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HomeMy WebLinkAboutCOM 0035.000 2000-2002 i _ / ~ 1 ~ _ November 29, 2000 2009'1 Mr Robert Yanabu Chief Engineer Department of Public works County of Hawaii 25 Aupuni Street Hilo, Hawaii 96720 Dear Mr Yanabu: Subject. Kulaimano Wastewater Treatment Plant Compliance Evaluation Inspection Attached for your use is a copy of our compliance evaluation inspection report for the subject facility. The facility was inspected on September 21, 2000 and given a general rating of "Unacceptable" for the following reasons: 1 Sludge continues to be stored ~n the abandoned effluent polishing pond. The pond is considered an active sludge unit and must be properly closed in accordance with Federal Regulation 40 CFR Part 503. The County has not provided a closure plan acceptable to the Department of Health and is subject to enforcement action, 2 Discharging non-chlorinated effluent into State Waters in violation of the plant's NPDES permit in January 2000; 3. Exceeding effluent total residual chlorine limits in August and September 2000; and 4. Inconsistent flow readings between the plant's influent and effluent flowmeters. Other concerns noted during the inspection are included in the attached report. Com•n \o._ File \n_SE~ 1{rt To•_ pEl-~ ReE. uace_ 1 3 2000 Mr. Robert Yanabu November 29, 2000 Page 2 Please submit within 45 days after receipt of this letter a written corrective action plan addressing the cited deficiencies The plan should also include a reasonable time schedule for implementation of your actions. Should you have any questions, please call Ken Muranaka of our Wastewater Branch at direct toll free no. 974-4000, ext. 64294. Sincerely, THOMAS E. ARIZUMI, P.E., CHIEF Environmental Management Division KTM erm Attachment c: EPA Region IX (Tom Huetteman, w/ report) Deputy Director for Environmental Health (w/ report) County Council Public Works Chairperson (w/ report) Clean Water Branch (w/ report) Unltsd Stabs Envlronmenbl Proiectlon Agency Form Approved EPA ws.hinpton, D c so4eo OMB No 2040-0057 Water Compliance Inspectlon Report Approval expires 8-31-98 Secllon A National Data System Coding (I e , PCS) Transaction Cade NPDES yr/mo/tlay Inspection Type Inspector Fac Type ,U zU 3~HIllololzlol717101„ ,Zo 0 o s z 1,7 ,sU ,sU zoU Remarks +lllllllllllllllllllllllllllllllllllllllllllllll~ Inspection Work Days Facility Self-MOnilonng Evaluation Rating B7 pA _--____-Reserved- ~12L1JBg ,D~ ~tU 72U 73W74 ~Sl I l l l l l b Secllon B Faclllly Data Name and Location of Facility Inspected (tor rndusrnel users drschergmg ro POTW also include POTW Entry Time/Date Permit ErtectNe Dale name end NPDES permit number 1 00 p m 09/21 /2000 04/2511999 Kulalmano Wastewater Treatment Plant Exi; Time/Date Permit Expiration Dale Kulalmano Town, Pepeekeo, Hawall 3 30 p m 09/2112000 04/25/2004 Name(s) of On-Site Representative(syTille(syPhonesnd Faz Numbedsl Other Facility Data Lyle Hlrota, WWTP Superintendent, Ph 961-8754IFax 961-8687 Charles Dawrs, WWTP Supervisor,DRC, Ph 961-8753/Fax 961-8687 Name, Address of Responsible ORcial/ritle/Phone antl Fax Number(s) Robert Yanabu, Chief Engineer, DPW, County of Hawan Ph (808) 961-8324 Contacted ~Y9s XO No Secllon C Areas Evaluated During Inspectlon (Cheek only those areas evaluated) X Permit X Flow Measurement X Operations 8 Maintenance CSOISSO (Sewer Overflow) X RewrdslReporis X Self-Monitonng Program X Sludge Handling/Disposal Pollution Prevention X Facility Site Review Compliance Schedules Pretreatment MulOmedia EMuentlReceiving Water Laboratory Storm Water Other Secllon D Summary of FlndingslComments (Attach add/tlonel sheets or narrative and eheckllsts as necessary) See attached Findings Name(s) and SlpnaWre(s) of Inspecbr(s) Apenty/Olflce/Phone and Faz Numbers Date y., DOH, WWB 1586-4294 11/0112000 Ken Muranaka - Steven Sato ~ DOH, WWB 1586-4294 11/0112000 Libby B Stoddard DOH, CWB 1586-4309 1110112000 Signature of Management O A Reviewer Agenty/ORce/Phone end Fax Numbers Dale EPA Forrn 3580) (Rev 9.94) Previous editions tiro obsolete CLEAN WATER BRANCH STATE DEPARTMENT OF HEALTH P.O. BOX 3378 HONOLULU, HAWAII 96801 NPDES COMPLIANCE INSPECTION REPORT PERMITTEE: COUNTY OF HAWAII DEPARTMENT OF PUBLIC WORKS FACILITY: KULAIMANO WASTEWATER TREATMENT PLANT PERMIT NO: HI 0020770 DATE OF INSPECTION: September 21, 2000 REPORT PREPARED BY: KEN MURANAKA DATE PREPARED: November 1, 2000 FINDINGS INTRODUCTION Department of Health (DOH) personnel K. Muranaka, S. Sato, and L. Stoddard conducted an NPDES Compliance Evaluation Inspection (CEI) of the Kulaimano Wastewater Treatment Plant (KWWTP) on September 21, 2000. Lyle Hirota, Wastewater Treatment Plant (WWTP) Superintendent, and Charles Dawrs, WWTP Supervisor in Direct Responsible Charge represented the County of Hawaii (County) during the inspection. NPDES Permit No HI 0020770 was issued on March 25, 1999 and became effective on April 25, 1999. The permit expires at midnight on April 25, 2004. The permit authorizes the County of Hawaii to discharge secondary treated wastewater to the receiving waters named the Pacific Ocean through Outfall Serial No. 001 at Latitude 19°50'12"N