Document rmr5eyq2brmDx8RQGw2QzqM7

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 11/08/2023 10:20 AM (PT) Announced: No 11/08/2023 03:10 PM (PT) Access: Granted 55F, Sunny 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 Rainier Rainier Sewage Treatment Plant 106 West 6th Street Rainier, Oregon 97048 Columbia 46.091976, -122.943336 FRS ID Permit Number SIC 110006696478 OR0020389 4952 (Sewage Treatment) Lead Inspector: RAYMOND ANDREWS Date: 2024.01.08 08:58:44 -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 10:28:40 -08'00' Digitally signed by PETER CONTRERAS Peter Contreras EPA Region 10 contreras.peter@epa.gov (206) 553-6708 Page 1 of 8 City of Rainier STP OR0020389 SECTION I - Opening Conference I arrived at the Rainier Sewage Treatment Plant (the "Site" or "Facility"), located at 106 W 6th St, Rainier, Oregon, at 10:20 AM (PT) on 11/08/2023 for an unannounced inspection. I presented my credentials to Sue Lawrence and informed her 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 # OR0020389. This report is based on information supplied by the City of Rainier 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 Attendee Name Title Present in Opening Conf. Present in Closing Conf. EPA Region 10 Raymond Andrews Lead Inspector Yes Yes City of Rainier Sue Lawrence Public Works Director Yes Yes (Outgoing) City of Rainier Patrick McCoy Public Works Director Yes Yes (Incoming) City of Rainier Alexandria Acevedo Operator Yes Yes City of Rainier Jerry Cold Mayor Yes Yes City of Rainier W. Scott Jorgensen City Administrator Yes Yes Facility Information Responsible Official Mayor Jerry Cold; mayor@cityofrainier.com STP Service Population The facility serves a population of approximately 2,075. Industrial Users? The facility does not receive waste from industrial users. Does the facility accept waste from septage haulers? The facility receives an average of 2,500 gallons per day (gpd) of septage. The additional waste does not affect the system's functioning. Hours of Operation The facility is staffed Monday through Friday from 0800 until 1630. On Saturdays and Sundays, the facility is staffed for two hours for routine checks. An on-call operator is available 24/7 to address any problems 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 capacity of 1.03 million gallons per day (mgd) with an Average Daily Flow average daily dry weather flow of 0.33mgd, and an average daily wet weather flow of 0.75mgd. Types of primary flow Influent flow is measured with a Parshall Flume and level. Effluent flow is measured measuring devices? with a V-notch weir. The flow measuring devices are inspected weekly. Receiving Water Columbia River Number of Outfalls The facility has a single outfall. 2 of 6 How often do you visually inspect the outfall? The outfall discharge point is 20 feet underwater, so the facility is unable to make a direct observation of the outfall. How do you manage Biosolids are collected and hauled to Wasco County landfill. your biosolids? Has there been any The facility has not had any unreported bypasses or overflows in the past 12 months. 