Document OEGq7vbO4xa10m97vaE9dMMNv

NPDES Inspection Report - Wastewater Treatment Facility National Database Information Inspection Date: August 21, 2024 Inspection Type: CEI - Wastewater Treatment Facility Entry/Exit Time: Opening Conference: 9:15 a.m.-1:30 p.m. on 8/19/2024 Site Review: 11:45 a.m.-12:40 p.m. on 8/21/2024 NPDES ID Number: SDG589504 NAICS Code: 221320 Inspection ID: 202408_SDG589504 Lead inspector and affiliation: Jennifer Ferrando / EPA Region 8 Inspector and affiliation: Brit Rustad / EPA Region 8 Facility Location Information Site/Facility Name & Location: Manderson Lagoon System Lat/Long: 4314'6.11"N, 10227'53.87"W 19 Ballpark Dr., Manderson, SD 57756 Email Report to: Ernie Abold, Director, Oglala Sioux Tribe (OST) Water & Sewer h20sewer@gwtc.net Contact Information Facility Contacts: Person/Company meeting definition of "Operator" Authorized Official(s) Name(s)/Title Ernie Abold / Director / OST Water & Sewer / present during the opening and closing conferences as well as the inspection James Begeman / Tribal Utility Consultant / Indian Health Service (IHS) / present during the opening and closing conferences as well as the inspection Oglala Sioux Tribe, Water and Sewer (OST Water & Sewer) Ernie Abold / Director / OST Water & Sewer Permit Information Is the permit on site and available? Lagoon Category: Potential to Monitoring Frequency: N/A Yes, digitally discharge but no discharge authorized, according to the authorization of coverage letter. Effective Date: 04/05/2016 Expiration Date: 12/31/2020 Is the Facility under a compliance (administratively continued) schedule? No Is correct contact information indicated on ICIS? Yes Indicate correct contact information: N/A Receiving Water(s): Wounded Knee Creek Regulatory Inspector's source of information: Notice of Intent for the permit, ICIS, ECHO and facility representatives Page 1 of 11 Areas Evaluated During Inspection Permit Self-Monitoring Program Records Compliance Schedule Facility Site Review Laboratory Effluent/Receiving Waters Operations and Maintenance Flow Measurement Sludge Handling/Disposal Pretreatment Pollution Prevention Stormwater Combined Sewer Overflow Sanitary Sewer Overflow Report Review and Signature Drafter Name Draft Date Contact Information JENNIFER JENNIFER FERRANDO Digitally signed by Jennifer Ferrando FERRANDO 15:44:46 -07'00' Date: 2024.11.05 10/17/2024 U.S. EPA Region 8 Denver, Colorado ferrando.jennifer@epa.gov (303) 312-6601 Reviewer Name Draft Date Contact Information U.S. EPA Region 8 Brit Rustad 10/18/2024 Denver, Colorado rustad.brit@epa.gov (303) 312-6885 Management Reviewer Name/Signature/Date Contact Information EMILIO LLAMOZAS Digitally signed by EMILIO LLAMOZAS Date: 2024.11.05 14:52:40 -07'00' U.S. EPA Region 8 Denver, Colorado llamozas.emilio@epa.gov (303) 312-6407 Emilio Llamozas, NPDES and Wetlands Enforcement Section Supervisor Inspection Narrative and Site Description 1.0 Introduction The inspection was conducted at the Manderson Lagoon System wastewater treatment facility (facility; WWTF) located in Manderson, Oglala Lakota County, South Dakota, to evaluate compliance with the facility's National Pollutant Discharge Elimination System (NPDES) permit. The EPA is responsible for implementing the NPDES program in Indian Country within the State of South Dakota. The inspection was announced approximately one month prior to the inspection to coordinate logistics for the inspection. On the morning of August 19, 2024, U.S. Environmental Protection Agency (EPA) inspectors Brit Rustad and Jennifer Ferrando (collectively, "we") met with Oglala Sioux Tribe Water & Sewer (OST Water & Sewer) Director, Ernie Abold. We were also joined by Indian Health Service (IHS) Page 2 of 11 representative James Begeman, Tribal Utility Consultant. We presented our credentials and had an opening conference in the OST Water & Sewer office where we explained the purpose of the inspection and discussed the design, operation, and Clean Water Act and NPDES compliance of multiple WWTFs operated by the OST Water & Sewer, including the subject facility. After the opening conference, we proceeded to conduct site reviews of the WWTFs operated by OST Water & Sewer, including the subject facility, for the remainder of August 19, 2024, through August 22, 2024. Throughout the inspection, we noted our observations in a checklist. Photographs taken during the inspection are included in the attached photo log. 2.0 OST Water & Sewer Operations During the opening conference when discussing all facilities, Ernie Abold indicated that over the course of a week all WWTFs, including four lift stations, are checked. OST Water & Sewer is not keeping weekly inspection logs for these checks or any operations or maintenance logs. Only two of the four lift stations currently have Supervisory Control and Data Acquisition (SCADA) capabilities, which creates a burden for the limited staff to physically go check the two remaining lift stations