Document NeMN0ZwKbZYy8e13kYdnjjwrw

EPA REGION 5 Enforcement and Compliance Assurance Division INSPECTION REPORT Inspection Entry Date/Time Inspection Exit Date/Time Weather Media Statute(s)/Program(s) Type of Inspection 08/04/2023 08:18 AM (ET) Announced: Yes 08/04/2023 11:30 AM (ET) Access: Granted Day 1 - sunny and mild Water Clean Water Act, NPDES, WWTP Compliance Evaluation Inspection (CEI) Permittee Name Facility or Site Name Facility/Site Physical Address City, State, Zip Code County/Borough/Parish Facility GPS Coordinates Mailing Address (If different) City, State, Zip Code Grand Traverse Band of Ottawa and Chippewa Indians Peshawbestown Wastewater Treatment Plant 3499 E. Putnam Road Suttons Bay, MI 49682 Leelanau County 44.966019, -85.64954 FRS ID 110009900009 Permit Number(s) (If Applicable) MI0054640 SIC and/or NAICS 4952 / 221320 Regulatory Representatives Participating in Inspection: Title Name Inspector Jennifer Bush Organization EPA REGION 5 Lead Inspector: Dean Maraldo [Signature] DINO MARALDO Digitally signed by DINO MARALDO Date: 2023.08.18 09:15:52 -05'00' EPA REGION 5 Maraldo.Dean@epa.gov (312) 353-2098 Supervisor Review: Ryan Bahr [Signature] Digitally signed by RYAN RYAN BAHR Date: 2023.08.18 BAHR 17:59:28 -05'00' EPA REGION 5 bahr.ryan@epa.gov 1 of 22 Peshawbestown Wastewater Treatment Plant Inspection Date: 08/04/2023 SECTION I - INTRODUCTION Site Entry and Inspection Objectives I, EPA REGION 5 Lead Inspector, Dean Maraldo, arrived at the Grand Traverse Band of Ottawa and Chippewa Indians' Peshawbestown Wastewater Treatment Plant ("Facility"), located at 3499 E. Putnam Road, Suttons Bay, Michigan, at 08:18 AM (ET) on 08/04/2023 for an announced inspection. I presented my inspector credentials to Joe Huhn and informed him that this was an EPA REGION 5 inspection to determine compliance as authorized by Clean Water Act (CWA) Section 308 and implementing regulations. EPA inspector Jennifer Bush joined me on the inspection and also presented inspector-in-training credentials to Mr. Huhn. This report is based on information supplied by Facility representatives, direct observations made by EPA inspectors, records and reports maintained by the permittee and other information including: photographs taken by EPA REGION 5 inspectors, physical evidence collected by EPA REGION 5 inspectors, measurements taken by EPA REGION 5 inspectors, verbal or written statements made by information supplied by Facility representatives during or subsequent to the on-site inspection, and materials, processes, data, photographs, or documents shown, demonstrated, or submitted to the EPA REGION 5 inspectors by Facility representatives during or subsequent to the on-site inspection. In addition, information gathered prior to or subsequent to the Inspection from a review of EPA and/or public records may be included in this report. Attendees Organization Attendee Name EPA REGION 5 EPA Grand Traverse Band Dean Maraldo Jennifer Bush Joe Huhn Grand Traverse Band Joe Burfield Facility/Site Description Title Lead Inspector Present in Opening Conf. Yes Inspector Yes Director of Public Yes Works West Bay Water Utility Yes Director Present in Closing Conf. Yes Yes Yes Yes I began by reviewing the Facility description provided in the Facility's NPDES permit ("Permit") (excerpt below) and the Facility representatives either confirmed or corrected (in bold) the information as described below. Unless noted otherwise, Facility responses were provided by Mr. Huhn. The application and plans indicate that the permittee operates a 0.12 MGD Sequencing Batch Reactor. Average daily flow is currently about 40k gallons or less. (SBR) system with phosphorus removal followed by ultraviolet disinfection. Solids from the SBR unit are wasted to two (2) aerobic digesters and then stored in covered tanks. From the storage tanks, the sludge is land applied by injection by a private contractor to farmland. The discharge is continuous to West Grand Traverse Bay. Facility/Site Information Next, I asked some background questions. Unless noted otherwise, Mr. Huhn provided the responses in the table below. Have any bypasses or overflows happened at the No plant or in the