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 for renovation or additional equipment to allow for increased wastewater flow? The facility is in the planning stages of implementing facility upgrades to increase flow capacity. Is any part of the facility nonoperational? The facility is fully operational. Does the facility conduct laboratory analysis in-house? The facility analyzes most parameters in-house. A contract lab conducts quarterly analysis of alkalinity. Total Kjeldahl Nitrogen (TKN) and ammonia are sent to the contract lad annually for analysis. The contract lab is: ALS Group USA, Corp. dba ALS Environmental 1317 South 13th Avenue Kelso, Washington 98626 (360) 577-7222 SECTION II - Records Review Records may not be in sequential order. Record: Other - EPA's Integrated Compliance Information System (ICIS) Database AOC: Yes Ref #: RA1-RR-007 Reviewed By: Raymond Andrews Reviewed Date: 11/08/2023 I reviewed information submitted by the facility to EPA's ICIS database for the period from November 2018 through October 2023. I found the facility exceeded effluent parameters 418 times over a 10-month period during the time reviewed. Those exceedances can be found in Appendix 2, Table 1. During the review of the information in ICIS, I found the facility missed schedule deadlines for three documents required by MAO # WQ/M-NWR-2022-044. The missed documents can be found in Appendix 2, Table 2. 3 of 6 Record: Other - Two ODEQ Enforcement Cases (WQ-M-NWR-2022-044 and WQ-M-NWR2023-091) AOC: No Ref #: RA1-RR-006 Reviewed By: Raymond Andrews Reviewed Date: 11/08/2023 I reviewed two enforcement cases initiated by ODEQ against the City of Rainier. The first, WQ-M-NWR-2023-044, was filed by ODEQ on January 9, 2023. This was a Mutual Agreement and Order (MAO) covered permit violations from October 2021 through November 2022. ODEQ issued a penalty of $52,650 to the facility, which was mitigated to $10,530 contingent upon completion of a Supplemental Environmental Project (SEP) by December 31, 2023. After the first MAO had been finalized, ODEQ found additional permit violations, so the State issued a initiated a second administrative action. The second action, WQ-M-NWR-2023-091, was filed by ODEQ on November 7, 2023. This action was a Notice of Civil Penalty Assessment and Order (NCPAO) covered violations from December 2022 through June 2023. The State issued a penalty of $31,500, which was mitigated to $6,310 contingent upon additional funds being allocated to the SEP agreed to in the MAO filed on January 9, 2023. Per an ODEQ representative, an amendment to the initial MAO is forthcoming which will adjust the SEP deadline to September 30, 2024. Record: Other - Emergency Response and Notification Plan AOC: No Ref #: RA1-RR-005 Reviewed By: Raymond Andrews Reviewed Date: 11/08/2023 Most of the plan was missing; started on page 20; Ms. Lawrence said she would look for a complete copy and if she can't find one, she will recreate it. Record: Other - Certified Operator Report AOC: No Ref #: RA1-RR-004 Reviewed By: Raymond Andrews Reviewed Date: 11/08/2023 The report shows two certified operators: Alexandria Acevedo, Collection Operator Grade I John Dewey, Collection Operator Grade II, and Treatment Operator Grade II Record: Laboratory Analysis Reports AOC: No Ref #: RA1-RR-003 Reviewed By: Raymond Andrews Reviewed Date: 11/08/2023 I reviewed random sampling of Lab Reports: 09/2020 12/2021 06/2022 02/2023 Record: Other - Biosolids Management Plan Ref #: RA1-RR-002 Reviewed By: Raymond Andrews AOC: No Reviewed Date: 11/08/2023 I reviewed the facility's Biosolids Management Plan, dated January 12, 2012. Plan needs to be updated. The copy of the plan I reviewed was unsigned and certified. 