Document RL3g8aVO62j61y5LmK8v9Xan

EPA Region 10 Enforcement and Compliance Assurance Division INSPECTION REPORT Inspection Entry Date/Time Inspection Exit Date/Time Weather Media Statute(s)/Program(s) Type of Inspection 03/20/2023 9:10 AM (PT) Announced: No 03/20/2023 12:30 PM (PT) Access: Granted 40F, Overcast Water Clean Water Act, NPDES, WWTP Compliance Evaluation Inspection Permittee Name Facility or Site Name Facility Physical Address City, State, Zip Code County Facility GPS Coordinates Mailing Address City, State, Zip Code City of Genesee Genesee WWTP Cow Creek Rd & Morscheck Rd Genesee, Idaho 83832 Latah 46.5413, -116.941432 P.O. Box 38 Genesee, Idaho 83832 FRS ID Permit Number SIC 110039696255 ID0020125 4952 (Sewage Systems) Lead Inspector: RAYMOND ANDREWS Date: 2023.05.22 10:02:18 -07'00' Digitally signed by RAYMOND ANDREWS Raymond Andrews EPA Region 10 andrews.raymond@epa.gov (206) 553-4252 Supervisor Review: PETER CONTRERAS Date: 2023.05.22 10:11:23 -07'00' Digitally signed by PETER CONTRERAS Peter Contreras EPA Region 10 Contreras.peter@epa.gov (206) 553-6708 1 of 10 SECTION I - INTRODUCTION Genesee WWTP ID0020125 Site Entry and Inspection Objectives I arrived at the City of Genesee WWTP ("Facility"), located at Cow Creek Rd & Morscheck Rd, Genesee, Idaho, at 9:10am on 03/20/2023 for an unannounced inspection. I presented my credentials to Dustin Brinkley and informed him that I was an inspector from EPA Region 10's Seattle office and I was at the facility to conduct an inspection to determine compliance with Section 308 of the Clean Water Act (CWA) Section 308 the facility's National Pollutant Discharge Elimination System (NPDES) permit, permit # ID0020125. This report is based on information supplied by Mr. Dustin Brinkly, the City Public Works Director, direct observations I made, and records and reports maintained by the facility. In addition, information gathered from a review of EPA, State, and/or public records may be included in this report. Attendees Organization EPA Region 10 Attendee Name Raymond Andrews Title Lead Inspector Present in Opening Conf. Yes Present in Closing Conf. Yes City of Genesee Dustin Brinkly Public Works Director Yes Yes Facility/Site Information What is the facility's The facility has a service population of 1,051 people with a total of 394 service service population? connection. How many employees The facility has two employees, Mr. Brinkly, who holds a Class 2 Wastewater Treatment does the facility certification, and James Mader. Mr. Mader was uncertified at the time of the inspection. have? When is the facility staffed? The facility is staffed 7:30am until 4:30pm, Monday through Friday. On Saturday and Sunday, either Mr. Brinkly, or Mr. Mader, conducts a check on the pumps and aerators which take approximately 30 minutes. How many outfalls does the facility have? The facility discharges through a single outfall. The facility discharges into Cow Creek which enters Union Flat Creek which is a tributary of the Palouse River. How often does the facility discharge? The facility discharges daily from December through April. The facility is permitted to land apply from May through October. The facility does not discharge in November. What is the design flow of the facility? 0.15 MGD What is the average 0.13 MGD daily flow? Does the facility treat The facility does not accept any waste other than domestic sewage. anything other than domestic sewage? Explain the facility's The sewage first enters a grinder at the headworks, then proceeds to a lift station which treatment process. moves the influent to a single aerated lagoon. From the lagoon, the influent enters a chlorine contact chamber. Prior to discharge, the effluent passes through dechlorination. Where does the facility collect in fluent and effluent samples? Influent samples are collected from a manhole located prior to the lift station. Effluent samples are collected at the point of discharge. 