Document znMp55JRbQ9YBLJ2OLQwNrdB

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 03/21/2023 9:15 AM (PT) Announced: No 03/21/2023 1:20 PM (PT) Access: Granted 50F, Overcast Water Clean Water Act, NPDES, WWTP Compliance Evaluation Inspection Permittee Name Facility Name Facility Physical Address City, State, Zip Code County Facility GPS Coordinates Mailing Address City, State, Zip Code City of Orofino City of Orofino WWTP 10200 Highway 12 Orofino, Idaho 83544 Clearwater 46.487385, -116.267884 217 First Street, P.O. Box 312 Orofino, Idaho 83544 FRS ID Permit Number SIC 110010027318 ID0020150 4952 (Sewage Systems) Lead Inspector: RAYMOND ANDREWS Date: 2023.05.25 11:17:03 -07'00' Digitally signed by RAYMOND ANDREWS Raymond Andrews EPA REGION 10 andrews.raymond@epa.gov (206) 553-4252 Supervisor Review: PETER CONTRERAS Date: 2023.05.25 11:43:35 -07'00' Digitally signed by PETER CONTRERAS Peter Contreras EPA REGION 10 contreras.peter@epa.gov (206) 553-6708 1 of 8 City of Orofino WWTP Permit #: ID0020150 SECTION I - Opening Conference Site Entry and Inspection Objectives I arrived at the Orofino WWTP (the "Site" or "Facility"), located at 10200 Highway 12, Orofino, Idaho at 09:15 AM (PT) on 03/21/2023 for an unannounced inspection. I was accompanied on my inspection by Carolyn Whitney, an IDEQ inspector. I presented my inspector credentials to Michael Martin, the City of Orofino's Water/Wastewater Superintendent. I informed Mr. Martin that I was an inspector from EPA Region 10's Seattle office and I was at the facility 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 # ID0020150. This report is based on information supplied by Mr. Martin, my direct observations, and records and reports maintained by the facility. In addition, information gathered from a review of EPA, State, and/or public records may be included in this report. Attendees Organization EPA Region 10 IDEQ City of Orofino Attendee Name Raymond Andrews Caroline Whitney Michael Martin Title Lead Inspector IPDES Compliance Officer Water/Wastewater Superintendent Present in Opening Conf. Yes Present in Closing Conf. Yes Yes Yes Yes Yes Facility/Site Information What is the facility's service population? How many employees does the facility have? When is the facility staffed? What is receiving water? How many outfalls does the facility have? The facility has a service population of approximately 2,400 citizens. The facility is located within the tribal boundaries of the Nez Perce Tribal Reservation, but the tribe does not own or operate the facility. The names and certification of the wastewater operators are listed below: Mr. Michael Martin - Class III WW Treatment, Class II Collections Mr. Rick Bird - Class II WW Treatment Mr. Jim Thorp - Class I WW Treatment Mr. Justin Beard - Taking Class I WW Treatment Certification Test in June 2023 Per Mr. Martin, the facility is staffed 8:00am until 5:00pm, Monday - Friday. On Saturdays and Sundays, the on-call operator spends 4 hours each day checking and maintaining the facility. Clearwater River The facility has a single outfall. The outfall is across the river from the facility. The primary collection point is on the north side of river. Wastewater is pumped under the river to the wastewater treatment facility on the east side of the river. After the wastewater has been treated, the effluent is pumped back under the river to the north side for discharge. What is the design flow of the facility? What is the average daily flow? Effluent samples are collected after final treatment. The actual discharge point is in the middle of the Clearwater River and was submerged at the time of the inspection. The design flow is 0.88 million gallons per day (MGD). The average daily flow for summer is 0.25 MGD. The average daily flow in winter is 0.5 MGD 2 of 8 City of Orofino WWTP Permit #: ID0020150 How often does the facility discharge? The facility is authorized to discharge year-round. Raw wastewater is collected on the east side of the Clearwater River and is pumped under the river through underground piping to the headworks on the west side of the river. Explain the facility's treatment process. The effluent goes through bar screening to remove large solids followed by screening through a fine screen to remove grit and other fine solids. The screenings go to a transfer station for disposal and the effluent