ID 0020001 National Pollutant Discharge Elimination System
(NPDES) Permit, Salmon, Idaho

Executive Summary
Getting into Compliance and Staying in Compliance
A Plan of Management
Calvin B. Leman, PhD
March 15, 2010
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 and violations because of failure to submit
required documents to EPA will stop.
We must manage the lagoons.
The organic load to these lagoons is 100 times less than many aerated lagoons.
We are really managing ponds.
Managing the lagoons 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.
Constant monitoring at the effluent and at the influent will simplify our work.
All of the measurement data will transfer to a computer for analysis.
All of this instrumentation is less than $20,000, including a microscope
to see what is in the effluent.
We can explore how to best produce the DMR reports.
The measurements that I have discussed so far are only for management of
the lagoon. We will know what the
effluent report is all the time and will make adjustments to the lagoon to meet
better than 85% removal of TSS and BOD, and to meet all the other parameter
values that EPA wants now and may want later.
Procedure to Test the Lagoons[i]
Purpose is to obtain a baseline of operation[ii],
which will guide the next process.[iii]
Characterize the Current DMR Procedure
Obtain a report of aerator operation: which aerators are run when and how long
each is run. Plot this procedure on
a diagram of the lagoons. Obtain
the performance characteristics of each aerator: horse power (for cost analysis)
and oxygen dissolved in water because of each aerator.
Obtain the current procedure and process of sampling and testing for the
DMR reports.[iv]
Characterize the Current Lagoon
Measure these five variables (pH, dissolved oxygen, temperature, turbidity, and
sludge-blanket depth[v])
from bottom to surface, at 100-foot intervals diagonally across the lagoon from
SW to NE. Measure these five
variables at the influent and at the effluent.
Add to these data the sampling for the DMR measurements.
South lagoon is 695 feet diagonally; north lagoon is 786 feet diagonally.[vi]
Plot the location of each sample-point and the location of each aerator.
Mark each location in the lagoons so you can return to it again, to make
the next measurement. Take a sample
midway down the sloping side of the lagoon. This test should show the efficiency
of the aerators and guide the next process. A dissolved oxygen concentration
less than 1 mg/l anywhere in the lagoon must be prevented.[vii]
Test again 24 hours later, making no
change in operation. Repeat this
procedure until acceptable accuracy and precision is obtained.[viii]
Aerator Study
Choose the aerator that has run the longest.
At 5-foot intervals from the aerator, measure the five variables from
surface to bottom. Measure these
perpendicular from the aerator at three places (each 120 degrees), to measure
any directional influence of the aerator.
Do these measurements, until no unexpected change in concentration of
these variables occurs. From these
data, plot the effective area and depth that the aerator affects.
From this study, we can calculate the effect of the aerators on the
wastewater processing. This will
guide the management of these aerators and guide any change in these aerators.
Effluent and Other Visual Study
Using a 40x1600 microscope, observe the effluent.
Identify the species you see at regular time intervals.
Use this visual-analysis process to help characterize any sample from
anywhere in the wastewater system and in the management of the lagoon.
For example, this visual analysis can help identify the living species in
the lagoon. It can alert, for
example, the presence of blue-green algae, before these algae become a problem.
[ix]
SUMMARY
I will accomplish the following:
1. I will provide management direction to stabilize the lagoons so they will
operate at a high efficiency and the effluent will consistently meet the
requirements of our 2007 EPA discharge permit.
2. I will develop and write an operations and management plan which includes how
the lagoons operate, testing requirements, sampling, acceptable levels of ph,
oxygen, etc. and how to correct activities occurring in the lagoons that need to
be corrected in order to allow maximum performance.
3. I will develop a quality assurance plan that will be acceptable to the EPA
and IDEQ.
4. I will recommend any purchases of the necessary equipment to operate and
manage the lagoons for optimum performance.
5. I will train the personnel, selected by the City, how to manage and operate
the sewer lagoons to comply with our EPA discharge permits.
6. I will make myself available to answer any questions that might arise
regarding the operation of the lagoons once my work has been completed. Any
additional work required would be billed hourly.
March
15, 2010 Workshop Documents[x]
[i]
This procedure is to collect data
that will guide the development of a Quality Assurance Plan and of an
Operations and Management Plan for ID0020001.
These plans can be developed when the lagoon is stabilized, the
management direction is established, and the DMR reports are well within
compliance. To
meet EPA requirements, I will prepare an Operation and Maintenance Plan
now so we can send notice to EPA now, in response to the January 10,
2010 Notice of Continuing Noncompliance.
I will make sure that the Quality Assurance Plan is in good
order. When we develop the
final direction for the Quality Assurance Plan and for the Operation and
Maintenance Plan, we can notify EPA and Idaho DEQ of these updates.
[ii]
Analysis of the DMR data for
ID0020001 from 1988 to 2009 shows the need for this baseline data.
The scatter of these data makes management of the lagoon
difficult. Even the time of
year that violations occur is difficult to analyze.
The data shown below is from the excel file at:
http://votingpeoplehelpingpeople.com/Jesse_Creek/Tools.html
EPA provided the data from 2000
to 2009. Salmon City
provided the data from 1988 to 2000.

