Document Z4ew0Ln6dopj6gqZVkVr3bb4O

WASTEWATER TREATMENT SYSTEM COMPLIANCE EVALUATION INSPECTION REPORT Purpose: NPDES Compliance Evaluation Inspection Facility: Big Sand Lake/West Hertel Wastewater Treatment Plant St. Croix Chippewa Indians of Wisconsin Reservation P.O. Box 67 Hertel, Wisconsin 54893 (NW of Section 2, T38N, R15W) NPDES Permit Number: WI-0062847 Date of Inspection: October 27, 2020 EPA Inspectors: Dean Maraldo, EPA Region 5; (312) 353-2098; maraldo.dean@epa.gov Valerie Dooling, EPA Region 5; (312) 886-7167; dooling.valerie@epa.gov St. Croix Chippewa Indians of Wisconsin Representatives: David Buck, Utility Supervisor; (715) 645-2045 Trent Strapon, Operator-in-training; (715) 645-2045 Indian Health Service (IHS) Representative: Shane Hoffmann, Tribal Utility Consultant, (715) 365-5129 Report Prepared by: Dean Maraldo, EPA Region 5 Inspector Maraldo, Digitally signed by Maraldo, Dean EPA Inspector Signature: _D_e_a__n_________D0_9a_:t2e_2::24_04_2-00_.51_'00._02'9___________ Approver Name & Title: Ryan Bahr, Chief, Section 2, Water Enforcement and Compliance Assurance Branch Digitally signed by Bahr, Bahr, Ryan Ryan Date: 2020.10.29 Approver Signature/Date ______________1_7_:0_2:_35_-_05_'0_0'_____________ Big Sand Lake/West Hertel WWTP CEI Inspection Report [This page intentionally left blank] Big Sand Lake/West Hertel WWTP CEI Inspection Report TABLE OF CONTENTS I. Introduction .................................................................................................................................. 1 II. Background................................................................................................................................... 1 III. Inspection Activity Summary ....................................................................................................... 2 IV. Closing Conference and Areas of Concern .................................................................................. 4 V. Documents Received and References........................................................................................... 4 LIST OF ATTACHMENTS Attachment A: Aerial Image of the Big Sand Lake/West Hertel WWTP Attachment B: Photo Log Attachment C: Plan view diagram of the Big Sand Lake/West Hertel WWTP Attachment D: Summary of effluent limit violations (11/1/2015-9/30/2020). Big Sand Lake/West Hertel WWTP CEI Inspection Report [This page intentionally left blank] Big Sand Lake/West Hertel WWTP CEI Inspection Report I. INTRODUCTION On October 27, 2020, I inspected the St. Croix Chippewa Indians of Wisconsin's (Tribe) Big Sand Lake/West Hertel Wastewater Treatment Plant (facility) (see Attachment A for an aerial image of the facility). I assessed the Tribe's compliance with the National Pollutant Discharge Elimination System (NPDES) permit for the facility. The inspection consisted of the following major activities: Inspection opening conference; Interview/discussions with representatives from the Tribe including the status of NPDES permit- specific reports, description of facility operations and maintenance (O&M), self-monitoring activities; and results of Discharge Monitoring Report (DMR) review; Physical inspection of the facility; and Closing conference. This report summarizes the results of the inspection. The following organizations and representatives were involved in the inspection of the facility: St. Croix Chippewa Tribe Utility Department: David Buck, Utility Supervisor Trent Strapon, Operator-in-training EPA Inspectors: Dean Maraldo, Inspector Valerie Dooling, Inspector-in-training Indian Health Service (IHS) Representative: Shane Hoffmann, Tribal Utility Consultant II. BACKGROUND The Tribe is authorized to discharge from the facility under permit WI-0062847 (permit). The Tribe's Utility Department is responsible for the facility's operation and compliance with NPDES permit requirements. The Tribe is responsible