collection system in the last year? 2 of 22 Peshawbestown Wastewater Treatment Plant Inspection Date: 08/04/2023 Backup electrical power source, and does it turn on Generator at plant (installed ~2017), main LS has stationary automatically? generator, others portable Type(s) of primary flow measuring device(s)? Mag meter for influent, effluent has ultrasonic sensor Industrial Users Medical clinic with dental Are there any plans for renovation or additional Process of designing new lift station (one of the smaller equipment to allow for increased wastewater flow? systems) to replace the old station (there are eight lift stations in total, mostly small, with four main stations) Is there currently any portion of the treatment No train that is non-operational? Do you accept waste from septage haulers? If so, what problems have you experienced? Very infrequently, not open to the general public Do you use in-house or contract out for laboratory analyses? (including metals or WET testing) In house lab (for biochemical oxygen demand, phosphorus, ammonia, bacteria, total suspended solids, and pH), all but mercury and toxicity testing Responsible official Joe Huhn WWTP Design Capacity & Average Daily Flow 40,000 gallons per day, very little inflow or infiltration ("I&I") WWTP Approx. # of residents served 130 residential connections and 20 commercial and governmental connections Contributing (or shared) Jurisdictions No Outfalls: Outfall #001 to West Grand Traverse Bay Operation schedule: M-F, 8-5pm, on call weekends, with auto dialers for alarms What sort of failure alarm does the plant have? Power loss, high level in lift stations, mixer failure, pump failures, SBR basins levels Any Confidential Business Information concerns? No Inspection Focus Areas and Locations Location/Area/Sub-area Interview Reporting Self Monitoring Operations and Maintenance ("O&M") Sanitary Sewer Overflows ("SSOs") Flow Monitoring Discharge Monitoring Report ("DMR") Review Records Review Physical Inspection Final Outfall #1 Description Facility Office Facility Wastewater Treatment Building Shoreline of West Grand Traverse Bay (45.02934833, -85.60010666) 3 of 22 Peshawbestown Wastewater Treatment Plant Inspection Date: 08/04/2023 SECTION II - OBSERVATIONS Location: Interview/Reporting (non-DMR) Observation #: DM1-OB-001 Date: 08/04/2023 Mr. Huhn confirmed that non-DMR reporting required under the Permit is up to date, including the Asset Management Report and the Pollutant Minimization Program Status report for Mercury, due by January 31 each year. Location: Interview/Self Monitoring Observation #: DM1-OB-002 Date: 08/04/2023 Facility responses regarding Self Monitoring were provided by Mr. Huhn, unless noted otherwise. I started by asking about the location of influent and effluent sampling locations. Influent samples are collected before the headworks and composite effluent samples (time proportioned) before ultraviolet ("UV") treatment. Effluent grab samples collected after UV treatment, per the Permit. Composite samples are cooled to <4C to properly preserve them during the compositing period. During the last inspection, I recommended investing in NIST thermometers for refrigerators and autosamplers. Mr. Burfield confirmed that this was done. The Band recently submitted an NPDES Permit renewal application. I confirmed that the application was complete, including results of required additional monitoring. During the last inspection, I noted that sampling/lab forms were incomplete, lacking a place for date/time of sample collection and the name of person collecting sample. Mr. Burfield confirmed that the forms have not been updated to include this information. Location: Interview/O&M Observation #: DM1-OB-003 Date: 08/04/2023 Facility responses regarding O&M were provided by Mr. Huhn, unless noted otherwise. Are all treatment units operable? Yes During the last inspection, I observed that the digestor decant process relied on a portable trash pump. The Band intended on installing a permanent decant system. Mr. Burfield confirmed that they still use the trash pump. Is sufficient sludge wasted from treatment system at proper time intervals to maintain process