Chronology of Events in Connection with ID0020001
This permit shall become effective
October 1, 2007
The permittee must provide EPA and Idaho Department of Environmental Quality (IDEQ) with written notification that the Quality Assurance Plan (QAP) has been developed and implemented by December 30, 2007,
The permittee must provide EPA and IDEQ with written notification that the Operation and maintenance (O&M) Plan has been developed and implemented by March 29, 2008.
On
Jun 18, 2008, ID DEQ (EPA asked DEQ to inspect) reported the
Permit violation: need to install a
composite sampler.
On the
October 7, 2008 Notice of Violations,
EPA said they had reviewed the
DMRs from October 2007 to July 2008 and identified effluent limitation
exceedances that constitute more than
120 violations of the Clean Water Act,
On
October 20 and November 12 of 2008,
Salmon replied to this Notice of Violation.
Shanafelt
said that Keller
helped him.
Analysis of DMR Data
October 1, 2007
Permit changed the 65% removal to 85% removal.
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM (NPDES)
DISCHARGE MONITORING REPORT (DMR) at
http://votingpeoplehelpingpeople.com/Jesse_Creek/FOIA_103-10_ID0020001_DMRs[1].pdf
DMR from
01/01/2000 to 11/30/2009
Exceed 65%, then 85%
(changed by
October 1, 2007
Permit.)
% BOD removed must be more than
65%
for month beginning with:
6/1/2001
54
6/1/2002
59
12/01/2002
no value
08/01/2003
no value
09/01/2003
56
12/01/2003
63
04/01/2006
no value
07/01/2006
no value
% removed must be more than
85%
12/1/2008
84
3/1/2009
77
4/1/2009
76
5/1/2009
63
6/1/2009
61
TSS removal
must be less than 65%
03/01/2000
no value
06/01/2000
63
12/01/2000
no value
06/01/2001
60
12/01/2002
no value
08/01/2003
no value
12/01/2003
59
11/01/2004
52
03/01/2006
59
07/01/2006
no value
11/01/2006
45
TSS removal must be
less than 85%
12/01/2007
83
03/01/2008
81
04/01/2008
74
03/01/2009
71
04/01/2009
75
06/01/2009
78
9
No Value
20 less than 65% or 85%,
after:
This permit shall become effective October
1, 2007
29 DMR violations, not
120 violations, as the Notice of Violations states.
Where are the other
violations?
EPA reports DMR violations after
the October 1, 2007 Permit, from 10/07 to 12/09:
|
SALMON, CITY OF |
Query 10/07 thru 12/09 |
||||||||
|
NPDES ID |
Monitoring
Period Start Date |
Violation
Code |
Parameter
Code |
Parameter
Desc |
Limit Value in Std. Units |
DMR Value |
Limit Unit
Short Desc |
Monitoring
Period End Date |
DMR Value
Received Date |
|
ID0020001 |
12/1/2007 |
E90 |
81011 |
Solids,
suspended percent removal |
85. |
83. |
% |
12/31/2007 |
1/22/2008 |
|
|
3/1/2008 |
E90 |
81011 |
Solids,
suspended percent removal |
85. |
81. |
% |
3/31/2008 |
4/14/2008 |
|
|
4/1/2008 |
E90 |
00530 |
Solids, total
suspended |
30. |
31. |
mg/L |
4/30/2008 |
5/12/2008 |
|
|
4/1/2008 |
E90 |
81011 |
Solids,
suspended percent removal |
85. |
74. |
% |
4/30/2008 |
5/12/2008 |
|
|
12/1/2008 |
E90 |
81010 |
BOD, 5-day,
percent removal |
85. |
84. |
% |
12/31/2008 |
1/12/2009 |
|
|
3/1/2009 |
E90 |
81010 |
BOD, 5-day,
percent removal |
85. |
77. |
% |
3/31/2009 |
4/13/2009 |
|
|
3/1/2009 |
E90 |
81011 |
Solids,
suspended percent removal |
85. |
71. |
% |
3/31/2009 |
4/13/2009 |
|
|
4/1/2009 |
E90 |
00530 |
Solids, total
suspended |
45. |
49. |
mg/L |
4/30/2009 |
5/11/2009 |
|
|
4/1/2009 |
E90 |
81010 |
BOD, 5-day,
percent removal |
85. |
78. |
% |
4/30/2009 |
5/11/2009 |
|
|
4/1/2009 |
E90 |
81011 |
Solids,
suspended percent removal |
85. |
75. |
% |
4/30/2009 |
5/11/2009 |
|
|
5/1/2009 |
E90 |
81010 |
BOD, 5-day,
percent removal |
85. |
63. |
% |
5/31/2009 |
6/12/2009 |
|
|
6/1/2009 |
E90 |
81010 |
BOD, 5-day,
percent removal |
85. |
69. |
% |
6/30/2009 |
7/13/2009 |
|
|
6/1/2009 |
E90 |
81011 |
Solids,
suspended percent removal |
85. |
78. |
% |
6/30/2009 |
7/13/2009 |
http://votingpeoplehelpingpeople.com/Jesse_Creek/SalmonReport.xls
Skyler,
Thank you for clarifying Table B-2. That convoluted discussion to stop the treatment equivalent to secondary for this NPDES shows that EPA intends to regulate.
