8.2. SR 09-19-2011~~ a~i
MEMORANDUM
TO: Mayor and City Council
FROM: Justin Femrite, P.E., City Engineer
DATE: September 19, 201 I
ITEM 8.2.
SUBJECT: Update on MPCA Compliance Evaluation Inspection for the
Wastewater Treatment Facility
On August 29, 2011 the City of Elk River received a letter from the Minnesota Pollution
Control Agency (MPCA) which summarized a Compliance Evaluation completed at the
Waste Water Treatment Facility by MPCA staff on August 10, 2011. I have attached a copy
of the letter to this memo.
There are two issues contained in the letter that I have provided clarification on below:
1. An effluent loading violation was reported in August 2010 with no violation reported
since that time. This violation resulted from the issue of excess sludge building up in
the final clarifier which resulted and affected the sand filters and various processes at
the treatment plant. At the time, the wastewater staff applied additional staff
resources and modified treatment processes to bring our discharge within the limits
of our permit. As a permanent solution, on January 18, 2011, the City Council
approved the necessary modifications to our waste sludge pump and control systems
to control this issue in the future. These improvements were installed and have
mitigated the issues that were experienced in August 2010.
2. During the August 10, 2011, inspection, the MPCA indicated there are a number of
cluster developments within Elk River that own and operate their own cluster
wastewater treatment systems. Many of these cluster system's current NPDES/SDS
permits axe coming up for reissuance and are facing potential new limits that will be
difficult to meet. The MPCA has indicated when these permits get reissued they will
likely face limits on the amount of nitrates they can discharge to their drainfields.
These cluster systems were not designed to adequately treat wastewater for nitrates.
The process required for the treatment for nitrates is complex and extremely costly.
The MPCA has inquired if the City of Elk River would consider allowing these
cluster systems to hook up to the City sewer system. The MPCA is expected to
begin meeting with the owners of these facilities and is only asking if this may be an
option they can offer as a solution.
I will be prepared to discuss these items further at the City Council meeting and take any
direction or feelings the Council has on the issue.
If you have any questions, please contact me.
r~~ ,^ ,,
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Minnesota Pollution Control Agency
Brainerd Office 17678 College Road I Suite 105 I Baxter, MN 56425 1218-828-2492
800-657-3864 ~ 651-282-5332 TTY ~ www.pcastate.mn.us ~ Equal Opportunity Employer
August 29, 2011
The Honorable John Dietz
Mayor, City of Elk River
13065 Orono Parkway
Elk River, MN 55330
RE: Elk River Wastewater Treatment Facility
NPDES/SDS Permit No. MN0020788
Compliance Evaluation Inspection
Dear Mayor Dietz:
Svc 3 a ;~;,,
Enclosed is the Compliance Evaluation Inspection (CEI) report that resulted from an inspection of the
Elk River Wastewater Treatment Facility (WWTP) on August 10, 2011, by Herschel Biasing of the Minnesota
Pollution Control Agency (MPCA). -
The CEI consisted of a visual inspection of the facility and a discussion with Mr. Gary Leirmoe, Wastewater
chief operator, and Mr.lustin Femrite, city engineer, city of Elk River. In addition, there was a review of the
monthly Discharge Monitoring Reports (DMRs) for the time period from January2010 to June 2011. The
facility's biosolids land application sites were not inspected. Based on the results of the CEI, one violation of
the terms and conditions set forth in the National Pollutant Discharge Elimination System (NPDES)/State
Disposal System (SDS) permit was noted. Please see the attached CEI Report for further detail.
If you have questions, please contact me at 218-316-3860 or 800-657-3864.
Sincerely,
,~'
Herschel Biasing
Pollution Control Specialist Senior
Brainerd Office
Municipal Division
HB:vms
Enclosure
cc: Gary Leirmoe, Wastewater Chief Operator, Elk River
Ron Swenson, MPCA, Brainerd
Herschel Biasing, MPCA, Brainerd (main file)
INSPECTION SUMMARY
A Compliance Evaluation Inspection was conducted on August 10, 2011, by Herschel Biasing of the MPCA to
determine the facility's compliance with the terms and conditions of its NPDES/SDS Permit. The following is
a summary of the findings and comments resulting from that inspection.
Areas of Concern or General Comments:
• Overall Physical Condition of the plant appears to be in excellent working condition. The operators keep
things in good working order and strive in day to day operations and maintenance trying to achieve full
compliance.