several times per week to ensure they are operating properly. Ernie Abold stated that OST Water & Sewer performs jetting of the collection system for all WWTFs twice a year, in the spring and fall. Lastly, sludge has not been removed from any WWTFs; according to the tribal utility consultant, sludge accumulation has not been an issue with any of the lagoons on Pine Ridge based on previous depth testing and observations. OST Water & Sewer operates both the water distribution as well as sewer collections systems across the Pine Ridge Reservation, which encompasses just over 2 million acres. According to Ernie Abold there are approximately 48,000 tribal members with half of these being served by the sewer collections system and the other half being primarily on septic systems. Septage from the majority of these septic systems is pumped and hauled to OST Water & Sewer's WWTFs throughout the reservation. At the time of the inspection, OST Water & Sewer employed 3 operators, in addition to the Director, and various managerial and administrative support staff. Only one of the three operators held any certifications. OST Water & Sewer customers, rates, and finances were briefly discussed during the opening conference. Users are billed a single, monthly water and wastewater fee. Ernie Abold stated that OST Water & Sewer's budget is not supplemented by any other resources. OST Water & Sewer recently began a 5-year rate increase, as the last rate increase was in 2009. Additionally, according to the OST Water & Sewer representative, the utility is owed over $1 million in outstanding user fees. This is in part a result of OST Water & Sewer's limited ability to discontinue service for customers who do not pay their bill. 3.0 Facility Description and Site Review The facility is permitted as a no discharge facility under the EPA Region 8 General Permit for Wastewater Lagoon Systems in Indian Country in South Dakota (Permit) issued in 2016. A Notice of Page 3 of 11 Intent (NOI) was submitted on September 30, 2024, for coverage under the 2022 Lagoon General Permit. The NPDES Permits Section is currently processing the NOI. According to the facility representatives the facility serves roughly 385 people in the Manderson community, including a school cafeteria. The facility accepts hauled waste from pumped septic tanks in the surrounding communities. According to the facility's 2016 Notice of Intent (NOI) for General Permit coverage, the hauled waste is dumped directly into the primary cell or into a manhole immediately upstream of the lagoon. During the opening conference on August 19, 2024, Ernie Abold stated that he did not know whether haulers were using the Manderson Lagoon for septage disposal. The facility is a four-cell lagoon system. Wastewater flows into the primary cell (Cell 1) and from there can be directed to either of the secondary cells (Cell 2 or Cell 3) via a level control structure in the berm near the eastern corner of Cell 1. Wastewater from Cell 2 can also flow to Cell 3 via the same level control structure. From Cell 3, wastewater can flow into a percolation pond (Cell 4). The facility can discharge via an outfall on the south berm of Cell 4; discharges would flow to Wounded Knee Creek, located approximately 150 feet south of Cell 4. James Begeman stated that an IHS project is underway to repair Cell 2 in 2025; the project includes repairing erosion around the berms and relining the cell. When we arrived, the gate was open, the lock was missing, and warning signs were not posted near the gate (photo 1), though several warning signs were observed elsewhere around the perimeter fence. The perimeter fence was damaged and down in some locations (photo 5) and horses were grazing on the berms of the lagoon, inside the perimeter fence. We observed septage on the berms of Cell 1, near the facility gate (photo 2). Only Cell 1 contained wastewater at the time of the inspection; James Begeman estimated that the wastewater level was between 3 and 5 feet in Cell 1 based on the configuration of the valves in the level control structure. The wastewater in Cell 1 was green in color and appeared to contain high levels of algae (photos 2 and 3). James Begeman stated that Cell 2 had been temporarily removed from service in anticipation of the upcoming IHS rehabilitation project. He also suggested that excessive percolation in Cells 1 and 3 may be preventing the cells from filling and providing the intended level of treatment prior to percolation in Cell 4. Excessive vegetation exceeding 6 inches in height and woody vegetation (small shrubs) were present on the inside slopes of the berms of all four cells and throughout Cells 2, 3, and 4 (photos 1, 4, 6, and 7). Trees were also growing throughout Cell 4 (photo 9). The inside slopes of the north, east, and south berms of Cell 2 were heavily eroded in multiple locations (photo 7). The overflow pipe from Cell 4 is set very high in the south berm of the cell, approximately 