Document pBjpbqGv9z691bwekxdvVeYqa

EPA REGION 10 Enforcement and Compliance Assurance Division INSPECTION REPORT Inspection Entry Date/Time Inspection Exit Date/Time Weather Media Statute(s)/Program(s) Type of Inspection 11/07/2023 10:30 AM (PT) Announced: No 11/07/2023 03:45 PM (PT) Access: Granted 57F, Cloudy Water Clean Water Act, NPDES, WWTP Compliance Evaluation Inspection Permittee Name Facility Name Facility Address City, State, Zip Code County Facility GPS Coordinates City of Lafayette Lafayette Sewage Treatment Plant 260 SE Madison Street Lafayette, Oregon 97127 Yamhill 45.239149, -123.112026 FRS ID Permit Number SIC 110006696316 OR0022551 4952 (Sewage Treatment) Lead Inspector: RAYMOND ANDREWS Date: 2024.01.08 09:34:44 -08'00' Digitally signed by RAYMOND ANDREWS Raymond Andrews EPA Region 10 andrews.raymond@epa.gov (206) 553-4252 Supervisor Review: PETER CONTRERAS Date: 2024.01.08 10:24:59 -08'00' Digitally signed by PETER CONTRERAS Peter Contreras EPA Region 10 contreras.peter@epa.gov (206) 553-6708 City of Lafayette STP OR0022551 SECTION I - Opening Conference I arrived at the Lafayette Sewage Treatment Plant (the "Site" or "Facility"), located at 260 SE Madison St, Lafayette, Oregon, at 10:30 AM (PT) on 11/07/2023 for an unannounced inspection. I presented my credentials to Chad Snyder and I informed him I was there to conduct an inspection to determine compliance with the Clean Water Act (CWA) and the facility's National Pollutant Discharge Elimination System (NPDES) permit, permit # OR0022551. This report is based on information supplied by City of Lafayette representatives, my direct observations, and records and reports maintained by the permittee. In addition, information gathered prior to or after the Inspection from a review of EPA, State, and/or public records may be included in this report. Attendees Organization EPA Region 10 Attendee Name Raymond Andrews Title Lead Inspector Present in Opening Conf. Yes Present in Closing Conf. Yes City of Lafayette Chad Snyder Public Works Director Yes Yes City of Lafayette Ron Layne WWTP Operator Yes Yes Facility Information Responsible Official Mayor Hillary Malcomson; hmalcomson@ci.lafayette.or.us STP Service Population The facility serves a population of approximately 4,700. Industrial Users? The facility does not receive waste from industrial users. Does the facility accept waste from septage haulers? The facility does not accept waste from septage haulers. Hours of Operation The facility is fully staffed Monday through Friday from 0700 until 1700, and on Saturday, Sunday & Holidays from 0700 until 0900. An on-call operator is available 24/7 to address any issues that arise during off hours. What type of failure alarm does the plant have? The facility has a supervisory control and data acquisition (SCADA) system which sends a message to the on-call operator if a problem is detected. STP Design Capacity & The facility has a design flow of 0.63 million gallons per day (mgd) with a peak daily flow Average Daily Flow of 1.89 mgd. The facility has an average daily flow of 0.55 mgd. Type of primary flow The facility uses an ultrasonic flow measuring device which is calibrated annually by the measuring device? manufacturer or a contractor. Receiving Water South Yamhill River Number of Outfalls The facility has a single outfall. How often do you visually inspect the outfall? The outfall is submerged for a large part of the year, so it is not visually inspected on a schedule. The outfall is inspected when the water level is low enough. How are biosolids managed? Biosolids are allowed to settle in two storage lagoons. Every two years, a contractor dredges the lagoons, collects the solids, and hauls them away. Page 2 of 9 City of Lafayette STP OR0022551 Has there been any The facility has not had any bypasses or overflows in the past year. bypasses or overflows in the last