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Iowa Department of Natural Resources_NPDES InspectionFields of Opportunities STATE OF IOWA TERRY E. BRANSTAD, GOVERNOR KIM REYNOLDS, LT. GOVERNOR July 10, 2014 City of Dubuque City Hall 50 West 13th St. Dubuque, IA 52001 ATTN: Honorable Mayor & City Council DEPARTMENT OF NATURAL RESOURCES CHUCK GIPP, DIRECTOR RE: Dubuque Wastewater Treatment Facility Inspection and Notice of Violation: 567 -IAC Chapter 64.3 Permit to Operate NPDES Permit #: 3126001 Dear Honorable Mayor & City Council: Enclosed is the report of the recent inspection of the above facility conducted by Sue Miller of the Field Office #1 staff. We believe you will find the report self-explanatory and strongly encourage you to take action on the requirements and recommendations listed at the end of the report. This report finds the City of Dubuque WRRC in violation of the facility NPDES permit for failure to collect adequate bacteria samples. The previous inspection in February 2013 also found the City in violation of the same permit requirement. In addition, this office is concerned that there is not adequate staffing at the WRRC. Mr. Brown is approaching retirement and there is no one with the appropriate certification and experience with this complex plant that is ready to take over when he does retire. It is strongly recommended that the City make plans for either hiring an additional Grade 4 wastewater operator or encouraging existing employees to obtain higher certification. This letter does not preclude the DNR from pursuing enforcement action regarding any violation. If you have any questions about the inspection or report, please contact Sue Miller or myself at this office. Amber Sauser Environmental Specialist Senior cc: DNR Records Center (w/encl.) Michael Van Milligan, City Manager, City Hall, 50 W. 13th St., Dubuque, IA 52001 (w/encl.) John Klostermann, 925 Kerper Ct., Dubuque, IA 52001 Jonathon Brown, WPCF, 795 Julien Dubuque Dr., Dubuque, IA 52003 Paul Marshall, US EPA, Region VII, 11201 Renner Blvd., Lenexa, KS 66219 File: WW/Dubuque eFile: 31 WW Dubuque 061214 nins sjm.docx FIELD OFFICE #1 / 909 West Main Suite 4 / Manchester, IA 502057 563-927-2640 / FAX 563-927-2075 NPDES Permitit. 3126001 IOWA DEPARTMENT OF NATURAL RESOURCES WASTEWATER TREATMENT FACILITY INSPECTION Page 1 o 6 FACILITY INFORMATION FACILITY NAME: City of Dubuque Water Pollution Control PLANT GRADE: IV RESPONSIBLE AUTHORITY/OWNER: City of Dubuque ADDRESS: 50 West 13th St. CITY: Dubuque STATE: Iowa ZIP: 52001 PHONE: 563/589-4110 RESPONSIBLE OPERATOR NAME: Jonathon Brown GRADE: IV CERTIFICATION NUMBER: 1671 DESIGN CAPACITY AVERAGE MGD: 13.47 MAXIMUM MGD: 24.5 POUNDS BOD/DAY: 41,200 PE (BOD): 246,706 NOW TREATING AVERAGE MGD: 7.0078 MAXIMUM MGD 18.724 (April 2014) POUNDS CBOD/DAY: 44,669.71 (Feb. 2014) PE (BOD): 267,483 PERIOD REVIEWED: 2/1/2013-5/31/2014 POPULATION SERVED: 52,895 SELF-MONITORING ./ RECEIVING STREAM Mississippi River -A1, B(WW1) GENERAL DESCRIPTION: Pure 02 Activated sludge treatment plant with anaerobic sludge digestion, sludge dewatering and land application INSPECTION INFORMATION INSPECTION DATE THIS INSPECTION: 06/12/2014 @9:30 AM DATE LAST INSPECTION: 02/07/2013 PURPOSE: Routine Compliance Inspection PERSONS INTERVIEWED NAME: Jonathon Brown William O'Brien TITLE: Wastewater Plant Manager Pretreatment Coordinator NPDES PERMIT COMPLIANCE SUMMARY INSPECTOR: SELF- MONITORING Operation /1 Sat. ■ Reports Submitted: Marg.* ❑ Unsat.* Required a Data on Reports: Sat. ❑ Marg.* ❑ Unsat.* Testing V Adequacy: Sat. ❑ Marg.* ❑ Unsat.* EFFLUENT LIMITATIONS SELF-MONITORING ./ RESULTS: Satisfactory ❑ Marginal* ❑ Unsatisfactory* SAMPLES THIS INSPECTION TYPE: None LAB DATA ATTACHED? ■Yes ❑ No RESULTS: ❑ Satisfactory ❑ Marginal* ❑ Unsatisfactory* VISUAL APPEARANCE OF EFFLUENT: Not observed VISUAL APPEARANCE OF RECIEIVING STREAM: Not observed COMPLIANCE SCHEDULE COMPLIANCE WITH ❑ Sat. ❑ Marg.* ■ SCHEDULE: Unsat.* NEXT ITEM DUE: NA DATE DUE: NA * Explain in Comments and Recommendations Section AUTHENTICATION INSPECTOR: NAME: Sue Miller, Environmental Specialist DATE: REVIEWER: NAME: Amber Sauser, Environmental Specialist Senior DATE: City of Dubuque Wastewater Treat. NPDES Permit It. 3126001 nspection Date: 06/12/14 Page 2of6' GENERAL DESCRIPTION: I arrived at the Dubuque Water & Resource Recovery Center (WRRC) on Julien Drive in Dubuque for an announced inspection at 9:30 a.m. on June 12, 2014. The City of Dubuque wastewater treatment facility has just completed a $64 million upgrade. The facility continues to be a pure oxygen activated sludge treatment plant with three covered aeration basins. In normal operation, two aeration basins are used. Treatment modifications include replacement of grit and screening equipment, the addition of one primary clarifier and refurbishing of the existing three primary clarifiers; conversion of two former trickling filters to flow equalization; replacing all of the mixers on the aeration basins; refurbishing the 4 existing