Document gDKOBOag145YxV3yzKD5DENKJ

NPDES Compliance Inspection Report City of Wapato Wastewater Treatment Plant Wapato, WA NPDES Permit # WA0050229 Inspection Date: June 18, 2024 Prepared by: Rick Cool U.S. Environmental Protection Agency, Region 10 Enforcement & Compliance Assurance Division Water Enforcement & Field Branch Surface Water Enforcement Section Inspector Signature/Date: RICHARD COOL Digitally signed by RICHARD COOL Date: 2024.08.08 16:13:01 -07'00' Supervisor Signature/Date: Marshalonis, Daniel (Dino) Date: 2024.08.08 17:54:48 -07'00' Digitally signed by Marshalonis, Daniel (Dino) City of Wapato Wastewater Treatment Plant NPDES # WA0050229 Contents I. Facility Information ............................................................................................................ 3 II. Inspection Information........................................................................................................ 3 III. Permit Information.............................................................................................................. 4 IV. Background ...........................................................................................4 V. Inspection Chronology........................................................................................................ 5 VI. Opening Conference ........................................................................................................... 6 VII. Site Tour ........................................................................................................................... 7 VIII. File Review ... .................................................................................................................... 8 IX. Areas of Concern ................................................................................................................ 9 X. Closing Conference........................................................................................................... 19 Attachment A - Facility Aerial & Process Schematics .................................................................... Attachment B - Photograph Log ...................................................................................................... Attachment C - EPA ICIS Violations Report............................................................... Attachment D - DOI Geological Survey Rating Table.................................................... Attachment E - Anatek Labs, Inc. December 2023 Lab Report Excerpt (PFAS)...................... 2 City of Wapato Wastewater Treatment Plant NPDES # WA0050229 (Unless otherwise noted, all details in this inspection report were obtained from conversations and communications (e.g., emails, submissions, etc.) with Amber Musgrave, Wastewater Treatment Plant Lead Operator, and Jeff Schumacker, Public Works Director, and from reviews of documents and direct inspection observations) I. Facility Information Facility Name: City of Wapato Wastewater Treatment Plant (Facility) Facility Owner/Operator: City of Wapato, Washington Physical Address: 68170 U.S. Highway 97 Wapato, WA 98951 Lat/Long: Mailing Address: 46.434326, -120.422001 205 East 3rd Street Wapato, WA 98951-1326 Facility Contacts: Jeff Schumacker, Public Works Director (m) (509) 853-8013 Email: jschumacker@wapato-city.org Amber Musgrave, Lead Operator (o) (509) 877-3031 Email: amusgrave@wapato-city.org Permit Number: WA0050229 Receiving Water: Drainage Way #2 Wanity Slough Yakima River II. Inspection Information Inspection Date: June 18, 2024 Inspectors: Rick Cool, Nicolas Haddad Arrival Time: 8:45 a.m. Departure Time: Approximately 1:45 p.m. Weather: Sunny, hot 3 Purpose: City of Wapato Wastewater Treatment Plant NPDES # WA0050229 To evaluate and determine Facility compliance with the National Pollutant Discharge Elimination System (NPDES) Permit No. WA0050229 and the Clean Water Act (CWA). III. Permit Information The Facility is permitted under NPDES Permit No. WA0050229 (herein, 2023 Permit) that was issued, as modified, in September 2023 and effective on October 1, 2023. This current permit and the discharge authorization will expire at midnight, September 30, 2028. The Facility's prior NPDES permit was issued on September 15, 2011 (herein, 2011 Permit) and it became effective on November 1, 2011. The 2011 Permit expired on October 31, 2016 but it was administratively extended until issuance of the 2023 Permit's effective date. As noted below, the City of Wapato and EPA entered into a consent agreement and final order (i.e., CAFO Docket No. CWA-10-2021-0126) and an administrative order on consent (i.e., AOC Docket No. CWA-10-2021-0125) for past violations associated with the 2011 Permit, including effluent limitation violations that occurred through February 2020. Accordingly, the scope of this June 18, 2024 EPA inspection included the period of time since March 1, 2020, including discharge monitoring reports submitted by the City of Wapato through April 2024 and related matters up through the inspection date, June 18, 2024. IV. Background According to the EPA's 2023 Permit-related 2022 Fact Sheet, the City of Wapato owns and operates the Facility located in Wapato, Washington. The Facility's sanitary sewage collection system has no combined sewers. The Facility serves a resident population of 5,058. The Facility receives domestic wastewater from commercial and residential sources and also receives industrial wastewater from three local fruit packing plants. The EPA 2022 Fact Sheet notes the Facility design flow is 1.16 million gallons per day (mgd) and the reported actual flows between April 2017 and February 2022 ranged from 0.436 to 0.922 mgd (average monthly flow). The EPA 2022 Fact Sheet notes in late 2015, the Facility upgraded to a Membrane Bio-Reactor (MBR) system for secondary treatment. The MBR system uses a combination of a suspended growth biological treatment method, and membrane filtration. In addition, the Facility uses ultraviolet (UV) disinfection. The Facility Outfall 001 discharges into Wapato Irrigation Project (WIP) Drainage Way No. 2. The WIP Drainage Way No. 2 drains into Wanity Slough, which empties into the Yakima River. The Facility discharges to the Yakama Nation's tribal waters. 4 City of Wapato Wastewater Treatment Plant NPDES # WA0050229 Attachment A of this inspection report includes an aerial photo (map) of the Facility showing the layout of the Facility and identifying locations of major Facility treatment units and installations. Attachment A also includes a schematic of the Facility's wastewater treatment process/flow and a schematic of the Facility's sludge flow process. The Attachment A map and schematics were included in the EPA's 2022 Fact Sheet as Figures 3-5. The Facility was last inspected by EPA on October 27, 2019. The Facility was subject to two formal compliance enforcement actions after the 2019 inspection. In 2021, EPA and the City of Wapato entered into a consent agreement and final order (i.e., CAFO Docket No. CWA-10-2021-0126) for primarily past effluent limitation violations (e.g., ammonia, zinc, copper) where the City agreed to pay a penalty of $25,750. The City also agreed, with EPA, to an administrative order on consent (i.e., AOC Docket No. CWA10-2021-0125) requiring the Facility to undertake corrective actions related primarily to implementation of engineering solutions and anticipated Facility upgrades to address the chronic metals-related effluent limitation violations. V. Inspection Chronology This was an announced inspection. On May 28, 2024, I emailed Elizabeth Sanchey and Will Badonie, Yakama Nation's Environmental Program, regarding the EPA's proposed June 2024 compliance evaluation inspection and the Yakama Nation's potential participation. In subsequent communications with Blythe Delarosa, I received confirmation of tribal interest and intent to participate in any scheduled Facility inspection. On June 10, 2024, I emailed Mr. Schumacker and Ms. Musgrave with my introduction and proposed compliance evaluation inspection project, and during a subsequent call, agreement was reached on EPA conducting the Facility inspection on Tuesday, June 18, with an anticipated 9:00 a.m. start time. We (Nicolas Haddad and me) arrived at the Facility at about 8:45 a.m. We entered the Facility office and introduced ourselves to Ms. Musgrave, Mr. Schumacker and Ms. Susan Welland, a Wastewater Plant Specialist, Gray & Osborne, Inc. (consulting engineers). EPA credentials were presented to the Facility representatives and I provided the Facility staff with a copy of EPA's small business information fact sheet. Shortly after our arrival, Wil Badonie and Joe Herrera, Yakama Nation Environmental Program inspectors, arrived and made introductions. Mr. Badonie and Mr. Herrera participated in the entire inspection. The EPA inspectors were accompanied by Facility representatives and the Yakama Nation inspectors during the entire inspection. EPA inspectors were not denied access to any part of the Facility during the inspection. 