Document vVB3DEZx2EqMpJ0gDzBJ7Lm4Y

EPA REGION 10 Enforcement and Compliance Assurance Division INSPECTION REPORT Inspection Entry Date/Time Inspection Exit Date/Time Weather Media Statutes/Programs Type of Inspection 06/04/2024 09:00 AM (AKT) Announced: Yes 06/04/2024 02:15 PM (AKT) Access: Granted 50F, Drizzly Water Clean Water Act, NPDES, WWTP Compliance Evaluation Inspection Permittee Name Facility Name Facility Address City, State, Zip Code Borough Facility GPS Coordinates Mailing Address City, State, Zip Code Full Cycle - Power Systems and Supplies of Alaska Ward Cove Industrial and Maritime Center 7037 N Tongass Hwy Ketchikan, Alaska 99901 Ketchikan Gateway 55.408382, -131.726632 P.O. Box 772 Ward Cove, Alaska 99928 FRS ID Permit Number SIC 110003045259 AK0053384 4952 (Sewerage Systems) Regulatory Representatives Participating in Inspection: Title Name Inspector Katrina Chambon Organization EPA Region 10 Lead Inspector: RAYMOND ANDREWS Date: 2024.07.26 08:48:52 -07'00' Digitally signed by RAYMOND ANDREWS Raymond Andrews EPA Region 10 andrews.raymond@epa.gov (206) 553-4252 Supervisor Review: PETER CONTRERAS Date: 2024.07.26 09:20:33 -07'00' Digitally signed by PETER CONTRERAS Peter Contreras EPA REGION 10 contreras.peter@epa.gov (206) 553-6708 Ward Cove Industrial and Maritime Center NPDES Permit #AK0053384 SECTION I - Opening Conference I arrived at the Ward Cove Industrial and Maritime Center (the "Site" or "Facility"), located at 7037 N Tongass Hwy, Ketchikan, at 09:00 AM (AKT) on 06/04/2024 for an announced inspection. I was accompanied by Katrina Chambon, an Inspector in Training, who was there to assist with the inspection and observe inspection procedures. I presented my credentials to Stephen Bradford and informed him I was there to determine compliance with the Clean Water Act (CWA), and the facility's National Pollutant Discharge Elimination System (NPDES) permit, permit # AK0053384. This report is based on information supplied by facility representatives, direct observations made by me, and records and reports maintained by the facility. 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 EPA REGION 10 Katrina Chambon Inspector Yes Yes Ward Cove Group Stephen Bradford Executive Vice Yes No President Full Cycle LLC Paul Manabat Operations Yes No Administrator Full Cycle LLC Greg Black Operations Manager Yes No Facility Information Responsible official Design Capacity & Average Daily Flow Hours of operation? Describe the flow path. Number of Outfalls? Type of primary flow meter. What failure alarm does the plant have? Stephen Bradford, stephen@wcgak.com The facility has a design flow capacity of 0.025 million gallons per day (mgd), i.e.,25,000 gallons per day, and an average daily flow of 0.005mgd, i.e. 5,000 gallons per day. The facility operates Monday through Friday from 8am until 5pm. The facility employs a full-time operator with a part time operator available as needed. The facility has an oncall person for weekends, holidays, and evenings. Influent enters a 15,000-gallon receiving tank. From the receiving tank, the wastewater goes through a filter augur to remove large solids and then continues to the aerated 100,000-gallon vault. From the vault, the influent goes through a belt filter press. From the belt press, solids go into a container for pick-up and disposal by a 3rd party. The liquids go into a 12,000 holding tank from the holding tank, the wastewater is pumped to the treatment plant where it goes through secondary aeration and chlorine disinfection. After chlorine disinfection, the waste stream mixes with lake water and is then discharged into Ward Cove. There is no dechlorination prior to discharge. The facility has a single submerged outfall, which discharges into Ward Cove. The outfall was last inspected in 2019 during an EPA requested survey required prior to the building of a new dock. The facility uses an ultrasonic flow meter. The facility does not have a failure alarm. 