Document N2DRwnRvKeJ9R8ZgjV8EOOVmQ

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 07/29/2024 09:30 AM (AT) Announced: Yes 07/29/2024 01:40 PM (AKT) Access: Granted 55F, Overcast Water Clean Water Act, NPDES, WWTP Compliance Evaluation Inspection Permittee Name Facility Name Facility Physical Address City, State, Zip Code Borough Facility GPS Coordinates Mailing Address City, State, Zip Code City of Petersburg Petersburg WWTP 1404 14th Street Petersburg, Alaska 99833 Petersburg 56.817036, -132.932961 P.O. Box 329 Petersburg, Alaska 99833 FRS ID Permit Number SIC 110000760917 AK0021458 4952 (Sewerage Systems) Lead Inspector: RAYMOND ANDREWS Date: 2024.08.07 09:22:17 -07'00' Digitally signed by RAYMOND ANDREWS Raymond Andrews EPA Region 10 andrews.raymond@epa.gov (206) 553-4252 Supervisor Review: PETER CONTRERAS Date: 2024.08.07 13:34:11 -07'00' Digitally signed by PETER CONTRERAS Peter Contreras EPA Region 10 contreras.peter@epa.gov (206) 553-6708 City of Petersburg WWTP Permit # AK0021458 SECTION I - Opening Conference I arrived at the Petersburg WWTP (the "Site" or "Facility"), located at 1404 14th Street, Petersburg, Alaska, at 09:30 AM (AT) on 07/29/2024 for an announced inspection. I presented my credentials to Justin Haley, the Wastewater Supervisor, and informed him I was there to determine compliance with the Clean Water Act (CWA), and the facility's National Pollutant Discharge Elimination System (NPDES) permit, permit # AK0021458. This report is based on information supplied by facility representatives, direct observations made by me, and records and reports maintained by the facility. 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. Attendees Organization Attendee Name Title Present in Present in Opening Conf. Closing Conf. EPA Region 10 Raymond Andrews Lead Inspector Yes Yes City of Petersburg Justin Haley Wastewater Yes Yes Supervisor Facility Information Responsible official? Mayor Mark Jensen, mayorjensen@petersburgak.gov cc: Chris Cotta and Justin Haley Approximate Service The facility has a service population of approximately 3,000. Population? WWTP Design Capacity & Average Daily Flow? The facility has a design capacity of 3.6 million gallons per day (MGD). The average daily flow is 0.438mgd. How many employees The facility has operators on site seven days a week. The facility has two full time does the facility have? employees and one part time employee. Mr. Haley has a Level 4 certification in What are the Collections and a Level 3 certification in treatment. The full-time employee has a employees' Level 2 certification in treatment. The part time employee, who works primarily in certifications? drinking water treatment, holds no wastewater treatment certifications. What is the facility's The facility is fully staffed Monday through Friday from 6am until 3:30pm. There is operation schedule? an operator on-call on weekends and holidays. Contributing or shared Jurisdictions The facility receives septage and waste from cruise ships. The facility receives approximately 40,000 gallons of waste per year from the ships and septic systems. The facility has not noticed any negative effects on its systems due to the waste it accepts. Does the facility have Industrial Users? The facility has one industrial user, a solid waste bailing facility owned by the Borough. The facility creates liquid waste by squeezing liquid out of garbage and forming the solids into bails for transport to Seattle by barge and then to a landfill in central Washington. What is the treatment The facility's treatment train consists of screening with 0.04-inch screens followed process? by grit removal and primary sedimentation using clarifiers. Sludge is pumped to an aerated holding tank. 2 of 6 City of Petersburg WWTP Permit # AK0021458 How do you manage your biosolids? The facility treats the sewage sludge to separate as much of the water from the solids as possible. This is done by dewatering using a belt filter press. Then the sludge is moved to a concrete slab and is mixed with woods chips. After the sludge has been mixed with wood chips, it is then composted on site. After composting process is complete, the biosolids are taken to a landfill and used as cover. Is any portion of the The facility is fully operational. treatment train that is non-operational? Type of primary flow The facility uses an in-line Ultrasonic flow meter. Per manufacturer, the meter measuring device? does not require