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REPORT OF COMPLIANCE SAMPLING INSPECTION (CSI)
AT
Sac and Fox Tribe of the Mississippi in Iowa (WWTF)
349 Meskwaki Road
Tama, Iowa 52339
NPDES NO: IA-0073750
February 3-6,2020
BY
U. S. ENVIRONMENTAL PROTECTION AGENCY
Region 7
Enforcement And Compliance Assurance Division (ECAD)
INTRODUCTION
I performed a Compliance Sampling Inspection (CSI) at the Sac and Fox Tribe of the Mississippi
in Iowa Wastewater Treatment Facility (WWTF) near Tama, Iowa, from February 3,2020,
through February 6,2020. The inspection was authorized by Section 308(a) of the Federal Clean
Water Act. This narrative report presents the findings of the inspection.
PARTICIPANTS
Sac and Fox Tribe of the Mississippi in Iowa (Sac and Fox)
Roger Eberhart, WWTF Operator, h20op.mpw@meskwaki-nsn.gov
U. S. Environmental Protection Agency (EPA)
Joe Heafner, Life Scientist (913) 551-7091 (Lead Inspector)
PROCEDURES
I arrived, unannounced, at the Sac and Fox WWTF at 1:00 p.m. on February 3,2020, and I
introduced myself to Mr. Eberhart, presented my credentials, and explained the purpose and
procedures of the inspection. These procedures included completing the Water Compliance
Inspection Report (attachment 1), an EPA Region 7 Biosolids Checklist (attachment 2) facility
walk-through with photos (attachment 3), a check of the self-monitoring records, the collection
of influent and effluent samples, and an exit interview.
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From February 3,2020, through February 6,2020,1 used an I SCO model 3710 automatic
composite sampler to collect a 24-hour composite sample of the influent before the grit chamber.
I suspended a weighted length of new Tygon tubing into the influent channel. I connected the
other end to the sampler pump and programmed it to collect evenly spaced aliquots every 15
minutes into a clean Nalgene bottle, which was packed in ice. I returned each day to service the
sampler. I removed the bottle, agitated its contents and poured them into clean, pre-labeled
containers for the analysis of Biochemical Oxygen Demand (BOD), Non-Filterable Solids
(NFS), Ammonia, and Total Kjeldahl Nitrogen (TKN). I measured the pH and temperature in a
separate grab sample using a field meter.
I used an ISCO model 3700 automatic composite sampler to collect a 24-hour composite sample
of the effluent from the effluent channel after the Ultraviolet (UV) channel (UV was not in use
during the inspection) from February 3,2020, through February 6, 2020.1 suspended a weighted
length of new Tygon tubing into the channel preceding the discharge to the receiving stream. I
connected the other end to the sampler pump and programmed it to collect evenly spaced
aliquots every 10 minutes into a clean Nalgene bottle, which was packed in ice. I returned each
day to service the sampler. I removed the collection bottle, agitated its contents and poured them
into clean, pre-labeled containers for the analysis of BOD, NFS, TKN, and Ammonia. I
measured the pH and temperature in a separate grab sample using a field meter.
On February 5,2020,1 took a grab sample of the digested biosolids from the facility. I allowed
the digested biosolids to settle, decanted the water, then placed the digested biosolids into clean
8-ounce jars for the analysis of total metals(except for Mercury) and percent solids.
Each day, I placed the samples I collected on ice in an ice chest with field sheets and chain of
custody documents, sealed the container and shipped it overnight to the EPA Region 7 Science
and Technology Center (STC) for analysis. I followed Region 7 standard operating procedures in
the collection, packaging, transportation and handling of the samples. Samples that were
collected and shipped on February 4,2020, and February 5,2020, did not arrive to the STC on
time to complete the analysis of Biochemical Oxygen Demand (BOD) within the proper holding
times. All other samples arrived at the STC within proper holding times.