4 of 6 Record: Calibration Records Ref #: RA1-RR-001 Reviewed By: Raymond Andrews AOC: No Reviewed Date: 11/08/2023 I reviewed the Instrument Calibration Data Sheet -for July 2022. contractor: Buell Calibration & Controls P.O. Box 722 Gresham, Oregon 97030 (5030 928-0264 Calibrations were conducted by a SECTION III - Sampling Activities No sampling was conducted. SECTION IV - Areas 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 #: RA1-RR-007 Records Review: Other - EPA's ICIS Database Permit Requirement Schedule A.1.a-c establishes effluent limitations that are not to be exceeded. AOC: The facility exceeded effluent parameters 418 times over a 10-month period during the period reviewed. Those exceedances can be found in Appendix 2, Table 1. AOC Reference #: RA1-RR-007 Records Review: Other - EPA's ICIS Database Mutual Agreement and Order Section II.11.A., Tasks 2.a, 3.a, and 3.b.i AOC: I found the facility missed schedule deadlines for three documents required by MAO # WQ/M-NWR-2022044. The missing required documents can be found in Appendix2, Table 2. SECTION V - Closing Conference I held a closing conference with facility personnel at 03:10 PM (PT) on 11/08/2023. During the closing conference, I discussed my observations and Areas of Concern identified during the inspection. Observations and Areas of Concern have not yet been evaluated for a formal compliance determination. SECTION VI - List of Appendices 1. Photo Log 2. Missing Documents and Effluent Exceedance Tables 5 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. P1010851 - Laboratory Bench Sheet, dated November 8, 2023 P1010852 - Instrument Calibration Data Sheet, Effluent Flowmeter, dated July 19, 2022 P1010853 - Instrument Calibration Data Sheet, Effluent Flowmeter, dated July 13, 2021 P1010854 - Instrument Calibration Data Sheet, Influent Flowmeter, dated July 19, 2022 P1010855 - Biosolids Management Plane, dated, January 12, 2012, page 1 P1010856 - Influent Auto-sampler P1010857 - Effluent Auto-sampler 6 of 6 APPENDIX 2: Missing Documents and Effluent Exceedance Tables Table 1. Effluent Exceedance Areas of Concern Month Parameter DMR Value Permit Limit January 2020 TSS 15 10 January 2020 TSS 71 15 January 2020 TSS 152.4 130 January 2020 TSS 423.3 250 January 2020 TSS 584 190 September 2020 TSS 12 10 September 2020 TSS 31 15 September 2020 TSS 211 130 September 2020 TSS 396.1 170 October 2020 TSS 22 15 October 2020 TSS 143. 130 October 2020 TSS 229.8 170 March 2021 pH 5.8 6 August 2021 TSS 12 10 August 2021 TSS 23 15 October 2021 BOD5,20C 19 15 October 2021 BOD5,20C 149.4 130 October 2021 BOD5,20C 260.1 170 October 2021 TSS 113 10 October 2021 TSS 388 15 October 2021 TSS 866.2 83 October 2021 TSS 3281 130 October 2021 TSS 6255.8 170 October 2021 Solids, susp % rmv 84.2 85 December 2022 BOD, 5-day,20C 254.7 250 December 2022 TSS 19 10 December 2022 TSS 48 15 December 2022 TSS 194.6 130 December 2022 TSS 676 190 December 2022 E. coli 2420 406 July 2023 pH 5.51 6 July 2023 TSS 33 10 July 2023 TSS 85 15 August 2023 pH 5.94 6 September 2023 pH 5.93 6 Unit mg/L mg/L lb/d lb/d lb/d mg/L mg/L lb/d lb/d mg/L lb/d lb/d SU mg/L mg/L mg/L lb/d lb/d mg/L mg/L lb/d lb/d lb/d % lb/d mg/L mg/L lb/d lb/d #/100mL SU mg/L mg/L SU SU Limit Type Mo Avg Wkly Avg Mo Avg Daily Max Wkly Avg Mo Avg Wkly Avg Wkly Avg Daily Max Wkly Avg Wkly Avg Daily Max Daily Min Mo Avg Wkly Avg Wkly Avg Wkly Avg Daily Max Mo Avg Wkly Avg Mo Avg Wkly Avg Daily Max Mo Av Mn Daily Max Mo Avg Wkly Avg Mo Avg Wkly Avg Daily Max Daily Min Mo Avg Wkly Avg Daily Min Daily Min # Violations 31 7 31 1 7 30 7 7 1 7 7 1 1 31 7 7 7 1 31 7 31 7 1 31 1 31 7 31 7 1 1 31 7 1 1 Table 2. Missing Scheduled Documents Scheduled Date Document April 30, 2023 September 30, 2023 September 30, 2023 Report of Preliminary Findings of an Initial Wastewater Treatment Plan Flow and Load Capacity Evaluation Proposal for an Interim Improvements Plan and Schedule Report of Field Investigation with Maps and a Proposal for Initial Peak Flow Reduction Projects