Document BRpoLqNyJdxRnB0842pX3o0E4

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 01/27/2025 9:45 AM (PT) Announced: Yes 01/27/2025 1:04 PM (PT) Access: Granted 53F, Overcast 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 Sandy Point WWTP 4369 Germain Road Ferndale, Washington 98248 Whatcom 48.814547, -122.706568 FRS ID Permit Number SIC 110009764371 WA0025658 4952 (Sewerage Systems) Lead Inspector: RAYMOND ANDREWS Date: 2025.02.26 05:32:39 -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: 2025.02.26 09:31:03 -08'00' contreras.peter@epa.gov (206) 553-6708 Sandy Point WWTP Permit # WA0025658 SECTION I - Opening Conference I arrived at the Lummi Sandy Point WWTP ("Facility"), located at 4369 Germain Road, Bellingham, Washington, at 9:45 AM (PT) on 01/27/2025 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 # WA0025658. 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 first of three inspections I conducted on Lummi Tribal wastewater treatment facilities. The Sandy 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 Lummi Sewer and Brad Solomon Sewer Manager Yes No 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 operation schedule? What is the facility's service population? What is the facility's design capacity and average daily flow? What is the facility's primary flow measuring device? How often is the flow measuring device calibrated? What is the facility's receiving water? There is an operator on site for four hours on Monday and Friday, one hour Tuesday through Thursday. The facility has on-call person on weekends and holidays that conducts morning checks. The District plans to start a daily 8hour schedule around the end of February 2025. The facility services approximately 1,000 residents. The facility has a design capacity of 0.250 million gallons per day (mgd), and an average daily flow of 0.175 mgd. The facility uses two Magmeters to measure flow, one at the influent and one at the effluent. The manufacturer specifications state the magmeters do not require calibration. The facility discharges directly into the Strait of Juan de Fuca which empties into Puget Sound. 2 of 6 Sandy Point WWTP Permit # WA0025658 How many outfalls The facility has a single outfall. does the facility have? How often is the outfall inspected? An operator visually inspects the outfall daily. Where do you sample The influent is sampled prior to the headworks. The effluent is sampled at the influent? Effluent? outfall. 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 picked up by a 3rd party contractor and disposed of on an asneeded 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 to is an alarm 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 The facility has not had any bypasses or overloads in the last five years. any bypasses or hydraulic overloads in the past 5-years? Has the facility been renovated or upgraded in the last 5-years? The facility has not been renovated or upgraded in the last five years. Are there any plans to The District has plans for upgrades, but they are more than 5 years out. renovate or upgrade the facility? SECTION II - Observations There were no observations made of facility operations made 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 Sandy Point WWTP Permit # WA0025658 AOC: Yes Reviewed Date: 02/13/2025 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 1118 times over a 18-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. 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..." 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: 01/27/2025 At the time of inspection, I reviewed the facility's Emergency Response and Public Notification Plan (ERPN). The plan was undated. The ERPN was also out of date. It contained contact names that are no longer valid, i.e, District Manager, Dale Anderson. The ERPN did not explain how notification to 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: 01/27/2025 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 Sandy Point WWTP Permit # WA0025658 SECTION IV - Sampling Activity No sampling was conducted. 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. 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. 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 1118 times over an 18-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 ERPN did not appear to explain how notification to 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.d of the Permit states, at a minimum, the ERPN must, in part, "Ensure that appropriate personnel are aware of and follow the plan and are appropriately trained..." AOC: The ERPN contains contact names that are no longer valid. 