Voting people helping people

Trying to Communicate With the City Council

 

 

Trying to Communicate With Our City Council on January 20, 2010

To:          Salmon City Council

From:    Calvin Leman

Date:     January 20, 2010

 

Salmon will not be the first city in Idaho to use wastewater from the city to nourish crops.  Here are a few cities, from the Idaho DEQ list:

Wastewater Management: Final Wastewater Reuse Permits

 

Albion, City of LA-000077-02

 

Arco, City of LA-000029-02

 

Ashton, City of LA-000047-02

 

Bayview Water and Sewer District LA-000105-03

 

Bellevue, City of LA-000112-01

 

Bruneau Water and Sewer District LA-000129-02

 

Carey Water and Sewer District LA-000021-02

 

Coolin Sewer District LA-000013-03

 

Cottonwood, City of LA-000144-02

 

Dubois, City of LA-000166-02

 

Filer, City of LA-000079-02

 

Franklin, City of LA-000014

 

Hayden Area Regional Sewer Board LA-000109-03

 

Hazelton, City of LA-000023-02

 

 

 

Go to   http://www.deq.state.id.us/water/permits_forms/permitting/wlaps_final.cfm

to see them all.

 

We don’t have to report to EPA if we don’t put wastewater into the river:

 

• ·         We don’t have to spend $4 million dollars to try to fix a lagoon system that has never worked, according to EPA data on BOD and TSS.

• ·         We don’t have to send reports or anything to EPA, if we don’t put the water into the river.

• ·         If we don’t put the water into the river, we don’t have to send $4 million dollars out of Salmon.  The $60,000, which we gave Keller Associates for an analysis, did find some pipes that may need fixed.  It is not clear that the $30,000 taxpayer dollars and $30,000 DEQ dollars are a good value for the Keller study.[i]

• ·         If we don’t put the water into the river, we don’t have to fix the collection system.  Ingress and inflow are not a problem for constructed wetlands or for direct-land applications.

 

 

 

Keller’s description of constructed wetlands does not agree with the documents that EPA has been publishing.  To see for yourself, go to EPA[ii] or go to http://votingpeoplehelpingpeople.com/default.html and click on Municipal Wastewater Video Presentation.  At the bottom of that page you see the link: "constructed wetlands wastewater municipal" (1 to 15 of 1053)

A constructed wetland may be on a high spot that is out of the flood zone and North of the lagoons.  Other possibilities for where the water may go are the Overacker and the Nelson fields of agriculture.  Other people may want the water, if the water rights on the river are adjudicated.

 

The city can find a solution to the wastewater issue that is good for the farmers, good for the city, good for the river, and good for the people of Salmon.

 

 

 

In the Twenty Years Between EPA Visits, Salmon Has Had Trouble Complying with Wastewater Testing and With Making Reports to EPA. 

Salmon does not have to report to EPA if Salmon does not put water into the river.

The previous NPDES Permit for this facility was effective on April 2, 1987, and had expired on April 1, 1992. Permit conditions were administratively extended since the expiration until a NPDES Permit was re-issued. [iii]  The collection system was built in 1940 and 1950 decades and located in its present location in 1970.[iv]  The infiltration problem with the collection system has been known at least since 1987, and probably exited before 1987.

On January 30, 2006, Salmon City submitted an NPDES Permit Application.  On October 1, 2007 EPA issued a new permit for Salmon.[v]  In the EPA Fact Sheet[vi]  that was issued with the Permit, EPA said: EPA does not have the discretion to incorporate a compliance schedule for the 85% minimum percent removal for BOD5 and TSS because the 85% minimum percent removal requirements are federal secondary treatment standards which does not allow for a compliance schedule. Salmon’s requirement changed from 65% to 85% removal.  That Fact Sheet lists 22 violations from 2001 to 2007.

 

Even though the August 21,2007 NDPES permit specified that Salmon must send notice to EPA and to Idaho DEQ saying that a Quality Assurance Plan and an Operations and Maintenance Plan was on hand at the facility, it took a violation notice[vii] in October of 2008 from EPA to make Salmon respond on October 16[viii] and on November 12.[ix]  That violation notice lists 120 violations of the Clean Water Act.