5 City of Wapato Wastewater Treatment Plant NPDES # WA0050229 During the inspection, I conducted an opening conference followed by a cursory records review, then a Facility tour/walk-around and finally, a closing conference. Post-inspection, the Facility provided some additional records and sampling documentation which I reviewed upon receipt. VI. Opening Conference After an initial routine opening conference discussion of inspection scope, logistics, and related miscellaneous inspection information, I used a question-and-answer format to learn about the Facility's staffing and recent operations. The Facility currently employes three certified operators. The Facility is attended to seven days a week and generally four-10 hour days with an operator on-site on Friday - Sunday, 2 hours per day. The four 10-hour days are generally 6:00 a.m. to 4:30 or 5:00 p.m. depending on length of the lunch period. At the time of the June 2024 inspection, the primary clarifier had an inoperable skimmer arm due to a gear drive failure but the clarifier settling solids and removal capability was still functional. The grinder that was out of service at the time of the EPA's 2019 inspection and the source of an EPA area-of-concern then has been deemed to not be needed and it has been abandoned. I asked about the cause of the April 2024 discharge monitoring report's (DMR) data entries about the effluent limitation exceedances for Total Ammonia as N. The 2023 Permit requires the Facility to monitor this ammonia pollutant parameter once-per-week. Facility representatives did not have any explanation as to limit exceedances and cause(s) of the following April 2024 DMR entries for the Total Ammonia as N concentration and loading requirements: Limit Type Monthly Avg Daily Max Monthly Avg Daily Max 2023 Permit Limit 0.7 mg/L 2.6 mg/L 7.0 lbs/day 25.0 lbs/day DMR Value 15.9 mg/L 17.1 mg/L 72.5 lbs/day 87.7 lbs/day % Exceedance 2,171 558 936 251 The City has not experienced any sanitary sewer overflows since the 2019 EPA inspection's inquiry about existence of overflows that pre-existed that 2019 inspection. Facility influent and effluent flows are measured using electromagnetic flow meters (i.e., magmeters). The EPA 2019 inspection report indicated the magmeters were inspected and calibrated bi-annually but in response to my questions about the frequency of magmeter calibration, Facility staff indicated the magmeters had never been calibrated. Drainage Way No. 2 upstream flow measurements are taken upstream of the Facility Outfall 001 near the footbridge. The drainage way upstream flow is measured manually using a graduated gage (i.e., marked points on a visual scale) attached to a steel fence post that is driven into and anchored into the drainage way bank. See Photo 7 in Attachment B, Photograph Log, of this inspection report for a photo of the gage/fence post on the bank located near the footbridge. 6 City of Wapato Wastewater Treatment Plant NPDES # WA0050229 The gage scale observation is then compared to and evaluated against an existing calibrated drainage way gage height chart (which chart apparently takes into account the physical dimensions of the Drainage Way No. 2 at the Facility location). A copy of the gage height chart was provided to the EPA inspectors and is included with this inspection report as Attachment D. The chart is identified as a U.S. Department of Interior (DOI) Geological Survey rating table for "Drain 2 Wapato Sanitation Outlet" (dated March 14, 1988). The chart includes a gage height measurement x-and-y axis table and an associated "second-foot" entry (i.e., cubic feet per second) that can then be calculated to determine upstream drainage way flow in million-gallonsper-24-hours once the flow depth measurement is evaluated using the table/chart. Facility effluent and influent 24-hour composite sampling is conducted with refrigerated Sigma and ISCO auto-samplers collecting, on a time proportioned basis, approximately 20 milliliters per sample into a 5-gallon jug over a 24-hour period. The final sample for analysis is drawn from each of the sampler's time-composited 5-gallon jug sample. Receiving water pollutant parameter sampling of the Drainage Way No. 2 is done by grab samples. The Facility is currently not conducting 24-hour composite sampling of the receiving water but is instead obtaining one receiving water grab sample upstream and one receiving water grab sample downstream of the Facility's Outfall 001. Receiving water temperatures are being taken Monday-Friday, usually in the mornings. Facility sludge is picked up and transported to a regional collection-composting facility in Sunrise, Washington. Under the 2021 AOC, the City, through Gray & Osborne, Inc. (consulting engineers), submitted a Wastewater Facility Plan Amendment (G&O #23809, October 2023) to EPA that outlined a wastewater treatment facility (WWTF) metals compliance study schedule as means to achieve compliance with the Facility's NPDES permit effluent metals limits. The October 2023 Amendment's anticipated project schedule indicated that follow-up testing (including pilot studies) would be conducted during October - December 2023 (p. 1-2) with completion of the pilot tests targeted for January 2024 (pp. 5-7 through 5-8). When I asked about the status of the pilot studies during the inspection, Facility representatives indicated the metal removal pilot study/testing is still ongoing as of this EPA June 2024 inspection. VII. Site Tour We did a site tour/walk-around where EPA inspectors examined and made observations of all major on-site physical components of the Facility, including all areas where effluent is treated and conveyed. Attachment B, Photograph Log, of this inspection report includes the photos identified below taken during the inspection. Site tour areas included the following: Headworks (Photo 1); Rotary drum screens (Photo 2); 7 City of Wapato Wastewater Treatment Plant NPDES # WA0050229 Influent sampling point and auto-sampler; Primary clarifier (Photo 3); Anoxic selector tanks; MBR's pre-aeration basins (Photo 5); UV disinfection units (Photo 6); Sludge digestors; Sludge drying beds and dried sludge storage area (Photo 4); Drainage Way No. 2 upstream sampling/flow measurement location (Photo 7); and Effluent auto-sampler (Photo 8). VIII. File Review I reviewed the following records and documents as part of the total inspection process: NPDES Permit No. WA0050229 (the 2023 Permit). The Facility had a copy of the 2023 Permit available on-site. NPDES Permit No. WA0050229 (the 2011 Permit). As noted previously, the scope of this current EPA inspection included time periods covered by the prior NPDES permit (i.e., the 2011 Permit) going back to March 1, 2020. Discharge Monitoring Reports (DMRs). EPA Integrated Compliance Information System (ICIS) generated monthly DMR data pulls, including electronic DMRs, for March 2020 through May 2024. Note: the Facility's actual May 2024 DMR data was not yet ICIS-available at the June 10, 2024 date of the ICIS data pull. EPA-Generated Violations Report & NCEP Report. ICIS-generated Violations Report and a National Compliance Evaluation Program (NCEP) Report for the time period of March 1, 2020 through May 31, 2024. Note: the Facility's actual May 2024 DMR data was not yet ICIS-available at the June 10, 2024 date of the ICIS data pull. See Attachment C of this inspection report for the Violations Report. Quality Assurance Plan (QAP). The Facility had available the latest QAP edition, June 2022. Operation and Maintenance Plan (O&M Plan). Both the 2011 and 2023 Permits require an O&M Plan. The Facility provided EPA with a copy of the O&M Plan prepared by Gray & Osborne, Inc. (consulting engineers), dated December 2016 for EPA's confirmation of the O&M Plan's existence and availability at the Facility. Whole Effluent Toxicity (WET) Reports. For WET reports, I reviewed EPA records for available WET reports back to the date of the 2019 EPA inspection (August 27, 2019) and post-inspection, other WET reports submitted by the Facility in July 2024, based on this inspector's request for additional documentation of WET sampling/lab results and 8 City of Wapato Wastewater Treatment Plant NPDES # WA0050229 reports. The EPA inspector request was made during the June 18, 2024 inspection for anything WET report related generally available back to the 2019 inspection time period. Selected monthly sampling data documentation. I conducted a cursory review of some analytical data and calculation sheets used to document Facility laboratory and commercial lab results for the preparation of DMRs. Selected calibration records for the Facility pH meter and dissolved oxygen meter. PFAS 2023 Sampling Data. During the inspection, EPA requested copies of any PFAS sampling data done to date since issuance of the 2023 Permit. The Facility provided a copy of pages 1-2 of an apparent 6-page lab report (reported December 28, 2023) from Anatek Labs, Inc. for a single Facility PFAS sample taken December 6, 2023 analyzed using a drinking water matrix. The two-page excerpt of the Anatek Labs, Inc. 6-page report for the single Facility PFAS sample only is included as Attachment E to this inspection report. 2023 Permit Notifications to EPA. The 2023 Permit requires the Facility to provide written notification that an O&M Plan has been developed and is being implemented and that a QAP has been developed and is being implemented. The Facility was able to produce the U.S. Postal Service green-colored receipt return cards for the submissions of these two notifications apparently mailed to EPA. However, this inspection report includes an area-of-concern that the existing June 2022 QAP that was in effect when the Facility notified EPA of a QAP having been developed and being implemented is an outdated QAP that is not accurately reflective of the 2023 Permit requirements. IX. Areas of Concern A. Effluent Limit Exceedances The 2011 Permit, Part I.B., states in part: "The permittee must limit and monitor discharges from outfall 001 as specified below. All figures represent maximum effluent limits unless otherwise indicated. 