final clarifiers; installation of ultraviolet disinfection and step aeration at the outfall. Biosolids are treated in four, 1 -million gallon, anaerobic digesters. Digested biosolids are dewatered using two rotary drum thickeners and land applied. The facility no longer incinerates biosolids. Influent and effluent flow meters have been replaced. On the day of this inspection, the following units were in operation: Two new influent magmeters, one on each influent line; two new mechanical bar screens; two grit chambers; two "tea cup" style grit washers; four primary clarifiers; two aeration basins; two final clarifiers followed by Uv disinfection and step aeration. The four anaerobic digesters are now completed and have been receiving biosolids since approximately August 2012. Both incinerators have been dismantled and removed from the site. Sludge dewatering has begun, with sludge being hauled off-site. There is no on-site dewatered sludge storage except for a semi - dump truck used for hauling. The cogeneration facility is currently running with three turbines and three heat exchangers using plant effluent to heat and cool the administration building. Disinfected plant effluent is also used as process water in the plant operations. NPDES PERMIT COMPLIANCE: The monthly operation reports (MORs) were reviewed for the reporting period from Feb 2013 through May 2014. Design Capacity/Effluent Limitations — During the above mentioned reporting period the following observations were made: • The current design influent flow rates for the old plant are 17.32 MGD AWW and 23.24 MGD MWVV. During the above mentioned reporting period the facility was in compliance with the current facility design flow. • BOD design for the plant is 41,200 pounds per day. Currently the plant averages a daily load of approximately 24,392. The maximum daily load reported during the reporting period was 44,669 pounds on February 19, 2014. • The 30 -day and 7 -day average CBOD5 effluent limitations are 25 mg/L and 40 mg/L respectively. During the above mentioned reporting period the facility was in compliance with the CBOD5 effluent limitations of the facility NPDES permit. • The 30 -day and 7 -day average total suspended solids (TSS) effluent limitations are 30 mg/L and 45 mg/L respectively. During the above mentioned reporting period the facility was in compliance with the TSS effluent limitations of the facility NPDES permit. • The daily maximum e.coli effluent limitation is 126 organisms/100 ml. Samples are required to be collected once every 3 months. The facility reported no sample collected from March through May 2014. The previous permit required fecal coliform samples to be collected once every 3 months. During 2013, no samples were collected for the months of June, July and August 2013. This is a violation of the facility NPDES permit. City o,` Dubuque Wastewater NPDES Permit : 3126001 Treatment Inspection Inspection Date: 06/12/14 Page 3of6 • The 30 -day and daily maximum mercury effluent limitations are 0.0103 mg/L and 0.01187 mg/L respectively. During the above mentioned reporting period the facility was in compliance with the mercury effluent limitations of the facility NPDES permit. • Effluent limitations for ammonia nitrogen vary by the month of the year. During the above mentioned reporting period the facility was in compliance with the ammonia nitrogen effluent limitations of the facility NPDES permit. COLLECTION SYSTEM: BYPASSES The City has reported twenty-three sanitary sewer overflows and two basement backups caused by obstructions in the City's mains since the last inspection. The City is under a Consent Decree to eliminate all sanitary sewer overflows. The City has initiated an intensive inflow and infiltration (1/1) inspection program that is working to identify and repair inflow from private property. The City Council recently approved sewer lining in three City sewer sheds. In addition, the City Council approved a new Fats, Oils and Grease (FOG) ordinance and will reassign the 1/I inspectors to investigating restaurants and other businesses to enforce the ordinance. FACILITY EVALUATION: PRE-TREATMENT UNITS (This Facility) Raw influent is delivered to the City of Dubuque WRRC via two separate forcemains and enters the facility through two new mechanical bar screens followed by two grit basins. The grit slurry is then transported to two grit washing units. Grit and screenings are disposed of at the Dubuque Metro Area Solid Waste Agency (DMASWA) landfill. TREATMENT UNITS Primary treatment is provided by four primary clarifiers. At the time of this inspection all four primary clarifiers were operating. The new and refurbished primary clarifiers are no longer covered except for a negative pressure odor control baffle cover over the effluent weirs. Secondary treatment is provided in three, pure oxygen activated sludge basins. Only two basins were being operated at a time. The basins are covered and nine (9) mechanical mixers located on top of each basin. Oxygen is