Director of Compliance Report. October 18, Plant Loading and Operations Summary September 2017

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1 Plant Loading Director of Compliance Report October 18, 2017 Plant Loading and Operations Summary September 2017 Biochemical Oxygen Demand, 5-Day (Avg. 17,703 lbs/day) Total Suspended Solids (Avg. 25,513 lbs/day) Average Daily Flow (20.81 million gallons/day) Maximum Daily Flow (27.66 million gallons/day) 28 percent of design 24 percent of design 51 percent of design 22 percent of design Permit Limits Reported Violations (avg./max.) Values CBOD 5, mg/l 20/40 2/3 0 TSS, mg/l 25/45 3/4 0 NH 3 -N, mg/l 1.5/ / Fecal coliform per * (max) ml Chlorine Residual, 0.05* (max) mg/l Dissolved Oxygen, 6.0 (minimum) mg/l 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 September there were two NPDES permit discharge exceedances. One was for total residual chlorine and the other for nickel. Total Residual Chlorine Issues: At approximately 9:30 a.m. on September 12, 2017 effluent sampling test results indicated an exceedance of the daily maximum total residual chlorine (TRC) concentration permit limit. Retesting at approximately 11:30 a.m. showed the TRC discharge concentration to be below the permit limit, and in fact it was below the mg/l detection limit. It was determined the excursion was a result of facility maintenance activities in which a primary clarifier was put online as part of a planned maintenance project. Because the activity resulted in the diversion of a considerable volume of flow to a clarifier there was a period of time where the actual flow going through the plant was substantially lower than what was being recorded at the head end of the plant. During this non-steady state flow period the chlorination and dechlorination systems were unable to adequately compensate for the actual conditions within 1

2 the plant. And for a brief period of time the chlorination equipment dosing rates, which uses the influent flow rate, continued dosing based on the higher flow rate, while the dechlorination system dosing rate, which are based on the actual effluent flow rate (lower), was applying sodium bisulfite solution at a rate insufficient to completely dechlorinate the effluent stream. Once the flow rate equalized the problem was corrected. To prevent these conditions from reoccurring in the future the District has been working to change the location where it obtains flow rates used to calculate the hypochlorite dosage rate for the chlorination equipment. To date the District has attempted to install and operate two different flow meters in structure 264 which is located just prior to the chlorination process. Moving the flow monitoring equipment here will provide for a much more trustworthy flow rate when calculating the hypochlorite dosing rate. But so far the District has not been able to get a consistently reliable flow reading under all flow conditions at this location. After discussions with the manufacturer and the supplier of the current flow meter (Flowdar) in structure 264 it was decided the District should relocate the existing meter eight inches higher than the highest point in the pipe that water will be expected to flow. Moving the meter should help make the unit more reliable in transmitting signals during high flow conditions. This modification was made on September 26, The plan is to now evaluate the reliability of the meter in its new location under various flow conditions to verify its reliability before it is used as the primary flow meter when establishing the hypochlorite dosing rates. If this meter relocation does not prove successful then the alternative plan will be to choose a different meter, with the hope of having it installed and tested prior to the beginning of the 2018 disinfection season. Plans are to continue to evaluate the existing flow meter for reliability even after the disinfection season ends so verification of its reliability can be established prior to the next disinfection season. The ultimate goal will be to have whatever equipment is needed in place so we will have a reliable flow monitoring device in structure 264 as soon as possible. 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 the IEPA. Updates on nickel related issues that took place during September and early October include: 1. As a result of the August 31, 2017 meeting between the District and IEPA which was held to discuss the current status of the nickel site specific rule petition activities and the pending compliance commitment agreement (CCA) associated with the alleged nickel violations, the District agreed to provide IEPA with a letter identifying its preference on how to best address the pending compliance commitment agreement (CCA). On September 25, 2017 the District, provided the IEPA with the above mentioned letter. 2

3 2. The September 21, 2017 conference call between USEPA, IEPA, Windward Environmental, OSU, HeplerBroom, and the District took place as planned. Bob Santore of Windward Environmental provided updates and responded to questions raised by USEPA. A follow-up conference call is now scheduled for October 16, 2017 to discuss any remaining issues. During the call the group was reminded that the District is being required to have the updated site specific rule petition and supporting documentation filed with the Illinois Pollution Control Board (IPCB) by the current November 30, 2017 due date. USEPA and IEPA were also informed that the District will continue to work with them while completing these documents, and will provide copies of the draft documents for their review as soon as they are available. 3. On September 29, 2017 the District, through its attorneys, HeplerBroom, filed a motion for extension of the current due date for filing an amended petition updating the Time Limited Water Quality Standard (TLWQS) variance, and showing compliance with Section 38.5 of the Illinois Environmental Protection Act and 40 CFR The motion sought an extension until December 31, The motion informed the IPCB that additional time is needed to allow for the Site Specific Rule proceedings to conclude and, if necessary, allow the District time to file a substantially compliant amended TLWQS variance petition. On October 5, 2017 the IPCB granted an extension for submitting the required information until December 31, 2018 to allow the related site-specific rulemaking proceedings (R12-14) to reach a conclusion, and to require the District file an amended petition by the new due date, if needed. 4. 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 30, In the most recent granting of the time 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 is November 30, 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. The District is working to have the required updated site specific rule petition and the supporting technical information filed with the IPCB by the required November 30, 2017 due date. Along with submitting the site specific rule petition and supporting documents by the November 30, 2017 due date the plan is to submit answers to the questions previously asked by the IPCB with respect to how the two related dockets in 4 and 5 above should proceed, including our position on any potential conflicts in proceeding with both dockets and obtaining the sought relief in both dockets. HeplerBroom is providing legal assistance with developing this submittal. 3

