Document Qgp87ODOZ234M7bJd2Oe3xV34
RETURN RECEIPT REQUESTED
REGION 10
SEATTLE, WA 98101
Mr. Dan Fielding Hatchery Manager Quinault National Fish Hatchery 3 Sockeye Road Humptulips, Washington 98552
Re: NOTICE OF VIOLATION Quinault National Fish Hatchery NPDES Permit Number WAG130005
Dear Mr. Fielding:
The U.S. Environmental Protection Agency (EPA) appreciates your time and cooperation during EPA's July 28, 2023, Clean Water Act (CWA) inspection of the Quinault National Fish Hatchery ("Facility"). EPA inspected the Facility and reviewed administrative files to assess the Facility's compliance with the requirements of the CWA and the National Pollutant Discharge Elimination System (NPDES) general permit WAG130000 ("Permit") for Federal Aquaculture Facilities and Aquaculture Facilities Located in Indian Country.
The Quinault National Fish Hatchery is permitted to discharge under the Permit WAG130005, which became effective on August 1, 2016 and has been administratively extended since the expiration date of July 31, 2021.
The purpose of this letter is to notify the Facility of noncompliance with the Clean Water Act at the Facility and to request that the Facility return to compliance.
1. Parts IV.F.d.,1-5 of the General Aquaculture Permit describes Quality Assurance Plan (QAP) content requirements such as sampling procedures, map illustrating sampling point locations, personnel qualifications and training and the "name, address and telephone number of the laboratory used by or proposed to be used by the Permittee."
During the post-inspection file review of the Facility's QAP, the inspector noted the sampling analyses procedures described in the Facility's QAP needed to be updated to include parameter limits for analytical detection and quantification, analytical methods used by the lab Fremont Analytical, complete contact information for the lab, qualification and training of personnel and a map indicating locations of sampling points.
2. Part IV.G.5.a.,1-2 of the General Aquaculture Permit describes the Facility's Best Management Practices (BMP) Plan material storage requirements.
During the site walkthrough, the inspector identified a strong odor in the flammable and chemical storage shed from an unknown chemical source indicating a possible leak and/or lack of proper chemical containment and storage.
3. Part IV.G.5.e.,5 of the General Aquaculture Permit describes the operational content requirements of the Facility's BMP Plan.
During the site walk through, Facility staff informed the inspector that although chlorine disinfection is not used at the Facility, Chlorine may be used to disinfect the hauling equipment/ trucks. A post-inspection review of the BMP Plan did not include how any excess or unused disinfectants would be properly treated before it is discharged to water of the U.S.
4. Part V.G of the General Aquaculture Permit describes that annual report of operations "must include the information specified in Appendix E." Appendix E is the "Annual Report of Operations" form containing the section to summarize a Facility's aquaculture drug and chemical usage.
The inspector's post-inspection review of the Facility's 2021 and 2022 Annual Reports noted Florfenicol/Aquaflor was marked in the reports as having been used, but the Annual Reports were missing additional details about the usage of the chemical/drug.
Quinault National Fish Hatchery is requested to respond, in writing, to the findings stated above within 45 days of receipt of this letter. Your response should include the causes of the violations and the measures taken to address the current violations and prevent future violations. The request for information in this letter is made under the authority of Section 308 of the CWA, 33 U.S.C. 1318. In accordance with the provisions of 40 C.F.R. 2.203(b), you may assert a business confidentiality claim covering part or all the information submitted by clearly identifying it as "confidential." If no such claim accompanies the information when it is received by the EPA, it may be made available to the public without further notice.
Please send your response letter via email to:
Wesley Simmons Compliance Officer U.S. Environmental Protection Agency simmons.wesley@epa.gov
If the Facility fails to correct the violations identified in this letter, EPA may pursue a formal enforcement action pursuant to Section 309 of the CWA, 33 U.S.C. 1319. Section 309(a) of the CWA,
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33 U.S.C. 1319(a), authorizes EPA to issue administrative orders requiring specific measures be taken to ensure compliance with the CWA.
EPA appreciates your attention to this matter. If you have any questions concerning this matter, please do not hesitate to contact Wesley Simmons, of my staff, at simmons.wesley@epa.gov or (206) 553-6066.
Sincerely,
JEFFERY KENKNIGHT
Digitally signed by JEFFERY KENKNIGHT Date: 2024.09.09 15:09:57 -07'00'
Jeff KenKnight, Manager Water Enforcement and Field Branch Enforcement and Compliance Assurance Division
cc: Mr. Sam Van Liew Assistant Project Leader
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