Director of Compliance Report. October 19, Plant Loading and Operations Summary September 2016

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1 Director of Compliance Report October 19, 2016 Plant Loading and Operations Summary September 2016 Plant Loading Biochemical Oxygen Demand, 5-Day (Avg lbs/day) Total Suspended Solids (Avg lbs/day) Average Daily Flow (21.19 million gallons/day) Maximum Daily Flow (43.54 million gallons/day) 29 percent of design 36 percent of design 52 percent of design 35 percent of design Permit Limits (avg./max.) Reported Values Violations CBOD 5, mg/l 20/40 2/2 0 TSS, mg/l 25/45 4/6 0 NH 3 -N, mg/l 1.5/ / Fecal coliform per 100 ml 400* (max) 21 0 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 Nickel Issues: During the month of September the NPDES permit limitation for total nickel was exceeded. The District continues to work towards getting the existing NPDES permit nickel water quality effluent limitation updated by pursuing a site specific rule through the Illinois Pollution Control Board (IPCB). The request is based on an alternative model which takes into account actual site specific conditions when establishing the appropriate nickel water quality limitation. The SDD staff (Tim Kluge and Steve Nightingale) and District consultants continue to work with USEPA and IEPA. Updates during September include: On September 22 a conference call was held between the District staff (Steve Nightingale & Tim Kluge), Kathy Hodge of Heplerbroom (District attorney), Bob Santore of Windward 1

2 Environmental (modeling Expert), and Rob Colombo from Eastern Illinois University (River Study). The purpose of the call was to determine what should be the next steps in the process of pursuing the site specific rule change. It was decided that: 1. Revised information is still needed if the District wants to update the current site specific rule petition already in front of the IPCB. To do this the new information will be submitted to Kathy Hodge. Once updated by Kathy it will forward it to workgroup for review and approval. ADM will be given the opportunity to review the updated petition for accuracy as well. 2. Before the District moves to the next step in the process to seek the site specific rule change for the revised nickel water quality standard through the IPCB it was decided that we should first work to address any remaining concerns USEPA may still have. This is crucial since USEPA must also approve the revised standard. At this point it appears the latest recommendation by USEPA would be for the District to perform one final test, a synthetic hard water test with added dissolved organic carbon (DOC), which is to confirm the model prediction that reduced nickel toxicity is a result of DOC. On October 5 Allison of Oregon State submitted an to USEPA along with the proposed testing protocol for the suggested aquatic toxicity testing. Tim Kluge provided a copy of the proposal to IEPA for review and comments as well. Our goal is to get approval of the testing protocol before the test begins. We are also seeking guidance on how the results should be interpreted. It is estimated that this additional the aquatic toxicity testing will cost the District about $9400. On September 9 Al Keller, the IEPA Bureau of Water Permit Section Manager was contacted by the District (Steve Nightingale). The purpose of the call was to provide Mr. Keller with an update on the progress of the nickel site specific rule change petition. Updates are necessary because the Permit Section has agreed, for the time being, to postpone processing the permit renewal while the District works to obtain the revised nickel limitation. Once the limitation is revised the plan is to incorporate it into the permit during the renewal process rather than in a separate permit modification procedure. In doing this the IEPA can eliminate the need for an additional permit modification request, public notice, and the associated added cost. This option is available because the Distict submitted a timely renewal application to IEPA, therefore allowing the District to continue to operate under the existing permit until the permit is renewed. The District s plan remains to have the updated site specific rule petition ready for submittal to the IPCB once USEPA indicates we have addressed all their questions. This includes performing the above referenced toxicity testing. Background information: Initially the District obtained a variance from the IPCB for the nickel permit limitation which allows time to evaluate and implement procedures/equipment with the goal of eventual compliance. In addition to the variance request the District has filed for a site specific rule with 2

