Florida Department of Environmental Protection Northwest District Branch Office Capital Circle Northeast Tallahassee, Florida 32301

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1 Florida Department of Environmental Protection Northwest District Branch Office Capital Circle Northeast Tallahassee, Florida Charlie Crist Governor Jeff Kottkamp Lt. Governor Michael W. Sole Secretary August 20, 2009 BY ELECTRONIC MAIL Mr. Hank Garrett, Manager East Point Water & Sewer District 40 Island Drive Eastpoint, Florida Dear Mr. Garrett: On June 15, 2009, a Department representative conducted a Domestic Wastewater inspection of the Eastpoint Wastewater Treatment Plant. A copy of the inspection report is enclosed. Please address the Inspection Comments noted in the report regarding the Out-of-Compliance rating. We are requesting corrective action or a written response within 30 days of the date of this letter. Please note that this letter and report, being part of the Department s investigation, is preliminary to agency action in accordance with Section (5), Florida Statutes. If you have any questions, please contact Michelle Fish at 850/ or Michelle.Fish@dep.state.fl.us. Sincerely, Marlane Castellanos Branch Manager MC/mf Enclosure c: David Morres, FDEP (David.Morres@dep.state.fl.us) Kim Allen, FDEP (Kim.Allen@dep.state.fl.us) Kacey Smith, FDEP (Kacey.J.Smith@dep.state.fl.us) Jennifer Paris, FDEP (Jennifer.Paris@dep.state.fl.us) More Protection, Less Process

2 FLORIDA DEPARTMENT OF ENVIRONMENTAL PROTECTION WASTEWATER COMPLIANCE INSPECTION REPORT FACILITY AND INSPECTION INFORMATION COMET ENTRY DATE 6 / 15 / 09 Name and Physical Location of Facility WAFR ID: County Entry = Optional Eastpoint Water & Sewer District WWTP FLA Franklin 10:00:00 AM Sewer Plant Road Phone Exit Date/Time Eastpoint, Florida (850) :34:00 PM Name(s) of Field Representatives(s) Operator Certification # Phone Mr. Hank Garrett Lead Operator C (850) Name and Address of Permittee or Representative Title Operator Certification # Mr. Hank Garrett Manager (850) Eastpoint Water & Sewer District 40 Island Drive Eastpoint, FL Inspection Type: C E I Samples Taken(Y/N): Sample ID#: Samples Split (Y/N): Domestic Industrial Were Photos Taken(Y/N): Log book Volume Page FACILITY COMPLIANCE AREAS EVALUATED IC: In Compliance; NC: Out of Compliance; SC: Significant out of Compliance; NA: Not Applicable; NE or Blank: Not Evaluated Significant Non-Compliance Criteria Should be Reviewed when Out of Compliance Ratings Are Given in Areas Marked by a PERMITS/ORDERS SELF MONITORING PROGRAM FACILITY OPERATIONS EFFLUENT/DISPOSAL IC 1. Permit NC 3. Laboratory IC 6. Facility Site Review IC 9. Effluent Quality NA 2. Compliance Schedules NC 4. Sampling IC 7. Flow Measurement NC 10. Effluent Disposal IC 5. Records & Reports IC 8. Operation & Maintenance IC 11. Residuals/Sludge 13. Other: IC 12. Groundwater Facility and/or Order Compliance Status: In-Compliance Out-Of-Compliance Significant-Out-Of-Compliance Recommended Actions: Name(s) and Signature(s) of Inspector(s) District Office/Phone Number Date Michelle Fish TBO/ (850) Signature of Reviewer District Office/Phone Number Date Marlane Castellanos TBO/ (850) /20/2009

