Iowa Department of Natural Resources - NPDES W&RRC Inspection Report Copyright 2014
City of Dubuque Consent Items # 6.
ITEM TITLE: Iowa Department of Natural Resources - NPDES
Inspection
SUMMARY: Correspondence from the Iowa Department of Natural
Resources providing the inspection report for the Water&
Resource Recovery Center(W&RRC).
SUGGESTED DISPOSITION: Suggested Disposition: Receive and File; Refer to City
Manager
ATTACHMENTS:
Description Type
IDNR Inspection Report W&RRC Supporting Documentation
Fields of Opportunities STATE OF IOWA
TERRY E. BRANSTAD, GOVERNOR H) MAY51 ` K: : DEPARTMENT OF NATURAL RESOURCES
KIM REYNOLDS, LT. GOVERNOR CHUCK GIPP, DIRECTOR
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May 26, 2016 Dub uC
City of Dubuque
City Hall
50 West 13th Street
Dubuque, IA 52001
SUBJECT: Dubuque Wastewater Treatment Facility Inspection
NPDES Permit#: 3126001
it
Honorable Mayor and Council:
Enclosed is the report of the recent inspection of the above facility conducted by Brian Jergenson 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.
Deficiencies related to the handling of grit and bar screenings and septage were observed during this
inspection. In addition, flow meter calibration is not being conducted and an O&M manual has not been
received by this office. Note in the report that responses to deficiencies are required within 30 and 90 days of j
receipt of this letter.
If you have any comments or questions about the inspection or report, please contact Brian at 563/927-2640 or
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brian.jergenson@dnr.iowa.gov.
The cooperation and assistance provided by William O'Brien and Josh Contreraz during the inspection is
appreciated.
Sincerely,
J'
Amber Sauser
Environmental Specialist Senior
cc: IDNR 5th Floor Records, Wallace Bldg. (NPDES #3126001)
William O'Brien, WPCF, 795 Julien Dubuque DR, Dubuque, IA 52003
John Klostermann, 925 Kerper Court, Dubuque, IA 52001
Paul Marshal, US EPA, Region VII, 11201 Renner BLVD, Lenexa, KS 66219
File: WW/Dubuque
Efile: 31 WW Dubuque ins 062316 bdj
FIELD OFFICE#1 / 909 W MAIN ST / MANCHESTER IA 52057
563-927-2640 / FAX 563-927-2075 / www.iowadnr.gov
Et ur ,Iowa Qepartnentxof Natural Resources`3 , N
+ e„
UVastewater n Treatment Fac�htyl Insp`ec#ior I
NPDES Permit#: 3126001 Page 1
' y4 'FACILITY INFORMATION ' l G,
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Facility: Name: City of Dubuque Water Pollution Control Plant Grade: IV
Responsible Authority/Owner: City of Dubuque
Address: 50 West 13t' Street Phone: 563/589-4110
City: Dubuque State: IA Zip: 52001
Responsible Certification
Operator: Name: William O'Brien Grade: IV Number: 9472
General Pure Oxygen activated sludge treatment plant with anaerobic sludge digestion, sludge dewatering and s
Description: land application and UV disinfection j
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Design
Capacity: Average MGD: 13.47 Maximum MGD: 24.5
Pounds BOD/Day: 41,200 PE (BOD): 246,707
Now Treating: Average MGD: 7.35 Maximum MGD: 18.2
Pounds BOD/Day: 38,199 PE (BOD): 228,734
Period Reviewed: 7/1/2014-4/30/2016 Population Served: 57,637 _
Receiving
Stream: Mississippi River
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Inspection: Date and Time of Inspection: 5/23/2016 0900 Purpose: Routine Compliance Insp.
Date of Last Inspection: 6/12/2014
Persons
Interviewed: Name: William O'Brien Title: Wastewater Plant Manager
Name: Josh Contreraz Title: Environmental Coordinator
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Self- Operation Reports Submitted: Required Data on Reports: Testing Adequacy:
Monitoring: Z Sat. ❑ Marg.* ❑ Unsat.* ❑ Sat. ❑ Marg.* .❑ Unsat,* Z Sat. ❑ Marg.* ❑ Unsat.*
Effluent Self-Monitoring Results:
Limitations: ® Compliance ❑ Infrequent Non-Compliance* ❑ Significant Non Compliance*
Samples this Results:
Inspection: Type: None Lab Data Attached? ❑ Yes ❑ No ❑ Sat. ❑ Marg.* ❑ Unsat.*
Visual Appearance of Effluent: Clear
Visual Appearance of Receiving Stream: Normal/Turbid
Compliance Compliance w/Schedule:
Schedule: ❑ Sat. ❑ Marg.* ❑ Unsat.* ® NA Next Item Due:
Date Due: _
*Additional details in the narrative report
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Inspector: Name&Title: Brian Jer enson, Environmental Specialist Date: _ 6114
Reviewer: Name &Title: Amber Sauser, Environmental Specialist Senio Date: G_62 ^
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Updated 10/22/2015 cmc DNR Form 542-3158
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NPDES Permit#: 3126001 Page 2
Were deficiencies noted or significant observations made during the inspection?