year? Does the facility have The facility has emergency generators that automatically start in the event of a power back-up power? failure. The generators power the entire facility. Are there any plans to Currently, there are no plans to increase facility capacity. renovate the facility to allow for increased wastewater flow? Is any part of the facility nonoperational? The facility is fully operational. Does the facility conduct laboratory analysis in-house? The facility uses a contract lab to conduct all laboratory analysis except for pH, temperature, and E coli. The contract lab is: Edge Analytical Laboratories 1620 South Walnut Street Burlington, Washington 98233 (800) 755-9295 SECTION II - Observations Location: Laboratory Observation #: RA1-OB-001 Date: 11/07/2023 The pH 10 buffer solution used to calibrate the pH meter was expired. Weather: 57F, Cloudy SECTION III - Records Review Records may not be in sequential order. Record: Other - Chain of Custody Documents and Laboratory Analysis Ref #: RA1-RR-007 Reviewed By: Raymond Andrews AOC: No Reviewed Date: 11/07/2023 I reviewed the Facility's chain-of-custody and laboratory analysis documents from November 2021 through October 2023. The documents appeared to be in order and contain all the required information. Record: Permit AOC: No Ref #: RA1-RR-006 Reviewed By: Raymond Andrews Reviewed Date: 11/07/2023 I reviewed the facility's National Pollutant Discharge Elimination System (NPDES) Permit, permit # OR0022551. The permit was issued by ODEQ on September 30, 2020, with an effective date of November 1, 2020, and an expiration date of August 31, 2025. Record: Other - EPA's Integrated Compliance Information System (ICIS) Database Report AOC: Yes Ref #: RA1-RR-005 Reviewed By: Raymond Andrews Reviewed Date: 11/07/2023 I reviewed data in EPA's Integrated Compliance Information System (ICIS) Database covering the period from November 2018 through October 2023. I found 1,131 effluent exceedances over a 17-month period from October 2019 through August 2023. A list of parameter exceedances can be found in Appendix 2, Table 1. I found seven Discharge Monitoring Reports (DMRs) that were submitted late or incomplete. A list of those DMRs can be found in Appendix 2, Table 2. Page 3 of 6 Record: Other - ODEQ Inspection Report Ref #: RA1-RR-004 Reviewed By: Raymond Andrews City of Lafayette STP OR0022551 AOC: No Reviewed Date: 11/07/2023 I reviewed an inspection report for an inspection conducted by ODEQ on December 8, 2022. ODEQ found Areas of Concern that included: numerous effluent exceedance violations, nine instances of failure to submit noncompliance reports between October 2019 and September 2022, failure to submit four complete discharge monitoring reports (DMRs) in 2022, and failure to monitor various parameters between September 2019 and August 2022. Record: Other - Oregon Department of Environmental Quality (ODEQ) Mutual Agreement and Final Order (MAFO) AOC: No Ref #: RA1-RR-003 Reviewed By: Raymond Andrews Reviewed Date: 11/07/2023 I reviewed the Mutual Agreement and Final Order (MAFO) between ODEQ and the facility. The MAFO was filed March 30, 2022. The facility agreed to a penalty of $5,111, after mitigation due the facility agreeing to complete an ODEQ approved Supplemental Environmental Project (SEP). The MAFO required the facility to repair, install, or replace equipment due to exceedances of effluent limits. The required equipment changes included replacing the alum pumps, adjusting the facility's SCADA system, and purchasing a certified thermometer. Record: Other - Quality Assurance (QA) Plan AOC: Yes Ref #: RA1-RR-002 Reviewed By: Raymond Andrews Reviewed Date: 11/07/2023 I reviewed the facility's Quality Assurance (QA) Plan, dated 2023. The QA Plan appeared to be in draft form. It did not have a date other than the year and was not signed and did not appear to have