A town like Salmon and other small towns cannot run facultative lagoons as big towns can. They don’t have the population to tax and they don’t have the expertise to run the wastewater facility. In addition to difficulty testing the water, small towns have difficulty completing Quality Assurance Plans and Operations and Maintenance Plans, which the Clean Water Act requires EPA to demand.
Because the BOD does not vary with the influent flow and that violations occur randomly need to be examined. Not EPA, not Idaho DEQ, not you, and not the town of Salmon have addressed this issue. EPA simply took the 95th percentile. This problem has occurred since 1999, as the Fact Sheet, and the data at Water Discharge Permits (PCS) Salmon show.
Keller’s discussion of
constructed wetlands
in
Keller Associates
Draft is inconsistent with EPA documents
Free Water Surface
Wetlands for Wastewater Treatment A technology Assessment
EPA 1999 , Wetlands
in USA ,
Process Design
Manual: Land Treatment of Municipal Wastewater Effluents
EPA 2006, and the documents at
"constructed wetlands
wastewater municipal" (1 to 15 of 1053) . Other
sources are
Arcata CA and other ,
APPLICABILITY OF
CONSTRUCTED WETLANDS FOR ARMY INSTALLATIONS , and Building
Engineered Wetlands to Reduce Costs
Like the EPA documents, monographs such as Treatment Wetlands, 2009, 2nd edition, Kadlec and Wallace show that constructed wetlands can be a solution to wastewater treatment, especially for small towns where land is not expensive.
With constructed wetlands, then irrigation, the regulation by EPA stops and regulation by Idaho DEQ begins: 58.01.17 - RULES FOR THE RECLAMATION AND REUSE OF MUNICIPAL AND INDUSTRIAL WASTEWATER and IDAPA 58 TITLE 01 CHAPTER 16 58.01.16 - WASTEWATER RULES . Just downstream of the effluent outlet, farmers pump water from the Salmon River for irrigation. If those farmers use treated wastewater, that irrigation water will have the nitrogen and phosphorus in the water, which they now add in fertilizer.
Sawtooth Fish Hatchery: Sawtooth Cleaning Waste Ponds in Stanley, Idaho makes a park out of their constructed wetland. Hemet/San Jacinto Multipurpose Constructed Wetlands Project uses the water in a variety of ways.
Keller Associates may create a new market, help waterways, and help small towns, if you were successful building constructed wetlands.
If Keller Associates has not studied constructed wetland technology and has not built a constructed wetland, it is not a surprise that your 90% draft found constructed wetlands an unreasonable solution for Salmon’s wastewater. I could find no data to support the hypothesis that your proposed solution will stop the violations, which have occurred following other repairs, in all the data we have. If we don’t put water into the river, the violations do stop.
Sincerely,
Cal
PS
If Salmon continues to violate the provisions
of the
Clean Water Act, EPA may take action. If Overacker on the west
side of the river were to use the effluent, the technology in
Process Design Manual: Land Treatment of
Municipal Wastewater Effluents
EPA 2006 may apply. Also useful is
Wastewater Technology
Fact Sheet Free Water Surface Wetlands EPA 2000
Mr. Leman,
We apologize for the delay in the response.
With regard to the Treatment Equivalent to Secondary Criteria evaluation in the NPDES Fact Sheet, the table you referenced is analyzing the reported values of discharged TSS and BOD for the Salmon Wastewater System and comparing to the criteria for classification as Treatment Equivalent to Secondary Treatment. This is a classification that would place the system under different discharge limitations than the current discharge permit. As outlined in the fact sheet, the Salmon system does not meet criterion 1. We would concur that the reading is a bit confusing, but the result is that the Salmon system is not eligible for this classification. Further clarification may be gained by contacting the EPA NPDES staff.
We do not have any monitoring data for most of the period from 1987 to 2003. We have monitoring data since 2003 that was used in our analysis for the WWFPS.
The comments cited regarding high flow are in regard to the I/I problem that has been identified in the WWFPS and in previous assessments of the system. It is not a new problem for the system.
EPA conducts site inspections during NPDES permit renewal as well as reviewing DMR reports.
The City may have records of the design specifications for the treatment plant construction in 1986-87. They do have copies of the construction plans of which we were provided copies. We are not aware of any test data beyond the monitoring reports submitted to EPA.
We hope that this information is helpful to you. Thank you for your interest in the Salmon wastewater study.
Respectfully,
Skyler Allen, EIT
Keller Associates Inc.
From:
Calvin Leman [mailto:calvin_leman2001@yahoo.com]
Sent:
Sunday, December 27, 2009 12:12 PM
To: Skyler
Allen
Cc: Calvin
B Leman
Subject:
Re: Salmon 90% Draft of WWFPS
Skyler,
Thank you for offering to answer questions. Can you help us?
