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Updated information regarding lagoon compliance with EPA

Summary

The data for ID0020001 from 2004 to 2009 show that the principle problem with the effluent is the reduced retention time in the lagoon. Hydraulic retention time (retention time) of 44 days is reduced to about 25 days because of sludge, which is estimated at 6 to 8 feet deep[i] in the lagoon. Facultative lagoons[ii] function properly with 30 to 60 days retention time.

With this information, we can see that if we dig out the sludge in the lagoon so that the retention time is raised back to 44 days, the cost estimate is 200k+. Furthermore, if this is fixed, the wastewater facility may be in compliance. No other work may need to be done.

Detail with References

The data from 2004 to 2009[iii] show that the principle problem with the effluent is the reduced retention time in the lagoon. Retention time of 44 days is reduced to about 25 days because of sludge, estimated at 6 to 8 feet deep in lagoon 1. Facultative lagoons function properly with 30 to 60 days retention time[iv].

If the lagoon is sized for 3 mgd, the current maximum flow of just over 2 mgd is well within this lagoon to accomplish 85% removal of BOD and TSS, as is specified in the October 2007 permit. The data do not support the claim that infiltration is the cause of the violations. Most violations are being recorded near the minimum flow rate for this lagoon, when the lagoon temperature is less than 20 degrees C, and when the pH is above 6.7[v]. No data supports the claim that reducing the flow rate will stop violations. Violations are occurring at flow rates near 1 mgd. Only 4 of 21 TSS violations have occurred at greater than 1.25 mgd. These TSS violations may be caused by algae and not the influent. The BOD violations may be caused by the nitrifying organisms described in footnote VII and not the influent.

Most bacteria (saprophytic, mesophylic) in the lagoon operate maximally above 20 degrees Centigrade. All the violations but one[vi] has been at temperatures less than 20 degrees C. With the reduced retention time, these low temperatures cause the bacteria to slow their rate of breakdown. This can cause incomplete breakdown of the influent and result in BOD and TSS violations.[vii]

[i]

[ii] This lagoon is functioning as a facultative lagoon because algae are growing. A properly functioning aerated lagoon should have no algae problem. The technology and performance of aerated lagoons approach those of the facultative lagoon as the aerated lagoon becomes larger, shallower, and less aerated. (http://www.lagoonsonline.com/technote3.htm)

[iii] http://www.epa-echo.gov/cgi-bin/effluentsquery.cgi?permit=ID0020001&pipe=all&paramtr=all&monlocn=effonly&period=all&outt=effonly&date=20061001%7C20090930&charts=viol&tool=echo

[iv] http://www.lagoonsonline.com/general.htm

[v] Most bacteria in the lagoon function optimally at pH 6.7 to7.5. Most violations are occurring at pH higher than 8.

[vi] 20.6 degrees C on 6/1/2009 to 6/30/2009.

[vii] These high BOD values may be due to the nitrogenous component in the effluent, which is common in aerated lagoons, especially in cold water. EPA has given their approval to the use of a nitrification inhibitor, provided that the effluent permit states the limit in terms of the CBOD5 instead of the BOD5. Millions of dollars may have been spent needlessly on new treatment facilities (http://www.lagoonsonline.com/technote1.htm). Unlike the carbonaceous demand, which is proportional to the concentration of the biodegradable carbon constituents in the effluent, the nitrogenous demand exerted during the 5-day test is proportional to the number of nitrifying organisms that happen to be caught in the sample being tested.

Effluent BOD5 and CBOD5 data from an aerated lagoon system in Maine that treats

a domestic wastewater. (Courtesy of George Bloom, Woodard and Curran, Engrs. Taken from Rich (1999))

http://www.clemson.edu/ces/departments/eees/outreach/AERATEDLAGOONTECHNOLOGY.pdf

Effluent BOD5 and CBOD5 data from an aerated lagoon system in Maine that treats

a domestic wastewater. (Courtesy of George Bloom, Woodard and Curran, Engrs. Taken from Rich (1999))

Hypotheses, Fact, Data

Hypotheses:

We should work on this land application now and complete it in one year, or less.

We can find funding for this study and for building the land application, in a couple of months or less.

Salmon will have EPA violations whether we try to fix some of the infiltration or we don’t.

Spending money for infiltration repair should not divert time and money from the land application.

EPA does not have the digression to make exceptions to the Clean Water Act. Fixing infiltration may be less convincing to EPA than developing a land application, which keeps water out of the river completely.

Violations will stop when we stop putting effluent into the river. We have no guarantee that fixing infiltration will stop violations. For example, Rigby has no infiltration but does have EPA violations.

All the effluent may go into the S-10 ditch, the Norton Canal, and to the Overacker ranch, during the irrigation season.

Effluent in winter may go to a storage-reservoir-wetland on the Overacker Ranch or temporarily into the river, as the Overacker ranch reservoir-wetland-agriculture is completed.

Fact: We have about 2 mgd effluent during irrigation season and about 1 mgd effluent during the winter.

Flood irrigation is 10% efficient and takes 1 mg each time to irrigate one acre. Sprinklers are 85% efficient.

Overacker ranch can absorb more water than is needed for agriculture. Mark Olson (NRCS) estimates Overacker ranch to use 423,129,600 to 486,599,040 gallons of water May through September.

Diverting the effluent to agriculture allows the aerated lagoon to be changed to the cheaper-to-operate facultative lagoon, in which algae play a major role. The TSS caused by algae are not an issue when effluent is not directed into the river.

Data: Map showing:

(1) The path of the proposed pipeline to the Overacker ranch. Estimated cost (Mark Olson) from $250,000 to maybe $500,000 to get the water from the lagoon to agriculture.

(2) The Norton canal, the S-10 ditch, and any other path the effluent may take. Ensure that no connection to a natural waterway is possible anywhere.

Research in Progress

http://www.epa.gov/npdes/pubs/chapt_05.pdf

Chemical oxygen demand (COD) and total organic carbon (TOC) laboratory

tests can provide an accurate measure of the organic content of wastewater in a

shorter time frame than a BOD5 test (i.e., several hours versus 5 days). Pursuant to

40 CFR §133.104(b), the permit writer may substitute COD or TOC monitoring for

BOD5 when a long-term BOD:COD or BOD:TOC correlation has been demonstrated.

http://edocket.access.gpo.gov/cfr_2003/julqtr/pdf/40cfr133.105.pdf

(b) Chemical oxygen demand (COD)

or total organic carbon (TOC) may be

substituted for BOD5 when a long-term

BOD:COD or BOD:TOC correlation has

been demonstrated.

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Hypotheses, Fact, Data

Research in Progress