calibration. How many Outfalls The facility has one outfall. The facility discharges into Fredrich Sound. The outfall does the facility have? is submerged and has never been inspected. Inspection of the outfall is not a requirement under the current permit. What is your overflow/emergency capacity? The facility does not have an emergency overflow capacity. Per Mr. Haley, the facility has never overflowed. Have any bypasses or overflows happened at the plant or in the collection system in the last year? The facility has not had any bypasses or overflows in the last five years. Do you use in-house or contract out for laboratory analyses? The facility conducts in-house analysis of all pollutant parameters except ammonia which is performed by a contract lab. The contract lab the facility uses is: Admiralty Environmental 641 W. Willoughby Avenue, Suite 301, Juneau, Alaska 99801 (907) 463-4415 What sort of failure alarm does the plant have? The facility has a SCADA system which will detect problems with the treatment system. Once the SCADA system detects a problem it sends out an automated message to the operators' cell phones. Backup electrical power source, and does it turn on automatically? The facility has a back-up generator which runs the entire facility and main lift station. The generator has an automatic transfer switch, so it automatically activates when it senses a loss of power. Are there any plans for renovation or additional equipment to allow for increased wastewater flow? Currently, there are no plans for upgrades. Once the facility receives its next permit iteration, disinfection will be required. SECTION II - Observations No observations were made that constitute an area of concern. 3 of 6 City of Petersburg WWTP Permit # AK0021458 SECTION III - Records Review Records may not be in sequential order. Record: Other - Lab Reports and Chain of Custody Documents Ref #: RA1-RR-005 Reviewed By: Raymond Andrews AOC: No Reviewed Date: 08/06/2024 Post inspection, I reviewed the facility's lab reports and chain of custody documents from August 2023 through July 2024. I did not note any areas of concern. Record: Other - Notice of Noncompliance (Effluent Exceedance) AOC: No Ref #: RA1-RR-004 Reviewed By: Raymond Andrews Reviewed Date: 08/06/2024 Post inspection, I reviewed a letter from Mr. Hartley to EPA explaining the exceedance of the BOD, 5-day, 20C monthly average and daily maximum in the April 2024 monitoring month. The exceedance is further discussed in the EPA's Integrated Compliance Information System (ICIS) Database entry in Records Review and in the Areas of Concern sections of this report. Record: Other - Letter from City of Petersburg to EPA AOC: No Ref #: RA1-RR-003 Reviewed By: Raymond Andrews Reviewed Date: 08/06/2024 Post inspection, I reviewed a letter, dated February 1, 2021, the City of Petersburg's Wastewater Operations Supervisor, Justin Haley, sent to EPA explaining the reason the BOD, 5-day, 20C parameter for the monitoring month ending January 31, 2021, was not included on the discharge monitoring report (DMR) for the stated monitoring period. The reason explained in the letter was the facility's incubator was not functioning properly and a replacement could not be received in time. Additionally, no viable alternative for performing the analysis was available. Record: Other - EPA's Integrated Compliance Information System (ICIS) Database AOC: Yes Ref #: RA1-RR-002 Reviewed By: Raymond Andrews Reviewed Date: 08/06/2024 Post inspection, I reviewed a report generated by EPA's ICIS database from July 2019 through June 2024. The report showed the facility exceeded its monthly average and daily max of BOD, 5-day, 20C for the August 2024 monitoring month. The ICIS report also showed the facility did not submit data for BOD, 5-day, 20C for the monitoring perioding ending January 31, 2021, which was due by February 10, 2021. Record: Other - Quality Assurance (QA) Plan AOC: Yes Ref #: RA1-RR-001 Reviewed By: Raymond Andrews Reviewed Date: 07/29/2024 At the time of the inspection, I reviewed the facility's QA Plan, dated December 2022. The QA plan was revised and certified by the current Public Works Director, Chris Cotta, on July 30, 2024. Based on required elements missing from the QA Plan, it appears the Plan was not developed consistent with Requirements for Quality Assurance Project Plans, EPA QA/R-5 EPA, and Guidance on Quality Assurance Project Plans, EPA QA/G-5 as required by the permit. The QA Plan did not include sample shipping methods. The QA Plan did not include qualifications and specific training of the facility staff. The QA Plan did not include the name and contact information of the contract laboratory. The QA Plan did not include qualifications and specific training of the facility staff. SECTION IV - Sampling Activity No sampling was conducted. 