Pretreatment Compliance Inspection. Summary Report

Transcription

1 Summary Report Discharger: Location: Contacts: City of El Centro NPDES No. CA Imperial County 2255 N. La Brucherie Road El Centro, CA Frank Pacheco, Pretreatment Coordinator, City of El Centro Felix DeLeon, Chief Plant Operator, City of El Centro Inspection Date: February 16, 2010 Inspected By: Chuck Durham, Tetra Tech, Inc. Byron Ross, Monitoring & Management Services, LLC (subcontractor for Tetra Tech, Inc.) John Carmona, Colorado River Basin Regional Water Quality Control Board

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3 Contents 1. Executive Summary Introduction Wastewater Treatment Facility NPDES Reporting and Additional Monitoring at the WWTF Corrosion Control and Collection System Monitoring Legal Authority Pretreatment Streamlining Regulations Control Mechanisms Local Limits Nondomestic Discharger Characterization Compliance Monitoring Compliance Sampling Compliance Inspections Nondomestic Discharger Site Visit Conducted during the Inspection Slug Discharge Control Plan Summary of Requirements and Recommendations Requirements Recommendations... 8 City of El Centro iii

4 Attachments Attachment A Water Enforcement National Database (WENDB) Worksheet Attachment B River Ranch Fresh Foods Waste Discharge Application Attachment C Nondomestic Discharger Site Data Sheet Attachment D City of El Centro Industrial User Lists Attachment E City of El Centro Municipal Code Chapter 22 Attachment F City of El Centro Enforcement Response Plan City of El Centro iv

5 1. Executive Summary The City of El Centro (City) Public Works Department provides wastewater collection and treatment services for a population of approximately 32,000. The Wastewater Treatment Facility (WWTF) is regulated under National Pollutant Discharge Elimination System (NPDES) No. CA and Order No. R The City does not have an approved pretreatment program, nor has the Colorado River Basin Regional Water Quality Control Board (Water Board) required the City to obtain an approved program. The City s Municipal Code Chapter 22 or sewer use ordinance (SUO) contains local limits and allows the City to inspect, monitor, and permit nondomestic users (NDUs). The City is in the process of revising its SUO. It has been communicating with the NDUs but has not issued permits, conducted regular inspections or monitoring of the NDUs. The inspection team identified one NDU that is a noncategorical SIU, on the basis of its wastewater process flow. The City is required to revise its legal authority and its pretreatment program to include the three requirements promulgated by the pretreatment streamlining regulations. The inspection team recommends that the City review its SUO to ensure that it has included all the minimum requirements of Title 40 Code of Federal Regulations (CFR) Part 403. Also, with the classification of River Ranch Fresh Foods as an SIU, the City is required to permit, inspect and sample the discharger per 40 CFR 403.8(f)(1) and (2). The federal pretreatment regulations at 40 CFR require that the City notify the Water Board of any modifications it intends to make to its pretreatment program. 2. Introduction The Water Board, with assistance from Tetra Tech, Inc., conducted a Pretreatment Compliance Inspection (PCI or inspection) of the City on February 16, Without an approved pretreatment program, the primary purpose of this PCI was to evaluate any efforts the City has implemented with respect to source control and to identify any potential categorical industrial users (CIUs) or SIUs that might be discharging to the publicly owned treatment works (POTW). This report describes the primary concerns generated as a result of the inspection. Please note that, for the purposes of the report, recommendations and requirements are addressed as if the City had an approved program. Before the PCI, the inspection team identified possible NDUs by conducting an Internet review and a Yellow Pages review. During the PCI, the possible nondomestic dischargers were reviewed with City staff, as well as reviewing the NDUs the City had identified. During the inspection, one nondomestic discharger, River Ranch Fresh Foods, was identified as an SIU. The inspection consisted of three parts: an interview of the City s source control staff, a review of the pretreatment program files, and site visits to area NDUs. The interview included a discussion with the City s pretreatment coordinator and chief plant operator regarding the program in general, the City s compliance sampling and inspection City of El Centro 1

