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.