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 the permit." Table 1 of Part I.B. shows the effluent limits and monitoring requirements for all identified monitored parameters listed therein. The 2023 Permit, Part I.B., also states in part: "The permittee must limit and monitor discharges from Outfall 001 as specified in the Table below. All figures represent maximum effluent limits unless otherwise indicated. 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 the permit." Table 1 of Part I.B. shows the effluent limits and monitoring requirements for all identified monitored parameters listed therein. 9 City of Wapato Wastewater Treatment Plant NPDES # WA0050229 As part of this inspection, I reviewed ICIS-generated DMRs from March 2020 through April 2024. The DMR results including numerous effluent limit exceedances during this time period are summarized in the Violations Report, Attachment C to this inspection report, which attachment is incorporated herein by reference. Please note, the Violations Report characterizes effluent limit exceedances as effluent violations using a violation code E90. The area-of-concern is that the Facility is regularly exceeding NPDES permit effluent limits for multiple parameters. Some DMR non-exceedance limit data anomalies discussed in another area-of-concern below. B. April 2024 Ammonia-as-N Effluent Limit Exceedances The 2023 Permit, Part I.B., Table 1, has more restrictive Total Ammonia-as-N effluent limits for the Facility's Outfall 001 discharge for the period from April 1 through October 31. Table 1 requires the Facility to monitor effluent for Total Ammonia-as-N once-per week, using a 24-hour composite sample. As noted above, the Facility's April 2024 DMR included the following DMR value entries for this pollutant parameter: Limit Type Monthly Avg Daily Max Monthly Avg Daily Max 2023 Permit Limit 0.7 mg/L 2.6 mg/L 7.0 lbs/day 25.0 lbs/day DMR Value 15.9 mg/L 17.1 mg/L 72.5 lbs/day 87.7 lbs/day % Exceedance 2,171 558 936 251 I highlight these particular effluent limits exceedances in part because ammonia-as-N limit exceedances do not appear to have occurred since the August - October 2015 time period listed in the 2021 CAFO so these April 2024 exceedances portend some potential new issues of concern with Facility operations. Additionally, Facility representatives did not have any explanation as to the cause(s) of these ammonia-as-N exceedances when asked about them during the June 2024 inspection. C. Flow Proportional 24-Hour Composite Sampling Protocol The 2023 Permit, Part VII., Definitions, Item No. 35, defines "24-hour composite" as follows: "24-hour composite" sample means a combination of at least 8 discrete sample aliquots of at least 100 milliliters, collected over periodic intervals from the same location, during the operating hours of a facility over a 24 hour period. The composite must be flow proportional. The sample aliquots must be collected and stored in accordance with procedures prescribed in 40 CFR 136. (italics added for emphasis). The Facility is not conducting flow proportional 24-hour composite sampling in accord with the 2023 Permit sampling requirements. The evidence indicates the Facility is using a time-proportional 24-hour sampling method. For example, Facility effluent and influent 24-hour composite sampling is conducted with refrigerated Sigma and ISCO auto-samplers collecting, on a time proportioned basis, approximately 20 milliliters per 10 City of Wapato Wastewater Treatment Plant NPDES # WA0050229 sample into a 5-gallon jug over a 24-hour period. The final Facility sample for laboratory analysis is drawn from each of the auto-sampler's time-composited 5-gallon jug sample. D. No 24-hour Composite Sampling of Required Receiving Waters Samples The 2023 Permit, Part I.D, Receiving Water Monitoring, requires monitoring in the WIP Drainage Way No. 2 in accord with the Part I.D. Table 5, which requires a 24-hour composite sample type for the following four (4) pollutant parameters: pH, hardness as CaCO3, Total Phosphorus and Total Nitrogen. The 2023 Permit, Part VII, Definitions, states in relevant part that the 24-hour composite sample must be flow proportional. The Facility has not installed the sampler equipment and supporting infrastructure capability to conduct automated 24-hour flow-proportional composite sampling of the Drainage Way No. 2 upstream and downstream of the Facility Outfall 001. At this time, the Facility is still using the grab sample type to sample and monitor for these four pollutant parameters from the drainage way. E. Flow Measurement of Receiving Waters The 2023 Permit, Part I.D, Receiving Water Monitoring, requires monitoring in the WIP Drainage Way No. 2 in accord with the Part I.D. Table 5, which requires a "meter" sample type for the flow parameter, once-per-week upstream and downstream of the Facility's Outfall 001. At the time of the inspection, the Facility had not installed a stationary flow meter(s) or metering equipment and supporting infrastructure capability to conduct a meter sample type of the Drainage Way No. 2 flow upstream near the footbridge and downstream of the Facility Outfall 001. At the time of the inspection, the Facility measured drainage way upstream flow manually using a graduated gage (i.e., marked points on a visual scale) attached to a steel fence post that is driven into and anchored into the drainage way bank. See Photo 7 in Attachment B, Photograph Log, of this inspection report for a photo of the gage/fence post located near the footbridge. The Facility staff's visual observation of the drainage way flow depth on the gage (visual scale) is then evaluated using a 1988 DOI Geological Survey gage height chart/rating table to convert the visual observation of the drainage flow depth on the gage scale to an estimated upstream flow rate for the Drainage Way No. 2 at that upstream-of-the-Outfall location. An additional area of concern (in addition to the lack of a meter sample type requirement discussed above) is that the gage/steel fence post location in the drainage way bank does not appear to be located to easily and accurately evaluate low flows within the drainage way with the potential for vegetative growth (e.g., bank grasses) to obscure some lower portions of the gage/steel fence post. It appears some maintenance may be needed around the gage/steel fence post on a periodic basis to ensure visual observations of the 11 City of Wapato Wastewater Treatment Plant NPDES # WA0050229 drainage way water level on the gage scale can be done efficiently, safely and without any obscured view of the gage scale. Note also, during post-inspection information exchanges, Facility staff apprised this inspector on August 7, 2024 that to confirm the flow estimate results using the graduated scale gage, the Facility bought a Global Water Instrumentation portable flow probe (Model FP211) that has an expandable probe rod, ranging in length from 5.5 feet to 14 feet. The web-available Global Water 2009 User's Manual description for this Model FP211 states, in part, the flow probe is a velocity instrument for measuring flows in open channels and partially filled pipes and that the water velocity probe consists of a protected propeller and water bearing for measuring water velocity, coupled to a telescoping probe handle ending with a LCD display flow computer. F. Temperature Sampling of Receiving Waters The 2023 Permit, Part I.D, Receiving Water Monitoring, requires temperature monitoring in the WIP Drainage Way No. 2, upstream and downstream of the Facility Outfall 001, five-times-per-week in accord with the Part I.D. Table 5, Footnote No. 1 which states: "Sampling must occur Monday through Friday, once a day between April 1 and October 31. Sampling must occur between 5pm and 6pm." The evidence, including Facility employee hours of routine Facility attendance, indicates the Facility is not conducting Drainage Way temperature monitoring routinely during the 5:00 pm - 6:00 pm Permit-required time period, and that the receiving water temperature monitoring is usually conducted in the mornings. G. Weekly Visual Observations of Receiving Waters & Observation Log The 2023 Permit, Part I.B.2.b. includes a specific weekly visual observation requirement and related record keeping regarding the subpart 2.a. narrative limitation on the nodischarge requirement regarding floating, suspended or submerge matter of any kind in concentrations causing nuisance or objectionable conditions or that may impair designated uses of the receiving waters. Part I.B.2.b. states: "The permittee must observe the surface of the receiving water weekly in the vicinity of where the effluent enters the surface water. The permittee must maintain a written log of the observation which includes the date, time, observer, and 12 City of Wapato Wastewater Treatment Plant NPDES # WA0050229 whether there is the presence of floating, suspended, or submerged matter. The log must be retained and made available to EPA or the Yakama Nation upon request." The EPA requested to view a copy of this written observation log during the records review part of the inspection. The Facility was not able to produce the observation log because a written log of receiving water observations is not being created and retained. H. DMR