6 procedures, enforcement, and WWTF issues. The information available in the files for specific NDUs was minimal; therefore, the file review was limited to a cursory review of the SUO and recent discharge monitoring reports. As part of the PCI, the following NDUs were inspected: River Ranch Fresh Foods (identified as noncategorical SIU) Temple-Inland (recommend classification as noncategorical SIU) Three other NDUs were identified as not significant: o Rogar Manufacturing o Wymore Industries, Inc. o Mall Jewelry Repair This report summarizes the overall findings of the inspection and describes the program elements that are not consistent with federal pretreatment program requirements. In addition, the report provides recommendations to enhance the effectiveness of program implementation and enforcement. 3. Wastewater Treatment Facility The wastewater treatment facility (WWTF) has an average daily flow of 4.0 million gallons per day, with a design capacity of 8.0 million gallons per day. The WWTF includes primary clarification, activated sludge, secondary clarification, and ultraviolet disinfection with chlorination used only for emergency disinfection needs. Biosolids treatment includes anaerobic digestion, belt press filters, with continued drying on concrete beds to produce a final sludge cake of approximately 94 percent total solids. Biosolids are transported to Arizona and land applied. No interferences to the operation of the WWTF were reported. However, the City did state that in the past the influent had discoloration at various times, and the effluent toxicity tests have failed. The City attributed the chronic toxicity test failures to increased conductivity readings measured at the WWTF. 3.1 NPDES Reporting and Additional Monitoring at the WWTF The City tests and analyzes for priority pollutants in the effluent and receiving stream once per year. The inspection team recommends that the City monitor, at least annually, the WWTF influent and effluent for all the 40 CFR Part 503-listed metals. The City conducts biosolids monitoring and analyses before disposal. The 2009 biosolid sample results reviewed for metals and pathogens met the exceptional sludge criteria for 40 CFR Part 503. The inspection team did identify that molybdenum was not included in the 2009 biosolids analyses. The inspection team recommends that the City include analysis for molybdenum for all future biosolids analyses to ensure that the biosolids meet the 40 CFR Part 503 criteria for molybdenum of 75 mg/kg dry weight. 3.2 Corrosion Control and Collection System Monitoring The City has 15 sewer pumping stations. The City adds Bioxide (calcium nitrate) at some sites in the collection system to control hydrogen sulfide and odors. The inspection team recommends that the City s collection system monitoring (consisting of closed circuit City of El Centro 2

7 television, water jetting, and the like) team and the City s pretreatment coordinator increase communication with each other regarding any corrosion or blockage problem areas. The inspection team reminds the City staff that corrosion problems can increase below food service establishment discharges, where the ph of the discharges can be from 4.0 to 5.5 standard units. 4. Legal Authority The federal pretreatment regulations at 40 CFR 403.8(f) require that every POTW subject to the national pretreatment program has the necessary legal authority to apply and enforce section 307(b) and (c) and section 402(b)(8) of the Clean Water Act. The City does not have an approved pretreatment program. The City s SUO allows the City to sample, monitor, and permit NDUs. The City is in the process of revising its SUO and local limits. In concurrence with the revisions to the SUO, the City is developing an Enforcement Response Plan (ERP). City representatives indicated that these documents are under internal review and no target date for adoption has been set. The inspection team recommends that the City review its SUO to ensure that it includes all the minimum requirements of 40 CFR Part 403. Also, the City has not revised its legal authority and its pretreatment program to include the three requirements promulgated by the pretreatment streamlining regulations. The Tetra Tech inspectors provided the City with electronic copies of the EPA Model SUO and Legal Authority Review checklist to assist in the SUO preparation. The federal pretreatment regulations at 40 CFR require that the City notify the Water Board of any modifications it intends to make to its pretreatment program. 4.1 Pretreatment Streamlining Regulations On October 13, 2005, the U.S. Environmental Protection Agency promulgated several changes to the general pretreatment regulations (streamlining rule). The following table indicates where to find those changes in the newly revised general pretreatment regulations at 40 CFR Part 403. Issue Sampling for pollutant not present General control mechanisms Best management practices Slug control plans Equivalent concentration limits for flow-based standards Equivalent mass limits for concentration-based standards Use of grab and composite samples Significant noncompliance criteria Removal credits Nonsignificant CIU Middle Tier CIU Miscellaneous changes Section of 40 CFR Part 403 Rule 403.8(f)(2)(v), (e) 403.8(f)(1)(iii) 403.5, 403.8(f), (b), (e), (h) 403.8(f)(1)(iii)(B)(6), 403.8(f)(2)(vi) 403.6(c)(6) 403.6(c)(5) (b), (d), (e), (g), (h) 403.8(f)(2)(viii) 403.7(h) 403.3(v)(2), 403.8(f)(2)(v), (6), (e)(1), (g), (i), (q) 403.8(f)(2)(v)(C), (e)(3), (i) (g), (j), (l), (m) City of El Centro 3

