Document yk02pOL6g3EXX4YYr0vGzp5y6

NPDES Compliance Inspection Report Paradise WWTP WA0025569 Paradise WWTP Paradise, WA NPDES Tracking Number WA0025569 Inspection Date: August 30, 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: 2022.12.20 14:46:23 -08'00' Supervisor Signature/Date: PETER CONTRERAS Date: 2022.12.21 10:29:18 -08'00' Digitally signed by PETER CONTRERAS Paradise WWTP WA0025569 Contents I. Facility Information .......................................................................................................1 II. Inspection Information...................................................................................................2 III. Permit Information.........................................................................................................2 IV. Enforcement Background ..............................................................................................2 V. Inspection Chronology...................................................................................................4 VI. Opening Conference ......................................................................................................5 VII. Laboratory Inspection ....................................................................................................5 VIII. Site Review ....................................................................................................................6 IX. File Review ....................................................................................................................6 X. Areas of Concern ...........................................................................................................6 XI. Closing Conference........................................................................................................8 Attachment A - Aerial Images & Facility Diagram Attachment B - Photograph Log Attachment C - Facility's Response to NOV 2 of 20 Paradise WWTP WA0025569 [Unless otherwise noted, all details in this inspection report were obtained from conversations with Mr. Micah Henderson, a review of facility documents, and/or from observations made during the inspection.] I. Facility Information Facility Name: Facility Owner/Operator: Physical Address: Mailing Address: Lat/Long: Facility Contacts: Paradise WWTP National Park Service 1 Wastewater Rd. Mount Rainier National Park Paradise, WA 98361 55210 238th Ave E Ashford, WA 98304 46.7833530, -121.7488572 Micah Henderson, Manager Paradise WWTP Office: (360) 569-2211 x7113 Cell: (360) 569-2211 Email: micah_henderson@nps.gov Stephanie Coffey National Park Service - Office of Public Health Cell phone: (202) 573-5721 Email: stephanie_coffey@nps.gov Permit Number: NAICS Code: Receiving Water: WA0025569 221320 (Sewage Treatment Facilities) Nisqually River 3 of 20 II. Inspection Information Inspection Date: Inspector: Arrival Time: Departure Time: Weather: Purpose: Paradise WWTP WA0025569 August 30, 2022 CJ Langlois EPA Region 10, ECAD/WEFB/FDDWES Phone: 206-553-2739 1:00 p.m. 4:00 p.m. Mostly Sunny, 55 F To evaluate compliance with the requirements of the Clean Water Act (CWA) and the Washington Department of Ecology National Pollutant Discharge Elimination System (NPDES) individual discharge permit (WA0025569) III. Permit Information The Paradise WWTP was authorized to discharge under the National Pollutant Discharge Elimination System permit #WA002556 on February 1, 2017. The permit expired on January 31, 2022, and has since been administratively extended. IV. Enforcement Background On March 26, 2019, the Paradise WWTP was issued a Notice of Violation (NOV) related to NPDES Permit # WA0025569. This NOV was issued because of 715 violations on their Discharge Monitoring Report (DMR). Since the permit became effective in February of 2017, the facility has had ongoing issues with Biochemical Oxygen Demand (BOD) effluent exceedances. Prior to the issuance of this permit, the plant was regulated under the Federal Facility Compliance Agreement (FFCA) and at that time, they were taking the effluent samples from after the filter and just prior to the chlorine contact chamber. As the permit became effective, the facility realized that their previous effluent sampling point was not the most representative location for the treated effluent. Once the sampling location was moved, the exceedances for the BOD began. The composite sampler needed to be placed inside of the plant due to the inaccessible nature outside the facility. The WWTP is located on a very steep mountainside and accessibility to the plant is further complicated by 4 of 20 Paradise WWTP WA0025569 the extreme snowfall on Mount Rainier. The sample point is plumbed in the dechlorination chamber just before the discharge