP Photo #:09 (DSCN2118) Description: Facing south, photo of the ISCO refrigerated effluent sampler. Photo #:10 (DSC2126) Description: Facing north, photo of the outfall/discharge to Owl Creek. Complete list of photographs taken during the inspection: DSCN2108 - Photo of the ISCO 4210 Flow Meter control panel and recording log. Flow was reading 1.1MGD at the time of the photo. DSCN2109 - Near the headworks, photo of ISCO 3710 refrigerated influent sampler. DSCN2110 - Facing east, photo of the influent weir and flow meter. DSCN2111 - Facing east, photo of the open channel that receives wastewater from the two primary lagoons. DSCN2112 - Facing south, photo of manual coarse screen located at the end of the open channel. DSCN2113 - Facing west, photo of primary lagoon (Pond 1a) in foreground. DSCN2114 - Facing west, photo of the cascade aeration channel (concrete step aerator). DSCN2115- Facing south, photo of secondary lagoon and polishing lagoon (Pond 3 in foreground, Pond 4 in background) DSCN2116 - Facing north, photo of the chlorine contact chamber. DSCN2117 - Facing east, photo of the outfall of the chlorine contact chamber to underground discharge pipe. DSCN2118 - Facing south, photo of the ISCO refrigerated effluent sampler. DSCN2119 - Photo of the effluent ISCO 4230 Bubble Flow Meter Page 28 of 37 NPDES WA0022357 City of Othello STP 2021 Inspection Report DSCN2120 - Photo of Hach pH Meter DSCN2121 - Photo of 4/13/21 Certificate of Calibration by Quality Control Services DSCN2122 - Photo of Dissolved Oxygen Meter and calibration log. DSCN2123 - Photo of the Plant Flow Plan DSCN2124 - Photo of the Plant Flow Plan DSCN2125 - Photo of the 1/15/21 effluent bench sheet form DSCN2126 - Facing north, photo of the outfall/discharge to Owl Creek. Page 29 of 37 NPDES WA0022357 City of Othello STP 2021 Inspection Report ATTACHMENT F May 1, 2021 - December 1, 2017 Effluent Limit Exceedances Page 30 of 37 NPDES WA0022357 City of Othello STP 2021 Inspection Report WA0022357 Reported Effluent Limit Exceedances (May 1, 2021 - December 1, 2017) Date: May 1, 2021 May 1, 2021 May 1, 2021 May 1, 2021 April 29, 2021 April 28, 2021 April 27, 2021 April 26, 2021 April 25, 2021 April 24, 2021 April 23, 2021 April 22, 2021 April 21, 2021 April 20, 2021 April 19, 2021 April 18, 2021 April 17, 2021 April 16, 2021 April 15, 2021 April 14, 2021 April 6, 2021 April 1, 2021 April 1, 2021 April 1, 2021 April 1, 2021 April 1, 2021 April 1, 2021 March 2, 2021 March 1, 2021 March 1, 2021 March 1, 2021 February 1, 2021 February 1, 2021 February 1, 2021 January 1, 2021 January 1, 2021 January 1, 2021 December 3, 2020 December 2, 2020 December 1, 2020 December 1, 2020 Parameter : Permit Limit BOD5 Monthly Average 30 mg/L BOD5 Weekly Average 