5 of 6 Sandy Point WWTP Permit # WA0025658 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 showing the QAP was reviewed annually. AOC Reference #: RA1-RR-001 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. SECTION VI - Closing Conference I held a closing conference with facility personnel at 1:04 PM (PT) on 01/27/2025 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. Area of Concern Tables 6 of 6 APPENDIX 1: Photo Log Screw Press IMG-202501271020572057102922.jpg 01/27/2025 10:20 AM No CBI No PII Photographer: Raymond Andrews Screw press at headworks. Ultrasonic sensor activates press when water gets to about 20 inches deep. Screw Press Trench IMG-202501271022472247123518.jpg 01/27/2025 10:22 AM No CBI No PII Photographer: Raymond Andrews The influent pipe is below surface level and the sensor is above. Aeration Basin IMG-202501271025332533143005.jpg 01/27/2025 10:25 AM No CBI No PII Photographer: Raymond Andrews Influent flows to the aeration basin after it goes through the clarifiers. Two Primary Clarifiers 01/27/2025 10:26 AM No CBI No PII IMG-20250127102636263693004.jpg Photographer: Raymond Andrews Two Rotational Biological Reactor (RBCs) IMG-20250127102941294194084.jpg 01/27/2025 10:29 AM (PT) No CBI No PII Photographer: Raymond Andrews The RBCs do most of the biological work breaking down solids. Rotational Biological Reactor (RBC) 01/27/2025 10:32 AM (PT) No CBI In profile. No PII IMG-202501271032173217132709.jpg Photographer: Raymond Andrews Secondary Clarifier IMG-202501271033573357167232.jpg 01/27/2025 10:33 AM No CBI No PII Photographer: Raymond Andrews This is one of two secondary clarifiers. The influent is split between the two clarifiers. UV Disinfection 01/27/2025 10:35 AM No CBI The UV bulbs are cleaned monthly. No PII IMG-202501271035463546144512.jpg Photographer: Raymond Andrews Effluent Auto Sampler IMG-202501271037413741122223.jpg 01/27/2025 10:37 AM No CBI No PII Photographer: Raymond Andrews The effluent auto-sampler collects timed samples. A sample is collected every hour over a 24-hour period. Note: The back-up thermometer is to the left of the collection jar. Outfall Intake 01/27/2025 10:38 AM No CBI No PII IMG-202501271038543854100488.jpg Photographer: Raymond Andrews Digester IMG-202501271041284128156897.jpg 01/27/2025 10:41 AM No CBI No PII Photographer: Raymond Andrews Biosolids are transferred to the digester, where they stay for at last 90 days. The aeration runs in cycles of 40 minutes on and 20 minutes off. Influent Auto-sampler IMG-202501271045124512118851.jpg 01/27/2025 10:45 AM No CBI No PII Photographer: Raymond Andrews The influent auto-sampler collects timed samples. A sample is collected every hour over a 24-hour period. Note: The back-up thermometer is behind and to the left of the collection jar. APPENDIX 2: Area of Concern Tables Month Feb 2020 Jul 2020 Jul 2020 Dec 2020 Mar 2021 Aug 2021 Sep 2021 Sep 2021 Sep 2021 Nov 2021 Nov 2021 Dec 2021 Jan 2022 Jan 2022 Jan 2022 Jan 2022 Jan 2022 Jan 2022 Jan 2022 Jan 2022 Jan 2022 Jan 2022 Mar 2022 Mar 2022 Mar 2022 Mar 2022 Apr 2022 Apr 2022 May 2022 Sep 2022 Sep 2022 Sep 2022 Dec 2022 Dec 2022 Dec 2022 Dec 2022 Dec 2022 Dec 2022 Dec 2022 Dec 2022 Jan 2023 Jan 2023 Effluent Exceedances Parameter Solids, susp % rmv Solids, total susp Solids, susp % rmv Solids, susp % rmv Solids, susp % rmv Solids, susp % rmv Solids, total susp Solids, total susp Solids, susp % rmv BOD, 5-day, % rmv Solids, susp % rmv Solids, susp % rmv BOD, 5-day, 20C BOD, 5-day, 20C BOD, 5-day, 20C BOD, 5-day, 20C Solids, total susp Solids, total susp Solids, total susp Solids, total susp BOD, 5-day, % rmv Solids, susp % rmv BOD, 5-day, 20C Solids, total susp BOD, 5-day, % rmv Solids, susp % rmv Solids, total susp Solids, susp % rmv Solids, susp % rmv Solids, total susp Solids, total susp Solids, susp % rmv BOD, 5-day, 20C BOD, 5-day, 20C Solids, total susp Solids, total susp Solids, total susp Solids, total susp BOD, 5-day, % rmv Solids, susp % rmv BOD, 5-day, % rmv Solids, susp % rmv DMR Value 83 67 74 84 83 84 31 47 80 84 73 78 42 61 68 105.3 59 89 101 199.4 76 64 56 69 82 80 32 82 84 35 60 76 52 114.1 90 107 196 256.8 70 83 81 75 Permit Limit 85 45 85 85 85 85 30 45 85 85 85 85 30 45 63 94 30 45 63 94 85 85 45 45 85 85 30 85 85 30 45 85 45 94 30 63 45 94 85 85 85 85 Unit % mg/L % % % % mg/L mg/L % % % % mg/L mg/L lb/d lb/d mg/L mg/L lb/d lb/d % % mg/L mg/L % % mg/L % % mg/L mg/L % mg/L lb/d mg/L lb/d mg/L lb/d % % % % Limit Type Mo Av Mn Wkly Avg Mo Av Mn Mo Av Mn Mo Av Mn Mo Av Mn Mo Avg Wkly Avg Mo Av Mn Mo Av Mn Mo Av Mn Mo Av Mn Mo Avg Wkly Avg Mo Avg Wkly Avg Mo Avg Wkly Avg Mo Avg Wkly Avg Mo Av Mn Mo Av Mn Wkly Avg Wkly Avg Mo Av Mn Mo Av Mn Mo Avg Mo Av Mn Mo Av Mn Mo Avg Wkly Avg Mo Av Mn Wkly Avg Wkly Avg Mo Avg Mo Avg Wkly Avg Wkly Avg Mo Av Mn Mo Av Mn Mo Av Mn Mo Av Mn # Violations 29 7 31 31 31 31 30 7 30 30 30 31 31 7 31 7 31 7 31 7 31 31 7 7 31 31 30 30 31 30 7 30 7 7 31 31 7 7 31 31 31 31 Month Oct 2023 Oct 2023 Jan 2024 Dec 2024 Dec 2024 Dec 2024 Parameter Solids, total susp Solids, susp % rmv Solids, susp % rmv BOD, 5-day, 20C BOD, 5-day, % rmv Solids, susp % rmv Effluent Exceedances DMR Value 59 69 64 107.5 84 81 Permit, Limit 45 85 85 94 85 85 Unit mg/L % % lb/d % % Limit Type Wkly Avg Mo Av Mn Mo Av Mn Wkly Avg Mo Av Mn Mo Av Mn # Violations 7 31 31 7 31 31 Monitoring Period End Date August 31, 2020 August 31, 2020 August 31, 2020 Late DMR Parameters DMR Due Date September 10, 2020 September 10, 2020 September 10, 2020 Parameter Nitrogen, ammonia total [as N] Nitrogen, ammonia total [as N] Nitrite + Nitrate total [as N] DMR Value Received Date October 16, 2020 October 16, 2020 October 16, 2020