3 the IPCB for an updated and more accurate permit limit. The variance expired at the end of June 2014, and due to opposition from USEPA, the IEPA has not granted an extension. Final action by the IPCB on both the variance and the site specific rule has since been put on hold temporarily while the District works with USEPA and IEPA to address their concerns. Due date for the next status report to the IPCB for the variance request is January 3, Due date for the next status report to the IPCB for the site specific rule petition is December 31, General Activities: 1. Normal operational activities took place for plant operators during September, which included the continued need for sustained coordination with contractors to facilitate ongoing construction projects. Operations staff continues to work with engineers and contractors to 1) resolve the leaks on the #3 primary digester, and 2) optimize the operation of the new Parkson Rotary Drum Thickener. The operations staff has been working with the lab personnel to determine the best feed rate of ferrous chloride for removal of the hydrogen sulfide (H 2 S) in the digester gas. Gas quality in the digester is always important during the day-to-day operation, and critical if the District intends to eventually move towards replacing our COGEN units (engines which generate electricity from our biogas). 2. Illinois Nutrient Reduction Strategy -- On September 11 Dean Frommelt of ADM was contacted by the District (Steve Nightingale) to discuss the draft Nutrient Reduction Strategy Study and Processing Modeling - Interim report that was developed by Black and Veatch for the District. The purpose of the call was to share with Dean what the District feels still needs to be addressed in the report before it goes final. Specifically, we wanted to make sure the report accurately reflects that its intent was to originally be proactive, and was a result of the recent USEPA & IEPA s state wide nutrient reduction initiatives. We also want the report to make it clear that until USEPA and/or IEPA provides additional guidance or specific regulations to follow the District will have to wait before we can move forward. Dean appeared to be in agreement with our comments and concerns. The District plans to share a copy of any revisions with ADM prior to the report going final. 3. Steve Nightingale successfully completed the mandatory annual 8-hour hazwopper health and safety refresher course to maintain his 24-hour training certification. The on-line training was through the USEPA National Enforcement Training Institute and available at no charge to regulatory agencies, including sanitary districts. Maintaining the proper level of hazwopper safety training will allow Steve access to sites that may store, treat, and dispose of hazardous waste and who discharge their wastewater to the District. 3

4 4. Update on the fall land application of District biosolids: On September 20 District staff participated in the Oros and Busch company safety meeting held at the Wyckles facility. As approved under IEPA permit the land applications season for applying District biosolids to area farmlands at agronomic rates began on September 22. Through October 12 Oros and Busch (contractor) has applied a total of 12.1 million gallons of biosolids to area farmlands. 5. It should be noted that the District operations staff have been given the task of operating the dredge equipment at the Wyckles facility as part of the land application program. To date the staff has done a fantastic job in keeping sludge moving with the dredge equipment so it is available for transport when needed. Super job! 6. Below are some pictures of the biosolids land application program: Photo 1: Biosolids being loaded onto tankers at the Wyckles storage facility 4

5 Photo 2: Tanker loaded with biosolids on its way to the farm fields Photo 3: Tanker arriving to the off loading site near fields 5

6 Photo 4: Frac tank for temporary biosolids storage Photo 5 - Preparing to receive the biosolids 6

7 Photo 6: Biosolids storage (Frac Tank), pumping equipment & delivery hose used to supply the land application equipment with biosolids Photo 7: Hose used to supply the actual land application equipment 7

8 2016 Biosolid Land Application Sites 7. Regulatory activities related to the decommissioning of the two existing south sludge lagoon No s 8 & 9 located on the Macon County Conservation District property is as follows: a) The District continues to operate under the IEPA NPDES general permit (ILR10X197) issued August 1 requires the District implement the IEPA approved stormwater pollution prevention plan during the decommissioning process. The permit is needed because the 8

9 activity disturbs more than one acre of land. Once decommissioning of the two ponds has been completed, and the site has been properly stabilized for erosion control, the District will send in a completed notice of termination to IEPA. b) The District continues the decommissioning process of south sludge lagoons #8 and #9 as permitted under the IEPA state construction permit (2016-AB61363) issued on September 2. The permit is conditional and requires that an IEPA field inspector verify that all sludge has been removed before we can begin to remove the berms surrounding lagoons #8 and #9. IEPA inspection of lagoon #9 was made on September 1, follow-up conformation photos were provided to IEPA on September 2, and an approval from IEPA to commence closure of lagoon #9 was given on September 6. IEPA inspection of lagoon #8 was made on September 23, follow-up conformation photos were provided to IEPA on September 26, and an approval from IEPA to commence closure of lagoon #8 was given on September The groundwater monitoring wells located in the vicinity of south sludge lagoons (#6, #7, #8, #9) which are no longer needed due to the removal of south sludge lagoons #8 and # 9 have now been sealed, capped and abandoned in accordance with the Macon County Department of Public Health (MCDPH), supplemented by what the IEPA Bureau of Land requires. Currently it is expected that 4 of the 17 wells will be retained for monitoring groundwater around remaining south sludge lagoons #6 and #7. Cost for sealing, capping and abandonment of the ten wells by SKS Engineering was $ The application to renew the current IEPA permit for the District s biosolids is still under review by the IEPA Bureau of Land Permit Section. The renewal application is requesting to not only land apply biosolids from Wyckles facility, but also from the remaining south sludge lagoons (#6 and #7). The current permit (2011-SC-2041) expires on October 31, CSO Summary Location Events Discharge (million gallons) Estimated Total Duration of Discharges (hrs) Oakland Avenue (Outfall 003) Lincoln Park (Outfall 004) McKinley Avenue (Outfall 007) Seventh Ward (Outfall 008)