4 Nickel Site Specific Rule Petition and Variance Petition basic 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 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 September. 2. Sanitary Sewer Overflow (SSO) Incident Spring Creek SSO: On October 6, 2017 the District received a violation notice (VN) from IEPA for the Spring Creek Sanitary Sewer Overflow which was identified by the District on September 11, 2017 (See September Board Report for Details). The District now has 45-days to respond to the VN. Current plans are to respond to the VN within the required time frame and indicate the event has been eliminated, identify what was done to correct the problem, and outline what is being done in the future to prevent the situation from happening again. 3. On September 18, 2017 Steve Nightingale of the District participated in the quarterly Decatur Sustainable Water Resources Alliance meeting sponsored by the City of Decatur. 4. Recent activities related to land application of District biosolids: On September 29, 2017 District staff participated in the Oros and Busch kickoff safety meeting which was held at the Wyckles facility. On October 2, 2017 Oros and Busch began land application of the Districts biosolids. For the first couple of days only day shifts took place to allow time for staff to become proficient in the site specific activities and process. On October 4 two shifts began. 4

5 a. Each shift is 10 hours b. Shifts run from 6 a.m. to 4 p.m. and 4 p.m. to 2 a.m. five days a week. c. Weekends have one 12 hour shift (alternate day and night) d. As of October 9 th 2.02 million gallons of biosolids have been land applied. Map showing the site locations for the fall land application season: 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)

6 Laboratory Activities: Laboratory Activities - Routine A total of 1,649 analyses were performed in the laboratory during the month of September. 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 characterize the nutrient loading on the plant. Laboratory Activities - Non-Routine 1) The four-year river study with Eastern Illinois University continued in September. 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. 2) Keith Richard attended the IWEA Executive Board and Committee Chair Meeting at Starved Rock Lodge on September 22. The group meets quarterly to discuss current and upcoming activities of the IWEA and its committees. 3) Keith Richard and Markesha Davis attended WEFTEC 2017 in Chicago. They attended various technical sessions and visited many lab equipment booths in the trade show. Keith Richard also served as a judge for the laboratory event of the Operations Challenge at WEFTEC. The laboratory portion of the challenge consisted of analyzing six separate samples for ph, alkalinity, and ammonia as quickly and accurately as possible. The teams that were competing came from all over the world. The best teams were able to complete the laboratory event in as little as six minutes! The competition was very intense but everyone enjoyed the experience. Keith Richard (center) with other judges from the IWEA Laboratory Committee at WEFTEC 6

7 Pretreatment Activities: Pretreatment - General Activities: 1) Pretreatment personnel monitored four industrial users (IU) and performed nine industrial user inspections during September ) A new wastewater discharge permit was prepared for Norfolk Southern Railway Company during September 2017 because their existing permit will expire soon. 3) A new wastewater discharge permit was issued to the ADM James R Randall Research Center (ADM JRRRC) during September ADM JRRRC has recently become a significant industrial user due to the amount of process flow they discharge to the sewers so we have issued the new permit. 4) A wastewater hauler permit application was sent to Bodine Environmental Services during September 2017 because their current permit is due to expire soon. 5) A wastewater hauler permit application was received from Kelley s Septic Tank Service during September 2017 because their existing permit was due to expire soon. 6) Self-monitoring report forms were sent to our significant industrial users (SIU s) to remind them that it is time to do their required self-monitoring and submit a report to the SDD. 7) Pretreatment personnel have identified 34 dental offices within the borders of the SDD that appear to be subject to the new federal dental amalgam (40 CFR Part 441) pretreatment categorical regulations. During September the SDD sent out letters to these offices making them aware of the new regulations. As part of the notification process the facilities were provided with certification forms which will document the facility is capturing their dental amalgam and following certain best management practices. Pretreatment Ordinance - Verbal Notices: 1) A Verbal Notice was issued to Tate and Lyle Ingredients Americas (T&L) on September 1, 2017 because they exceeded their daily maximum biochemical oxygen demand (BOD) limit on August 19, ) An additional Verbal Notice was issued to T&L on September 18, 2017 because they submitted a daily flow report that showed that they exceeded their daily maximum discharge flow on September 16, Pretreatment Ordinance - Warning Notices: 1) A Warning Notice was issued to Prairie Farms Dairy on September 14, 2017 because their self-monitoring showed that they exceeded their total fats, oils, and grease limit on August 16, Pretreatment Ordinance - Notices of Violation: No Notices of Violation were issued during September Pretreatment Ordinance - Executive Orders: No Executive Orders were issued during September

8 Pretreatment Ordinance - Penalty Assessments: The following industrial penalties were assessed for September 2017: 1) Archer Daniels Midland Company $1, ) Prairie Farms Dairy $3, ) Tate and Lyle Ingredients Americas $1, 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