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3.d.1 Bliss Collector - WW Inspection ReportCMas Minnesota Pollution Control Agency 520 Lafayette Road North I St. Paul, Minnesota 55155-4194 1 651-296-6300 800-657-3864 1 Use your preferred relay service I info.pca@state.mn.us I Equal Opportunity Employer June 9, 2016 Hon. Randall Simonson, Mayor City of Scandia 14727 209th Street North Scandia, MN 55073 RE: Bliss Collector WWTP State Disposal System Permit No. 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 (Facility) on May 24, 2016, by Kaitlin Jamieson of the Minnesota Pollution Control Agency (MPCA). The CEI consisted of a visual inspection of the Facility and a discussion with Jeff Anderson -Maintenance Worker and Dave Williams -Public Works Director. In addition, there was a review of the monthly Discharge Monitoring Reports (DMRs) for the time period from September 1, 2012 to May 24, 2016. Based on the results of the CEI, 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. To address the violations, the MPCA requests a written response within 30 days of receipt of this report. If you have any questions, please contact me at 651-757-2306 or kaitlin.jamieson@state.mn.us. Sincerely, <av-r" Ye1r"e4v*v This document has been electronically signed. Kaitlin Jamieson Environmental Specialist 2 Municipal and Industrial Wastewater Section Municipal Division KJ:wgp Enclosure cc: Jeff Anderson, City of Scandia Neil Soltis, City of Scandia t-wq-wwprm2-33 • 4118116 Minnesota Pollution Control Agency Water Quality Point Source Program Compliance Evaluation Inspection Report Facility information: Facility name: Bliss Collector WWTP Permit number: MN0054119 Address: 18925 Manning Trail, Scandia, Minnesota 55073 SIC code: 4952 - Sewerage Systems Permit expiration date: February 29, 2020 Facility design flow: 0.02 mgd (AWW) EPA Facility Type classification: EPA Minor Type of flow: Domestic Plant class: Class D Land application type: Septage 24-hour contact: Public Works Office Phone: 651433-5223 Geographic information: MPCA region: MPCA Metro Region County: Washington Basin: St. Croix River Major watershed: Lower St. Croix River Receiving water: Not applicable Those present during the inspection: Jeff Anderson, Maintenance Worker Dave Williams, Public Works Director MPCA representatives: Kaitlin Jamieson, Compliance Inspector Inspection information: Inspection date: May 24, 2016 Inspection category: Routine Inspection Inspection type: WW Compliance Evaluation Inspection Facility components: • Collection system (gravity and/or pressure) • Collection system (gravity septic tank effluent) • Collection system (pumped septic tank effluent) • Effluent Disposal - Subsurface Trench/Bed • Effluent filtration (sand without backwash) • Individual or Community SSTS • Primary treatment - septic tank • Single Pass Media Filter t-wq-wwprm2-33 • 4118116 Minnesota Pollution Control Agency Significant industrial users: 4952 - Sewerage Systems Treatment plant operators: Jeff Anderson, Class D certification, expires June 1, 2016 (renewal requested) Service Provider certification, expires February 13, 2019 t-wq-wwprm2-33 • 4118116 Inspection Summary A Compliance Evaluation Inspection was conducted on May 24, 2016, by Kaitlin Jamieson 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: 1. Overall Physical Condition of the Facility a. The Facility appeared well maintained and appeared to be in good operating condition. b. The Facility grounds were fenced, gated, posted and locked. 2. Sampling Methods/Lab Certification a. All samples are taken at the appropriate locations as identified in the permit, and are representative of flow through the Facility and treatment system. b. Sampling is performed by Facility staff. c. Samples are delivered to a contract lab for analysis, Pace Analytical Services Inc. — Virginia, Minnesota, Minnesota Department of Health State lab ID #027-137-445, EPA Lab Code MN01084. The lab results records are adequate and maintained for a minimum of three years. d. pH testing is performed on site by the Facility operator. Original pH meter readings and pH meter calibration logs were not adequately kept. See the Alleged Violations section for further description. 