for conducting monitoring activities and reporting monitoring results to EPA. Currently, one certified operator, Patty Edwards, operates the facility along with the Utility Supervisor (Mr. Buck), and an operator-in-training (Mr. Strapon). The Utility Department is responsible for the Tribe's water and wastewater utilities including the water and wastewater treatment facilities, and the water distribution and wastewater collection systems. The operators' duties include operation and maintenance of all utility assets, water and wastewater monitoring, and reporting. The Tribe receives support and technical assistance from the U.S Public Health Service, Indian Health Service. According to its Web site, the IHS, through the Sanitation Facilities Construction (SFC) Program Division, is responsible for delivering environmental engineering services and sanitation facilities to American Indians and Alaska Natives. The SFC Program provides American Indian and Alaska Native homes and communities with essential water supply, sewage disposal, and solid waste disposal facilities. IHS environmental engineers plan, design, and manage most SFC projects. 1 Big Sand Lake/West Hertel WWTP CEI Inspection Report Pre-Inspection Conference Call EPA and the Tribe held a conference call on October 15, 2020, to discuss the inspection process and planned inspection precautions due to the COVID-19 pandemic. Also, to avoid unnecessary face-to-face discussions during the inspection, we went over the Tribe's compliance with NDPES permit reporting requirements. Based on information gathered during the call, the Tribe complied with NPDES permit reporting requirements, except for the development and implementation of a preventive maintenance program (due October 18, 2017, pursuant to NPDES Permit Part I.C.3.d). I also requested the Tribe provide operator certifications, treatment system maps, and the facility O&M Plan before the inspection to reduce review time in the field. The Tribe provided all of the requested documents prior to the inspection. III. INSPECTION ACTIVITY SUMMARY III. A. Opening Conference The inspection opening conference began with introductions at 12:57 p.m. on October 27, 2020, at the Tribe's utility building garage. I presented my U.S. EPA Inspector credentials to Mr. Buck and then discussed the inspection's intended scope. Mr. Shane Hoffmann (Indian Health Service), Ms. Dooling, and Mr. Strapon, the Tribe's operator-in-training, were also in attendance. I requested that Mr. Buck provide monthly operation reports (MORs) for July thru September 2020. Mr. Buck retrieved copies of the MORs, and we began the Interview portion of the inspection. III. B. Interview I started the interview portion of the inspection by asking Mr. Buck if the Tribe submitted an NPDES permit reapplication package, as the facility's NPDES permit expires on April 11, 2021. He confirmed that the permit reapplication package was submitted to EPA. I then asked Mr. Buck how things were going at the facility. He said that the facility is operating well except two of the six treatment wetlands that have been offline for two years due to invasive grasses and vines. He added that the vines clog the aeration tubing in the treatment wetlands. Mr. Buck also mentioned the chronic copper and E.coli violations reported in the Tribes DMRs (see Appendix D). He said the Tribe has not been able to figure out the source of the copper violations but believes the E.coli violations may be due to worms growing in the sand filters. I offered to assist the Tribe and IHS with an investigation into the causes of the copper and E.coli issues. I asked Mr. Buck to describe the facility's treatment process from the collection system to the final outfall. According to Mr. Buck, 7 lift stations help pump wastewater to the facility headworks, consisting of three 25,000-gallon septic tanks. The collection system includes 75 