FACILITY DESCRIPTION
The Sac and Fox WWTF is owned and operated by the Meskwaki Nation. The physical address
for the WWTF is approximately 500 yards south of the casino/hotel complex on the Meskwaki
Settlement east of Tama, Iowa. The legal description is the NW 1/4, Section 23, Township 83
North, Range 16 West within Tama County (attachment 4). The WWTF treats domestic
wastewater from the casino/hotel complex, a convenience store, approximately 350 residential
homes, and 15 tribal buildings. Final effluent from the WWTF is discharged on a continuous
basis to an unnamed tributary (locally known as Onion Creek) of Iowa River (Outfall 001).
The WWTF consists of a screening building (automatic bar screen and grit removal), a three
train Aeromod® extended aeration activated sludge treatment system, sludge press, and an
2
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Ultraviolet (UV) disinfection system. At the time of the inspection, the UV system was not in
operation. Biosolids are wasted from the settling tanks to one of three aerobic digesters located
on the east end of each train. Biosolids are treated, thickened, and then dewatered through the
use of a sludge press. The dewatered biosolids are then transported to a local sanitary landfill for
disposal. The facility also operates a three-cell equalization basin system that is utilized during
high flows. Wastewater can be diverted to the basins during the high flow events and then held
until the water can be brought back through the headworks and treated. The facility does have
the capability to discharge from the three-cell lagoon system to the unnamed tributary through
Outfall 002. Mr. Eberhart stated that the facility has not discharged through this outfall in some
time.
The WWTF's National Pollutant Discharge Elimination System (NPDES)
Permit IA-0073750 was issued on April 2,2018 (attachment 5). The permit expires on April 1,
2023.
The NPDES permit also includes the filter backwash water and the Reverse Osmosis reject water
from the drinking water treatment plant (Outfall 003). This outfall was not inspected during this
inspection.
FINDINGS AND OBSERVATIONS
The following findings were noted during the plant and record review. A complete summary is
given in the NPDES Compliance Inspection Report (attachment 1). These findings were
discussed with Mr. Eberhart during the exit meeting.
Self-Monitoring Data Review:
Prior to the inspection, I obtained a spreadsheet of the NetDMR data for the Sac and Fox WWTF
from January 2017 through January 2020.1 received the Excel spreadsheet on January 21,2020,
and reviewed the data. The review noted that the facility reported that the facility violated the
effluent limits for BOD and Ammonia in September 2017.
During the inspection I reviewed the Discharge Monitoring Reports (DMRs) for 2018 and 2019
for completeness. The review included all laboratory data provided to the Sac and Fox from their
contract laboratories. After the completion of the inspection, Mr. Eberhart provided via email the
2019 Discharge Monitoring Reports including the laboratory data sheets provided to him. After
receiving the data, I copied the Excel spreadsheet and Discharge Monitoring Reports to a
Compact Disc (CD) and placed the CD in the permanent file of the facility.
During the inspection Mr. Eberhart stated that he was having issues entering the required DMR
data into the NetDMR electronic system. Mr. Eberhart stated that his permit requires him to test
his influent and effluent on a monthly basis; however, he only is to report on a quarterly basis.
During the inspection he showed me that he could not enter in data points for all three months.
3
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Mr. Eberhart stated that in order to comply with the permit conditions, he has been averaging the
three-month monitoring period for each parameter and then entering that data into the NetDMR
system. During the inspection we contacted Erin Kleffner of EPA to get advice on how to report
the data correctly. She stated that it was not ideal; however, the facility could report the highest
monthly results throughout the three-month monitoring period, and this would allow for the data
entry into NetDMR. Mr. Eberhart stated that he would start entering the data into NetDMR in
this way to comply with the monitoring requirements of the permit. At that time, I also cautioned
Mr. Eberhart to keep records of all sampling data as required by his permit.
Sample Results
The analytical results from the inspection were received on March 4,2020, from the Region 7
STC laboratory. This data was not discussed during the exit interview. The analytical results for
BOD, NFS, TKN, Ammonia, pH, and temperature of the samples I collected are presented in
Table 1 and 2 below. See attachment 6 for the analytical data packet.
After receiving the analytical results on March 4,2020,1 calculated the loading rates for BOD,
NFS, and Ammonia and those are presented in Table 3.
