Document QXGzVb5V7KqXOBpbK0jDLoq9k

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 09/06/2023 08:06 AM (CT) 09/06/2023 10:45 AM (CT) Announced: Yes Access: Granted 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 Sokaogon Chippewa Community Sokaogon Chippewa Community Wastewater Treatment System 3051 Sand Lake Road Crandon, WI 54520 45.484938, -88.963972 FRS ID 110064633794 Permit Number(s) (If Applicable) WI0071501 SIC and/or NAICS 4952 Regulatory Representatives Participating in Inspection: Title Name Inspector Ray Cullen Organization EPA REGION 5 Lead Inspector: Dean Maraldo Supervisor Review: Ryan Bahr [Signature] DINO MARALDO Digitally signed by DINO MARALDO Date: 2023.09.12 14:50:01 -05'00' EPA REGION 5 Maraldo.Dean@epa.gov (312) 353-2098 [Signature] RYAN BAHR Digitally signed by RYAN BAHR Date: 2023.09.12 17:20:18 -05'00' EPA REGION 5 bahr.ryan@epa.gov 1 of 18 Sokaogon Chippewa Wastewater Treatment System Inspection Date: 09/06/2023 SECTION I - INTRODUCTION Site Entry and Inspection Objectives I, EPA REGION 5 Lead Inspector, Dean Maraldo, arrived at the Sokaogon Chippewa Community Wastewater Treatment System (the "Facility"), located at 3051 Sand Lake Road, Crandon, WI 54520, at 08:06 AM (CT) on 09/06/2023 for an announced inspection. I, along with EPA REGION 5 inspector Ray Cullen, presented our inspector credentials to Tina VanZile and informed them that this was an EPA REGION 5 inspection to determine compliance as authorized by Clean Water Act (CWA) Section 308 and implementing regulations. This report is based on information supplied by Facility representatives, direct observations made by the EPA REGION 5 inspectors, records and reports maintained by the permittee and other information including: photographs taken by EPA REGION 5 inspectors, physical evidence collected by the 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 REGION 5 Sokaogon Chippewa Community Sokaogon Chippewa Community Sokaogon Chippewa Community Sokaogon Chippewa Community Indian Health Service Dean Maraldo Ray Cullen Jake McGeshick Jackie Braun Kenneth McNinch Tina VanZile Shane Hoffman, P.E. Title Lead Inspector Inspector Operator Present in Opening Conf. Yes Yes No Present in Closing Conf. Yes Yes No Environmental Assistant Yes Yes Utilities Director Yes Yes Environmental Director Yes Yes Tribal Utility Consultant No Yes Facility/Site Description I began by reviewing the Facility description provided in the current permit (excerpt below) and the Facility representatives confirmed the information as described below. Permit Fact Sheet Facility Description: The application and plans indicate that the permittee owns and operates a 0.09 million gallons per day ("MGD") wastewater treatment system. The system consists of fine screening followed by septic tanks (2 primary and 2 secondary), recirculating sand filter beds (4) and ultraviolet disinfection. The discharge is continuous to a subsurface discharging system 50 feet from the edge of a wetland on the Mole Lake Indian Reservation. The subsurface discharge almost immediately surfaces from the foot of the system and flows over riprap directly to Wetland 22. 2 of 18 Sokaogon Chippewa Wastewater Treatment System Inspection Date: 09/06/2023 Sludge generated at the facility is hauled offsite by a private hauler when needed and land applied. The treatment system serves the Sokaogon Chippewa Community and Casino/Hotel. Facility Information Next, I asked some background questions. Unless noted otherwise, Ken McNinch (Utility Director) provided the responses in the table below. Responsible official? Ken McNinch How do you manage your biosolids? This year had some sludge removed and disposed through a private contractor, about 21,000 gallons Have any bypasses or overflows No happened at the plant or in the collection system in the last year? Industrial Users? No Are there any