Document wDvM6kxrBQgXqGgnpjRYpyL96

Makah National Fish Hatchery WAG130004 NPDES Compliance Inspection Report Makah National Fish Hatchery Makah Tribe Neah Bay, WA NPDES Tracking Number WAG130004 Inspection Date: 09/07/2022 Prepared by: CJ Langlois U.S. Environmental Protection Agency, Region 10 Enforcement & Compliance Assurance Division Water Enforcement & Field Branch Field, Data & Drinking Water Enforcement Section Inspector Signature/Date: Langlois, Curmit Digitally signed by Langlois, Curmit Date: 2023.01.20 09:49:20 -08'00' Supervisor Signature/Date: PETER CONTRERAS Date: 2023.01.20 09:54:48 -08'00' Digitally signed by PETER CONTRERAS Makah National Fish Hatchery WAG130004 Contents I. Facility Information .......................................................................................................3 II. Inspection Information...................................................................................................4 III. Permit Information.........................................................................................................4 IV. Enforcement Background ..............................................................................................4 V. Inspection Chronology...................................................................................................5 VI. Opening Conference ......................................................................................................5 VII. Laboratory Inspection ....................................................................................................6 VIII. Site Review ....................................................................................................................6 IX. File Review ....................................................................................................................6 X. Areas of Concern ...........................................................................................................7 XI. Closing Conference........................................................................................................8 Attachment A - Aerial Image Attachment B - Photograph Log 2 of 14 Makah National Fish Hatchery WAG130004 [Unless otherwise noted, all details in this inspection report were obtained from conversations with Kristin Bates, a review of facility documents, and/or from observations made during the inspection.] I. Facility Information Facility Name: Facility Owner: Facility Operator: Physical Address: Mailing Address: Lat/Long: Facility Contacts: Permit Number: NAICS Code: Nearest Surface Water: Hoko Creek Hatchery U.S. Fish & Wildlife Service U.S. Fish & Wildlife Service 897 Fish Hatchery Rd Neah Bay, Washington 98357 P.O. Box 739 Neah Bay, Washington 98357 48.2901938, -124.6517443 Kristin Bates, Hatchery Manager Makah National Fish Hatchery Office: (360) 645-2521 Cell: 360-640-2006 Email: kristin_bates@fws.gov WAG130004 112511 (Fish Hatcheries) Tsoo-Yess River (receiving water) 3 of 14 II. Inspection Information Makah National Fish Hatchery WAG130004 Inspection Date: September 7, 2022 Inspector: CJ Langlois EPA Region 10, ECAD/WEFB/FDDWES Phone: 206-553-2739 Arrival Time: Departure Time: 11:00 a.m. 1:30 p.m. Weather: Partly Cloudy, 50 F Purpose: To evaluate compliance with the requirements of the Clean Water Act (CWA) and the National Pollutant Discharge Elimination System (NPDES) permit for Federal Aquaculture Facilities and Aquaculture Facilities Located in Indian Country within the boundaries of the State of Washington III. Permit Information On June 21, 2016, the U.S. Environmental Protection Agency (EPA) issued the National Pollutant Discharge Elimination System (NPDES) permit for Federal Aquaculture Facilities and Aquaculture Facilities within the boundaries of the State of Washington ("Permit"), permit #WAG130000. The permit became effective on August 1, 2016, and expired on July 31, 2021. Subsequently, the permit was administratively continued. On February 2, 2021, the facility submitted a Notice of Intent to discharge to EPA. On July 22, 2021, EPA Region 10's NPDES Permitting Unit (NPU) authorized the facility to discharge under NPDES tracking # WAG130004. IV. Enforcement Background 4 of 14 Makah National Fish Hatchery WAG130004 The facility had an inspection by the EPA on April 4, 2018, and has had no prior enforcement actions. V. Inspection Chronology This was an announced inspection. On July 26, 2022, I first contacted the EPA Region 10 tribal coordinator, Mahri Lowinger, for contact information for the Makah Tribe. Mahri Lowinger provided the name and contact information for Ms. Kristin Bates, the Makah National Fish Hatchery Manager. On July 26, 2022, I reached out to Ms. Bates to schedule the Clean Water Act inspection of the hatchery. On September 7, 2022, Vanessa Oquendo and myself arrived at 11:00 a.m. and I presented my credentials to Ms. Bates. Vanessa was attending for training and observation. I was accompanied by Ms. Bates throughout the inspection and was not denied access to any area of the facility. Ms. Bates answered all my questions. I began the inspection with a brief opening conference with Ms. Bates and explained the scope of the inspection. We first sat down in the office on site, and I conducted a file review. Ms. Bates then led us on a tour of the facility and explained the various processes of their operation. We ended with a brief closing conference outside to discuss observations and next steps. VI. Opening Conference The Makah National Fish Hatchery is in the temperate rain forest of Washington's Olympic Peninsula. Since 1981, the hatchery has annually raised around 3 million salmon and trout for release into the Tsoo-Yess River on the Makah Indian Reservation. The hatchery is owned and operated by the U.S. Fish & Wildlife Service and partners with the Makah Tribe to raise Chinook salmon, coho salmon, and steelhead. The hatchery has a 2.3 million release goal of Chinook salmon, 300,000 release goal of coho salmon, and a 180,000 release goal of steelhead. Their average daily flow is approximately 16,560,000 gallons per day. Flow is measured