Table 1: Analytical Results for Influent
Parameter
(February 4)
Sample # 1
(February 5)
Sample #2
(February 6)
Sample #3
BODs (mg/L)1
135 J5
165 J5
194 J5
NFS (mg/L)
138
131
157
TKN (mg/L)
25.9
26.6
30.9
Ammonia (mg/L)
17.0
16.2
18.1
Temperature (°C)3
12.7
12.5
12.2
pH4
7.55
7.81
7.27
'mg/L = milligrams per liter
2 Samples 1,2, and 3 were J coded for BOD due to high recovery of the analyte in the laboratory
control sample. The actual concentration may be lower than the reported value.
3 °C = degrees Celsius, Temperature was measured in the field.
4 pH is not to be averaged; pH was measured in the field.
4
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Table 2: Analytical Results for Effluent Samples Collected During Inspection
Parameter
(February 4)
Sample# 11
(February 5)
Sample #12
(February 6)
Sample # 13
Concentration
Permit Limits5
BOD5 (mg/L)1
7.142
2.02 J3
5.38 J3
30/40
NFS (mg/L)
13.3
4.08
4.09
80/120
Ammonia (mg/L)
ND
ND
ND
Seasonal
3.55/7.11 for
February
TKN (mg/L)
2.20
1.23
1.31
N/A
Temperature (°C)4
9.9
9.8
9.4
N/A
pH3
7.86
7.60
7.5
6.0-9.0
Flow in MGD
0.187 MGD
0.166 MGD
0.167 MGD
N/A
'mg/L = milligrams per liter.
2 Samples 11 and 12 was not qualified as the sample was analyzed outside of the required holding time.
3Sample 12 and 13 were J coded for BOD due to high recovery of the analyte in the laboratory control
sample. The actual concentration may be lower than the reported value.
4oC = degrees Celsius, pH is not to be averaged, pH was measured in the field.
5Permit limits for CBOD and NFS are Monthly followed by 7-day Averages. Permit limits for Ammonia
are Monthly averages followed by Daily Maximum.
Table 3: Calculated Loading Rates Based on Analytical Results for Effluent Samples
Collected During Inspection
Parameter
(February 4)
Sample #11
(February 5)
Sample #12
(February 6)
Sample #13
Mass Permit
Limits1
BOD5 (lbs/day)
9.99
2.48
6.72
105.08/157.63
NFS (lbs/day)
18.60
5.07
5.11
105.8/157.63
Ammonia
(lbs/day)
ND
ND
ND
7.92/20.74
Flow in MGD
0.187 MGD
0.166 MGD
0.167 MGD
N/A
'Permit limits for CBOD and NFS are Monthly followed by 7-day Averages. Permit limits for Ammonia
are Monthly averages followed by Daily Maximum.
Samples collected during the inspection indicate that the facility was in compliance with the
effluent limits set forth in the NPDES permit.
5
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Biosolids (sludge)
As mentioned above, the facility currently utilizes three aerobic digesters to treat and store the
biosolids. Treated biosolids are dewatered two to three times per year via a belt filter press. Mr.
Eberhart stated that the dewatered biosolids are placed in a dump truck and then taken to the
Tama County Sanitary Landfill. Mr. Eberhart stated that the facility hauled approximately 45.13
tons of biosolids to the landfill in 2019.
I asked Mr. Eberhart if the facility had ever conducted a hazardous waste determination on the
biosolids and he stated no. I then provided to Mr. Eberhart a copy of the EPA guidance for
landfilling biosolids, which states that a determination needs to be conducted to ensure that the
biosolids are non-hazardous before disposing in the landfill. Mr. Eberhart stated that he would
order the testing before sending another load of biosolids to the landfill.
Laboratory
The facility utilizes a contract laboratory (City of MarshalItown, Iowa) for the analysis of BOD,
TSS, NH3. Mr. Eberhart stated that the facility also utilizes Test America Laboratories in Cedar
Falls, Iowa for E.coli analysis. During the inspection I reviewed laboratory records to ensure that
all analysis complied with requirements of 40 CFR part 136. After the inspection I requested that
Mr. Eberhart provide the laboratory data sheets for 2019.1 reviewed the data and noted that all
data was consistent with the monthly and quarterly monitoring. I also noted that all holding times
were met and all methods appeared to meet requirements of 40 CFR part 136. Mr. Eberhart
stated that they keep a logbook of when he calibrates the pH meter.
