Document gaVR7NXdD6aLXqKQa0anVV5yQ

EPA REGION 5 Enforcement and Compliance Assurance Division INSPECTION REPORT Inspection Entry Date/Time Inspection Exit Date/Time Weather Media Statute(s)/Program(s) Type of Inspection 10/25/2023 08:03 AM (CT) 10/25/2023 11:30 AM (CT) Announced: Yes Access: Granted Water Clean Water Act, NPDES, WWTP Compliance Evaluation Inspection (CEI) Permittee Name Facility or Site Name Facility/Site Physical Address City, State, Zip Code County/Borough/Parish Facility GPS Coordinates Menominee Tribal Utilities Neopit Wastewater Treatment Facility W1599 N. County Highway M Neopit, WI 54150 Menominee County 44.893249, -88.592349 FRS ID 110012921071 Permit Number(s) (If Applicable) WI0073059 SIC and/or NAICS 4952 Regulatory Representatives Participating in Inspection: Title Name Inspector Ray Cullen Organization EPA REGION 5 Lead Inspector: Dean Maraldo [Signature] DINO MARALDO Digitally signed by DINO MARALDO Date: 2023.11.07 13:42:17 -06'00' EPA REGION 5 Maraldo.Dean@epa.gov (312) 353-2098 Supervisor Review: Ryan Bahr [Signature] Digitally signed by RYAN RYAN BAHR Date: 2023.11.07 BAHR 17:25:48 -06'00' EPA REGION 5 bahr.ryan@epa.gov 1 of 16 Neopit WWTF Inspection Date: 10/25/2023 SECTION I - INTRODUCTION Site Entry and Inspection Objectives I, EPA Region 5 Lead Inspector, Dean Maraldo, arrived at the Neopit Wastewater Treatment Facility (the "Facility" or "Neopit WWTF"), located within the Menominee Indian Reservation, Menominee County, Neopit, Wisconsin (the S 1/2 of Section 17, Township 29N, Range 14 E), at 08:03 AM (CT) on October 25, 2023, for an announced inspection. I was joined by EPA inspector Ray Cullen. We presented our EPA inspector credentials to Darryl Pyawasay (Operator) and informed them that this was an EPA inspection to determine compliance as authorized by Clean Water Act (CWA) Section 308 and implementing regulations. This report is based on information supplied by Facility representatives, direct observations made by the EPA inspectors, records and reports maintained by the Facility and other information including: photographs taken by EPA inspectors, physical evidence collected by the EPA inspectors, measurements taken by EPA inspectors, verbal or written statements made by Facility representatives during or subsequent to the on-site inspection, and materials, processes, data, photographs, or documents shown, demonstrated, or submitted to the EPA inspectors by Facility representatives during or subsequent to the on-site Inspection. In addition, information gathered prior to or subsequent to the inspection from a review of EPA and/or public records may be included in this report. Attendees Organization Attendee Name EPA Region 5 EPA Region 5 Indian Health Service Menominee Tribal Utilities Menominee Tribal Utilities Dean Maraldo Ray Cullen Shane Hoffman David Mahkimetas Darryl Pyawasay Facility/Site Description Title Present in Opening Conf. Lead Inspector Yes Inspector Yes Tribal Utility Consultant Yes Operator Yes Present in Closing Conf. Yes Yes Yes Yes Operator Yes Yes I began by reviewing the Facility description provided in the Facility's NPDES Permit, as follows: The renovated treatment system consists of two aerated cells followed by a settling cell. These cells are meant to be operated in series with an operating depth of 12 feet. Following the settling cell, the operator can direct the effluent to any of three seepage cells for final disposal. The maximum daily average design flow rate to the new system is 0.17 million gallons per day (mgd) with a peak sustained flow of 0.34 mgd. Final discharge to groundwater via seepage cells to Tourtillotte Creek. Darryl Pyawasay confirmed that the description is still accurate. 2 of 16 Neopit WWTF Inspection Date: 10/25/2023 Facility/Site Information Next, I asked some background questions. Darryl Pyawasay provided the responses in the table below. Do you use in-house or contract out for laboratory analyses? Contract out to lab for Biochemical Oxygen Demand (CBOD), Phosphorus, Ammonia, and Total Suspended Solids (TSS) Operation schedule? Facility checked twice a week; cells swapped every thirty days; monitored with SCADA Outfalls? No outfall, seepage cells to groundwater WWTP Approx. # of residents served? 