plans for renovation or Yes, $1.2 million grant for new fine screen, ammonia removal, and to repair additional equipment to allow for leaky walls in UV system room. Shane Hoffman (Indian Health Service) increased wastewater flow? provided a copy of work summary (see Appendix 2 - Document Log) Is there currently any portion of the treatment train that is nonoperational? Yes, fine screen is offline. Bypassing fine screen to bar screen for about 4 years. No impact on compliance with permit limits Do you accept waste from septage No haulers? If so, what problems have you experienced? Do you use in-house or contract out Only pH and Dissolved Oxygen analyzed in-house for laboratory analyses? Operation schedule? M-Th, 7am-5pm, operators on call 24/7 Contributing Jurisdictions? No WWTP Approx. # of residents served? Tina VanZile said about 550 residents served WWTP Design Capacity & Average Daily Flow? 86,000 gallons per day, average about 25,000-30,000 gallons per day CBI concerns? No Inspection Focus Areas and Locations Location/Area Interview Non-DMR Reports Effluent Limit Violation Review Operations and Maintenance ("O&M") Self Monitoring Flow Monitoring Sanitary Sewer Overflows ("SSOs") Physical Inspection Close Out Conference Description Sokaogon Chippewa Community Administration Office Sokaogon Chippewa Community Wastewater Treatment System Sokaogon Chippewa Community Administration Office 3 of 18 Sokaogon Chippewa Wastewater Treatment System Inspection Date: 09/06/2023 SECTION II - OBSERVATIONS Location: Interview/Non-DMR Reports Observation #: DM1-OB-001 Date: 09/06/2023 Unless noted otherwise, Ken McNinch provided the responses (in bold) below. Operation and Maintenance Status Report submitted by January 31, 2023 (Permit Part I.C.3.b)? Operation and Maintenance Status Report for 2022 not yet submitted. Phosphorus Management Plan Status Report submitted by January 31, 2023 (Permit Part I.C.4)? Phosphorus Management Plan Status Report for 2022 not yet submitted. Wetland Protection/Monitoring Plan Progress Report submitted by January 31, 2023 (Permit Part I.C.7.c)? Yes. Are the records and reports maintained by the permittee for at least 3 years? Permit records kept "indefinitely". Location: Interview/Effluent Limit Violation Review Observation #: DM1-OB-002 Date: 09/06/2023 I provided Ken McNinch and Tina VanZile with a list of permit effluent limit exceedances, and we discussed the causes of each exceedance (See Appendix 2 - Document Log, for summary of effluent limit exceedances). The causes of recent exceedances are described below. N-ammonia exceedances: winter 2019 and 2021; Ken McNinch attributed exceedances to cold temperatures. He said they now use molasses and lime supplements in winter. E.coli exceedances: May 2020; May 2022: Ken McNinch attributed exceedances to UV bulb issues. He said they ran out of UV bulbs (COVID supply issue). Now, they keep extra bulbs. 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. Ken McNinch said he wasn't sure. Location: Interview/O&M Observation #: DM1-OB-003 Date: 09/06/2023 Unless noted otherwise, Ken McNinch provided the responses (in bold) to the questions below. Are all treatment units operable? Yes, except fine screen. Maintenance record system exists and includes: o As-built drawings? Yes. o Maintenance history? Currently just started taking maintenance notes in a small notebook. Provided copy of list of things to do to improve O&M (See Appendix 2 - Document Log). o Maintenance costs? Tina VanZile said maintenance costs tracked by accounting department. o SOP for operation and maintenance of each item of major equipment. Not yet. 4 of 18 Sokaogon Chippewa Wastewater Treatment System Inspection Date: 09/06/2023 Operator certifications? Facility employs two operators, Ken McNinch (Wisconsin certifications for recirculating multimedia filters and biological