pipe. An initial step to reduce BOD was to change the chlorination chemical from Sodium Bisulfate to Vita-D Chlor. This improved BOD but not enough to meet the permit requirements. The facility then troubleshooted the issue and determined that the high BOD levels were likely coming from the dechlorination tank that had experienced a discharge of partially treated sewage in 2011. The park made efforts to clean the dechlorination tank as best as possible, but again, due to the access challenges presented by the location of the WWTP, cleaning can only be done via pumping water & air through the tank and cleaning the contact pipe prior to its intersection with the dechlorination tank. Full access to the tank would require significant construction. In a response to the NOV, the NPS described actions they took to the violations noted by EPA. The written response from the NPS was dated April 30, 2019, and is included as Attachment C. The letter describes challenges and efforts made to clean the dechlorination tank, sampler, & tubing, including options for jet steaming and shock disinfection that would require consultation with the permitting authority. Violations related to Total Suspended Solids were described in the NPS response as related to grease build up associated with concessions at Paradise Inn and the Visitor Center. Observations and efforts to remedy the exceedances were described as occurring in July 2017, July/August 2018, and 2019, including a plan to implement a Standard Operating Procedure for kitchen operations believed to be the source of TSS exceedances. Mr. Henderson stated that an "SOP was developed through US Public Health Services and the vendor that runs concessions up at Paradise. Maintenance has always been done on the chlorine pump at the plant. We have switched from a pulse pump to a peristaltic pump, and they are closely monitored and maintained". Additional troubleshooting and SOPs are described for fecal coliform exceedances identifying chlorine pump failure and a plan for increased maintenance. V. Inspection Chronology This was an announced inspection. On August 11, 2022, I called Micah Henderson and setup the inspection for August 30, 2022. On August 30, 2022, I arrived at the facility around 1 p.m. Due to there being no cellphone coverage on the mountain, there was some miscommunication and the inspection did not start until 2:50 p.m. I presented my credentials to Mr. Henderson and Stephanie Coffey who works for the National Park Service - Office of Public Health. I was accompanied by Mr. Henderson and Stephanie Coffey throughout the 5 of 20 Paradise WWTP WA0025569 entire inspection and was not denied access to any area of the facility. Mr. Henderson answered all my questions. I began the inspection with a brief opening conference with Mr. Henderson and Stephanie Coffey and I explained the scope of the inspection. We first sat down in the office on site, and I conducted a file review. Mr. Henderson 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 Paradise WWTP is situated on the South facing slope of Mount Rainier. The National Park Service (NPS) owns, operates, and maintains the Paradise WWTP located in Mount Rainier National Park. The WWTP treats raw sewage from Paradise Inn, the visitor center, ski dorm, and public restrooms. The WWTP also treats some stormwater along with high-temp dishwashers, and grease traps. Paradise Inn only operates from May through September due to the severe winters up on Mount Rainier. The WWTP serves a population of approximately 5,000 people per day in the summer months and closer to 1,000 during the winter months. There is a standby generator in case of a power loss. Minimally treated sewage was discharged in 2011 due to an operator failing to control sludge build-up. Roughly 200,000 gallons were released into the drainage ditch upstream of the Nisqually River. The operator lost his job because of this and received a felony conviction for violating the Clean Water Act (CWA). The WWTP's outfall is quite far from the Nisqually River. It's estimated that 1000 vertical feet and 500 horizontal feet separate the WWTP from Dead Horse Creek, which flows to the Nisqually River. Mr. Henderson mentioned that the park conducted an engineering assessment several years ago and the conclusion of that assessment was that the path of the surface flow does not exist from the WWTP to the Nisqually River. Mr. Henderson mentioned that there is a plan to replace the entire plant in the next 5 years due to the larger influx of people using the facilities on the mountain and due to tighter environmental restrictions. Flow is measured by a partial flume and daily flow during the Summer is estimated between 70,000 and 100,000 gallons. This averages out to about 20,000 gallons per day over the entire year. Discharging occurs everyday and is not a continuous flow discharge. 