335 connections WWTP Design Capacity & Average Daily Flow? covered in description as summarized above, yesterday 0.107 million gallons per day (MGD), avg 0.7-0.9 MGD. Overnight lows around 0.06 MGD Responsible official? Darryl Pyawasay Do you accept waste from septage haulers? No Is there currently any portion of the treatment One aerator tube not working, but system still working (Indian train that is non-operational? Health Service SDS project planned for 2024 completion) Are there any plans for renovation or No additional equipment to allow for increased wastewater flow? Any Industrial Users? No Have any bypasses or overflows happened at No the plant or in the collection system in the last year? How do you manage your biosolids? No sludge issue, cleaned out during last rehab CBI concerns? No Inspection Focus Areas and Locations Location/Area/Sub-area Interview Records/Non-DMR Reporting Self Monitoring Operations and Maintenance (O&M) Flow Monitoring SSOs Physical Inspection Close Out Conference Description Operations office at Keshena WWTP Neopit WWTF Operations office at Keshena WWTP 3 of 16 Neopit WWTF Inspection Date: 10/25/2023 SECTION II - OBSERVATIONS Location: Interview/Records/Non-DMR Reporting Observation #: DM1-OB-001 Date: 10/25/2023 I reviewed the Facility's compliance data in EPA's ECHO database. There were no reported effluent limit exceedances in the last five years. I asked the following reporting-related questions and Darryl Pyawasay provided the responses (in bold), below: Are Facility NPDES records and reports maintained for at least 3 years? Yes. Has the Treatment System Map been completed? Yes. I also confirmed completion with the EPA Region 5 Permits Program. Are you implementing a Preventive Maintenance Program (Permit Part I.d.3.d.)? Yes. Are daily logs maintained per Permit Part I.B.2.? Yes, operational logs are at the Facility. Additional monitoring completed per Permit Part I.D.7. (4 times over permit terms, annually)? Yes, up to date. Done four times Location: Interview/Self Monitoring Observation #: DM1-OB-002 Date: 10/25/2023 I asked the following Self Monitoring-related questions and Darryl Pyawasay provided the responses (in bold), below: Where are influent and effluent samples collected? Influent samples are collected at the autosampler in the control building before treatment on the main line coming in. Effluent autosamplers are located in the control building after the Parshall flume before going to the seepage cells. Grab samples are collected from the autosampler. pH/DO samples are brought back to lab for analysis. Do you record pH/DO sample analysis time? No. Are composite samples cooled to <4C to properly preserve them during the compositing period? Yes. Do you measure the final composite sample temperature to make sure that the cooling is sufficient? Yes. Do you record these results? Yes. Is there a thermometer in the refrigerator used to store samples? Yes. Is this thermometer checked each time that it is used and are the results of the checks recorded? Yes. Are all grab samples cooled with ice, gel packs or refrigerated to <6C from the time of collection until analysis including shipping time, if applicable? Yes. Do you have a copy of the EPA approved analytical methods for each of the analyses performed at the Facility? Yes, we will provide a copy. Are the thermometers annually checked for calibration using a NIST certified thermometer or does the Facility purchase new NIST certified thermometers yearly? No. Commercial lab used? Yes, Northern Lakes Service, Crandon, WI. Do monitoring records include laboratory instrument calibration and maintenance records? Yes. Location: Interview/O&M Observation #: DM1-OB-003 Date: 10/25/2023 I asked the following O&M-related questions and Darryl Pyawasay provided the responses (in bold), below: Are all treatment units operable? Yes. Collection system information: How many miles of sewer? We will provide. 4 of 16 Neopit WWTF Inspection Date: 10/25/2023 How many lift stations? Two. How many customers or connections? 335 connections. Is the Management Plan available and does it meet the requirements in Permit Part I.B.3.6.? Yes. Summarize operator certifications: three certified wastewater operators. Sufficient sludge is wasted from treatment system at proper time intervals to maintain process efficiency. No sludge issues here. On a regular basis, operators monitor the key operating parameters? Yes, groundwater system, so once per month check DO across lagoons to check aeration. Bypasses in last 12 months? No. Does the wastewater treatment facility have an alarm system for all essential equipment? Yes, for Facility we have a SCADA linked to phones. Power, blower failure, security, and building temps trigger alarms. Lift station alarms include high level, low level, pump failures, power, etc. Are alarms sent to qualified personnel who can respond immediately to remedy the problem? Yes, via SCADA. Are routine and preventive maintenance scheduled performed and recorded? Yes. Does the Facility maintain written procedures for responding to emergencies such as power failures, floods, fires, and other natural disasters? Yes. Is a logbook kept which documents all plant activities on a daily