Table B2 on page 32 of the Fact Sheet (http://yosemite.epa.gov/r10/water.nsf/NPDES+Permits/Current+ID1319/$FILE/ID0020001+FS.pdf ) says: In column 2, To meet Treatment Equivalent to Secondary Criteria (1) and (3), BOD Mo. Avg. (mg/l) [Be greater than 30 mg/l. The table shows the wastewater facility 95th percentile is 17.6 mg/l.]
In column 3, the BOD Wk. Avg. (mg/l) must be greater than 45 mg/l and it is 26.4 mg/l.
What do these data mean? We want the BOD to be low, but EPA says it must be high?
Is EPA saying that the inflow is too dilute in wastewater BOD substances?
|
Calculation |
95th percentile = 17.6 mg/l |
95th percentile = 25.1 mg/l |
95th percentile = 30.6 mg/l |
95th percentile = 36.2 mg/l |
5th percentile = 65.8% |
|
To meet Treatment Equivalent to Secondary Criteria (1) and (3) |
Be greater than 30 mg/l |
1.5 times the monthly calculation (17.6 mg/l x 1.5 = 26.4 mg/l) must be greater than 45 mg/l |
Be greater than 30 mg/l |
1.5 times the monthly calculation (30.6 mg/l x 1.5 = 46 mg/l) must be greater than 45 mg/l |
Be greater than 65% |
|
Does Data meet Criteria (1) and (3) |
NO |
NO |
YES |
YES |
YES |
Do you have data from the start of the treatment facility, from 1987 to 2004?
EPA has data from 2004 to 2009 at http://www.epa-echo.gov/cgi-bin/effluentsquery.cgi?permit=ID0020001&pipe=all¶mtr=all&monlocn=effonly&period=all&outt=effonly&date=20061001%7C20090930&charts=viol&tool=echo but not from 1987 to 2004. That data is not at http://oaspub.epa.gov/enviro/fii_query_dtl.disp_program_facility?p_registry_id=110011271685 either.
In 2001 and in 2004, EPA reported that the flow to the wastewater facility was too high http://iaspub.epa.gov/reports/rwservlet?cwns2004key+report=ffs.rdf+destype=cache+outputimageformat=gif+desformat=pdf+p_af_nbr=16000174001
User: Dottie Bayo Date: 12-16-2004 13:10:52
Comment by Alan Stanford 12/9/04
Flow to population still very high due to very high
I/I.
User: Nancy Bowser Date: 09-13-2001 11:21:11
The flow to population ratio is not within the
50-150 gpcd because the collection system for the
City of Salmon is old and has extremely high I/I.
The treatment facility was oversized to accommodate
the excessive I/I.
Was EPA here in Salmon then or do you suppose they took data from reports that Salmon sent to EPA?
Where can we find the specifications and test data of the original wastewater facility?
EPA was at the wastewater facility in 1987 and in 2007, according to the Fact Report. Those data from 1987 to 2004 will show if the wastewater facility was in compliance then.
Sincerely,
Cal
Calvin Leman
305 Washington Street
Salmon ,
ID 83467
208-756-4104 phone or fax
http://votingpeoplehelpingpeople.com/
Voting People Helping People is registered
with the IRS as an Educational and Scientific
501(C)(3)foundation.
From:
Skyler Allen <sallen@Kellerassociates.com>
To:
"calvin_leman2001@yahoo.com"
<calvin_leman2001@yahoo.com>
Cc:
James Mullen <jmullen@Kellerassociates.com>
Sent:
Tue, December 22, 2009 9:02:00 AM
Subject:
Salmon 90% Draft of WWFPS
Mr. Leman,
The 2007 Salmon wastewater discharge permit can be found at the following location.
http://yosemite.epa.gov/r10/water.nsf/NPDES+Permits/Current+ID1319/$FILE/ID0020001+FP.pdf
If you have any difficulty, I was able to locate with a search engine with the string “NPDES Permit #IID-002000-1”.
Please call or email with additional questions.
Respectfully,
Skyler D. Allen, E.I.T.
Keller Associates, Inc.
305 N. 3rd Avenue , Suite A
Pocatello , ID 83201
(208) 238-2146
(208) 238-2162 - Fax
We thank you for helping with our wastewater issue. You are helping ordinary people. We need the help of an engineer, who understands the municipal wastewater solutions that the EPA has published. Keller Associates does not have that engineer.
Your help led to Toni Hardesty getting the attention of Greg Eager, who sent us the Notice of Violation that EPA sent to Salmon City in 2008.
Salmon City has done nothing about this Notice of Violation. We ordinary people expect our city officials to obey the law. This violation notice could result in a penalty, which our taxes have to pay, because the city did not obey the law.
The Citizens Advisory Committee for the wastewater issue was half city employees.