8 Many of the streamlining provisions are changes that the POTW may adopt at its discretion. A few of the provisions, however, require the POTW to revise its legal authority. The required changes include the following: 40 CFR 403.8(f)(1)(iii)(B)(6): clarification that slug control requirements must be referenced in SIU control mechanisms 40 CFR 403.8(f)(2)(viii)(A C): revisions to the significant noncompliance (SNC) definition 40 CFR (g): modifications to the sampling requirements and a clarification to the requirement to report all monitoring results Therefore, the City is required to revise its legal authority and its pretreatment program to include the three requirements promulgated by the pretreatment streamlining regulations. Those revisions are considered nonsubstantial as long as the revisions directly reflect the federal requirements. Furthermore, the inspection team reminds the City that before implementing any of the other non-required streamlining provisions, the City must also revise its legal authority. Revisions to the City s legal authority to incorporate the pretreatment streamlining provisions are considered nonsubstantial as long as the changes directly reflect the federal requirements. Consequently, the City must notify the Water Board at least 45 days before implementing nonsubstantial modifications. 4.2 Control Mechanisms The regulation at 40 CFR 403.8(f)(1) lists the minimum requirements for an industrial user (IU) permit. Section of the City s SUO provides a list of control mechanism contents, which includes the federal minimum requirements that are to be included in an IU permit issued by the City. The City has not issued any control mechanisms to IUs. Section of the City s SUO states that no SIU may discharge wastewater into the POTW without first obtaining a waste discharge permit from the director. The file review and on-site inspection identified River Ranch Fresh Foods as a noncategorical SIU, as defined at 40 CFR 403.3(v)(ii). The City received a waste discharge application from River Ranch Fresh Foods on January 29, The City is required per 40 CFR 403.8(f)(1)(iii) to issue a control mechanism to River Ranch Fresh Farms and to comply with state and local SUO requirements. The inspection team recommends that the City issue a control mechanism to Temple-Inland on the basis of the IU on-site visit information regarding reasonable potential to adversely affect the POTW s operation. 5. Local Limits The federal pretreatment regulations at 40 CFR 403.5(c) require POTWs to develop and enforce local limits to implement the general and specific prohibitions at 40 CFR 403.5(a) and (b). The pretreatment regulations also require POTWs to continue to develop the local limits as necessary and effectively enforce the limits. In addition, the promulgated federal streamlining regulations state that POTWs may develop best City of El Centro 4

9 management practices (BMPs) to implement the general and specific prohibitions. The BMPs must be considered local limits and pretreatment standards [40 CFR 403.5(c)(4)]. The City has established local limits in its SUO. The calculations and technical basis for the local limits could not be located. The inspection team recommends that the City evaluate its local limits to ensure that the technical basis of the limits is adequate. The federal pretreatment regulations at 40 CFR require that the City notify the Water Board of any modifications it intends to make to its pretreatment program. The inspection team recommends that the City submit the findings and proposed actions from the local limits evaluation to the Water Board for approval before adopting any changes. Also, the inspection team recommends that the City maintain a copy of the local limits calculations at the WWTF. 6. Nondomestic Discharger Characterization The federal pretreatment regulations at 40 CFR 403.8(f)(2) require that POTWs develop and implement procedures to identify and locate industrial users that might be subject to the local pretreatment program. Those procedures must also include proper categorization of all SIUs as defined at 40 CFR 403.3(v). The City reviews business records, building permits, and water connection information to identify potential IUs subject to the local pretreatment program. The City monitors and provides BMP information to approximately 120 food service establishments for fats, oils, and grease discharge control. Also, the City maintains a list of 35 auto repair shops, 27 dentists, 5 dry cleaners, and 10 other NDUs. The file review and on-site inspection at River Ranch Fresh Foods identified that it is an SIU as defined at 40 CFR 403.3(v)(ii). The City is required to properly categorize all SIUs and meet all pretreatment regulations related to SIU permitting, inspection, and sampling per 40 CFR 403.8(f)(1) and (2). 7. Compliance Monitoring The federal pretreatment regulations at 40 CFR 403.8(f)(2)(v) require that a POTW develop and implement an inspection and monitoring program to determine, independent of information supplied by nondomestic dischargers, compliance or noncompliance with applicable pretreatment standards and requirements. Furthermore, 40 CFR 403.8(f)(2)(vii) requires POTWs to investigate instances of noncompliance and enforce the regulations as necessary. 7.1 Compliance Sampling The regulations at 40 CFR 403.8(f)(2)(v) require that all SIUs be sampled at least once a year unless the POTW has authorized a CIU to forego sampling of a pollutant regulated by federal pretreatment requirements. In such a case, the POTW must sample for the waived pollutant(s) at least once during the permit term [40 CFR 403.8(f)(2)(v)(A)]. The City has collected sporadic grab samples for ph in the collection system downstream of two of the NDUs. However, no 24-hour composite samples or other regular sampling at NDUs has been conducted by the City. On the basis of the inspection information reviewed for River Branch Fresh Foods, the facility should be classified as an SIU. With City of El Centro 5

