Document OO0qm2jBbJV1xO645NmBxBXj

NPDES Compliance Inspection Report City of Craigmont Wastewater Treatment Plant Winchester, Idaho Permit #: ID0021288 Inspection Date: July 31, 2023 Prepared by: Kevin Stockton PG Environmental Prepared for: Environmental Protection Agency Region 10 Enforcement & Compliance Assurance Division Water Enforcement & Field Branch Surface Water Enforcement Section Signature/Date: JASON RODRIGUEZ Date: 2023.10.25 13:50:50 -07'00' Digitally signed by JASON RODRIGUEZ Supervisor Signature/Date: Marshalonis, Daniel (Dino) Date: 2023.10.27 15:01:47 -07'00' Digitally signed by Marshalonis, Daniel (Dino) Contents I. Facility Information ............................................................................................................ 2 II. Inspection Information........................................................................................................ 2 III. Permit Information.............................................................................................................. 3 IV. Background ..................................................................................................................... 3 V. Inspection Chronology........................................................................................................ 3 VI. Facility Review ................................................................................................................... 4 VII. File Review ..................................................................................................................... 5 VIII. Areas of Concern ................................................................................................................ 5 IX. Closing Conference............................................................................................................. 7 ATTACHMENT A - Photograph Log........................................................................................ 8 ATTACHMENT B - ICIS 5-year Exceedance Report............................................................ 14 All details in this report were obtained through conversations with Bob Samsel (Maintenance Supervisor, City of Craigmont) or from observations made during the inspection. I. Facility Information Facility Name: City of Craigmont Wastewater Treatment Plant (WWTP) Facility Owner: City of Craigmont, Idaho (Permittee) Facility Operator: City of Craigmont, Idaho Facility Address: US-95 and Lauer Road Craigmont, Idaho 83523 Lat/Long: 46.23083 N, -116.4575 W Mailing Address: City of Craigmont P.O. Box 250 Craigmont, Idaho 83523 Facility Contact: Richard "Bob" Samsel, Maintenance Supervisor City of Craigmont Phone: (208) 507-1417 Email: craigmontpwd@gmail.com Permit Number: ID0021288 Receiving Water: John Dobb Creek to North Fork Lawyers Creek II. Inspection Information Inspection Date: July 31, 2023 EPA Inspection Team: Kevin Stockton PG Environmental Phone: (720) 789-8050 Email: kevin.stockton@pgenv.com Chris Pardo PG Environmental Phone: (703) 398-4251 Email: Chris.Pardo@pgenv.com Arrival Time: 12:15 PM Departure Time: 1:50 PM Purpose: To determine compliance with National Pollutant Discharge Elimination System (NPDES) Permit No. ID0021288 and Administrative Order on Consent (AOC) Docket No. CWA-102021-0117. III. Permit Information The Craigmont WWTP ("WWTP" or "Facility") is permitted under NPDES Permit No. ID0021288 ("Permit"). The Permit became effective on June 1, 2020 and is due to expire on May 31, 2025. In July 2021, EPA issued AOC Docket No. CWA-10-2021-0117 due to violations of the Permit's effluent limitations for 5-day biochemical oxygen demand (BOD5), total residual chlorine (TRC), and total suspended solids (TSS). The AOC requires the Permittee to develop a Facility Plan by June 1, 2021 and fully implement the Facility Plan by June 1, 2025 including "actions and the construction of all upgrades and remedial measures necessary to how achieve and maintain compliance with the effluent limitations and requirements of the Permit." Refer to Section VII (File Review), below, for more information about the Permittee's progress developing and implementing the Facility Plan. IV. Background The City of Craigmont ("City"), located in Lewis County and within the boundary of the Nez Perce Reservation, owns, operates, and maintains the Facility. The WWTP consists of a primary and secondary lagoon system followed by chlorination, dechlorination, and sand filtration. Effluent from the Facility is intermittently discharged to John Dobb Creek. Craigmont