Attachment 4 - Washington State Department of Health CLM045 Documents.pdf

STATE OF WASHINGTON

DEPARTMENT OF HEALTH

OFFICE of ENVIRONMENTAL HEALTH and SAFETY

243 Israel Road SE PO Box 47824 Olympia, Washington 98504-7824

(360) 236-3330 TDD Relay Services 1-800-525-0127

November 15, 2019

Ms. Sarah Creachbaum, Superintendent Olympic National Park 600 E Park Ave Port Angeles, WA 98362-6798

Subject: CLM045; Hurricane Ridge Visitor Center Large On-site Sewage System (LOSS);

Public Health and Environmental Concerns and LOSS Requirements

Dear Superintendent Creachbaum:

On October 22, 2019, I spoke with the National Park Service (NPS) Olympic National Park Engineer Kerri Cook by phone to discuss a potential drainfield failure at the Hurricane Ridge Visitor center in the park. Ms. Cook related observations made during fieldwork at the facility that indicate the drainfield for the existing onsite sewage system is likely to fail in the near future. Based on the information Ms. Cook relayed to me, and on a preliminary review of the record drawings of the existing system, I concur with Ms. Cook’s assessment that the drainfield is in a state of imminent failure.

Please be aware that LOSS owners are required to address and correct all failures immediately following department notification. This letter describes our understanding of the current situation and the requirements for addressing the LOSS condition.

1. Existing system condition The exiting onsite sewage system (OSS) consists of concrete sewers and manholes; a septic tank;

and a drainfield that is dosed via gravity flow from the septic tank. Based on record drawings, the system was constructed almost 70 years ago, in 1951. Ms. Cook and her team conducted site work to evaluate the function of the OSS in late October 2019 (during off-peak season). During the fieldwork, septic tank effluent was observed ponding on top of the infiltrative surface of the drainfield and in the distribution box located at a slightly higher elevation than the drainfield.

While ponding wastewater may be expected during high-use times, the fact that it is ponding during low-flow times indicates the infiltrative surface is blocked with biological growth or with

Ms. M. Sarah Creachbaum solids from the wastewater. During high-flow times, it is very likely that the reduced infiltration rate will cause untreated wastewater to surface within the park.

Potential points of wastewater release to the surface or shallow environment include:

the septic tank: wastewater that cannot infiltrate in the drainfield is likely to back up into the septic tank and may be released through the riser/tank interface or riser lids;

conveyance system upline of the septic tank: wastewater may also back up into the sewer lines and manholes and be released into the environment through cracks, loose joints, or collapsed areas within the system; and soil downslope of the drainfield: wastewater ponding within the corrugated pipe of the drainfield creates hydrostatic pressure, and the wastewater may develop pathways to flow laterally, surfacing downslope of the drainfield area.

The Hurricane Ridge Visitor Center OSS was constructed in 1951, at a time when the number of visitors was much lower than current park use. The potential for imminent failure is a combination of aging infrastructure, increased use of the visitor center, and increase in wastewater strength due to the installation of water-reducing plumbing fixtures.

2. Contingency Plans for Summer 2020

We understands that NPS intends to continue limited weekend use of the Hurricane Ridge Visitor Center septic system from November 2019 through March 2020. Under the low-flow conditions, we believe that this will be acceptable. However, if the drainfield fails as a result of increased visitation during the summer season, the DOH may require changes in operation, temporary use of a holding tank, or other emergency measures in order to reduce or eliminate the risk to public health and environment. Depending on the severity of drainfield failure, the DOH may also require the NPS to discontinue use of the LOSS if necessary to protect public health and the environment.

Please submit for DOH review and approval an operating plan with contingency options for continued use of the existing LOSS from April 2020 until LOSS modifications to address the impending drainfield failure are completed. The plan should include frequent monitoring of the drainfield and identify resources to manage wastewater that cannot be discharged to the drainfield.

3. Requirements for LOSS modification

The NPS provided flow data from 2012 to 2019, which indicates that average daily flow during the peak months of July and August consistently exceeds 8,000 gallons per day (gpd). As such, the system meets the definition of a large onsite sewage system (LOSS), regulated under Washington Administrative Code (WAC) 246-272B. With the understanding that the increased wastewater flow is due to expanded use of the visitor center, the LOSS must conform to current design requirements of the regulations. There are several aspects of the existing drainfield that do not meet existing regulations. As such it is unlikely that it can be rehabilitated for ongoing use.