45 mg/L BOD5 Percent Removal 85% TSS Percent Removal 85% pH Daily Max 9 pH Daily Max 9 pH Daily Max 9 pH Daily Max 9 pH Daily Max 9 pH Daily Max 9 pH Daily Max 9 pH Daily Max 9 pH Daily Max 9 pH Daily Max 9 pH Daily Max 9 pH Daily Max 9 pH Daily Max 9 pH Daily Max 9 pH Daily Max 9 pH Daily Max 9 Mercury (dissolved) 19.71 ng/L TSS Average Monthly 45 mg/L TSS Average Weekly 65 mg/L TSS Percent Removal 85% Mercury (average monthly)13.5 ng/L BOD5 Average Monthly 30 mg/L BOD5 Percent Removal 85% Mercury (dissolved) 19.71 ng/L BOD5 Percent Removal 85% Mercury (average monthly)13.5 ng/L TSS Percent Removal 85% TSS Percent Removal 85% Fecal Coliform (weekly) 540 /100ml BOD5 Percent Removal 85% Fecal Coliform (weekly) 540 /100ml BOD5 Percent Removal 85% TSS Percent Removal 85% pH Daily Max 9 pH Daily Max 9 pH Daily Max 9 TSS Percent Removal 85% Reported Value 34.51 mg/L 45.89 mg/L 77% 81% 9.1 9.1 9.2 9.4 9.3 9.4 9.6 9.5 9.8 9.5 9.6 9.5 9.4 9.4 9.3 9.2 47.8 ng/L 45.27 mg/L 71.5 mg/L 77% 47.8 ng/L 30.78 mg/L 80.8% 31.6 ng/L 73.7% 31.6 ng/L 70.5% 79.8% 2419 /100ml 81.80 1440 /100ml 78.7% 78.4% 9.10 9.10 9.10 67.5% Page 31 of 37 NPDES WA0022357 City of Othello STP 2021 Inspection Report December 1, 2020 December 1, 2020 October 1, 2020 October 1, 2020 October 1, 2020 October 1, 2020 October 1, 2020 September 1, 2020 September 1, 2020 September 1, 2020 September 1, 2020 September 1, 2020 September 1, 2020 September 1, 2020 September 1, 2020 September 1, 2020 September 1, 2020 September 1, 2020 September 1, 2020 September 1, 2020 August 1, 2020 August 1, 2020 August 1, 2020 August 1, 2020 August 1, 2020 August 1, 2020 August 1, 2020 August 1, 2020 July 1, 2020 July 1, 2020 July 1, 2020 July 1, 2020 July 1, 2020 July 1, 2020 July 1, 2020 June 1, 2020 June 1, 2020 May 1, 2020 April 1, 2020 April 1, 2020 April 1, 2020 April 1, 2020 April 1, 2020 March 1, 2020 Fecal Coliform (weekly) BOD5 Percent Removal BOD5 Average Monthly BOD5 Average Monthly BOD5 Percent Removal TSS Percent Removal Fecal Coliform (weekly) BOD5 Percent Removal Fecal Coliform Monthly TSS Average Monthly TSS Percent Removal BOD5 Average Weekly pH BOD5 Average Weekly TSS Average Monthly BOD5 Average Monthly Fecal Coliform (weekly) BOD5 Average Monthly TSS Average Weekly TSS Average Weekly BOD5 Percent Removal TSS Percent Removal Fecal Coliform Monthly Fecal Coliform Weekly pH TSS Average Monthly TSS Average Weekly BOD5 Average Monthly TSS Average Monthly BOD5 Percent Removal BOD5 Average Weekly pH TSS Percent Removal BOD5 Average Monthly TSS Average Weekly pH BOD5 Average Weekly Fecal Coliform Weekly BOD5 Percent Removal TSS Percent Removal pH BOD5 Average Monthly TSS Average Weekly TSS Percent Removal 540 /100ml 85% 30 390 lbs/day 85% 85% 540 /100ml 85% 200 /100ml 45 mg/L 85% 585 Lbs/Day 8.5 45 mg/L 390 lbs/day 390 lbs/day 400 /100ml 30 mg/L 65 mg/L 585 Lbs/Day 85% 85% 200 / 100ml 400 / 100ml 8.5 45 mg/L 65 mg/L 30 mg/L 45 mg/L 85% 45 mg/L 8.5 85% 30 mg/L 65 mg/L 8.5 45 mg/L 400 /100ml 85% 85% 8.5 30 mg/L 65 mg/L 85% 2419 /100ml 79.38 37.31 400.678 lbs/ day 62.8% 76% 1113.91 /100ml 33.00 1220.00 58 mg/L 51% 936 Lbs/Day 8.9 103 mg/L 581 lbs/day 617 lbs/day 1600 / 100ml 65 mg/L 100 mg/L 1121 lbs/day 54% 58% 217 /100ml 540 / 100ml 8.9 49 mg/L 79 mg/L 31 mg/L 51 mg/L 54% 48 mg/L 9.1 29% 41 mg/L 71 mg/L 8.6 47 mg/L 2420 /100ml 70% 59% 9.5 32 mg/L 72 mg/L 66% Page 32 of 37 NPDES WA0022357 City of Othello STP 2021 Inspection Report March 1, 2020 March 1, 2020 March 1, 2020 March 1, 2020 March 1, 2020 March 1, 2020 February 1, 2020 February 1, 2020 February 1, 2020 February 1, 2020 January 1, 2020 January 1, 2020 January 1, 2020 January 1, 2020 January 1, 2020 January 1, 2020 January 1, 2020 December 1, 2019 December 1, 2019 December 1, 2019 December 1, 2019 October 1, 2020 September 1, 2020 September 1, 2019 September 1, 2019 September 1, 2019 September 1, 2019 September 1, 2019 September 1, 2019 September 1, 2019 September 1, 2019 September 1, 2019 September 1, 2019 September 1, 2019 August 1, 2019 August 1, 2019 August 1, 2019 August 1, 2019 August 1, 2019 August 1, 2019 August 1, 2019 August 1, 2019 August 1, 2019 August 1, 2019 BOD5 Average Monthly TSS Average Monthly TSS Average Monthly BOD5 Average Monthly pH TSS Average Weekly TSS Percent Removal pH Fecal Coliform BOD5 Average Monthly Fecal Coliform Monthly Fecal Coliform Weekly BOD5 Average Weekly BOD5 Average Weekly BOD5 Average Monthly BOD5 Design Criteria TSS Design Criteria Fecal Coliform Monthly Fecal Coliform Weekly pH TSS Design Criteria Fecal Coliform Weekly TSS Average Weekly BOD5 Average Weekly Fecal Coliform BOD5 Average Monthly TSS Average Weekly BOD5 Average Weekly TSS Percent Removal pH Fecal Coliform TSS Average Monthly BOD5 Average Monthly BOD5 Percent Removal pH BOD5 Average Monthly BOD5 Percent Removal TSS Average Monthly BOD5 Average Weekly TSS Percent Removal TSS Average Weekly TSS Average Monthly BOD5 Average Weekly TSS Average Weekly 85% 390 lbs/day 45 mg/L 30 mg/L 8.5 585 Lbs/Day 85% 8.5 400 /100ml 85% 200 / 100ml 400 / 100ml 585 Lbs/Day 45 mg/L 30 mg/L 2600 lbs/day 2600 lbs/day 200 /100ml 400 / 100ml 8.5 2600 lbs/day 400 /100ml 65 mg/L 585 Lbs/Day 400 /100ml 390 lbs/day 585 lbs/Day 45 mg/L 85% 8.5 200 /100ml 390 lbs/day 30 mg/L 85% 6.5 30 mg/L 85% 45 mg/L 585 Lbs/Day 85% 65 mg/L 390 lbs/day 45 mg/L 585 Lbs/Day 80% 473 lbs/day 49 mg/L 36 mg/L 9.2 598 lbs/day 60% 8.8 1120 /100ml 84% 1409 /100ml 2420 100/ml 829 Lbs/day 111 mg/L 38 mg/L 3772 lbs/day 2684 lbs/day 1054 /100ml 1300 / 100ml 