efficiency? Yes, and scheduled for sludge hauling this month. On a regular basis, do operators monitor the key operating parameters (e.g., mixed liquor suspended solids MLSS, mixed liquor volatile suspended solids, and sludge age, and conducting the necessary adjustments to meet the limits of the permit? Yes, daily settleability, additional pH and DO. 4 of 22 Peshawbestown Wastewater Treatment Plant Inspection Date: 08/04/2023 Any bypasses over the last year? No. Are alarms sent to qualified personnel who can respond immediately to remedy the problem? Yes, Joe Burfield said automated alerts start with plant alarms, then staff cell phones. Are routine and preventive maintenance scheduled performed and recorded? Yes, Joe Burfield said they tried different programs, but using paper tracking currently. Is a logbook kept which documents all plant activities on a daily basis? Yes, Joe Burfield said they record Daily notes on a computer. Does the facility maintain an inventory of spare parts, either at the facility or close by, sufficient to keep all of its treatment units operational? Yes, Joe Burfield said he thinks they have a written inventory. Is the standby power regularly exercised under load? Yes, weekly exercise, and a semi-annual maintenance contract. Mr. Huhn mentioned that the collection system map is maintained in the Band's GIS system. I asked about the asset management requirements in the Permit. Mr. Huhn said they started an asset inventory for lift stations but not the wastewater plant. He also said that they have not started the asset risk evaluation, required under Permit Part I.C.3.a.G.(b). Mr. Huhn provided a copy of the 2022 Annual Asset Management Report due, January 31, 2023 (see Document Log, Appendix 2). Next, I asked about the Facility's O&M record system, including: Maintenance cost records: Mr. Burfield said he uses a spreadsheet for now. Repair history: rely on written tracking. Are Instruction files for operation and maintenance of each item of major equipment available? Yes Operator certifications: Joe Huhn (Michigan Class B); Joe Burfield (Michigan Class A); Ricky Woods (operator, Michigan Class C); also, currently interviewing for an apprentice operator. Location: Interview/SSOs Observation #: DM1-OB-004 Date: 08/04/2023 I asked if there have there been any backups or overflows in the sanitary sewer collection system, including pump stations, manholes and piping since the last inspection. Mr. Huhn said there were no SSOs since the last inspection. Location: Interview/Flow Monitoring Observation #: DM1-OB-005 Date: 08/04/2023 I asked what type of influent and effluent flow meters are used. Mr. Burfield said they rely on a mag meter for influent flow, and an ultrasonic sensor over a flume for effluent flow. Flow measuring devices are professionally calibrated at least once per year. 5 of 22 Peshawbestown Wastewater Treatment Plant Inspection Date: 08/04/2023 Location: Interview/DMR Review Observation #: DM1-OB-006 Date: 08/04/2023 I provided a list of permit effluent limit exceedances (see Document Log, Appendix 2) to the Facility representatives and asked to describe the cause(s) if known. Mr. Huhn provided the information below. October/November 2021: Phosphorus, Total Suspended Solids, and pH effluent limit exceedances, including exceedances of daily maximum limits. Caused by accidental ferric chloride cycling into tanks, killing "bugs", and resulting in low pH (2.7); returned to compliance the next month. April/May 2019: Phosphorus effluent limit exceedances, including exceedances of daily maximum limits. Due to organic overload from septage haulers. I asked if all noncompliance which may endanger health or the environment, including all violations of daily limits, have been orally reported within 24 hours and followed up with a letter to EPA within 5 days. Mr. Huhn said they have not reported all Permit effluent limit exceedances. Location: Physical Inspection Observation #: DM1-OB-007 Date: 08/04/2023 Weather: sunny mild The physical inspection of the wastewater treatment plant began at 10:20 AM (ET) on August 4, 2023. Joe Huhn and Joe Burfield led the tour of the facility. Inspection observations were