These deficiencies include:

The drainfield consists of a filter bed providing approximately 1600 square feet of infiltrative surface. During peak months, septic tank effluent is applied to the infiltrative surface at a rate equal to or greater than 5.0 gpd/day. This rate is a least five time greater than current design standards.

The current system does not have pressure distribution or timed dosing;

There is no identified reserve drainfield area; and A vehicular access road for septic tank pumping has been constructed over the top of the filter bed drainfield.

The configuration of Hurricane Ridge’s LOSS was typical of systems constructed in 1951, and the focus of such systems was disposal of waste. Current design practices include treatment units that ensure sustainable treatment of the wastewater prior to dispersal to the environment; they provide ongoing protection for both public health and the surrounding environment.

Modifications to the LOSS will need to provide this level of protection.

4. Steps for completing the LOSS modification

a. Identification of drainfield area

Your staff worked to complete fieldwork needed to identify the drainfield area for a replacement LOSS before snow accumulation prevented access to the area. On October 25, 2019, the DOH conducted a site inspection of soil test pits and confirmed Ms. Cook’s prior soil characterization. You will receive a separate letter from DOH Hydrogeologist Frank Baird regarding his findings, but we concur with her characterization of the soil in the area south of the visitor center. While the soils are suitable for drainfield, design considerations will need to address the complex soil profile, which includes a restrictive layer at depths of 22-61 inches below the ground surface underlain by Type 1 soils.

b. Predesign report A predesign report will be required as a means to establish the feasibility of the proposed LOSS modifications. The report will define the project parameters (wastewater flow, pollutant concentrations), describe the proposed treatment and dispersal methods, and identify a reserve drainfield area. Information supporting the protection of cultural resources will also be required.

c. Site risk survey Ms. Cook submitted a Site Risk Survey and supporting documents to DOH on October 31, 2019. However, we will perform a final evaluation using the information provided in the Predesign report, and will notify you in writing of our final requirements for the LOSS modification design.

d. Engineering report The DOH will require an engineering report, plans and specifications for your proposed LOSS modifications, in accordance with the LOSS new project review and approval process.

You will be notified of the decision to approve, or require changes to the design. If approved, the department will issue a notice to construct.

5. Operating Permit - Hurricane Ridge Visitor Center LOSS

As an operating LOSS, you are required to obtain an operating permit from the DOH. On October 23, 2019, you submitted an application for a LOSS permit for Hurricane Ridge Visitor Center. We have assigned a system ID of CLM045 to the site, and are developing system-specific conditions for the permit. At this time, we anticipate including conditions to continue with the Predesign Report, Engineering Report, and construction of the LOSS modifications. We will work with your staff to develop a reasonable timeline for completing the work.

Ms. Creachbaum, we appreciate the work your staff has done to ensure the NPS protects the public visiting the Hurricane Ridge Visitor Center. Your commitment to protecting the public health and the environment while preserving the Olympic National Park is evident, and we will continue to support you and your staff in designing and constructing the LOSS modifications in a timely manner.

Please do not hesitate to contact me if you have questions or would like to discuss the concerns identified in this letter.

Sincerely, Dotti F. Ramey, PhD, PE Supervisor, LOSS & Reclaimed Water Program Office of Environmental Health & Safety Division of Environmental Public Health cc: Lisa Turecek, P.E., Chief of Facility Management, Olympic National Park

Kerri Cook, P.E., Engineer, Olympic National Park Frank Baird, Hydrogeologist, LOSS Program, DOH Laura Homan, Compliance Manager, DOH

Print Date: December 09, 2019

Effective Date: October 23, 2019

Expiration Date: March 31, 2021

Large On-site Sewage System (LOSS)

OPERATING PERMIT

Issued by:

STATE OF WASHINGTON DEPARTMENT OF HEALTH

Office of Environmental Health & Safety Olympia, Washington

Authorizes National Park Service (Olympic National Park)

600 E Park Avenue Port Angeles, Washington 98362

To operate your LOSS in accordance with the standard and special conditions that follow:

Todd Phillips R.S.