Submission of Receiving Water Monitoring Results The 2023 Permit, Part I.D.8.a. states: Receiving water monitoring results must be reported on the monthly DMR. The Facility's DMRs do not contain and include the Drainage Way No. 2 monitoring results and the Facility is not routinely submitting the receiving waters monitoring results on a monthly basis to EPA using any other form for submission. I. DMR Coding & Entries The 2011 Permit, Part III.B., requires the permittee to summarize all monthly monitoring results on the DMR. The 2011 Permit, Part X.E. provides that reports (e.g., DMRs) must be signed and certified which certification (Part X.E.4.) provides the report is certified as "true, accurate, and complete." For context, the EPA's 2022 Fact Sheet reported that after the 2011 Permit was issued, the Facility's chlorine disinfection system was replaced with ultraviolet disinfection and that there is no longer a source of chlorine in the Facility's discharge. The EPA's 2019 inspection report states the Facility ceased using chlorine as a disinfectant in November 2015. The Facility's DMRs for March - August 2020 use a NODI-8 entry (i.e., Other - see comments) for total residual chlorine (TRC) entries, and each of the DMRs includes the following comment in the DMR Comment section: No chlorine in use . . . UV disinfection only. Beginning in September 2020 and through September 2023, the Facility's DMR entries for TRC was NODI-B (Below Detection Limit/No Detection) which was not a correct entry because the Facility continued to use only UV disinfection and no sampling for TRC was occurring because the Facility was not using chlorine for disinfection. This same/similar coding error was raised to the Facility's attention as an area-of-concern in the EPA 2019 inspection report. At that time and in regard to the DMR's TRC entries, the Facility was apprised to use NODI-9 (Conditional Monitoring - Not Required for this Period). The NODI-9 entry should have been used for the September 2020 - September 2023 DMRs when TRC was not being used in the Facility or sampled for. J. DMR Entry Computations & DMR Entries As part of this inspector's evaluation of Facility zinc/copper DMR anomalies (see related area-of-concern below), I requested the Facility to provide all of the lab reports for 13 City of Wapato Wastewater Treatment Plant NPDES # WA0050229 applicable weekly and/or monthly samples for the three months of May-June 2023 and October 2023. Facility submissions were made post-inspection in response to this inspector request and the submissions were reviewed. As background, the 2011 Permit, Part I.B., Table 1, has a total recoverable zinc average monthly concentration limit of 25 g/L and a maximum daily concentration limit of 52 g/L The Facility's internal May 2023 sample computation worksheet indicated that the four weekly copper sample results were all non-detect, and that 3 of 4 weekly zinc sample results were non-detect but that the May 2, 2023 weekly zinc sample result was reported from the lab report as 182 g/L. The corresponding LabTest lab report (reported May 11, 2023) confirmed the May 2 zinc sample result was 0.182 mg/L or 182 g/L. However, the Facility's May 2023 DMR included a NODI-B entry (i.e., Below Detection Limit/No Detection) for all DMR zinc concentration and loading entries, including a NODI-B for the May 2023 DMR maximum daily limit entry. K. Whole Effluent Toxicity (WET) Tests & DMR Data Entries or Lack Of The 2011 Permit, Part I.B., Table 1, Footnote 5, requires the Facility to sample and conduct WET testing quarterly. During a pre-inspection record review of available EPA ICIS/DMR data indicated that no WET testing was done and reported in Facility DMRs from a period after October 2018 through September 2023, except for a WET test result in the November 2021 DMR. Based on a DMR data pull for the March, 2020 - September, 2023 time period, the DMRs had a NODI-9 entry (i.e., Conditional Monitoring; Not Required This Period.) despite the fact that the 2011 Permit required quarterly WET testing. Post-inspection, the Facility sent this inspector a box of WET lab reports, mercury sampling information and other Facility DMR related monthly computation worksheets that I reviewed and are the basis for the following areas-of-concerns regarding WET testing and related DMR reporting. The Facility did not provide WET lab reports for the following six (6) calendar quarters: Q2 2019; Q1 2020; Q3 2020; Q2 2021; Q1 2023; and Q3 2023. The lack of WET lab reports for these 6 calendar quarters, in combination with the Facility's NODI-9 entries for the same 6 calendar quarters indicates the Facility failed to conduct WET testing during those 6 calendar quarters. The Facility's box of WET lab reports included WET lab reports for the following nine (9) calendar quarters during my target time period of March 2020 through September 2023: Q2 2020; Q4 2020; Q1 2021; Q3 2021; Q1 - Q4 2022; and Q2 2023. The existence of these 9 WET lab reports indicates the Facility's DMR NODI-9 entries were not accurate or correct and that the Facility failed to file accurate and complete DMRs regarding WET sampling and testing. 14 City of Wapato Wastewater Treatment Plant NPDES # WA0050229 L. Total Recoverable Mercury Sampling and DMR Entries The 2011 Permit, Part I.B., Table 1, Footnote 6 requires the Facility to sample for total recoverable mercury on a calendar quarterly frequency after the first year of the 2011 Permit. During a pre-inspection record review of available EPA ICIS/DMR data indicated that no mercury testing was done and reported in Facility DMRs for three calendar quarters: April - June 2021; January - March 2022; and April - June 2023. Each DMR mercury entry for these 3 calendar quarters specified NODI-9 (i.e., Conditional Monitoring - Not Required This Period). Post-inspection, I reviewed and evaluated the Facility's box containing mercury-related documentation and this review/evaluation is the basis for the following areas-of-concern. The Facility box submission did not include any sample results lab reports for mercury sampling for the calendar quarter January - March 2022. The combination of the Facility's DMR NODI-9 entry and lack of any confirming documentation indicates the Facility failed to conduct required mercury monitoring for this calender quarter. In the Facility box submission, I found documentation indicating mercury samples were taken with reportable lab results for the April-June 2021 and April-June 2023 calendar quarters. The existence of these two calendar quarters of reportable mercury sampling results indicates the Facility's DMR NODI-9 entries were not accurate or correct and that the Facility failed to file accurate and complete DMRs regarding mercury sampling. M. PFAS Sampling The 2023 Permit, Part I.B., Table 1, requires the Facility to sample and report sampling results for Per- and Polyfluoroalkyl Substances (PFAS) for PFAS in the Facility influent, effluent and sludge on a frequency of twice-per-year. The 2023 Permit, Part I.B.11, requires potential PFAS sampling of discharges of industrial dischargers if any PFAS is detected in the Facility's influent, effluent or sludge sampling completed by three years after the effective date of the 2023 Permit. During the inspection's opening conference, EPA asked whether the Facility had conducting any PFAS sampling to date and if so, what were the results. In response to this inquiry, the Facility provided a copy of pages 1-2 of an apparent 6-page lab report (reported December 28, 2023) from Anatek Labs, Inc. for a single Facility PFAS sample taken December 6, 2023 analyzed using a drinking water matrix. It is not readily apparent from this 2-page lab report excerpt whether the Facility's December 6, 2023 PFAS sample was of the Facility influent or the effluent. The two-page excerpt of the Anatek Labs, Inc. 6-page report for the single Facility PFAS sample only is included as Attachment E to this inspection report. The areas-of-concern is that the Facility must implement PFAS sampling/testing of all three potential sources of PFAS presence - i.e., Facility influent, effluent and sludge and 15 City of Wapato Wastewater Treatment Plant NPDES # WA0050229 do this 3-source sampling at least twice-per-year since the October 1, 2023 effective date of the 2023 Permit. N. Emergency Response and Public Notification Plan The 2011 Permit, Part II.D., requires the Facility to develop and implement an overflow emergency response and public notification plan (herein ERP). The City was required to submit a written notice to EPA and the Yakama Nation that an ERP had been developed and was implemented within six months of the effective date of the 2011 Permit (effective date: November 1, 2011). The 2023 Permit, Part II.F., requires the Facility to develop and implement the same type of ERP as required in the 2011 Permit. Additionally, the City was required to submit a written notice to EPA and the Yakama Nation that an ERP had been developed and was implemented within 180 days of the effective date of the 2023 Permit (effective date: October 1, 2023). During the inspection's record review, EPA requested to review a copy of the Facility ERP. Pre-inspection review indicated EPA had not received any written notification of the ERP's existence or implementation. During the inspection, Facility representatives confirmed there was no existing ERP. O. June 2022 Quality Assurance Plan (QAP) The 2023 Permit, Part II.C., states in part: "The permittee must develop a quality assurance plan (QAP) for all monitoring required by this permit." (italics added for emphasis). Facility representatives acknowledged their current June 2022 QAP is their only QAP. A cursory review of the June 2022 QAP demonstrates it has not been revised, updated or modified to conform to the 2023 Permit's monitoring requirements. In fact, the June 2022 QAP's signature page (all three signatures dated June 9, 2022) has a revision date of June 2, 2022, approximately 25 days prior to the EPA's issuance of the 2022 Fact Sheet on or about June 27, 2022. The June 2022 QAP pre-dates even the draft permit that EPA initially public-noticed in June 2022 and as a consequence, this existing QAP does not accurately reflect the 2023 Permit monitoring requirements. P. June 2022 Quality Assurance Plan (QAP) The 2011 Permit, Part II.B.3.c), required the QAP to include qualification and training of Facility personnel. The Facility's June 2022 QAP, Section 1.5, stated that initial training for new operators on sampling and analytical methods and QA/QC requirements and procedures will be conducted on a priority basis; that additional training is conducted periodically (two days per year) as required to maintain competence in analytical skills; and that records of all training are kept in each trainee's personnel folder. 