goes into a grit clarifier to separate any remaining grit from liquid. The effluent then flows to the oxidation ditch where it remains for approximately 30-days while the wastewater is biologically treated to remove organic material. Once the effluent leaves the oxidation ditch, it goes to the clarifiers. From the clarifier, the liquor (supernate) and the solids go different routes. The clarified effluent travels to the chlorine contact chamber for disinfection. The facility does not dechlorinate the effluent. The supernate is then sent back across the river for discharge. The discharge point is in the approximate middle of the river. From the clarifier, the solids, Returned Activated Sludge (RAS), are sent back to the oxidation ditch. Mr. Martin calculates how much sludge needs to be maintained in the system. Sludge deemed to be excess is sent to the sludge holding tank daily. Sludge from the holding tank is sent to a building for flocculation and dewatering. Once the sludge has been dewatered, it is loaded onto trucks and shipped to farmers for land application. I asked Mr. Martin if the facility had any problems meeting the permit's chlorine limits since the facility does not dechlorinate. He said the facility has not had any problems meeting their limits. A review of data submitted to ICIS supports Mr. Martin's statement. Who conducts the sampling? Mr. Martin draws the influent and effluent samples. Does the facility treat anything other than domestic sewage waste? The facility has one industrial user. It is an "anodizer" which uses aluminum, caustic soda, and sulphur acid in the anodizing process. The industrial user pre-treats its effluent by neutralizing the chemicals prior to sending the waste stream to the wastewater treatment facility. Mr. Martin said the addition of the industrial waste stream does not seem to have a negative effect on the wastewater treatment plant's operations. Does the facility conduct its own sampling? The facility conducts its own sampling. The facility monitors chlorine, temperature, pH, BOD, TSS, ammonia, E. coli, and flow and analyzes all parameters at its in-house lab. Is the facility sampling more than required? The facility samples more than required and all extra samples are included in calculations for DMRs. How does the facility The facility analyzes pH using a pH meter and probe. The meter is calibrated weekly analyze pH? by staff and once a year an outside contractor comes in to calibrate all equipment. Does the facility accept waste from septage haulers? The facility accepts waste from septage haulers. Mr. Martin said there have been no problems maintaining the facility as a result of accepting the additional waste. The septage haulers are required to pre-treat the waste they deliver prior to discharging it at the treatment facility and they are only allowed to discharge 3,000 gallons of liquor per day. Are any upgrades planned at the facility? The facility is planning to upgrade to UV disinfection in Summer 2023. 3 of 8 City of Orofino WWTP Permit #: ID0020150 SECTION II - Observations Location: Facility Laboratory Observation #: RA1-OB-001 In the facility's lab, I observed the pH 10.0 calibration buffer solution was expired. Date: 03/21/2023 SECTION III - Records Review Records may not be in sequential order. Record: Other - Quality Assurance (QA) Plan Ref #: RA1-RR-001 Reviewed By: Raymond Andrews AOC: Yes Reviewed Date: 03/21/2023 The Quality Assurance (QA) Plan was not signed or dated, was not in the format specified in the reference documents cited in the permit, did not show the qualifications and training of personnel and did not contain details on the number of samples to be collected, analytical detection and quantitation limits for each target compound, and the type and number of quality assurance field samples to be collected. The QA Plan map had a facility diagram with sampling points marked but does not contain a map. Record: Other - EPA's Integrated Compliance Information System (ICIS) Database AOC: Yes Ref #: RA1-RR-002 Reviewed By: Raymond Andrews Reviewed Date: 03/21/2023 Upon review of data in EPA's Integrated Compliance Information System (ICIS) database, I found the facility had a total of 52 effluent exceedances between 5/1/2018 and 4/30/2023. 