Those serving on the Waste Water Citizen’s Advisory Council are: Sandra Barrett, Dave Blauser, Harlan Finnemore, Steve Gould, Ken Gutzman, Leo Marshall, Dan Maiyo, William Teuscher, Harry Shanafelt, Mickey Verbeck, Bob Wiederrick, Luke Prange and George Ambrose
City Employees
That committee did not reach consensus on fixing the wastewater facility as Keller Associates recommends, according to a non-city-employee on that committee. The city council did no analysis of the wastewater issue. They simply took the advice of Keller, negotiated for less work and less money ($8 million to $4 million) and are going to pass a wastewater tax increase to pay the $4 million. Councilman Jim Kleusner told me that the council takes whatever advice city administrator, George Ambrose, recommends. "That's what we pay him for," Kleusner said.
At the public meeting on this wastewater issue, two people opposed, zero people were neutral, and zero people were in favor of the ordinance to increase our taxes to fix the wastewater system as Keller recommends.
At the January 6 Salmon City Council meeting, I asked the council to explore a constructed wetland solution, and gave the council a written copy of this analysis. Councilman Ken Gutzman told me they were not going to do anything for two years, apparently because he thinks the current EPA permit is good enough for now. Mayor John Miller told me that the land for a wetland would cost too much. Councilman Leo Marshall asked what credential I had for criticizing their plan. I said PhD biochemistry. The council voted unanimously in favor of the second reading of the wastewater tax increase, to pay Keller Associates the $4 million estimate to fix the lagoon system we have now.
Neither the city council nor Keller Associates has studied the EPA documents. For more than 35 years, EPA has been publishing documents, free to the public, about constructed wetlands as a way to use wastewater that is ½ to 1/8 the cost of facultative lagoons, which we are using now. Treated wastewater can go to irrigation and not into the river. EPA does not regulate this method of using wastewater. The Notice of Violation says Salmon has been out of compliance 120 times.
I describe some of this EPA help and a solution for Salmon wastewater at:
http://votingpeoplehelpingpeople.com/Jesse_Creek/Media_Cal_Wastewater_1.html
A 2006 EPA document (Process Design Manual: Land Treatment of Municipal Wastewater), which Salmon could use, is a process that is even more simple and less expensive than a constructed wetland.
Lenore, this is just Cal talking. This wastewater issue can apply to all small towns with a wastewater problem. What is missing is an engineer to help with these solutions. Engineering firms make less money with these wetland solutions and find reasons (like Keller did) that they won’t work. None of these reasons is accurate.
Maybe the legislature or Idaho DEQ can identify experts in these wastewater solutions, who could help small towns with our wastewater problems.
Thank you for helping,
Cal
Cal…I’d definitely be talking about details of wastewater treatment I’m not versed in, so I believe Willie will be the best person to answer those questions about BOD and the desired levels for effective treatment.
DEQ gets copied on all the DMRs the city submits, but we either archive them or dispose of them after the approximate five year mark. But, when EPA drafts new permits, they rely primarily on the DMR data as well as any flow data into the plant and the seasonal flows in the Salmon River . If you have specific questions about how EPA drafted the permit, the permit writer was Kai Shum (206.553.0060). He might have his administrative record which would outline his methodology and data used.
Looking in our files, it appears Willie did an inspection in 2008 and I didn’t see when EPA last conducted an on-site inspection.
I think Willie’s also out for the holiday, but he’ll get back to you when he does get in. Please let me know we can be of assistance in Willie’s absence. Thanks
Troy Saffle
Regional Water Quality Manager
Idaho Department of Environmental Quality
900 N. Skyline, Suite B
Idaho Falls, Idaho 83402
troy.saffle@deq.idaho.gov
208.528.2650
208.521.5913 (c)
Table B2 on page 32 of the Fact Sheet (http://yosemite.epa.gov/r10/water.nsf/NPDES+Permits/Current+ID1319/$FILE/ID0020001+FS.pdf ) says: In column 2, To meet Treatment Equivalent to Secondary Criteria (1) and (3), BOD Mo. Avg. (mg/l) [Be greater than 30 mg/l. The table shows the wastewater facility 95th percentile is 17.6 mg/l.]
In column 3, the BOD Wk. Avg. (mg/l) must be greater than 45 mg/l and it is 26.4 mg/l.
What do these data mean? We want the BOD to be low, but EPA says it must be high?
Is EPA saying that the inflow is too dilute in wastewater BOD substances?
|
Calculation |
95th percentile = 17.6 mg/l |
95th percentile = 25.1 mg/l |
95th percentile = 30.6 mg/l |
95th percentile = 36.2 mg/l |
5th percentile = 65.8% |
|
To meet Treatment Equivalent to Secondary Criteria (1) and (3) |
Be greater than 30 mg/l |
1.5 times the monthly calculation (17.6 mg/l x 1.5 = 26.4 mg/l) must be greater than 45 mg/l |
Be greater than 30 mg/l |
1.5 times the monthly calculation (30.6 mg/l x 1.5 = 46 mg/l) must be greater than 45 mg/l |
Be greater than 65% |
|
Does Data meet Criteria (1) and (3) |
NO |
NO |
YES |
YES |
YES |
Do your records show when EPA was here or when IDEQ was in Salmon, from 1987 to 2009?
