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5.e) MPCA Letter re: violations with Bliss Collector f � � � �� � / SCANDIA Staff Renort Date of Meeting: December 11, 2012 To: City Council From: Kristina Handt, City Administrator Re: MPCA Letter re: violations with Bliss Collector Agenda Item#: S.e) Background: On December 3, 2012 the City received a letter from Mark Hugeback, Compliance Coordinator with MPCA. The letter was in regards to a Compliance Evaluation Inspection that was conducted on September 11, 2012 on the Bliss Collector System. The inspection and review of records revealed four violations of the State Disposal System Permit. A copy of Mr. Hugeback's letter is included in your packet. The violations were as follows: Violation 1: MPCA staff documented that the Regulated Party failed to submit a number of DMRs by the required due date. DMRs are due 21 days after the end of the month. Violation 2: MPCA staff documented that the regulated Party failed to meet its effluent discharge limit for flow during the Apri12008 DMR reporting period. Violation 3: MPCA staff documented that the Regulated Party failed to report a sample value for Nitrate Nitrogen on its July 2011 DMR. Violation 4: MPCA staff documented that the Regulated Party failed to monitor pH within 15 minutes or less of sample collection at monitoring station WS 001. Issue: The City must provide a written response to these violations within 30 days of receipt of the letter. How should the City respond? Proposal Details: Staff has drafted a proposed response. A copy is included in your packet. , The main point staff stressed is that a new contractor has taken over effective December 1, 2012 and that there will be more staff oversight of that contractor than there had been in the past. The Maintenance Superintendent will be having regular contact with EcoCheck and receiving copies of the reports they submit to the state. Staff has asked Pete Ganzel,Washington County Environmental Services, to provide the amended DMR for July 2011 as requested by MPCA. We are meeting with Pete on Monday, December 10`h and will bring any additional information obtained to the work session meeting. Fiscal Impact: NA Options: Provide direction to staff on any changes needed to the letter. Changes will be made and brought back to the December 18th Council meeting. December 5, 2012 Mr. Mark Hugeback Compliance Coordinator, MPCA 18 Wood Lake Drive SE Rochester, MN 55904 - RE: Bliss Collector, SDS Permit Number MN0054119, Compliance Evaluation Inspection Dear Mr. Hugeback, The City of Scandia is in receipt of your letter dated November 28, 2012 regarding four violations found during the September Compliance Evaluation Inspection of the Bliss Collector System. We appreciate you bringing these issues to our attention and giving us an opportunity to respond. On September 18,2012, the Scandia City Council approved a contract with EcoCheck (Natural Systems utilities, MN LLC) to provide wastewater operation services. A copy of our contract with them is included for your information. We believe this new partnership will ensure proper reporting in the future. �` The City Council r ed your le at their December 11, 2012 meeting and would like to submit the following in respons e four ific violations mentioned in your letter: Violation 1:Submit a mont R by 21 days after the end of each calendar month following permit issuance. As mentioned above,the City has recently contracted with a new operator. The terms of their contract require them to submit monthly DMR reports to MPCA. Furthermore, EcoCheck will be submitting copies of those reports to the City's Maintenance Superintendent so we will have an added level of oversight that was not present before. Violation 2:The Permittee shall comply with the Limits and Monitoring requirements as specified. . . Again, the City has a new operator for the Bliss Collector System effective December 1, 2012. In addition to providing copies of reports to the City's staff, there will be more frequent testing and a regular schedule has been established. Violation 3: MPCA staff documented that the Regulated Party failed to report a sample value for Nitrate Nitrogen on its July 2011 DMR A copy of an amended DMR for July 2011 is enclosed with this letter. The City will continue to coordinate with its new operator to prevent supplying incomplete reports in the future. Violation 4: MPCA staff documented that the regulated Party failed to monitor pH within 15 minutes or less of sample collection time at the monitoring station WS 001. City staff has spoken with EcoCheck and confirmed that they will be monitoring pH samples within 15 minutes when taken at the WS 001 station. Once again we'd like to thank you for bringing these issues to our attention. The City of Scandia looks forward to working with you and other