16 City of Wapato Wastewater Treatment Plant NPDES # WA0050229 During the inspection's record review, EPA requested to see copies of the annual QAP, Section 1.5 training records for 2022 through 2024 to date. Facility representatives acknowledged formal QAP-based annual training was not conducted and no QAP-related training records existed or were produced for EPA review. Q. Twenty-Four Hour Notice Noncompliance Reporting & 5-Day Report The 2011 Permit, Part I.B.4. states: "The permittee must report within 24 hours any violation of the maximum daily limits for the following pollutants: E. coli bacteria, total residual chlorine, total ammonia, total recoverable copper and total recoverable zinc. Violations of all other effluent limits are to be reported at the time that discharge monitoring reports are submitted (See III.B. and III.H.)." The 2011 Permit, Part III.G.1.d), Twenty-four Notice of Noncompliance Reporting, requires the permittee to report violations of the maximum daily discharge limitations for applicable pollutants identified by Part I.B.2. within 24 hours from the time the permittee becomes aware of the circumstances and under Part III.G.2., the permittee must also provide a written submission addressing all of the informational requirements in Part III.G.2.a) through 2.e) for these applicable violations of the maximum daily discharge limits. The 2023 Permit, Part I.B.5. states: "The permittee must report within 24 hours any violation of the maximum daily limits for the following pollutants: E.coli, ammonia and zinc. Violations of all other effluent limits are to be reported at the time that discharge monitoring reports are submitted. (See Permit Parts III.B Reporting of Monitoring Results and III.G Twenty-four Hour Notice of Noncompliance Reporting of this permit." The 2023 Permit, Part III. G.1.d), Twenty-four Hour Notice of Noncompliance Reporting, requires the permittee to report violations of the maximum daily discharge limitations for applicable pollutants identified by the 2023 Permit, Part I.B., within 24 hours from the time the permittee becomes aware of the circumstances and under Part III.G.2., the permittee must also provide a written submission addressing all of the informational requirements in Part III.G.2.a) through 2.e) for these applicable violations of the maximum daily discharge limits. I reviewed the Surface Water Enforcement Section (SWES) NPDES 24-hour Noncompliance Hotline inventory going back through 2019 and I did not identify any entries associated with the Wapato Facility calling in any maximum daily limit exceedances. Additionally, I reviewed the EPA ICIS_Reports folders in the EPA Region 10 N drive and could not locate any Wapato Facility 5-day written reports submitted in accordance with the Part III.G.2. of either the 2011 or 2023 Permits. The EPA Violations Report (Attachment C) shows routine maximum daily limitation exceedances of the total zinc limit going back to March 2020, exceedances of the total copper maximum daily limitation during the months of December 2022 and September 17 City of Wapato Wastewater Treatment Plant NPDES # WA0050229 2023, and a very significant total ammonia-as-N maximum daily limit exceedance (both concentration and loading limits) in April 2024. The area-of-concern is that the Facility is not making the 24-hour noncompliance notification and submitting the required follow-up 5-day written report in accordance with its NPDES permit requirements. R. Other Noncompliance Reporting The 2011 Permit, Part III.H., Other Noncompliance Reporting, states: "The permittee must report all instances of noncompliance, not required to be reported within 24 hours, at the time that monitoring reports for Part III.B. ("Reporting of Monitoring Results") are submitted. The reports must contain the information list in Part III.G.2 of this permit ("Twenty-four Notice of Noncompliance Reporting")." The 2023 Permit, Part III.H., Other Noncompliance Reporting, states the permittee must report all instances of noncompliance, not required to be reported within 24 hours, at the time that monitoring reports for Permit Part III.BIII.A. [sic], Reporting of Monitoring Results are submitted, and that these reports must contain the information listed in the Permit, Part III.G Twenty-four Hour Notice of Noncompliance Reporting. This Part III.H. also contains more specific reporting requirements for noncompliance events associated with combined sewer overflows, sanitary sewer overflows or bypass events. I reviewed the ICIS-Reports folder in the EPA Region 10 N drive and the Facility's DMR Comment section and routinely, I could not locate any additional Facility noncompliance reporting for other violations, including non-maximum daily limit violations (e.g., monthly average exceedances), that should have been made and submitted under these 2011 and 2023 Permit provisions. S. 2023 & 2024 Zinc and Copper DMR Entry Anomalies During pre-inspection preparation and as I was reviewing historical DMRs, I identified a peculiar deviation related to a pattern of NODI-B (i.e., below detection limit/no detection) DMR entries for zinc and copper limit results in 2023 and 2024. Given this Facility's historical issues with metals limits exceedances, the apparent sudden pattern of NODI-B entries appeared to be an anomaly which is summarized in the table below. Month/Year Zinc Copper* 2011 Permit required weekly samples for both metals. May 2023 X X June 2023 X X July 2023 X X Aug 2023 X X Sept 2023 Oct. 1 2023 Permit required weekly zinc & monthly copper 18 Month/Year City of Wapato Wastewater Treatment Plant NPDES # WA0050229 Zinc Copper* samples. Oct 2023 X X Nov 2023 X X Dec 2023 Jan 2024 Feb 2024 X Mar 2024 X (*) Copper: Also, X for June, July & Sept 2022 which would have been 2011 Permit weekly copper samples. I brought this information to the attention of the Facility representatives during the inspection for their consideration and response. The Facility representatives did not have any explanation or insights for the apparent sudden changes in effluent pollutant parameter concentrations and these NODI-B entries. It was not clear from the on-site inspection discussion of this information whether the Facility was going to review the matter in an effort to determine the causes or reasons for the apparent sudden nondetection sample results. X. Closing Conference After the site tour, I did a brief closing conference with Mr. Schumacker, Ms. Musgrave and Ms. Welland and discussed my site tour observations and a preliminary list of areas of concern identified during the inspection and records review, noting these were preliminary areas of concern subject to review, supplementation and revision. Mr. Badonie and Mr. Herrera were also in attendance for this closing conference. After this closing conference, I thanked the Facility representatives for their time, help and cooperation for this inspection process, then we departed the Facility. 19 City of Wapato Wastewater Treatment Plant NPDES # WA0050229 ATTACHMENT A - Facility Aerial & Process Schematics 20 Wapato 'WWf!F Figure 3 Facility Layout Diagram Fact Sheet: WA0050229 - City of Wapato Page 50 of 72 PRE- I- AERATION z TANKS w :::, DIST .