2 of 10 Genesee WWTP ID0020125 Which parameters does the facility monitor? Per the permit, the facility monitors E. coli, total residual chlorine, ammonia, phosphorus (summer), temperature, pH, biological oxygen demand (BOD), and total suspended solids (TSS). Who conducts the sampling? Dustin Brinkly draws both the influent and effluent samples. Does the facility conduct its own analysis? Most sampled parameters are analyzed by a contract lab. Anatek Labs, Inc. - Moscow 1282 Alturas Drive Moscow, Idaho 83843 (208) 883-2839 Is the facility sampling more frequently than required? The facility does sample more frequently than required by the Permit. Additional samples are factored into the results reported on the Discharge Monitoring Reports (DMRs). Does the facility analyze any parameters? Due to the 15-minute hold time, pH is analyzed by the facility at the time of sample collection. pH is monitored using a digital pH meter which the facility calibrates prior to each use. Has the facility violated a daily maximum, or monthly average, limit? The facility violates a daily maximum or monthly average about 3 times a year. The facility frequently exceeds the monthly averages of biochemical oxygen demand (BOD) and total suspended solids (TSS). To whom was the Exceedances are reported on DMRs. exceedance reported? Has the facility been Yes. The facility added aeration to its lagoon in 2020. changed or upgraded in the last 5-years? Are any upgrades planned at the facility? The City has sent out a notice requesting bids for construction of a new wastewater treatment plant. 3 of 10 SECTION II - OBSERVATIONS Genesee WWTP ID0020125 Location: Outfall Observation #: RA1-OB-001 Date: 03/20/2023 Weather: 40F, Overcast Around the discharge pipe at the outfall, there appeared to be areas of foamy bubbles. In addition to the bubbles, there was a turbid plume leading from the outfall that was noticeably darker than the ambient water in the creek. Turbid Plume Bubbles 4 of 10 SECTION III - RECORDS REVIEW Genesee WWTP ID0020125 Record: Other - EPA's Integrated Compliance Information System Database Ref #: RA1-RR-003 Reviewed By: Raymond Andrews AOC: Yes Reviewed Date: 05/11/2023 Upon review of data in EPA's Integrated Compliance Information System (ICIS) database from 5/1/2018 - 4/30/2023, I found the facility had a total of 1,811 effluent exceedances between 5/1/2018 and 4/30/2023. Record: Discharge Monitoring Reports (DMRs) AOC: Yes Ref #: RA1-RR-002 Reviewed By: Raymond Andrews Reviewed Date: 05/11/2023 Upon review of data in EPA's ICIS database from 5/1/2018 - 4/30/2023, I found the facility was late in submitting two Discharge Monitoring Reports (DMRs), submitted two incomplete DMRs, and one DMR was "administratively resolved". Record: Other - Compliance Order on Consent and Compliance Agreement Schedule AOC: Yes Ref #: RA1-RR-001 Reviewed By: Raymond Andrews Reviewed Date: 05/11/2023 Upon review of data in EPA's ICIS database from 12/1/2018 - 4/28/2023, I found the facility was late in submitting 10 scheduled documents. The facility also failed to submit one other scheduled document. SECTION IV - AREAS OF CONCERN AOC Reference #: RA1-RR-001 Records Review: Other - Compliance Order on Consent and Compliance Agreement Schedule Regulation and/or Permit Requirement Part I.B.3.d, "Use the temperature device manufacturer's software to generate (export) an Excel or electronic ASCII text file. The file must be submitted annually to the EPA and IDEQ by January 31 for the previous monitoring year along with the placement log." Permit Part II.C.4, "The permittee must submit an Annual Report of Progress which outlines the progress made towards reaching the compliance date for the ammonia effluent limitations. The annual Report of Progress must be submitted by July 20th of each year. The first report is due July 20th, 2018, and annually thereafter, until compliance with the ammonia effluent limits is achieved." Permit Part II.E.4, "The Permittee must submit this list, along with a summary description of the sources and information gathering