is a small community with a population of approximately 500 people (based on 2010 Census). The collection system is a separate sanitary sewer system serving residential connections and one restaurant. The Permittee has not identified industrial wastewater discharges into the system. The treatment system has a designed maximum flow rate of 0.12 million gallons per day (MGD). The City's Maintenance Supervisor, Bob Samsel ("Facility Representative"), is responsible for operating and maintaining the WWTP and collection system. V. Inspection Chronology On July 24, 2024, EPA notified the Permittee of the inspection via email. The Facility's Maintenance Supervisor agreed to meet representatives from PG Environmental, an EPA Contractor ("EPA Inspection Team"), at the Facility on the afternoon of July 31, 2023 for the inspection. The EPA Inspection Team arrived at the facility at 12:15pm on July 31, 2023. Mr. Kevin Stockton with PG Environmental presented his Clean Water Act (CWA) inspector credentials and explained the purpose of the inspection to the Facility Representative. The inspection consisted of introductions, an opening conference, a Facility review, a file review, and a closing conference. During the Facility review, the EPA Inspection Team observed each stage of the treatment process starting at the headworks of the facility and working down the treatment train. Following the Facility review, the EPA Inspection Team conducted a file review at the Maintenance Building, located approximately 0.5 miles northwest of the Facility. During the closing conference, the EPA Inspection Team discussed preliminary observations with the Facility representative. The EPA Inspection Team thanked the Facility Representative for their time and departed from the Maintenance Building at approximately 1:50 pm. Photographs taken during the inspection can be found in Attachment A, Photograph Log. VI. Facility Review The Facility is located along Highway-95, situated just outside of the City limits. Untreated wastewater enters the Facility from the City's sanitary sewer collection system, into an influent vault structure that is equipped with a Parshall flume for flow measurement (refer to Attachment A, Photographs 1 and 2). From the influent vault structure, flow enters the primary lagoon (refer to Attachment A, Photographs 3 and 4). Flow from the primary lagoon enters the secondary lagoon through a valve box located between the lagoons (refer to Attachment A, Photographs 5, 6, and 7). Neither lagoon is aerated. Effluent from the secondary lagoon flows through a v-notch weir, for effluent flow measurement, where it is dosed with gaseous chlorine for disinfection (refer to Attachment A, Photographs 8 through 11). The Facility representative stated that approximately three to four pounds of gaseous chlorine is typically used per day. From the v-notch weir, flow enters an open-top chlorine disinfection unit (refer to Attachment A, Photograph 12). Once full, the chlorine disinfection unit is manually emptied into one of the Facility's three sand filters (refer to Attachment A, Photographs 13 through 17). Effluent flow from the sand filters discharges intermittently to John Dobb Creek via Outfall 001 at the southeast perimeter of the Facility (refer to Attachment A, Photograph 18). A small out-building located near the effluent v-notch weir serves as a field laboratory and chlorine storage space. Flow, pH, temperature, and TRC are analyzed on site. Ammonia, BOD5, TSS, and E. coli are analyzed offsite by Anatek Labs in Moscow, ID. Effluent flow is dechlorinated using sodium sulfite tablets at the sand filters and at the Outfall 001 discharge point. The Facility has installed improvised dichlorination units, fabricated from 5-gallon buckets at the sand filters. The Facility representative explained that the improvised dechlorination units were installed at the sand filters because the dechlorination unit at the discharge point was not always sufficient for removing TRC. He stated dechlorination has been more reliable since installing the improvised dechlorination units at the sand filters, resulting in fewer exceedances of the Permit's TRC effluent limitation. At the time of inspection, the facility had not exceeded the TRC limit in 2023. The Facility exceeded the TRC limit six times in 2022. VII. VIII. The Facility was last inspected in 2019. Since that inspection, the Permittee has made safety improvements at Outfall 001. The Permittee installed a concrete slab at the outfall to provide a stable surface for sample