Dairy closed
in 2000. Variability
decreased in 2000, because of less carbon loading of lagoon.
Error in sampling and management is evident over the 21-year
period.
[iii]
I can consult on these procedures for $3500 per month and a yearly
budget of $50,000. If the city
wishes that I help a willing and capable city employee to do this work,
my contract with the city will end sooner.
An employee, who is thrilled with problem solving and wants to
learn data measurement and analysis, can manage this lagoon.
This employee must also enjoy writing Quality Assurance Plans,
Operation and Management Plans, and keeping EPA informed.
[iv]
Explore a process to test the DMR
samples at the lagoon, as preliminary measurements, before the samples
are sent for analysis. The
HACH BOD test simplifies this procedure.
http://www.epa.gov/compliance/monitoring/programs/cwa/dmr/index.html
Lois at the hospital lab is to be in the lab March 3, 2010.
We can explore the role that the
hospital may play in DMR reporting. The staff on February 26, 2010 told
me they do total coliform and E. coli now.
[v]
The instruments and equipment for
these first measurements is about $8,000.
The microscope and lab BOD is about an additional $4000. Test
instruments that we are analyzing include:
http://votingpeoplehelpingpeople.com/Jesse_Creek/TSS%20and%20probes.pdf
http://votingpeoplehelpingpeople.com/Jesse_Creek/bod%20with%20hqd%20meter[1].pdf
http://votingpeoplehelpingpeople.com/Jesse_Creek/tss%20gravimetric[2].pdf
Sludge Estimate from Keller Associates
An estimate of $200,000 is suggested as a planning level cost for lagoon cleaning. Compare this to footnote VII, where the removal of sludge is by bottom aerators.
Excerpted from
the 2007 Fact Sheet, page 8:
Harry Shanafelt, informed EPA that the lagoons are approximately 5 to 6
acres each, and 12 feet deep. Pond I was observed to have 10 aerators
installed; Pond II was observed to have 5 aerators installed, with one
additional designated aerator in the vicinity. Along the banks of the
Salmon River near the point of discharge, EPA took GPS readings.
According to the application, the outfall is submerged about 40 from the
banks and 5 feet deep. Using the collected GPS readings, and a
computerized positioning program, EPA estimated the coordinates of the
submerged outfall as: Latitude: 45º
11’ 32.5” N; and, Longitude: 113º
53’ 10.7” W.
You can see the aerators
in the Google image below:

[vii]
Low dissolved oxygen can cause a
variety of noncompliance issues for a lagoon.
If we find areas of low oxygen, we must make corrective changes
in order to stop noncompliance.
One possibility is to install bottom aerators:
http://www.clean-flo.com/systems/wastewater-aeration/
Bottom
aerators aerate bottom water and they bring bottom water to the surface,
where the atmosphere and top aerators oxygenate the water.
Estimated cost of these aerators is $21,412.
Compare this to the estimated $200,000 for removal of the sludge
by Keller Associates.
[viii]
These tests provide a baseline
for this more comprehensive testing: (1) Effluent cBOD measurement (2)
Effluent soluble BOD5 and total BOD concentrations (3) Effluent pH and
its diurnal variation (4) Lagoon dissolved oxygen concentration and its
diurnal variation (5) Microscopic examination.
[ix]
Algae are a normal and needed part of a lagoon, providing much of the
oxygen for BOD5 stabilization. Management
of the lagoon must prevent algae overgrowth, which is the cause of 2/3
of noncompliance in a Colorado study
(http://lagoonsonline.com/trouble-shooting-wastewater-lagoons.htm).
An algae concentration of 4 x 105/ml can cause a BOD5
effluent concentration >30 mg/l, a pH increase (as high as pH 9), a
TSS/BOD ratio >2, an increase in dissolved oxygen in the lagoon, and a
low soluble BOD5 in the effluent.
Examination by a microscope can identify the algae, the filamentous
bacteria, and the sulfur bacteria.
Anaerobic sulfur bacteria or filamentous bacteria in the effluent
will indicate anaerobic areas in the lagoon.
Sulfur Bacteria