10 the classification of River Branch Fresh Foods as an SIU, the City is required per 40 CFR 403.8(f)(2)(v) to sample the discharger at least once per year. 7.2 Compliance Inspections The regulations at 40 CFR 403.8(f)(2)(v) require that all SIUs be inspected at least once a year, unless a discharger is subject to the reduced reporting requirements under 40 CFR (e)(3). The POTW must inspect such dischargers at least once every two years [40 CFR 403.8(f)(2)(v)(C)]. The City has conducted some inspections of the NDUs. However, the documentation of the inspections is not adequate. The inspection team provided example IU site inspection forms to the City and reviewed inspection information with the City during the PCI. With the classification of River Branch Fresh Foods as an SIU, the City is required per 40 CFR 403.8(f)(2)(v) to inspect the discharger at least once a year. Details of any NDU inspections should be kept on file at the City WWTF. 7.3 Nondomestic Discharger Site Visit Conducted during the Inspection The inspection team, along with City personnel, inspected five non-domestic users as part of the PCI. The inspection team noted the following during the site visit: River Ranch Fresh Foods. The discharger has 425 seasonal employees that receive field vegetables (i.e., lettuce, broccoli, cauliflower, cabbage, carrots) from November through March for processing and packaging. Processing includes cooling, washing, cutting/slicing/dicing, mixing, bagging, boxing, and transport off-site for cold storage. Process wastewater is generated from four main areas: hydro-chiller, chillers water, vegetable and process wash water, and process area washdown/cleanup water that discharge to the industrial sump pit. Approximately 80 percent of the process wastewater is from the chillers water, which is discharged to the industrial sump pit twice per day. The discharger has no pretreatment equipment. Vegetable waste is manually cleaned from the industrial sump pit daily. Chemicals with secondary containment that are stored on-site include ammonia for use as a coolant, sodium hypochlorite, hydrochloric acid, quaternary ammonia, and anti-scale chemicals. The discharger has just initiated a trial using chlorine dioxide for disinfection, instead of sodium hypochlorite. The discharger provided an average daily process flow of approximately 500,000 gallons per day. However, a review of the City water usage records indicates that the average daily water usage is approximately 750,000 gallons per day. The process wastewater flow is 12 to 19 percent of the City s WWTF average daily flow. On the basis of information gathered at the site visit, the inspection team recommends that the City classify the discharger as an SIU. The inspection team also recommends that the City identify a sample location and issue a permit to the discharger. Temple-Inland. The discharger produces corrugated packages/boxes. To connect the box layers, the discharger produces glue on-site that contains corn starch, borax, sodium hydroxide, and waterproofing agents. Approximately 6 to 12 kits of dyes for box labels are used each day. The discharger stated that no process City of El Centro 6

11 wastewater is discharged to the City sewer system. The discharger has a wastewater treatment system that receives all wastewater from the process area floor drains. The treatment system consists of two equalization tanks, a mixing tank for polymer, sodium hydroxide and a coagulant, and a clarifier. Sludge produced from the treatment system is dewatered at two frame filter presses. The sludge is hauled off-site for disposal. Treated wastewater is then reused in the glue mixture or other areas of the process. The City staff indicated that in the past, the WWTF has received wastewater with different colors and wastewater with glue-like characteristics. The inspection team recommends that the City identify the process wastewater discharge location to the City sewer and issue a permit to the discharger because of reasonable potential to adversely affect the POTW s operation. Wymore Industries, Inc. The facility is a combined repair shop and industrial parts/supply store. The repair shop includes a machining and welding area. No process wastewater is produced in these areas. Rogar Manufacturing. The facility cuts, crimps and assembles various types of wires for the semiconductor industry. There is no process wastewater; only sanitary waste is discharged to the City sewer system. Mall Jewelry Repair. This is a small jewelry repair shop in the mall. No process wastewater was identified. 7.4 Slug Discharge Control Plan The federal pretreatment regulations at 40 CFR 403.8(f)(2)(vi) require the City to evaluate each SIU, by October 14, 2006, or within one year of becoming an SIU, to determine whether the SIU needs to develop and implement a slug discharge control plan. A slug discharge is any discharge of a nonroutine, episodic nature, including an accidental spill or noncustomary batch discharge [40 CFR 403.8(f)(2)(vi)]. The regulations also require each SIU to notify the POTW immediately of any changes at its facility affecting the potential for a slug discharge. The inspection team recommends that the City require River Ranch Fresh Foods and Temple-Inland to develop and implement a slug discharge control plan. 8. Enforcement The federal pretreatment regulations at 40 CFR 403.8(f)(5) require the City to develop and implement an enforcement response plan (ERP). That plan must contain detailed procedures indicating how the City will investigate and respond to instances of industrial user noncompliance. The City has an ERP and an enforcement section in the City s SUO (Section ). The inspectors remind the City that it might need to modify the ERP to be consistent with the revised SUO to ensure they do not conflict with one another. City of El Centro 7