~... BOX w PA a: (D ~ N 0 z MBR BUILDING > :::, DISTRIBUTION BOX C BLO~R & CENTRIFUGE BUILDING MBR INFLUENT N >< 3:: i w (.!) < z < PLANT a: C EFFLUENT CHLORINE CONTACT TANKS { OUT OF SERVICE) FEED - FORWARD PUMP STATION ANOXIC SELECTOR TANKS PUMP-BLO~R BUILDING PRIMARY AEROBIC DIGESTER CITY OF WAPATO NPOES PERMIT APPLICATION FIGURE 1 PROCESS FLOW DIAGRAM Figure 4 Process Flow Diagram Fact Sheet: WA0050229 - City of Wapato Gra.y &Oshorn.e, Inc. CONSULTING ENGINEERS W \ wAPAJO\UJ:llJ. - NPOl'.5 PfAwtt ,\PP\JCAllC>l\fOlll[SV,C I OIIC Page 51 of 72 PREAERATION TANKS DISTRIBUTION BOX PA TO SLUDGE DRYING BEDS OR TRUCK MBR TANKS N ci z MBR BUILDING > ::> DISTRIBUTION BOX C ANOXIC SELECTOR w (!I ::> ...J VI ~ 0 VI FEED-FORWARD ~ PUMP STATION : : 11 CI--H_l_f-~Nu-~- g~- N-S-TE~-~-\ - ~-~-tN'--KS----1 0 0 ANAL CLARIAERS {OUT OF SERVICE) BLOWER & CENTRIFUGE BUILDING CITY OF WAPATO NPDES PERMIT APPLICATION FIGURE2 SLUDGE FlOW DIAGRAM Gray &Oshorn.e, Inc. CONSULTINO ENGINEERS PUMP-BLOWER BUILDI NG Figure 5 Sludge Flow Diagram Fact Sheet: WA0050229 - City of Wapato w \WAPAT0\1111:u - hPDC.S PlttwlT APP\JC."1'\'10.IRESVIC 20Ml Page 52 of 72 City of Wapato Wastewater Treatment Plant NPDES # WA0050229 ATTACHMENT B - Photograph Log (Photographs were taken by Rick Cool with a Panasonic Lumix FH-25 camera) 21 Wapato Wastewater Treatment Plant Wapato, Washington NPDES Inspection June 18, 2024 Photographed by: Rick Cool Photo 1: P1010603 Headworks 06/18/2024 Photo 2: P1010604 Influent Screens 06/18/2024 Photo 3: P1010605 Primary Clarifier 06/18/2024 Photo 4: P1010606 06/18/2024 Sludge Drying Beds & Stockpiled Dried Sludge 1 Wapato Wastewater Treatment Plant Wapato, Washington NPDES Inspection June 18, 2024 Photographed by: Rick Cool Photo 5: P1010607 An MBR Pre-Aeration Basin 06/18/2024 Photo 6: P1010608 UV Disinfection Units 06/18/2024 Photo 7: P1010609 06/18/2024 Drainageway #2 Upstream Sampling Location - Flow Gage/Fence Post Anchored Near Concrete Wall in Drainage Way Bank near Footbridge Photo 8: P1010610 2 Effluent Auto-Sampler 06/18/2024 City of Wapato Wastewater Treatment Plant NPDES # WA0050229 ATTACHMENT C - EPA ICIS Violations Report 22 NPDES ID(s): WA0050229 State: WA Major/Minor Indicator: Violation Date: 03/01/2020 - 05/31/2024 Violation Type(s): Environmental Protection Agency Integrated Compliance Information System Violations Report Created Date: 09/15/201 O Refresh Date: 06/10/2024 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: WAPATO, CITY OF 68172 HIGHWAY 97 WAPATO, WA 98951 Major On On On WA0050229 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 JEFF SCHUMACKER, LEAD OPERATOR 509-853-8013 YAKIMA RIVER VIA DRAINAGE DITCH #2 Permit Issued: Permit Effective: Permit Expired: Permit Status: 07/26/2023 10/01/2023 09/30/2028 Effective Facili~ Information Facility Name: Facility Location: WAPATO, CITY OF - WAPATO WWTP 68172 HIGHWAY 97 (YAKAMA RESERVATION) WAPATO, WA 98951 County: Region : State-Region: Yakima 10 07 DMR Non-ReceiP-t Violations Violation Code D90 Monitoring Period End Date 08/31/2020 DMRDue Date 09/10/2020 Limit Set 001-A Parameter 50060 - Chlorine, total residual Mon. Loe. Seas. ID 0 D90 08/31/2020 09/10/2020 001-A 50060 - Chlorine, total residual 0 D90 08/31/2020 09/10/2020 001-A 50060 - Chlorine, total residual 0 D90 08/31/2020 09/10/2020 001-A 50060 - Chlorine, total residual 0 D90 07/31/2020 08/10/2020 001-A 50060 - Chlorine, total residual 0 D90 07/31/2020 08/10/2020 001-A 50060 - Chlorine, total residual 0 D90 07/31/2020 08/10/2020 001-A 50060 - Chlorine, total residual 0 D90 07/31/2020 08/10/2020 001-A 50060 - Chlorine, total residual 0 D90 06/30/2020 07/10/2020 001-A 50060 - Chlorine, total residual 0 D90 06/30/2020 07/10/2020 001-A 50060 - Chlorine, total residual 0 FRSID: Federal Facility Ownership: Type of Ownership: 110009763461 N Municipality DMR Value Q1 Q2 C2 C3 Q1 Q2 C2 C3 Q1 Q2 NODI Code **8** **8** 'lrlrB** **8** **8** 1rlr8** **8** **8** **8** -a** RNC Del Code/ RNC Det. Date N 10/11/2020 K 10/11/2020 N 10/11/2020 K 10/11/2020 N 09/10/2020 K 09/10/2020 N 09/10/2020 K 09/10/2020 N 08/10/2020 K 08/10/2020 RNC Res. Code/ RNC Res. Date 0 10/11/2021 0 10/11/2021 0 10/11/2021 0 10/11/2021 0 09/10/2021 0 09/10/2021 0 09/10/2021 0 09/10/2021 0 08/10/2021 0 08/10/2021 DMRVal. Rec Date 09/18/2020 09/18/2020 09/18/2020 09/18/2020 08/20/2020 08/20/2020 08/20/2020 08/20/2020 07/20/2020 07/20/2020 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 of9 NPDES ID(s): WA0050229 State: WA Major/Minor Indicator: Violation Date: 03/01/2020 - 05/31/2024 Violation Type(s): Violation Code D90 D90 D90 D90 D90 D90 D90 D90 D90 D90 D90 D90 D90 D90 Monitoring Period End Date 06/30/2020 06/30/2020 05/31/2020 05/31/2020 05/31/2020 05/31/2020 04/30/2020 04/30/2020 04/30/2020 04/30/2020 03/31/2020 03/31/2020 03/31/2020 03/31/2020 DMRDue Date 07/10/2020 07/10/2020 06/10/2020 06/10/2020 06/10/2020 06/10/2020 05/10/2020 05/10/2020 05/10/2020 05/10/2020 04/10/2020 04/10/2020 04/10/2020 04/10/2020 Environmental Protection Agency Integrated Compliance Information System Violations Report Limit Set 001-A WA0050229 DMR Non-Recei~t Violations Parameter Mon. Loe. Seas. ID 50060 - Chlorine, total residual 0 001-A 50060 - Chlorine, total residual 0 001-A 50060 - Chlorine, total residual 0 001-A 50060 - Chlorine, total residual 0 001-A 50060 - Chlorine, total residual 0 001-A 50060 - Chlorine, total residual 0 001-A 50060 - Chlorine, total residual 0 001-A 50060 - Chlorine, total residual 0 001-A 50060 - Chlorine, total residual 0 001-A 50060 - Chlorine, total residual 0 001-A 50060 - Chlorine, total residual 0 001-A 50060 - Chlorine, total residual 0 001-A 50060 - Chlorine, total residual 0 001-A 50060 - Chlorine, total residual 0 DMR Value C2 C3 01 02 C2 C3 01 02 C2 C3 01 02 C2 C3 Violation Code E90 Monitoring Period End Date 04/30/2024 Limit Set 001-A Parameter 0061 O- Nitrogen, ammonia total [as NJ Mon. Loe. Seas. ID SNC Group Effluent Violations EA Identifier Value Type/ Stat. Base Q1 MOAVG Reported Value/Units 72.5 Ibid Created Date: 09/15/201 O Refresh Date: 06/10/2024 Report Version 1.5, Modified : 1/4/2017 NODI Code **8** **8** 'lrlrB** **8** **8** 'lrlrB** **8** **8** **8** 'lrlrB** **8** **8** 'lrlrB** **8** RNC Del Code/ RNC Det. Date N 08/10/2020 K 08/10/2020 N 07/11/2020 K 07/11/2020 N 07/11/2020 K 07/11/2020 N 06/10/2020 K 06/10/2020 N 06/10/2020 K 06/10/2020 N 05/11/2020 K 05/11/2020 N 05/11/2020 K 05/11/2020 RNC Res. Code/ RNC Res. Date 0 08/10/2021 0 08/10/2021 0 07/11/2021 0 07/11/2021 0 07/11/2021 0 07/11/2021 0 06/10/2021 0 06/10/2021 0 06/10/2021 0 06/10/2021 0 05/11/2021 0 05/11/2021 0 05/11/2021 0 05/11/2021 DMRVal. Rec Date 07/20/2020 07/20/2020 06/20/2020 06/20/2020 06/20/2020 06/20/2020 05/19/2020 05/19/2020 05/19/2020 05/19/2020 04/20/2020 04/20/2020 04/20/2020 04/20/2020 % Exceed. 936% Limit Value/ Units <=7 Ibid RNC Det. Code/ RNC Del 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 2 of9 NPDES ID(s): WA0050229 State: WA Major/Minor Indicator: Violation Date: 03/01/2020 - 05/31/2024 Violation Type(s): Environmental Protection Agency Integrated Compliance Information System Violations Report Violation Code E90 Monitoring Period End Date 04/30/2024 E90 04/30/2024 E90 04/30/2024 E90 04/30/2024 E90 04/30/2024 E90 04/30/2024 E90 03/31/2024 E90 03/31/2024 E90 03/31/2024 E90 03/31/2024 E90 02/29/2024 E90 02/29/2024 E90 02/29/2024 E90 01/31/2024 E90 01/31/2024 E90 01/31/2024 E90 12/31/2023 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 Parameter 0061 O- Nitrogen, ammonia total (as NJ 0061 O- Nitrogen, ammonia total [as NJ 0061 O- Nitrogen, ammonia total [as NJ 01094 - Zinc, total recoverable 01094 - Zinc, total recoverable 01094 - Zinc, total recoverable 01094 - Zinc, total recoverable 01094 - Zinc, total recoverable 01094 - Zinc, total recoverable 01094 - Zinc, total recoverable 01094 - Zinc, total recoverable 01094 - Zinc, total recoverable 01094 - Zinc, total recoverable 01094 - Zinc, total recoverable 01094 - Zinc, total recoverable 01094 - Zinc, total recoverable 01094 - Zinc, total recoverable Mon. Loe. Seas. ID SNC Group 0 2 0 2 0 2 0 2 0 2 0 2 0 2 0 2 0 2 0 2 0 2 0 2 0 2 0 2 WA0050229 Effluent Violations EA Identifier Value Type/ Stat. Base 02 DAILYMX C2 MOAVG C3 DAILYMX 01 MOAVG C2 MOAVG C3 DAILYMX 01 MOAVG 02 DAILYMX C2 MOAVG C3 DAILYMX 01 MOAVG C2 MOAVG C3 DAILYMX 01 MOAVG C2 MOAVG C3 DAILYMX C2 MOAVG Reported Value/Units 87.7 Ibid 15.9 mg/I 17.1 mg/I .28 Ibid 55 ug/1 55 ug/1 .625 Ibid 1.5 Ibid 65 ug/1 347 ug/1 .25 Ibid 48 ug/1 70 ug/1 .25 Ibid 63.5 ug/1 80 ug/1 49 ug/1 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: 09/15/201 O Refresh Date: 06/10/2024 Report Version 1.5, Modified : 1/4/2017 % Exceed. 251% 2,171% 558% 17% 120% 6% 160% 200% 160% 567% 4% 92% 35% 4% 154% 54% 96% Limit Value/ Units <=25 Ibid <=.7 mg/I <=2 .6 mg/I <=.24 Ibid <=25 ug/1 <=52 ug/1 <= .24 Ibid <=.5 Ibid <=25 ug/1 <=52 ug/1 <=.24 Ibid <=25 ug/1 <=52 ug/1 <= .24 Ibid <=25 ug/1 <=52 ug/1 <=25 ug/1 RNC Det. Code/ RNC Del Date RNC Res. Code/ RNC Res. Date T 03/31/2024 T 03/31/2024 V 02/29/2024 T 02/29/2024 V 01/31/2024 T 01/31/2024 T 12/31/2023 Page 3 of9 NPDES ID(s): WA0050229 State: WA Major/Minor Indicator: Violation Date: 03/01/2020 - 05/31/2024 Violation Type(s): Violation Code E90 Monitoring Period End Date 09/30/2023 E90 09/30/2023 E90 09/30/2023 E90 09/30/2023 E90 09/30/2023 E90 04/30/2023 E90 04/30/2023 E90 04/30/2023 E90 03/31/2023 E90 03/31/2023 E90 02/28/2023 E90 02/28/2023 E90 02/28/2023 E90 01/31/2023 E90 12/31/2022 E90 12/31/2022 E90 12/31/2022 E90 11/30/2022 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 01094 - Zinc, total recoverable 01094 - Zinc, total recoverable 01094 - Zinc, total recoverable 01119 - Copper, total recoverable 01119 - Copper, total recoverable 01094 - Zinc, total recoverable 01094 - Zinc, total recoverable 01094 - Zinc, total recoverable 01094 - Zinc, total recoverable 01094 - Zinc, total recoverable 01094 - Zinc, total recoverable 01094 - Zinc, total recoverable 01119 - Copper, total recoverable 01094 - Zinc, total recoverable 01094 - Zinc, total recoverable 01119 - Copper, total recoverable 01119 - Copper, total recoverable 01094 - Zinc, total recoverable Environmental Protection Agency Integrated Compliance Information System Violations Report Mon. Loe. Seas. ID 0 SNC Group 2 0 2 0 2 0 2 0 2 0 2 0 2 0 2 0 2 0 2 0 2 0 2 0 2 0 2 0 2 0 2 0 2 0 2 WA0050229 Effluent Violations EA Identifier Value Type/ Stat. Base 01 MOAVG 02 DAILYMX C3 DAILYMX 01 MOAVG 02 DAILYMX 01 MOAVG C2 MOAVG C3 DAILYMX C2 MOAVG C3 DAILYMX C2 MOAVG C3 DAILYMX C2 MOAVG C2 MOAVG C2 MOAVG C2 MOAVG C3 DAILYMX C2 MOAVG Reported Value/Units 1.36 Ibid 4.1 Ibid 63.9 ug/1 .066 Ibid .2 Ibid .25 Ibid 55 ug/1 100 ug/1 46.3 ug/1 65 ug/1 75.5 ug/1 100 ug/1 4.8 ug/1 32.8 ug/1 45.4 ug/1 4.19 ug/1 6.3 ug/1 38.7 ug/1 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: 09/15/201 O Refresh Date: 06/10/2024 Report Version 1.5, Modified : 1/4/2017 % Exceed. 