4 of 8 City of Orofino WWTP Permit #: ID0020150 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-001 Records Review: Other - Quality Assurance Plan Regulation and/or Permit Requirement Permit Part II.B.3.c., "At a minimum, the QAP must include...Qualification and training of personnel." AOC: The QA Plan did not contain the qualifications and training of personnel. AOC Reference #: RA1-RR-001 Records Review: Other - Quality Assurance Plan Regulation and/or Permit Requirement Permit Part II.B.3.b., "At a minimum, the QAP must include...Map(s) indicating the location of each sampling point." AOC: The QA Plan map had a facility diagram with sampling points marked but does not contain a map. AOC Reference #: RA1-RR-001 Records Review: Other - Quality Assurance Plan Regulation and/or Permit Requirement Permit Part II.B.2, "Throughout all sample collection and analysis activities, the permittee must use the EPAapproved QA/QC and chain-of-custody procedures described in EPA Requirements for Quality Assurance Project Plans (EPA/QA/R-5) and Guidance for Quality Assurance Project Plans (EPA/QA/G-5). The QAP must be prepared in the format that is specified in these documents." AOC: The QA Plan was not in the format specified in the reference documents cited in the permit. AOC Reference #: RA1-RR-001 Records Review: Other - Quality Assurance Plan Regulation and/or Permit Requirement Permit Part II.B.3.a., "At a minimum, the QAP must include...Details on the number of samples...analytical detection and quantitation limits for each target compound...type and number of quality assurance field samples..." AOC: The QA Plan did not contain details on the number of samples to be collected, analytical detection and quantitation limits for each target compound, and the type and number of quality assurance field samples to be collected. AOC Reference #: RA1-RR-002 Records Review: Other - EPA's ICIS Database Regulation and/or Permit Requirement Permit Part I.B, "The permittee must limit and monitor discharges from outfall 001 as specified in Table 1. Effluent Limitations and Monitoring Requirements, below. All figures represent maximum effluent limits unless otherwise indicated. The permittee must comply with the effluent limits in the tables at all times unless otherwise indicated, regardless of the frequency of monitoring or reporting required by other provisions of this permit. AOC: I found the facility had a total of 52 effluent exceedances between 5/1/2018 and 4/30/2023. A table of the exceedances is in Appendix II. 5 of 8 City of Orofino WWTP Permit #: ID0020150 AOC Reference #: RA1-OB-001 Location: Facility Laboratory Regulation and/or Permit Requirement Permit Part II.B, "The permittee must develop quality assurance plan (QAP) for all monitoring required by this permit." QA Plan, Part 5.2.2, "pH Meters - All pH meters have an accuracy of at least plus or minus 0.1 pH unit and provide for temperature correction of pH measurements. Calibrations are performed with a minimum of two standardization buffers in the appropriate pH range." AOC: The pH 10.0 calibration buffer solution was expired. SECTION V - Closing Conference I held a closing conference with Mr. Martin at 01:20 PM (PT) on 03/21/2023. During the conference, I discussed my 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 VI - List of Appendices I. Photo Log II. Areas of Concern Tables 6 of 8 APPENDIX I: 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. P1010623 - Expired Calibration Buffer Solution, pH 10.0, photo 1 P1010624 - Expired Calibration Buffer Solution, pH 10.0, photo 2 P1010625 - Fine Grit Screen P1010626 - Influent Sampling Point, near fine grit screen P1010627 - Grit Clarifier P1010628 - Oxidation Ditch Paddlewheel P1010629 - Oxidation Ditch P1010630 - Clarifier, single P1010631 - Clarifiers, both P1010632 - Sludge Holding Tank P1010633 - Chlorine Contact Chamber, photo 1 P1010634 - Chlorine Contact Chamber, photo 2 P1010635 - Effluent Sampling Point at Chlorine Contact Chamber P1010636 - Auto-sampler Control Board City of Orofino WWTP Permit #: ID0020150 7 of 8 APPENDIX II: Areas of Concern Tables City of Orofino WWTP Permit #: ID0020150 Month Jan 2019 Jan 2019 Apr 2019 Apr 2019 Mar 2021 Parameter TSS TSS Chlorine Chlorine E. coli Effluent Exceedances DMR Permit Value Limit 104 45 569 330 4.35 3.6 7.78 5.5 727 406 Unit mg/L lb/d lb/d lb/d #/100mL Limit Type Wkly Avg Wkly Avg Mo Avg Wkly Avg Inst Max # Violations 7 7 30 7 1 8 of 8