EPA data from 10/2007 to 12/2009[x] shows 13 violations. EPA lists violations at various locations[xi]  

Toni Hardesty can say[xii] that Salmon is being proactive and that EPA takes that into consideration.  The data and violations that EPA has collected on Salmon shows that EPA will not tolerate violations of the Clean Water Act, proactive or not.

When Ken Gutzman said that we are not going to do anything for two years, I suppose he is saying the current permit is good till 2012.  Inconsistent with Ken’s statement are:

 (1) EPA violation notice about not sending the forms

(2) ID0020001 NPDES BOD and TSS violations occurring on a regular basis, since 1987

(3) EPA documents that show constructed wetlands and direct land application as solutions to municipal wastewater.

The city can find a solution to the wastewater issue that is good for the farmers, good for the city, good for the river, and good for the people of Salmon.

 

 

 

Trying to Communicate With Our City Council on January 6, 2010

 

Salmon Wastewater Facility ID-002000-1 and How to Fix it.

 

In the last century the people guided the government to stop the Vietnam War, to protect Human Rights, and to protect the air and the water.  The people were being harmed by the air and by the water.  People were dying from government radioactivity testing and industry pollution of water.  You may remember that the Cuyahoga River caught fire.

What does this have to do with Salmon?

In response to the polluted water in the last century, the federal government made the Clean Water Act.  That act returned some of federal tax dollars to Salmon to build a sewage treatment plant in 1987.  EPA issued a permit and did not come to Salmon again until 2007.  In 2007 the EPA wrote two documents about Salmon:

(1)    Authorization to Discharge Under the National Pollutant Discharge Elimination System (NPDES)

(2)    Fact Sheet (for NPDES Permit #ID-002000-1

 

That Fact Sheet in Table B-2 stipulates that Salmon must meet the Clean Water Act standard Secondary Treatment.  That means that we must remove 85% of the BOD and TSS substances before putting the water into the Salmon River.

The Fact Sheet Table B-2 shows Salmon out of compliance 22 times, from 3/31/2001 to 3/31/2007.  We have no reason to believe that the wastewater facility was ever in compliance, from the day it was started.

In 2008, Salmon City asked Keller Associates to address this problem.

Keller reports:

Since the discharge permit was renewed in 2007, the Salmon wastewater system has failed to achieve the 85% removal level for TSS in six months and failed to achieve the 85% removal level for BOD in five months. (According to Keller Associates)

 

The Salmon wastewater treatment plant has recorded several violations to the NPDES permit that went into effect in October 2007. Violations have primarily been in the TSS removal percentage (six violations) and BOD5 removal percentage (five violations). The discharge BOD concentrations were still within the limits of the permit and discharge TSS concentrations exceeded the limit for monthly average once and weekly average once. The low removal occurred due to low influent concentration. Under the previous NPDES permit the system has had 11 other violations since 2003. These violations included: four TSS removal percentage violations, two BOD5 removal percentage violations in 2003 due to low influent BOD5 concentration, three to fecal coliform 7-day geometric mean due to UV disinfection system fouling that were immediately corrected by cleaning the UV unit, one to the effluent TSS concentration limit in March 2003, and one to the effluent total monthly TSS limit in April 2007. (Keller Associates)

 

Keller states that we should pay $4 million now and even more money every year from now on.[i]

 

Keller is watching out for their company.  They are not recommending the best wastewater plan for Salmon. 

 

Keller’s discussion of wetlands simply demonstrates that they don’t know what constructed wetlands are.  They have not studied the documents that EPA and others have produced on constructed wetlands and they have not read the books on constructed wetlands.

 

When I asked a technical question on Table B-2, Skyler Allen of Keller told me that he had to consult with IDEQ to answer.  Skyler Allen never did answer. Jim Mullens of Keller was in Salmon.  He does not answer telephone calls or email.