MPCA staff to ensure that�all requirements of the State Disposal System Permit are met. ,,��. a;�r,q �<�a Sincerely, ::; ,., Kristina Handt ` ' Administrator,City of�c2india �::.. �� r�`� ,���� �,, "'��s. "�::; 3 �4. l: � . . �: "�`.a},,.;�� �: � Minnesota Pollution Control Agency � Rochester Office� 18 Wood Lake Drive SE � Rochester,MN 55904 � 507-285-7343 800-657-3864 � 651-282 5332 TTY � www.pcastate.mn.us � Equal Opportunity Employer RECEIVED November28,2012 �E� —� ZQ�2 CITY OF SCANDIA The Honorable Randall Simonson Mayor,City of Scandia Bliss Collector 14727-209th Street North Scandia, MN 55073 RE: Bliss Collector,SDS Permit Number MN0054119,Compliance Evaluation Inspection Dear Mayor Simonson: Enclosed is the Compliance Evaluation Inspection (CEI) Report that resulted from an inspection of the Bliss Collector Wastewater Treatment Facility(Regulated Party)on September 11,2012,by Adam Gulsvig of the Minnesota Pollution Control Agency(MPCA). The CEI consisted of a visual inspection of the facility and a discussion with Pete Ganzel,Washing County Environmental Services. In addition to the CEI,there was a review of the Regulated Part�s records for the time period January 1,2008,to September 11,2012. Based on the results of the CEI,four violations of the terms and conditions set forth in the State Disposal System (SDS)Permit were noted. Please see the attached CEI Report for further detail. The MPCA requests a written plan to address the violation within 30 days of receipt of this report. The MPCA will be requiring all permitted Wastewater Treatment Facilities to submit Daily Values and Discharge Monitoring Reports electronically through the MPCA's eDMR portal by December 31,2012.This will require the Permittee to provide,or make available,a computer with high-speed internet and Microsoft Excel,to the operator or designated staff.The Permittee should begin making arrangements to submit DMRs electronically in the near future, but no later than December 31,2012. For further assistance, please contact Tamara Dahl at 507-476-4252. The Honorable Randall Simonson Page 2 November 28, 2012 Adam Gulsvig has accepted a position with another agency,so if you have questions regarding this letter, please contact me at 507-206-2650 or 800-657-3864. Sincerely, 7 u�G'� �-� Mark Hugeback Compliance Coordinator Rochester Office Municipal Division Enclosures cc: Pete Ganzel,Washington County(w/enclosures) Mary DeZurik,MPCA(w/enclosures) Enforcement Database Coordinator, MPCA(w/enclosures) ❑ Letter of Warning ❑Alleged Violation Letter ❑ Notice of Violation ❑Stipulation Agreement ❑Schedule of Compliance � Other written correspondence MINNESOTA POLLUTION CONTROLAGENCY WATER QUALITY POINT SOURCE PROGRAM Compliance Evaluation Inspection Report FACILITY INFORMATION: THOSE PRESENT DURING THE INSPECTION: Facility Name:Bliss Collector Facilitv Representatives Permit Number: MN0054119 Pete Ganzel,Washington County Address: See location description Scandia, Minnesota 55073 MPCA Representatives Permit Expiration Date: March 31,2015 Adam Gulsvig Facility Design Flow:0.0198 mgd(AWW) Major Minor Classification: Minor INSPECTION INFORMATION: Type of Flow: Domestic Inspection Date:September 11,2012 Plant Class: D Inspection Type:CEI,Domestic Municipal without Land Application Type: N/A Sampling Inspection Category:State 24 Hour Contact: Phone: FACILITY COMPONENTS: Septic Tank-effluent pumping GEOGRAPHIC INFORMATION: Collection with graviry and/or Pressure Sewer MPCA Region: Metro 3 Septic Tanks County:Washington 3 Single Pass Media Filter Basin:St.Croix River 3 Subsurface Trench Major Watershed: Lower St.Croix River Receiving Water: None listed WASTE CONTRIBUTORS: No waste contributors are listed for this permit. TREATMENT PLANT OPERATORS: Pete Ganzel,Class D—Expires 7/1/2014 1 INSPECTION SUMMARY A Compliance Evaluation Inspection was conducted on September 11,2012,by Adam Gulsvig of the Minnesota Pollution Control Agency(MPCA)to determine the facility's compliance with the terms and conditions of its State Disposal System (SDS) Permit.The following is a summary of the findings and comments resulting from that inspection. Areas of Concern or General Comments: • Overall Phvsical Condition of the plant - The Regulated Part�s facility appeared to be well operated and in good condition at the time of inspection. No obvious operation and maintenance issues were observed. • Samplin�Methods/Lab Certification - The Regulated Party collects samples for all parameters and conducts onsite analysis of potential for Hydrogen(pH),Temperature,and Specific Conductance.All other parameters required by the SDS Permit are transferred to the Minnesota Department of Health(MDH)analysis. - During the inspection,the MPCA staff discussed the procedures for onsite analysis of pH,Temperature,and Specific Conductance with the Regulated