Document DbyYKorpKExZOmVJ6BnOwMJM
NPDES Off-Site Compliance Monitoring Clean Water Act Desk Audit Report
City of Tensed Wastewater Treatment Plant
Tensed, Idaho Permit # ID0025101
Prepared by: Raymond Andrews U.S. Environmental Protection Agency, Region 10 Enforcement & Compliance Assurance Division Water Enforcement & Field Branch Surface Water Enforcement Section
Signature/Date:
Andrews, Raymond L. Date: 2020.11.06 08:38:41 -08'00' Digitally signed by Andrews, Raymond L.
Supervisor Signature/Date:
MICHELE JENCIUS Date: 2020.11.06 09:27:33 -08'00' Digitally signed by MICHELE JENCIUS
Contents
I. Facility Information ............................................................................................................ 1 II. Off-Site Compliance Monitoring Information.................................................................... 1 III. Permit Information.............................................................................................................. 2 IV. Background ........................................................................................................................ 2 V. Evaluation Chronology ....................................................................................................... 2 VI. Facility Summary................................................................................................................ 2 VII. File Review ........................................................................................................................ 3 VIII. Areas of Concern ................................................................................................................ 3
A. Effluent Limit Exceedances ............................................................................................. 3 B. Discharge Monitoring Reports (DMR) ............................................................................ 3 C. Operations & Maintenance (O&M) Manual.................................................................... 4 D. Quality Assurance Plan (QAP) ........................................................................................ 4 E. Sample Preservation Temperature ................................................................................... 4 IX. Closing Conference............................................................................................................. 4
Attachment A - Aerial Photo Attachment B - Tables
(Unless otherwise noted, all details in this report were obtained from conversations with Leonard Johnson or Mayor Rick Keaveny, or from observations made during the off-site compliance review.)
I. Facility Information
Facility Name:
City of Tensed Wastewater Treatment Plant (WWTP)
Owner:
City of Tensed, Idaho
Operator:
LJ Sewer & Water LLC
Physical Address:
8761 Branch Road Tensed, Idaho 83870
Lat/Long:
47.15072, -116.92614
Mailing Address:
City of Tensed P.O. Box 126 Tensed, Idaho 838709
Facility Contacts:
Rick Keaveny, Mayor City of Tensed Phone: (208) 274-3239 Email: mayorcityoftensed@gmail.com
Leonard Johnson, Operator LJ Sewer & Water LLC Phone: (208) 818-6875 Email: ljsewer@gmail.om
Permit Number:
ID0025101
NAICS Code:
221320 - Sewage Treatment Facilities
Receiving Water:
Hangman Creek, tributary to Spokane River
II. Off-Site Compliance Monitoring Information
An off-site Clean Water Act Desk Audit was conducted for the City of Tensed's Wastewater Treatment Plant. The purpose of the audit was to evaluate the facility's compliance with the National Pollutant Discharge Elimination System (NPDES) permit and the Clean Water Act (CWA). The evaluation included a scheduled phone interview with a facility representative and a records request/review of permit related documents.
EPA Representative:
Raymond Andrews, NPDES Inspector EPA Region 10, ECAD / SWES
Documents Reviewed:
Operation & Maintenance Plan 5-Year ICIS Violations Report Discharge Monitoring Reports from January 2018 through May 2020 Chain of Custody Documents from January 2018 through December 2019
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ID0025101 NPDES Permit & Fact Sheet
Phone Interview:
24 September 2020 (approximately 1.5 hours)
Present for Interview: Rick Keaveny, Mayor, City of Tensed Leonard Johnson, Operator, LJ Sewer & Water LLC
III. Permit Information
The City of Tensed's Wastewater Treatment Plant ("Facility") is permitted to discharge under NPDES permit ID0025101 ("Permit"). On October 1, 2020, the current iteration of the Facility's permit became effective, and it will expire on September 30, 2025. This Desk Audit will primarily use the previous version of the Permit, which was in effect from April 1, 2004, until March 31, 2009. The previous Permit was administratively extended until the new Permit became effective.
IV. Background
The City of Tensed owns the municipal wastewater treatment plant (WWTP) located within the Coeur d'Alene tribal reservation boundary. The Facility has been at its current location since 1982. The WWTP is operated and maintained by LJ Sewer & Water LLC. LJ Sewer took over operation of the Facility in March 2020.
The WWTP treats domestic wastewater from the City of Tensed, serving a population of approximately 120 people through 58 connections. There are no industrial customers discharging to the WWTP.
The Facility was last inspected by EPA on August 26, 2016. On April 27, 2017, EPA issued the Facility a Notice of Violation based on findings noted in the 2016 inspection report.
V. Evaluation Chronology
This off-site compliance evaluation was announced. On September 16, 2020, I called Mr. Leonard Johnson, the Facility operator. I told him that due to COVID-19 pandemic restrictions I would not be conducting a routine site inspection. I told him I would instead be conducting an off-site compliance evaluation, which would consist of a scheduled phone interview to discuss WWTP operations, as well as a records request and review of permit related documents. I explained that my findings of the evaluation would be documented in a report that would be shared with the Facility and reviewed by an EPA compliance officer. I provided a copy of the U.S. EPA Small Business Resources Information through email on November 4, 2020.