3. Discharge Monitoring Reports (DMRs)/Sample Values/Annual Reports a. Several DMRs due over the review period were submitted late. b. The DATES DMRs and related records were reviewed for reporting accuracy. The monitoring data was accurately reflected on the DMRs. c. Daily/Sample values have been submitted with all DMRs. 4. Inflow & Infiltration (1&1)/ Collection System issues a. The collection system consists of 70 individual septic tanks and 46 shared septic tank effluent pumping (STEP) systems which pump to one of two lift stations. b. Lift station pumps are pulled annually for maintenance and cleaning. c. The main lift station is set to be replaced in the near future. d. The city of Scandia (City) coordinates pumping the individual septic tanks. Tank levels are measured annually, and pumped as needed. e. The Facility experience some I&I issues. 5. Flow data a. The Facility's design flow is 0.0198 million gallons per day (MGD). b. The Facility's reported average influent flows over the past several years were: i. 2013 — 0.007 MGD ii. 2014-0.010 MGD iii. 2015-0.007 MGD iv. 2016-0.008 MGD (to date) c. The reported three-year average influent flow at the Facility is about 0.008 MGD. The Facility appears to be operating at approximately 40 percent of the permitted design capacity. d. WS001 pumps are used to monitor flow for permit reporting. Pump run times are recorded daily. The operators can remotely access pump run time information. e. Pumps are pulled annually for cleaning, maintenance and calibration. Pump calibration records are stored electronically and have been maintained for three years. t-wq-wwprm2-33 • 4118116 6. Enforcement Actions over the review period a. None. 7. Compliance Schedule progress a. A Compliance Schedule was included in the current permit due to concerns with the Facility's ability to consistently meet the state drinking water standard for nitrate at monitoring well GW -004. b. The Compliance Schedule required a Nitrogen Mitigation Plan (Plan) be submitted by March 18, 2016. A Plan was submitted to the MPCA on March 14, 2016, but it did not include all the required information. The City has hired the firm Bolton & Menk to assess the treatment system and prepare a detailed Plan. The Plan should be completed and submitted to the MPCA promptly. c. A final report is required September 2, 2019 (180 days prior to permit expiration). i. Permit Chapter 1, section 1.2. The report shall serve as a performance report and summarize the treatment system's ability to consistently achieve compliance with the Minnesota Department of Health (MDH) drinking water standard of 10 milligrams per liter (mg/L) for Nitrate Nitrogen at either the end of discharge of the treatment facility or within the downstream monitoring wells. The performance report shall include, if necessary, what is needed to maintain compliance with the MDH standard of 10 mg/L, including recommendations concerning modifications to the facility design, operation, and/or maintenance. 8. Biosolids/Land Application Sites a. The 2013 and 2015 Biosolids Annual Reports due over the review period were submitted late. See the Alleged Violations section for further description. 9. Pretreatment a. Not applicable. Only residential homes are connected to the Facility. 10. General Maintenance Schedule a. Operation and Maintenance manuals for Facility components were maintained on site. b. The general maintenance schedule was appropriate and followed. c. Facility grounds and drainfields are mowed a couple times each year, as needed. d. There were some signs of gopher mounds on site. The operators control gophers as needed. e. Facility tanks are pumped approximately each year. f. Two of the three drainfields were being operated. Drainfield number two has been rested for a couple years to try and minimize impacts to monitoring well GW -004. g. There are three sand filters, and each year the operator rotates which filters are in use. 11. Record Keeping a. Most required records were neatly kept and available upon request. 12. Other a. There were no unauthorized releases or overflows reported over the review period. t-wq-wwprm2-33 • 4118116 Alleged violations/description of non-compliance table: # Citation Requirement Results or Comments 1 SDS Permit Number The Permittee shall comply with the limits and monitoring The Permittee exceeded the limit for MN0054119; Limits and requirements as specified. Flow, Daily Maximum. See Table 1 Monitoring Requirements below for specific exceedances. 2 SDS Permit Number 1.1. The Permittee shall submit a Nitrogen Mitigation Plan for The Permittee submitted an MN0054119; Chapter 1 MPCA approval within one year of permit issuance. This plan shall incomplete Nitrogen Mitigation Plan. Compliance Schedule; Section serve as a monitoring and evaluation plan for documenting the 1. Compliance Schedule treatment effectiveness of the treatment system components. Nitrogen Mitigation Plan; The Plan shall include an overall assessment of the entire subpart 1.1. treatment system at the facility, along with recommendations and any potential changes to the engineering design for lowering the Total Nitrogen entering the soil dispersal system. By lowering the Total Nitrogen prior to disposal, it may be possible to lower the elevated Nitrates detected in the on-site monitoring well G W004. 