Yes =See Comments Section for details
No= No deficiencies or significant observations were noted
Lack of Entry= Item not applicable or not observed.
Item Yes No Item Yes No
1. Collection System 9. Sludge Handling and Disposal
a. Operation and Maintenance ❑ ® a. Operation and Maintenance ® ❑
b. Physical Condition ❑ ® b. Physical Condition ❑
c. Dry Weather Capacity ❑ ® c. Capacity ❑
d. Infiltration/Inflow ❑ ® d. Effectiveness ❑ ED
e. Bypass(es) ❑ ® e. Final Disposal, Solids ❑ ED
2. Lift Station(s)(Collection System) f. Final Disposal, Liquids ❑
a. Operation and Maintenance ❑ ® 10. Lagoon Structures
b. Physical Condition ❑ ® a. Maintenance ❑ ❑
c. Capacity ❑ ® b. Physical Condition ® ❑
d. Reliability/Emergency Operation ® ❑ c. Capacity ❑ ❑
3. Industrial Waste Pre-Treatment d. Cell Configuration ❑ ❑
a. Significant Industrial Users ❑ ® e. Storage/Drawdown Management ❑ ❑
b.Waste Toxicity/Compatibility ❑ ® 11. Flow Measurement
c. Strength Reduction ❑ ® a. Operation and Maintenance ® ❑
d. Effect on Treatment Plant ❑ ® b. Capacity ❑
4. Preliminary Treatment c. Continuity ❑
a. Operation and Maintenance ® ❑ d. Location. Method/Effectiveness ❑
b. Physical Condition ❑ ® 12. Pumping
c. Capacity ❑ ® a. Operation and Maintenance ❑
d. Effectiveness ❑ ® b. Physical Condition ❑
5. Primary Treatment c. Capacity ❑ ® qq
a. Operation and Maintenance ® ❑ d. Reliability/Emergency Operation ❑
b. Physical Condition ❑ ® 13. Miscellaneous
c. Capacity ❑ ® a. Location ❑
d. Sludge/Scum Removal ❑ ® b. Odors ❑
e. Effectiveness ❑ ® c. Emergency Operation ❑ ED
6. Secondary Treatment d. Bypass(es) ® ❑
a. Operation and Maintenance ❑ ® e. Equipment ❑
b. Physical Condition ❑ ® f. Buildings&Grounds ❑
c. Capacity ❑ ® g. Lab Certification ❑
d. Recirculation ❑ ® h. Other ❑
e. Freezing ❑ ® 14. Staffing, Operator Certification
f. Effectiveness ❑ ® a. Operator, Direct Responsibility ❑
7. Final Settling b. Shill.Operator(s) ❑ ID
a. Operation and Maintenance ® ❑ c. General Staffing ® ❑
b. Physical Condition ❑ ® 15. Supplementary
c. Capacity ❑ ® a. Permit Availability ❑
d. Effectiveness ❑ ® b. Operation Reports Availability ® ❑
8. Supplementary Treatment c. Equipment Records Maintenance ❑
a. Operation and Maintenance ❑ ® d. Previously Noted Deficiencies ❑
b. Physical Condition ❑ ® e. Improvements ❑
c. Capacity ❑ ® f. Domestic/Industrial Growth ❑
d. Effectiveness ® ❑ g. Recommendations ® ❑
h. Required Actions ® ❑
Updated 10/22/2015 cmc DNR Form 542-3158
. Iowa Department ofriNatural Resources
�,
Wastewater Treatment F Iity Fa
inspection rm
City of Dubuque Water Pollution
Facility Name: Control Page 3
NPDES Permit# 3126001 Inspection Date: 5/23/2016
ti � �, INTRODUCTION araft
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The City of Dubuque Water Pollution Control facility consist of a pure oxygen activated sludge treatment plant. The facility
consists of two influent lines (each with magmeters), two mechanical bar screens, two grit chambers, two"tea cup" style
grit washers, four primary clarifiers, three covered aeration basins and four final clarifiers followed by UV disinfection and
step aeration. Waste activated sludge is dewatered by two rotary drum thickeners prior to pumping to anaerobic
digesters; the City's sludge is classified and Class I for land application.