treatment), and Jake McGeshick, operator in training (not yet certified for wastewater). On a regular basis, do operators monitor the key operating parameters and conducting the necessary adjustments to meet the limits of the Permit? Yes, conduct routine ammonia and phosphorus testing. Does the wastewater treatment facility have an alarm system for all essential equipment? Yes, alarms include generator kick on, high flow for dosing tanks, high level screen room, and lift stations levels (all but two lift stations are alarmed, however, the others will be soon via a new project). Are alarms sent to qualified personnel who can respond immediately to remedy the problem? Yes, to both operators. Does the Facility maintain written procedures for responding to emergencies such as power failures, floods, fires, and other natural disasters? Yes, they have an Emergency Response Plan, but it needs to be updated. Is a logbook kept which documents all plant activities on a daily basis? Yes, currently use small notebook, but moving to a more formal written process. 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? Not yet. Does the Facility have standby power for all treatment units? ((40CFR122.41(e). Yes, they have a generator the plant, automatically exercised every Monday. Four lift stations have backup generators. Total of 6 lift stations. Working on obtaining a generator for Youth Center lift station. Sewer collection system overview: miles of conveyance? Shane Hoffman estimated 7-8 miles of conveyance. Number of lift stations? 6 Number of connections/residents served? approximately 550 residents, about 150 houses on the system according to Tina VanZile. Location: Interview/Self Monitoring Observation #: DM1-OB-004 Date: 09/06/2023 Ken McNinch provided the responses (in bold) to the questions below. Are the influent and effluent sampling locations as specified in permit and representative of the waste stream? Yes, influent samples collected prior to screen, effluent samples collected after UV. Are composite samples flow proportioned? Yes, time based. Are composite samples cooled to <4C to properly preserve them during the compositing period? Yes. Do you record composite sampler vault temperatures? Yes. Are all grab samples cooled with ice, gel packs or refrigerated to <6C from the time of collection until analysis including shipping time? Yes. I reviewed the Facility's sample bench sheet for pH and dissolved oxygen. I noted that the sheet did not include the names of the operators collecting and analyzing the samples. This is necessary to confirm that samples were analyzed within holding times. 5 of 18 Sokaogon Chippewa Wastewater Treatment System Inspection Date: 09/06/2023 Location: Interview/Flow Monitoring Observation #: DM1-OB-005 Date: 09/06/2023 Ken McNinch provided the responses (in bold) to the questions below. What type of influent meter is used? mag meter What type of effluent meter is used? mag meter Are influent and effluent flow measuring devices professionally calibrated, at least once per year? Yes, once per year. Location: Interview/SSOs Observation #: DM1-OB-006 Date: 09/06/2023 Ken McNinch provided the responses (in bold) to the questions below. Have there been any backups or overflows in the sanitary sewer collection system, including pump stations, manholes and piping since the last inspection? No. Any complaint about sanitary sewer system backups or basement backups over the last year? No. Location: Physical Inspection Observation #: DM1-OB-007 Date: 09/06/2023 Weather: Cloudy, mild Physical Inspection observations are documented in the Photo Log (see Appendix 1). The physical inspection started at: 9:25 AM (CT), and ended at: 10 AM (CT). Returned to office for close out at 10:05 AM (CT). Photo(s) 1. SOKA0296.JPG 2. SOKA0293.JPG 3. SOKA0294.JPG 4. SOKA0295.JPG 5. SOKA0297.JPG 6. SOKA0298.JPG 7. SOKA0299.JPG 8. SOKA0300.JPG 9. SOKA0301.JPG SECTION III - SAMPLING ACTIVITIES AND ANALYTICAL RESULTS No sampling was conducted. 