ࡱ> KMJ'` -bjbjLULU 8H.?.?w%%DDDD8 <H,%"%%%%%%%$;&h(*%}*%DD?%!!!DR%!%!!:",""t ]dSH" %U%0%R"RG)G)"G)"`=!l/*%*%j% DDDDDDD  California Regional Water Quality Control Board North Coast Region Interoffice Memorandum TO: John Short, File (Crescent City WWTF) FROM: Charles Reed DATE: 03/09/2011 SUBJECT: INSPECTION REPORT - CRESCENT CITY WWTF [January 3, 2011] CIWQS Inspection ID # 3885102 On March 3, 2011, I conducted a routine compliance inspection of the Crescent City Wastewater Treatment Facility. The inspection commenced at approximately 8:20 AM with a review of laboratory records and concluded at about 11:00 AM. Weather during the inspection was rainy. At 11:00, I participated in a meeting with Crescent Citys Jim Barnts, Lonnie Levi, and Eric Weir along with the Citys consultants to discuss issues related to renewal of the Citys NPDES permit. In attendance during the facility inspection was Joel, WWTF Operator. I also met with Sandy Byrne, laboratory director, during my review of the laboratory records. I took photographs during the inspection (Attached). No effluent or receiving water sampling was included in this inspection. RECENT SITE HISTORY I last inspected the facility on January 12, 2010. (CIWQS Inspection ID # 2057787) Since this last inspection, I recorded violations of the 6-month median effluent limitation for ammonia for the months of January, February, and March of 2010. Measurements of effluent ammonia in subsequent months have met effluent limits as a result of improved performance of the biological treatment system (MBR system) and the solids digestion system. The discharge was also out of compliance with the 6-month median effluent limitation for copper for monthly samples collected January through May. Monitoring results from June through December 2011 show compliance with this effluent limit. The Discharger submitted an application of a renewed if its NPDES permit in August 2010. A draft permit was prepared and a public hearing to consider adoption of the permit is scheduled for May 5, 2011 in Eureka. Former Chief Operator, Jim Dohrer, is no longer with Crescent City. He has been replaced by Lonnie Levi. FIELD NOTES Headworks Joel reported that the grinder pump/screw pumps continue to perform exceptionally well. However, Joel mentioned that the grinder pump had on occasion clogged when solids collected from lift station were brought to the headworks and added to the waste stream. The City has since devised a work around to avoid this problem, which is discussed in the Solids Handling section of this inspection report. I photographed plastic material in the vicinity of the grinder pump. (PHOTO) Joel said the plastic is media from the Rumiano Cheese pretreatment unit. Mr. Levi said later that this happens on rare occasions as a result of the media bubbling out of the Rumiano treatment system during high cheese processing flows. Once the plastic media arrives at the grinder pump, it is kicked out of the waste stream on to the ground surface in the headworks area. Anaerobic Digestion Both anaerobic digesters were online and in operation at the time of the inspection. Rehabilitation work on the digesters has been completed. However, the boilers, which heat the digesters to the proper temperature, were recently out-of-service, and Joel said that the digesters were taking a while to get healthy. I photographed digester solids leaking out from the edges of the floating primary digester cover. It appeared that the secondary digester cover had already been cleaned before the inspection. (PHOTOS) These solids are being manually pumped to the headworks by operations staff on an as-needed basis. Primary Treatment I noted that there was considerable floating scum and grease in the influent end of the primary clarifiers. (PHOTO) Joel said that the scum removal occurs daily by directing the material to the (newly automated) tilting troughs, but the maintenance activity had not yet occurred for the day. Secondary Treatment Membrane bioreactors (MBR) project was completed in August 2011. Initial monitoring results show a dramatic improvement in effluent quality since the unit went into operation. I observed and photographed the MBR unit as Joel explained the process flow. (PHOTOS) Sludge