recorded in a field notebook and captured in the Photo Log (Appendix 1). The physical inspection of the wastewater treatment plant was completed at 11:10 AM (ET) on August 4, 2023. Photo(s) 1. GTBP0271.JPG 2. GTBP0279.JPG 3. GTBP0269.JPG 4. GTBP0270.JPG 5. GTBP0274.JPG 6. GTBP0273.JPG 7. GTBP0275.JPG 8. GTBP0276.JPG 9. GTBP0277.JPG 10. GTBP0278.JPG 11. GTBP0282.JPG 12. GTBP0280.JPG 13. GTBP0281.JPG 14. GTBP0283.JPG 15. GTBP0284.JPG 6 of 22 Peshawbestown Wastewater Treatment Plant Inspection Date: 08/04/2023 SECTION III - RECORDS REVIEW Record: DMR Reports Ref #: DM1-RR-001 Reviewed By: Dean Maraldo AOC: Yes Reviewed Date: 08/04/2023 I reviewed the DMR and bench sheets for May 2023, and noted the following issues: Bench sheet: May 2023; form should include analysis time for pH, Dissolved Oxygen ("DO"), and any other parameters. The form should also include the sample analysis and collection time and operator/sampler name, and analyst name. See Appendix 2 for copy of the daily lab/bench sheet for 5/31/2023. I checked several days of bench sheets and compared against the DMR calculation sheet. No issues or errors were found. SECTION IV - SAMPLING ACTIVITIES AND ANALYTICAL RESULTS No sampling was conducted. SECTION V - AREA 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 #: DM1-OB-003 Location: Interview/O&M Regulation and/or Permit Requirement Permit Part II.B.1. Proper operation and maintenance AOC: During the last inspection, I observed that the digestor decant process relied on a portable trash pump. The Band intended on installing a permanent decant system. Mr. Burfield confirmed that they still use the trash pump. AOC Reference #: DM1-OB-003 Location: Interview/O&M Regulation and/or Permit Requirement Permit Part I.C.3.a.G. Inventory and assessment of fixed assets AOC: Mr. Huhn said they started an asset inventory for lift stations but not for the wastewater plant. He also said that they have not started the asset risk evaluation, required pursuant to Permit Part I.C.3.a.G.(b). AOC Reference #: DM1-OB-006 Location: Interview/DMR Review Regulation and/or Permit Requirement Permit Part I.A. Final Effluent Limitations and Monitoring Requirements AOC: Permit effluent limit exceedances. October/November 2021: Phosphorus, Total Suspended Solids, and pH effluent limit exceedances, and April/May 2019 Phosphorus effluent limit exceedances. 7 of 22 Peshawbestown Wastewater Treatment Plant Inspection Date: 08/04/2023 AOC Reference #: DM1-OB-006 Location: Interview/DMR Review and Reporting Regulation and/or Permit Requirement Permit Part II.A.D.8 Reporting Requirements AOC: I asked if all noncompliance which may endanger health or the environment, including all violations of daily limits, have been orally reported within 24 hours and followed up with a letter to EPA within 5 days. Mr. Huhn said they have not reported all Permit effluent limit exceedances. AOC Reference #: DM1-OB-003 Location: Interview/O&M Regulation and/or Permit Requirement Permit Part I.C.3.a.G.(b). Inventory and assessment of fixed assets AOC: Mr. Huhn said they started an asset inventory for lift stations but not the wastewater plant. He also said that they have not started the asset risk evaluation, pursuant to Permit Part I.C.3.a.G.(b). AOC Reference #: DM1-RR-001 Records Review: DMR Reports Regulation and/or Permit Requirement 40 CFR Part 136, Permit Part II.C.3. Monitoring Procedures; Permit Part II.B.1. Proper Operation and Maintenance (proper operation and maintenance also includes adequate laboratory controls and appropriate quality assurance procedures) AOC: Bench sheet/form for May 2023 should include analysis time for pH, DO, and any other parameters. The form should also include the sample analysis and collection time and operator/sampler name, and analyst name. AOC Reference #: DM1-OB-007 Location: Physical Inspection Regulation and/or Permit Requirement Permit Part I, Treatment Facility Description AOC: The abandoned Aqua Disc tertiary filter is no longer in use and not included in process description in the current Permit but included in process flow diagram for the new proposed Permit. Mr. Huhn said he would contact the EPA permitting program to