collection and replaced the earthen/wooden stairs for accessing the outfall with sturdier metal stairs. File Review The EPA Inspection Team reviewed the following documents during the file review portion of the inspection: Quality Assurance Plan and Standard Operating Procedures NPDES Permit No. ID0021288 Facility Operations and Maintenance Manual City of Craigmont 2022 Wastewater Improvement Plans (i.e., "Facility Plan") Lab Reports and Monitoring Data from 2020 through 2023 The Permittee maintains hardcopy documentation for onsite parameter analysis and thirdparty laboratory reports at the Maintenance Building. The EPA Inspection Team did not observe any mathematical or transcription errors in the Facility's monitoring and reporting documentation. In order to comply with the AOC, the Permittee has contracted Mountain Waterworks, Inc. to design a new wastewater treatment system at the Facility. The preliminary plans involve decommissioning the existing lagoons and sand filters and installing a new headworks with an automated bar screen (and a manual bar screen for backup), three new aerated lagoons, and two submerged aerated rock filters. Effluent will still be chlorinated and dechlorinated prior to discharge at the existing Outfall 001 location. The Facility representative explained that the capital cost for the project is estimated at approximately $7 million. The Permittee plans to utilize a combination of United States Department of Agriculture (USDA) grant funding, American Rescue Plan Act (ARPA) grant funding, and Idaho State Revolving Fund (SRF) funding. The Facility representative stated that the new treatment system is expected to be operational by the end of 2024, and any remaining funds will be allocated to collection system improvements. Areas of Concern The following areas of concern were noted during this inspection: A. Effluent Limitations and Monitoring Section I.B of the Permit identifies effluent limitations for discharges to John Dobb Creek from the Facility's Outfall 001 (Table 1) and states, "The permittee must comply with the effluent limits in the tables at all times unless otherwise indicated, regardless of the frequency of monitoring or reporting required by other provisions of this permit. " According to EPA's Integrated Compliance Information System (ICIS), the Facility had 35 effluent violations between June 30, 2018 and February 28, 2023, including: 14 TRC violations 11 TSS violations 5 BOD5 violations 4 pH violations 1 E.coli violation. Attachment B contains additional details about the violations. As previously mentioned, the Permittee has had fewer TRC violations since installing the improvised dechlorination units at the Facility's sand filters. B. Representative Monitoring Section III.A of the Permit states, "Samples and measurements taken for the purpose of monitoring must be representative of the monitored activity." The EPA Inspection Team observed that effluent flow is not measured at the end of the treatment process but is instead measured in between the secondary lagoon and the chlorination chamber (before the sand filters and dechlorination units). The Facility Representative explained that he estimates the average daily effluent flow based on how long it takes the chlorination unit to empty through the sand filters and outfall (typically several days). Because effluent flow is not physically measured at the end of the treatment process, the calculation of effluent pollutant loadings from the Facility may not be accurate. C. Proper Operation and Maintenance Section IV.E of the Permit states that "The permittee must 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." The inspectors observed the following maintenance needs at the Facility: a. Heavy solids accumulation at the influent vault structure (refer to Attachment A, Photograph 1). b. Solids accumulation and several dead ducks in the valve box in between the two lagoons (refer to Attachment A, Photographs 6 and 7). c. Damage to the staff gauge at the effluent v-notch weir, which may inhibit accurate flow measurement (refer to Attachment A, Photograph 10). D. Operation and Maintenance Plan Section II.A of the Permit states, "the permittee must develop and implement an Operations and Maintenance (O&M) Plan for the wastewater treatment facility. Any existing O&M Plan may be modified for compliance with this section. Any changes occurring in the operation of the plant must be reflected within the O&M Plan." At the time of the inspection, the Permittee's O&M Plan was not reflective of current