EPA has data from 2004 to 2009 at http://www.epa-echo.gov/cgi-bin/effluentsquery.cgi?permit=ID0020001&pipe=all¶mtr=all&monlocn=effonly&period=all&outt=effonly&date=20061001%7C20090930&charts=viol&tool=echo but not from 1987 to 2004. That data is not at http://oaspub.epa.gov/enviro/fii_query_dtl.disp_program_facility?p_registry_id=110011271685 either.
In 2001 and in 2004, EPA reported that the flow to the wastewater facility was too high http://iaspub.epa.gov/reports/rwservlet?cwns2004key+report=ffs.rdf+destype=cache+outputimageformat=gif+desformat=pdf+p_af_nbr=16000174001
User: Dottie Bayo Date: 12-16-2004 13:10:52
Comment by
Alan Stanford
12/9/04
Flow to population still very high due to very high I/I.
User: Nancy Bowser Date: 09-13-2001 11:21:11
The flow to population ratio is not within the 50-150 gpcd because
the collection system for the City of Salmon is old and has
extremely high I/I. The treatment facility was oversized to
accommodate the excessive I/I.
Was EPA here in Salmon in 2001 and 2004 or do you suppose they took data from reports that Salmon sent to EPA or to IDEQ? Does EPA keep all the NPDES permits and reports and IDEQ keeps the last 5 years?
Neither Eva DeMaria at EPA in Seattle (206.553.1970) nor any of her colleages is in during the holidays. When they do return, we will try to find the specifications and test data of the original wastewater facility and from 1987 to 2004.
EPA was at the wastewater facility in 1987 and in 2007, according to the Fact Report. Those data from 1987 to 2004 will show if the wastewater facility was in compliance then.
Sincerely,
Cal
Calvin, this office maintains DMRs for five years and they are available in PDF. All you’d need to do is please fill out the public records request found here: http://www.deq.idaho.gov/public/public_records.cfm and we can get them sent to you in a format you desire. The older DMRs will need to come from EPA. I didn’t find them online, however, contacting Eva DeMaria at EPA in Seattle (206.553.1970) should put you on a path to get them.
I do not find the Operations and Maintenance Plan from 2008 in our records so I assume it was never submitted to us.
All of our NPDES files are open to examination, so if you have a specific document you want, we can get it to you. Alternatively, you are more than welcome to come to our office and review the entire set of files for the facility.
I assume you’ve already got the permit, but it can be found here: http://yosemite.epa.gov/r10/water.nsf/NPDES+Permits/Current+ID1319/$FILE/ID0020001+FP.pdf
Willie Teuscher, in our office, is the engineer who is most familiar with the details of the system, and could answer specific questions. Please let me know if you have difficulty viewing the public records form or other information.
Thanks
Troy Saffle
Regional Water Quality Manager
Idaho Department of Environmental Quality
900 N. Skyline, Suite B
Idaho Falls, Idaho 83402
troy.saffle@deq.idaho.gov
208.528.2650
208.521.5913 (c)
From:
Calvin Leman [mailto:calvin_leman2001@yahoo.com]
Sent:
Saturday, December 26, 2009 10:11 AM
To: Troy
Saffle
Subject:
Permit No.: ID-002000-1
Troy,
Are the
(1) Permit No.: ID-002000-1 Discharge Monitoring Reports DMRs,
(2) Operation and Maintenance Plan (due March 29, 2008),
(3) and other data described in Schedule of Submissions of the August 21, 2007 Authorization to Discharge Under the National Pollutant Discharge Elimination System available on the Internet or elsewhere? We seek data from April 2, 1987 to the present.
We seek adequate data to analyze the performance of the treatment facility (from its first report on April 2, 1987 to the current report), which is authorized to discharge from a facility located in Salmon, Idaho , at the following location(s): Outfall Receiving Water Latitude Longitude, 001 Salmon River 450 11’ 32.5” N 1130 53’ 10.7” W
Our current analysis of the data in Table B-2 from DMR submitted, which is in the Fact Sheet (page 31) for ID-002000-1, gives us reason for concern. The 95 Percentile measurement is on data, which is random and is not what we expect from 2001 to 2007.
Sincerely,
Calvin Leman
Calvin Leman
305 Washington Street
Salmon ,
ID 83467
208-756-4104 phone or fax
http://votingpeoplehelpingpeople.com/
Voting People Helping People is registered
with the IRS as an Educational and Scientific
501(C)(3)foundation.
Calvin,
We appreciate your interest in this project. To effectively respond to your questions we are consulting with IDEQ for additional clarification on some of the points to make a more complete and clear response. We will get in touch with you again after the new year regarding these inquiries. Thank you.
Sincerely,
Skyler Allen, EIT
Skyler,
Thank you for offering to answer questions. Can you help us?
Table B2 on page 32 of the Fact Sheet (http://yosemite.epa.gov/r10/water.nsf/NPDES+Permits/Current+ID1319/$FILE/ID0020001+FS.pdf ) says: In column 2, To meet Treatment Equivalent to Secondary Criteria (1) and (3), BOD Mo. Avg. (mg/l) [Be greater than 30 mg/l. The table shows the wastewater facility 95th percentile is 17.6 mg/l.]