connections serving about 500 residents. I asked if there were any industrial users. Mr. Buck said there were not. From the headworks, wastewater flows to six treatment wetlands and then to three parallel single-pass sand filters. Treated effluent flows from the sand filters to an effluent vault and through a Parshall flume to the final outfall. Mr. Buck estimated the facility treats an average treated effluent flow of 13,000 gallons per day. The facility's final effluent discharges to an unnamed wetland. Next, I asked Mr. Buck about lift station operations. He stated the lift stations were running well with no issues, overflows, or backups in the collection system. He also confirmed that there were no problems with power outages and that the main lift station (#5), which pumps all the flow to the headworks, has an emergency backup generator. I asked if the Tribe has an automatic alarm system to alert operators of issues. He confirmed that the facility has an alarm system with emergency call-out capability, alerting managers and operators of any problems. 2 Big Sand Lake/West Hertel WWTP CEI Inspection Report We then discussed influent and effluent monitoring. Mr. Buck acknowledged that influent flow was estimated using pump run times at main Lift Station 5. Effluent flow is measured at the Parshall flume using an ultrasonic level meter. I asked about flow meter calibration. Mr. Buck confirmed that the meter was serviced and calibrated annually. Mr. Buck then described influent sampling procedures, including the collection of samples before the headworks. Mr. Buck stated that all influent samples are collected as grab samples. I reminded Mr. Buck that the NPDES permit (Part I.B.) requires collection of influent samples using 24-hour composite samples for biochemical oxygen demand (BOD5), copper, and phosphorus. Mr. Buck confirmed that the Tribe collects 24-hour composite samples for the appropriate effluent parameters. However, he stated that the composite sampler (ISCO) is not refrigerated. I reminded Mr. Buck that samples must be preserved (including cooling) according to test procedures approved under 40 CFR Part 136. Mr. Buck added that samples were sometimes stored in a refrigerator in the Utility Garage before shipping to the laboratory. I asked if the refrigerator had a certified thermometer to confirm the appropriate cooling per 40 CFR Part 136. He said there was not a thermometer in the refrigerator. I identified no other selfmonitoring issues. Finally, I asked about septage and sludge accumulation in the system. Mr. Buck stated that the septage was cleaned out of the first headwater tank annually and shipped to the Rice Lake Wastewater Treatment Plant. At this point in the inspection, I asked Mr. Buck if we could conduct the physical inspection of the facility. Mr. Buck agreed with the plan, and we departed for the treatment wetland facility to conduct the physical inspection. III. C. Physical Facility Inspection The physical inspection of the treatment wetland facility began at 1:47 p.m. on October 27, 2020. The weather was cold and sunny. Mr. Buck led the tour, and Ms. Dooling, Mr. Hoffmann, and Mr. Strapon joined us. The physical inspection is summarized below. Photos referenced below are included in the Photo Log (Attachment B). A plan view flow diagram of the facility is provided in Attachment C. We began the inspection at the influent vault (Photograph 1; STWH0001.jpg) before the headwork septic tanks. We then viewed the headworks area, including septic tanks 1 and 2 (Photograph 2; STWH0002.jpg) and septic tank 3 and the diverter tank (Photograph 3; STWH0003.jpg). Photograph 4 shows the inside of the headwork diverter tank, including diversion weirs (STWH0004.jpg). Next, we viewed treatment wetlands 1-3 (Photograph 5; STWH0005.jpg; noted cattails in the offline treatment wetlands 1 and 2), treatment wetland 4 (Photograph 6; STWH0006.jpg), treatment