Party.The Regulated Party stated that the parameters mentioned above are analyzed immediately after sample collection,with the exception of pH,at all groundwater monitoring stations.In regards to pH monitoring at station WS 001(effluent to drain field), pH is monitored by the MDH lab in St. Paul.While the MPCA recognizes that MDH is a certified lab and therefore capable of monitoring pH,the Regulated Part�s SDS Permit states that pH must be analyzed within 15 minutes or less of sample collection time.The Regulated Party will be required to being pH monitoring at station WS 001 within 15 minutes of sample collection time. - All other samples appeared to be taken at the correct representative sampling points � and with approved sampling methods. • Dischar�e Monitorin�Reports(DMRs1/Annual Reports/Other Repuired Submittals - As stated in the above cover letter,the MPCA staff conducted a file review of the Regulated Part�s SDS Permit for the time period January 1,2008,through September 11,2012.The�le review consisted of an audit of the Regulated Part�s compliance with record keeping and submittal requirements set forth in SDS Permit Number MN0054119. - Late submittals DMRs:The MPCA staff documented that the Regulated Party submitted 12 late DMRs over the course of the file review period.Please be advised, the Regulated Part�s SDS Permit states that all DMRs(groundwater and waste stream stations)shall be submitted to the MPCA by 21 days after the end of each calendar month.The MPCA staff discussed the late DMRs with the Regulated Party during the inspection and will take the details of that discussion into account when determining what level of enforcement action is appropriate regarding this particular violation. - Unreported Analyte:The MPCA staff documented that the Regulated Party failed to report the instantaneous maximum value of Nitrate Nitrogen at monitoring station GW 006 during the July 2011 DMR reporting period. Failure to report a sample value for a required analyte is considered a violation of the SDS Permit. - Effluent Limit Exceedance:The MPCA staff documented that the Regulated Party reported an exceedance of the Calendar Month Average flow limit during the April 2008 DMR reporting period.The Calendar Month Average flow limit is 0.0198 million gallons per day(mgd),the Regulated Party reported an average of 0.02014 mgd. Exceeding an effluent limit is considered violation of the SDS Permit. - eDMR:The MPCA will be requiring all permitted Wastewater Treatment Facilities to submit Daily Values and DMRs electronically through the MPCA eDMR portal by December 31,2012.This will require the Permittee to provide,or make available,a computer with high-speed internet and Microsoft Excel,to the operator or designated staff.The Permittee should begin making arrangements to submit DMRs electronically in the near future, but no later than December 31, 2012. For further assistance please contact Tamara Dahl at 507-476-4252. • Infiltration/Inflow Collection Svstem issues—N/A • Flow data(compare desi�n flow to actual flow) - The MPCA staff reviewed the Regulated Party's flow data and determined that the facility did not exceed its design flow during the review period.See the table below for � more detail. Descriptor Flow(mgd) Facility Design Flow(Flow to Drainfield) 0.0198 2009 Reported Flow 0.0120 2010 Reported Flow 0.0100 2011 Reported Flow 0.0110 3 Year Avg. 0.0110 %of Design Flow 55.5 2012 YTD Flow 0.0080 *mgd=million gallons per day • Enforcement Actions over the review period—N/A � • Compliance Schedule proaress—N/A • Biosolids/Land Application Sites - No issues with Biosolids management were observed or discussed during the inspection.According to the Regulated Party's Biosolids Annual Reports,all solids are transferred off site to Metropolitan Council Environmental Service for processing/disposal. • General Maintenance Schedule Reviewed—Dailv.Weeklv and Monthlv Oaeration and Maintenance(O&Ml - The Regulated Part�s SDS Permit contains specific operation and maintenance requirements for the septic tanks,drain fields,collection system,and monitoring instruments.The MPCA staff reviewed the Regulated Part�s maintenance records regarding the above O&M requirements and determined the Regulated Party satisfied all 0&M requirements outlined in the SDS Permit during the review period. • Record Keepin� - The Regulated Party maintains all records,as required by Chapter 8,Part 1,Subpart � 1.20 of SDS Permit Number MN0054119. Alleged Violations/Corrective Actions 1. Violation:SDS Permit Number MN0054119 Chapter 1,Part 2,Subpart 2.1 and Part 3,Subpart 3.1 states: Submit a monthly DMR monthly by 21 days after the end of each calendar month following permit issuance. Station ID DMR Due Date DMR Received Date WS 001 5/21/2008 11/26/2008 WS 002 5/21/2008 11/26/2008 WS 002 5/21/2010 6/15/2010 GW 