EPA: Duluth water system has significant deficiencies

DULUTH, MN. (Northern News Now) - A letter from the United States Environmental Protection Agency (EPA) to the city says, “The EPA has found evidence that your system has significant deficiencies.”

The letter was sent on November 8, following an inspection of the City of Duluth public water system in mid-August.

The purpose of the inspection was to make observations about the site conditions, operation, and monitoring of the System to evaluate compliance with the Safe Drinking Water Act.

The EPA letter in part reads, “A significant deficiency includes a defect in design, operation, or maintenance, or a failure or malfunction of the sources, treatment, storage, or distribution system that EPA determines to be causing, or has the potential for causing the introduction of contamination into the water delivered to consumers.”

In the letter, several “areas of concern” were discovered from the August 16 and 17 visit from federal inspectors.

The areas of concern ranged from maintenance of the systems to emergency contingencies, to physical and cyber security.

Responding to the report Director of Public Works and Utilities Jim Benning said in statement, “Public Works and Utilities are in receipt of a letter outlining the report from their August inspection of our water system. It outlines several repairs needed to the water infrastructure. It is important to note that the quality of our drinking water supply is not affected by anything in this report. Our department will continue to work through the items in the report and comply with the EPA’s request for a response addressing them in ten days.”

Areas of concern include:

The System is served by one intake pipe. The System does not have alternative sources of water or emergency connections.
A System employee stated the influent surge valve in the Lakewood Pumping Station was inoperable and could not be closed, potentially causing a flood in the station in a surge event. Repairs for the valve were denied.
The System stated during the walkthrough that the finished water ground reservoirs have never been inspected. A System employee stated that continued requests to have the storage structures inspected and water mixers installed in the storage structures have been denied by System management and engineering.
The System lacks technical, managerial, and financial (TMF) capacity based on numerous areas of concern identified in this report. In addition to the areas of concern in this report, the System has no dedicated in-house maintenance staff, several positions remain vacant, and preventative maintenance forms were not routinely or recently completed due to resource constraints. The System is currently running at two-thirds operational capacity, causing operators to often work multiple shifts in a day. The System stated that its revenue was spent on projects outside of it. The System’s safety coordinator position was vacant at the time of the inspection, which was stated as the reason for System staff being behind on several trainings.
The rotating screen had corrosion along the supporting base. The 36″ and 42″ pipes in the Lakewood Pumping Station had significant corrosion. General rust and corrosion were noted on the water lines in the Rapid Mix Gallery. The ammonia tank had paint flaking and corrosion on the bottom half and on the support structure. Significant corrosion was noted on the access hatch to the clearwell in the Filter Gallery. Corrosion was noted on the transfer, return, and sludge pump piping. Piping in the basement of the Recovery Station was heavily corroded. The clarifier was in poor condition with corrosion throughout the structure. Access ladders to filters were heavily corroded. Corrosion was noted on the piping inside the filters. The basement of the Woodland Pumping Station contained heavily corroded pipes. Rust was starting to form on the surge tank piping of the Middle Pumping Station. Piping throughout the Airport Booster Station was corroded in areas. Corrosion was noted on the piping inside the Bayview Pumping Station and on the Proctor Pumping Station’s pipes.
The structure of the Lakewood Pumping Station had a warped wall, and the roof was in disrepair.
The air vents on the pumps at the Upper Lakeside Pumping Station did not have screens. The pump’s air vents did not have screens and were taped in the Orphanage Pumping Station. The air vents on the pumps at the Woodland Pumping Station did not have screens. Reservoir A had two air vents, both with coarse screens. Two air vents were located near the suction gauge of the Endion Reservoir, and both had coarse screens. Both Middle Reservoirs had one air vent located in the center of each reservoir, both with coarse screens. The air relief vents located on pumps at the Highland Pumping Station did not have screens. It was unsure if the air vent on the concrete Arlington Reservoir had a fine mesh screen. The air vent of the grass-top Arlington Reservoir had a coarse screen. All Six West Reservoirs’ air vents had three coarse screens. The air relief vents located on pumps at the West Duluth Pumping Station did not have screens. The air relief vents on the pumps at the Proctor Pumping Station did not have screens.
Security issues were noted throughout the distribution system. The Upper Lakeside Tank did not have a secure perimeter surrounding the area. Significant graffiti was noted on the entire surface of the Upper Lakeside Tank. Graffiti was noted on both Woodland Reservoirs and the reservoirs did not have a fence surrounding the area. Graffiti was noted on both Reservoir A vents and was currently used as a soccer field. The lid of a main hatch of the Endion Reservoir was missing two bolts. Graffiti was noted on the concrete Middle Reservoir. Vegetation was noted along the sides of the concrete Middle Reservoir and fence line. The fence surrounding the Middle Reservoirs was damaged. Six hatches of the Six West Reservoirs were welded shut due to previous issues with the public accessing the reservoirs. The Six West Reservoirs did not have a fence surrounding the area. The fence surrounding the one access hatch of the Six West Reservoirs was locked, including an additional lock for the hatch, but the fence had gaps. Graffiti was noted on the air vents of the Six West Reservoirs. The fence surrounding the Bayview Reservoir was damaged and had significant vegetation along the fence line. The base of the Proctor Tank had graffiti on the surface.
The Upper Lakeside Tank was discolored, and the paint was flaking in several areas, most notably at the base. Significant graffiti and corrosion were noted on the entire surface of the Upper Lakeside Tank. The Orphanage Tank was discolored on the metal exterior, with portions of the exterior surface corroded. The underside of the Orphanage Tank’s overflow pipe was flaking and cracked due to corrosion. The System stated the Orphanage Tank was scheduled for an interior and exterior inspection in the fall of 2023, but it did not include repainting. The Highland Tank had discoloration on the underside. Corrosion was noted on the surface of the Bayview Reservoir. Corrosion and discoloration were noted on the entire exterior surface of the Proctor Tank.
An active drip was noted on a pipe on Pump #2 of the Orphanage Pumping Station. Liquid had accumulated on Pump #1 of the West Duluth Pumping Station and the source of the liquid was unclear.
Both East and West Woodland Reservoirs had negative drainage along the base of the structures. The West Duluth Reservoir had a depressional area surrounding the entire edge of the structure.
Reservoirs:
- Woodland Reservoir i. Efflorescence was noted along the sidewalls of both reservoirs. The concrete roofs and sidewalls of both were cracked and spalling. Significant staining and drip were noted on the sidewall of the West Woodland Reservoir.
- Middle Reservoirs i. The concrete siding and roof of the reservoir were cracked throughout and spalling.
- Bayview Reservoir i. The concrete pad for the reservoir had vegetation growing alongside it and was cracked and spalling. The bottom seal of the reservoir appeared broken.
- Endion Reservoir i. Edges of the reservoir were cracked and spalling.
The access hatches of Reservoir A did not have sanitary seals. Neither access hatches of the Endion Reservoir had sanitary seals. Four access hatches were located between the two Middle Reservoirs; all were locked but none had sanitary seals. The access hatch of the grass-top Arlington Reservoir was locked but did not have a sanitary seal. The access hatches of the Six West Reservoirs did not have sanitary seals.
The valve vault inside the fence line of Reservoir A contained valves but the System stated the valves are inoperable.
Significant vegetation was noted along the edges and roof of the Endion Reservoir. Vegetation was noted along the sides of the concrete Middle Reservoir. Vegetation was noted along the edges of the concrete top of the Arlington Reservoir. The entire edge of the West Duluth Reservoir was overgrown with vegetation. The concrete pad for the Bayview Reservoir had vegetation growing alongside of the structure.
A threaded sample tap was located on Pump #1 at the Arlington Pump Station. Threaded sample taps were noted on the piping inside the Highland Pumping Station. A System operator stated they were not sure if there were backflow prevention devices on the taps but did not think there were.
The overflow screen of Highland Tank seemed to have been blown out and was damaged.
At the time of the inspection, the SCADA screen read that the bypass valve was open, and the pumps were on. Neither the bypass valve nor the pumps were running at that time. The System operator was not sure whether the SCADA error was due to the power bump from the day prior or a larger issue with SCADA.
The overflow pipe of the Bayview Reservoir had no air gap, and the System was not sure where it drained to.
A pressure relief valve (PRV) on the backwash finished water line was actively leaking in the Rapid Mix Room. The leak had seeped through the adjacent wall into a hallway. A caution sign was placed on the standing water in the hallway to the Rapid Mix Gallery. The System stated one of two PRVs is due for replacement this fall; it was ordered in January of 2023 and the System is waiting for it to arrive.
The System stated the two clearwells have never been inspected to its knowledge. The System stated it had drained the clarifier to inspect but it has never been taken out of service for routine maintenance.
The System stated during a backwash event, the backwash pumping rate is at 23 MGD, which is higher than the typical 14 MGD producing rate of the plant. The System stated concerns about potentially pulling off the discharge line for backwashing and directing flow in the opposite direction. The System does not have a backwash tank to pull from. The Endion Reservoir level drops during a backwash. The System confirmed there are no backflow prevention devices to prevent backwash events from pulling off the distribution system.
The System does not have a formal Asset Management Plan. The System stated it is currently using the EAM application and GIS at Lakewood Water Treatment Plant (LWTP), used for asset management, on a “very limited basis.”
The System confirmed it does not conduct backflow prevention device inspections.
When EPA asked if the System has a cross-connection program, the System stated it does not; it has a local ordinance banning cross-connections and requirements for backflow prevention devices. The System stated plumbing inspectors will track cross connections and its backflow program.

In a statement from the City of Duluth’s Public Works Director, Jim Benning, he says:

Public Works and Utilities are in receipt of a letter outlining the report from their August inspection of our water system. It outlines several repairs needed to the water infrastructure. It is important to note that the quality of our drinking water supply is not affected by anything in this report. Our department will continue to work through the items in the report and comply with the EPA’s request for a response addressing them in ten days.

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