wetland 5 (Photograph 7; STWH0007.jpg), and treatment wetland 6 (Photograph 8; STWH0008.jpg). We walked to the effluent sampling shed (Photograph 9; STWH0009.jpg) and viewed the ISCO effluent composite sampler Photograph 10; STWH0010.jpg) and the system process control panels (Photograph 11; STWH0011.jpg, and Photograph 12; STWH0012.jpg). Next, we viewed the effluent vault, which contained the effluent flume, effluent composite sampler tubing, and sonic flow meter. I observed worms along the bottom of the effluent flume, and Ms. Dooling noted that the composite sampler tube inlet was covered by a screen (Photograph 13; STWH0013.jpg). Mr. Buck stated that the screen was in place to keep worms from being drawn into the composite sampler. The group then drove across Rt. 70 to the final effluent Outfall 001. Effluent Outfall 001 is distributed through four outfall pipes to reduce channeling at the head end of the unnamed wetland (Photograph 14; STWH0014.jpg). The effluent was clear, and no issues were observed in the receiving water. On the way back to the Utility Garage, we stopped to observe main Lift Station 5 (Photograph 15; STWH0015.jpg) and the backup power generator for Lift Station 5 (Photograph 16; STWH0016.jpg). 3 Big Sand Lake/West Hertel WWTP CEI Inspection Report I completed the physical inspection, and the group returned to the Utility Garage to prepare for the closing conference. IV. CLOSING CONFERENCE AND AREAS OF CONCERN After taking some time to review notes with Ms. Dooling, I began the closing conference at the Tribe's Utility Garage. Before reviewing preliminary areas of concern, I asked Mr. Buck if he had copies of the chain of custody (COC) forms for samples sent to the laboratory for analysis. Mr. Buck said he did not retain copies of COCs. I recommended he contact the laboratory regarding COC records and start retaining copies of COCs as evidence of proper sampling documentation and management. I started by reviewing some of the preliminary areas of concern with Mr. Buck, Mr. Strapon, Ms. Dooling, and Mr. Hoffmann. I noted that other areas of concern might be identified after further review of inspection notes and documents received as part of the inspection. The preliminary areas of concern included: A review of Tribe's certified DMRs revealed chronic exceedances of permit effluent limits [Permit Part I.A] for E.coli (monthly average and daily max) and copper (monthly average and daily maximum). See Attachment D for a detailed summary of E.coli and copper effluent limit violations from November 2015 to September 2020; Two treatment wetlands have been offline for two years due to invasive grass and vines, and worms were observed in the effluent flume. Pursuant to Permit Part I.C.3 and Part II.B.1, the Tribe shall at all times properly operate and maintain all facilities and systems of treatment and control; Influent samples are collected as grab samples. Composite samples are required for BOD5, copper, and total phosphorus. [Permit Part I.B]; Effluent samples collected via 24-composite sampler must be preserved (e.g., refrigerated) in accordance with 40 CFR Part 136; Effluent composite sampler tube inlet was covered by a screen to keep worms from being drawn into the composite sampler. Pursuant to Permit Part I.A.b, representative samples shall be collected in the effluent line after the single-pass filter effluents combine; To meet the test procedure and sample preservation requirements of 40 CFR Part 136.3, the Tribe should invest in a NIST certified thermometer, install a thermometer in the Utility Garage refrigerator used as part of the self-monitoring program, and log temperatures regularly; No preventive maintenance program. [Permit Part I.C.3.d]; and The Tribe does not retain copies of the chain of custody forms for samples sent to the laboratory for analysis. Pursuant to Permit Part II.C.4, the permittee shall retain records