12 9. Summary of Requirements and Recommendations Listed below are the primary requirements and recommendations resulting from the inspection of the City s pretreatment program. For more specific information pertaining to each comment, see the cited sections of the report. 9.1 Requirements 1. The City is required to revise its legal authority and its pretreatment program to include the three requirements promulgated by the pretreatment streamlining regulations. 40 CFR 403.8(f)(1)(iii)(B)(6): clarification that slug control requirements must be referenced in SIU control mechanisms 40 CFR 403.8(f)(2)(viii)(A C): revisions to the SNC definition 40 CFR (g): modifications to the sampling requirements and a clarification to the requirement to report all monitoring results (Section 4.1, Pretreatment Streamlining Regulations) 2. The City is required per 40 CFR 403.8(f)(1)(iii) to issue a control mechanism to River Ranch Fresh Farms and to comply with the local SUO requirements. (Section 4.2, Control Mechanisms) 3. The file review and on-site inspection at River Ranch Fresh Foods identified that it is an SIU as defined at 40 CFR 403.3(v)(ii). The City is required to properly categorize all SIUs and meet all pretreatment regulations related to SIU permitting, inspection, and sampling per 40 CFR 403.8(f)(1) and (2). (Section 6, Nondomestic Discharger Characterization) 4. On the basis of the inspection information reviewed for River Branch Fresh Foods, the facility should be classified as an SIU. With the classification of River Branch Fresh Foods as an SIU, the City is required per 40 CFR 403.8(f)(2)(v) to sample the discharger at least once per year. (Section 7.1, Compliance Sampling) 5. With the classification of River Branch Fresh Foods as an SIU, the City is required, per 40 CFR 403.8(f)(2)(v) to inspect the discharger at least once a year. Also, the City must keep documentation of the inspections. (Section 7.2, Compliance Inspections) 9.2 Recommendations 1. The inspection team recommends that the City issue a control mechanism to Temple-Inland according to the IU on-site visit information regarding reasonable potential to adversely affect the POTW s operation. (Section 4.2, Control Mechanisms) 2. The inspection team recommends that the City monitor, at least annually, the WWTF influent and effluent for all the 40 CFR Part 503-listed metals. The inspection team recommends that the City include analysis for molybdenum for City of El Centro 8

13 all future biosolids analyses to ensure that the biosolids meet the 40 CFR Part 503 criteria for molybdenum of 75 mg/kg dry weight. (Section 3.1, NPDES Reporting and Additional Monitoring at the WWTF) 3. The inspection team recommends that the City s collection system monitoring team and the City s pretreatment coordinator increase communication with each other regarding any corrosion or blockage problem areas, to ensure appropriate action is taken to prevent future problems. (Section 3.2, Corrosion Control and Collection System Monitoring) 4. The inspection team recommends that the City evaluate its local limits to ensure that the technical basis of the limits is adequate. The inspection team recommends that the City submit the findings and proposed actions from the local limits evaluation to the Water Board for approval before adopting any changes. Also, the inspection team recommends that the City keep a copy of the local limits calculations at the WWTF. (Section 5, Local Limits) 5. The inspection team recommends that the City classify River Ranch Fresh Foods as an SIU. Also, the inspection team recommends that the City clearly identify a sample location. (Section 7.3, Nondomestic Discharger Site Visit Conducted during the Inspection) 6. The inspection team recommends that the City identify the process wastewater discharge location of Temple-Inland to the City sewer and issue a permit to the discharger because of the reasonable potential to adversely affect the POTW s operation. (Section 7.3, Nondomestic Discharger Site Visit Conducted during the Inspection) 7. The inspection team recommends that the City require River Ranch Fresh Foods and Temple-Inland to submit a slug discharge control plan. (Section 7.4, Slug Discharge Control Plan) City of El Centro 9