April 7, 2009 City Council
Concerns of
Salmon Citizens on April 7, 2010 Salmon City Council
Offered by Calvin B. Leman,
PhD
305 Washington Street
Salmon, Idaho 83467
Aerobic Lagoons
At the March 22 workshop, we learned that aerobic micro species
consume BOD at 20-30 times the rate of anaerobic micro species.
Because the lagoons, as they
are, were in compliance most of the time for the last 20 years,
making the lagoons aerobic will produce a BOD and TSS about 15 mg/l
or less all of the time, which is in EPA compliance all the time.
This statement is supported by multiple studies of similar
ponds. Ask me for
references.
The lagoons can be aerobic for an
equipment cost of $21,412,
using Clean-Flo bottom aerators.
Clean-Flo offers a
one year warranty on the complete system, and a 3- year warranty on
the airline and diffusers.
And they are willing to make other arrangements that the city
may want. A copy of the
Clean-Flo proposal is included with these concerns.
Keller Planning
Study (70
pages, $60,000, $857/page)
On page 55:
“The existing lagoon system
is functioning just as a lagoon system should.”
This ludicrous statement may just be a poor choice of
words. Why do we have violations if the lagoons are working as they
should? The statement
continues then to explain that a filter for $2,175,000 will fix the
problem, with absolutely no data to support this recommendation. And
no guarantee from Keller that it
will. Keller measured
the depth of the sediment.
Keller did not measure the
composition of the sediment.
Keller did not measure the pH, BOD, TSS, turbidity, dissolved
oxygen, temperature, or oxidation-reduction potential (ORP) in
pertinent parts of the lagoons over a specific time.
The Keller plan is rich with conjecture and with
speculation. The Keller
report is poor with scientific analysis.
This is costly to Salmon citizens.
Lagoons Can’t Do
It?
On page
3: “Lagoon systems have a
limited capacity to remove TSS and BOD5.” What does
limited capacity mean?
What data supports this conjecture?
Why is the lagoon in compliance most of the time now?
The I/I have not changed in 20 years.
On page
3: “In addition to the dilute
influent, seasonal changes in the wastewater treatment plant
including re-suspension of solids during lagoon turnover and algae
growth in the lagoons are contributing to the effluent BOD and TSS
levels.” What data
supports this conjecture?
The Keller report has no data that shows that sludge or I/I
affect BOD and TSS. When the lagoons were built (no sludge) the
effluent was worse than it is now with sludge.
EPA data from 1988 to 2009 shows this.
Algae
On page
55: “Algae can be killed by
chemical means or by deprivation of sunlight.”
Keller
failed to say that algae cannot populate aerobic lagoons.
Carbon dioxide is a limiting factor for algae in aerobic
water. The aerobic Salmon
River has no algae problem.
Keller says that a cover on the lagoon for $1,233,000 will
keep algae out of the effluent, with absolutely no data to support
this speculation. And no guarantee
that it will. That cover will make that section of the lagoon
completely anaerobic, just before the discharge, putting methane,
ammonia, organic acids, and pH change into the effluent, if BOD is
present in that section of the lagoon.
Are Suspected
On page
56: “The high levels of TSS
are suspected to result from re-suspension of the settled solids
from lagoon turnover and
algae blooms.” This
ludicrous statement makes no sense at all.
Exactly what does
turnover mean? What
data do they have to support this speculation? What algae blooms and
turnover occurred in December, when we got an EPA violation?
Keller did not measure the effluent
for anything or measure anything else anywhere in the lagoons.
Any statement of high levels (they must mean concentration)
must be supported with data, especially when millions of
Salmon-citizen dollars may be spent needlessly.
Raise User Fees
On page
69: “In order for the City to
be able to complete the projects shown in Table 9.2 ($6,578,000,
page 65), the city would need to raise
monthly user rates to the $33.00 to $43.00 range. “
This statement shows that they don’t want to fix the
problem. They just want
to work on it forever, at Salmon citizen’s expense.
If we make the lagoons aerobic, the city can reduce the
wastewater fee to where it was before the last increase, not
increase it even more.
Keller Working
With the City and With DEQ
On page
70: “Keller Associates, Inc.
staff has worked closely with City staff and elected officials in
analyzing the wastewater system and developing improvements that
will have lasting beneficial impacts on the City.” Keller has
also worked closely with Idaho DEQ.
That was obvious at the March 22 workshop.
William Teuscher (DEQ) said that DEQ
had approved the Keller plan.
When DEQ offers a low-interest loan to the city, DEQ
succeeds, Keller gets money, and the Salmon citizens get to pay back
the loan. Mr. Teuscher
also said that bottom aeration does not always work.
That is true, if the bottom aeration does not bring the
bottom dissolved oxygen to the same concentration as the surface
oxygen. Mr. Teuscher
offered no data on dissolved oxygen in the cases he mentioned.
When I ask Willie (during the break) about measuring oxygen
in those cases where bottom aeration did not work, he said they did
not.
His statement “does not always work” means
nothing without data to support it.
Mr. Teuscher of Idaho DEQ,
like Keller, is poor with scientific analysis.
The Salmon City Council has been listening to them both.
Sign a Bond
On page
71: “The actions recommended
by this study will enable the Salmon wastewater system to provide
wastewater collection and treatment which will comply with the
current and anticipated regulation and accommodate the projected
growth of the city for the next 20 years.”
This long statement might mean something, if Keller signs a
bond to support this conjecture. Jim
Mullens of Keller Associates has said they will not sign a bond.
Conclusion
These are just a
few of the conjectures, speculations, misstatements, and lack of
data throughout the Keller report.
The Keller report paints a dark picture of more expense, then
more expense for Salmon.
When the city installs bottom aeration and measures the
dissolved oxygen and other parameters needed for management of the
lagoons, the Keller report will look even worse.
We will have data, not conjecture, as is prevalent in all
parts of the Keller report.
Salmon citizens will know, because
their wastewater fee will be reduced.