and Longitude 155°05'11"W from its KWWTP located at TMK: (3) 2-8-07:075, Kulaimano town, Pepeekeo, Hawaii, in accordance with the effluent limitations, monitoring requirements and other conditions set forth in NPDES Permit No. HI 0020770 and in the DOH "Standard NPDES Permit Conditions," dated October 1, 1997. FACILITY DESCRIPTION The KWWTP is a secondary activated sludge wastewater treatment plant servicing the town of Kulaimano on the island of Hawaii. The plant has a design capacity of 0.5 million gallons per day (MGD). The plant is currently operating at only one-sixth of the design capacity due to unrealized developments in the Pepeekeo area. This allows the plant operators to run only one of two available treatment trains. Liquid stream treatment processes include barminution, grit removal, activated sludge, secondary clarification, chlorination, and dechlorination. The effluent polishing pond has been abandoned and is currently being bypassed. Solids stream treatment processes include aerobic digestion and dewatering by centrifuge. A dual cell gravity (DCG) filter unit 1 is also available as backup to the centrifuge. The dewatered sludge is disposed of at the Hilo Landfill. STATUS OF PAST DEFICIENCIES The 1999 Operation and Maintenance (O&M) inspection found the facility to be operating satisfactorily. However, a general rating of UNACCEPTABLE was given for the following reasons 1. The effluent polishing pond has been abandoned in place since the mid-1980's and the pond still contains sewage sludge. The pond is considered an active sludge unit and must be properly closed in accordance with Federal Regulation 40 CFR Part 503. 2. The influent sampling station was temporarily relocated downstream of the grit chamber after the barminutor became inoperable. The relocated sampling station violates Section A.2. of the facility's NPDES permit. The following is the current status of the above deficiencies: 1. The Department of Health's Clean Water Branch (CWB) issued a notice of apparent violation letter dated November 24, 1999 for the above violations upon completion of the 1999 O&M inspection. The County responded with a letter, dated March 24, 2000, that an analysis of the sludge and field survey of the pond had been completed. The County reported the concentrations and loading of the priority pollutants found in the sludge to be well under the limits established under 40 CFR Part 503. The County also submitted a proposed closure plan with the data The CWB requested clarification on a number of items relating to the said closure plan in a letter to the County on May 18, 2000. The County has yet to respond to the CWB's request for clarification. 2. The influent sampling station was relocated back to the original approved sampling point on September 15, 1999. The status of the other deficiencies noted in the 1999 O&M inspection are as follows: 1. The barminutor at the headworks was inoperable. The barminutor was repaired and placed back in service. 2 2. The suction from the headworks ventilation system was noticeably weak. The County installed a larger pulley for increased suction. 3. Aeration Basin turbine #1 was out of service due to ate electrical tripping problem. The County's electricians have not resolved the tripping problem with the turbine unit. The unit remains locked out at the control panel. 4. The baffle boards for Final Clarifier #1 needs replacement. No backup capability exists until the new boards are installed. The County completed replacement of the baffle boards in Final Clarifier #1 and has placed the clarifier unit into service. Final Clarifier #2 was then taken out of service and now serves as the backup unit to Final Clarifier #1. 5. The flow chart recorder for the aerobic digester records an airflow even when the blowers are not in operation. The unit requires repair/calibration. No change. The County reported that the recorder device is used only to record events and actual airflow volume is unnecessary. 6. The electrical board for the backup DCG unit was removed for use at the Papaikou wwTP and was never replaced. This makes the unit inoperable resulting in no backup dewatering unit at the plant. The County installed a new replacement board. The unit was started up during the inspection and found to be operable. 7. Blower #1 was inoperable. The County has no immediate plans to repair the unit. The facility still has three other operable blower units and only one blower is used at a time. 8 The facility's backflow preventez- leaked water. The backflow preventer was inspected and repaired. The backflow preventer did not leak during the current inspection. MODIFICATION/ADDITION The Federal Emergency Management Agency (FEMA) provided the County with a portable 600KW emergency generator for use as backup to the facility's 400KW emergency generator. A manual switch and connector was also provided by FEMA to make the connection. 