6 of 18 Sokaogon Chippewa Wastewater Treatment System Inspection Date: 09/06/2023 SECTION IV - 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 #: DM1-OB-001 Location: Interview/Facility Information Regulation and/or Permit Requirement Permit Part II.B.3: Bypass not exceeding limitations. The permittee may allow any bypass to occur which does not cause effluent limitations to be exceeded, but only if it also is for essential maintenance to assure efficient operation. AOC: Treatment bypass - fine screen is offline. Facility bypassing fine screen for about 4 years. No impact on compliance with permit effluent limits. AOC Reference #: DM1-OB-001 Location: Interview/Non-DMR Reports Regulation and/or Permit Requirement Permit Part I.C. - Special Conditions, Reporting AOC: Operation and Maintenance Status Report for 2022 not submitted by January 31, 2023 (Permit Part I.C.3.b). Phosphorus Management Plan Status Report for 2022 not submitted by January 31, 2023 (Permit Part I.C.4). AOC Reference #: DM1-OB-002 Location: Interview/Effluent Exceedance Review Regulation and/or Permit Requirement Permit Part II.D.8 - Twenty-Four Hour Reporting for Violations. The permittee shall orally report any noncompliance which may endanger health or the environment, within 24 hours from the time the permittee becomes aware of the circumstances. AOC: The Utility Director could not confirm that all noncompliance which may endanger health or the environment, including all violations of daily limits, have been orally reported to EPA within 24 hours. AOC Reference #: DM1-OB-004 Location: Interview/Self Monitoring Regulation and/or Permit Requirement Permit Part II.B.1. - Proper O&M. Proper operation and maintenance also include adequate laboratory controls and appropriate quality assurance procedures. AOC: I observed that the sample bench sheets for pH and dissolved oxygen did not include the names of the operators collecting and analyzing the samples. This is necessary to confirm that samples were analyzed within holding times. 7 of 18 Sokaogon Chippewa Wastewater Treatment System Inspection Date: 09/06/2023 AOC Reference #: DM1-OB-007 Location: Physical Inspection of Facility Regulation and/or Permit Requirement Permit Part II.B.1. - Proper O&M. 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. AOC: Significant vegetation observed growing on surface of the sand filter (see Appendix 1, Photo Log image SOKA0296.JPG). SECTION V - CLOSING CONFERENCE Closing Conference I began the closing conference with Facility personnel at 10:08 AM (CT) on 09/06/2023. During the closing conference, I discussed the observations and preliminary Areas of Concern identified during the inspection. Observations and Areas of Concern have not yet been evaluated for a formal compliance determination. I reviewed the timing for completing the inspection report and went over the documents received during the inspection (See Appendix 2 - Document Log). I asked if there were any questions before concluding the inspection. The Facility representatives had no further questions, and we concluded the inspection at 10:30 AM (CT). Communication Log No additional information received by EPA REGION 5 after exiting the Facility on 09/06/2023. SECTION VII - LIST OF APPENDICES 1. Photo Log 2. Document Log 8 of 18 Sokaogon Chippewa Wastewater Treatment System Inspection Date: 09/06/2023 APPENDIX 1: PHOTO LOG Influent composite sampler (ISCO) 09/06/2023 09:26 AM No CBI Physical Inspection Note thermometer with heat sink. No PII SOKA0293.JPG Dean Maraldo 45.483565, -89.00204666 Influent flow meter monitor 09/06/2023 09:27 AM No CBI Physical Inspection Poor image quality. Image out of focus. No PII SOKA0294.JPG Dean Maraldo 45.483565, -89.00204666 9 of 18 Sokaogon Chippewa Wastewater Treatment System Inspection Date: 09/06/2023 Headworks, fine screen and bar screen SOKA0295.JPG 09/06/2023 09:28 AM No CBI No PII Dean Maraldo Physical Inspection 45.48367833, -89.00236166 Fine screen was out of service for about four years, according to the Utility Director. Sand Filters SOKA0296.JPG 09/06/2023 09:38 AM No CBI No PII Dean Maraldo Physical Inspection 45.48338833, -89.00243166 Sand filters covered with vegetation and requires maintenance. 