009 8/21/2008 8/28/2008 �w o10 8/zs/Zoos s/zs/Zoos GW 011 8/21/2008 8/28/2008 GW 012 8/21/2008 8/28/2008 GW 013 8/21/2008 8/28/2008 GW 014 8/21/2008 8/28/2008 GW 015 8/21/2008 8/28/2008 GW 016 8/21/2008 8/28/2008 GW 017 8/21/2008 8/28/2008 During an inspection and file review on September 11, 2012,the MPCA staff documented that the Regulated party failed to submit the DMRs outlined in the above table by the required due date. � Corrective Action:Within 30 days after receipt of this report, provide a written description to the MPCA indicating what action has been and/or will be taken to prevent future late submittals of DMRs. 2. Violation:SDS Permit Number MN0054119 states: The Permittee shall comply with the Limits and Monitoring requirements as specified below. Station ID Parameter Limit Type Discharge Limit Reported Discharge DMR Date WS 002 Flow Calendar Month Average 0.0198 MGD 0.020214 MGD 4/30/2008 Violation:SDS Permit Number MN0054119 Chapter 8, Part 1,Subpart 1.31 states: Effluent Violations: If sampling by the Permittee indicates a violation of any discharge limitation specified in this permit,the Permittee shall immediately make every effort to verify the violation by collecting additional samples, if appropriate, investigate the cause of the violation, and take action to prevent future violations.Violations that are determined to pose a threat to human health or a drinking water supply,or represent a significant risk to the environment shall be immediately reported to the Minnesota Department of Public Safety Duty Officer at 1-800-422-0798(toll free) or 651-649-5451 (metro area). In addition,you may also contact the MPCA during business hours. Otherwise the violations and the results of any additional sampling shall be recorded on the next appropriate DMR or report. During the routine inspection and file review on September 11, 2012,the MPCA staff documented that the Regulated Party failed to meet its effluent discharge limit for flow during the April 2008 DMR reporting period. Corrective Action:Within 30 days after receipt of this report,submit a written response indicating the corrective measures to be taken to ensure all future effluent limit violations properly reported to the MPCA in accordance with Chapter 8, Part 1,Subpart 1.31 of SDS Permit Number MN0054119. 3. Violation:SDS Permit Number MN0054119 Chapter 8, Part 1,Subpart 1.21 states: Completing Reports:The Permittee shall submit the results of the required sampling and monitoring activities on the forms provided, specified, or approved by the MPCA.The information shall be recorded in the specified areas on those forms and in the units specified. (Minn. R. 7001.1090,subp. 1, item D; Minn. R. 7001.0150, subp. 2, item B) Required forms may include: Discharge Monitoring Reports Supplemental Form. Individual values for each sample and measurement must be recorded on the DMR Supplemental Form,which, if required,will be provided by the MPCA.The DMR Supplemental Forms shall be submitted with the appropriate DMRs.You may design and use your own supplemental form; however, it must be approved by the MPCA. Note: Required summary information M.UST also be recorded on the DMR.Summary information that is submitted ONLY on the DMR Supplemental Form does not comply with the reporting requirements. Parameter Discharge Units Limit Type Effective Period Sample Frequenc Limit Type � y Nitrogen, Nitrate, Monitor Only mg/L Instantaneous Apr,lul,Oct Grab 1 x Month Total(as N) Maximum During the routine inspection and file review on September 11, 2012,the MPCA staff documented that the Regulated Party failed to report a sample value for Nitrate Nitrogen on its July 2011 DMR. Corrective Action:Within 30 days after receipt of this report,the Regulated Party must submit an amended DMR for July 2011 that contains a value for Nitrate Nitrogen. 4. Violation:SDS Permit Number MN0054119 Chapter 8, Part 1,Subpart 1.15 states: Representative Sampling.Samples and measurements required by this permit shall be conducted as specified in this permit and shall be representative of the discharge or monitored activity(40 CFR 122.41 (j) (1)). During the September 11,2012, inspection and file review,the MPCA staff documented that the Regulated Party failed to monitor pH within 15 minutes or less of sample collection time at monitoring station WS 001. Corrective Action: Within 30 days after receipt of this report,the Regulated Party must submit a plan describing the corrective measure taken/to be taken to ensure all future samples of pH taken from station WS 001 are analyzed within 15 minutes or less of sample collection time. Signature of Inspector � Date �, `�.. � ti �. ! . Comments,questions and submittals should be addressed to: Mark Hugeback Minnesota Pollution Control Agency 18 Wood Lake Drive Southeast Rochester, Minnesota 55904 507-206-2650