operational protocols. Specifically, the O&M plan did not reflect the dechlorination procedures being implemented at the Facility. The Facility representative stated that an updated O&M Plan would be developed as part of the upcoming Facility upgrades. IX. Closing Conference Following the walk-through and records review, the EPA Inspection Team held a closing conference with the Facility Representative. They discussed preliminary observations and gave a brief overview of the post-inspection process. ATTACHMENT A Photograph Log All photographs taken by Chris Pardo on July 31, 2023 Photograph Log - Craigmont WWTP Solids Photograph #01 (DSCN9121) Description: View of the Facility's influent vault structure equipped with Parshall flume for flow measurement. Note the heavy solids accumulation in the vault structure. Photograph #02 (DSCN91215) Description: View of the Facility's influent Parshall flume, as shown in Photograph 1. Photograph #03 (DSCN9129) Description: View, facing southeast, of the Facility's primary lagoon. Photograph #04 (DSCN9130) Description: View, facing north, of the Facility's primary lagoon. Photograph Log - Craigmont WWTP Dead ducks Solids Photograph #05 (DSCN9132) Description: View, facing northeast, of the Facility's secondary lagoon. Photograph #06 (DSCN9171) Description: View of the valve box in between the Facility's primary and secondary lagoons. Note the solids accumulation and dead ducks inside the valve box. Photograph #07 (DSCN9174) Description: Additional view of dead ducks inside the valve box in between the Facility's primary and secondary lagoons, as shown in Photograph 6. Photograph #08 (DSCN9135) Description: View of the Facility's v-notch weir for measuring flow leaving the secondary lagoon. Photograph Log - Craigmont WWTP Damaged Photograph #09 (DSCN9139) Description: Additional view of the Facility's v-notch weir. Photograph #10 (DSCN9138) Description: View of the staff gauge for the Facility's v-notch weir. Note the damage to the staff gauge. Photograph #11 (DSCN9141) Description: View of the chlorine feed system inside the Facility's out-building. Photograph #12 (DSCN9151) Description: View of the Facility's disinfection unit. Photograph Log - Craigmont WWTP Photograph #13 (DSCN9152) Description: View of manual valves for directing flow from the disinfection unit to the sand filters. Photograph #14 (DSCN9157) Description: View of one of the Facility's three sand filters. Photograph #15 (DSCN9158) Description: View of two of the Facility's three sand filters. Photograph #16 (DSCN9159) Description: View of one of the Facility's sand filters. Photograph Log - Craigmont WWTP Outfall 001 Photograph #17 (DSCN9156) Description: View of an improvised dechlorination unit at one of the Facility's sand filters. Photograph #18 (DSCN9162) Description: View of the Facility's Outfall 001 to John Dobb Creek. ATTACHMENT B ICIS 5-year Exceedance Report NPDES ID(s): ID0021288 State: ID Major/Minor Indicator: Violation Date: 06/01/2018 - 06/01/2023 Violation Type(s): Environmental Protection Agency Integrated Compliance Information System Violations Report Created Date: 09/15/2010 Refresh Date: 06/15/2023 Report Version 1.5, Modified: 1/4/2017 Permittee Name: Permittee Address: Major/Minor Indicator: Compliance Track. Status: DMR Non Receipt Flag: RNC Tracking Flag: CRAIGMONT, CITY OF PO BOX 250 CRAIGMONT, ID 83523 Minor On On On ID0021288 Primary SIC Code: Primary SIC Desc: Primary NAICS Code: Primary NAICS Desc: Cognizant Official: Cognizant Offcl. Ph.: Receiving Body: 4952 Sewerage Systems 221320 Sewage Treatment Facilities MONTE THOMASON, MAINT SUPV 208-924-5432 JOHN DOBBS CREEK Permit Issued: Permit Effective: Permit Expired: Permit Status: 04/21/2020 06/01/2020 05/31/2025 Effective Facility Information Facility Name: Facility Location: CRAIGMONT, CITY OF - CRAIGMONT WWTP STATE HIGHWAY 95, ON NEZ PERCE RESERVATION CRAIGMONT, ID 83523 County: Region: State-Region: Lewis 10 04 DMR Non-Receipt Violations FRS ID: Federal Facility Ownership: Type of Ownership: 110039886291 N Municipal or Water District Violation Code D80 D80 D80 D80 Monitoring Period End Date 06/30/2020 06/30/2020 06/30/2020 06/30/2020 DMR Due Date 07/20/2020 07/20/2020 07/20/2020 07/20/2020 Limit Set 001-A Parameter 00610 - Nitrogen, ammonia total [as N] 001-A 00610 - Nitrogen, ammonia total [as N] 001-A 00610 - Nitrogen, ammonia total [as N] 001-A 00610 - Nitrogen, ammonia total [as N] Mon. Loc. 1 1 1 1 Seas. ID 0 0 0 0 DMR Value Q1 Q2 C1 C3 NODI Code **E** **E** **E** **E** RNC Det. Code/ RNC Det. Date N 08/20/2020 K 08/20/2020 N 08/20/2020 K 08/20/2020 RNC Res. Code/ RNC Res. Date 0 08/20/2021 0 08/20/2021 0 08/20/2021 0 08/20/2021 DMR Val. Rec Date 07/22/2020 07/22/2020 07/22/2020 07/22/2020 Violation Code E90 Monitoring Period End Date 02/28/2023 E90 12/31/2022 E90 11/30/2022 Limit Set 001-A 001-A 001-A Parameter 31648 - E. coli, MTEC-MF 50060 - Chlorine, total residual 00530 - Solids, total suspended Mon. Loc. 1 Seas. ID 0 SNC Group R 0 2 1 0 1 Effluent Violations EA Identifier Value Type/ Stat. Base C3 INST MAX Q2 DAILY MX C2 MO AVG Reported Value/Units 1,543.1 cfu/100ml .109 lb/d 36.6 mg/l % Exceed. 