 

 

EPA Compliance Data on Salmon Wastewater Facility

 

03-MAR-1987 Permit Issued

01-APR-1992 Permit Expired

 

Compliance Monitoring History (05 years )

 

Statute	Source ID	System	Inspection Type	Lead Agency	Date	Finding
CWA	ID0020001	ICP	Evaluation (CEI); NPDES - Base Program	State	05/28/2008	Under Review

 

 

 

CWA/NPDES Compliance Status

Statute:Source ID CWA:ID0020001

QTR1 Oct-Dec06

QTR2 Jan-Mar07

QTR3 Apr-Jun07

QTR4 Jul-Sep07

QTR5 Oct-Dec07

QTR6 Jan-Mar08

QTR7 Apr-Jun08

QTR8 Jul-Sep08

QTR9 Oct-Dec08

QTR10 Jan-Mar09

QTR11 Apr-Jun09

QTR12 Jul-Sep09

Non-compliance in Quarter

Yes

N/A

Yes

N/A

Yes

Yes

Yes

Yes

Yes

Yes

Yes

Yes

 

 

Notices of Violation or Informal Enforcement - AFS, PCS, ICIS-NPDES, RCRAInfo (05 year history)

 

Statute	Source ID	Type of Action	Lead Agency	Date
CWA	10-200011350	Administrative - Informal	EPA	10/07/2008

 

 

http://www.epa-echo.gov/cgi-bin/get1cReport.cgi?tool=echo&IDNumber=ID0020001

 

 

If we put the effluent into a wetland and then onto the land to irrigate crops, we no longer must meet the Clean Water Act by submitting National Pollutant Discharge Elimination System reports to EPA.  We no longer will be threatened with fines for $10,000 or for $32,500.

 

 

Meeting this EPA requirement has been a problem since 1987.  It is time to stop.

 

It is time to work with the Idaho Department of Environmental Quality, the Upper Salmon Basin Watershed Project, the Lemhi Soil and Water Conservation District, and the farmers who will use the irrigation water.

It is time to find a consultant engineer who can help the people of Salmon to build a constructed wetland and an irrigation system.

 

In Salmon, Idaho, $26,823 is the median income,[ii] with 19.5% of the population  below the poverty line, including 28.3% of those under age 18 and 14.3% of those age 65 or over.

With Recovery Funds and other grants and loans available to small cities for wastewater treatment: 

(1)   We ask the city council to find help with the expense from other sources, such as this form http://www.deq.idaho.gov/water/permits_forms/forms/waste_water/form_b_loi_ww_grant.doc, which is for a city to get grant funding for a planning effort (a facility plan or engineering report must be completed prior to a construction loan): 

 

or this form http://www.deq.idaho.gov/water/permits_forms/forms/waste_water/form_c_loi_ww_loan.doc, which is for the city to get loan funding for design and construction (it very rarely works out for a city to obtain a loan in the same year it takes on a planning effort…a consideration if the city hasn’t yet completed its plan): Tim Wendland, DEQ Division of Water Quality, Loan Program Manager, (208) 373-0439.  Elk Bend, for example got a grant last April from DEQ for their wastewater issue. Chubbuck in Bannock County just got $11 million interest free load for their wastewater issue.

 

(2)   We ask the city council to consider a constructed wetland solution for wastewater.  These wetland solutions are ½ to 1/8 [iii] the cost of a conventional wastewater treatment facility.  The Environmental Protection Agency has many documents showing free-water surface wetlands the best value for small towns, where land is available.  The city council chose Keller Associates to propose a solution. That firm has no experience with constructed wetlands solutions.   Wetland solutions are in South Dakota and in Canada, where it is even colder.   Apparently Keller Associates did not examine the EPA documents about small town waste-water systems, which are generally 2-8 times less expensive than the conventional treatment plant we have.  

Wetland systems are inexpensive and mechanically simple, but biologically complex. They can perform a variety of treatment reactions with little or no operator input, and operate at high treatment efficiency.   Fresh-water Surface (FWS) Wetlands in 1999 were in these states:

 

 

 

FWS constructed wetlands in 1999 [iv]

 

 

 

Almost all FWS wetlands are in small towns, like Salmon.

 

Here is a 7-fold saving by using a wetland:

 

 

[v]

 

More information is on epa.gov and on votingpeoplehelpingpeople.com.

Other Information

City Council meets at 6:00 PM the first and third Wednesdays in the city center.  The public is invited and has two opportunities to talk with the council.

Media by Cal on Trying to Communicate With Our City Council on January 6, 2010