Inspected By: Agency: Date of Inspection

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1 Inspected By: Agency: Date of Inspection Leo Sarmiento, WRCE Jim Fischer, WRCE Bridget Chase, WRCE Roy O Connor, Geologist SWRCB-Office of Enforcement SWRCB-Office of Enforcement SWRCB-Office of Financial Assistance North Coast Regional WQCB 10/1/2014 Name and Location of Facility Inspected Entry Date/Time Exit Lewiston Park Mutual Water Company Wastewater Treatment Plant (CIWQS Place ID # ) Old Lewiston Road at Viola Lane Lewiston, CA WDID NO. Order No. Design Capacity 1A83052OTRI ,000 GPD (peak) 20,000 GPD (average) Facility Receiving Water Name: N/A Representative(s) Name(s) & Title(s): Chief Plant Operator: Chris Erickson, Grade I 10/1/2014 (0845) 10/1/2014 (1400) Permit Effective Date Permit Expiration D 4/28/1983 N/A Plant Classification: Class II Contact Information: Phone No: (530) Plant Operator: Wayne Carlson, Grade I Operator-in-Training (OIT) Inspection Consent Approved By: Wayne Carlson, Grade I OIT Date Time 10/1/ Treatment Train Description Primary (mechanical) Secondary (biological) Headworks/fixed bar screen, one Imhoff Tank, and two sludge drying ponds One extended aeration tank Chemical (disinfection) One chlorine contact tank with combined final clarification On October 1, 2014, the above State Water Resources Control Board inspection team staff performed a scheduled inspection of the Lewiston Park Mutual Water Company wastewater treatment plant (hereafter, LPMWC WWTP) in Lewiston, California. The weather during the inspection was sunny and warm with temperatures in the 80s. The purpose of the inspection was to evaluate LPMWC s compliance with Waste Discharge Requirements (WDRs), Order No including review of plant staffing and facility operations, maintenance, financial, and management activities. Page 1 of 17

2 The LPMWC WWTP has a maximum design flow of 50,000 gallons per day (gpd) but currently serving the Lewiston Subdivision with 167 connections, five businesses, elementary school, church, veterinary office and an apartment complex (for more information, see Attachment 1 LMPWD Pant Classification Form ). A number of LPMWC representatives and an outside consultant were present for the scheduled inspection including Chris Erickson, part-time Grade I Wastewater Operator and acting Chief Plant Operator (CPO), Wayne Carlson, Wastewater Grade I Operator-in-Training (OIT), board members, additional LPMWC support staff, and two representatives from an outside consulting firm (see Attachment 2 Lewiston Park Mutual Water Company Inspection Sign-In Sheet for ). LPMWC WWTP unit processes include one manual bar screen, one Imhoff tank, two sludge drying ponds, one aeration tank and a chlorine contact tank which is used also for final clarification. Final effluent is discharged via gravity pipeline across Trinity River and into a subsurface leach field for final disposal. PRE- INSPECTION CONFERENCE We arrived at the Lewiston Valley Motel restaurant located at 4795 Trinity Dam Boulevard at approximately 0830 hrs and began the pre-inspection conference in a large isolated room in the front of the restaurant. After introductions, Fischer explained the purpose of the scheduled inspection to document LPMWC s regulatory compliance with Order and wastewater treatment plant operator certification regulations (California Code of Regulations, Title 23, Division 3, Chapter 26) including review of LPMWC WWTP staffing, operations, maintenance, and management. The pre-inspection conference included many questions and answers covering a wide variety of topics and information related to the staffing, operations, maintenance and management of the wastewater treatment plant, including some basic information about the sewage collection system and former spills. The main questions, topics and information including statements summarized from LPMWC representatives is provided below: 1. LPMWC WWTP Staffing: Erickson stated that he currently works at the plant part time and is the designated Chief Plant Operator (CPO) for the facility while Carlson is the Grade I OIT for LMPWC working at the plant full time and overseeing the day-to-day operations. Sarmiento reminded Erickson and the others present for the inspection that the plant will need to have an official California certified wastewater operator by March 2015 in accordance with the plant classification requirement by the Office of Operator Certification. Sarmiento asked for an organizational chart and Jamie Day (LPMWC Office Manager) provided us with a sketch showing the LPMWC organizational structure (see Attachment 3 LPMWC Org Chart Sketch ) 2. Monitoring Reports: Roy O Connor (Regional Board 1) talked about past violations for failure to submit monthly monitoring reports and he stated that LMPWC has rarely sent any of the required monitoring reports to the regional water board over the past 5 years. 3. WWTP Layout and Treatment Processes: Page 2 of 17