10 Laboratory Activities: Laboratory Activities - Routine A total of 1,902 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 in preparation for anticipated permit limits to assist with process design. Laboratory Activities - Non-Routine 1) Water samples from the woodchip bioreactor were received for nitrate analysis weekly in September. The samples from each week showed elevated nitrate levels in the water entering the bioreactor and nearly undetectable levels in the water leaving the bioreactor. The bioreactor still appears to be removing nitrate very effectively. 2) 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 similar to the results obtained last month. 3) The sludge land application season started on September 22 and grab-composite samples from the tanker trucks were analyzed in the lab daily. 4) A data-logging gas meter was temporarily installed in the vent pipe at the Oreana 1 pump station to collect data on hydrogen sulfide levels in the air. The data from the gas meter will be used to determine the best option for hydrogen sulfide control at the pump station. Pretreatment Activities: Pretreatment - General Activities: 1) Pretreatment personnel monitored thirteen industrial users (IU) and performed eight industrial user inspections. 2) A permit application package was received from Archer Daniels Midland Company (ADM) on September 20, 2016 because their current permit is due to expire in December ) New wastewater hauler discharge permits were prepared for Kelley s Septic Tank Service, Bodine Services, K&M Portable Toilets, City of Decatur Municipal Services, Septic Specialist, Parks Sewer Service, and Midwest Pottyhouse during September 2016 because their current permits were due to expire in September ) A compliance meeting was held with Stripmasters Services, Inc. on September 20, 2016 to discuss why Stripmasters has exceeded their daily maximum and monthly average discharge flow limits several times in recent months. Stripmasters showed us evidence that their business has grown to the point where they need higher flow limits. 10

11 5) A new discharge permit was prepared for issuances to Akorn, Inc. because their current permit is due to expire October 25, ) An amended discharge permit was prepared for issue to Stripmasters Services, Inc. because their business has grown so much that they need higher discharge flow limits in their permit. 7) Semiannual self-monitoring report forms were prepared and sent out to all SDD significant industrial users during September to remind the users to perform the monitoring required by their permits and to submit their required reports by the December 1, 2016 due date. Pretreatment Ordinance - Verbal Notices: A Verbal Notice was issued to Prairie Farms Dairy, Inc. (PFD) on September 8, 2016, because PFD discharged wastewater that exceeded their permit limit for total fats, oils, and grease (FOG- T) on July 29 and August 5 as shown in their self-monitoring reports. A Verbal Notice was issued to Tate and Lyle (T&L) on September 12, 2016, because they discharged wastewater on September 8, 2016 that exceeded their daily maximum permit limit for Total Suspended Solids (TSS). A Verbal Notice was issued to ADM on September 19, 2016, because they discharged wastewater to discharge point B that exceeded their permit limit for total fats, oils, and grease (FOG-T) on September 1, An additional Verbal Notice was issued to T&L on September 21, 2016, because they discharged wastewater from their discharge point C on September 21, 2016 that exceeded their daily maximum permit limit for total dissolved sulfides. Pretreatment Ordinance - Warning Notices: A Warning Notice was issued to T&L on September 26, 2016 because they discharged wastewater from their discharge point C that exceeded their daily maximum permit limit for total dissolved sulfides on September 21, 26, and 27, Pretreatment Ordinance - Notices of Violation: No Notices of Violation were issued during September Pretreatment Ordinance - Executive Orders: No Executive Orders were issued during September Pretreatment Ordinance - Penalty Assessments: The following industrial penalties were assessed for September 2016: Prairie Farms Dairy $1, Tate and Lyle Ingredients Americas, Inc. $7,

12 Archer Daniels Midland Company $1, Plant Operating Graphs: Flow Comparison: SDD vs. ADM + T&L Discharges and Rainfall Flow, MGD 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 T&L+ADM limit Plant Design SDDi T&L+ADM 12

13 TSS, pounds/day TSS Comparison: SDD Inf T&L+ADM Discharges 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.+ 13