10 of 18 Sokaogon Chippewa Wastewater Treatment System Inspection Date: 09/06/2023 Dosing tank pad and UV Room 09/06/2023 09:40 AM No CBI Physical Inspection Dosing tanks located under concrete pad. No PII SOKA0297.JPG Dean Maraldo 45.48310666, -89.00321 Effluent flow meter and monitor in UV Room SOKA0298.JPG 09/06/2023 09:41 AM No CBI No PII Dean Maraldo Physical Inspection 45.48325333, -89.00302 Effluent meter read 18.3 gallons per minute (about 26,352 gallons per day). 11 of 18 Sokaogon Chippewa Wastewater Treatment System Inspection Date: 09/06/2023 Effluent composite sampler (ISCO) in UV Room 09/06/2023 09:42 AM No CBI No PII Physical Inspection Note thermometer with heat sink. SOKA0299.JPG Dean Maraldo 45.48325333, -89.00302 UV Disinfection system in UV Room 09/06/2023 09:44 AM No CBI Physical Inspection UV bulbs are cleaned once a week. No PII SOKA0300.JPG Dean Maraldo 45.48325333, -89.00302 12 of 18 Sokaogon Chippewa Wastewater Treatment System Inspection Date: 09/06/2023 Facility backup generator 09/06/2023 09:53 AM No CBI No PII Physical Inspection Generator automatically exercised every Monday. SOKA0301.JPG Dean Maraldo 45.48325, -89.00267 13 of 18 Sokaogon Chippewa Wastewater Treatment System Inspection Date: 09/06/2023 APPENDIX 2: DOCUMENT LOG Documents Received Document Name Contains CBI or PII Date Received Pages Indian Health Service - Estimated Dates for Upgrades No 9/6/2023 1 EPA Summary of Effluent Limit Exceedances No Provided by EPA 1 O&M Improvement Plan No 9/6/2023 2 Emergency Response Plan No 9/6/2023 15 * Document not included in report to protect potential private or personal information (e.g., home phone numbers). Attached to Report? Yes Yes Yes No* 14 of 18 Hoffmann, Shane (IHS/BEM) From: Sent: To: Subject: Kohnhorst, Nathan (IHS/BEM) Tuesday, September 5, 2023 7:01 AM Hoffmann, Shane (IHS/BEM) Mole Lake dates Here are the estimated dates: Fine Screen Replacement o Bid received: 6/21/23 o Substantial complete: 270 days from signed Notice to Proceed (I don't think the Notice to Proceed has been signed yet by the Tribe but estimate that to happen in Sept. 2023); this would then be June 2024 for substantial complete Concrete Repairs to UV chamber - estimated construction in 2024. Ammonia Reduction - will review treatment options with McMahon Assoc in late 2023/early 2024. In review of options with the Tribe, will determine if there is a need to implement a treatment option since the Ammonia limit was removed from the NPDES permit, reporting Ammonia is still required by the permit. SCADA Upgrades - will occur once fine screen install is complete to incorporate into upgrades. Thanks Nathan LCDR Nathan Kohnhorst, Sr. Field Indian Health Service Sanitation Facilities Construction 129 North Brown St. Rhinelander, WI 54501 715-365-5117 (office) nathan .koh nhorstc hs.gov Engineer Sokaogon Chippewa WWTS Inspection Date: 09/06/2023 1 Page 15 of 18 Effluent Limit Exceedances Report WI0071501: SOKAOGON CHIPPEWA WASTEWATER TREATMENT SYSTEM, CRANDON, WI 54520 Monitoring Period Date Range: 10/01/2018 to 06/30/2023 Exceedance Details Monitoring Period Date 11/30/2018 12/31/2018 1/31/2019 1/31/2019 2/28/2019 2/28/2019 3/31/2019 5/31/2020 5/31/2020 2/28/2021 2/28/2021 3/31/2021 3/31/2021 5/31/2022 Outfall 1 1 1 1 1 1 1 1 1 1 1 1 1 1 Parameter Description Nitrogen, ammonia total (as N) Nitrogen, ammonia total (as N) Nitrogen, ammonia