8.7 2856 lbs/day 921 /100ml 67 mg/L 1094 Lbs/day 1600 /100ml 552 lbs/day 625 lbs/day 83 mg/L 64% 8.8 583 /100ml 451 lbs/day 49 mg/L 68% 2 43 mg/L 76% 51 mg/L 594 lbs/day 60% 74 mg/L 459 lbs/day 66 mg/L 724 lbs/day Page 33 of 37 NPDES WA0022357 City of Othello STP 2021 Inspection Report August 1, 2019 August 1, 2019 July 1, 2019 July 1, 2019 July 1, 2019 July 1, 2019 July 1, 2019 July 1, 2019 July 1, 2019 July 1, 2019 July 1, 2019 July 1, 2019 July 1, 2019 July 1, 2019 July 1, 2019 July 1, 2019 June 1, 2019 June 1, 2019 June 1, 2019 June 1, 2019 June 1, 2019 May 1, 2019 May 1, 2019 May 1, 2019 May 1, 2019 May 1, 2019 May 1, 2019 May 1, 2019 April 1, 2019 April 1, 2019 April 1, 2019 April 1, 2019 April 1, 2019 April 1, 2019 April 1, 2019 April 1, 2019 March 1, 2019 March 1, 2019 March 1, 2019 March 1, 2019 March 1, 2019 March 1, 2019 February 1, 2019 February 1, 2019 Fecal Coliform Weekly BOD5 Average Monthly TSS Percent Removal TSS Average Monthly BOD5 Average Monthly BOD5 Percent Removal TSS Design Criteria BOD5 Average Monthly BOD5 Design Criteria TSS Average Weekly TSS Average Monthly pH Flow Design Criteria BOD5 Average Weekly Fecal Coliform TSS Average Weekly TSS Average Weekly TSS Percent Removal BOD5 Average Monthly BOD5 Average Weekly BOD5 Design Criteria TSS Average Monthly BOD5 Percent Removal TSS Average Monthly pH TSS Average Weekly TSS Percent Removal TSS Weekly Average TSS Weekly Average pH TSS Percent Removal BOD5 Average Monthly TSS Average Monthly Fecal Coliform Weekly TSS Average Monthly TSS Average Weekly TSS Percent Removal TSS Average Monthly BOD5 Average Monthly Fecal Coliform Monthly Fecal Coliform Monthly BOD5 Percent Removal TSS Average Monthly TSS Percent Removal 400 /100ml 390 lbs/day 85% 390 lbs/day 30 mg/L 85% 2600 lbs/day 390 lbs/day 2600 lbs/day 585 Lbs/Day 45 mg/L 8.5 7.5 MGD 45 mg/L 400 /100ml 65 mg/L 65 mg/L 85% 30 mg/L 45 mg/L 2600 lbs/day 390 lbs/day 85% 45 mg/L 8.5 65 mg/L 85% 585 Lbs/Day 585 Lbs/Day 8.5 85% 85% 45 mg/L 400 /100ml 390 lbs/day 65 mg/L 85% 390 lbs/day 30 mg/L 200 /100ml 400 /100ml 85% 45 mg/L 85% 920 / 100ml 393 lbs/day 75% 546 lbs/day 44 mg/L 79% 3701 lbs/day 410 lbs/day 2742 lbs/day 1023 lbs/day 72 mg/L 8.7 14.593 MGD 53 mg/L 2420 /100ml 135 mg/L 76 mg/L 70% 38 mg/L 60 mg/L 5340 lbs/day 476 lbs day 81% 63 mg/L 8.7 116 mg/L 68% 891 Lbs/day 962 lbs/day 8.7 66% 77% 63 mg/L 921 /100ml 578 lbs/day 122 mg/L 76% 432 lbs/day 35 mg/L 2420 /100ml 2420 /100ml 84% 60 mg/L 35% Page 34 of 37 NPDES WA0022357 City of Othello STP 2021 Inspection Report February 1, 2019 February 1, 2019 February 1, 2019 February 1, 2019 February 1, 2019 January 1, 2019 January 1, 2019 January 1, 2019 January 1, 2019 December 1, 2018 December 1, 2018 December 1, 2018 December 1, 2018 November 