Mr. Johnson and I agreed to conduct the interview on September 24, 2020, at 10:00am. I provided Mr. Johnson with a list of records for him to send to me for review. The complete list of records reviewed for the evaluation are listed in Section II of this report.
Mr. Johnson was unable to scan and email the requested documents until the morning of the interview so they could not be reviewed in advance. An aerial photo of the Facility taken from Google Earth is attached as Attachment A. Data, organized in Tables, is provided in Attachment B.
VI. Facility Summary
Mr. Leonard Johnson, LJ Sewer & Water LLC, is the sole operator of the WWTP. The Facility does not have any other employees. The Honorable Rick Keaveny, Mayor of Tensed, was also present during the phone interview.
The treatment process consists of wastewater entering the WWTP at a lift station equipped with grinder pumps. From the lift station, wastewater is pumped to two lagoons for treatment. The lagoons are connected in series.
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Each lagoon has a volume of 4.5 million gallons. Effluent from the lagoons is disinfected with chlorine and then routed to a small holding pond for dechlorination prior to discharging into Hangman Creek via a single outfall, outfall 001. The Facility's design flow is approximately 0.03 million gallons per day (mgd) with an average monthly flow of 0 to 0.15 mgd. Since the design flow is less than 1 mgd, the Facility is considered a minor facility.
The Facility is staffed on a part-time basis. Mr. Johnson is on-site from about 6:30 - 7:30am daily to conduct operational checks. He is also responsible for sample collection when required. Sampling is only conducted during the months where a discharge occurs. The Facility is currently authorized to discharge from November through January, then March through May. The Facility holds wastewater in its lagoons outside of the discharge period. As of September 24, 2020, the date of the phone interview, the Facility had last discharged on April 30, 2020.
Influent samples are collected at lift station and effluent samples are collected after dechlorination. Although the Facility measures flow, it is not measured with a flow meter. Flow is determined by calculating how long it takes to fill a five-gallon bucket.
The Facility is required by permit to sample and test for biochemical oxygen demand BOD5, total suspended solids (TSS), E. coli, total residual chlorine (TRC), total phosphorus (TP), total ammonia, (TA), pH, and temperature (C). Mr. Johnson tests for pH and temperature himself. Accurate Testing Labs LLC in Coeur d'Alene, Idaho conducts sample analysis for all other parameters.
VII. File Review
As part of this off-site compliance evaluation, I reviewed the following documents that were provided to me by the facility:
ICIS Violations Report - September 2015 through August 2020 Discharge Monitoring Reports (DMRs) - January 2018 through August 2020 Chain of Custody Documents - May 2018 through December 2019 Operations & Maintenance Manual - Dated 1978
VIII. Areas of Concern
I noted the following areas of concern during the off-site evaluation:
A. Effluent Limit Exceedances Part I.A.I. of the permit states, in part, " that "During the period beginning on the effective date of this permit the Permittee is authorized to discharge wastewater...provided the discharge meets the limitations and monitoring requirements set forth herein."
Based on my review of the reported 5-year effluent data, using EPA's Integrated Compliance Information System (ICIS), the Town of Tensed has reported 24 instances of effluent exceedances in 7 months over the past 5 years as shown in the Attachment B, Table I. My concern is that facility is not preventing effluent exceedances.
B. Discharge Monitoring Reports (DMR) Part II.B.1 of the permit states, "The permittee must summarize monitoring results each month on the Discharge Monitoring Report (DMR) form (EPA No. 3320-1) or equivalent or forms provided or specified by the Director for reporting results of monitoring of sludge use or disposal practices. The permittee must submit reports monthly, postmarked by the 15th day of the following month."
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DMRs must be submitted monthly whether there was a discharge or not. In cases of no discharge, the "No Discharge" block must be checked on the DMR to alleviate the facility from the requirement to provide data. During the audit, I reviewed electronic copies of DMR's provided by the facility covering the time period from January 2018 through August 2020. Additionally, I reviewed the ICIS data from September 2015 through August 2020. I found numerous DMRs were late, incomplete, or not filled out properly, as shown in Attachment B, Table II. My concern is that the facility is not submitting correct and complete DMRs by the due date.
C. Operations & Maintenance (O&M) Manual Part II.A of the permit issued in October 2020 states, in part, "Any changes occurring in the operation of the plant must be reflected within the O&M Plan."
The O&M manual currently used by the City of Tensed is dated 1978. Per Mr. Johnson, the facility purchased two new influent pumps. My concern is that the O&M Manual might need to be updated to include changes to the facility that have occurred since the facility's manual was originally written.
D. Quality Assurance Plan (QAP) Part I.D of the Permit states that "The permittee must develop a quality assurance plan (QAP) for all monitoring required by this permit. The plan must be developed and implemented by October 1, 2004. Any existing QAPs may be modified for the requirements under this section."
Per Mr. Johnson, the Facility did not have a Quality Assurance Plan at the time of the phone interview. My concern is the facility does not have a QAP that would ensure quality control is maintained in laboratory procedures.