3 INSPECTION COMMENTS Eastpoint WWTP, PERMITS/ORDERS 1. Permit: In Compliance FDEP Permit FLA was issued July 29, 2005 and expires on July 28, At the time of inspection, a copy of the permit was onsite and available for review. An application for renewal should be submitted at least 180 days prior to expiration of the current permit. 2. Compliance Schedule: Not Applicable SELF MONITORING PROGRAM 3. Laboratory: Out of Compliance Total Residual Chlorine (TRC) and ph samples are analyzed using a Hach Pocket Colorimeter II. The meter is calibrated using secondary gel standards as part of the DPD method for TRC analysis and ph buffer 7 s.u. and Phenolred solution for ph analysis. A Hach Sension6 Dissolved Oxygen meter and Hach Inline Surface Scatter 6 turbidimeter are used for in-house process control. The Phenol-red test to analyze ph is not an approved method by the Department or the U.S. Environmental Protection Agency. This method is not deemed acceptable because color verification measurement is not accurate and Phenol-red tests do not compensate for temperature. A Department approved method should be used for compliance reporting (See Figure 1, attached). Florida Administrative Code : (1) Field testing, sample collection and preservation; and laboratory testing, including quality control procedures, shall be in accordance with methods approved by the Department and the United States Environmental Protection Agency. (2) Approved test procedures shall be in accordance with the following publications which are hereby incorporated by reference:

4 Page 2 (a) Annual Book of Standards, Volumes and (Water I and II), American Society for Testing and Materials, 1916 Race Street, Philadelphia, Pennsylvania, (b) Methods for Chemical Analysis of Water and Wastes, EPA-600/ ,March 1979, Revised 1983, Environmental Protection Agency. National Technical Information Service, Department of Commerce, Springfield, VA (Publication No.PB ). (c) Standard Methods for the Examination of Water and Wastewater, 16th Edition, American Public Health Association, th Street, N.W., Washington, D.C (3) Any laboratory tests required by this rule shall be performed by a laboratory that has been certified by HRS in accordance with Rule 10D , F.A.C., to perform that test. On-site tests for dissolved oxygen, ph, and total chlorine residual shall be performed by a laboratory certified to test for dissolved oxygen, ph, and total chlorine residual or under the direction of an operator certified in accordance with Chapter 61E12-41, F.A.C. It was noted that meters are not being properly calibrated. It was also noted that composite samples are refrigerated; however, the in-house thermometer is not verified by a certified laboratory thermometer. Facility staff should calibrate and verify the TRC meter, ph meter and lab thermometer according to DEP Standard Operating Procedures (SOPs). Staff should also maintain calibration logs for all meters used in compliance reporting. Since the inspection, facility staff has been provided with guidance documents on proper meter calibration and verification. Permit No. FLA010065, Part V: 5. The permittee shall maintain the following records and make them available for inspection on the site of the permitted facility: a. Records of all compliance monitoring information, including all calibration and maintenance records and all original strip chart recordings for continuous monitoring instrumentation and a copy of the laboratory certification showing the certification number of the laboratory, for at least three years from the date the sample or measurement was taken; The Water Spigot in Panama City conducts analysis of biweekly samples for Five Day Carbonaceous Biological Oxygen Demand (CBOD5), Total Suspended Solids (TSS), and Fecal Coliform.

5 Page 3 4. Sampling: Out of Compliance Grab samples for TRC and ph are collected daily for onsite analysis. Biweekly grab samples are collected for Fecal Coliform. Influent and effluent samples for analysis of CBOD5 and TSS are required to be collected via eighthour flow proportioned composites on a biweekly basis. Facility staff stated that 200 ml grab samples are taken every two hours over an eight-hour period to represent a composite sample. Samples should be flow proportionate. Since the inspection, facility staff has been provided with guidance documents on proper meter calibration and verification. Florida Administrative Code : (18) "Flow-proportioned composite sample" shall consist of samples collected at hourly intervals. The volume of each individual sample which is used to form the composite shall be proportional to the flow at the time of collection. Equal-volume composite sampling may be used provided that the time between samples is inversely proportional to the cumulative flow since the previous sample, and provided that the number of individual samples is equivalent to the number which would be required if hourly samples were used for composite sample formation. A review of the Chain of Custody forms indicates that samples for all parameters consistently have been analyzed within prescribed holding times. 5. Records and Reports: In Compliance All Monthly Discharge Monitoring Reports (DMRs), Chain of Custody forms, Quarterly Groundwater Monitoring Reports (GMRs), Operations and Maintenance (O&M) Manual, and daily operational logs were onsite and available for inspection. As noted above, meter calibration records should be maintained.

