City Council Meeting February 3, 2010

 

Roger Grenier explains the lack of management of the lagoons.

 



Roger Grenier describes how the absence of management of the lagoons for 22 years has created data scatter in the Discharge Management Reports (DMR).   This data scatter makes it impossible to discern meaningful trends and has caused EPA to send notices of violation to Salmon for DMR violation and for not sending a Quality Assurance Plan and Operations and Management Plan, as the 1987 Permit requires.

Roger recommends: (1) Develop detailed sampling protocol (2) Acquire real-time data acquisition instrumentation and develop and implement a proactive lagoon management plan (3) Develop baseline performance data for a managed lagoon.  Determine if our lagoons as currently configured and properly managed can meet current permit requirements (4) Cal’s feeling is that little or no oxygen is in the bottom strata of the sludge and if we change from surface aerators to bottom aerators, then the bacteria in the sludge can reduce the sludge by about 70% and save the $200,000 estimate to remove the sludge (5) We need to replace the collapsed sections of collector piping anyway.  To some degree this should reduce the dilution of the incoming wastewater and make it easier to obtain the required percent reduction.  (6) It is essential once we establish a performance baseline for a properly managed facility that we only make one change at a time so that we can quantify the effects of that change (7) As soon as we are able to consistently meet our permit requirements further proposed corrective actions can be cancelled or postponed until our economic condition improves.  


Calvin Leman Describes the Solution to the Problems in the Lagoon.




 

I have studied the Salmon, Idaho Discharge Management Reports (DMR) data for ID0020001 from 1988 through 2009 and conclude that the lagoon facility will respond to quantitative measurement and careful management. This means that EPA effluent violations will stop, when we manage the lagoon as I say.

Managing the lagoon means: (1) measuring the pH, temperature, and dissolved oxygen (at least) every three feet from the bottom to the water surface, and (2) adjusting the lagoon aeration, pH, and other variables according to the data we find.  These measurements must be made in the necessary locations of the lagoons so that we can establish a baseline.  As we make these measurements, we will know the depth of the sediment in both lagoons.  From these data, we will be able to devise a satisfactory method of dealing with the sediment.  We may be able to remove the sediment with proper aeration techniques, using current technology.

 

 

 

Chronology of Events

 

October 1, 2007 EPA issues permit to Salmon for ID0020001

(1)  Quality Assurance Plan due Dec 30, 2007

(2)  Operation and Maintenance Plan due March 29, 2008

October 7, 2008 Notice of Violation (120 violations)

(1)  October 16, 2008: Salmon Response to EPA

(2)  November 12, 2008: Salmon Response to EPA

January 21, 2010, Notice of Continuing Violations (367 violations)

(1)  Threatens monetary penalties.

 

 

Salmon City knows of these violations with each monthly Discharge Monitoring Report (DMR), which Salmon submits to EPA. 

Salmon should have reported to EPA about how Salmon was dealing with these violations, when these violations occur.  Salmon does not keep EPA informed about how Salmon is addressing these monthly violations.  Instead, Salmon waits until EPA sends a Notice of Violation.

A way to give the bacteria the oxygen they need:

Clean-Flo Aerators

CLEAN-FLO wastewater treatment methods and results with inversion system for aeration. A system along with beneficial bacteria and enzymes has been successful at reducing BOD, increasing dissolved oxygen, improving water quality, reducing organic sludge and liquefying sludge, eliminating odors, and reducing bacteria levels for irrigation or re-use, reducing blue green algae, duckweed, water meal, wastewater aeration