total (as N) Nitrogen, ammonia total (as N) Nitrogen, ammonia total (as N) Nitrogen, ammonia total (as N) Nitrogen, ammonia total (as N) E. coli E. coli Nitrogen, ammonia total (as N) Nitrogen, ammonia total (as N) Nitrogen, ammonia total (as N) Nitrogen, ammonia total (as N) E. coli Limit Type DAILY MX DAILY MX MO AVG DAILY MX MO AVG DAILY MX DAILY MX 30DA GM DAILY MX MO AVG DAILY MX MO AVG DAILY MX DAILY MX DMR Value 11 13 10.2 12 10.4 14 16 154 650 10 13 10.7 14 2400 DMR Value Unit mg/L mg/L mg/L mg/L mg/L mg/L mg/L #/100mL #/100mL mg/L mg/L mg/L mg/L #/100mL Limit Value 9.87 9.87 9.87 9.87 9.87 9.87 9.87 126 410 9.87 9.87 9.87 9.87 410 Limit Value Qualifier <= <= <= <= <= <= <= <= <= <= <= <= <= <= Limit Value Unit mg/L mg/L mg/L mg/L mg/L mg/L mg/L #/100mL #/100mL mg/L mg/L mg/L mg/L #/100mL % Exceedance 11 32 3 22 5 42 62 22 59 1 32 8 42 485 Sokaogon Chippewa WWTS Inspection Date: 09/06/2023 Page 16 of 18 Sokaogon Chippewa Community O&M Starting from here is the what I do daily. When I pull into town to come punch in I look to see if I see any water leaks by any hydrants or where the main is running thru town. When I get to the Wastewater Plant! are Main Office I look to see if anyone has pulled in by the gate and usually pick up any garbage by are entrance. When I get to the building I look for any signs of damage or trespassers overnight. When I come in the main building I check the SCADA computer. After the computer check I check the fine screen. Then I will do rounds. Rounds consist of checking the raw sampler. Getting the Raw flow reading. Double check the fine screen. Turning Samplers on when testing. Checking over the whole Raw sample room for anything out of place. Then I check the Effluent room. Getting the flow reading checking the UV if it is on. Checking the sampler and the condition of the room and all equipment in the building. Turning samplers on when testing. Then I check the Sand filter to see if it is blinding out and needs to be broken up with are ATV and Disc. After checking that I look around to see if I can see any sign of trespassers over night or over the weekend. Then I go down to Are Effluent discharge area and check that to see if all is ok. Then I come check emails and phone messages. After that is done I go check the pump house. The lifts stations. And the booster stations along with the water tower and the Stand Pipe water storage tank. Pumphouse- check temp of building. Get the pump start and run times. Test water for chlorine residuel. Check chlorine tank and all of the inside of building. Lift stations- get run times and start times. Temp where available. And generator run and start times on all lift stations where available. Water tower and Stand pipe- check outside for damage and check inside of water tower for leaks. This is done Monday and Thursday. Booster station- check outside for damage. Inside I get the run times and starts of all the pumps and the flow reading. Also get temp. Clean UV bulbs once a week. Monthly Checks Wastewater Plant Samplers- clean Sampler hoses and sample jugs Sokaogon Chippewa WWTS Inspection Date: 09/06/2023 Page 17 of 18 Generators- check the whole thing over. If your reading this you must have some common sense so when I say check the whole thing it over it means everything. EVERYTHING! Lift Stations- open hatch to the Shit and Such and check for Grease and the other good time things. Clean as needed. Use your head a little and determine if it needs cleaning. For the Water part of monthly checks. The only thing I check monthly are the well Heads by the Pumphouse Testing: Wastewater samples get tested twice a week for CBOD, TSS, Ammonia, and Phosphorus. Water testing is Chlorine residual daily, BacT testing monthly and the EPA sends a drinking water monitoring schedule very 3 years. Sokaogon Chippewa WWTS Inspection Date: 09/06/2023 Page 18 of 18