basis? Yes. Does the Facility maintain an inventory of spare parts, either at the Facility or close by, sufficient to keep all of its treatment units operational? Yes, part of a new asset management system. Does the Facility have standby power for all treatment units? Yes, all Neopit facilities covered by dedicated generators. Is the standby power regularly exercised under load? Yes. Is septage waste accepted at the Facility? No. How do you maintain vegetation on the dikes? Burning once a year per management plan but looking into alternatives such as herbicide application. Location: Interview/Flow Monitoring Observation #: DM1-OB-004 Date: 10/25/2023 I asked the following Flow Monitoring-related questions and Darryl Pyawasay provided the responses (in bold), below: What type of influent meter is used? Rosemont mag meter. What type of effluent meter is used? Parshall flume with flow sensor. Are influent and effluent flow measuring devices professionally calibrated at least once per year? Yes, calibrated yearly, last time in August 2023. Do Facility personnel check the calibration of the flow measuring devices, between the annual professional calibrations? Yes, but not often, twice in several years. If yes, do Facility personnel record the results of these additional tests, and are the results within 10 percent accuracy? No. Location: SSOs/SSOs Observation #: DM1-OB-005 Date: 10/25/2023 I asked Darryl Pyawasay if they experienced any backups or overflows in the sanitary sewer collection system, including lift stations, manholes and piping since the last inspection? He said no and added that he was aware of some lateral backups due to "customer issues". 5 of 16 Neopit WWTF Inspection Date: 10/25/2023 Location: Physical Inspection/Neopit WTF Observation #: DM1-OB-006 Date: 10/25/2023 Weather: rain, cool We completed the interview portion of inspection at 10:00 am CT and drove to the Neopit wastewater treatment facility to conduct the physical inspection. Physical Inspection observations are documented in the Photo Log (see Appendix 1). The physical inspection concluded at 10:45 am CT on October 25, 2023. Photo(s) 1. NEOP0325.JPG 2. NEOP0326.JPG 3. NEOP0327.JPG 4. NEOP0328.JPG 5. NEOP0329.JPG 6. NEOP0331.JPG 7. NEOP0332.JPG 8. NEOP0333.JPG 9. NEOP0334.JPG 10. NEOP0335.JPG 11. NEOP0336.JPG 12. NEOP0337.JPG SECTION III - SAMPLING ACTIVITIES AND ANALYTICAL RESULTS No sampling was conducted. SECTION IV - AREA OF CONCERN Areas of Concern may not be in sequential order. The presentation of Areas of Concern does not constitute a formal compliance determination or violation. AOC Reference #: DM1-OB-002 Location: Interview/Self Monitoring Regulation and/or Permit Requirement Permit Part I.B.2: Monitoring Requirements and Limitations. pH grab samples to be analyzed in the field and immediately after collection. Permit Part II.B.1: Proper Operations and Maintenance. The permittee shall at all times properly operate and maintain all facilities and systems of treatment and control (and related appurtenances) which are installed or used by the permittee to achieve compliance with the conditions of this permit. Proper operation and maintenance also includes adequate laboratory controls and appropriate quality assurance procedures. 6 of 16 Neopit WWTF Inspection Date: 10/25/2023 AOC: Effluent pH samples are collected from the autosampler and brought to the lab for analysis. Permit Part I.B. requires pH samples to be collected as grab samples and analyzed immediately in the field. Sample/lab bench sheets for TSS, pH, DO do not include sampler name, analyzer name, time of collection, and time of analysis. Thermometers are not checked annually for calibration using a NIST certified thermometer. AOC Reference #: DM1-OB-004 Location: Interview/Flow Monitoring Regulation and/or Permit Requirement Permit Part II.C.2: Flow Measurement. Appropriate flow measurement devices and methods consistent with accepted scientific practices shall be selected and used to ensure the accuracy and reliability of measurements of the volume of monitored discharges. The devices shall be installed, calibrated and maintained to ensure that the accuracy of the measurements is consistent with the accepted capability of that type of device. AOC: Facility personnel do not routinely check and record the calibration of the flow measuring devices, between the annual professional calibrations. AOC Reference #: DM1-OB-006 Location: Physical Inspection/Neopit WTF Regulation and/or Permit Requirement Permit Part II.B.1: Proper Operations and Maintenance. The permittee shall at all times properly operate and maintain all facilities and systems of treatment and control (and related appurtenances) which are installed or used by the permittee to