Collection System
During the inspection I discussed the collection system with Mr. Eberhart. He stated that the
average age of the collection system is 40 years old with sections that are newer and older. Mr.
Anderson stated that there were approximately 15 miles of sanitary sewers in the city. He stated
that approximately three to five miles of the system is cleaned each year. There are three lift
stations within the system (Spring Road, Casino and one north of Highway 30). We observed all
lift stations during the inspection. All lift stations have an auto-dialer and/or audible alarm
system that notifies the operators or issues at the lift stations. All lift stations appeared to be in
good working condition at the time of the inspection.
Mr. Eberhart stated that the collection system does not typically have any sanitary sewer
overflows or complaints of basement backups. When the facility does get a complaint of a
basement backup, the facility investigates to make sure that the collection system is ok.
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Operational Issues and Observations
1. [ observed all areas of the WW I F during the inspection (photos 1 - 6). 1 noted thai all
the treatment units were in good operating condition at the lime of the inspection.
2, I observed the outfall and the receiving stream during the inspection (photos 8-9), As
noted earlier, the facility discharges on a consistent basis to the unnamed tributary of
the Iowa River. I noted that in general the effluent appeared to be free of solids.
During the observation of the unnamed tributary. 1 noted that the streambed was free
of solids or other debris from the facility. 1 completed an KPA Stream Characteristics
and Water Nexus form lor the unnamed tributaries of Silver Creek (attachment 8 and
photos 4-6).
Summary
The facility needs to ensure that all Discharge Monitoring Reports are submitted as accurately as
possible and on time. Sac and Fox, per the discussion with F.PA, should report the highest value
found during the monthly analyses. The facility must maintain all records of analyses per the
permit requirements.
The facility needs to conduct a hazardous waste determination on the biosolids that are disposed
of in the sanitary landfill.
The Sac and Fox should continue efforts to reduce and eliminate Inflow and Infiltration (I&l)
within the sanitary sewer s\ slem.
/ "T
'' N
Joe I lealVfer David I'ratl
/ / f
f'Fife Scientist Acting Section Chief
Date: 3f)Z-1-zoz. 'o Date: C V < t \ v
Attachments:
1. Water Compliance Inspection Report, Form 3560-3 (4 pages)
2. FPA Region 7 Biosolids Checklist (3 pages)
3. Digital Photographs with Photo Fog (6 pages)
4. Facility Satellite Photos/Maps (2 pages)
5. NPDHS permit issued on April 2. 2018 (19 pages)
6. laboratory Analytical Report for Activity J A112010 (7 pages)
7. liPA Stream Characteristics and Water Nexus Form (2 pages)
7
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PHOTO LOG
Facility Name / Address: Sac and Fox of the Mississippi in Iowa WWTF
349 Meskwaki Road
Tama, IA 52339
State Facility ID#:
Facility EPA ID#: IA-0073750
Date: February 3-6,2020
Image Numbers: DSCN2529 - DSCN2537
File Name (if any): N/A
Photographer: Joe Heafner
Type of Camera: Nikon Coolpix AW100, Serial #: 32157507
Digital Recording Media: Flashcard
All digital photos were copied by: Joe Heafner on February 20,2020
All digital photos were copied to: CD-R
Original copy is stored in: CD-R. Digital photos were downloaded to CD-R all by Joe Heafner. No
changes were made in the original image files prior to storage on the CD-R.
Report
Photo #
Photographer
Date
Approx.
Time
Flashcard Name
(DSCNxxxxJPG)
Description
1.
Joe Heafner
2/4/20
1425
DSCN2529
This photograph shows the inside of the influent building that
includes an automatic bar screen and grit screw. EPA sampler
can be seen in middle of photo.
2.