6 Page 4 FACILITY OPERATIONS 6. Facility Site Review: In Compliance The facility is securely surrounded by a cyclone fence. The grounds, including the spray fields, are mowed regularly. The walkways and railings of the plant were secure and stable. Disinfection is achieved using Chlorine gas. The storage building for the chlorine gas tanks features audio and visual alarms, leak detection, and adequate ventilation provided by fans near the floor. Emergency eyewash and breathing apparatus were readily accessible. An onsite diesel generator is capable of assuming all plant operations, and is tested weekly under load. Backflow prevention devices are to be certified at least once annually. The onsite RPZ backflow prevention device was last inspected and certified by Clay Moore of Moore s Backflow Service on April 10, Flow Measurement: In Compliance The primary flow measurement device is a 60 V-notch weir at the outfall of the Chlorine Contact Chamber (CCC). An American Sigma 950 ultrasonic flow meter with accompanying Honeywell Truline chart recorder serves as the secondary device. A review of the DMRs from January 2008 through May 2009 indicates that this million gallons per day (MGD) permitted facility experienced an average monthly flow of MGD. The flow meter is to be calibrated and certified annually. The last calibration was performed by Tim Johnson of Florida Rural Water Association on December 9, 2008.

7 Page 5 8. Operation and Maintenance: In Compliance The facility is staffed by a Class C (or higher) operator a minimum of three hours per day for six days each week. This facility consists of preliminary treatment, dual SBRs, dual sand filters, disinfection and disposal at an onsite sprayfield. Preliminary treatment consists of a microscreen and grit chamber cyclone degritter. Materials collected from the headworks are stored in a waste bin for transport and disposal at the Franklin County landfill. After screening, influent is stored in an aerated equalization tank before being pumped to SBRs. Dual SBR tanks are alternated and operate at a capacity of 300,000 gallons per day. Batch cycles are controlled by a computer program and run approximately six hours under normal conditions. Cycles can be adjusted to provide optimal treatment. At the time of inspection, mixed liquor within both SBRs featured a healthy color and odor. From the SBRs, effluent enters a flow equalization tank before entering dual sand filters. It was noted that the equalization tank contained heavy algae. Staff stated that there are plans to cover the tank to reduce/prevent algae growth. Dual sand filters are covered and appeared to be functional. Filters are backwashed regularly. The facility has two digesters for treatment of waste activated sludge before drying and disposal. At the time of this inspection, it appeared that all systems were operating in a satisfactory manner. EFFLUENT/DISPOSAL 9. Effluent Quality: In Compliance Effluent from dual sand filters is pumped to the CCC. Chlorine gas is bubbled into the head the CCC, allowing a minimum of 15 minutes of contact time for disinfection during peak flows.

8 Page 6 At the time of inspection, the effluent within the CCC appeared clear and free of particulate matter. Minimal algae was noted on the floor of the CCC. A grab sample yielded a ph of 7.3 s.u. and a TRC of 1.3 mg/l. A review of the monthly DMRs from January 2008 through May 2009 indicates that this facility had a fecal coliform exceedance that affected multiple parameters. Monitoring Reported Permitted Parameter Period Value Value January 2008 Fecal Coliform (Max) > #/100mL January 2008 Fecal Coliform (90%) > #/100mL January 2008 Fecal Coliform (An.Avg.) #/100ml Staff stated that the Fecal Coliform exceedance was caused by a defective air valve seat connecting the SBRs. The valve seat was replaced after discovery. In April 2009, the facility failed to report TSS data for outfall R-001. A file review showed a TSS of 1.2 mg/l (60.0 mg/l Max). In the future, DMRs with missing or incorrect data should be updated and resubmitted. 10. Effluent Disposal: Out of Compliance From the CCC, effluent is piped to a lined polishing pond before being pumped to an onsite 18-acre sprayfield. The sprayfield appeared to have a properly maintained cover crop. It was noted at the time of inspection that one spray head was damaged, possibly by the contracted landscaper. Staff stated that it would be replaced. The facility featured a train of two lined and one unlined reject water / overflow ponds. At the time of inspection, the ponds featured heavy vegetation (See Image 1, attached). Vegetation in lined holding ponds should be controlled to prevent disrupting the integrity of the lining and to maintain capacity. Staff inquired about the use of algaecides; chemical treatments may be used if they meet the herbicide and pesticide regulations set forth by the State of Florida.