4 of 6 City of Petersburg WWTP Permit # AK0021458 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-001 Records Review: Other - Quality Assurance (QA) Plan Permit Requirement Part I.G.2 of the permit states, in part, " Throughout all sample collection and analysis activities, the Permittee shall use the EPA approved quality assurance, quality control, and chain-of custody procedures described in: a. Requirements for Quality Assurance Project Plans, EPA QA/R-5 EPA, and b. Guidance on Quality Assurance Project Plans, EPA QA/G-5." AOC: The Plan was not developed consistent with Requirements for Quality Assurance Project Plans, EPA QA/R5 EPA, and Guidance on Quality Assurance Project Plans, EPA QA/G-5. AOC Reference #: RA1-RR-001 Records Review: Other - Quality Assurance (QA) Plan Permit Requirement Part I.G.4 of the permit states, in part, "At a minimum the plan shall include the following...Sampling shipment procedures." AOC: The QA Plan did not include sample shipping methods. AOC Reference #: RA1-RR-001 Records Review: Other - Quality Assurance (QA) Plan Permit Requirement Part I.G.4 of the permit states, in part, "At a minimum the plan shall include the following...Qualification and training of personnel." AOC: The QA Plan did not include qualifications and specific training of the facility staff. AOC Reference #: RA1-RR-001 Records Review: Other - Quality Assurance (QA) Plan Permit Requirement Part I.G.5 of the permit states, "Name(s), address(es) and telephone number(s) of the laboratories, used by or proposed to be used by the Permittee, shall be specified in the Quality Assurance Plan." AOC: The QA Plan did not include the name and contact information of the contract laboratory. AOC Reference #: RA1-RR-002 Records Review: Other - EPA's Integrated Compliance Information System (ICIS) Database Permit Requirement Part I.A, Table 1 of the permit shows, in part, the effluent concentration limit for BOD, 5-day, 20C in April is a Monthly Average of 140 mg/L, and a Daily Maximum of 200 mg/L. AOC: The facility exceeded its monthly average and daily max of BOD, 5-day, 20C for the August 2024 monitoring month. Month Parameter DMR Value Permit Limit Unit Limit Type April 2024 BOD, 5-day, 20C 170.9 140. mg/L Mon Avg April 2024 BOD, 5-day, 20C 255.6 200. mg/L Daily Max 5 of 6 City of Petersburg WWTP Permit # AK0021458 AOC Reference #: RA1-RR-002 Records Review: Other - EPA's Integrated Compliance Information System (ICIS) Database Permit Requirement Part II.C of the permit states, in part, "Reporting of Monitoring Results. Monitoring results shall be summarized each month on the Discharge Monitoring Report (DMR) form. The reports shall be submitted monthly and are to be postmarked by the 10th day of the following month." AOC: The facility did not submit data for BOD, 5-day, 20C for the monitoring perioding ending January 31, 2021, which was due by February 10, 2021. SECTION VI - Closing Conference I held a closing conference with facility personnel at 01:40 PM (AKT) on 07/29/2024 for the inspection. During the closing conference, I discussed the observations and Areas of Concern I 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 6 of 6 APPENDIX 1: Photo Log All photos were taken by Lead EPA Inspector, Ray Andrews, during the inspection. Photos were not manipulated beyond minor cropping for sizing and labels or callouts to draw attention to the subject of the photo. All photos taken during the inspection are included in the Photo Log; however, only photos that support an Observation or Area of Concern are included in the inspection report. P1020007 - Daily Logbook, June 26 - 29, 2024, example pages P1020008 - Laboratory Daily Inspection and Maintenance Checklist, page 1 P1020009 - Laboratory Daily Inspection and Maintenance Checklist, page 2 P1020010 - Clarifier, photo 1 P1020011 - Clarifier, photo 3 P1020012 - Clarifier, photo 4 P1020013 - Clarifier, photo 5 P1020014 - Clarifier, photo 6 P1020015 - Clarifier, photo 7 P1020016 - Clarifier, photo 8 P1020017 - Clarifier, photo 9 P1020018 - Shore Sign