achieve compliance with the conditions of this permit. AOC: Observed heavy cattails in the water along the edge of Aeration lagoon #2 (Photo Log image NEOP0328.JPG); Observed heavy algae cover and heavy cattails on the Polishing Pond ((Photo Log image NEOP0329.JPG); and Observed heavy vegetation on Seepage cell #1 (Photo Log image NEOP0332.JPG). SECTION V - CLOSING CONFERENCE AND FOLLOW UP Closing Conference I held the inspection closing conference with Facility personnel at 11:15 AM (CT) on October 25, 2023. During the closing conference, I discussed the observations and preliminary Area of Concern identified during the inspection. Observations and Areas of Concern have not yet been evaluated for a formal compliance determination. I also provided an estimated timeframe for completing an inspection report. I requested copies of treatment flow diagram and O&M manual by Wednesday, November 1. Before concluding the inspection, I asked if there were any questions. Facility representatives had no further questions. We concluded the inspection and departed the Facility at 11:30 AM (CT) on October 25, 2023. 7 of 16 Neopit WWTF Inspection Date: 10/25/2023 Follow Up The following items were requested by the inspector at the time of the inspection. Location: DM1-RR-001 Area: O&M Requested electronic copies of treatment system flow diagrams and operations and maintenance manual. [Received via email on October 30, 2023]. Location: Interview DM1-OB-003 Area: O&M Requested Facility representatives provide the number of miles of sewer in the collection system. Location: Interview DM1-OB-002 Area: Self Monitoring Requested electronic copy of the EPA approved analytical methods for each of the analyses performed at the Facility. [Received via email on October 30, 2023]. Communication Log I received an electronic copy of the treatment system flow diagrams, collection system diagrams, operations and maintenance manual, and lab analytical methods summary from Darryl Pyawasay via email on October 30, 2023. SECTION VI - LIST OF APPENDICES 1. Photo Log 2. Document Log 8 of 16 Neopit WWTF Inspection Date: APPENDIX 1: PHOTO LOG 10/25/2023 Influent Autosampler 10/25/2023 10:28 AM No CBI Physical Inspection/Neopit WTF Noted thermometer. No PII NEOP0325.JPG Dean Maraldo 44.99051333, -88.82409833 Influent flowmeter display 10/25/2023 10:29 AM No CBI Physical Inspection/Neopit WTF No PII NEOP0326.JPG Dean Maraldo 44.99051333, -88.82409833 9 of 16 Neopit WWTF Inspection Date: 10/25/2023 Aeration lagoon #1 10/25/2023 10:29 AM No CBI Physical Inspection/Neopit WTF No PII NEOP0327.JPG Dean Maraldo 44.99051333, -88.82409833 Aeration lagoon #2 NEOP0328.JPG 10/25/2023 10:31 AM No CBI No PII Dean Maraldo Physical Inspection/Neopit WTF 44.99065, -88.82392999 Noted heavy cattails in the water along the edge of the lagoon. 10 of 16 Neopit WWTF Inspection Date: 10/25/2023 Polishing pond 10/25/2023 10:31 AM No CBI Physical Inspection/Neopit WTF Noted heavy algae cover and cattails. No PII NEOP0329.JPG Dean Maraldo 44.99051166, -88.82332333 Effluent Parshall Flume Vault 10/25/2023 10:34 AM No CBI Physical Inspection/Neopit WTF Noted flow sensor. No PII NEOP0331.JPG Dean Maraldo 44.99095833, -88.82405666 11 of 16 Neopit WWTF Inspection Date: 10/25/2023 Seepage cell #1 10/25/2023 10:35 AM No CBI Physical Inspection/Neopit WTF Noted heavy vegetation. No PII NEOP0332.JPG Dean Maraldo 44.99101666, -88.82392833 Facility backup generator 10/25/2023 10:36 AM No CBI Physical Inspection/Neopit WTF No PII NEOP0333.JPG Dean Maraldo 44.99101666, -88.82392833 12 of 16 Neopit WWTF Inspection Date: 10/25/2023 Aeration blowers (3) 10/25/2023 10:37 AM No CBI Physical Inspection/Neopit WTF No PII NEOP0334.JPG Dean Maraldo 44.99095666, -88.824105 Effluent Autosampler 10/25/2023 10:37 AM No CBI Physical Inspection/Neopit WTF Noted thermometer and clear tubing. No PII NEOP0335.JPG Dean Maraldo 44.99079833, -88.82412833 13 of 16 Neopit WWTF Inspection Date: 10/25/2023 Effluent flowmeter display 10/25/2023 10:38 AM No CBI Physical Inspection/Neopit WTF No PII NEOP0336.JPG Dean Maraldo 44.99079833, -88.82412833 Daily operations log and seepage cell rotation log 10/25/2023 10:38 AM No CBI No PII Physical Inspection/Neopit WTF Seepage cells are rotated monthly. NEOP0337.JPG Dean Maraldo 44.990905, -88.82420666 14 of 16 Neopit WWTF Inspection Date: APPENDIX 2: DOCUMENT LOG Document Name NPDES Permit WI0073059 Neopit Detailed Facility Report source: EPA-ECHO Neopit Facility Drawing and Schematics Neopit O&M Manual Lab Methods Summary 10/25/2023 Contains CBI or PII Date Received No 10/23/2023 No 10/23/2023 Yes 10/30/2023 No 10/30/2023 No 8/29/2023 Pages 28 7 38 78 1 Attached to Report? No No No No Yes 15 of 16 Neopit WWTF Inspection Date: 10/25/2023 16 of 16