see if diagram can be corrected prior to issuance of the new Permit. SECTION VI - CLOSING CONFERENCE AND FOLLOW UP Closing Conference I held a closing conference with Facility personnel at 11:20 AM (ET) on 08/04/2023. During the closing conference, I discussed the observations, preliminary Areas of Concern, and follow up items identified during the inspection. Observations and preliminary Areas of Concern have not yet been evaluated for a formal compliance determination. Before concluding, I discussed the timeframe for completion of the inspection report. With no additional questions, I concluded the inspection at 11:30 AM (ET) on 08/04/2023. 8 of 22 Peshawbestown Wastewater Treatment Plant Inspection Date: 08/04/2023 Follow Up Questions Of the follow up questions discussed during the inspection, only the item below is outstanding. Location: Interview Area: O&M Sub-area: Asset Management DM1-OB-003 Facility representatives will confirm if the Facility maintains a written inventory of spare parts for the wastewater treatment system. Communication Log No additional information received by EPA REGION 5 after exiting the Facility on 08/04/2023. SECTION VII - LIST OF APPENDICES 1. Photo Log 2. Document Log 9 of 22 Peshawbestown Wastewater Treatment Plant Inspection Date: APPENDIX 1: PHOTO LOG 08/04/2023 Influent flow meter and tap location 08/04/2023 10:26 AM (ET) No CBI Physical Inspection Located in treatment building. No PII GTBP0269.JPG Photographer: Dean Maraldo Ferric room 08/04/2023 10:28 AM (ET) Physical Inspection Location of Ferric tanks (2). No CBI No PII GTBP0270.JPG Photographer: Dean Maraldo 10 of 22 Peshawbestown Wastewater Treatment Plant Inspection Date: 08/04/2023 SCADA Screen 08/04/2023 10:29 AM (ET) No CBI No PII Physical Inspection SCADA screen located in laboratory/control room. GTBP0271.JPG Photographer: Dean Maraldo Pre-EQ Basin 08/04/2023 10:33 AM (ET) No CBI Physical Inspection SBR Pre-EQ Basin, located in Tank Room. No PII GTBP0273.JPG Photographer: Dean Maraldo 11 of 22 Peshawbestown Wastewater Treatment Plant Inspection Date: 08/04/2023 SBR Basin #1 GTBP0274.JPG 08/04/2023 10:34 AM (ET) No CBI No PII Photographer: Dean Maraldo Physical Inspection SBR Basin #1 currently offline and used for additional storage as needed. SBR Basin #2 08/04/2023 10:35 AM (ET) No CBI Physical Inspection SBR Basin #2 currently in use. No PII GTBP0275.JPG Photographer: Dean Maraldo 12 of 22 Peshawbestown Wastewater Treatment Plant Inspection Date: 08/04/2023 Influent Autosampler GTBP0276.JPG 08/04/2023 10:37 AM (ET) No CBI No PII Photographer: Dean Maraldo Physical Inspection Located at Pre-EQ basin. Refrigerated unit with heat-sink thermometer. Digestors (2) 08/04/2023 10:39 AM (ET) Physical Inspection Digestors (2) No CBI No PII GTBP0277.JPG Photographer: Dean Maraldo 13 of 22 Peshawbestown Wastewater Treatment Plant Inspection Date: 08/04/2023 Digestors (2) GTBP0278.JPG 08/04/2023 10:39 AM (ET) No CBI No PII Photographer: Dean Maraldo Physical Inspection Note trash pump used to decant to Basin 1 (storage), usually once per day. Ultraviolet (UV) Treatment GTBP0279.JPG 08/04/2023 10:49 AM (ET) No CBI No PII Photographer: Dean Maraldo Physical Inspection UV system contains four banks. Three banks operational, fourth is offline and used as needed. 14 of 22 Peshawbestown Wastewater Treatment Plant Inspection Date: 08/04/2023 Effluent autosampler 08/04/2023 10:51 AM (ET) No CBI No PII Physical Inspection Effluent auto sampler before UV. Noted clean tubing. GTBP0280.JPG Photographer: Dean Maraldo Effluent manhole GTBP0281.JPG 08/04/2023 10:53 AM (ET) No CBI No PII Photographer: Dean Maraldo Physical Inspection Noted flow sensor in manhole above flume. From here flow travels about 1/2 mile to the bay. 15 of 22 Peshawbestown Wastewater Treatment Plant Inspection Date: 08/04/2023 Aqua Disc System GTBP0282.JPG 08/04/2023 10:56 AM (ET) No CBI No PII Photographer: Dean Maraldo Physical Inspection Abandoned Aqua Disc tertiary filter. No longer in use and not included in process description in the current Permit but included in process flow diagram for the new proposed Permit (See Appendix 2 for copy of the flow diagram). Mr. Huhn said he would contact the EPA permitting program to see if diagram can be corrected prior to issuance of the new Permit. Lift Station 4 GTBP0283.JPG 08/04/2023 11:08 AM (ET) No CBI No PII Photographer: Dean Maraldo Physical Inspection Lift station 4 wet well. Pumps sewage to Lift Station 3 (last station before plant). 