Director of Compliance Report. September 20, 2017

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1 Director of Compliance Report September 20, 2017 Plant Loading and Operations Summary August 2017 Plant Loading Biochemical Oxygen Demand, 5-Day (Avg lbs/day) Total Suspended Solids (Avg lbs/day) Average Daily Flow (22.45 million gallons/day) Maximum Daily Flow (33.22 million gallons/day) 24 percent of design 29 percent of design 55 percent of design 27 percent of design Permit Limits (avg./max.) Reported Values Violations CBOD 5, mg/l 20/40 2/2 0 TSS, mg/l 25/45 4/5 0 NH 3 -N, mg/l 1.3/ / Fecal coliform per 100 ml 400* (max) Chlorine Residual, mg/l 0.05* (max) Dissolved Oxygen, mg/l 6.0 (minimum) Total Nickel, mg/l (avg.) Total Zinc, mg/l 0.075/ / *Effluent disinfection is required May 1 through October 31. Operations Summary During the month of August there was one NPDES permit exceedance, which was for nickel. Nickel Related Issues: The District continues to work towards getting the existing NPDES permit nickel water quality effluent limitation updated by pursuing a site specific water quality standard through the Illinois Pollution Control Board (IPCB). District staff (Tim Kluge and Steve Nightingale) and consultants continue to work with USEPA and IEPA. Updates on nickel related issues during August and early September include: 1. On August 31, 2017 the District participated in an Illinois EPA, Bureau of Water Compliance Section meeting to discuss the current status of the nickel site specific petition activities and the pending compliance commitment agreement (CCA). 1

2 2. The September 11, AM scheduled conference call between USEPA, IEPA, Windward Environmental, OSU, HeplerBroom, and the District had to be postponed due to family medical issues for the Windward Environmental representative (modeler). The call has been moved to the next scheduled call date which is September 21 at 11 AM. It will be determined if we need a follow up call at the end of that call. The Proposed agenda for this call is to have Bob Santore and Allison Cardwell provide updates to the group on their efforts to revise the supporting information for the Districts site specific rule petition pending before the Illinois Pollution Control Board (IPCB) so it reflects using Dissolved Organic Carbon (DOC) as the basis for updating the existing nickel water quality standard, and using the Biotic Ligand Model in more of a supporting role. Plans are to also use the time to answer any remaining questions that USPEA or IEPA may still have. When rescheduling the call the participating group was reminded that although the IPCB granted an extension until November 30, they also instructed us to provide the needed information supporting our petition and to be ready to proceed with scheduling the hearing at that time. They were also reminded that it appears the IPCB expects the District to be ready to move forward without seeking additional time extensions. In response to changing the date of the meeting USEPA reminded the District that they would like us to share the draft supporting documentation and proposed draft rule language with USEPA and IEPA before presenting it to the IPCB. They were informed that as soon as we get the petition updated, and the supporting documentation in the proper written form from Allison Cardwell and Bob Santore we will share it with them. 3. The current due date for updating the Time Limited Water Quality Standard (TLWQS) variance application with the IPCB showing compliance with 40 CFR has been extended to October 9, The due date for submitting the status report to the IPCB for the pending variance (automatically converted to a TLWQS variance based on recent Illinois legislation) is November 31, In the most recent approval for extension the IPCB has asked the District to include in the next report an explanation on how the site specific rulemaking is impacted by 1) the newly-adopted Section 38.5 (TLWQS) of the Environmental Protection Act (45 ILCS 5/3805 (2016), and 2) the conversion of the District s variance petition to a time limited water quality standard variance under the section. 5. The due date for submitting a status report to the IPCB and seeking any additional extensions for scheduling a hearing on the pending site specific rule petition has now been extended to November 31, At that time the IPCB appears to be expecting the District to be prepared to provide all documentation necessary to support the District s petition for a site specific rule and move forward with scheduling a hearing. Along with the submittals in 4 and 5 above the IPCB has asked the District to explain its position on how the two related dockets should proceed, including its position on any potential conflicts in proceeding with both dockets and obtaining the sought relief in both dockets. Nickel Site Specific Rule Petition and Variance Petition background information: 1. Initially the District obtained a variance from the IPCB for the nickel permit limitation which allows an exemption from compliance with the numeric standard while the district evaluates procedures, equipment, or other avenues with the goal of eventual compliance. The variance expired at the end of June 2014, and 2