from the MBR, along with other secondary sludge will be sent to the centrifuge in the future. Currently, secondary and primary sludges are sent to the gravity thickener. I noted a 20,000-gallon Baker Tank (PHOTO) on a service road between the MBR unit and the rotating biological contactors (RBCs). Joel explained that the tank is temporary and used to contain chlorinated filtrate from the MBR system. The temporary storage allows the operators to meter the chlorinated water back into the waste stream at a rate that wont disrupt the system or cause effluent limit violations. It is anticipated that a project (MMP Compliance Project) to install permanent storage tanks will be completed by the end of 2011. I inspected the RBCs. Joel said that since the MBR went into service, the RBCs have been seen light organic loading. I noted that there was markedly less biomass on the filter media at the most downstream filters. Snail infestation was not observed on the filters, which would be consistent with cooler ambient temperatures. Primary effluent is currently split about 60% to the MBR unit and 40% to the RBCs, with the MBR unit running at its maximum capacity of 1.6 MGD. Solids Handling Joel described a recently enacted procedure whereby solids removed from lift stations are dumped to bermed area next to secondary clarifiers. (PHOTO) Liquid is allowed to dewater into drop inlet that leads back to headworks. Dried solids are then placed in garbage bin and sent to landfill. I questioned Joel and Mr. Levi separately about this practice. Joel said that the practice creates a horrible smell. Mr. Levi said that the landfill is aware of the nature of the waste and accepts it for disposal. I told Mr. Levi that I would review the NPDES permit and the statewide sanitary sewer system general permit to determine if this practice was in violation of any requirement. Scum and grease removed from the primary clarifiers is collected in a garbage bin and disposed of with the Citys municipal solid waste. I questioned Joel whether this was standard procedure, noting that this waste stream in many WWTFs is most commonly added to the anaerobic digesters where it is stabilized with primary and secondary sludge. He said that the Citys manner of disposal was common practice for the City. I inspected the area around the garbage bin for the presence of spilled solids, but observed none. (PHOTO) Records The generator log book indicated that the 1.2M KV Cummins generator is exercised weekly for one hour. The most recent log entry was from 2/21/11. I reviewed raw laboratory data sheets for November 2010 and checked influent and effluent TSS, BOD and fecal coliform results to confirm accuracy of SMR reporting. In some instances laboratory results reviewed were not consistent with reported data. I discussed the discrepancy wit Ms. Byrne and she said that she would submit a corrected SMR for November 2010. The corrected SMR was provided in an email on March 4, 2011. I did not review the operators log book. Laboratory I conversed with Ms. Byrne in the laboratory about laboratory issues with the draft NPDES permit. She asked for 1) clarification about the chronic toxicity method for sample collection, 2) more flexibility in monitoring months for toxicity, and 3) clarification on receiving water monitoring locations. I said that I would look into these issues, but recommended that the City raise the issues in its comment letter. COMPLIANCE CONCERNS There does not appear to be an obvious permit violation for the Citys handling of solids removed from lift stations. However, it is poor practice. I suggested to Mr. Levi and Mr. Barnts that this practice did not seem like a long term solution and that I they might consider alternative handling practices to prevent the occurrence of nuisance conditions or health impacts to the Citys operations staff. I observed dried biosolids on a ramp leading from the biosolids pressing room/loading building to a service road that leads to an exit gate for the WWTF. I examined the curb outside the WWTF where spilled biosolids might collect, but saw no biosolids there. Nevertheless, I am concerned that storm water could carry spilled biosolids off the property into the surface waters without adequate