3 SDS Permit Number 7.1. By December 31 following the end of each cropping year, the The Permittee submitted the 2013 MN0054119; Chapter 5. Permittee shall submit a Biosolids Annual Report for the land and 2015 Biosolids Annual Reports Domestic Wastewater — application of biosolids on a form provided by or approved by the late. The 2013 report was due by Biosolids Domestic Septage (No MPCA. The report shall include the requirements in Minnesota December 31, 2013, but was Analysis Required); Section 7. Rules, part 7041.1700. submitted late on January 29, 2014. Reporting Requirements; The 2015 report was due by subparts 7.1. and 7.2. 7.2. The permittee shall submit a Biosolids Annual Report by December 31, 2015, but was December 31 of each year for biosolids storage and/or transfer submitted late on March 15, 2016. and activities occurring during the cropping year previous to December 31. The report must indicate whether or not biosolids The Permittee submitted several Chapter 7. Total Facility were transferred and/or stored. If biosolids were transferred, the DM Rs late. See Table 2 below for Requirements; Section 1. report must describe how much was transferred, where it was specific late or non -submitted General Requirements, subpart transferred to, the name of the facility that accepted the transfer reports. 1.23. and the contact person at that facility. "Cropping year" means a year beginning on September 1 of the year prior to the growing season and ending August 31 the year the crop is harvested. For example, the 2012 cropping year began September 1, 2011, and ended August 31, 2012. t-wq-wwprm2-33 • 4118116 t-wq-wwprm2-33 • 4118116 1.23. Submitting Reports. Electronic Discharge Monitoring Reports (eDMRs), DMR Sample Values and/or Operational Spreadsheets or DMR Supplemental Forms, and related attachments shall be submitted electronically via the MPCA Online Services Portal after authorization is approved. Authorization must be applied for and approved prior to submittal via the Online Services Portal. eDMRs and DMR Sample Values and/or Operational Spreadsheets or DMR Supplemental Forms shall be electronically submitted by the 21st day of the month following the monitoring period end or as otherwise specified in this permit. Electronic DMR submittal must be complete on or before 11:59 PM of the 21st day of the month following the end of the monitoring period or as otherwise specified in this permit. A DMR shall be submitted for each required station even if no discharge occurred during the monitoring period. (Minn. R. 7001.0150, subps. 2.13 and 3.H) 4 SDS Permit Number 1.18. Certified Laboratory. A laboratory certified by the The Permittee did not properly verify MN0054119; Chapter 7. Total Minnesota Department of Health and/or registered by the MPCA or calibrate meters used for on-site Facility Requirements; Section shall conduct analyses required by this permit. Analyses of analysis including pH, specific 1. General Requirements; dissolved oxygen, pH, temperature, specific conductance, and conductance, and temperature. subparts 1.18, 1.20, and 1.21. total residual oxidants (chlorine, bromine) do not need to be completed by a certified laboratory but shall be completed by The Permittee did not verify or equipment that is verified for accuracy before use. (Minn. Stat. calibrate the pumps used for flow Sec. 144.97 through 144.98 and Minn. R. 4740.2010 and monitoring at least twice annually. 4740.2050 through 4740.2120) [Minn. R. 4740.2010] Pump calibrations are performed once per year. 1.20. Equipment Calibration: Flow meters, pumps, flumes, lift stations or other flow monitoring equipment used for purposes of The Permittee did not maintain determining compliance with the permit shall be verified and/or original records of sample time and calibrated for accuracy at least twice annually. [Minn. R. analysis time for sampling and 7001.0150, subp. 2] monitoring that is performed on site. 1.21. Maintain Records. The Permittee shall keep the records required by this permit for at least three years, including DMRs, inspections, calibration and accuracy verifications, maintenance records, any calculations, original recordings from field or t-wq-wwprm2-33 • 4118116 Table 1. Limits and Monitoring Requirements Exceedances