1, 2018 November 1, 2018 November 1, 2018 November 1, 2018 November 1, 2018 November 1, 2018 October 1, 2018 October 1, 2018 October 1, 2018 October 1, 2018 October 1, 2018 October 1, 2018 October 1, 2018 October 1, 2018 October 1, 2018 October 1, 2018 October 1, 2018 September 1, 2018 September 1, 2018 September 1, 2018 September 1, 2018 September 1, 2018 September 1, 2018 September 1, 2018 September 1, 2018 September 1, 2018 September 1, 2018 September 1, 2018 September 1, 2018 August 1, 2018 August 1, 2018 Fecal Coliform Monthly TSS Average Monthly TSS Average Weekly TSS Average Weekly Fecal Coliform pH Fecal Coliform Monthly Fecal Coliform Weekly TSS Percent Removal TSS Percent Removal Fecal Coliform pH Fecal Coliform BOD5 Average Monthly Fecal Coliform pH TSS Percent Removal BOD5 Percent Removal Fecal Coliform Monthly TSS Average Monthly Fecal Coliform Monthly BOD5 Percent Removal TSS Average Monthly BOD5 Average Weekly BOD5 Average Weekly TSS Percent Removal TSS Average Weekly Fecal Coliform Weekly BOD5 Average Monthly BOD5 Average Monthly BOD5 Average Monthly pH Fecal Coliform BOD5 Average Monthly TSS Percent Removal BOD5 Average Weekly TSS Weekly Average TSS Weekly Average TSS Average Monthly TSS Average Monthly BOD5 Percent Removal Fecal Coliform Monthly BOD5 Average Monthly BOD5 Average Weekly 200 /100ml 390 lbs/day 585 Lbs/Day 65 mg/L 400 /100ml 8.5 200 /100ml 400 /100ml 85% 85% 200 / 100ml 8.5 400 /100ml 30 mg/L 400 /100ml 8.5 85% 85% 200 /100ml 45 mg/L 200 /100ml 85% 390 lbs/day 45 mg/L 585 Lbs/Day 85% 585 Lbs/Day 400 / 100ml 390 lbs/day 30mg/L 30mg/L 8.5 400 /100ml 390 lbs/day 85% 45 mg/L 65 mg/L 585 Lbs/Day 45mg/L 390 lbs/day 85% 200 /100ml 30 mg/L 45 mg/L 2164 /100ml 581 lbs/day 718 lbs/day 80 mg/L 2420 / 100ml 8.8 357 / 100ml 435 /100ml 77% 79% 1366 /100ml 8.8 2420 /100ml 33 mg/L 579/ 100ml 8.8 73% 77% 400 /100ml 50 mg/L 485 /100ml 63% 511 lbs/day 70 mg/L 671 lbs /day 45% 641lbs /day 1550/ 100ml 449 lbs/day 45mg/L 49 mg/L 8.9 2420 /100ml 406 lbs/day 28% 52 mg/L 107 mg/L 833 Lbs/day 71 mg/L 583 lbs/day 61% 249 /100ml 49 mg/L 62 mg/L Page 35 of 37 August 1, 2018 August 1, 2018 August 1, 2018 August 1, 2018 August 1, 2018 August 1, 2018 August 1, 2018 August 1, 2018 August 1, 2018 August 1, 2018 July 1, 2018 July 1, 2018 July 1, 2018 July 1, 2018 July 1, 2018 July 1, 2018 July 1, 2018 July 1, 2018 July 1, 2018 June 1, 2018 June 1, 2018 June 1, 2018 June 1, 2018 June 1, 2018 June 1, 2018 June 1, 2018 June 1, 2018 May 1, 2018 May 1, 2018 May 1, 2018 May 1, 2018 May 1, 2018 May 1, 2018 May 1, 2018 May 1, 2018 May 1, 2018 April 1, 2018 April 1, 2018 April 1, 2018 April 1, 2018 April 1, 2018 April 1, 2018 April 1, 2018 April 1, 2018 NPDES WA0022357 City of Othello STP 2021 Inspection Report Fecal