Joe Heafner
2/4/20
1427
DSCN2530
This photograph shows the third "train" of the treatment system
including the aerobic digester and mixing zone.
3.
Joe Heafner
2/4/20
1427
DSCN2531
This photograph shows the clarifier portion of the 3rd "train" in
the treatment system.
4.
Joe Heafner
2/4/20
1428
DSCN2532
This photograph shows the 1st and 2nd "train" of the treatment
system.
5.
Joe Heafner
2/4/20
1428
DSCN2533
This photograph shows the clarifier portions of the I" and 2nd
"train" of the treatment system.
6
Joe Heafner
2/4/20
1435
DSCN2534
This photograph shows the biosolids press. Biosolids from the
clariflers are wasted to the press and dewatered. Biosolids then
are disposed of in a sanitaiy landfill off site.
7.
Joe Heafner
2/4/20
1438
DSCN2535
This photograph shows the old three-cell lagoon system that was
converted until a stormwater equalization basin. During high
flows wastewater is diverted to the lagoons then fed back to the
mechanical plant as flow slows down.
8.
Joe Heafner
2/4/20
1607
DSCN2536
This photograph shows the unnamed tributary (aka Onion Creek)
downstream of outfall 001.
9.
Joe Heafner
2/4/20
1607
DSCN2537
This photograph shows the unnamed tributary (aka Onion
Creek). Looking northwest towards Outfall 001.
Attachment _3_Page—
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Sac and Fox of the Mississippi in Iowa WWTF
Iowa
2 .5 .'.(12(1 2/(}/202(!
Compliance Sampling
Inspection
Direction: Southwest
DliSCKir [ K IN
;[K"h Uk' - .j[i Jljtliill.lt ic !- .L!' ¦I'jYl.'li .Kid V ri' ''¦i.TCU . s .1 \ \ ^l^pld'
can Iv seen in middle of photo.
1
Dale
2 4 20
I'ISOIlX.RAI'lil-'R
Joe 1 icatncr
~»SS«;
I
Compliance Sampling
Inspection
Direction: Northeast
DKSCRIIMION
I hi.s photograph shows the third "train" ol'ihe treatment
sv stem including the aerobic digester and inking /one
2
Date
2 4 20
I'lK IKKiRAI'iil R
Joe 1 leattiei
Attachment Page ^ of Ce
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Sac and Fox ot'tlu- .\lisMNM[>|)i in Imva WWII'
Tama, lowu
2/3/2(12(1 - 2/6/202(1
Compliance Sampling
Inspection
DESCRIPTION
I'his photograph shim* the clarifier portion of the 3,d "train™ in
3
tiie treatment s\stem
1 )ate
1 Jireetion: Northeast
PHOTOGRAPHER
Joe Heather
2)4/20
Compliance Sampling
Inspection
Directum: Northeast
DESCRIPTION
PI IO I (KiRAPHEK
1 his photograph slums the IJ and 2riS "train" of the
Ueatnient system.
Joe 1 ie.tfticr
Attachment Page 3 of (f
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Sac ;uul l"o\
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Sac and Fox of (he Mississippi in Iowa WWI I*"
l ama. Sown
2 .*'70211 - 2'6<2II?0
(,'nniplimiee Sampling
Inspection
Direction: South
DESCRIPTION
This photograph shows the old three-cell lagoon system that
was converted until a storm water equalization basin. During
high (lows wastewater is diverted to the lagoons then fed back
lo the mechanical plant as flow slows down.
7
Date
2/4/20
PHOTOGRAPHER
Joe Heather
«::#
¦
SS'Sr.
tKKKKm
Compliance Sampling
Inspection
Direction: Southwest
'JiQIIIIH^HI
- .SBMBMflNMHBI
DI'.Sl Rll' i ION
IMIOTI KiRAI'lIHR
1 his photograph .show \ (he tmrtaim
( reck i downstream of out Kill 001.
Joe I fcolncr
Attachment
3 Rage of &
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Sac ;iml lro\ of the Mississij>pi in iltow> I he unnamed trihutun (;ika Onion
("reeks, I.ookim> northwest inwards
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