Station Parameter Limit automatic monitoring instruments, laboratory sheets, chain of Reported Value Limit Type Reporting Period custody forms, copies of all reports required by the permit, and all Flow 0.0297 mgd 0.032 data used to complete the permit application. The Permittee shall 5/1/2013 — 5/31/2013 WS001 Flow 0.0297 extend these record retention periods upon request of the MPCA. 0.035 Daily Maximum 6/1/2013 — 6/30/2013 a. The exact place, date, and time of the sample or measurement; Flow 0.0297 mgd 0.0571 b. The date of analysis; 4/1/2014-4/30/2014 WS001 Flow 0.0297 c. The name of the person(s) who performed the sample 0.0397 Daily Maximum 6/1/2014-6/30/2014 collection and/or measurement; 8/25/2015 GWO11 7/1/2015 — 7/31/2015 d. The name of the person(s) who performed the analysis and/or 8/25/2015 GWO12 7/1/2015 — 7/31/2015 calculation; 8/25/2015 e. The analytical techniques, procedures and methods used; and f. The results of the analysis. Table 1. Limits and Monitoring Requirements Exceedances Station Parameter Limit Units Reported Value Limit Type Reporting Period WS001 Flow 0.0297 mgd 0.032 Daily Maximum 5/1/2013 — 5/31/2013 WS001 Flow 0.0297 mgd 0.035 Daily Maximum 6/1/2013 — 6/30/2013 WS001 Flow 0.0297 mgd 0.0571 Daily Maximum 4/1/2014-4/30/2014 WS001 Flow 0.0297 mgd 0.0397 Daily Maximum 6/1/2014-6/30/2014 Permitted flow limits were exceeded as shown in the table. Table 2. Discharge Monitoring Reports Submitted Late Station Reporting Period DMR Due Date DMR Submittal Date WS001 5/1/2015 — 5/31/2015 6/21/2015 6/25/2015 GWO01 7/1/2015 — 7/31/2015 8/21/2015 8/25/2015 GWO04 7/1/2015 — 7/31/2015 8/21/2015 8/25/2015 GWO06 7/1/2015 — 7/31/2015 8/21/2015 8/25/2015 GWO08 7/1/2015 — 7/31/2015 8/21/2015 8/25/2015 GWO09 7/1/2015 — 7/31/2015 8/21/2015 8/25/2015 GWO10 7/1/2015 — 7/31/2015 8/21/2015 8/25/2015 GWO11 7/1/2015 — 7/31/2015 8/21/2015 8/25/2015 GWO12 7/1/2015 — 7/31/2015 8/21/2015 8/25/2015 t-wq-wwprm2-33 • 4118116 GWO13 7/1/2015 — 7/31/2015 8/21/2015 8/25/2015 GWO14 7/1/2015 — 7/31/2015 8/21/2015 8/25/2015 GWO15 7/1/2015 — 7/31/2015 8/21/2015 8/25/2015 GWO16 7/1/2015 — 7/31/2015 8/21/2015 8/25/2015 GWO17 7/1/2015 — 7/31/2015 8/21/2015 8/25/2015 WS001 7/1/2015 — 7/31/2015 8/21/2015 8/25/2015 WS001 8/1/2015 — 8/31/2015 9/21/2015 Not submitted WS002 6/1/2015 — 9/30/2015 10/21/2015 5/24/2016 WS001 12/1/2015 — 12/31/2015 1/21/2016 4/21/2016 WS001 2/1/2016 — 2/29/2016 3/21/2016 4/12/2016 WS001 4/1/2016 — 4/30/2016 5/21/2016 Not submitted GWO01 4/1/2016 — 4/30/2016 5/21/2016 Not submitted GWO04 4/1/2016 — 4/30/2016 5/21/2016 Not submitted GWO06 4/1/2016 — 4/30/2016 5/21/2016 Not submitted GWO08 4/1/2016 — 4/30/2016 5/21/2016 Not submitted GWO09 4/1/2016 — 4/30/2016 5/21/2016 Not submitted GWO10 4/1/2016 — 4/30/2016 5/21/2016 Not submitted GWO11 4/1/2016 — 4/30/2016 5/21/2016 Not submitted GWO12 4/1/2016 — 4/30/2016 5/21/2016 Not submitted GWO13 4/1/2016 — 4/30/2016 5/21/2016 Not submitted GWO14 4/1/2016 — 4/30/2016 5/21/2016 Not submitted GWO15 4/1/2016 — 4/30/2016 5/21/2016 Not submitted GWO16 4/1/2016 — 4/30/2016 5/21/2016 Not submitted GWO17 4/1/2016 — 4/30/2016 5/21/2016 Not submitted Required DMRs were submitted late or not submitted as shown in the table. t-wq-wwprm2-33 • 4118116 Corrective Action Section: 1. Within 30 days of receipt of this CEI, the Permittee shall summarize the cause of the permit limit exceedances and describe any actions taken to ensure these do not occur in the future. 2. Within 30 days of receipt of this CEI, the Permittee shall submit a complete Nitrogen Mitigation Plan. 3. Within 30 days of receipt of this CEI, the Permittee shall summarize the cause of the late reports and describe what actions have been or will be taken to ensure all reports are submitted on time in the future. 4. Within 30 days of receipt of this CEI, the Permittee shall submit a summary to the MPCA demonstrating how adequate records will be maintained for at least three years including records of equipment calibrations on meters used for on-site analysis, flow meter verification or calibrations performed twice annually, and original sampling records that include sample time and analysis time. STATE OF MINNESOTA POLLUTION CONTROL AGENCY June 9, 2016 <�" �G�rwtel-On. Date signed This document has been electronically signed. Kaitlin Jamieson Environmental Specialist 2 Municipal and Industrial Wastewater Section Municipal Division Address questions and submittals requested above to: Kaitlin Jamieson Minnesota Pollution Control Agency 520 Lafayette Road North St. Paul, Minnesota 55112 651-757-2306 kaitlin.jamieson@state.mn.us t-wq-wwprm2-33 • 4118116 9