6 of 20 Paradise WWTP WA0025569 VII. Laboratory Inspection The laboratory utilized is the Water Management Laboratories in Tacoma, WA. This lab is approximately a 3-hour drive from the WWTP. At the time of the inspection, all of the pH buffers were expired on the site. Mr. Henderson has since sent me an email with a picture of non-expired buffer solutions. VIII. Site Review Mr. Henderson led me on a tour of the facility. An aerial image appears in Attachment A and a photograph log appears in Attachment B. We first started out at the headworks and I inspected the flow meter and flume (Photo 1). The facility's influent sampling point is right before the grinder at the headworks. Their effluent and influent samples are collected at approximately the same time. I proceeded to inspect the composite sampler (Photo 2), the grinder, and the equalization tank (EQ), and aeration basin. From the aeration basin (Photo 3), the effluent flows into the secondary clarifiers and then the surge tank. Once the effluent is controlled and buffered, it flows to the flocculation tank, the settling tank, and then the filtration tank. The flow then makes it way to the backwash storage tank, through the chlorine contact pipes (Photo 4), the dechlorination tank, and then it leaves the WWTP and the treated wastewater outfalls onto a steep mountain side. The effluent samples are collected after the dechlorination tank before it leaves the building. IX. File Review I reviewed the following records: Quality Assurance Plan (QAP) - April 2, 2019 Discharge Monitoring Reports (DMR's) for June, July, and August 2022. Monitory Records - 2022 Operation and Maintenance Plan (O&M Plan) - Revised on May 2020 X. Areas of Concern A. Effluent Limit Violations 7 of 20 Paradise WWTP WA0025569 Part I.B.1 of the permit states that "The permittee must limit and monitor discharges from Outfall 001 as specified in Table 1, below. All figures represent maximum effluent limitations unless otherwise indicated. The permittee must comply with the effluent limitations in Table 1 at all times unless otherwise indicated, regardless of the frequency of monitoring or reporting required by other provisions of this permit." Between November of 2017 and May of 2022, there were a total of 56 effluent violations. Most of these limit exceedances were due to excessive "total suspended solids (TSS)" and "BOD 5 - day". Other effluent limit exceedances include "ammonia nitrogen - total", "fecal coliform", and "pH". 8 of 20 Paradise WWTP WA0025569 Since the April 2019 response letter, there have been the following exceedances: 7 exceedances for BOD 1 exceedance for pH 11 exceedances for TSS 5 exceedances for ammonia And 1 exceedance for fecal coliform B. Proper Operation and Maintenance Part IV.E. states that "The permittee must 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. This provision requires the operation of back-up or auxiliary facilities or similar systems which are installed by the permittee only when the operation is necessary to achieve compliance with the conditions of the permit." It is my concern that the prior discharge of minimally treated sewage in 2011 is largely contributing to the exceedances in BOD. According to the permit, proper maintenance of systems of treatment and control is required. XI. Closing Conference I held a closing conference with Mr. Henderson following the inspection outside. I stated that they are required to have up-to-date pH buffers and gave a brief overview of the post-inspection process. I thanked him for his time and assistance. 9 of 20 Attachment A - Aerial Image & Facility Diagram Paradise WWTP WA0025569 Figure 1 - Google Maps aerial image 10 of 20 Paradise WWTP WA0025569 Figure 2 - Photograph taken of facility layout 11 of 20 Paradise WWTP WA0025569 Attachment B - Photograph Log (Photographs were taken by CJ Langlois on August 30, 2022, with a Panasonic DMC-FH25.) Photo 1 - Flow meter and flume 12 of 20 Paradise WWTP WA0025569 Photo 2 - Composite sampler 13 of 20 Paradise WWTP WA0025569 Photo 3 - Aeration basin 14 of 20 Paradise WWTP WA0025569 Photo 4 - Chlorine contact chamber 15 of 20 Attachment C Paradise WWTP WA0025569 16 of 20 IN REPLY REFER TO: LA. April 30, 2019 United States Department ofthe Interior NATIONAL PARK SERVICE Mount Rainier National Park 55210 238**' Avenue East Ashford, WA 98304 RECEIVED V MA I 6 NATIOf^AL RK VICE J Mr. Raymond Andrews Compliance Officer Water and Wetlands Enforcement Unit U.S. Environmental Protection Agency 1200 Sixth Avenue, Suite 155 OCE-201 Seattle, Washington 98101 EPA - rxPGlON 10 Office of Compliance and Enforcement Re: Response to Findings