3 Sarmiento asked LPMWC representatives for a plant layout diagram for the facility to begin the discussion. Carlson stated that no plant drawings, schematics or any as built or engineering design documentation exists; in addition, that no operator logbooks exist for the facility. Next, Erickson and Carlson both provided us with a basic overview of LPMWC wastewater and drinking water treatment plant units, focusing mostly on describing the wastewater plant equipment including the Imhoff tank, aeration basin, and chlorine contact tank. Carlson also provided us with details about the LPMWC water treatment system wells. Sarmiento asked LPMWC representatives about flow rates during dry and wet weather through the plant and the types of flow meters in place. Carlson stated that the only way they can calculate flow into the plant is to use their potable drinking water plant influent meter to calculate the approximate flows since their effluent ultrasound meter is not operational. However, we recognize that this method is not a reliable approach since some households may consume more water for irrigation use than others. Carlson provided more information to us about the LMPWC potable drinking water plant and the condition of this equipment. Carlson stated that the drinking water plant is currently inadequate for contact time for proper disinfection before water then enters the potable water distribution system. Carlson also stated that they are currently pumping approximately 80,000 to 90,000 gallons of potable water per day into the LMPWC distribution system. Fischer asked LPMWC representatives if they have any industrial companies located within the LMPWC service area. Nixon stated that a company with ~20 employees out of the bay area called Fabtron is currently discharging sewage into the LMPWC sewer system. 4. WWTP Operations and Maintenance: Board member Nixon stated that the wastewater treatment plant is in very poor operating condition and that there have been no significant repairs at the plant in the past 5 years. Carlson stated that since he has been working at the plant which has been nearly one year, the v notch effluent flow meter was out of service due to failure of the ultrasound sensor. Carlson also stated that one of their biggest problems is solid materials being pushed from the aeration tank into the chlorine contact tank. The aeration tank has no provision for removing or wasting solids out of the tank. Carlson also said another issue they think there are having is wastewater seeping from one of the pond berms and their goal is to try to dry this pond to investigate further. Carlson stated that LPMWC does not have any standard operating procedures in place for the wastewater treatment plant. Sarmiento reminded LPMWC representatives including Carlson and Erickson that they need to have a copy of the permit issued by the regional water board onsite and they must have standard operating procedures (SOPs) in place to ensure proper operations and maintenance of the plant at all times to comply with the permit. Sarmiento asked LPMWC representatives to explain typical operational procedures conducted at the plant. Carlson stated to us that he manually removes solids out the Imhoff tank to the sludge drying ponds at approximately 3 times per week. Carlson also said that he scrapes off the Imhoff tank and the Page 3 of 17