E. Sample Preservation Temperature Part II.C of the permit states, "Monitoring must be conducted according to test procedures approved under 40 CFR 136..."
40 CFR Part 136, Table II, dated March 1, 2014, shows the preservation temperature for all tested parameters. The listed preservation temperature for E. coli is < 10 C. Table II lists the preservation temperature for all other parameters as 6 C.
I reviewed 15 chain of custody (COC) documents that were dated from May 16, 2018 through December 23, 2019. Out of the 15 COC documents, 13 documents showed the sample temperature upon receipt by Accurate Testing Labs was above 10 C, as shown in Attachment B, Table III. My concern is that the facility is not properly preserving effluent samples.
IX. Closing Conference
I held a closing conference with Mr. Johnson, we discussed the areas of concern identified during the off-site evaluation. I told him that I would provide him with I thanked him for his time and assistance.
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ATTACHMENT A - Aerial Photo from Google Earth Aerial photo of City of Tensed's Wastewater Treatment Facility retrieved October 8, 2020.
ATTACHMENT B - Tables Table I - Effluent Exceedance Data
Month November 2015
April 2016 May 2016 May 2018 May 2018 May 2018 January 2019 January 2019 January 2019 January 2019 January 2019 April 2019 April 2019 April 2019 April 2019 April 2019 April 2019 December 2019 December 2019 December 2019 December 2019 December 2019 December 2019 December 2019
Parameter Chlorine Chlorine Chlorine TSS TSS TSS TSS Chlorine Chlorine Chlorine Chlorine TSS TSS Chlorine Chlorine E. coli E. coli BOD5 TSS TSS Chlorine Chlorine Chlorine Chlorine
DMR Value .13 .11 .11 13 40 51 8.3 .062 .062 .18 .18 14 17
.0275 .0511 2740 13705 15.7
36 38 .038 .05 .23 1
Permit Limit .1 .1 .1 11 8 30 8.0
.025 .025
.1 .1 8 11 .025 .025 576 126 8 30 8 .025 .025 .1 .1
Unit mg/L mg/L mg/L lb/d lb/d mg/L lb/d lb/d lb/d mg/L mg/L lb/d lb/d lb/d lb/d #/100mL #/100mL lb/d mg/L lb/d lb/d lb/d mg/L mg/L
Limit Type Daily Max Daily Max Daily Max Wkly Avg Mo Avg Mo Avg Mo Avg Daily Max Mo Avg Daily Max Mo Avg Mo Avg Wkly Avg Mo Avg Daily Max Inst Max Mo Geomn Mo Avg Mo Avg Mo Avg Mo Avg Daily Max Mo Avg Daily Max
Monitoring Period November 2015 December 2015 January 2016 March 2016 April 2016 May 2016 November 2016 December 2016 January 2017 February 2017 April 2017 May 2017 November 2017 December 2017 January 2018 March 2018 April 2018 May 2018 June 2018 July 2018 October 2018 November 2018 December 2018 January 2019 February 2019 March 2019 April 2019 May 2019 June 2019 July 2019 September 2019 November 2019 December 2019 March 2020 April 2020 May 2020 June 2020 July 2020
Received September 12, 2016 September 12, 2016 September 12, 2016 September 12, 2016 September 12, 2016 September 12, 2016
May 23, 2018 May 23, 2018 May 23, 2018 May 23, 2018 May 23, 2018 May 23, 2018 May 23, 2018 May 23, 2018 May 23, 2018 May 23, 2018
On Time On Time On Time On Time On Time On Time On Time On Time On Time On Time On Time On Time On Time On Time On Time Not Received January 07, 2020 Not Received Not Received Not Received On Time On Time
Table II - DMR Data
Hardcopy
Reviewed Late
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
Notes Only Flow and Chlorine data reported.
X X X X X X X X X X X X X
X
X
X
X
X
Only Flow and Chlorine data reported.
X
X
X
X
X
"No Discharge" box unchecked; no sampling conducted.
X
X
X
X
X
X
X
X
Page 2 was dated 10/10/2018.
X
X
Page 2 Monitoring Period "From" and "To" dates missing.
X
X
X
X
X
Hardcopy DMR date incorrect.
X
X
X
X
X
X
X
X
Incomplete; missing pH.
X
X
Page 1 Monitoring Period "From" and "To" dates missing.
X
X
Hardcopy date incorrect.
X
X
X
X
X
X
X
X
X
X
X
X
X
"No Discharge" box unchecked; no sampling conducted.
X
X
X
X
X
X
X
X
X
X
X
X
Table III - COC Temperature Data
Date May 16, 2018 May 23, 2018 May 30, 2018 January 02, 2019 April 17, 2019 April 22, 2019 April 24, 2019 April 29, 2019 April 30, 2019 October 01, 2019 October 15, 2019 December 03, 2019 December 11, 2019 December 17, 2019 December 23, 2019
Temperature 15.9 C 14.3 C 18.4 C 16.2 C 14.9 C 23.3 C 14.9 C 14.7 C 15.2 C 19.6 C 17.5 C 7.9 C 4.1 C 3.8 C 4.7 C