Filamentous Bacteria

[1] March 15, 2010 Workshop Documents
How the Lagoon Works
Add 100 ml of activated sludge to a
liter of wastewater and aerate the mixture.
Observe the growth rate of the micro-organisms from the sludge.
Their number increases at the same rate as they take up oxygen.
Then the number of micro-organisms decreases, as the food (BOD5)
from the liter of wastewater decreases.
Because we keep adding oxygen, the decrease in the number of
micro-organisms is really because they are running out of food, BOD5.

Figure III-1 shows that the ideal growth curve has 3 phases: logarithmic growth phase, declining growth phase, and the endogenous phase. This type of curve would develop if 100 mL of activated sludge were added to a liter of wastewater and the mixture was aerated for a given length of time.
Continuous Process
The lagoon runs continuously. The
sludge process occurring at the lagoon should be in the extended
aeration part of the next figure. This is the area of acceptable BOD5,
minimum detention time, and minimum cost of operation.

Aerobic Digestion
During aerobic digestion, pollutants are broken down into carbon dioxide
(CO2), water (H2O), nitrates (NO3-),
sulfates (SO4-2), phosphates (PO4-3),
and biomass (microorganisms). By using
aerators, the process can be accelerated. Of all the
biological treatment methods, aerobic digestion is the most widespread,
is used throughout the world, and is the
principle process in an aerated
lagoon.
Path of Aerobic Digestion

Anaerobic Decomposition
The anaerobic process only takes place under strict anaerobic
conditions. It requires specific adapted bio-solids and particular
process conditions, which are considerably different from those needed
for aerobic treatment.

Anaerobic
decomposition is a four-step process:

How Bottom Aeration Works
Compare bottom aeration of a lagoon to a compost pile.
Compost Pile:
turn it and the pile gets smaller due to naturally occurring bacteria
breaking it down. Don’t turn it and the pile reduces very slowly
because of anaerobic conditions.
This is aerobic compared to anaerobic.
This is how bottom aeration decreases sludge.
The aerobic micro species metabolize the organic part of the
sludge. On average, about
70% of the volume of the sludge is removed by the aerobic micro species.
My use of the words, micro species, refers to bacteria, fungi, algae,
protozoa, water molds, slime molds, and other one-celled or multi-celled
small plants and animals.
The Micro Species Environment
With bottom aeration, aerobic bacteria, yeast, and other micro species
predominate. These micro
species work 20-30 times faster than anaerobic micro species.
They give off carbon dioxide and water, just as humans do, as end
products of living.
Anaerobic micro species give off hydrogen sulfide (H2S),
ammonium ion (NH4-1), bicarbonate ion (HCO3-1),
carbonate ion (CO3-2) and other partly oxidized
chemical species. When one
of the micro species gets ahead of the other, their products increase in
concentration. These
concentration changes can change pH, ionic strength, and alkalinity.
These changes can inhibit other micro species.
When this occurs, BOD and TSS can increase in concentration.
With aerobic micro species, the nitrate and other compounds are
incorporated into new micro species.
When the micro species reach a steady state, then the nitrate,
phosphate, etc. appear in the solution or in the case of nitrogen, may
be given off as nitrogen gas (NO3-
NO2-
NO
N2O
N2).
When the predominant species are aerobic, swings in pH and
dissolved oxygen do not occur, because algae and other species do not
become main players.
Aerobic micro species can metabolize all the substances in the influent.
This simplifies management of the lagoon.
The chemical imbalances caused by competing aerobic and facultative
micro species play an insignificant part, when oxygen is in all parts of
the lagoon. Algae cannot
thrive because too little carbon dioxide is in the top water of the
lagoon.
The Clean-Flo bottom aerators will create aerobic conditions from top to
bottom in the lagoons. With aerobic conditions
throughout the water column, aerobic
micro species will assist in sludge reduction and reduce incoming
organics. The
artificial aeration also keeps the wastewater in the pond mixed, keeping
organics and bacteria in contact.
Aeration allows the pond to have shorter detention times and
heavier loading.
The Clean-Flo bottom aerators can create aerobic conditions everywhere
in the lagoons. From 100
mg/l influent, the Clean-Flo system can create an effluent with better
than 85% removal of BOD5 and TSS.
Because of the
bacteria and aquatic insects that will
be present in aerobic conditions, the
BOD should be about 10-20 mg/l.
The
minimum sewage influent reported from 1988 to 2010 is 11 mg/l, maximum
is 608 mg/l, and average is 85 mg/l.
Example of
Performance of Bottom Aeration
The
Bel Marin Keys Community Services District (BMKCSD) in Novato CA in 2007
authorized CLE Engineering, Inc. (CLE) to perform a water quality pilot
study of the Paddleboat Lagoon within the South Lagoon.
This complete study is at
http://votingpeoplehelpingpeople.com/Jesse_Creek/Tools.html
Note the dissolved oxygen difference at top, middle, and bottom depths
before installation of bottom aeration and 126 days after:

Intermediate sampling in the study shows increasing bottom dissolved
oxygen and pH stabilization.


Where We Are Now
The lagoons we have:
(1)
Vary in flow rate
from 1 mgd to 2 mgd
(2)
Have
sewage influent reported from 1988 to 2010 that is
low: minimum is 11 mg/l, maximum is 608 mg/l, and average is 85 mg/l.
Wastewater lagoons are typically about 32,000 mg/l influent.
(3)
Vary in temperature
from 3 degrees Centigrade to 25 degrees.
(4)
May freeze over with
current management, as the north lagoon did this winter.
(5)
Are more like ponds
than like wastewater lagoons?
(6)
Have produced mostly
compliant effluent values over these 21 years, with only a few
noncompliant values in DMR reports, with current management.
(7)
Have anaerobic,
facultative, and aerobic environments present, as shown by the 1988 to
2010 effluent data.
Where We Can Be
To be compliant 100%
of the time:
Create a 100% aerobic environment in the lagoons, with bottom aeration.
(1)
Aerobic micro species
are 20-30 times faster at breaking down organic matter, compared to
anaerobic and facultative micro species.
(2)
The aerobic
environment will eliminate the anaerobic and facultative micro species.
(3)
Aerobic lagoons can
operate at a fraction of the cost of wastewater lagoons.
Four horsepower will oxygenate both lagoons.
(4)
The vertical
variation (12 mg/l to less than 1 mg/l) in dissolved oxygen is
eliminated.
(5)
The partially
oxidized products (e.g. H2S, CH4) of anaerobic
micro species are eliminated.
This will stabilize pH, because these acids will not be produced.
Neither will the ammonium ion (NH4+1) be
produced: NH3 + O2 + Bacteria
® NO2
+ O2 + Bacteria
®NO3-1
The nitrification that occurs in the BOD5 test will not
occur in the aerobic environment.
From ammonia to nitrate (Reaction 1 can be anaerobic.
Reaction 2 is aerobic.
There two bacterial species involved.
Nitrosomonas sp. bacteria which oxidize ammonia to nitrite,
while Nitrobacter bacteria convert nitrite to nitrate, with both species
using the energy released by the reactions. This process involves a
complex series of reactions that can be summarized as:
1.
For Nitrosomonas:
55NH4++ 76 O2 + 109HCO3-
C5H7O2N
+ 54NO2-+ 57H2O + 104H2CO3
2.
For Nitrobacter:400NO2-
+ NH4+ + 4H2CO3 + HCO3-
+ 195 O2
C5H7O2N
+ 3H2O + 400 NO3-
(6)
Fewer micro species
will be competing for the nutrients.
This will stabilize the pH, because the micro species will be in
a steady state, not increasing or decreasing in number or in the
products they make.
The Condition We Have:

The Condition We Can Have:

Cost
estimate is
$21,412
The cost for the system and airline is $18,388. The cost for the
bacteria and enzymes is $1,476. The order will be shipped by truck on
pallets. The shipping cost will be $1,548. $21,412 capital investment
and operating cost to run four 1-horsepower compressors.
Compare this to the cost of operating the top compressors.

This
document is at
http://votingpeoplehelpingpeople.com/Jesse_Creek/WorkshopMarch15.html#_edn7