of all monitoring information, including all calibration and maintenance records and 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, for a period of at least three years from the date of the sample, measurement, report or application. After sharing the areas of concern, I asked Mr. Buck if he had any questions. With no questions from Mr. Buck, I provided an estimated timeframe for completion of the inspection report, and we concluded the closing conference. I departed the Tribe's Utility Garage at 3:05 p.m. on October 27, 2020. V. DOCUMENTS RECEIVED AND REFERENCES Documents received during the inspection: Monthly Operation Reports (July-September, 2020). 4 Big Sand Lake/West Hertel WWTP CEI Inspection Report Specific resources included by reference: Big Sand Lake/West Hertel WWTP NPDES Permit# WI-0062847; issued by U.S. EPA; expiration date April 11, 2021. 5 Big Sand Lake/West Hertel WWTP CEI Inspection Report Attachment A: Aerial Image of the Big Sand Lake/West Hertel WWTP A-1 Big Sand Lake/West Hertel WWTP CEI Inspection Report [This page intentionally left blank] Big Sand Lake/West Hertel WWTP CEI Inspection Report Attachment B: Photo Log Big Sand Lake/West Hertel WWTP EPA Inspection October 27, 2020 All photos taken by Valerie Dooling, Inspector, U.S. EPA Camera: Ricoh WG-4 1: STWH0001 Description: Influent vault prior to first septic tank. Location: Headworks. N45 48 50, W 92 11 29 Camera Direction: 266 Date/Time: October 27, 2020; 13:49 B-1 Big Sand Lake/West Hertel WWTP CEI Inspection Report 2: STWH0002 Description: Area of septic tanks 1 and 2, and influent vault shed (small blue shed on the left of photo). Location: Headworks septic tank area. N45 48 51, W 92 11 29 Camera Direction: 345 Date/Time: October 27, 2020; 13:51 B-2 Big Sand Lake/West Hertel WWTP CEI Inspection Report 3: STWH0003 Description: Area of septic tank 3 (foreground), and diverter tank vault doors (adjacent to white vent pipes) in background. Location: Headworks septic tank area. N45 48 51, W 92 11 29 Camera Direction: 48 Date/Time: October 27, 2020; 13:51 B-3 Big Sand Lake/West Hertel WWTP CEI Inspection Report 4: STWH0004 Description: Diverter tank with diversion weirs visible. Location: Headworks septic tank area. N45 48 51, W 92 11 29 Camera Direction: 347 Date/Time: October 27, 2020; 13:53 5: STWH0005 Description: Treatment wetlands 1-3 (in order left to right). Note cattails growing in offline treatment wetlands 1 and 2. Location: Treatment wetlands area. N45 48 51, W 92 11 29 Camera Direction: 39 Date/Time: October 27, 2020; 13:54 B-4 Big Sand Lake/West Hertel WWTP CEI Inspection Report 6: STWH0006 Description: Treatment wetland 4. Location: Treatment wetlands area. N45 48 51, W 92 11 29 Camera Direction: 61 Date/Time: October 27, 2020; 13:55 7: STWH0007 Description: Treatment wetland 5. Location: Treatment wetlands area. N45 48 51, W 92 11 29 Camera Direction: 75 Date/Time: October 27, 2020; 13:55 B-5 Big Sand Lake/West Hertel WWTP CEI Inspection Report 8: STWH0008 Description: Treatment wetland 6. Location: Treatment wetlands area. N45 48 50, W 92 11 29 Camera Direction: 202 Date/Time: October 27, 2020; 13:56 B-6 Big Sand Lake/West Hertel WWTP CEI Inspection Report 9: STWH0009 Description: Effluent ISCO composite sampler. Location: Effluent shed. N45 48 48, W 92 11 33 Camera Direction: 296 Date/Time: October 27, 2020; 14:01 B-7 Big Sand Lake/West Hertel WWTP CEI Inspection Report 10: STWH0010 Description: Effluent ISCO composite sampler control panel. Location: Effluent shed. N45 48 48, W 92 11 33 Camera Direction: 232 Date/Time: October 27, 2020; 14:01 B-8 Big Sand Lake/West Hertel WWTP CEI Inspection Report 11: STWH0011 Description: Process pump control panel. Location: Effluent shed. N45 48 48, W 92 11 33 Camera Direction: 7 Date/Time: October 27, 2020; 14:02 B-9 Big Sand Lake/West Hertel WWTP CEI Inspection Report 12: STWH0012 Description: Process blower