controlled by sensors located in the headspace. Four final clarifiers provide final settling. All four of the four clarifiers were operating on the day of this inspection. It was noted in the previous inspection that with only two final clarifiers on line, the sludge blankets in each are unusually thick, estimated at 12'. On the day of this inspection, the sludge blanket was closer to two feet. Solids management has improved considerably with the anaerobic digesters on line. Disinfection is provided by two parallel channels of two ultraviolet banks. The effluent normally flows through the former chlorine contact chamber that is now equipped with finger weirs designed to stabilize the water level in the disinfection channels thus keeping the bulbs submerged. The final treatment process occurs when the effluent flows down the concrete step aeration process designed to oxygenate the discharge. City of Dubuque Wastewater Treatment Inspection NPDES Permit #: 3126001 ion Date: 06/12/14 Page4of6 SLUDGE HANDLING AND DISPOSAL Primary sludge and secondary sludge are no longer stored separately. Secondary sludge is aerated, but the primary sludge is not. Waste activated sludge is dewatered by two new rotary drum thickeners prior to pumping to the anaerobic digesters. On the day of this inspection Mr. Brown reported that all four anaerobic digesters were operating. Two are thermophilic, operating at a temperature of 131°F. One is mesophilic, operating at a temperature of 100°F. The fourth is operated at 950 F. Digested sludge is dewatered using two sludge centrifuges. Dewatered sludge is then loaded directly to a semi -dump truck that is staged in the lower level of the sludge handling building. Nutri-Ject has contracted with the City to haul sludge to a land application site where they have constructed a storage building for the dewatered sludge. WRRC has no on-site storage capacity for this sludge. Nutri-Ject Systems is in the process of constructing a sludge storage building at the Richard Thole farm located at 9357 Haxbylane Road, in Dubuque County. After our inspection, Mr. Brown and I drove to the sludge storage building location on Haxbylane Road. We observed that the building was completed. There was a small amount of sludge in the building. I observed no liquids from the stored sludge. City of Dubuque's sludge is classified as Class I for land application. There are fewer restrictions on how and where Class I sludge can be land applied, however this office has fielded questions regarding land application on frozen ground. The fields at the Thule farm are fairly steeply sloped and runoff could be a problem when snow melts. The City must understand that it would be a violation if sludge solids were to run off into a water of the State. Since the building has enough storage to get through the winter, we see no reason why sludge should be land applied on frozen ground at this location. FLOW MEASUREMENT Magnetic meters on the two influent forcemains are the reported flow measurement at the plant. The Catfish magmeter was replaced in March 2012 and the Terminal magmeter was replaced in June 2012. The effluent flow is also measured by a pressure transducer and flume which are also new. Neither has been calibrated since they were installed. Mr. Brown reported that he would schedule a calibration. FLOW EQUALIZATION One intermediary pump station is located between the old 200' diameter, trickling filters and the activated sludge basins. The trickling filters have been emptied of rock, cleaned and are in the process of being retrofitted to be flow equalization basins. Total flow equalization capacity is 3.4 MG. The basins have not been put on line as yet but could be put into service manually if needed. So far, there has not been a need to use them. EMERGENCY POWER Mr. Brown reported that the wastewater treatment plant has emergency generation capable of operating the entire plant in the event of a power outage. Several of the smaller lift stations have no back up power source. The City maintains two portable generators that can be used at the four lift stations that have connections for them. The Cedar lift station has been renovated and has a standby generator. The Dog Track lift station has a connection for a portable generator. The Terminal Street lift station has undergone renovation and now has a standby generator. The Catfish Creek lift station also has a standby generator. All of the major lift stations have alarms connected to the SCADA. HAULED WASTES The plant now has a designated receiving station for septic wastes that are hauled to the plant. Every permitted septic hauler has a swipe card to allow access. The station is located after the headworks and is equipped with its own bar screen and flow meter. City of Dubuque Wastewater Treatmen NPDES Permit #: 3126001 nspection Date: 06/12/14 Page 5of6 PREVIOUSLY NOTED DEFICIENCIES: I performed a pre-treatment audit at the City of Dubuque WRRC in December 2012. That report contained the following requirement: The City must determine the compliance status of all of its lUs for 2012 and submit a status report to this office by January 24, 2013. To -date, this information has not been received by the field office. Failure to accurately determine the compliance status of industrial users is a violation of the facility NPDES permit. On the day of this inspection, I spoke with William O'Brien regarding whether he had been able to determine if any of the City's lUs were in significant noncompliance (SNC.) He reported that there was one industry that was in SNC, but the City did not send a notice of violation nor did it issue a public notice in accordance with its Enforcement Response Plan (ERP). Mr. O'Brien also reported that he can only devote 10% of his time to the pretreatment program due to the heavy volume of laboratory workload. Mr. Brown reported that he would like to hire a full time pretreatment coordinator. The City must provide for adequate administration of the pretreatment program. In addition, Major Contributing Industries Limitations, Monitoring and Reporting Requirement #6 permit requirement (page 16 of NPDES #3126001) requires the City to evaluate the pretreatment program particularly in regard to the pretreatment streamlining rule. A report of the findings and proposal for modifications to correct any deficiencies is due to the department within one year of permit issuance. STAFFING, OPERATOR CERTIFICATION (General Staffing) Assistant plant manager Bill Jungk retired on June 29, 2012. Jonathon Brown remains the only person at the plant with the appropriate Grade 4 certification. It has been over two years since Mr. Jungk retired and the City has not found an appropriate replacement. Since the last inspection three more certified operators left employment at WRRC. Two uncertified employees were hired to replace them. William O'Brien is the only Grade III operator at the plant and he has no experience operating this plant. The City is reminded that any shift operator must be at least a Grade II as per IAC 81.2(4). The following is a list of the operators that this office has associated with the City of Dubuque WRRC: Operator Name JONATHON BROWN WILLIAM O'BRIEN RICK NEUMANN ERIC KREMER CHRIS LESTER DARYL WICKRE ANDREW PETTIGUE BRIAN CUE Certificate WW4 WW3 WW2 WW2 WW2 WW1 NO GRADE NO GRADE Operator Designation OPERATOR -IN -CHARGE REGULAR OPERATOR, LAB TECH AND PRETREATMENT COORDINATOR REGULAR OPERATOR REGULAR OPERATOR REGULAR OPERATOR REGULAR OPERATOR This office is concerned that there is not adequate staffing at the WRRC. Mr. Brown is approaching retirement and there is no one with the appropriate certification and experience with this complex plant that is ready to take over when he does retire. It is strongly recommended that the City make plans for both hiring an additional Grade 4 wastewater operator and encouraging existing employees to obtain higher certification. City of Dubuque Wastewater Treatment NPDES Permit : 3126001 Date: 06/12/14 Page 6of6' NUTRIENT REDUCTION: The City is reminded of the Nutrient Reduction requirement contained in the facility NPDES permit on page 17. A report of the City's report that evaluates the feasibility and reasonableness of reducing the amounts od nitrogen and phosphorus discharged to surface waters is due no later than October 1, 2015. SUMMARY OF REQUIRMENTS 1. Bacteria samples are required to be collected once every 3 months. The facility did not report any fecal coliform samples for the months of June, July or August 2013. The facility did not report any e.coli sampies for the months of March, Aprii or May 2014. This is a repeat violation of the facility NPDES permit. 2. The City must provide for adequate administration of the pretreatment program. 3. The City is required to determine the compliance status of all of its Industrial Users and enforce all pretreatment permits. 4. Major Contributing Industries Limitations, Monitoring and Reporting Requirement #6 permit requirement (page 16 of NPDES #3126001) requires the City to evaluate the pretreatment program particularly in regard to the pretreatment streamlining rule. A report of the findings and proposal for modifications to correct any deficiencies is due to the department within one year of permit issuance. 5. The City is reminded of the nutrient reduction requirement contained in the facility NPDES permit on page 17. The City's report that evaluates the feasibility and reasonableness of reducing the amounts of nitrogen and phosphorus discharged to surface waters is due no later than October 1, 2015. SUMMARY OF RECOMMENDATIONS 1. This office is concerned that there is not adequate staffing at the WRRC. Mr. Brown is approaching retirement and there is no one with the appropriate certification and experience with this complex plant that is ready to take over when he does retire. It is strongly recommended that the City make plans for both hiring an additional Grade 4 wastewater operator and encouraging existing employees to obtain higher certification.