Stated in Notice of Violation Dated March 26,2019 Dear Mr. Andrews, We have reviewed the Notice of Violation(NOV)Dated March 26,2019,related to NPDES Permit Number WA-002556-9. These violations were discovered, after reviewing our administrative files and in response to the July 7,2018,inspection ofour Facility conducted by the Environmental Protection Agency(EPA). We have prepared the following responses to the findings highlighted in that document. Review of Administrative Files 1. Explanation and measures that have been taken and are being taken to address Discharge Monitoring Report(DMR)with 715 violations. a. Violations in reference to Biochemical Oxygen Demand(BOD)over permitted limit: The BOD has been an ongoing issue since the permit became effective in February 2017. Prior to the issuance of this permit when the plant was running under the Federal Facility Compliance Agreement(FFCA),the operators got the effluent sample from after the filter and just prior to the chlorine contact chamber. As the permit became effective and sampling equipment was purchased, it became clear that the current location for sampling final effluent was not the most representative location for treated effluent and we needed to install the sampling equipment to the sample point in the dechlorination tank. Once the sampling location was moved,the exceedances for BOD began. Since the actual discharge ofthe plant is piped approximately 1,110 feet from the plant and not accessible 6 months out ofthe year when snowfall is heavy,the composite sampler needed to be placed inside the plant at the sample point plumbed in to the de-chlorination chamber just before the discharge pipe. This is the most representative location accessible year-round for the plant 17 of 20 effluent. The first samples taken were well over the permit BOD limit and we immediately began to evaluate methods for addressing BOD. An initial step to reduce BOD was to change the chlorination chemical from Sodium Bisulfate to Vita-D Chlor for dechlorination ofthe effluent. This improved BOD,but not sufficiently to meet permit requirements. We then verified that the issue was in the dechlorination tank by taking a BOD sample before the dechlorination process and the lab results were less than 3mg/l. We concluded that BOD may be impacted ifthe tank still contained sludge from the 2011 discharge ofpartially treated sewage referenced in the inspector's report. The park has made efforts to clean the dechlorination tank, but due to access challenges presented by its location (full access would require significant construction into both the chlorine contact chamber and the dechlorination tank)this has remained a challenge. Methods ofcleaning to date include: pumping and cleaning the chlorine contact pipe prior to its intersection with the dechlorination tank,and also pumping air into tank then draining back out through sample point. Park staffalso clean the tubing to the sampler weekly to keep bacteria from growing within. Additionally,staffraised the composite sampler higher and closer to the sample point in order to keep the sample line dry to prevent growth in that section oftubing. Finally, park staffhave selected a contractor to assess and recommend additional cleaning options. We anticipate that these options will include: i. Jet steaming water through the discharge point 24" main to the dechlorination tank. The park staffhas been unable to do this with existing equipment. This can only be done during the summer months, ii. Shock disinfecting the dechlorination tank and utilize a sandbag filled with Vita-D-chlor, Vitamin D at the discharge point to try and remove any leftover sludge in the dechlorination tank. This can only be done during the summer months,and will be in consultation with the permit authority. b. Violations in reference to Total Suspended Solids(TSS)over permitted limit: The sample location for TSS was the same as BOD (prior to the effective date of February 2017)before chlorination and then subsequently was moved to the dechlorination tank. We believe the TSS issue is due to the concessionaire not keeping up with pumping the grease trap located at the Paradise Inn. In July of2017,we noticed grease building up in the aeration tanks. As a result the TSS leaving the plant started going up. We asked the concessionaire to pump the grease trap. Once completed,the TSS started going down back below permit limits. We asked the concessionaire from that point on to pump the grease trap every two weeks to keep the grease out ofthe plant. In the summer of2018,before the Iim opened the dish washer was re-plumbed to keep it from directly flowing into the grease trap. It was plumbed incorrectly which made the problem worse. The plant was over-loaded with grease and in July and August of2018 the plant TSS went over the permit limit. The dish washer was plumbed back to its original configuration and we pumped as much grease as we could out ofthe plant. By September 2018,effluent TSS was back below permit limits and the concessionaire went back to pumping every two weeks. The Inn was shut down at the beginning of October for the winter, but in November 2018 grease started showing up and we were having TSS issues again. We expect it is coming from the visitor center. 