best management practices. I will express my concerns to City staff that improved housekeeping is required, at a minimum, to prevent contaminants from leaving the site in storm water runoff. The Citys pretreatment program, while improving, still is not in complete compliance with the federal pretreatment program. A Pretreatment Compliance Inspection (PCI) was conducted by an EPA contractor on February 24, 2011 and I was informed by the inspector that there are deficiencies in the Citys program that cause the City to be out of compliance with its NPDES permit. The PCI report will be forwarded to the City, accompanied by a Notice of Violation. I will contact City staff to agree on a time schedule for the City to complete required pretreatment tasks that will bring the City into compliance. Photo Log Photo 1: Plastic Material at Grinder Pump Photo 2: Primary Digester with Solids Photo 3: Secondary Digester Photo 4: MBR Oxic Zone Photo 5: MBR Aerobic Zone Photo 6: Temporary Storage Tank for MBR Filtrate Photo 7: Bermed Area for Solids Dewatering Photo 8: Waste Bin for Primary Grease and Scum     PAGE  PAGE 4 1DEJK\]`amqrs     % = H Z º޶޺޲޺ަ޺ޢyޮh}hBl 5h}h}5 h;5hNohNo5hNohXhthph hJh[UhUh hUhBl 5 hUhUhU5CJaJhUhBl 5CJaJ hUhBl hU5CJ hU5CJ hUh @05CJaJ/1DE\]   '  `0Px*$gd  `0P*$gdc `0*$gdBl  $(a$gdU $ $a$gdU$a$gdBl w---Z c g h " ' (     + 3 D E K P \ e    ' H X Y [ \ r y ļ̸ܸجؤب̨ؤؤhhH hA&hA&hA&h.hhtht5h{ hKchMhoH3h 5hth1hhBl h h^Fh;h)h`=)hnhXh[UhhJ: !*D^*'+,>Vc}}z{ 1f/_`ȼȼرЭиХСȸЩh}h6hbFhKc hh1h%hMhJ\hJ\5hJ\hwDh)ph{bph1h1>*hch^F5h\hi~h{hA&hhHh C='{ 1Ea `0P*$gd6 `0P*$gd `0P*$gd `0P*$gd `0x*$gd^F `0P*$gdc CDyz$(01EXYZ`hltBCIKr %'?C$&'+/1_aӿӿӿӿӻ뻳ӷǷǷhhXhMh\hhLh1h1h1>*hbFh)hjh6hN+]hN+]5hN+]h%hJ\hjhj>*E_`a7X[8CKLQR!!!!!!!!!)"T"\""""" #-#1#O###($3$f$$$$Žߕߕh5ThwDhwD>*hLhqhoH3h`=)hKchKch.y>*hKchKc>* h6h6hN+]hN+]5hN+] h`=)h6hwD h6>*h6hbFhXh1hMh.y:!!U"#($3$%%')-,yyy & F `0vP*$^vgd `0P*$gdj  `0Px*$gd5T `0P*$gd `0P*$gdL `0P*$gdKc `0P*$gdc `0P*$^gd6 $$$%"%$%<%`%%%=&]&}&~&&&&','6'Q'~'''(((())))B+D+Q+,,-,.,7,8,@,C,c,d,l,o,,,,,,,,,,ɿhN+]h\bmH sH hN+]h =mH sH  hj h =hwhN+]h\bh = hXhj h =h =5>*hXhRhh%hh&hj h`=)h`=)h6hj hj 5h5ThwD6-,.,8,d,,,,,-D-u-v-w-y-z-|-}------ &`#$gd% `0P*$gd = `0P*$gdj  `0Px*$gd =,,,,,,,,---"-C-D-L-O-t-u-v-w-x-z-{-}-~----------------------h0fhUh}0JmHnHuh%hR hR 0JjhR 0JUhXjhXU hj h =hN+]h\bh =hN+]h\bmH sH hN+]h =mH sH hN+]hN+]mH sH ------------ `0P*$gdj  0*$ &`#$gd%h]hgdR 6&P1h:p5T/ =!"8#$% @@@ 6NormalCJ_HaJmH sH tH DA@D Default Paragraph FontRi@R  Table Normal4 l4a (k@(No List8@8 UHeader  !aJ4 @4 R Footer  !.)@. R Page Number%%H1DE\]'' { 1EaU(3!-$.$8$d$$$$$%D%u%v%w%y%z%|%}%%%%%%%%%%%%%%%000000000000000000000000000000000000000000000 0 0 0000000000000@000@000@000@000@0@0@0@0@0@000 0001DE\]'' { 1EU!-$.$8$d$$$$$%D%u%v%w%%%%000000000000000000000000000000000@0@ 000000 0 0 000000000000 0 0$@0@0 0 0$ $$$'Z $,- "-,--!#-  '!!8@0(  B S  ?% ?|&# @|&A|&B|&C|& D|&lE|&F|& G|&#H|&| I|&I J|&- K|&< 117UU^%     6<<]bb%  8*urn:schemas-microsoft-com:office:smarttagsCity9 *urn:schemas-microsoft-com:office:smarttagsState9 *urn:schemas-microsoft-com:office:smarttagsplace= *urn:schemas-microsoft-com:office:smarttags PlaceType= *urn:schemas-microsoft-com:office:smarttags PlaceName  AW  $$$$$$w%w%y%y%z%z%|%}%%%%%%%%$$$$w%w%y%y%z%z%|%}%%%%%%%%1DE]1E1)Uw%w%y%y%z%z%|%}%%%%%%%% w%w%y%y%z%z%|%}%%%%%%%% ^`[>*2Ph ^`hH.h ^`hH.h pLp^p`LhH.h @ @ ^@ `hH.h ^`hH.h L^`LhH.h ^`hH.h ^`hH.h PLP^P`LhH.^`o(. ^`hH. pLp^p`LhH. @ @ ^@ `hH. ^`hH. L^`LhH. ^`hH. ^`hH. PLP^P`LhH.[>                   &6qBMV* 5< j Bl !g y MbKiS+@"hX#@u#%g%A&`=)f*". @0oH3 7} 7@<7B9;|KB CwD^F^]HhHIJd OeQ5T[UXX'\J\N+]0@_\blbKcOuf.h=iDj kyknNoK$p{bpw.y S~i~< ER X;1RLXk\to{ #7t/J4H~4}hg'^bF|)pH{,] =.P-%&`{jX<Uy}L4*?d|0fe9c 5mY86QL,6[)pCmqd !h@1 %P@UnknownGz Times New Roman5Symbol3& z Arial"1hSWr&Ur&;DD4dd%d% 2qHP ?Bl 2/California Regional Water Quality Control BoardCharlesCharles  Oh+'0   0< \ h t 0California Regional Water Quality Control BoardCharles Normal.dotCharles14Microsoft Office Word@"O@=c@8f@d՜.+,0 hp  SWRCBDd%' 0California Regional Water Quality Control Board Title  !"#$&'()*+,-./0123456789;<=>?@ACDEFGHILRoot Entry FΰdN1Table%[)WordDocument8HSummaryInformation(:DocumentSummaryInformation8BCompObjq  FMicrosoft Office Word Document MSWordDocWord.Document.89q