been reviewed. The QA Plan ("Plan") did not meet the requirements of the Permit. The Plan did not contain sufficient information and was lacking details on equipment maintenance, quality control activities, and data handling procedures. Record: Other - Emergency Response Plan AOC: No Ref #: RA1-RR-001 Reviewed By: Raymond Andrews Reviewed Date: 11/07/2023 I reviewed the facility's Sanitary Sewer Overflow Emergency Response Plan, dated December 2015. The Plan was prepared for the City by: Tetra Tech 15350 SW Sequoia Parkway, Suite 220 Portland, Oregon 97224 (503) 598-0583 The Plan appeared to meet the minimum requirements of the Permit. SECTION IV - Sampling Activities No sampling was conducted. Page 4 of 6 SECTION V - Areas of Concern City of Lafayette STP OR0022551 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 #: RA1-OB-001 Location: Laboratory Permit Requirement Schedule B, Part 3, Table 3 of the Permit requires the facility to monitor pH to ensure it the pH of the effluent is between a minimum of 6.2, and a maximum of 9.0. AOC: The pH 10 buffer solution used to calibrate the pH meter was expired as can be seen in the photos below. AOC Reference #: RA1-RR-002 Records Review: Other - Quality Assurance (QA) Plan Permit Requirement Schedule B.2.c.i of the Permit states, "The permittee must develop and implement a written Quality Assurance Plan that details the facility sampling procedures, equipment calibration and maintenance, analytical methods, quality control activities and laboratory data handling and reporting. The QA/QC program must conform to the requirements of 40 CFR 136.7. AOC: The QA Plan ("Plan") did not meet the requirements of the Permit. The Plan did not contain sufficient information and was lacking details on equipment maintenance, quality control activities, and data handling procedures. AOC Reference #: RA1-RR-005 Records Review: Other - EPA's Integrated Compliance Information System (ICIS) Database Report Permit Requirement Schedule A.1 of the Permit states "...the Permittee must comply..." with the effluent limits established in Table A1 of the Permit. AOC: I found 1,131 effluent exceedances over a 17-month period from October 2019 through August 2023. A list of parameter exceedances can be found in Appendix 2, Table 1. Page 5 of 6 City of Lafayette STP OR0022551 AOC Reference #: RA1-RR-005 Records Review: Other - EPA's Integrated Compliance Information System (ICIS) Database Report Permit Requirement Schedule B.1 of the Permit states "...must submit to DEQ monitoring results and reports..." as shown in Table B1. Table B1 requires that all monitoring data be submitted by the 15th of the month following the end of the monitoring period. AOC: I found seven Discharge Monitoring Reports (DMRs) that were submitted late or incomplete. A list of those DMRs can be found in Appendix 2, Table 2. SECTION VI - Closing Conference I held a closing conference with facility personnel at 03:45 PM (PT) on 11/07/2023. During the closing conference, I discussed my observations and Areas of Concern identified during the inspection and records review. Observations and Areas of Concern have not yet been evaluated for a formal compliance determination. SECTION VII - List of Appendices 1. Photo Log 2. DMR and Effluent Exceedance Tables Page 6 of 6 APPENDIX 1: Photo Log All photos were taken by Lead EPA Inspector, Ray Andrews, during the inspection. Photos were not manipulated beyond minor cropping for sizing and labels or callouts to draw attention to the subject of the photo. All photos taken during the inspection are included in the Photo Log; however, only photos that support an Area of Concern are included in the inspection report. P1010843 - pH 10 Buffer Solution, expired, photo 1 P1010844 - pH 10 Buffer Solution, expired, photo 2 P1010845 - Influent Flow Meter P1010846 - Influent Auto Sampler P1010847 - Dissolved Oxygen