In column 3, the BOD Wk. Avg. (mg/l) must be greater than 45 mg/l and it is 26.4 mg/l.
What do these data mean? We want the BOD to be low, but EPA says it must be high?
Is EPA saying that the inflow is too dilute in wastewater BOD substances?
|
Calculation |
95th percentile = 17.6 mg/l |
95th percentile = 25.1 mg/l |
95th percentile = 30.6 mg/l |
95th percentile = 36.2 mg/l |
5th percentile = 65.8% |
|
To meet Treatment Equivalent to Secondary Criteria (1) and (3) |
Be greater than 30 mg/l |
1.5 times the monthly calculation (17.6 mg/l x 1.5 = 26.4 mg/l) must be greater than 45 mg/l |
Be greater than 30 mg/l |
1.5 times the monthly calculation (30.6 mg/l x 1.5 = 46 mg/l) must be greater than 45 mg/l |
Be greater than 65% |
|
Does Data meet Criteria (1) and (3) |
NO |
NO |
YES |
YES |
YES |
Do you have data from the start of the treatment facility, from 1987 to 2004?
EPA has data from 2004 to 2009 at http://www.epa-echo.gov/cgi-bin/effluentsquery.cgi?permit=ID0020001&pipe=all¶mtr=all&monlocn=effonly&period=all&outt=effonly&date=20061001%7C20090930&charts=viol&tool=echo but not from 1987 to 2004. That data is not at http://oaspub.epa.gov/enviro/fii_query_dtl.disp_program_facility?p_registry_id=110011271685 either.
In 2001 and in 2004, EPA reported that the flow to the wastewater facility was too high http://iaspub.epa.gov/reports/rwservlet?cwns2004key+report=ffs.rdf+destype=cache+outputimageformat=gif+desformat=pdf+p_af_nbr=16000174001
User: Dottie Bayo Date: 12-16-2004 13:10:52
Comment by Alan
Stanford 12/9/04
Flow to population still very high due to very high I/I.
User: Nancy Bowser Date: 09-13-2001 11:21:11
The flow to population ratio is not within the 50-150 gpcd because
the collection system for the City of
Salmon is old and has extremely high I/I. The treatment
facility was oversized to accommodate the excessive I/I.
Was EPA here in Salmon then or do you suppose they took data from reports that Salmon sent to EPA?
Where can we find the specifications and test data of the original wastewater facility?
EPA was at the wastewater facility in 1987 and in 2007, according to the Fact Report. Those data from 1987 to 2004 will show if the wastewater facility was in compliance then.
Sincerely,
Cal
Mr. Leman,
The 2007 Salmon wastewater discharge permit can be found at the following location.
http://yosemite.epa.gov/r10/water.nsf/NPDES+Permits/Current+ID1319/$FILE/ID0020001+FP.pdf
If you have any difficulty, I was able to locate with a search engine with the string “NPDES Permit #IID-002000-1”.
Please call or email with additional questions.
Respectfully,
Skyler D. Allen, E.I.T.
Keller Associates, Inc.
305 N. 3rd Avenue , Suite A
Pocatello , ID 83201
(208) 238-2146
(208) 238-2162 - Fax
Jim,
This is the idea I was talking about last night. Apparently the town council did not ask you to pursue a holistic solution. I assume that they asked you to react to the EPA. As a contractor, you can offer the best solution to the environment, economy, and energy problems with this project. Then show the town council how to do it.
Rather than reacting to EPA, we should be a model that EPA uses to show others how to solve the economy, energy, and environment problems in one step.
(6) Cattails (Typha ssp.) may be an appropriate species, because it can produce ethanol at higher rates per acre than corn or sugar beets. This can be part of the energy solution.
Hello Cal,
I have just completed a Cattail Evaluation Study for Otero County New Mexico. We collected data and demonstrated proof-of-concept for cattail growing as a biomass field crop in effluent saturated soil that is NOT a constant moisture concentration. We have show between 20 and 32 % nitrate reduction through cattail stands, and we have made cattail beer for distilling into fuel ethanol up to 13% which we believe will be elevated within commercial operation. During the next several months I plan to write a book highlighting the study and cattails to ethanol proof-of-concept. The Otero County Report is about 150 pages long including photographic and laboratory documentation.
Wastewater engineers that use cattails to remediate effluent have EPA approved methodologies. However, we are the first to use a saturated field from effluent wastewater. We will demonstrate cattail feedstock for fuel when we have a production quantity. Moreover, I received a report that one town is making their own fuel ethanol from a local feedstock (not cattails) that is mixed 50/ 50 with gasoline for police and city vehicles.
I will be posting more on all of this in the near future. Please stay in touch.
Best wishes,
Peggy
From:
Calvin Leman [mailto: calvin_leman2001@yahoo.com ]
Sent:
Thursday, December 10, 2009 9:51 AM
To: Peggy
Korth
Subject:
now in Salmon Idaho
Peggy,
we see Salmon about to change the waste water treatment here.