Director, Office of Environmental Health & Safety Washington State Department of Health

System ID: CLM045

System Name Hurricane Ridge Visitor Center

System ID CLM045

Peak Design Capacity 10000 gallons per day

County Name Clallam County Department of Health and Human Services

System Location 3002 Mt Angeles Road, Port Angeles, Washington 98362

System Status Active

Treatment Description

In compliance with the provisions of Chapter 70.118B Revised Code of Washington, Large on-site sewage disposal systems, and Chapter 246-272B Washington Administrative Code

STANDARD PERMIT REQUIREMENTS

1. The owner must ensure that the wastewater treatment system is operated, monitored, maintained, and permitted in accordance with regulations in WAC 246-272B.

2. The owner and/or operator must ensure that effluent waste strength prior to dispersal meets quality limits established in this permit or if not specified, must be equal to or higher quality than septic tank effluent originating from a residential source.

3. FAILURE:

a. The owner must correct all failures and malfunctions of the LOSS immediately.

b. The owner must report any failure to the Department of Health (DOH) to 360-236-3330 or wastewatermgmt@doh.wa.gov within one business day of discovery.

4. The owner and operator must ensure that certain substances do not enter the wastewater treatment system. These include:

• Strong bases, acids, chlorinated solvents, or other toxic or hazardous substances;

• Fire or explosion hazards;

• Solid or viscous wastes that could plug sewer lines;

• Drainage from surface runoff, footing drains, roof drains, subsurface storm water infiltration systems, swimming pools, hot tubs, and other non-sewage drains; and

• Industrial wastewater.

5. The owner must notify DOH of change of ownership at least 30 days prior to the change.

6. OPERATOR: The owner must continuously employ one or more qualified operators meeting the requirements of WAC 246-272B-07200. The owner must notify DOH of change of operator(s) within 30 days.

7. The operator must monitor, record, and report flow data and ensure that the maximum volume of sewage generated does not exceed the approved design flow. Report flow as the average gallons per day.

Calculate it from monthly readings unless required otherwise in the Monitoring section of this permit.

8. Water quality and effluent quality analyses must be conducted by a laboratory accredited by the Washington State Department of Ecology.

9. With appropriate notice to the owner, DOH may enter in or onto the LOSS site or LOSS facility at reasonable times during normal business hours as necessary to verify compliance with permit conditions or to investigate public health or environmental concerns.

10. The owner and operator are required to maintain for at least 3 years accurate records of all monitoring and maintenance-related activities and to provide them to DOH on request.

11. RENEWAL:

a. The owner must submit a permit renewal application, fees, and other items required in this permit 30 days prior to expiration of this permit.

b. The owner must submit an annual operating report signed by the system operator that documents maintenance and monitoring activities noted in the system’s approved O&M Manual and Monitoring and Reporting Plan, or as directed by DOH.

Forms and publications related to LOSS can be found online at www.doh.wa.gov/LOSS.

System ID: CLM045 Printed/Amended Date: 10/23/2019

SYSTEM SPECIFIC PERMIT CONDITIONS

System ID: CLM045 Printed/Amended Date: 10/23/2019

Contact wastewatermgmt@doh.wa.gov if you have questions regarding permit conditions. Submittals not sent with renewal packet should be sent to wastewatermgmt@doh.wa.gov.

New Conditions

Other: Submit a predesign report to establish the feasibility of the proposed LOSS modifications. The report will define the project parameters (wastewater flow, pollutant concentrations), describe the proposed treatment and dispersal methods, and identify a reserve drainfield area. Information supporting the protection of cultural resources will also be required.

Contingency Plan. Submit for DOH review and approval an operating plan with contingency options for continued use of the existing LOSS from April 2020 until LOSS modifications to address the impending drainfield failure are completed. The plan should include frequent monitoring of the drainfield and identify resources to manage wastewater that cannot be discharged to the drainfield.

FAILURE: ENGINEERING SUBMITTALS: Submit an engineering report, construction plans, specifications, and draft operation and maintenance manual for the system repair. These submittals must meet the standards of chapter 246-272B WAC. Submit by 05/01/2020.

An Engineering Report with Plans and Specifications is required for LOSS modifications.

System ID: CLM045 Printed/Amended Date: 10/23/2019

MONITORING REQUIREMENTS

Flow Monitoring Required, see permit requirement 7 on page 2 of this permit