Itemized Corrective Actions for EPA Executed.pdf
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- Attached to
- RFQ - Sewer Master Plan
- Solicitation number
- S-KS0030-00016043
- Issued by
- Benton County, Oregon
About this file
This document is an itemized corrective actions response from the City of Seaside, Oregon to the U.S. Environmental Protection Agency (EPA) following a desk audit of the City's wastewater treatment facility (OR0020401) conducted on April 24, 2024. The audit identified eight alleged violations of the National Pollutant Discharge Elimination System (NPDES) permit, including failure to submit a required toxicity sampling report (submitted February 10, 2023), failure to sample alkalinity in November 2023, exceedances of E. coli limits in October and December 2023 (629/100mL and 2,419/100mL respectively, against a permit limit of 406/100mL), and multiple total suspended solids (TSS) exceedances in December 2023 across monthly average (599 lb./d against 560 lb./d limit), daily maximum (3,414 lb./d against 1,100 lb./d limit), weekly average (1,833 lbs./d against 840 lb./day limit), removal efficiency (67% against 85% requirement), and concentration levels (134 mg/L against 45 mg/L limit). The City has elected to resolve these violations through an expedited settlement agreement without contesting the findings.
The City's corrective actions include modification of internal worksheets for permit-required sample recording, implementation of the H1 DMR Data Workbook for bacteria resampling procedures, and instruction to operators to maximize UV dose when fecal exceedances occur. For the TSS exceedances, the City attributes the violations to a single overnight clarifier blanket overflow incident accompanied by system-wide flooding and sanitary sewer overflows that were beyond reasonable control; the City commits to timely reporting to the Oregon Department of Environmental Quality and inclusion of noncompliance reports in future discharge monitoring reports should similar imbalances occur. The document is certified under penalty of law by a Contracted System Supervisor.
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1930 N Beaver Creek Rd. Seal Rock, OR 97376 Telephone 708-606-5249
To: Katrina Chambon, US EPA
Re: City of Seaside ESA, Itemized Corrective Actions
July 11, 2024
On April 24th, 2024, the EPA did a desk audit of City of Seaside OR0020401 wastewater treatment facility and identified the alleged violations. September 2022 failed to submit toxicity sampling report due October 15, 2022. The report was submitted February 10, 2023. November 2023 failed to sample alkalinity. October 2023 and December 2023 exceedance of E. coli; the permit limit is 406 E. coli organisms/100 milliliter (#/100 mL), and the results are 629/100mL and 2,419/100mL., respectively. December 2023 total suspended solids (TSS) exceedance of the monthly average of 560 pounds per day (lb./d), daily maximum of 1,100 lb./d, and weekly average of 840 lb./day; results are 599 lb./d, 3,414 lb./d, and 1,833 lbs./d, respectively. TSS exceedance of monthly average percent (%) removal of 85%, the result is 67%. TSS exceedance of weekly average of 45 milligrams per liter (mg/l), result is 134 mg/L. January 2024 exceedance of minimum pH of 6.0, the result is 5.8.
The City of Seaside self-reported the alleged violations, will not contest them, and wishes to resolve them via execution of an expedited settlement agreement. As part of the settlement process, the city is expected to elaborate on the actions taken by the city to correct the reported violations. An itemized list of corrective actions is listed below.
Violation #1 – Failure to submit required toxicity sampling report.
Corrective Action – The aforementioned report was submitted on February 10, 2023
Violation #2 - November 2023 failure to sample alkalinity.
Corrective Action – City staff have modified the internal worksheets used for recording permit required samples. The city has not failed to sample alkalinity since November 2023.
Violation #3 - October 2023, exceedance of E. coli; the permit limit is 406 E. coli organisms/100 milliliter (#/100 mL), and the results are 629/100mL.
Corrective Action – The City has added a spreadsheet to the internal worksheets used for recording permit required samples that includes “H1 DMR Data Workbook - Bacteria Special Report”. This is a worksheet that includes the procedure and calculations for the
SolidsDude Solutions LLC resampling of bacteria for reporting purposes. Should a bacterial exceedance occur the city is allowed to resample and average results per NPDES permit OR0020401. Operators are instructed to turn up the UV dose to the maximum extent possible when fecal exceedances occur.
Violation #4 - December 2023 exceedance of E. coli; the permit limit is 406 E. coli organisms/100 milliliter (#/100 mL) the results were 2,419/100mL.
Corrective Action – The City has added a spreadsheet to the internal worksheets used for recording permit required samples that includes “H1 DMR Data Workbook - Bacteria Special Report”. This is a worksheet that includes the procedure and calculations for the resampling of bacteria for reporting purposes. Should a bacterial exceedance occur the city is allowed to resample and average results per NPDES permit OR0020401. Operators are instructed to turn up the UV dose to the maximum extent possible when fecal exceedances occur.
Violation # 5, 6, 7, 8 - December 2023 total suspended solids (TSS) exceedance of the monthly average of 560 pounds per day (lb./d), daily maximum of 1,100 lb./d, and weekly average of 840 lb./day; results are 599 lb./d, 3,414 lb./d, and 1,833 lbs./d, respectively. TSS exceedance of monthly average percent (%) removal of 85%, the result is 67%. TSS exceedance of weekly average of 45 milligrams per liter (mg/l), result is 134 mg/L.
Corrective Action – These exceedances are all the result of a single incident in which a clarifier blanket overflowed the weir and resulted in a loss of solids through the outfall. The incident occurred overnight and was immediately corrected by operators the following morning. Samples were collected and results reported on DMR. The overflow was beyond the City’s reasonable control as it was accompanied by system wide flooding and SSO’s. Should an imbalance occur again in a clarifier it will be reported to the Oregon Department of Environmental Quality in a timely manner and a noncompliance report will be included in the discharge monitoring report.
I certify under penalty of law that this document and all attachments were prepared under my direction or supervision in accordance with a system designed to assure that qualified personnel properly gather and evaluate the information submitted. Based on my inquiry of the person or persons who manage the system, or those persons directly responsible for gathering the information, the information submitted is, to the best of my knowledge and belief, true, accurate, and complete. I am aware that there are significant penalties for submitting false information, including the possibility of fine and imprisonment for knowing violations.
Signed __________________
Title: Contracted System Supervisor
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