2 of 5 Ward Cove Industrial and Maritime Center NPDES Permit #AK0053384 Does the facility have The facility has a back-up generator in case of power failure. The generator back-up power? automatically activates during a failure and powers the entire treatment plant. How do you manage Sludge is collected and sent through a filter press for dewatering. After dewatering, the your biosolids? sludge is collected by a third party and hauled away. Has the facility had any bypasses, overflows, or hydraulic overloads in the last year? The facility has not had any bypasses, overflows, or hydraulic overloads in the last year. Does the facility have The facility does not have emergency storage capacity. overflow/emergency storage capacity? Industrial Users The facility does not have any industrial users but receives septage from residential citizens that are not covered by a municipal wastewater treatment facility. The septage volume is approximately 150,000 gallons a month and has no observable impact on facility operations. Are there any plans for renovation? The facility is in the planning stages of adding additional flow capacity. Is any portion of the plant nonoperational? The entire facility is operational. Do you use in-house or contract out for laboratory analyses? The facility's in house lab analyzes all pollutant parameters except for copper and ammonia. Copper and ammonia samples are sent to a contract lab for analysis. The contract lab is: Fremont Analytical 3600 Freemont Avenue North Seattle, Washington 98103 (206) 352-3790 SECTION II - Observations On the site tour, I did not make any observations that would constitute an area of concern. SECTION III - Records Review Records may not be in sequential order. Record: Other - Operations and Maintenance (O&M) Plan Ref #: RA1-RR-004 Reviewed By: Raymond Andrews AOC: Yes Reviewed Date: 06/04/2024 At the time of inspection, Katrina Chambon reviewed the facility's Operations & Maintenance (O&M) plan. She found, the O&M plan had the manuals for the various machinery that compose the treatment system, but did not contain specific SOPs for staff to explain operational procedures, there was no documentation showing the O&M plan is being updated annually, the O&M Plan did not contain best management practices (BMPs). Record: Laboratory Analysis Reports AOC: No Ref #: RA1-RR-003 Reviewed By: Raymond Andrews Reviewed Date: 06/04/2024 At the time of inspection, I reviewed lab reports and chain of custody documents from Jan 2023 through May 2024. The documents appeared to be complete and accurate. I did not note any areas of concern. 3 of 5 Ward Cove Industrial and Maritime Center NPDES Permit #AK0053384 Record: Other - Integrated Compliance Information System (ICIS) Database Ref #: RA1-RR-002 Reviewed By: Raymond Andrews AOC: Yes Reviewed Date: 06/04/2024 Prior to the inspection, I ran a deficiency report from EPA's ICIS data based for the period from June 2019 through May 2024. I found the facility exceeded its effluent parameters 641 times over 26 months during the period reviewed. A list of those exceedances is in a table in Appendix 2. Record: Other - Quality Assurance (QA) Plan AOC: Yes Ref #: RA1-RR-001 Reviewed By: Raymond Andrews Reviewed Date: 06/04/2024 At the time of the inspection, I reviewed the facility QA Plan. The QA Plan map did not include the sampling point. The QA plan did not include the qualifications and training of personnel, sample shipping requirements and laboratory data delivery requirements. SECTION IV - Sampling Activity No sampling was conducted. SECTION V - 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-001 Records Review: Other - Quality Assurance (QA) Plan Permit Requirement Part 2.1.5.2 of the permit states that "At a minimum, a QAPP must include...maps indicating the location of all permit required sampling points..." AOC: The QA Plan map did not include the sampling point. AOC Reference #: RA1-RR-001 Records Review: Other - Quality Assurance (QA) Plan Permit Requirement Part 2.1.5.3 of the permit states, " At a minimum, a QAPP must include...qualification and training of personnel..." AOC: The QA plan did not include the qualifications and training of personnel. AOC Reference #: RA1-RR-001 Records Review: Other - Quality Assurance (QA) Plan Permit Requirement Part 2.1.5.1 of the permit states, "At a minimum, a QAPP must include...sample shipping methods, and laboratory data delivery requirements..." AOC: The QA plan did not include sample shipping requirements and laboratory data delivery requirements. AOC Reference #: RA1-RR-002 Records Review: Other - Integrated Compliance Information System (ICIS) Database Permit Requirement Part 1.2.1 of the permit states, in part, "The permittee must comply with effluent limitations in the table(s) at all times unless otherwise indicated, regardless of monitoring frequency or reporting required by other provisions of this permit." AOC: The facility exceeded its effluent parameters 641 times over 26 months. 