16 of 22 Peshawbestown Wastewater Treatment Plant Inspection Date: 08/04/2023 Outfall #001 GTBP0284.JPG 08/04/2023 11:11 AM (ET) No CBI No PII Photographer: Dean Maraldo Physical Inspection Coordinates: 45.02934833, -85.60010666 Location of Outfall #001 (buried), which runs about 600 feet into West Grand Traverse Bay. 17 of 22 Peshawbestown Wastewater Treatment Plant Inspection Date: APPENDIX 2: DOCUMENT LOG Documents Received and Attached to Report Below Document Name Asset Management Report for 2022 Effluent Limit Exceedance Report (8/2018-6/2023) Laboratory Bench/Work Sheet for May 31, 2023 Process Flow Diagram, including abandoned filtration system Documents Received and Not Attached to Report Document Name NPDES Permit Application Forms, signed 2/21/2023 08/04/2023 Contains CBI or PII Date Received No 8/4/2023 No Provided by EPA No 8/4/2023 No 8/4/2023 Pages 1 1 1 1 Contains CBI or PII Date Received No 8/4/2023 Pages 107 18 of 22 PESHAWBESTOWN, MICHIGAN NPDES PERMIT NO. MI-0054640-05 SUMMARY OF ASSET MANAGEMENT ACTIVITIES FOR 2022 Below is an update regarding the asset management plan for the Peshawbestown MI., SBR plant for 2022. This plan is in the process of being developed and is partially implemented at this time. Additional work has continued on the development of the asset management plan thru 2022 and perhaps for several years beyond. A - Staffing: Below are the staff that oversee the Peshawbestown SBR Plant and their level of certification. - Norman Burfield - Michigan Class A wastewater certification - Joseph Huhn - Michigan Class B wastewater certification - CJ McGrath - not currently certified - Richard Woods - Michigan Class C wastewater certification B - Inspections: - Manhole inspections - Lift station inspections - Grease removal - Fire Extinguishers and Eye wash stations C - Expenditures: Three main areas include the Lift stations, Collection System and SBR plant - By-pass installed on station 1 and 2 - GIS mapping of collection system - UV lighting D - Summary of asset areas identified for action - Lift station replacement at Med lodge - Valve replacement - Lift station by-pass for #3 E - Budget for capital improvement - The Water Utilities program overseen by the Grand Traverse Band staff bill and collect revenue that equated to operating expenses and depreciation expenses. All assets over $5,000 are depreciated over a specific life cycle. These funds are collected throughout the year by the program and set aside for future need. Our depreciation amount for FY2022 was $171,259. Additional information can be request by contacting Joe Huhn by phone at 231-499-4235 or email joe.huhn@gtbindians.com ______________________________________ Date: 1/19/2023 Joseph R. Huhn Peshawbestown Wastewater Treatment Plant Page 19 of 22 Inspection date: 08/04/2023 Effluent Limit Exceedances Report MI0054640: GRAND TRAVERSE BAND OF OTTAWA, SUTTONS BAY, MI 49682 Monitoring Period Date Range: 08/01/2018 to 06/30/2023 Exceedance Details Monitoring Period Date 4/30/2019 5/31/2019 5/31/2019 10/31/2021 10/31/2021 11/30/2021 11/30/2021 11/30/2021 11/30/2021 Parameter Description Phosphorus, total (as P) Phosphorus, total (as P) Phosphorus, total (as P) pH Solids, total suspended Solids, total suspended Solids, total suspended Phosphorus, total (as P) Phosphorus, total (as P) Limit Type MAXIMUM MO AVG MAXIMUM MINIMUM WKLY AVG MO AVG WKLY AVG MO AVG MAXIMUM DMR Value 1.1 1 2.3 2.7 31 23 30 1.1 1.8 Limit Value 1 0.5 1 6 22.5 15 22.5 0.5 1 Limit Value Qualifier <= <= <= >= <= <= <= <= <= Limit Value Unit mg/L mg/L mg/L SU mg/L mg/L mg/L mg/L mg/L % Exceedance 10 100 130 38 53 33 120 80 Peshawbestown Wastewater Treatment Plant Page 20 of 22 Inspection date: 08/04/2023 Peshawbestown Wastewater Treatment Plant Page 21 of 22 Inspection date: 08/04/2023 Peshawbestown Wastewater Treatment Plant Page 22 of 22 Inspection date: 08/04/2023