6 inches from the top of the berm. Furthermore, the overflow structure is an open pipe, with no means of controlling discharges if the wastewater in Cell 4 were to reach the level of the pipe. Page 4 of 11 At the end of our inspections of OST Water & Sewer-operated WWTFs on August 22, 2024, we held a brief closing conference with Ernie Abold and James Begeman where we discussed preliminary findings. The following week on August 29, 2024, the EPA sent an email to Ernie Abold with the preliminary findings from the inspection and resources for documenting inspections, and a lagoon troubleshooting guide. On August 29, 2024, OST Water & Sewer submitted a Sanitary Sewer Overflow (SSO) Incident Report Form notifying EPA of the overflow from the Manderson Lagoon manhole on the west berm of Cell 1 (photo 4), and the spill response activities and corrective actions taken. The report indicates that OST Water & Sewer has added the SSO location to the preventive maintenance program and adjusted its schedule or method of preventive maintenance to prevent future SSOs at this location. Findings, Corrective Actions and Recommendations Finding #1: The Permittee was not documenting weekly lagoon inspections. The facility representative stated that OST Water & Sewer staff visit each lagoon and lift station weekly but did not maintain records of the inspections. The inspectors provided the facility representatives with a lagoon inspection report template form (Appendix D of the 2022 Lagoon General Permit) that the facility representatives could use to document the weekly lagoon inspections. Permit Requirement: Section 3.3.1 of the Permit states, "On at least a weekly basis, unless otherwise modified by written approval from the EPA, the permittee shall inspect its wastewater treatment facility. The permittee shall maintain a notebook recording all information obtained during the inspection. At a minimum, the notebook shall include the following: 3.3.1.1. Name of facility and permit number; 3.3.1.2. Date and time of the inspection; 3.3.1.3. Name of the inspector(s); 3.3.1.4. The facility's discharge status; 3.3.1.5. The flow rate of the discharge if occurring; 3.3.1.6. If a discharge is occurring, has occurred since the previous inspection, and/or if a discharge is likely to occur before the next inspection. (Note: If a discharge has occurred or is likely to occur before the next inspection, perform the appropriate monitoring and reporting requirements in Parts 3.2 and 5.4 of this permit if not already done.); 3.3.1.7. Is there is any leakage through the dikes; 3.3.1.8. Are there are any animal burrows in the dike; 3.3.1.9. Is there any erosion of the dikes (e.g., rills, cracks or other structural indications of erosion); 3.3.1.10. Are there are any rooted plants, including weeds growing in the water; 3.3.1.11. Does the vegetation growth on the dikes needs mowing (e.g. greater than 6" tall); 3.3.1.12. List the date scheduled for operation and maintenance procedures to be undertaken at the wastewater treatment facility. Page 5 of 11 3.3.1.13. Identification of operational problems and/or maintenance problems; 3.3.1.14. Recommendations, as appropriate, to remedy identified problems; 3.3.1.15. A brief description of any actions taken with regard to problems identified; and, 3.3.1.16. Other information, as appropriate. The permittee shall maintain the notebook in accordance with required record-keeping items listed above and shall make the log available for inspection, upon request, by authorized representatives of the U.S. Environmental Protection Agency or the applicable Tribe (see Part 5.10 of this permit)." Section 3.3.3 of the Permit states, "Problems identified during the inspection shall be listed with corrective action and a time frame to correct the issue. Example: repair cracks in North berm, remove animal and repair burrow, within 7 days. (See Part 6.5 of this permit.)" Section 5.7 of the Permit states, "The permittee shall retain records of all monitoring information, including all calibration and maintenance records and all original strip chart recordings for continuous monitoring instrumentation, copies of all reports required by this permit, and records of all data used to complete the application for this permit, inspection records, notifications to the EPA per this permit, and DMRs, for a period of at least five years from the date of the sample, measurement, report, application or submittal. Records of monitoring required by this permit related to sludge use and disposal activities must be kept at least five years (or longer as required by 40 C.F.R. Part 503). This period may be extended by request of the Director at any time. Data collected on site, data used to prepare the DMR, copies of DMRs, a copy of this NPDES permit, and the notice of intent for permit coverage, must be maintained on site." Corrective Action: Ensure that lagoon inspections are conducted weekly and documented in accordance with the