Do you know of a town that is using cattails for fuel? I can bring it to the attention of folks here.
Cal
Peggy G. Korth, President
40 Sun Valley Dr. , Spring Branch TX 78070
Cell:
512 757-4499,
830 885-4823; FAX
830 885-4827
Email:
rpk@gvtc.com
September
25, 2008
Calvin Leman
305 Washington Street
Salmon , ID 83467
208-756-4104 phone or fax
http://votingpeoplehelpingpeople.com/
Voting People Helping People is registered
with the IRS as an Educational and Scientific
501(C)(3)foundation.
Mr. Leman,
The 2007 Salmon wastewater discharge permit can be found at the following location.
http://yosemite.epa.gov/r10/water.nsf/NPDES+Permits/Current+ID1319/$FILE/ID0020001+FP.pdf
If you have any difficulty, I was able to locate with a search engine with the string “NPDES Permit #IID-002000-1”.
Please call or email with additional questions.
Respectfully,
Skyler D. Allen, E.I.T.
Keller Associates, Inc.
305 N. 3rd Avenue , Suite A
Pocatello , ID 83201
(208) 238-2146
(208) 238-2162 - Fax
http://lemhiweb.com/blog_view.php?logid=4&id=77
| Posted by - Gina Knudson |
| Last Updated on - Mon Dec 21, 2009 23:28:29 |
I attended last Wednesday's City Council meeting after seeing a legal notice in the paper announcing a $21 rate hike in our sewer fees. I knew the City had been reviewing upgrades to the wastewater treatment plant but I was alarmed at the steep increase. I had recently read of Recovery Act projects that helped communities like ours improve infrastructure so I decided to attend the public hearing and urge the council to make sure they had exhausted other financial options before imposing a $65 base fee on customers. The hearing started at 6:15 p.m. sharp, as advertised in the legal notice. Mayor John Miller asked for public comment in favor of the proposal, neutral comments, or opposed to the proposal. He laid out the ground rules. "This isn't a Q and A session," he told us. I reminded him of this when the first gentleman started providing comment and Mayor Miller interrupted him. As I gave my comments, I actually had to ask Mayor Miller to stop interrupting me and to stop pointing his finger at me as he countered my testimony. Once I finished my comments, Mayor Miller lectured me about the errors in my testimony and scolded me for not attending an open house meeting with the engineering firm contracted to help the City with its wastewater treatment study. The meeting started at 5 p.m., a fact not posted in the legal notice but listed in an article elsewhere in the paper. Mayor Miller also admonished me for not attending the wastewater treatment plant advisory committee meetings or the finance committee meetings where these issues were discussed. The reason public hearings are required in certain instances, such as fee increases that are greater than 105% of the existing rate, is so decision makers have a chance to hear and consider input from the public, whether or not they were involved in the issue previously. I was appalled at the treatment I received during this public hearing. I have attended many public meetings, listened to hundreds of public comments, and provided them myself occasionally. I assure you that the arrogance exhibited by this elected official ranks in a league of its own. I would think twice before asking my neighbors and fellow citizens to subject themselves to similar rudeness and disrespect. Something that hits the pocketbook so directly like a $21 increase to a monthly bill usually gets people interested enough to go to a public meeting about the subject. That evening I was surprised that only three of us showed up to say anything. After my experience, I am not so surprised. The law requires the City to provide a public hearing. The law, however, does not mandate courtesy. The return to civility is something voters will have to impose. |
From blog at http://lemhiweb.com/blog_view.php?logid=5&id=77
Gina,
The information at http://votingpeoplehelpingpeople.com/Jesse_Creek/Municipal%20Wastewater.html shows Free Water Surface Wetlands for Wastewater - an average service cost improvement of 2.1-fold to 8-fold is found. And other information. $4,704,000 is the cost for this current Salmon idea, according to http://lmshumate.com/article.php?article_id=1691 When I asked Jim Mullen (vp Keller Associates) who or what he consulted at EPA, he admitted that he had not. You may remember during the meeting he told me that he had. I told Jim Mullen and George Ambrose that we need to stop putting water into the river. Ambrose seemed to understand, when I showed them on Keller’s photo of the land next to the treatment plant.
EPA makes a convincing case for free-water surface wetlands, as a solution for towns that have enough land to put a free-water surface wetland. All of the epa and other articles say the cost is less than conventional treatment (capital investment and operation) and will work in northern climate, including Canada, according to ConstructedWetlands.org and Wetland Treatment Systems.
Keller did not consider this, apparently because they do not know about it. Apparently neither the council nor the citizen committee directed Keller to consider what epa recommends.
Page 1-11 of Free Water Surface Wetlands for Wastewater Treatment A technology Assessment EPA 1999 shows a map of USA where free water surface wetlands are. None are in Idaho.
I am getting in touch with consultiing engineers:
JUB Engineers
MWH
Murray, Smith & Associates, Inc.
Carollo
HDR
All have offices in Boise.
Calvin.