3 EFFLUENT LIMITATION NPDES permit limitations for the KWWTP are as follows: EFFLUENT CHARACTERISTIC EFFLUENT LIMITATIONS Biochemical Oxygen Demand 30 mg/1 (30-day average) 45 mg/1 (7-day average) 85~ removal Total Suspended Solids 30 mg/1 (30-day average) 45 mg/1 (7-day average) B5~ removal Total Residual Chlorine 0.0075 mg/1 pH Range 6.0 - 9.0 Standard Units Enterococci 7/100 ml The following effluent data was reported during the past year (based on monthly averages for the period September 1999 through August 2000): Influent BODS...... 264 mg/L (flow proportioned composite) Effluent BODS..... 2.7 mg/L (flow proportioned composite) Percent BODS Remova1.98.9~ Influent TSS.. 244 mg/L (flow proportioned composite) Effluent TSS......... 8.1 mg/L (flow proportioned composite) Percent TSS Remova1..96.4~ pH (min)...... 6.1 (grab sample) pH (max).... 7.0 (grab sample) NPDE3 PERMIT NON-COMPLIANCE On January 28, 2000, the KWWTP bypassed approximately 15,000 gallons of non-chlorinated effluent into State Waters when Effluent Pump #2 tripped off sometime during the previous night. The cause was reportedly due to a frayed wire on the Pump #2 motor control panel. The KWWTP exceeded the NPDES Total Residual Chlorine limitation of 0.0075 mg/1 on August 30, 2000 (0.008 mg/1), September 1, 2000 (0.03 mg/1), and September 2, 2000 (0.12 mg/1). The County suspects the problem was caused by a bad batch of sulfur dioxide 4 provided by the vendor, Brewer Chemical. Brewer Chemical was notified of the problem and will provide the County with a sample test kit. The Zone of Mixing monitoring results exceeded the 3.50 ug/1 ammonia nitrogen parameter for Station 3 (3.78 ug/1) on March 14, 2000. The 1999 Annual Sludge Report due by February 19, 2000 in accordance with Part C.7.a. was submitted about a month late on March 17, 2000. OBSERVATIONS The KWWTP continues to produce excellent single digit effluent as noted in previous reports. The low point total in the Department's Operation and Maintenance Questionnaire also indicates that the plant was generally operating well. The KWWTP averaged 0.066 MGD for the period of September 1999 through August 2000, equal to approximately 13 percent of the average design capacity. Last year's inspection report noted an average flow of 0.075 MGD for the inspection period July 1998 through June 1999. The County attributed the decrease in flow to mostly drier weather conditions during the past year. No additional sewer connections are anticipated in the immediate future. The KWWTP NPDES permit requires the County to monitor both the influent and effluent flows through the plant. The effluent flowmeter read consistently higher flows than the influent flowmeter. This occurred even during sunny days when evaporation was expected to result in a net reduction of effluent flow and also on sludge dewatering days. The average effluent flow exceeded the influent flow in excess of 10 percent for the months of October 1999 (15.4 percent), December 1999 (10.4 percent), January 2000 (12.2 percent), March 2000 (11.1 percent), April 2000 (22.5 percent), and May 2000 (13.1 percent). NPDES Standard Permit Condition, Section 3.b., requires flow measuring devices capable of measuring flows with a maximum deviation of less than plus or minus ten (10) percent from the true discharge rates throughout the range of expected discharge volumes. An area of concern noted occurs whenever the effluent pumps discharge excess water from the flow regulator back into the small chlorine contact tank (CCT). Splashing from the return water causes 5 turbulence within the small CCT that may affect the flowmeter readings. Aerator Turbine #1 continues to remain out of service due to an electrical tripping problem and has been locked out at the control panel. The County has placed a Priority 3 (lowest on a scale of 3) rating on the repair work order since the unit serves the backup aeration tank This problem was previously noted in last year's inspection report. With the exception of Aerator Turbine #1, no other major corrective maintenance backlog was noted. Preventive maintenance duties were reportedly up-to-date. A minor air leak from a flange on the blower discharge manifold was noted. The batteries for the emergency generator were observed to have a buildup of acid corrosion on the terminals. 3UbIl~fARY The KWWTP is given a general rating of UNACCEPTABLE for the following reasons: 1. Sludge continues to be stored in the abandoned effluent polishing pond. The County has not provided a closure plan acceptable to the Department. The County is subject to enforcement action for their lack of action. 2. Discharging non-chlorinated effluent into State Waters in January 2000. 3. Exceeding the effluent total residual chlorine requirement during the past year. 4. Inconsistent flow readings between the influent and effluent flowmeters. Other deficiencies/recommendations noted during the inspection include the following: 1. Repair of the Aerator Turbine #1 has still not been completed. 6 2. The battery terminals for the emergency generator showed signs of corrosion. Regular cleaning of the terminals is necessary to maintain good contact and prevent a voltage drop which may result in failure of the generator to start. 3. The effluent pump return water line should be relocated away from the sonic flow sensor to minimize turbulence in the CCT. 7