9 Page Residuals Management: In Compliance Sludge is pumped from the digester to eight onsite drying beds. Six sand drying beds were currently in use, while 2 tile beds were not. Odor control and vector attraction appeared to be adequately maintained. After drying is completed, the residuals are stored in a waste management container onsite. It was noted that a small amount of residuals appeared to have spilled onto the ground. All residuals should be contained to prevent runoff. Florida Administrative Code (2)(e): Residuals shall be stored in a manner that will not cause runoff of seepage from stored residuals, objectionable odors, or vector attraction. Residuals are transported for disposal at the Franklin County Landfill as permitted. Between September 2008 and April 2009, approximately 29 tons of dried residuals were hauled to the landfill. 12. Groundwater: In Compliance A review of GMRs from First Quarter 2008 to First Quarter of 2009 indicates that this facility had exceedances of two parameters. Monitoring Reported Permitted Well ID Parameter Period Value Value 2008 Q4 MWC-4 TN max mg/l 2008 Q4 MWC-4 TDS max mg/l A retest of TDS at MWC-4 resulted in a TDS of 487 mg/l, within permitted limits. It was also noted that ph levels in some compliance wells were low, consistent with background levels.

10 Page 8 Image 1: Reject Storage Ponds

11 Figure 1 (Effective ) Approved Test Procedures* REFERENCES NO. STORET CODE PARAMETER REPORTING UNITS STANDARD METHODS (1) ASTM (2) EPA (3) BOD 5 /CBOD 5 : Biochemical O 2 Demand-5 day, 20C mg/l as O TSS: Total Suspended Solids mg/l 209C D FLOW: Flow Through Plant mgd See Rule Text 4a FECAL COLI: Fecal Coliform, MF /100ml 909C p. 124 (4) 4b FECAL COLI: Fecal Coliform, MPN /100ml 908C p. 132 (4) Cl 2 -TOTAL: Chlorine, Total Residual mg/l as Cl 2 408A B D E F ph: Hydrogen Ion Activity ph units 423 D Cl 2 -FREE: Chlorine, Free Available mg/l as Cl 2 408C D D E F NO 2 + NO 3 : Nitrate plus Nitrite mg/l as N 418C D (B) F D (A)

12 Figure 1 (Effective ) Page (2) Approved Test Procedures (Continuation) REFERENCES NO. STORET CODE PARAMETER REPORTING UNITS STANDARD METHODS (1) ASTM (2) EPA (3) Org-N: Organic N (TKN minus NH 3 -N) mg/l as N Calculated by Difference (5) TKN: Kjeldahl N, Total mg/l as N Digestion/Distillation A or B D (A) Followed by - 417B D (A) or 417D D (A) or 417 E or F D (A) and D (B) D (A) NH3-N: Ammonia Nitrogen mg/l as N 417A D (A) Distillation - 417B D (B) Followed by - 417C or 417D or 417 E or F D (D) or 417G D (C) ORTHO-P: Ortho-Phosphate mg/l as P 424F D515-82(A) G

13 Figure 1 (Effective ) Page (3) Approved Test Procedures (Continuation) REFERENCES NO. STORET CODE PARAMETER REPORTING UNITS STANDARD METHODS (1) ASTM (2) EPA (3) TOTAL-P: Phosphorus, Total mg/l as P Digestion (Persulfate) - 424C(III) Followed by - 424F D515-82(A) or.3 or 424G or TOC: Total Organic Carbon mg/l as C 505 D (A,B) COD: Chemical Oxygen Demand mg/l 508A D or Cl: Chloride mg/l as Cl 407A D512-81(B) B D512-81(A) D512-81(C) D TDS: Total Dissolved Solids 209B NOTES: (1) "Standard Methods for the Examination of Water and Wastewater", APHA-AWWA-WPCF, 16th Edition, (2) "Annual Book of ASTM Standards", Volumes and (Water I and II), (3) "Methods for Chemical Analysis of Water and Wastes", EPA-600/ , Revised (4) "Microbiological Methods for Monitoring the Environment", EPA-600/ , (5) Organic nitrogen calculated as total Kjeldahl nitrogen minus ammonia-nitrogen. The methods listed are those for TKN; with and without the ammonia distillation step. The approved methods include detection of ammonia (after digestion/distillation) by titration, Nesslerization or ion-selective electrode. The manual distillation is not required (i.e. EPA methods 351.1, and 351.4) if comparability data on representative effluent samples are on company file to show that this preliminary distillation step is not necessary; however, manual distillation will be required to resolve any controversies. * For parameters not shown in Figure 1, approved test procedures shall be as specified in 40 CFR 136.