3 due to opposition from USEPA, the IEPA has not granted an extension. While pending, the variance petition has been automatically converted to a Time Limited Water Quality petition, due to recent state legislation. In addition to the variance request the District has filed for a site specific rule with the IPCB for an updated and more accurate site specific nickel permit limit. Both the variance and the site specific rule petition currently before the IPCB have been on hold while the District works with USEPA and IEPA to address their concerns. 2. As suggested by USEPA the site specific rule petition is being revised and will be based on the reduction in toxicity as a result of the effects of Dissolved Organic Carbon (DOC) in the effluent rather than the Biotic Ligand Model (BLM) results. It is however anticipated that the BLM will still be used, but only to the extent needed to verify the DOC toxicity reduction effects. The BLM is based on an alternative model which takes into account actual site specific conditions when establishing the appropriate nickel water quality limitation, so it will continue to be a good verification tool. General Activities: 1. Normal operational activities took place for plant operators during August. 2. Sanitary Sewer Overflow (SSO) Incident Spring Creek SSO At about 8:30 AM on 9/11/17 District staff became aware of the fact that no pumps were running at the St Louis Bridge pumping station (1290 Taylorville Road). As a result of the pump outage sewage had backed up into the collection system and eventually began overflowing into Spring Creek from the new manhole risers associated with the ongoing Spring Creek crossing construction project. Twenty minutes after the District staff became aware of the situation they had two pumps running and the SSO event was eliminated. As identified by IEPA s guidelines the District is required to 1) provide verbal notification to IEPA field office staff within 24-hours of becoming aware of the SSO, and 2) complete and submit the required IEPA Sanitary Sewer Overflow or Bypass Notification Summary Report within 5-days of the occurrence. The IEPA field office (Holly Hirchert) was contacted by phone by Steve Nightingale at about 8:40 AM on 9/12/17, which was within the 24-hour required reporting period. The required IEPA Sanitary Sewer Overflow or Bypass Notification Summary Report was completed and submitted to IEPA electronically and via certified mail on 9/14/17, which was within the required 5-day reporting period. In addition to submitting the IEPA reports the IEPA required the District notify the Illinois Emergency Management Agency (IEMA) of the Release. IEMA was contacted by phone on 9/12/17 at around 9:10 AM and the required report was filed. Incident number H WAS issued by IEMA. IEMA is responsible for notifying any other regulatory agencies. 3

4 3. Location of Spring Creek SSO is included below. 4. On August 22 Steve Nightingale attended the Illinois Environmental Regulatory Group/ Illinois EPA (IERG/IEPA) Environmental Compliance in Illinois Land Basics Seminar. The purpose of the seminar is to provide basic information on the permitting and compliance issues as they relate to waste management, as well as updating the participants on recent changes to waste handling requirements and possible future regulatory changes. 5. On August 30 Steve Nightingale and Greg Pyles participated in Illinois Water Environment Association (IWEA) Plant Operations Committee sponsored Rock River Water Reclamation District plant tour and technical sessions. Included in the technical sessions was a presentation by Aqua-Aerobic Systems on the Aqua Nerda treatment process, and its enhanced abilities to biologically treat wastewater to remove nutrients. 6. In addition to the IWEA Operations Plant tour in Rockford on August 30 th Greg Pyles participated in the IWEA Nutrient Workshop in Addison Illinois on September 6 th. 7. On September 13 Steve Nightingale attended the Illinois Environmental Regulatory Group/ Illinois EPA (IERG/IEPA) Environmental Compliance in Illinois Water Basics Seminar. The purpose of the seminar is 4

5 to provide basic information on the permitting and compliance issues as they relate to wastewater, as well as updating the participants on recent changes to wastewater handling and treatment requirements and possible future regulatory changes. While attending the seminar Steve Nightingale also gave a presentation on Working with Your POTW and the federal pretreatment program. 8. Activities related to land application of the District biosolids: On September 1 a total of 85 written notification letters were sent to owners of property adjacent to the land on which biosolids will be applied this fall. In addition, officials in Macon County and Blue Mound Township whose jurisdiction includes the land on which biosolids will be applied were also sent notifications. These notifications are a requirement of Section of the Environmental Protection Act. Based on recent agronomic calculations the District can expect the available cropland (1588 acres) which have been secured by Oros and Busch for the fall land application season to provide for the ability to land apply approximately 37 million gallons of biosolids, if needed. Map showing the site locations for the fall land application season: 5