control panel. Location: Effluent shed. N45 48 48, W 92 11 33 Camera Direction: 7 Date/Time: October 27, 2020; 14:02 B-10 Big Sand Lake/West Hertel WWTP CEI Inspection Report 13: STWH0013 Description: Effluent parshall flume. Note worms along the bottom of the flume, and screen covering composite sampler tube inlet. Location: Effluent vault. N45 48 48, W 92 11 33 Camera Direction: 50 Date/Time: October 27, 2020; 14:04 B-11 Big Sand Lake/West Hertel WWTP CEI Inspection Report 14: STWH0014 Description: Diffused outlets to final effluent Outfall 001. Location: Unnamed wetland south of Rt. 70. N45 48 29, W 92 11 52 Camera Direction: 30 Date/Time: October 27, 2020; 14:15 B-12 Big Sand Lake/West Hertel WWTP CEI Inspection Report 15: STWH0015 Description: Lift station 5 vault and vent. Location: Area just north of Rt. 70 shoulder. N45 48 32, W 92 11 53 Camera Direction: 284 Date/Time: October 27, 2020; 14:20 B-13 Big Sand Lake/West Hertel WWTP CEI Inspection Report 16: STWH0016 Description: Lift station 5 backup generator and controls. Location: Area just north Rt. 70 shoulder. N45 48 32, W 92 11 53 Camera Direction: 18 Date/Time: October 27, 2020; 14:20 B-14 Big Sand Lake/West Hertel WWTP CEI Inspection Report Attachment C: Plan view flow diagram of the Big Sand Lake/West Hertel WWTP C-1 Big Sand Lake/West Hertel WWTP CEI Inspection Report [This page intentionally left blank] Big Sand Lake/West Hertel WWTP CEI Inspection Report Attachment D: Summary of effluent limit violations (11/1/2015-9/30/2020). Effluent Limit Exceedances Report WI0062847: ST. CROIX TRIBAL COUNCIL, WEBSTER, WI 54893 Monitoring Period Date Range: 11/01/2015 to 9/30/2020 Exceedance Details Monitoring Period Date 7/31/2016 7/31/2016 8/31/2016 5/31/2017 5/31/2017 6/30/2017 7/31/2017 8/31/2017 8/31/2017 9/30/2017 9/30/2017 5/31/2018 5/31/2018 6/30/2018 6/30/2018 7/31/2018 7/31/2018 7/31/2018 8/31/2018 8/31/2018 8/31/2018 9/30/2018 9/30/2018 5/31/2019 6/30/2019 6/30/2019 6/30/2019 7/31/2019 7/31/2019 5/31/2020 5/31/2020 6/30/2020 6/30/2020 7/31/2020 7/31/2020 Parameter Description Copper, total recoverable Solids, suspended % removal Copper, total recoverable Copper, total recoverable E. coli Copper, total recoverable Copper, total recoverable Copper, total recoverable E. coli Copper, total recoverable E. coli E. coli E. coli Copper, total recoverable E. coli Copper, total recoverable Copper, total recoverable E. coli Copper, total recoverable E. coli E. coli Solids, total suspended E. coli E. coli Copper, total recoverable E. coli E. coli Copper, total recoverable Copper, total recoverable E. coli E. coli Copper, total recoverable E. coli Copper, total recoverable Copper, total recoverable Limit Type DAILY MX MN % RMV DAILY MX DAILY MX MO GEO DAILY MX DAILY MX DAILY MX MO GEO DAILY MX MO GEO MO GEO DAILY MX DAILY MX DAILY MX DAILY MX MO AVG DAILY MX DAILY MX MO GEO DAILY MX WKLY AVG MO GEO DAILY MX DAILY MX MO GEO DAILY MX DAILY MX MO AVG DAILY MX MO GEO DAILY MX DAILY MX DAILY MX MO AVG DMR Value 0.078 84.04 0.077 0.371882 345.32 0.05 0.056 12.69841 400.93 9.977324 209.28 177.58 2000 0.085 740 0.091 0.0815 740 0.048 152 2000 47 131 700 0.055 170 2000 0.059 0.057 2000 1195 0.048 2000 0.054 0.0455 Limit Value Qualifier <= >= <= <= <= <= <= <= <= <= <= <= <= <= <= <= <= <= <= <= <= <= <= <= <= <= <= <= <= <= <= <= <= <= <= Limit Value 0.044 85 0.044 0.011791 126 0.044 0.044 0.011791 126 0.011791 126 126 410 0.044 410 0.044 0.044 410 0.044 126 410 30 126 410 0.044 126 410 0.044 0.044 410 126 0.044 410 0.044 0.044 Value Unit mg/L % mg/L kg/d MPN/100mL mg/L mg/L kg/d MPN/100mL kg/d MPN/100mL MPN/100mL MPN/100mL mg/L MPN/100mL mg/L mg/L MPN/100mL mg/L MPN/100mL MPN/100mL mg/L MPN/100mL MPN/100mL mg/L MPN/100mL MPN/100mL mg/L mg/L MPN/100mL MPN/100mL mg/L MPN/100mL mg/L mg/L % Exceed 77 6 75 3054 174 14 27 107592 218 84515 66 41 388 93 80 107 85 80 9 21 388 57 4 71 25 35 388 34 30 388 848 9 388 23 4 D-1