280% 118% 22% Limit Value/ Units <=406 cfu/100ml <=.05 lb/d <=30 mg/l RNC Det. Code/ RNC Det. Date RNC Res. Code/ RNC Res. Date DMR Non-Receipt Violations: Asterisks around a NODI Code (e.g. **X**) indicate the NODI code will not automatically resolve RNC. Schedule Violations: Schedule Type P - Permit, A - Administrative, J - Judicial Page 1 of 6 NPDES ID(s): ID0021288 State: ID Major/Minor Indicator: Violation Date: 06/01/2018 - 06/01/2023 Violation Type(s): Violation Code E90 Monitoring Period End Date 11/30/2022 E90 06/30/2022 E90 06/30/2022 E90 06/30/2022 E90 06/30/2022 E90 05/31/2022 E90 04/30/2022 E90 04/30/2022 E90 04/30/2022 E90 04/30/2022 E90 04/30/2022 E90 04/30/2022 E90 04/30/2022 E90 07/31/2020 E90 07/31/2020 E90 06/30/2020 E90 06/30/2020 E90 06/30/2020 Limit Set 001-A 001-A 001-A 001-A 001-A 001-A 001-A 001-A 001-A 001-A 001-A 001-A 001-A 001-A 001-A 001-A 001-A 001-A Parameter 81011 - Solids, suspended percent removal 00400 - pH 50060 - Chlorine, total residual 50060 - Chlorine, total residual 50060 - Chlorine, total residual 00400 - pH 00400 - pH 00530 - Solids, total suspended 00530 - Solids, total suspended 50060 - Chlorine, total residual 50060 - Chlorine, total residual 81010 - BOD, 5day, percent removal 81011 - Solids, suspended percent removal 50060 - Chlorine, total residual 50060 - Chlorine, total residual 50060 - Chlorine, total residual 50060 - Chlorine, total residual 50060 - Chlorine, total residual Environmental Protection Agency Integrated Compliance Information System Violations Report Mon. Loc. K Seas. ID 0 SNC Group 1 1 0 R 0 2 R 0 2 R 0 2 1 0 1 0 1 0 1 1 0 1 R 0 2 R 0 2 K 0 1 K 0 1 R 0 2 R 0 2 R 0 2 R 0 2 R 0 2 ID0021288 Effluent Violations EA Identifier Value Type/ Stat. Base C1 MO AV MN C3 Q1 MO AVG Q2 DAILY MX C3 DAILY MX C3 C3 Q1 MO AVG C2 MO AVG Q2 DAILY MX C3 DAILY MX C2 MO AV MN C1 MO AV MN C1 MO AVG C3 DAILY MX Q2 DAILY MX C1 MO AVG C3 DAILY MX Reported Value/Units 62.9 % 9.08 .28 lb/d 1.08 lb/d .06 mg/l 9.47 9.44 30.9 lb/d 36.8 mg/l .067 lb/d .08 mg/l 84 % 79 % .07 mg/l .09 mg/l .1 lb/d .08 mg/l .09 mg/l DMR Non-Receipt Violations: Asterisks around a NODI Code (e.g. **X**) indicate the NODI code will not automatically resolve RNC. Schedule Violations: Schedule Type P - Permit, A - Administrative, J - Judicial Created Date: 09/15/2010 Refresh Date: 06/15/2023 Report Version 1.5, Modified: 1/4/2017 % Exceed. 147% 460% 2,060% 20% 3% 23% 34% 60% 7% 40% 40% 80% 100% 60% 80% Limit Value/ Units >=85 % <=9 <=.05 lb/d <=.05 lb/d <=.05 mg/l <=9 <=9 <=30 lb/d <=30 mg/l <=.05 lb/d <=.05 mg/l >=85 % >=85 % <=.05 mg/l <=.05 mg/l <=.05 lb/d <=.05 mg/l <=.05 mg/l RNC Det. Code/ RNC Det. Date RNC Res. Code/ RNC Res. Date T 07/31/2020 2 12/31/2020 T 07/31/2020 2 12/31/2020 Page 2 of 6 NPDES ID(s): ID0021288 State: ID Major/Minor Indicator: Violation Date: 06/01/2018 - 06/01/2023 Violation Type(s): Violation Code E90 Monitoring Period End Date 02/29/2020 E90 12/31/2019 E90 12/31/2019 E90 12/31/2019 E90 05/31/2019 E90 05/31/2019 E90 05/31/2019 E90 04/30/2019 E90 04/30/2019 E90 04/30/2019 E90 04/30/2019 E90 04/30/2019 E90 04/30/2019 E90 06/30/2018 Limit Set 001-A 001-A 001-A 001-A 001-A 001-A 001-B 001-A 001-A 001-A 001-A 001-B 001-B 001-A Parameter 81010 - BOD, 5day, percent removal 00530 - Solids, total suspended 00530 - Solids, total suspended 81011 - Solids, suspended percent removal 00310 - BOD, 5day, 20 deg. C 00310 - BOD, 5day, 20 deg. C 50060 - Chlorine, total residual 00530 - Solids, total suspended 00530 - Solids, total suspended 00530 - Solids, total suspended 81010 - BOD, 5day, percent removal 50060 - Chlorine, total residual 50060 - Chlorine, total residual 00400 - pH Violation Code Sch. Event Code Schedule Date Actual Date Environmental Protection Agency Integrated Compliance Information System Violations Report Mon. Loc. K Seas. ID 0 SNC Group 1 ID0021288 Effluent Violations EA Identifier Value Type/ Stat. Base C1 MN % RMV 1 0 1 1 0 1 K 0 1 C2 MO AVG C3 WKLY AVG C1 MN % RMV 1 0 1 1 0 1 1 0 2 1 0 1 1 0 1 1 0 1 K 0 1 Q1 MO AVG Q2 WKLY AVG Q2 DAILY MX Q1 MO AVG Q2 WKLY AVG C2 MO AVG C1 MN % RMV 1 0 2 1 0 2 1 0 Q1 MO AVG Q2 DAILY MX C3 Report Received Date Schedule Violations EA Identifier Sch. Num. Sch. Type Reported Value/Units 80 % 123 mg/l 123 mg/l 44 % 49 lb/d 49 lb/d .28 lb/d 72.5 lb/d 72.5 lb/d 54 mg/l 77 % .3 lb/d .22 lb/d 9.08 % Exceed. 