467% 720% 23% 100% 277% 4% 120% 92% 85% 25% 202% 92% 41% 31% 82% 23% 15% 55% Limit Value/ Units <=.24 Ibid <=.5 Ibid <=52 ug/1 <=.033 Ibid <= .053 Ibid <= .24 Ibid <=25 ug/1 <=52 ug/1 <=25 ug/1 <=52 ug/1 <=25 ug/1 <=52 ug/1 <=3.4 ug/1 <=25 ug/1 <=25 ug/1 <=3.4 ug/1 <=5.5 ug/1 <=25 ug/1 RNC Det. Code/ RNC Del Date T 09/30/2023 RNC Res. Code/ RNC Res. Date V 04/30/2023 T 04/30/2023 T 03/31/2023 T 02/28/2023 T 02/28/2023 T 01/31/2023 T 12/31/2022 T 12/31/2022 T 11/30/2022 2 10/31/2023 2 10/31/2023 2 10/31/2023 2 10/31/2023 2 06/30/2023 2 10/31/2023 2 10/31/2023 2 06/30/2023 2 10/31/2023 Page 4 of9 NPDES ID(s): WA0050229 State: WA Major/Minor Indicator: Violation Date: 03/01/2020 - 05/31/2024 Violation Type(s): Violation Code E90 Monitoring Period End Date 11/30/2022 E90 10/31/2022 E90 10/31/2022 E90 09/30/2022 E90 09/30/2022 E90 0813112022 E90 08/3112022 E90 0813112022 E90 08/3112022 E90 0713112022 E90 0713112022 E90 06/3012022 E90 0613012022 E90 05/3112022 E90 0513112022 E90 05/3112022 E90 0413012022 E90 0413012022 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 01094 - Zinc, total recoverable 01094 - Zinc, total recoverable 01094 - Zinc, total recoverable 01094 - Zinc, total recoverable 01094 - Zinc, total recoverable 01094 - Zinc, total recoverable 01094 - Zinc, total recoverable 01119 - Copper, total recoverable 01119 - Copper, total recoverable 01094 - Zinc, total recoverable 01094 - Zinc, total recoverable 01094 - Zinc, total recoverable 01094 - Zinc, total recoverable 01094 - Zinc, total recoverable 01094 - Zinc, total recoverable 01094 - Zinc, total recoverable 01094 - Zinc, total recoverable 01094 - Zinc, total recoverable Environmental Protection Agency Integrated Compliance Information System Violations Report Mon. Loe. Seas. ID 0 SNC Group 2 0 2 0 2 0 2 0 2 0 2 0 2 0 2 0 2 0 2 0 2 0 2 0 2 0 2 0 2 0 2 0 2 0 2 WA0050229 Effluent Violations EA Identifier Value Type/ Stat. Base C3 DAILYMX C2 MOAVG C3 DAILYMX 01 MOAVG 02 DAILYMX 01 MOAVG 02 DAILYMX 01 MOAVG C2 MOAVG 01 MOAVG C2 MOAVG C2 MOAVG C3 DAILYMX 01 MOAVG C2 MOAVG C3 DAILYMX 01 MOAVG C2 MOAVG Reported Value/Units 62 ug/1 31 .6 ug/1 54 ug/1 1.1 Ibid 2.3 Ibid 1.7 Ibid 2.4 Ibid .04 Ibid 5 ug/1 .317 Ibid 47.8 ug/1 41.45 ug/1 59 ug/1 .25 Ibid 42.9 ug/1 53.4 ug/1 .26 Ibid 45.6 ug/1 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: 09/15/201 O Refresh Date: 06/10/2024 Report Version 1.5, Modified : 1/4/2017 % Exceed. 19% 26% 4% 358% 360% 608% 380% 21% 47% 32% 91% 66% 13% 4% 72% 3% 8% 82% Limit Value/ Units <=52 ug/1 <=25 ug/1 <=52 ug/1 <=.24 Ibid <=.5 Ibid <= .24 Ibid <=.5 Ibid <=.033 Ibid <=3.4 ug/1 <= .24 Ibid <=25 ug/1 <=25 ug/1 <=52 ug/1 <=.24 Ibid <=25 ug/1 <=52 ug/1 <= .24 Ibid <=25 ug/1 RNC Det. Code/ RNC Del Date RNC Res. Code/ RNC Res. Date T 10/31/2022 T 09/30/2022 T 08131/2022 T 12131/2022 T 1213112022 T 0713112022 T 07131/2022 T 0613012022 V 05131/2022 T 05131/2022 V 0413012022 T 04130/2022 2 10/31/2023 2 10/31/2023 2 10131/2023 2 06130/2023 2 0613012023 2 1013112023 2 10131/2023 2 1013112023 2 10131/2023 2 10131/2023 2 1013112023 2 10131/2023 Page 5 of9 NPDES ID(s): WA0050229 State: WA Major/Minor Indicator: Violation Date: 03/01/2020 - 05/31/2024 Violation Type(s): Violation Code E90 Monitoring Period End Date 04/30/2022 E90 03/31/2022 E90 0313112022 E90 02/2812022 E90 02/2812022 E90 0113112022 E90 12/3112021 E90 1113012021 E90 11/3012021 E90 1113012021 E90 1013112021 E90 10/3112021 E90 1013112021 E90 09/3012021 E90 0913012021 E90 08/3112021 E90 0713112021 E90 0713112021 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 01094 - Zinc, total recoverable 01094 - Zinc, total recoverable 01094 - Zinc, total recoverable 01094 - Zinc, total recoverable 01094 - Zinc, total recoverable 01094 - Zinc, total recoverable 01094 - Zinc, total recoverable 01094 - Zinc, total recoverable 01094 - Zinc, total recoverable 01094 - Zinc, total recoverable 01094 - Zinc, total recoverable 01094 - Zinc, total recoverable 01094 - Zinc, total recoverable 01094 - Zinc, total recoverable 01094 - Zinc, total recoverable 01094 - Zinc, total recoverable 01094 - Zinc, total recoverable 01094 - Zinc, total recoverable Environmental Protection Agency Integrated Compliance Information System Violations Report Mon. Loe. Seas. ID 0 SNC Group 2 0 2 0 2 0 2 0 2 0 2 0 2 0 2 0 2 0 2 0 2 0 2 0 2 0 2 0 2 0 2 0 2 0 2 WA0050229 Effluent Violations EA Identifier Value Type/ Stat. Base C3 DAILYMX C2 MOAVG C3 DAILYMX C2 MOAVG C3 DAILYMX C2 MOAVG C2 MOAVG 01 MOAVG C2 MOAVG C3 DAILYMX 01 MOAVG C2 MOAVG C3 DAILYMX C2 MOAVG C3 DAILYMX C2 MOAVG 01 MOAVG C2 MOAVG Reported Value/Units 55 ug/1 54.9 ug/1 82.6 ug/1 50.25 ug/1 60 ug/1 50 ug/1 45.06 ug/1 .25 Ibid 55 ug/1 69 ug/1 .29 Ibid 56.5 ug/1 75.5 ug/1 44.34 ug/1 62.5 ug/1 34 ug/1 .3 Ibid 52.6 ug/1 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: 09/15/201 O Refresh Date: 06/10/2024 Report Version 1.5, Modified : 1/4/2017 % Exceed. 6% 120% 59% 101% 15% 100% 80% 4% 120% 33% 21% 126% 45% 77% 20% 36% 25% 110% Limit Value/ Units <=52 ug/1 <=25 ug/1 <=52 ug/1 <=25 ug/1 <=52 ug/1 <=25 ug/1 <=25 ug/1 <=.24 Ibid <=25 ug/1 <=52 ug/1 <=.24 Ibid <=25 ug/1 <=52 ug/1 <=25 ug/1 <=52 ug/1 <=25 ug/1 <= .24 Ibid <=25 ug/1 RNC Det. Code/ RNC Del Date RNC Res. Code/ RNC Res. Date T 03/31/2022 T 02128/2022 T 01131/2022 T 12131/2021 V 11130/2021 T 1113012021 T 10131/2021 T 1013112021 T 09130/2021 T 0813112021 T 0713112021 T 07131/2021 2 10/31/2023 2 10131/2023 2 10131/2023 2 10131/2023 2 10131/2023 2 1013112023 2 10131/2023 2 1013112023 2 10131/2023 2 1013112023 2 1013112023 2 10131/2023 Page 6 of9 NPDES ID(s): WA0050229 State: WA Major/Minor Indicator: Violation Date: 03/01/2020 - 05/31/2024 Violation Type(s): Violation Code E90 Monitoring Period End Date 07/31/2021 E90 06/30/2021 E90 0613012021 E90 06/3012021 E90 05/3112021 E90 0513112021 E90 05/3112021 E90 0413012021 E90 04/3012021 E90 0413012021 E90 0413012021 E90 03/3112021 E90 0313112021 E90 03/3112021 E90 0212812021 E90 02/2812021 E90 0212812021 E90 0113112021 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 01094 - Zinc, total recoverable 01094 - Zinc, total recoverable 01094 - Zinc, total recoverable 01094 - Zinc, total recoverable 01094 - Zinc, total recoverable 01094 - Zinc, total recoverable 01094 - Zinc, total recoverable 01094 - Zinc, total recoverable 01094 - Zinc, total recoverable 01094 - Zinc, total recoverable 01094 - Zinc, total recoverable 01094 - Zinc, total recoverable 01094 - Zinc, total recoverable 01094 - Zinc, total recoverable 01094 - Zinc, total recoverable 01094 - Zinc, total recoverable 01094 - Zinc, total recoverable 01094 - Zinc, total recoverable Environmental Protection Agency Integrated Compliance Information System Violations Report Mon. Loe. Seas. ID 0 SNC Group 2 0 2 0 2 0 2 0 2 0 2 0 2 0 2 0 2 0 2 0 2 0 2 0 2 0 2 0 2 0 2 0 2 0 2 WA0050229 Effluent Violations EA Identifier Value Type/ Stat. Base C3 DAILYMX 01 MOAVG C2 MOAVG C3 DAILYMX 01 MOAVG C2 MOAVG C3 DAILYMX 01 MOAVG 02 DAILYMX C2 MOAVG C3 DAILYMX 01 MOAVG C2 MOAVG C3 DAILYMX 01 MOAVG C2 MOAVG C3 DAILYMX 01 MOAVG Reported Value/Units 62 ug/1 .25 Ibid 49.6 ug/1 56.5 ug/1 .35 Ibid 67 ug/1 81 ug/1 .47 Ibid .6 Ibid 96 ug/1 128 ug/1 .275 Ibid 56.7 ug/1 64 ug/1 .29 Ibid 61 .25 ug/1 74 ug/1 .325 Ibid 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: 09/15/201 O Refresh Date: 06/10/2024 Report Version 1.5, Modified : 1/4/2017 % Exceed. 19% 4% 98% 9% 46% 168% 56% 96% 20% 284% 146% 15% 127% 23% 21% 145% 42% 35% Limit Value/ Units <=52 ug/1 <= .24 Ibid <=25 ug/1 <=52 ug/1 <= .24 Ibid <=25 ug/1 <=52 ug/1 <=.24 Ibid <=.5 Ibid <=25 ug/1 <=52 ug/1 <= .24 Ibid <=25 ug/1 <=52 ug/1 <=.24 Ibid <=25 ug/1 <=52 ug/1 <=.24 Ibid RNC Det. Code/ RNC Del Date RNC Res. Code/ RNC Res. Date V 06/30/2021 T 0613012021 T 0513112021 T 05131/2021 T 04130/2021 T 0413012021 V 0313112021 T 0313112021 T 02128/2021 T 0212812021 T 01131/2021 2 10/31/2023 2 1013112023 2 1013112023 2 10131/2023 2 10131/2023 2 1013112023 2 1013112023 2 1013112023 2 10131/2023 2 1013112023 2 10131/2023 Page 7 of9 NPDES ID(s): WA0050229 State: WA Major/Minor Indicator: Violation Date: 03/01/2020 - 05/31/2024 Violation Type(s): Violation Code E90 Monitoring Period End Date 01/31/2021 E90 01/31/2021 E90 12/31/2020 E90 12/31/2020 E90 12/31/2020 E90 11/30/2020 E90 11/30/2020 E90 11/30/2020 E90 11/30/2020 E90 10/31/2020 E90 10/31/2020 E90 09/30/2020 E90 09/30/2020 E90 08/31/2020 E90 08/31/2020 E90 08/31/2020 E90 07/31/2020 E90 07/31/2020 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 01094 - Zinc, total recoverable 01094 - Zinc, total recoverable 01094 - Zinc, total recoverable 01094 - Zinc, total recoverable 01094 - Zinc, total recoverable 01094 - Zinc, total recoverable 01094 - Zinc, total recoverable 01094 - Zinc, total recoverable 01094 - Zinc, total recoverable 01094 - Zinc, total recoverable 01094 - Zinc, total recoverable 01094 - Zinc, total recoverable 01094 - Zinc, total recoverable 01094 - Zinc, total recoverable 01094 - Zinc, total recoverable 01094 - Zinc, total recoverable 01094 - Zinc, total recoverable 01094 - Zinc, total recoverable Environmental Protection Agency Integrated Compliance Information System Violations Report Mon. Loe. Seas. ID 0 SNC Group 2 0 2 0 2 0 2 0 2 0 2 0 2 0 2 0 2 0 2 0 2 0 2 0 2 0 2 0 2 0 2 0 2 0 2 WA0050229 Effluent Violations EA Identifier Value Type/ Stat. Base C2 MOAVG C3 DAILYMX 01 MOAVG C2 MOAVG C3 DAILYMX 01 MOAVG 02 DAILYMX C2 MOAVG C3 DAILYMX 01 MOAVG C2 MOAVG 01 MOAVG C2 MOAVG 01 MOAVG C2 MOAVG C3 DAILYMX 01 MOAVG C2 MOAVG Reported Value/Units 82.6 ug/1 94.5 ug/1 .36 Ibid 90.1 ug/1 124 ug/1 .3 Ibid .57 Ibid 74.1 ug/1 120 ug/1 .3 Ibid 45.8 ug/1 .25 Ibid 30.7 ug/1 .33 Ibid 42.1 ug/1 58.5 ug/1 .29 Ibid 48.16 ug/1 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: 09/15/201 O Refresh Date: 06/10/2024 Report Version 1.5, Modified : 1/4/2017 % Exceed. 