at each of their six pumps located in their pumphouse. The pumps are always running at their maximum capacity. Ms. Bates stated that she is concerned about how the hatchery has been reporting their setteable solids. The permit has a setteable solids limit of .1 ml/L and the lab that the facility uses, Freemont Analytical, only has a lower detection limit set to <.2 ml/L. The facility has been reporting <.2 ml/L in their DMR's which has consequently given them effluent limit exceedance violations. Ms. Bates has since been informed to consult with their lab to see if that detection limit can be met. These testing procedures must meet the requirements listed under 40 CFR 136. If Freemont 5 of 14 Makah National Fish Hatchery WAG130004 Analytical is not able to meet these standards, this may require that the Makah National Fish Hatchery change contract labs. Ms. Bates also has the option to enter "Non-detect" or "ND" on the DMR, but this would likely be considered a permit violation. The influent sampling point is right before the pumphouse and the effluent sampling point is towards the end of the effluent channel. Their effluent sampling point isn't at the nearest possible point before discharge. It's possible that some algae at their current effluent sampling point is contributing to their setteable solids limit exceedances. ` VII. Laboratory Inspection Water samples are collected by Ms. Bates (Hatchery Manager). Samples are sent off to Freemont Analytical for analysis. Per the permit, the facility is required to sample for total suspended solids, net settleable solids, total residual chlorine, and temperature. VIII. Site Review Ms. Bates led Vanessa and myself on a tour of the facility. An aerial image appears in Attachment A and a photograph log appears in Attachment B. We first started off at the receiving water, the Tsoo-Yess River. The facility's influent sampling point is right before the pumphouse. Their monthly composite samples are taken four times per day towards the beginning and ends of each month. We then entered the pumphouse where I visually inspected the six water pumps. Each water pump has a different flow rate and all six pumps are running at their maximum capacity. I then visually inspected their degassing area. The hatchery uses an older gravity fed system (Photo 1) to degas. The intake pond and raceways (Photo 2) were also visually inspected. A UV light system is utilized for sockeye salmon. Chorine is used in the sockeye isolation building. Chloramine-T is used for the sockeye eggs. The facility also utilizes florfenicol as a preventative from bacterial coldwater disease. Oxytetracycline is also used for bacterial coldwater disease. I next visually inspected their sand filters and diesel generators. Their effluent samples are taken towards the end of the effluent channel (Photo 3). I mentioned to Ms. Bates that a more representative effluent sample could be taken at the effluent waterfall (Photo 4). IX. File Review I reviewed the following records: Notice of Intent (NOI) dated February 2, 2021 Discharge Monitoring Report (DMR) for Aug. 2022 6 of 14 Makah National Fish Hatchery WAG130004 Chain of custody - August 2022 Quality Assurance Plan (QAP) dated Jan. 2022 Best Management Practices (BMP's) Plan dated Jan. 2022 Authorization to Discharge dated July 22, 2021 X. Areas of Concern A. Part IV.3.b of the permit states that "The Permittee must limit discharges from all outfalls authorized under this permit as specified in Tables 1 and 2, below, as applicable. The limits in Table 1 apply to all hatchery discharges except those from separate off-line settling basin outfalls and rearing pond discharges during drawdown, limits for which are listed in Table 2. All limits represent maximum effluent limits, unless otherwise indicated. The Permittee must comply with the applicable effluent limits in the tables at all times, unless otherwise indicated, regardless of the frequency of monitoring or reporting." Since September 1, 2017, there have been a total of eight effluent limit exceedances for setteable solids according to ICIS (Integrated Compliance Information System). The reported effluent limit violations for setteable solids are due to their lab, Freemont Analytical, not being able to precisely measure down to .1ml/L. The lab's cutoff point is <.2 ml/L so when that measurement is reported on the DMR, it is flagged for a violation. It should also be noted that subscript 2 of the above table states that "Net concentration = effluent concentration - influent concentration. Net TSS and settleable solids determinations will require influent analysis in addition to effluent analysis unless the permittee chooses to assume that the pollutant concentration in the influent is zero..." As per the permit, the effluent for net setteable solids must be reported relative to 0.1ml/L. 7 of 14 Makah National Fish Hatchery WAG130004 XI. Closing Conference I held a closing conference with Ms. Bates following the inspection outside. I stated that no areas of concern were identified over the course of the inspection and gave a brief overview of the post-inspection process. I thanked her for her time and assistance. 8 of 14 Attachment A - Aerial Image Makah National Fish Hatchery WAG130004 Figure 1 - Aerial image taken from Google Maps 9 of 14 Makah National Fish Hatchery WAG130004 Attachment B - Photograph Log (Photographs were taken by CJ Langlois on September 7, 2022, with a Panasonic DMC-FH25. Timestamps on the photographs are inaccurate and would range in time from 12:00 p.m. - 1:30 p.m.) Photo 1/ P9060052 - Degassing area 10 of 14 Makah National Fish Hatchery WAG130004 Photo 2/ P9060054 - Raceway for steelhead 11 of 14 Makah National Fish Hatchery WAG130004 Photo 3/ P9060062 - Effluent sampling area 12 of 14 Makah National Fish Hatchery WAG130004 Photo 4/ P9060063 - Effluent waterfall 13 of 14 A complete list of photographs taken during the inspection: P9060047 P9060048 P9060049 P9060050 P9060051 P9060052 P9060053 P9060054 P9060055 P9060056 P9060057 P9060058 P9060059 P9060060 P9060061 P9060062 P9060063 Makah National Fish Hatchery WAG130004 14 of 14