Permit. Ensure that weekly lagoon inspection reports are retained in accordance with the recordkeeping requirements of the Permit. Provide the EPA and the Oglala Sioux Tribe Environmental Department with 1 month's worth of weekly inspection reports. Finding #2: Excessive vegetation was present throughout the lagoon and trees were growing in Cell 4. Vegetation more than 6 inches in height and woody vegetation was present on the inside berms of all cells and throughout Cells 2 - 4 (photos 1, 4, 6, and 7). Trees were growing inside Cell 4 (photo 9). Permit Requirement: Section 6.5 of the Permit states, "The permittee shall at all times properly operate and maintain all facilities and systems of treatment and control (and related appurtenances) which are installed or used by the permittee to achieve compliance with the conditions of this permit. Proper operation and maintenance also includes adequate laboratory controls and appropriate quality assurance procedures. This provision requires the operation of back-up or auxiliary facilities or similar systems which are installed by a permittee only when the operation is necessary to achieve compliance with the conditions of the permit. However, the permittee shall operate, at a minimum, one complete set Page 6 of 11 of each main line unit treatment process whether or not this process is needed to achieve permit effluent compliance. In addition to the operation and maintenance items in the manual for the lagoon system, the permittee shall do the following maintenance: ... 6.5.4. Remove rooted plants, including weeds, from the water on a regular basis or as needed; and 6.5.5. Keep the dikes mowed on a regular basis during the growing season or as needed (e.g., keep growth below 6" in height)." Corrective Action: Remove the overgrown vegetation and trees on the inside and around the berms and make repairs where roots have damaged the liner or compromised the structural integrity of the berms in accordance with Section 6.5 and relevant subparts of the Permit. Submit to the EPA and the Oglala Sioux Tribe Environmental Department photos once the vegetation and trees have been removed. Finding #3: Erosion was observed around the berms of Cell 2. The north, east, and south berms of Cell 2 were heavily eroded on the inside slopes (photo 7). Unstable and eroded berms can add total suspended solids to the wastewater in the lagoon. In addition, ongoing erosion can damage the lagoon liner, causing excessive water loss and compromising the lagoon's treatment effectiveness. The tribal utility representative indicated an IHS project scheduled for 2025 will include reshaping the berms and relining Cell 2. Permit Requirement: Section 6.5 of the Permit states, "The permittee shall at all times properly operate and maintain all facilities and systems of treatment and control (and related appurtenances) which are installed or used by the permittee to achieve compliance with the conditions of this permit. Proper operation and maintenance also includes adequate laboratory controls and appropriate quality assurance procedures. This provision requires the operation of back-up or auxiliary facilities or similar systems which are installed by a permittee only when the operation is necessary to achieve compliance with the conditions of the permit. However, the permittee shall operate, at a minimum, one complete set of each main line unit treatment process whether or not this process is needed to achieve permit effluent compliance. In addition to the operation and maintenance items in the manual for the lagoon system, the permittee shall do the following maintenance: ... 6.5.3. Promptly repair damage to dikes caused by burrowing animals and/or erosion." Corrective Action: Repair the erosion and any portions of the liner that may have been damaged. Submit to the EPA and the Oglala Sioux Tribe Environmental Department documentation of the repairs (e.g., photographs of the construction work and reshaped berms, or documentation associated with the IHS repair project that describes the work completed). Page 7 of 11 Finding #4: The gate to the lagoon was unlocked and open, a warning sign was not posted at the gate, and the perimeter fence was damaged. The facility gate was open when we arrived and the lock was missing (photo 1). Warning signs were posted in several locations around the lagoon, but there was no warning sign near the gate. The perimeter fence was damaged and down in several locations (photo 5). Horses were grazing on the lagoon berms inside the fence. EPA Guidance: EPA has developed guidance manuals on the proper operation and maintenance of lagoons. One of the guidance materials is called "Principles of Design and Operations of Wastewater Treatment Pond Systems for Plant Operators, Engineers, and Managers" (August 2011, EPA/600/R-11/088). https://www.epa.gov/sites/production/files/2014-09/documents/lagoon-pond-treatment-2011.pdf This guidance manual indicates on page 9-20 