33% 173% 89% 60% 63% 9% 180% 61% 12% 20% 53% 200% 120% Schedule Event/ Comments Created Date: 09/15/2010 Refresh Date: 06/15/2023 Report Version 1.5, Modified: 1/4/2017 Limit Value/ Units >=85 % <=45 mg/l <=65 mg/l >=65 % <=30 lb/d <=45 lb/d <=.1 lb/d <=45 lb/d <=65 lb/d <=45 mg/l >=85 % <=.1 lb/d <=.1 lb/d <=9 RNC Det. Code/ RNC Det. Date RNC Res. Code/ RNC Res. Date RNC Det. Code/ RNC Det. Date RNC Res. Code/ RNC Res. Date DMR Non-Receipt Violations: Asterisks around a NODI Code (e.g. **X**) indicate the NODI code will not automatically resolve RNC. Schedule Violations: Schedule Type P - Permit, A - Administrative, J - Judicial Page 3 of 6 NPDES ID(s): ID0021288 State: ID Major/Minor Indicator: Violation Date: 06/01/2018 - 06/01/2023 Violation Type(s): Violation Code C40 Sch. Event Code 50108 Schedule Date 12/31/2020 C30 50108 12/31/2020 C20 50108 12/31/2020 C10 50108 12/31/2020 C40 55099 12/31/2020 Actual Date 03/23/2021 03/23/2021 03/23/2021 03/23/2021 03/23/2021 Environmental Protection Agency Integrated Compliance Information System Violations Report Report Received Date 03/23/2021 03/23/2021 03/23/2021 03/23/2021 03/23/2021 ID0021288 Schedule Violations EA Identifier Sch. Num. Sch. Type 1 P 1 P 1 P 1 P 1 P Schedule Event/ Comments Operation and Maintenance (O&M) Report Comment: The permittee must provide EPA and Nez Perce Tribe with written notification that the Plan has been developed and implemented (see Part II.A of this permit). The Plan must be kept on site and made available to EPA and Nez Perce Tribe upon request. Operation and Maintenance (O&M) Report Comment: The permittee must provide EPA and Nez Perce Tribe with written notification that the Plan has been developed and implemented (see Part II.A of this permit). The Plan must be kept on site and made available to EPA and Nez Perce Tribe upon request. Operation and Maintenance (O&M) Report Comment: The permittee must provide EPA and Nez Perce Tribe with written notification that the Plan has been developed and implemented (see Part II.A of this permit). The Plan must be kept on site and made available to EPA and Nez Perce Tribe upon request. Operation and Maintenance (O&M) Report Comment: The permittee must provide EPA and Nez Perce Tribe with written notification that the Plan has been developed and implemented (see Part II.A of this permit). The Plan must be kept on site and made available to EPA and Nez Perce Tribe upon request. Quality Assurance Report Comment: The permittee must provide EPA and Nez Perce Tribe with written notification that the Plan has been developed and implemented (see Part II.B of this permit). The Plan must be kept on site and made available to EPA and Nez Perce Tribe upon request. DMR Non-Receipt Violations: Asterisks around a NODI Code (e.g. **X**) indicate the NODI code will not automatically resolve RNC. Schedule Violations: Schedule Type P - Permit, A - Administrative, J - Judicial Created Date: 09/15/2010 Refresh Date: 06/15/2023 Report Version 1.5, Modified: 1/4/2017 RNC Det. Code/ RNC Det. Date N 01/31/2021 RNC Res. Code/ RNC Res. Date 2 03/23/2021 N 01/31/2021 2 03/23/2021 N 01/31/2021 2 03/23/2021 Page 4 of 6 NPDES ID(s): ID0021288 State: ID Major/Minor Indicator: Violation Date: 06/01/2018 - 06/01/2023 Violation Type(s): Violation Code C30 Sch. Event Code 55099 Schedule Date 12/31/2020 C20 55099 12/31/2020 C10 55099 12/31/2020 C40 ERPNP 12/31/2020 Actual Date 03/23/2021 03/23/2021 03/23/2021 03/23/2021 Environmental Protection Agency Integrated Compliance Information System Violations Report Report Received Date 03/23/2021 03/23/2021 03/23/2021 03/23/2021 ID0021288 Schedule Violations EA Identifier Sch. Num. Sch. Type 1 P 1 P 1 P 1 P Schedule Event/ Comments Quality Assurance Report Comment: The permittee must provide EPA and Nez Perce Tribe with written notification that the Plan has been developed and implemented (see Part II.B of this permit). The Plan must be kept on site and made available to EPA and Nez Perce Tribe upon request. Quality Assurance Report Comment: The permittee must provide EPA and Nez Perce Tribe with written notification that the Plan has been developed and