methods used to develop this list, to EPA within two years following the effective date of the NPDES permit." Permit Part I.C.7.a, "The permittee must submit all surface water monitoring results for the previous calendar year for all parameters in an annual report to EPA and IDEQ by January 31st of the following year and if applicable, with the application (see Part V.B of this permit, Duty to Reapply)" AOC: The facility did not meet submission requirements for 11 scheduled documents. late, and one was not submitted. Late Annual Reports of Progress - 3 Surface Water Monitoring Reports - 3 Effluent Monitoring Reports - 2 Industrial User Report - 1 Facility Plan - 1 Ten documents were submitted Not Submitted Annual Report of Progress - 1 A table of the late and missing documents is in Appendix II. 5 of 10 Genesee WWTP ID0020125 AOC Reference #: RA1-RR-002 Records Review: DMR Reports Regulation and/or Permit Requirement Permit Part III.B.1, "Monitoring data must be submitted electronically to EPA no later than the 20th of the month following the completed reporting period. All reports required under this permit must be submitted to EPA as a legible electronic attachment to the DMR." AOC: The facility was late in submitting two Discharge Monitoring Reports (DMRs). The facility also submitted two incomplete DMRs, and one DMR was "administratively resolved". A table of the DMRs is in Appendix II. AOC Reference #: RA1-RR-003 Records Review: Other - EPA's ICIS Database Regulation and/or Permit Requirement Permit Part I.B.1, "The permittee must limit and monitor discharges from outfall 001 as specified in Table 1." AOC: I found the facility had a total of 1,811 effluent exceedances between 5/1/2018 and 4/30/2023. A table of effluent exceedances is in Appendix II. AOC Reference #: RA1-OB-001 Location: Outfall Regulation and/or Permit Requirement Permit Part I.B.4.a, "The permittee must not discharge floating, suspended, or submerged matter of any kind in concentrations causing nuisance or objectionable conditions or that may impair designated beneficial uses. AOC: Around the discharge pipe at the outfall, I observed what appeared to be areas of foamy bubbles. In addition to the bubbles, there was a plume leading from the outfall that was noticeably darker than the ambient water in the creek. SECTION V - CLOSING CONFERENCE I held a closing conference with Mr. Brinkly at 12:30 PM (PT) on 03/20/2023. During the conference, I discussed the observations and Areas of Concern I identified during the inspection. Observations and Areas of Concern have not yet been evaluated for a formal compliance determination. SECTION VI - LIST OF APPENDICES I. Photo Log II. Areas of Concern Tables 6 of 10 APPENDIX I: Photo Log P1010592 - Manhole prior to Lift Station, influent sampling point, closed P1010593 - Manhole prior to Lift Station, influent sampling point, open P1010594 - Lift Station (L)/Grinder (R) P1010595 - Grinder, interior P1010596 - Lift Station, interior P1010597 - Lagoon, photo 1 P1010598 - Lagoon, photo 2 P1010599 - Lagoon, photo 3 P1010600 - Chlorine Contact Chamber, photo 1 P1010601 - Chlorine Contact Chamber, photo 2 P1010602 - Chlorine Contact Chamber, photo 3 P1010603 - V-Notch Weir, photo 1 P1010604 - V-Notch Weir, photo 2 P1010605 - Flow Meter Recording Box P1010606 - Outfall, photo 1 P1010607 - Outfall, photo 2 APPENDIX II: Areas of Concern Tables Scheduled Submission Areas of Concern Schedule Event Annual Report of Progress Effluent Monitoring Report Surface Water Monitoring Report Industrial User Report Annual Report of Progress Surface Water Monitoring Report Facility Evaluation Plan Annual Report of Progress Effluent Monitoring Report Surface Water Monitoring Report Annual Report of Progress Schedule Date 7/20/2018 1/31/2019 1/31/2019 7/1/2019 7/20/2019 1/31/2020 3/31/2020 7/20/2020 1/31/2021 1/31/2021 7/20/2022 Received Date 6/11/2020 6/16/2020 6/12/2020 6/11/2020 6/11/2020 6/15/2020 4/24/2020 10/14/2021 10/14/2021 10/14/2021 Citation Part II.C.4 Part