A routine compliance inspection was conducted at the above facility at 9:00 A.M. on May 23, 2016. The inspection
11
involved a review of monitoring results and a thorough discussion regarding operation of the treatment plant and land
application of sludge. Finally, I conducted a walk through inspection of the treatment facility and observed the plant's
effluent and outfall location on the Mississippi River. I did not visit lift stations during the inspection, but discussed lift
station maintenance and emergency operations with staff during my inspection of the treatment facility.
NPDES Il? R�I[TECOMI?LIANIE SUtVIMARY " i l)_ " .fi. ;`.
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The monthly Discharge Monitoring Reports (DMRs)were reviewed for the reporting period from July 2014 through April
2016.
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Self- Monitoring—The reports were submitted regularly and on time and it appears that the wastewater testing
parameters of the NPDES permit are being consistently entered at the required frequencies on the operating reports.
During the inspection I discussed proper DMR data entry with Mr. O'Brien.
Design Capacity/Effluent Limitations— During the above mentioned reporting period the facility was in compliance
with the design capacity. Effluent limitations of the current NPDES permit were exceeded and are summarized below:
The Geometric Mean limitation of 126#/100 ml was exceeded with a Geometric Mean of 184#/100 ml during April, 2016.
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The 30-day and 7-day average CBOD5 effluent concentration limitations are 25 mg/L and 40 mg/L respectively. During j
the above mentioned reporting period both the 30-day and 7-day concentration limitations were exceeded during March, 1
2016 with values of 28 mg/L and 50 mg/L respectively. The 7-day mass effluent limitation of 4494 lbs/day CBOD5 was
also exceeded during March, 2016, with a value of 4610 lbs/day.
The maximum ammonia nitrogen concentration and mass limitations vary monthly. The maximum concentration
limitations were exceeded five days during July, 2015, and one day during August, 2015. The maximum mass limitation
was exceeded one day during July, 2015.
The 30-day and 7-day average TSS effluent concentration limitations are 30 mg/L and 45 mg/L respectively; both were
exceeded during March, 2016 (42 mg/L and 92 mg/L). The 7-day average concentration limitation of was also exceeded
during November, 2015 with an average concentration of 51 mg/L. The 7-day average TSS mass limitation of 5055
lbs/day was exceeded during March, 2016, with a 7-day average of 8601 lbs/day.
NPDES PERMIT—The facility's NPDES permit was issued October of 2013 and expires in 2018.
f FACIaLITY EVALUATION,
2.d: LIFT STATION(S) (COLLECTION SYSTEM): Reliability/Emergency Operation
The collection system is maintained by the Water Pollution Control staff. During the previous DNR inspection it was noted
that some of the lift stations were without dedicated generators and were not capable of receiving power from a portable
generator. I was assured during the inspection that all lift stations without dedicated generators have the ability to be
hooked to portable generators.
Updated 10/22/2015 cmc DNR Form 542-3158
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4.a: PRELIMINARY TREATMENT: Operation and Maintenance
During the inspection it was reported that grit and screenings are disposed of at the Dubuque Metropolitan Sanitary
Landfill. The grit and bar screenings have not been stabilized as is required in subrule 567 IAC 109.11(3) as cited below:
109.11(3) Stabilized grit, bar screenings, and grease skimmings. The sanitary landfill operator,
the generator, and the hauler shall comply with the following conditions and requirements whenever
stabilized grit, bar screenings, or grease skimmings are disposed of in a sanitary landfill.
a. The waste cannot contain any free liquids as determined by the paint filter liquids test.
b. The generator shall stabilize the grit, bar screenings, and grease skimmings prior to their
disposal at the landfill in order to destroy any pathogenic organisms. Stabilization can be done by
addition of lime to raise the pH to at least 12 for two hours.
c. The generator shall prearrange a delivery schedule with the landfill operator.
d. Upon arrival at the landfill, the hauler shall identify the waste to the landfill attendant.
e. The landfill operator shall direct the hauler to the working face.
f. The waste shall be deposited at the working face, covered with regular refuse or soil and
compacted.