Coliform Fecal Coliform Weekly BOD5 Percent Removal TSS Percent Removal TSS Average Monthly TSS Average Weekly TSS Average Monthly TSS Average Weekly pH TSS Design Criteria BOD5 Percent Removal TSS Percent Removal pH TSS Average Monthly TSS Average Weekly TSS Average Monthly TSS Average Weekly BOD5 Average Monthly BOD5 Average Weekly BOD5 Average Monthly TSS Average Monthly TSS Average Weekly TSS Average Weekly pH BOD5 Percent Removal TSS Percent Removal Fecal Coliform Weekly BOD5 Average Monthly BOD5 Average Weekly TSS Average Monthly TSS Average Weekly TSS Average Monthly TSS Weekly Average pH BOD5 Percent Removal TSS Percent Removal BOD5 Average Monthly TSS Average Monthly TSS Average Weekly TSS Average Monthly TSS Average Weekly pH BOD5 Percent Removal TSS Percent Removal 200 /100ml 400 /100ml 85% 85% 45 mg/L 65 mg/L 390 lbs/day 585 lbs/day 8.5 2600 lbs/day 85% 85% 8.5 45 mg/L 65 mg/L 390 lbs/day 585 lbs/Day 30 mg/L 45 mg/L 30 mg/L 45 mg/L 65 mg/L 585 Lbs/Day 8.5 85% 85% 400 / 100ml 30 mg/L 45 mg/L 45 mg/L 65 mg/L 390 lbs/day 585 Lbs/Day 8.5 85% 85% 30 mg/L 45 mg/L 65 mg/L 390 lbs/day 585 Lbs/Day 8.5 85% 85% 317 / 100ml 2420 / 100ml 61% 54% 96 mg/L 124 mg/L 639 lbs/day 807 lbs/day 9.0 2723 /lbs/day 76% 35% 9.7 108 mg/L 138 mg/L 480 lbs/day 614 lbs/day 41 mg/L 55 mg/L 37 mg/L 83 mg/L 139 mg/L 615 lbs/day 9.9 65% 40% 2420 /100ml 34 mg/L 53 mg/L 79 mg/L 107 mg/L 571 lbs/day 783 lbs/day 9.6 70% 24% 38 mg/L 86 mg/L 131 mg/L 616 lbs/day 956 Lbs/day 9.7 70% 36% Page 36 of 37 NPDES WA0022357 City of Othello STP 2021 Inspection Report March 1, 2018 March 1, 2018 March 1, 2018 March 1, 2018 March 1, 2018 March 1, 2018 March 1, 2018 February 1, 2018 February 1, 2018 January 1, 2018 January 1, 2018 January 1, 2018 January 1, 2018 January 1, 2018 January 1, 2018 January 1, 2018 December 1, 2017 December 1, 2017 December 1, 2017 December 1, 2017 December 1, 2017 December 1, 2017 December 1, 2017 BOD5 Average Monthly TSS Average Monthly TSS Average Weekly pH BOD5 Percent Removal TSS Percent Removal Fecal Coliform Weekly TSS Percent Removal Fecal Coliform Weekly Fecal Coliform Monthly Fecal Coliform Weekly TSS Average Weekly TSS Average Monthly TSS Average Weekly TSS Percent Removal TSS Average Monthly Fecal Coliform TSS Average Monthly TSS Average Monthly TSS Percent Removal pH Fecal Coliform Weekly TSS Average Weekly 30 mg/L 45 mg/L 585 Lbs/Day 8.5 85% 85% 400 /100ml 85% 400 /100ml 200 /100ml 400 /100ml 65 mg/L 390 lbs/day 585 Lbs/day 85% 45 mg/L 200 /100ml 390 Lbs/day 45 mg/L 85% 8.5 400 /100ml 585 Lbs/day 31 mg/L 48 mg/L 598 Lbs/day 9.4 74% 65% 4111 /100ml 66% 435 /100ml 865 /100ml 2420 /100ml 83 mg/L 680 Lbs/day 1240 Lbs/day 59% 47 mg/L 1118 /100ml 707 Lbs/day 50 mg/L 65% 10.5 2419 /100ml 895 Lbs/day Page 37 of 37