4 bar screens daily, where solids are disposed to the Anderson Landfill. Carlson also provided an explanation of the plant chlorination system which uses both tablets and liquid chlorine (sodium hypochlorite) for disinfection and he said he switched to using only liquid chlorine about the beginning of August 2014 and does not ever use their old chlorine gas system that was installed years ago. Carlson stated that they currently have two undersized peristaltic pumps (capacity of 1 gallon per day per pump) for the wastewater disinfection. Carlson also said they aim for a chlorine residual concentration in the effluent of 0.05 to 0.5 mg/l. Sarmiento asked LPMWC representatives about final effluent disposal and Carlson explained that after the effluent leaves the v-notch meter located adjacent to the chlorine contact tank, final effluent travels via gravity in a 4 inch pipe that crosses the Trinity River where it then enters the final percolation ponds in a subsurface disposal area. Sarmiento asked LPMWC representatives if the plant has any built-in system redundancy such as a system to handle an electrical power failure. Carlson stated that they have no backups or redundancy currently in place. Sarmiento asked LPMWC representatives for an overview of their wastewater sampling program and procedures; Carlson stated that Blade Varnum (employee of LPMWC that does plant maintenance) and he conduct wastewater sampling which includes chlorine residual, temperature and settleable solids on a daily basis and BOD and bacteria twice per month. Carson said that they currently do not have any equipment in place to measure dissolved oxygen and other parameters recorded on a regular basis which also include ph. Fischer asked LPMWC representatives about available historic records for the plant; Carlson stated that they have records as late as November Roy O Connor explained that in the past, LPMWC has traditionally sent some of their laboratory samples to Weaverville. Carlson said that last January 2014, they purchased some new meters to assist with measuring turbidity. 5. LPMWC Financial Information: Fischer asked LPMWC representatives to explain the financial operations for management of the wastewater treatment plant. Jamie Day (LPMWC Office Manager) stated that LPMWC currently has approximately 170 connections and 135 to 140 company share-holders. Day also stated that each resident pays approximately $35/month for sewage services and $40/month for water services and said that they just recently raised rates to assist with their operating costs. Board member Nixon stated that they are financially in poor shape with lower reserves (approximately $37,000 in cash reserves) and both the wastewater and drinking water plants are well beyond their useful lives of 25 years. 6. Sanitary Sewer System: Fischer asked LPMWC representatives to provide an overview of the sewage collection system and Erickson, Board member Nixon, and Board member Gaither provided the following information: o No as built drawings exist for the entire sewer system. o Most of the collection system consists of concrete main lines; some Orangeburg pipe is used for the sewer laterals which they do not maintain. o No pump stations exist upstream of the wastewater plant headworks and all sewage flows to the treatment plant via gravity. o Most of the main lines are 8 inches in diameter. Page 4 of 17

5 o LPMWC occasionally roots out main line sewers to address tree root issues; o Conner stated that no ongoing sewage overflows are occurring and they only had one large spill that occurred in October 2013 or last summer near the community church; Board member Nixon stated that the spill lasted less than a day and he saw it; he estimates it only lasted for approximately 1 ½ hours coming from a manhole and valve; he said the flows were fast at first and then tapered off; in response, Carlson called Weaverville Community Services District to have them help assist with break the blockage and root pipe and they should have a record of this service call in their records according to Carlson. o Chris Erickson says that they may have less than 1 mile of sewers and that they would check and get back to us. O Conner explained that their sanitary sewer system has severe inflow and infiltration (I/I) problems during wet weather and estimates they have a 10 to 1 ratio between wet weather and dry weather flows into the system and the treatment plant. Carlson agreed with these statements and stated that although they have high I/I, this is not causing any major overflows in the collection system or at the treatment plant during wet weather. Carlson also stated that they check the percolation pond area every few weeks. O Conner stated that their ponds are not typical percolation ponds since the sewage lines are buried and drain subsurface, approximately 60 to 100 feet from the Trinity River. 7. Inspection Consent: Sarmiento reiterated the main reasons for the inspection of the wastewater treatment plant and asked LPMWC representatives consent to inspect the facility and take photographs to document the visual inspection activities. Carlson provided his consent for the inspection and photographs at approximately 1005 hrs. PLANT VISUAL INSPECTION ACTIVITIES: At approximately 1015 hrs, we began the WWTP inspection to further evaluate LPMWC operational duties, procedures, and equipment in use at the plant. Photos 1-48 below document our visual inspection activities for all main plant wastewater unit processes including wastewater sampling procedures in use. We confirmed during the field inspection activities that no standard operating procedures (SOPs) or plant operations and maintenance documentation is available and used by LPMWC staff for the facility. 1. Absence of plant flow schematic diagram and/or engineering design documentation. Carlson stated that none of this documentation currently exists. 2. Unidentified pipelines and hoses: plant operators (Carlson and Erickson) were unable to explain flow of sewage through subsurface conveyances throughout the plant including locations and directions. 3. Inoperative gate valves: according to Carlson, at least five gate valves at the plant are currently inoperative (see Photos 2-5); Carlson was unable to determine the actual control position of each of the inoperative gate valves (ie, open or closed ). Page 5 of 17

6 Photo 1: Plant perimeter access fencing with locked gate Photo 2: Inspection of inoperable plant valves Photo 3: Extended aeration tank hose (left) and inoperative sewer influent valve (right) Photo 4: Carlson showing inspection team inoperative valves and piping with unknown flow directions Photo 5: Inoperative valves Photo 6: Plant headworks fixed grate Page 6 of 17