The City of Salmon does not report data to me. I will forward your request to our Engineering Group.
Thanks,
Steve Heaton
From:
Calvin Leman [mailto:calvin_leman2001@yahoo.com]
Sent:
Thursday, December 24, 2009 8:48 AM
To: Steven
Heaton
Subject:
Salmon
Steve,
Does Salmon submit the city EPA Permit No.: ID-002000-1 reports to you?
Calvin Leman
Calvin, this office maintains DMRs for five years and they are available in PDF. All you’d need to do is please fill out the public records request found here: http://www.deq.idaho.gov/public/public_records.cfm and we can get them sent to you in a format you desire. The older DMRs will need to come from EPA. I didn’t find them online, however, contacting Eva DeMaria at EPA in Seattle (206.553.1970) should put you on a path to get them.
I do not find the Operations and Maintenance Plan from 2008 in our records so I assume it was never submitted to us.
All of our NPDES files are open to examination, so if you have a specific document you want, we can get it to you. Alternatively, you are more than welcome to come to our office and review the entire set of files for the facility.
I assume you’ve already got the permit, but it can be found here: http://yosemite.epa.gov/r10/water.nsf/NPDES+Permits/Current+ID1319/$FILE/ID0020001+FP.pdf
Willie Teuscher, in our office, is the engineer who is most familiar with the details of the system, and could answer specific questions. Please let me know if you have difficulty viewing the public records form or other information.
Thanks
Troy Saffle
Regional Water Quality Manager
Idaho Department of Environmental Quality
900 N. Skyline, Suite B
Idaho Falls, Idaho 83402
troy.saffle@deq.idaho.gov
208.528.2650
208.521.5913 (c)
From:
Calvin Leman [mailto:calvin_leman2001@yahoo.com]
Sent:
Saturday, December 26, 2009 10:11 AM
To: Troy
Saffle
Subject:
Permit No.: ID-002000-1
Troy,
Are the
(1) Permit No.: ID-002000-1 Discharge Monitoring Reports DMRs,
(2) Operation and Maintenance Plan (due March 29, 2008),
(3) and other data described in Schedule of Submissions of the August 21, 2007 Authorization to Discharge Under the National Pollutant Discharge Elimination System available on the Internet or elsewhere? We seek data from April 2, 1987 to the present.
We seek adequate data to analyze the performance of the treatment facility (from its first report on April 2, 1987 to the current report), which is authorized to discharge from a facility located in Salmon, Idaho , at the following location(s): Outfall Receiving Water Latitude Longitude, 001 Salmon River 450 11’ 32.5” N 1130 53’ 10.7” W
Our current analysis of the data in Table B-2 from DMR submitted, which is in the Fact Sheet (page 31) for ID-002000-1, gives us reason for concern. The 95 Percentile measurement is on data, which is random and is not what we expect from 2001 to 2007.
Sincerely,
Calvin Leman
To access your question from our support site, click here.
| Subject | |
| Where can we find the tests for Permit No.: ID-002000-1 and the data produced... | |
| Discussion Thread | |
| Response (Public Access) | 12/28/2009 12:02 PM |
| Thank you for your inquiry to
the EPA Web site. Your request has been received by the
Headquarters
Public Access
Service, a contractor operated reference and
referral
service. The Public Access Service is a library reference and referral service and cannot provide scientific guidance, regulatory guidance or applicability determinations. We are providing the information and referrals/contacts listed below so that you can seek that support directly from Agency program staff or other information services that can provide that assistance. The Fact Sheet for the Draft NPDES Permit for the City of Salmon, Idaho may be viewed at: http://yosemite.epa.gov/r10/water.nsf/NPDES+Permits/Current+ID1319/$FILE/ID0020001+FS.pdf (PDF, 36 pp) It lists the following technical contact: Kai Shum email: Shum.Kai@epa.gov Phone: 206-553-0060 800-424-4372 (within Alaska, Idaho, Oregon, and Washington) Please inquire with this contact person regarding any technical questions you may have. You may also call the EPA Region 10 NPDES Permits Unit at 206-553-0775. The permit itself may be viewed at: http://yosemite.epa.gov/r10/water.nsf/NPDES+Permits/Current+ID1319/$FILE/ID0020001+FP.pdf (PDF, 26 pp) You may also be interested in the following frequently asked question. Answer Title: Where can I find EPA Test Methods? Answer Link: http://publicaccess.custhelp.com/cgi-bin/publicaccess.cfg/php/enduser/std_adp.php?p_faqid=222&p_created=1087843272 Thank you. ***************** Public Access Service, operated by ASRC Management Services EPA Headquarters Ariel Rios Building 1200 Pennsylvania Avenue, N.W. (3404T) Washington, DC 20460 Fax: (202) 566-0574 ***************** |
|
| Customer | 12/26/2009 01:17 PM |
| Where can we find the tests for Permit No.: ID-002000-1 and the data produced by these tests? The NPDES and Fact Sheet show values for BOD, TSS, etc. but have no information on how the tests are done. The data on BOD may not be valid., | |