Meter Readout Panel, photo 1 P1010848 - Dissolved Oxygen Meter Readout Panel, photo 2 P1010849 - Effluent Auto Sampler APPENDIX 2: Effluent Exceedance and DMR Tables Table 1. Effluent Exceedance Areas of Concern Month Parameter DMR Value October 2019 BOD, 5-day, 20C 14.41 October 2019 BOD, 5-day, 20C 26 October 2019 TSS 34.39 October 2019 TSS 98.5 October 2019 Phosphorus 9.91 October 2019 Solids, susp % rmvl 66.43 July 2020 Phosphorus 9.16 July 2020 Excess thermal load 4.5 August 2020 BOD, 5-day, 20C 15.35 August 2020 BOD, 5-day, 20C 26.5 August 2020 Phosphorus 8.67 August 2020 E. coli 2420. August 2020 Excess thermal load 4.81 September 2020 Phosphorus 2.17 September 2020 Excess thermal load 5.33 October 2020 BOD, 5-day, 20C 13.06 October 2020 BOD, 5-day, 20C 15.5 October 2020 TSS 22 October 2020 Phosphorus 6.96 February 2022 Ammonia 30 March 2022 BOD, 5-day, 20C 256.27 March 2022 BOD, 5-day, 20C 281.94 March 2022 TSS 50 March 2022 TSS 470.21 March 2022 TSS 585.39 May 2022 BOD, 5-day, 20C 17.6 May 2022 BOD, 5-day, 20C 37.5 May 2022 TSS 14.1 May 2022 TSS 32.6 June 2022 BOD, 5-day, 20C 69 June 2022 BOD, 5-day, 20C 78 June 2022 BOD, 5-day, 20C 100.3 June 2022 BOD, 5-day, 20C 104 June 2022 BOD, 5-day, 20C 126.41 June 2022 TSS 27.9 June 2022 TSS 48 June 2022 Ammonia 14.04 June 2022 Ammonia 26 June 2022 BOD, 5-day, % rmvl 68 July 2022 BOD, 5-day, 20C 45.6 July 2022 BOD, 5-day, 20C 78 July 2022 BOD, 5-day, 20C 83.4 July 2022 TSS 18.3 July 2022 TSS 28.3 July 2022 Ammonia 23.61 July 2022 Ammonia 30.7 July 2022 BOD, 5-day, % rmvl 77 August 2022 BOD, 5-day, 20C 24.3 August 2022 BOD, 5-day, 20C 56 August 2022 TSS 14.9 Permit Limit 10 15 10 15 1.2 85 2.8 4.2 10 15 1.2 406 4.2 1.2 4.2 10 15 15 2.8 20.2 210 280 45 210 280 10 15 10 15 10 50 75 15 100 10 15 11 20.2 85 10 15 75 10 15 11 20.2 85 10 15 10 Unit mg/L mg/L mg/L mg/L lb/d % lb/d kcal/d mg/L mg/L lb/d #/100mL kcal/d lb/d kcal/d mg/L mg/L mg/L lb/d mg/L lb/d lb/d mg/L lb/d lb/d mg/L mg/L mg/L mg/L mg/L lb/d lb/d mg/L lb/d mg/L mg/L mg/L mg/L % mg/L mg/L lb/d mg/L mg/L mg/L mg/L % mg/L mg/L mg/L Limit Type Mon Avg Wkly Avg Mon Avg Wkly Avg Mon Avg Mo Av Mn Mon Avg Wkly Avg Mon Avg Wkly Avg Mon Avg Daily Max Wkly Avg Mon Avg Wkly Avg Mon Avg Wkly Avg Wkly Avg Mon Avg Daily Max Wkly Avg Daily Max Wkly Avg Wkly Avg Daily Max Mon Avg Wkly Avg Mon Avg Wkly Avg Mon Avg Mon Avg Wkly Avg Wkly Avg Daily Max Mon Avg Wkly Avg Mon Avg Daily Max Mo Av Mn Mon Avg Wkly Avg Wkly Avg Mon Avg Wkly Avg Mon Avg Daily Max Mo Av Mn Mon Avg Wkly Avg Mon Avg # Violations 31 7 31 7 31 31 31 7 31 7 31 1 7 30 7 31 7 7 31 1 7 1 7 7 1 31 7 31 7 30 30 7 7 1 30 7 30 1 30 31 7 7 31 7 31 1 31 31 7 31 Month August 2022 August 2022 August 2022 September 2022 September 2022 September 2022 October 2022 October 2022 November 2022 June 2023 July 2023 July 2023 July 2023 August 2023 August 2023 Parameter TSS Ammonia Ammonia BOD, 5-day, 20C TSS TSS TSS TSS pH TSS TSS TSS Phosphorus TSS Phosphorus DMR Value 23 27 37 23 14.4 31.5 13 18.2 8 13 21 112.3 3.42 15.6 2.4 Permit Limit 15 11 20.2 15 10 15 10 15 9 10 10 100 1.2 10 1.2 Unit mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L SU mg/L mg/L lb/d lb/d mg/L lb/d Limit Type Wkly Avg Mon Avg Daily Max Wkly Avg Mon Avg Wkly Avg Mon Avg Wkly Avg Daily Max Mon Avg Mon Avg Daily Max Mon Avg Mon Avg Mon Avg # Violations 7 31 1 7 30 7 31 7 1 30 31 1 31 31 31 Table 2. DMR Areas of Concern Monitoring Period End DMR Due Date 12/31/2019 1/15/2020 7/31/2020 8/15/2020 11/30/2020 12/15/2020 7/31/2021 9/30/2021 5/31/2022 7/31/2022 8/15/2021 10/15/2021 6/15/2022 8/15/2022 DMR Received Date 6/5/2020 9/15/2020 12/14/2020 9/15/2021 11/24/2021 1/3/2023 2/7/2023 Notes Late/Incomplete. Missing BOD, 5-day, % removal, and Solids, suspended % removal Incomplete. Missing E. Coli Incomplete. Missing Ammonia, pH, Temperature, and Alkalinity Late. Phosphorus data was submitted late. Late. Late. Late.