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5.a: PRIMARY TREATMENT: Operation and Maintenance
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On the day of the inspection operation and maintenance of the primary clarifiers was discussed with Mr. O'Brien. During
our discussion in regard to scheduled maintenance on the clarifiers Mr. O'Brien was unaware of a regular schedule for
dewatering, cleaning, and inspecting the clarifiers.
7.a: FINAL SETTLING: Operation and Maintenance
On the day of the inspection Mr. O'Brien was unable to determine whether a regular schedule for maintenance on the final
clarifiers exists.
8.d: SUPPLEMENTARY TREATMENT: Effectiveness
The Department was made aware of two failures in the facility's UV disinfection system during the month of May 2016,
resulting in the discharge of approximately 2.45 million gallons of non-disinfected wastewater on May 61h and 10ti'. We
discussed the City's written report of disinfection noncompliance and corrective actions being implemented to prevent
future noncompliance. Any time disinfection is interrupted staff must report the incident to the Department within 24 hours
and a written report shall be submitted within 5 days; bacteria samples must also be collected.
9.a: SLUDGE HANDLING AND DISPOSAL: Operation and Maintenance
Nutri-Ject continues to haul the City's sludge at a rate of approximately five truckloads per week to a land application site
where a storage building was constructed for the dewatered sludge; the plant does not have sludge storage. The City's
sludge meets Class I criteria. All requirements in 567 IAC 67 for Class I sludge must be met in regard to land application
and management.
10.b: LAGOON STRUCTURES: Physical Condition
According to Field Office#1's file, the south ash pond was to be abandoned by April, 2015 by dewatering the pond and
transporting the ash to the landfill. During the inspection on 5/23/16 the south ash pond had not been abandoned but was
being used to dewater septage from independent haulers. According to Mr. O'Brien, septic haulers are directed to the
south ash pond instead of the designated septic waste receiving station when City staff determine the load contains
excessive grease or solids. Use of the south ash pond for dewatering wastewater is not appropriate and must cease
immediately. Furthermore, solids collected from the pond must be disposed of at the landfill after being properly
disinfected.
11.a. FLOW MEASUREMENT: Operation and Maintenance
During the 2014 inspection it was noted that flow meters had not been calibrated since their installations in 2012. As part
of the current inspection William O'Brien was unable to verify that the meters have been calibrated according to the
manufacturer's recommendation. The City is required to ensure the flow meters are calibrated accordingly.
Updated 10/22/2015 cmc DNR Form 542-3158
13.d. MISCELLANEOUS: Bypass(es)
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 and a Fats, Oils and Grease (FOG) ordinance. The City submits Semiannual
reports to the DNR and EPA as part of the Consent Decree.
14.c. STAFFING, OPERATOR CERTIFICATION: General Staffing
Jonathan Brown recently retired and William O'Brien is the Plant Manager serving as the Operator-in-Charge. Eric
Kremer has also acquired his Grade IV certification since the previous inspection. Josh Contreraz has been hired as the
Environmental Coordinator and will be taking over the pretreatment program.
15.b. SUPPLEMENTARY: Operation Reports Availability
During the inspection I had several operation and maintenance questions that could not be answered. It would benefit
staff to review the 0&M manual. This office has not received a copy of the plant's O&M manual.
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gq , SUdLARY '�
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The City of Dubuque is in general compliance with its NPDES permit. However, the former ash pond must no longer be
used to receive septage.
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fRa ik F ' t1 Ili ' iEC1l11REMENTS
1. Stabilize grit and bar screenings prior to disposal at the landfill in accordance with 567 IAC 109.11(3).
2. Ensure that bypasses of non-disinfected wastewater are reported to the Department within 24 hours and submit a
written report within five days; bacteria sampling must also be conducted.
3. The use of the former ash pond for dewatering septage is prohibited effective immediately. Once dewatered and
disinfected, the solids from the pond must be disposed of at a permitted solid waste facility. Submit
documentation of disposal within 90 days of receipt of this report.
4. Provide verification of flow meter calibration to this office within 30 days of receipt of this report.
5. Submit the treatment plant's O&M manual to this office within 30 days of receipt of this report.
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�,33� r � IM R RECOMMENDA710NS ��, ,
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1. Review the plant's O&M manual to ensure the recently installed equipment is being operated and maintained as
designed.
Updated 10/22/2015 cmc DNR Form 542-3158