7 Photo 7: Plant Imhoff tank (view 1) Photo 8: Plant Imhoff tank (view 2) Photo 9: Plant Imhoff tank (view 3) Photo 10: Extended aeration tank (view 1) 1. No procedures or maintenance practices in place for emptying waste sludge from aeration tank. 2. No sludge return activated sludge (RAS) or waste activated sludge (WAS) systems or piping is used and no ongoing samples for RAS or WAS are taken for process control operations. 3. Significant solids and algae in extended aeration tank (see Photo 11). Page 7 of 17

8 Photo 11: Extended aeration tank (view 2) Photo 12: Extended aeration tank (view 3) Photo 13: Extended aeration tank (view 4) Photo 14: Extended aeration tank (view 5) 1. No procedures or maintenance practices in place for chlorination system. 2. Poor housekeeping practices for operation of this system (see Photos 15-17). Page 8 of 17

9 Photo 15: Chlorine disinfection system and equipment Photo 16: Disinfection system shed Photo 17: Equipment storage adjacent to shed Photo 18: West Pond (view 1) 1. No procedures for maintenance of sludge drying ponds (see Photos 18-22). 2. No lining documentation for sludge drying ponds. Page 9 of 17

10 Photo 19: West pond (view 2) Photo 20: East Pond (view 1) Photo 21: East Pond (view 2) Photo 22: Pond transfer pump, pipes and valves 1. No procedures or maintenance practices in place for final effluent monitoring system. 2. Inoperative effluent flow meter/recorder (see Photos 23-26). 3. Poor housekeeping practices for operation of this system. Page 10 of 17

11 Photo 23: Final effluent flow meter (inoperative) Photo 24: Final effluent level sensor (inoperative) Photo 25: Final effluent Sparling flow meter (inoperative) Photo 26: Final effluent flow recorder (inoperative) 1. Absence of standard operating procedures (SOPs) in place for water quality sampling and improper health and safety practices for sampling (i.e, no gloves or eye protection when sampling). See Photo 30. Page 11 of 17

12 Photo 27: Inspection of plant sampling record (view 1) Photo 28: Sampling record sheet (view 2) Photo 29: Sampling discussion with plant OIT Photo 30: OIT conducting contact tank grab sample 1. No procedures or maintenance practices in place for maintaining the chlorine contact tank. 2. Poor water quality in tank with significant buildup of solid materials and algae (see Photos 31-34). Page 12 of 17

13 Photo 31: Chlorine contact tank (view 1) showing solids approximately 3 feet from top level Photo 32: Chlorine contact tank (view 2) Photo 33: Chlorine contact tank (view 3) Photo 34: Chlorine contact tank (view 4) Photo 35: OIT analyzing contact tank sample (view 1) Photo 36: OIT analyzing contact tank sample (view 2) Page 13 of 17

14 1. Poor housekeeping practices for operation of the laboratory (see Photos 37-40). Photo 37: Plant laboratory trailer inspection Photo 38: Laboratory chemicals Photo 39: Laboratory equipment/storage (view 1) Photo 40: Laboratory equipment/storage (view 2) Page 14 of 17

15 Photo 41: Compliance information posted in laboratory Photo 42: Effluent disposal area fencing and locked gate 1. No procedures or maintenance practices in place for maintaining the disposal area pipelines (see Photos 45 and 48). Photo 43: View of effluent disposal area Photo 44: Effluent pipeline near disposal area Page 15 of 17

16 Photo 45: Fractured pipeline located near disposal area Photo 46: Effluent pipeline crossing structure Photo 47: Inspection of pipeline crossing structure Photo 48: Close-up view of corroded pipeline section POST- INSPECTION CONFERENCE Following the visual inspection activities, a Post-Inspection Conference was conducted between 1245 hrs and 1400 hrs, covering the following points: 1. Review of the purpose of the announced inspection. 2. Visual findings summary. 3. Next steps, letter with Inspection Report including list of violations, and compliance and/or enforcement orders. 4. Discussion about CSD joint treatment study, plans to convert company to non-profit business organization, Board Members and shareholder relationships and funding programs by SWRCB. Page 16 of 17

17 ATTACHMENTS Attachment 1 (LPMWC Wastewater Treatment Plant Classification Form) Attachment 2 (LPMWC Inspection Sign-in Sheet ) Attachment 3 (LMPWC Organizational Chart Sketch) Page 17 of 17