18 of 20 The concessioner will install a grease trap in the summer season of2019. The park is providing the concessionaire with a Standard Operating Plan in order to improve kitchen operations and aid in reducing the amount of grease introduced into the sewer system. Additionally, we provided them with the information on where to purchase an in line grease trap to be installed at the visitor center in order to prevent grease from being introduced into the sewer. c. Violations in reference to Fecal Coliform over permitted limit: The fecal coliform exceedance has occurred twice during this review period, and both times were due to chlorine injection pump failure. The suction line for the chlorine injection pump became plugged overnight. Both instances, the injection line was cleaned next day when the problem was discovered. The SOP for the plant is being updated to include checking the lines for calcium build up each time the crock is refilled. 2. Explanation and response to failure to submit monitoring data and incomplete reports, a. Due to issues at the time with the DMR system and lack ofexperience with the system, we were told that the first month could be submitted with a hard copy. The report that was not submitted in the DMR has now been entered and submitted. We are adding the missing data to the five incomplete DMR submissions and are training our staff on how to submit fully compliant reports going forward to avoid reoccurrence ofthis problem. June 2018 Inspection 1. Explanation and response to sampling for total chlorine before and after dechlorination, a. During inspection, there was discussion about how to properly report the chlorine residual before dechlorination. Since the inspector clarified this misunderstanding, we have been entering the chlorine residual before dechlorination in the proper DMR fields. 2. Explanation and response to proper reporting of chlorine residual, a. After becoming aware of this concern, we will edit previous DMR reports to make those corrections and ensure we continue to enter data correctly going forward. 3. Explanation and response to Quality Assurance Plan(QAP)issues, a. The holding time for fecal coliform in the QAP of22 hours was a typo that was overlooked. It has been corrected and updated in the electronic copy and hard copy at the plant, b. The electronic copy was sent to the inspector was inadvertently incomplete. There is now a complete copy at the plant and a complete electronic PDF copy available as needed. 4. Explanation and response to composite sampler repair, a. A refrigeration contractor has been to the plant to work on the refrigeration side of the composite sampler. On 4/18/19 the sampler was recharged and is now working again. 5. DMR reporting refresher training will be conducted yearly. The plant SOP will be updated to show proper DMR entry instructions. 19 of 20 In recognition ofongoing challenges with the plants at Paradise and Longmire,the park has recently completed a comprehensive condition assessment ofthe Paradise Wastewater Plant and received a final report in May of2018. This condition assessment is attached. In addition, the National Park Service contracted in early 2019 with Facility Engineering Associates, P.C. to develop Project Scoping Assessments for rehabilitation ofthe Paradise and Longmire Wastewater Treatment Plants, their related collection systems and emergency backup power systems to remedy deferred maintenance and to ensure compliance with State Regulations. We have recently received the preliminary scoping reports and will soon be evaluating project alternatives and seeking federal funding for a major rehabilitation ofthese aging plants. In addition to the actions above. Mount Rainier National Park has been in regular contact with environmental engineering support from our Pacific West Regional support office, and a site visit is scheduled for June of2019 to provide further evaluation and recommendations on approach for the current permit exceedances on TSS and BOD.Please contact Mount Rainier Deputy Superintendent Tracy Swartout at 360-569-6502 if you have any questions regarding this response or to schedule a meeting to discuss next steps. Sincerely, Palmer L. Jenkins Superintendent 20 of 20