230% 82% 50% 260% 138% 25% 14% 196% 131% 25% 83% 4% 23% 38% 68% 13% 21% 93% Limit Value/ Units <=25 ug/1 <=52 ug/1 <= .24 Ibid <=25 ug/1 <=52 ug/1 <= .24 Ibid <=.5 Ibid <=25 ug/1 <=52 ug/1 <= .24 Ibid <=25 ug/1 <= .24 Ibid <=25 ug/1 <=.24 Ibid <=25 ug/1 <=52 ug/1 <= .24 Ibid <=25 ug/1 RNC Det. Code/ RNC Del Date T 01/31/2021 RNC Res. Code/ RNC Res. Date 2 10/31/2023 T 12/31/2020 T 12/31/2020 2 10/31/2023 2 10/31/2023 T 11/30/2020 2 10/31/2023 T 11/30/2020 2 10/31/2023 T 10/31/2020 T 10/31/2020 V 09/30/2020 T 09/30/2020 T 08/31/2020 T 08/31/2020 2 10/31/2023 2 10/31/2023 2 10/31/2023 2 10/31/2023 2 10/31/2023 2 10/31/2023 T 07/31/2020 T 07/31/2020 2 10/31/2023 2 10/31/2023 Page 8 of9 NPDES ID(s): WA0050229 State: WA Major/Minor Indicator: Violation Date: 03/01/2020 - 05/31/2024 Violation Type(s): Violation Code E90 Monitoring Period End Date 07/31/2020 E90 06/30/2020 E90 06/30/2020 E90 06/30/2020 E90 05/31/2020 E90 05/31/2020 E90 05/31/2020 E90 04/30/2020 E90 04/30/2020 E90 03/31/2020 Limit Set 001-A 001-A 001-A 001-A 001-A 001-A 001-A 001-A 001-A 001-A Parameter 01094 - Zinc, total recoverable 01094 - Zinc, total recoverable 01094 - Zinc, total recoverable 01094 - Zinc, total recoverable 01094 - Zinc, total recoverable 01094 - Zinc, total recoverable 01094 - Zinc, total recoverable 01094 - Zinc, total recoverable 01094 - Zinc, total recoverable 01094 - Zinc, total recoverable Violation Code C40 Sch. Event Code ERPNP Schedule Date 03/29/2024 Actual Date Environmental Protection Agency Integrated Compliance Information System Violations Report Created Date: 09/15/201 O Refresh Date: 06/10/2024 Report Version 1.5, Modified : 1/4/2017 Mon. Loe. Seas. ID 0 SNC Group 2 0 2 0 2 0 2 0 2 0 2 0 2 0 2 0 2 0 2 WA0050229 Effluent Violations EA Identifier Value Type/ Stat. Base C3 DAILYMX 01 MOAVG C2 MOAVG C3 DAILYMX 01 MOAVG C2 MOAVG C3 DAILYMX C2 MOAVG C3 DAILYMX C2 MOAVG Reported Value/Units 54 ug/1 .27 Ibid 49.3 ug/1 62.5 ug/1 .25 Ibid 49.4 ug/1 54.5 ug/1 41.64 ug/1 53.5 ug/1 48 .96 ug/1 % Exceed. 4% 13% 97% 20% 4% 98% 5% 67% 3% 96% Limit Value/ Units <=52 ug/1 <= .24 Ibid <=25 ug/1 <=52 ug/1 <= .24 Ibid <=25 ug/1 <=52 ug/1 <=25 ug/1 <=52 ug/1 <=25 ug/1 RNC Det. Code/ RNC Del Date RNC Res. Code/ RNC Res. Date V 06/30/2020 T 06/30/2020 V 05/31/2020 T 05/31/2020 T 04/30/2020 T 03/31/2020 2 10/31/2023 2 10/31/2023 2 10/31/2023 2 10/31/2023 2 10/31/2023 2 10/31/2023 Report Received Date Schedule Violations EA Identifier Sch. Num. Sch. Type p Schedule Event/ Comments Emergency Response and Public Notification Plan Comment: The pennittee must develop and implement an overflow emergency response and public notification plan. The pennittee must submit written notice to EPA and the Yakama Nation that the plan has been developed and implemented (See Part 11.F of this permit). RNC Det. Code/ RNC Det. Date N 04/29/2024 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 9 of 9 Environmental Protection Agency Integrated Compliance Information System Violations Report RNC Detection Codes Created Date: 09/15/201 0 Refresh Date: 06/10/2024 Report Version 1.5, Modified: 1/4/2017 Violation Type DMR Non-Receipt (DS0, 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 28 - Pretreatment DIS - Manual 2E - Deficient Report Page 1 of1 RNC Resolution Status Noncompliant (NC) Resolved Pending (RP) Resolved (RE) Environmental Protection Agency Integrated Compliance Information System Violations Report RNC Resolution Codes Created Date: 09/15/201 O Refresh Date: 06/10/2024 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 of1 Environmental Protection Agency Integrated Compliance Information System Violations Report NODI Codes Created Date: 09/15/201 O Refresh Date: 06/10/2024 Report Version 1.5, Modified: 1/4/2017 NODI Code 2 3 6 7 9 A B C E F I N p a 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 ParameterNalue Not Reported State-specific No Data Indicator - Valid Page 1 of1 Environmental Protection Agency Integrated Compliance Information System Violations Report DMR Violation Codes Created Date: 09/15/201 0 Refresh Date: 06/10/2024 Report Version 1.5, Modified: 1/4/2017 Page 1 of1 Environmental Protection Agency Integrated Compliance Information System Violations Report Schedule Violation Codes Created Date: 09/15/201 0 Refresh Date: 06/10/2024 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 of1 Environmental Protection Agency Integrated Compliance Information System Violations Report Monitoring Location Codes Created Date: 09/15/201 O Refresh Date: 06/10/2024 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 0 p Pl 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 Digester 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 of2 Environmental Protection Agency Integrated Compliance Information System Violations Report Created Date: 09/15/201 0 Refresh Date: 06/10/2024 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 lnstream Monitoring Page2 of2 City of Wapato Wastewater Treatment Plant NPDES # WA0050229 ATTACHMENT D - DOI Geological Survey Rating Table 23 City of Wapato Wastewater Treatment Plant NPDES # WA0050229 ATTACHMENT E - Anateck Labs, Inc. December 2023 Lab Report Excerpt (PFAS) 24 Anatek Labs, Inc. l 1282 Alturas Drive - Moscow, ID 83843 - (208) 883-2839 - email moscow@anateklabs.com 504 E Sprague Ste. D - Spokane, WA 99202 - (509) 838-3999 - email spokane@anateklabs.com Ct ((%/Z+ Client: Address: Attn: Labtest 201 East D St Yakima, WA 98901 Bennett Osborne System ID# Reference Number: Multiple Source Nos: Date Received: Sample Location: Matrix: MDL0299-01 12/08/23 09:30 12848 Drinking Water Per and Polyfluoroalkyl Substances ( PFAS) DOH# 0434 0433 0431 0432 0429 0430 043S 0436 0437 0438 0445 0446 0447 0448 0450 0451 0452 0453 0454 Analyte PFOA Pcrlluoroo<tanolc acid PfOS Petfluorooctanesutfon[c add PflixS Pcrlluorohexanesulfonlc add PFNA Perlluoronooanolc add PFBS Perfluorobutanesulfonlc add PFHpA Pcrlluoroheptanoic add PFHxA PerfluoroheleanoiC add PFDA Perfluorodecanolc add PFUnA Perf\uoroundea,noic aod PfDoA Perfluorododecanolc add ADONA 4,8Dloxa-3Hperlluoronon anolc acid 90PF30NS HFPO-DA Hexafuoropropytene oxide dimer add I IO PF30UdS 4:2FTS I H, I H,2H,2HPerfluorohex ane s.ilfonlc add 6:2FTS ! H,1H,2H,2HPerlluoroo<ta ne sulfonlc add 8:2FTS IH,IH,2H,2HPerfluorodec ane sulfonJc add NFDHA Nonafluoro-3,6-dioxahepta nolc add PFBA Petfluorobutanoic acid Result 2.54 14.1 NO NO NO NO 8.45 NO NO ND ND ND NO NO ND ND ND ND 3.33 Work Order: Project: Reported: MDL0299 12848 12/28/2023 15:36 Analytical Results Report System Name: Labtest Collect Date: Sample Type: 12/06/23 00:00 Sample Purpose: DOH Source #: County: Lab/Sample Number: 125-29901 Units ng/L ng/L ng/L ng/ L ng/L ng/L ng/L ng/L ng/L ng/L ng/L ng/L ng/ L ng/L ng/ L ng/L ng/ L ng/L ng/L LRL 2.00 2.00 2.00 2.00 2.00 2.00 2.00 2.00 2.00 2.00 2.00 2.00 2.00 2.00 2.00 2.00 2.00 2.00 2.00 SORL 2 2 2 2 2 2 2 2 2 2 2 2 2 2 2 2 2 2 2 SAL MCL Analyzed Analyst Method Qualifier 10 12/14/23 5:13 MER EPA 533 15 12/14/23 5:13 MER EPA 533 65 12/14/23 5:13 MER EPA533 9 12/14/23 5:13 MER EPA 533 34S 12/14/23 5:13 MER EPA 533 12/14/23 5:13 12/14/23 5:13 12/14/23 5:13 12/14/23 5:13 12/14/23 5:13 12/14/23 5:13 MER MER MER MER MER MER EPA 533 EPA 533 EPA 533 EPA 533 EPA 533 EPA 533 12/14/23 5:13 MER 12/14/23 5:13 MER EPA 533 EPA 533 12/14/23 5:13 12/14/23 5:13 MER MER EPA 533 EPA 533 12/14/23 5:13 MER EPA 533 12/14/23 5:13 MER EPA 533 12/14/23 5:13 MER EPA 533 12/14/23 5:13 MER EPA 533 Page 1 of 6 Anatek Labs, Inc. 1282 Alturas Drive - Moscow, ID 83843 - (208) 883-2839 - email moscow@anateklabs.com 504 E Sprague Ste. D. Spokane, WA 99202 - (509) 838-3999 - email spokane@anateklabs.com Client: Address: Attn: Labtest 201 East D St Yakima, WA 98901 Bennett Osborne System ID# Reference Number: Multiple Source Nos: Date Received: Sample Location: Matrix: MDL0299-01 12/08/23 09:30 12848 Drinking Water Work Order: Project: Reported: MDL0299 12848 12/28/2023 15:36 Analytical Results Report System Name: Labtest Collect Date: 12/06/23 00:00 Sample Type: Sample Purpose: DOH Source #: County: Lab/Sample Number: 125-29901 Per- and Polyfluoroalkyl Substances (PFAS) DOH # 0455 0456 0457 0458 0459 0460 Analyte PFHpS Perfluorohept.>nesulfonlc add PFMBA Pernuoro-4-metho,cybutan o1c acid PFMPA Perfluoro3methoxyp,apa nolc add PFPeA Pcrfluoropentanolc add PFPeS Perfluoropentanesutfonlc acid PFEESA Perfluoro(2-ethoxyethane) sulfonic acid Result ND ND NO 14.2 ND ND Units LRL SORL SAL MCL Analyzed Analyst ng/ L 2.00 2 12/14/23 5:13 MER ng/L 2.00 2 12/14/23 5:13 MER ng/L 2.00 2 12/ 14/23 5:13 MER ng/L 2.00 2 ng/L 2.00 2 12/14/23 5:13 MER 12/14/23 5:13 MER ng/L 2.00 2 12/14/23 5:13 MER Method EPA 533 Qualifier EPA 533 EPA 533 EPA 533 EPA 533 EPA 533 Page 2 of 6