implemented (see Part II.B of this permit). The Plan must be kept on site and made available to EPA and Nez Perce Tribe upon request. Quality Assurance Report Comment: The permittee must provide EPA and Nez Perce Tribe with written notification that the Plan has been developed and implemented (see Part II.B of this permit). The Plan must be kept on site and made available to EPA and Nez Perce Tribe upon request. Emergency Response and Public Notification Plan Comment: The permittee must develop and implement an overflow emergency response and public notification plan. The permittee must submit written notice to EPA and Nez Perce Tribe that the plan has been developed and implemented within 180 days of the effective date of this permit. (See Part II.F. of this permit) Created Date: 09/15/2010 Refresh Date: 06/15/2023 Report Version 1.5, Modified: 1/4/2017 RNC Det. Code/ RNC Det. Date N 01/31/2021 RNC Res. Code/ RNC Res. Date 2 03/23/2021 N 01/31/2021 2 03/23/2021 DMR Non-Receipt Violations: Asterisks around a NODI Code (e.g. **X**) indicate the NODI code will not automatically resolve RNC. Schedule Violations: Schedule Type P - Permit, A - Administrative, J - Judicial Page 5 of 6 NPDES ID(s): ID0021288 State: ID Major/Minor Indicator: Violation Date: 06/01/2018 - 06/01/2023 Violation Type(s): Violation Code C30 Sch. Event Code ERPNP Schedule Date 12/31/2020 C20 ERPNP 12/31/2020 C10 ERPNP 12/31/2020 C20 CS032 06/20/2021 C10 CS032 06/20/2021 Actual Date 03/23/2021 03/23/2021 03/23/2021 07/06/2021 07/06/2021 Environmental Protection Agency Integrated Compliance Information System Violations Report Report Received Date 03/23/2021 03/23/2021 03/23/2021 07/08/2021 07/08/2021 ID0021288 Schedule Violations EA Identifier Sch. Num. Sch. Type 1 P 1 P 1 P 2 P 2 P Schedule Event/ Comments Emergency Response and Public Notification Plan Comment: The permittee must develop and implement an overflow emergency response and public notification plan. The permittee must submit written notice to EPA and Nez Perce Tribe that the plan has been developed and implemented within 180 days of the effective date of this permit. (See Part II.F. of this permit) Emergency Response and Public Notification Plan Comment: The permittee must develop and implement an overflow emergency response and public notification plan. The permittee must submit written notice to EPA and Nez Perce Tribe that the plan has been developed and implemented within 180 days of the effective date of this permit. (See Part II.F. of this permit) Emergency Response and Public Notification Plan Comment: The permittee must develop and implement an overflow emergency response and public notification plan. The permittee must submit written notice to EPA and Nez Perce Tribe that the plan has been developed and implemented within 180 days of the effective date of this permit. (See Part II.F. of this permit) Other (See Comments) Comment: Other (See Comments) Comment: Created Date: 09/15/2010 Refresh Date: 06/15/2023 Report Version 1.5, Modified: 1/4/2017 RNC Det. Code/ RNC Det. Date N 01/31/2021 RNC Res. Code/ RNC Res. Date 2 03/23/2021 DMR Non-Receipt Violations: Asterisks around a NODI Code (e.g. **X**) indicate the NODI code will not automatically resolve RNC. Schedule Violations: Schedule Type P - Permit, A - Administrative, J - Judicial Page 6 of 6 Environmental Protection Agency Integrated Compliance Information System Violations Report RNC Detection Codes Created Date: 09/15/2010 Refresh Date: 06/15/2023 Report Version 1.5, Modified: 1/4/2017 Violation Type DMR Non-Receipt (D80, D90) Effluent (E90) Schedule Violations (C10, C20, C30, C40) Single Event RNC Detection Code K N A C H P R T U V X Y Z N S B D E F G I J Q W RNC Detection Description RPT - Non-receipt Violation, Non-Monthly Average RPT - Non-Receipt of DMR/Schedule Report ENF - Enforcement Order CHR - Chronic Violation CHR - Chronic Violation, Non-Monthly Average ENF - Enforcement Order, Non-Monthly Average TRC - TRC Limitations Exceeded, Non-Monthly Average TRC - TRC Limitations Exceeded EFF - Other Violation with TRC Non-Monthly Average EFF - Other Violation with TRC EFF - Manual Other Violation with TRC TRC - Manual TRC CHR - Manual Chronic SCH - Non-Receipt of DMR/Schedule Report SCH - Schedule Violation DIS - Manual 2A4 - Pass-Through DIS - Manual Other DIS - Manual 2F - Permit Narrative DIS - Manual 2G - Violation of Concern DIS - Manual 2A1 - Effluent Violation DIS - Manual 2A2 - Unauthorized Bypass DIS - Manual 2A3 - Unpermitted Discharge DIS - Manual 2B - Pretreatment DIS - Manual 2E - Deficient Report Page 1 of 1 RNC Resolution Status Noncompliant (NC) Resolved Pending (RP) Resolved (RE) Environmental Protection Agency Integrated Compliance Information System Violations Report RNC Resolution Codes Created Date: 09/15/2010 Refresh Date: 06/15/2023 Report Version 1.5, Modified: 1/4/2017 RNC Resolution Code 1 A 3 4 7 8 0 2 5 6 9 B RNC Resolution Description NC - Unresolved RNC NC - Manual Unresolved RNC RP - Due to Formal Enforcement Action Final Order with Compliance Schedule RP - In Compliance with Formal Enforcement Action Final Order Requirement RP - Manual RP - In Compliance with Formal Enforcement Action Order Requirement RP - Manual Due to Formal Enforcement Action Formal Order RE - Automated Administratively Resolved (DMR Non-Receipt Violations) RE - Back into Compliance RE - Resolved RP by NPDES Closure of Enf. Action Final Order with Comp. Schedule RE - Manual Resolution by Enforcement Action RE - Manual by Back into Compliance/Administratively Resolved RE - Manual by EPA/State/Tribal Action Page 1 of 1 Environmental Protection Agency Integrated Compliance Information System Violations Report NODI Codes Created Date: 09/15/2010 Refresh Date: 06/15/2023 Report Version 1.5, Modified: 1/4/2017 NODI Code 2 3 6 7 9 A B C E F I N P Q R T W X Y Acceptable? Y Y N Y Y Y Y Y N Y Y Y N Y Y Y Y N Y NODI Description Operation Shutdown Special Report Attached State-specific No Data Indicator - Invalid No Influent Conditional Monitoring - Not Required This Period General Permit Exemption Below Detection Limit/No Detection No Discharge Failed to Sample/Required Analysis Not Conducted Insufficient Flow for Sampling Land Applied Not Constructed Laboratory Error or Invalid Test Not Quantifiable Administratively Resolved Environmental Conditions - Monitoring Not Possible Dry Lysimeter/Well Parameter/Value Not Reported State-specific No Data Indicator - Valid Page 1 of 1 Environmental Protection Agency Integrated Compliance Information System Violations Report DMR Violation Codes Created Date: 09/15/2010 Refresh Date: 06/15/2023 Report Version 1.5, Modified: 1/4/2017 Violation DMR Non-Receipt Violation Effluent Violation Violation Code D80 D90 E90 Violation Indicator Type DMR, Monitor Only - Overdue DMR, Limited - Overdue DMR, Limited - Numeric Violation Page 1 of 1 Environmental Protection Agency Integrated Compliance Information System Violations Report Schedule Violation Codes Created Date: 09/15/2010 Refresh Date: 06/15/2023 Report Version 1.5, Modified: 1/4/2017 Violation Schedule Violation Violation Code C10 C20 C30 C40 Violation Indicator Type Schedule Event reported late Schedule Event achieved late but reported Schedule Event unachieved but reported Schedule Event unachieved and not reported Page 1 of 1 Environmental Protection Agency Integrated Compliance Information System Violations Report Monitoring Location Codes Created Date: 09/15/2010 Refresh Date: 06/15/2023 Report Version 1.5, Modified: 1/4/2017 Monitoring Location Codes 0 1 2 3 4 5 6 7 8 9 A AP B C CA D E E1 E2 E3 EA ED EG F G GW H I II IM IN J K L LA N O P PI PR PT Q R RS RW S SC SD SL SW T U V Monitoring Location Description Intake Effluent Gross Effluent Net Intake Public Water Pretreatment, Process Complete Upstream Monitoring Downstream Monitoring Intake from Stream Other Treatment, Process Complete Phosphate Removal, Process Complete Disinfection, Process Complete Alternate Process Prior to Disinfection Nitrogen, Removal Complete Calculated Adjusted Tertiary/Advanced Process Complete Secondary/Biological Process Complete Effluent Option 1 Effluent Option 2 Effluent Option 3 Effluent Adjusted Value Effluent w/additives Effluent Gross Primary/Prelimary Process Complete Raw Sewage Influent Groundwater During Manufacturing Intake from Well Industrial Influent Internal Monitoring Point Allowed Increase Intermediate Treatment, Process Complete Percent Removal Digestor Land Application Soil In Aeration Unit See Comments See Comments Prior to Irrigation Prior to Reuse Precipitation See Comments See Comments Beneficial Reuse Receiving Water See Comments See Comments Sediment Sludge Storm Water See Comments See Comments See Comments Page 1 of 2 Environmental Protection Agency Integrated Compliance Information System Violations Report Created Date: 09/15/2010 Refresh Date: 06/15/2023 Report Version 1.5, Modified: 1/4/2017 Monitoring Location Codes Monitoring Location Codes Monitoring Location Description W See Comments X End of Chlorine Contact Chamber Y Effluent Gross (Supplementary) Z Instream Monitoring Page 2 of 2