4 of 5 Ward Cove Industrial and Maritime Center NPDES Permit #AK0053384 AOC Reference #: RA1-RR-004 Records Review: Other - Operations and Maintenance (O&M) Plan Part 2.2.3 of the permit states, "The O&M Plan must be reviewed annually. Documentation of annual plan review by the permittee shall be retained onsite and made available to DEC upon request." AOC: There was no documentation showing the O&M plan was being reviewed annually. AOC Reference #: RA1-RR-004 Records Review: Other - Operations and Maintenance (O&M) Plan Permit Requirement Part 2.2.4 of the permit states, "The permittee shall ensure that the O&M Plan includes appropriate best management practices (BMPs). BMPs include measures that prevent or minimize the generation and potential for the release of pollutants to Ward Cove." AOC: The O&M Plan did not contain best management practices (BMPs). SECTION VI - Closing Conference I held a closing conference with facility personnel at 02:15 PM (AKT) on 06/04/2024 for the inspection. During the closing conference, I discussed observations and Areas of Concern I identified during the inspection. Observations and Areas of Concern have not yet been evaluated for a formal compliance determination. SECTION VII - List of Appendices 1. Photo Log 2. Effluent Exceedances Table 5 of 5 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 Observation or Area of Concern are included in the inspection report. P1010955 - Sampling Point P1010956 - Blowers (Aerators) P1010957 - 15,000 gallon Receiving Tank P1010958 - Shoreside Discharge Notification Sign, photo 1 P1010599 - Shoreside Discharge Notification Sign, photo 2 P1010960 - General Area of Outfall APPENDIX 2: Effluent Exceedances Table Month Parameter June 2019 June 2019 June 2019 July 2019 July 2019 August 2019 August 2019 September 2019 September 2019 September 2019 September 2019 October 2019 November 2019 December 2019 December 2019 December 2019 January 2020 January 2020 January 2020 January 2020 February 2020 February 2020 March 2020 March 2020 March 2020 March 2020 March 2020 March 2020 March 2020 March 2020 April 2020 June 2020 July 2020 July 2020 August 2020 August 2020 October 2020 November 2020 December 2020 January 2021 January 2021 March 2021 May 2021 May 2021 May 2021 May 2021 June 2021 August 2021 October 2022 October 2022 January 1900 January 2024 January 2024 April 2024 TRC TRC pH TRC pH TSS TSS Coliform, fecal Coliform, fecal pH TRC pH Coliform, fecal TSS TSS pH TSS TSS TSS TSS TSS Coliform, fecal TSS TSS TSS TSS TSS TSS Coliform, fecal TRC TRC Coliform, fecal Coliform, fecal Coliform, fecal TRC Coliform, fecal Coliform, fecal TSS Coliform, fecal Coliform, fecal Coliform, fecal pH Coliform, fecal Coliform, fecal Coliform, fecal Coliform, fecal pH Enterococci Coliform, fecal pH Coliform, fecal TRC pH pH DMR Value .24 1.16 6.31 .1 5.7 7.3 35 731 2800 6.44 .08 6.4 870 6.95 33 6.2 12.09 12.09 58 58 39 490 11.54 11.54 18.08 55 55 87 2100 .11 .1 30 18 81 1.09 60 20 32 19400 31000 78 9.39 8570 9410 46.1 118. 5.78 74 896 6.35 92 17.22 6.28 6.28 Permit Limit .21 1 6.5 2 6 6.3 30 200 800 6.5 .0075 6.5 800 6.3 30 6.5 6.3 9.4 30 45 30 200 6.3 9.4 12.6 30 45 60 800 .0075 .0075 14 14 43 1 43 14 30 800 800 43 8.5 200 800 14 43 6 35 800 6.5 43 17 6.5 6.5 Unit lb/d mg/L SU mg/L SU lb/d mg/L #/100mL #/100mL SU mg/L SU #/100mL lb/d mg/L SU lb/d lb/d mg/L mg/L mg/L #/100mL lb/d lb/d lb/d mg/L mg/L mg/L #/100mL mg/L mg/L #/100mL #/100mL #/100mL mg/L #/100mL #/100mL mg/L #/100mL #/100mL #/100mL SU #/100mL #/100mL #/100mL #/100mL SU CFU/100mL #/100mL SU #/100mL mg/L SU SU % Exceedance 14 16 3 95 5 16 17 266 250 1 967 2 9 10 10 5 92 29 93 29 30 145 83 23 43 83 22 45 163 1,367 1,233 114 29 88 9 40 43 7 2,325 3,775 81 10 4,185 1,076 229 174 4 111 12 2 114 1 3 3 Limit Type Daily Mx Daily Mx Inst Min Minimum Inst Min Mo Avg Mo Avg Mo Geomn Daily Mx Inst Min Daily Mx Inst Min Daily Mx Mo Avg Mo Avg Inst Min Mo Avg Wkly Avg Mo Avg Wkly Avg Mo Avg Mo Geomn Mo Avg Wkly Avg Daily Mx Mo Avg Wkly Avg Daily Mx Daily Mx Daily Mx Daily Mx Mo Geomn Mo Geomn Daily Mx Daily Mx Daily Mx Mo Geomn Mo Avg Daily Mx Daily Mx Daily Mx Daily Mx Mo Geomn Daily Mx Mo Geomn Daily Mx Minimum Mo Geomn Daily Mx Daily Mn Daily Mx Daily Mx Daily Mn Daily Mn # Violations 1 1 1 31 1 31 31 30 1 1 1 1 1 31 31 1 31 7 31 7 29 29 31 7 1 31 7 1 1 1 1 30 31 1 1 1 31 30 1 1 1 1 31 1 31 1 1 31 1 1 1 1 1 1