6 CSO Summary: Location Events Discharge (million gallons) Estimated Total Duration of Discharges (hrs) Oakland Ave. (Outfall 003) Lincoln Park (Outfall 004) McKinley Ave. (Outfall 007) Seventh Ward (Outfall 008) Laboratory Activities: Laboratory Activities - Routine A total of 2,138 analyses were performed in the laboratory during the month of August. Monitoring of treatment plant, industrial users, and receiving stream samples for compliance purposes and process monitoring continued. Laboratory personnel continued to perform additional background nutrient monitoring to help fully characterize the nutrient loading on the plant. Laboratory Activities - Non-Routine 1) Sampling of the dewatered sludge in the geobags in South Sludge Lagoon #6 was conducted during the first week of August. The purpose of the sampling was to characterize the dewatered sludge to determine the best disposal options and to estimate the total volume and weight of the sludge. The dewatered sludge was found to be fairly dry (approximately 40% solids) and the metals content was found to be higher than that of the sludge currently produced at the SDD. The total volume of dewatered sludge was estimated to be approximately 79,700 cubic yards with a total weight of approximately 62,000 tons. 2) The quarterly NPDES sampling of the influent, effluent, and sludge to Wyckles was conducted during the second week of August. 3) The four-year river study with Eastern Illinois University continued in August. Water samples from all six field sites were analyzed for nickel content. The nickel levels were slightly higher than last month due to very low flow in the river. 4) Markesha Davis attended the Seal Analytical AQ2 User Group and Troubleshooting Workshop in Chicago on August 22 nd. Our AQ2 instrument is used routinely to analyze for ammonia, organic nitrogen, and total phosphorus so the workshop provided valuable information about using the instrument more efficiently and effectively. 6

7 Pretreatment Activities: Pretreatment - General Activities: 1) Pretreatment personnel monitored twelve industrial users (IU) and performed five industrial user inspections during August ) A permit application was received from Norfolk Southern Railway Company during August 2017 because their current permit will expire soon. 3) Wastewater Hauler permit applications were sent to seven of our existing wastewater haulers on August 7, 2017 because their current permits are going to expire soon. Six of the seven submitted applications by the end of August 2017 and we received the seventh in the first week of September. 4) New wastewater discharge permits were issued to the Canadian National/Illinois Central Railroad and the City of Decatur Water Department during August Both permits were reissued permits due to their existing permits expiring. 5) A final sludge disposal report was received from ADM during August 2017 as required by Executive Order ADM met their commitment to haul away the prerequisite amount of solids from their pretreatment system, and they are continuing to waste solids from the system to locations other than the SDD. Pretreatment Ordinance - Verbal Notices: 1) A Verbal Notice was issued to Tate and Lyle Ingredients Americas (T&L) on August 3, 2017 because they submitted daily flow reports that showed that they exceeded their daily maximum discharge flow on July 29 and 30, ) A Verbal Notice was issued to Prairie Farms Dairy on August 16, 2017, because SDD monitoring showed that they discharged wastewater that exceeded their limit for total fats, oils, and grease (FOG-T) on August 9, ) A Verbal Notice was issued to Archer Daniels Midland Company (ADM) on August 21, 2017, because the ph chart for the West Plant showed that they had discharged wastewater with a ph that was only 4.2 standard ph units on August 17, ADM responded by sending documentation that showed that the ph drop was due to an operator standardizing the ph meter at the time the chart showed the drop. 4) An additional Verbal Notice was issued to T&L on August 21, 2017 because they submitted a daily flow report that showed that they exceeded their daily maximum discharge flow on August 19, Pretreatment Ordinance - Warning Notices: No Warning Notices were issued during August Pretreatment Ordinance - Notices of Violation: No Notices of Violation were issued during August Pretreatment Ordinance - Executive Orders: No Executive Orders were issued during August

8 Pretreatment Ordinance - Penalty Assessments: The following industrial penalties were assessed for August 2017: 1) Prairie Farms Dairy $1, ) Tate and Lyle Ingredients Americas $2, Plant Operating Graphs: Flow, MGD Flow Comparison: SDD vs. ADM + T&L Discharges and Rainfall Plant design ADM+T&L limit RAINFALL SDDi ADM+T&L Rainfall, inches BOD5, pounds/day BOD Comparison: BOD Inf vs. T&L + ADM Discharges Plant Design T&L+ADM limit SDDi T&L+ADM 8

9 TSS Comparison: SDD Inf T&L+ADM Discharges TSS, pounds/day Plant design ADM+T&L limit SDDi T&L+ADM If there are any questions or comments concerning this report, please contact me at 217/ x214 or by at stephenn@sddcleanwater.org. 9