that: "To discourage use of the ponds for recreation, the entire area should be fenced and warning signs displayed." Permit Requirement: Section 6.5 of the Permit states, "The permittee shall at all times properly operate and maintain all facilities and systems of treatment and control (and related appurtenances) which are installed or used by the permittee to achieve compliance with the conditions of this permit. Proper operation and maintenance also includes adequate laboratory controls and appropriate quality assurance procedures. This provision requires the operation of back-up or auxiliary facilities or similar systems which are installed by a permittee only when the operation is necessary to achieve compliance with the conditions of the permit. However, the permittee shall operate, at a minimum, one complete set of each main line unit treatment process whether or not this process is needed to achieve permit effluent compliance." Recommendation: Ensure the lagoon gate is maintained and locked to prevent unauthorized access and entrance as well as potential damage from horses on the berms. EPA recommends providing a combination key to septage haulers that are authorized by the OST Water & Sewer to discharge septage to the facility so that they can access the lagoon without breaking the lock. Ensure the lagoon fencing is intact and signs posted to prevent unauthorized access. Finding #5: The facility does not have enough staff or funding. During the opening conference, staffing and funding resources were discussed. The facility representatives estimated that six operators would be needed, in addition to the Director, to operate the WWTFs in compliance with the permit requirements; however, at the time of the inspection, only three operators were employed by OST Water & Sewer. In addition, the utility does not have sufficient revenue and is not able to collect unpaid user fees to fund necessary operation and maintenance activities. It is apparent based on that conversation as well as field observations that this facility does not have adequate staff or funding to fully comply with the permit. Page 8 of 11 Permit Requirement: Section 6.1 of the Permit states, "The permittee must comply with all conditions of this permit. Any failure to comply with the permit may constitute a violation of the Clean Water Act and may be grounds for enforcement action, including, but not limited to permit termination, revocation and reissuance, modification, or denial of a permit renewal application. The permittee shall give the director advance notice of any planned changes at the permitted facility that will change any discharge from the facility, or of any activity that may result in failure to comply with permit conditions." Recommendation: EPA recommends developing a staffing and funding plan (plan) that includes the number of staff needed to comply with the permit, staff retention plan (competitive pay and proper training), SOPs for collection of outstanding fees, and evaluation of alternative funding sources. EPA also recommends that the plan include deadlines for accomplishing each of the items listed in the plan. Finding #6: Septage haulers were not backing up to the lagoon. Septage was observed on the top of the berm of Cell 1, near the gate (photo 2). It appeared that septage haulers were not getting close enough to the lagoon before dumping. Permit Requirement: Section 6.5 of the Permit states, "The permittee shall at all times properly operate and maintain all facilities and systems of treatment and control (and related appurtenances) which are installed or used by the permittee to achieve compliance with the conditions of this permit..." Recommendation: Ensure vegetation growth is controlled at the septage dumping location so that trucks can get close enough to dump septage into the lagoon. Additionally, ensure that dumping is not causing erosion at the edge of the berm or consider constructing a concrete receiving pad or similar structure where septage can be dumped into the lagoon without damaging the berms. Educate septage haulers on appropriate and expected procedures for off-loading septage to the lagoon. Finding #7: The facility was experiencing an active sanitary sewer overflow (SSO). Raw sewage was overflowing from a manhole on the west berm Cell 1 at the time of the inspection (photo 4). Wastewater was flowing from the manhole into Cell 1. EPA Guidance: EPA has developed guidance manuals on the proper operation and maintenance of lagoons. One of the guidance materials is called "Principles of Design and Operations of Wastewater Treatment Pond Systems for Plant Operators, Engineers, and Managers" (August 2011, EPA/600/R-11/088). https://www.epa.gov/sites/production/files/2014-09/documents/lagoon-pond-treatment-2011.pdf This guidance manual indicates on page 9-11 that: "Maintaining an aerobic pond in good condition requires full-time operator attention. These activities should be performed on a daily