A Plan of Management
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 3, 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. 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.[vi]
Test again 24 hours later,
making no change in operation.
Repeat this procedure until acceptable accuracy and precision
is obtained.[vii]
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.
[viii]
[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.
http://votingpeoplehelpingpeople.com/Jesse_Creek/Tools.html
[iii]
A cost of about
$50,000 for equipment should result in effluent well within
EPA regulations.
[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
[vi]
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 $23,000.
Compare this to the estimated $200,000 for removal of
the sludge.
[vii]
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.
[viii]
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.