I.B.3.d Part I.C.7.a Part II.E Part II.C.4 Part I.C.7.a Compliance Order, Paragraph 3.1.1 Part II.C.4 Part I.B.3.d Part I.C.7.a Part II.C.4 Status Late Late Late Late Late Late Late Late Late Late Not Received Monitoring Period End 6/30/2019 8/31/2019 6/30/2020 6/30/2021 1/31/2023 Discharge Monitoring Reports Areas of Concern Due Date 7/20/2019 9/20/2019 7/20/2020 7/20/2021 2/20/2023 Received 11/12/2019 8/20/2021 4/3/2023 Notes Incomplete. DMR was missing data for: Dissolved oxygen; Nitrogen; ammonia total [as N]; Nitrogen, Kjeldahl, total [as N]; Nitrite + Nitrate total [as N]; Phosphorus, total [as P]; Oil & Grease; Chlorine, total residual; and Solids, total dissolved. Late. NODI Code "C" - "No Discharge" used. Administratively Resolved. NODI Code "E" - "Failed to Sample/Required Analysis Not Conducted" used. Incomplete. Administratively Resolved on 8/20/2022; Facility failed to submit data for: Chlorine, total residual; and Solids, total dissolved. Late. Facility was late in submitting data for: Nitrogen, ammonia total [as N] Month Dec 2018 Dec 2018 Dec 2018 Dec 2018 Dec 2018 Feb 2019 Feb 2019 Feb 2019 Feb 2019 Feb 2019 Mar 2019 Mar 2019 Mar 2019 Mar 2019 Parameter BOD5, 20C BOD5, 20C BOD5, 20C TSS BOD5,% rmv BOD5, 20C BOD5, 20C E. coli BOD5,% rmv TSS, % rmv BOD5, 20C BOD5, 20C BOD5, 20C BOD5,% rmv Effluent Exceedances DMR Value Permit Limit 39.9 30 59.9 38 59.9 56 63.1 56 80.8 85 39.7 30 39.8 38 1600 576 68 85 58 65 52.55 38 63 30 63 45 73 85 Unit mg/L lb/d lb/d lb/d % mg/L lb/d #/100mL % % lb/d mg/L mg/L % Limit Type Mo Avg Mo Avg Wkly Avg Mo Avg Mo Av Mn Mo Avg Mo Avg Inst Max Mo Av Mn Mo Av Mn Mo Avg Mo Avg Wkly Avg Mo Av Mn # Violations 31 31 7 31 31 28 28 1 28 28 31 31 7 31 Month Apr 2019 Dec 2019 Dec 2019 Dec 2019 Jan 2020 Jan 2020 Jan 2020 Feb 2020 Feb 2020 Feb 2020 Feb 2020 Feb 2020 Feb 2020 Mar 2020 Mar 2020 Mar 2020 Mar 2020 Mar 2020 Mar 2020 Apr 2020 Apr 2020 Nov 2020 Nov 2020 Nov 2020 Nov 2020 Nov 2020 Dec 2020 Jan 2021 Jan 2021 Jan 2021 Jan 2021 Jan 2021 Feb 2021 Feb 2021 Mar 2021 Mar 2021 Mar 2021 Mar 2021 Mar 2021 Dec 2021 Parameter BOD5,% rmv BOD5, 20C TSS BOD5,% rmv BOD5, 20C TSS BOD5,% rmv BOD5, 20C BOD5, 20C TSS TSS TSS BOD5,% rmv BOD5, 20C BOD5, 20C TSS TSS TSS TSS BOD5, 20C pH BOD5, 20C TSS TSS TSS BOD5,% rmv BOD5, 20C BOD5, 20C TSS TSS TSS BOD5,% rmv BOD5, 20C TSS BOD5, 20C pH TSS TSS BOD5,% rmv Ammonia DMR Value 78 31.5 50 73 43.2 54 77 31.9 55.9 59 103.3 103.3 81 39.2 52.31 98 98 130.8 130.8 33.85 9.55 33.7 66 66 71.56 62 35.8 31.8 62.55 75 75 69.4 38.5 58.9 43.5 9.19 45.8 68.76 74 22 Permit Limit 85 30 45 85 30 45 85 30 38 45 56 81 85 30 38 45 65 56 81 30 9 30 45 65 56 85 30 30 56 45 65 85 30 45 38 9 45 56 85 15 Unit % mg/L mg/L % mg/L mg/L % mg/L lb/d mg/L lb/d lb/d % mg/L lb/d mg/L mg/L lb/d lb/d mg/L SU mg/L mg/L mg/L lb/d % mg/L mg/L lb/d mg/L mg/L % mg/L mg/L lb/d SU mg/L lb/d % mg/L Limit Type Mo Av Mn Mo Avg Mo Avg Mo Av Mn Mo Avg Mo Avg Mo Av Mn Mo Avg Mo Avg Mo Avg Mo Avg Wkly Avg Mo Av Mn Mo Avg Mo Avg Mo Avg Wkly Avg Mo Avg Wkly Avg Mo Avg Inst Max Mo Avg Mo Avg Wkly Avg Mo Avg Mo Av Mn Mo Avg Mo Avg Mo Avg Mo Avg Wkly Avg Mo Av Mn Mo Avg Mo Avg Mo Avg Inst Max Mo Avg Mo Avg Mo Av Mn Mo Avg # Violations 30 31 31 31 31 31 31 29 29 29 29 7 29 31 31 31 7 31 7 30 1 30 30 7 30 30 31 31 31 31 7 31 28 28 31 1 31 31 31 31 Month Dec 2021 Jan 2022 Jan 2022 Feb 2022 Feb 2022 Mar 2022 Apr 2022 Jun 2022 Jun 2022 Nov 2022 Nov 2022 Dec 2022 Dec 2022 Jan 2023 Jan 2023 Feb 2023 Parameter Ammonia Ammonia Ammonia TSS, % rmv Ammonia pH Ammonia Phosphorus Phosphorus Ammonia Ammonia Ammonia Ammonia Ammonia Ammonia BOD5,% rmv DMR Value 25.69 19.1 20.9 41.5 17.93 9.51 21.1 6.18 6.18 20.7 22.4 21.2 21.7 17.6 26.4 71.2 Permit Limit 19 19 15 65 15 9 19 2 4 15 19 19 15 15 19 85 Unit lb/d lb/d mg/L % mg/L SU lb/d lb/d lb/d mg/L lb/d lb/d mg/L mg/L lb/d % Limit Type Mo Avg Mo Avg Mo Avg Mo Av Mn Mo Avg Inst Max Mo Avg Mo Avg Wkly Avg Mo Avg Mo Avg Mo Avg Mo Avg Mo Avg Mo Avg Mo Av Mn # Violations 31 31 31 28 28 1 30 30 7 30 30 31 31 31 31 28