basis, on a regular schedule and as needed: Page 9 of 11 x Maintain mechanical equipment x Keep pipelines, diversion boxes and screens clean x Collecting samples x Run lab tests x Perform housekeeping" And on page 9-12 that: "9.4.2.3 Maintenance General maintenance guidelines: x Inlet and outlet structures should be cleaned regularly to remove any floating debris, caked scum, or other trash that might produce odors or be unsightly." The following resources may assist OST Water & Sewer in preventing future SSOs: x Wastewater Collection System Toolbox: https://www3.epa.gov/region1/sso/toolbox.html x Collection System Operation and Maintenance Fact Sheet https://www3.epa.gov/npdes/pubs/sewcl.pdf x Condition Assessment of Underground Pipes: https://www3.epa.gov/region1/sso/pdfs/condition-assessment-underground-pipes.pdf x Guide for Evaluating Capacity, Management, Operation, and Maintenance Programs at Sanitary Sewer Systems: https://www3.epa.gov/npdes/pubs/cmom_guide_for_collection_systems.pdf x Small and Rural Wastewater Systems: https://www.epa.gov/small-and-rural-wastewatersystems x NPDES SSO fact sheets: https://www.epa.gov/npdes/npdes-sso-fact-sheets Permit Requirement: Section 5.8.2 of the Permit states, "The following occurrences of noncompliance shall be reported by telephone to the EPA, Region 8, NPDES Enforcement Unit at (800) 227-8917 (8:00 a.m. - 4:30 p.m. Mountain Time) and the applicable Tribe (see Appendix A for list of Tribes and telephone numbers) (8:00 a.m. - 4:30 p.m. local time) by the first workday following the day the permittee became aware of the circumstances: ... 5.8.2.2. Any unauthorized release, including sanitary sewer overflows..." Section 5.8.3 of the permit states, "A written submission shall also be provided to the EPA and to the applicable Tribe within five days of the time that the permittee becomes aware of the circumstances. The written submission shall contain: 5.8.3.1. A description of the noncompliance and its cause; 5.8.3.2. The period of noncompliance, including exact dates and times; 5.8.3.3. The estimated time noncompliance is expected to continue if it has not been corrected; and, 5.8.3.4. Steps taken or planned to reduce, eliminate, and prevent reoccurrence of the noncompliance. Page 10 of 11 The written submission shall be submitted to the following addresses: Original to: U.S. EPA, Region 8 Policy, Information Management & Environmental Justice Program (8ENF-PJ) Attention: Director 1595 Wynkoop Street Denver, Colorado 80202-1129 Copy to: Applicable Tribe (see Appendix A for list of Tribes)" Section 6.5 of the Permit states, "The permittee shall at all times properly operate and maintain all facilities and systems of treatment and control (and related appurtenances) which are installed or used by the permittee to achieve compliance with the conditions of this permit..." Corrective Action: Ensure the collection system is maintained to prevent SSOs and any unauthorized discharges of raw sewage. Ensure future SSOs and any unauthorized releases that may endanger human health and the environment are reported to the EPA per Permit requirements. In a response to the EPA and the Oglala Sioux Tribe Environmental Department, provide a description of the procedures that will be followed to prevent SSOs and to detect and mitigate as soon as possible any SSOs that do occur. On August 29, 2024, OST Water & Sewer submitted an SSO Incident Report Form notifying EPA of the overflow from the Manderson Lagoon manhole observed during the inspection, and the corrective actions taken. Finding #8: The lagoon outfall was an open pipe near the top of the berm. Cell 4 includes an overflow approximately 6 inches from the top of the berm. The structure is an open pipe without a valve or other means of controlling discharges if the wastewater in Cell 4 were to reach the level of the overflow pipe. Although it is not uncommon for non-discharging lagoons to include an outfall for emergency discharges to prevent the lagoon from overtopping, the configuration of the overflow pipe for Manderson Lagoon is inconsistent with the typical design of outfall structures from other non-discharging lagoons. Permit Requirement: Section 4.1 of the permit states, "No Discharge Requirement: Effective immediately and lasting through the life of this permit, there shall be no discharge except in accordance with the bypass provisions of this permit. If an unauthorized release occurs or is expected to occur, the permittee shall take the appropriate measures to minimize the discharge of pollutants (see Part 6.7)." Recommendation: EPA recommends that OST Water & Sewer review the approved plans for Manderson Lagoon to check if the overflow pipe in cell 4 was installed per the lagoon design. If the existing overflow pipe is inconsistent with the facility design, EPA recommends that OST Water & Sewer make the necessary modifications to ensure the outfall is installed and will function as designed. Page 11 of 11