• Sampling Methods/Lab Certification -compliant
• All required reports have been submitted complete and on time for the review period.
• At the time of the inspection the city of Elk River (City) was in the process of installation of new
collection tine coming into the main headworks of the treatment facility. The duration of this project
may result in problems this fall if biosolids land application is necessary. The City may need to work with
the road contractor on truck traffic during this time.
• The facility is designed to handle an influent average wet weather flow of 2.2 million gallons per day
(mgd). For the review period of January 2010 through June 2011 the facilities average flow has been 1.2
mgd.
• Enforcement Actions over the review period -none.
• Compliance Schedule progress-The current permit includes a chapter for the required submittals for
the facility upgrade.
• Biosolids/Land Application Sites-compliant.
• General Maintenance Schedule Reviewed -Daily, Weekly and Monthly O&M -compliant.
• Record Keeping -compliant.
• As part of the inspection, MPCA staff met with Mr. Leirmoe and Mr. Femrite to discuss the possibility of
the City expanding their collection line north to several cluster system developments. Most of these
cluster systems are within current City limits, located adjacent to each other, and are currently
contributing high nitrates to groundwater. These systems were not designed to adequately wastewater
for nitrates. Many of these cluster systems that have NPDES/SDS Permits with the MPCA are coming up
for reissuance, once these are reissued, the permits may contain compliance schedules that will require
nitrate limits. Because the cost for these cluster systems to upgrade to advanced wastewater treatment
to meet nitrate levels will be extremely costly, it may be in the best interest of all parties, to hookup to
City treatment.
• If the City would be interested in extending collection to the cluster systems, the MPCA would like to set
up a meeting with all parties to discuss the future of potential collection and treatment at the City's
wastewater treatment facility.
• For the review period of January 2010 through June 2011 the City had one effluent violation. For the
monitoring period of August, 2010 the City reported a Maximum Calendar Week Average CBOD of
307.50 kg/day with a limit of 157 kg/day. No effluent violations have taken place since this time.
• Please be aware that the City's current NPDES/SDS Permit expires on November 30, 2012. This current
permit requires the City to submit to the MPCA on or before 180 days of permit expiration a
• Pollutant Minimization Plan
• Phosphorus Management Plan
• Results of third or final acute test battery
• Results of the third and final sampling event for priority pollutants (no later than one year prior
to the expiration date of the current permit).
• Application for permit reissuance
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Please review your current NPDES/SDS Permit far any additional permit requirements that may pertain to
required submittals.
Signature of Inspector Date
~~
Comments and questions should be addressed to:
Herschel Biasing
Minnesota Pollution Control Agency
7678 College Road, Suite 105
Baxter, MN 56425
218-316-3860
4
MINNESOTA POLLUTION CONTROL AGENCY
WATER QUALITY POINT SOURCE PROGRAM
Compliance Evaluation Inspection Report.
FACILITY INFORMATION:
Facility Name: Elk River WWTP
Permit Number: MN0020788
Address: 248 Railroad Drive, Elk River, MN 55330
Permit Expiration Date: November 30, 2012
Facility Design Flow: 2.2 mgd (AWW)
Major Minor Classification: Major
Type of Flow: Domestic
Plant Class: B
Land Application Type: Type IV
24 Hour Contact: Mr. Gary D Leirmoe, Chief Operator
Phone: 763-635-1171
GEOGRAPHIC INFORMATION:
MPCA Region: North Central
County: Sherburne
Basin: Upper Mississippi River, Upper Portion
Major Watershed: Mississippi River-St. Cloud
Receiving Water: Mississippi River (1C, 2Bd, 36, 3C, 4A, 46, 5, 6] [ORV1N]
THOSE PRESENT DURING THE INSPECTION:
Facility Representatives Title
Gary Leirmoe Wastewater Operator
Justin Femrite City Engineer
MPCA Representatives Title
Herschel Biasing Pollution Control Specialist Senior
INSPECTION INFORMATION:
Inspection Date: August 10, 2011
Inspection Type: CEI, Domestic Municipal without Sampling
Inspection Category: State
FACILITY COMPONENTS:
Collection with gravity and/or Pressure Sewer
2 Bar Screen -mechanical
Influent Flow Meter
1 Grit Removal
2 Primary Clarifier
2 Trickling Filter
1 Activated Sludge -contact stabilization, conventional, step feed
Phosphorus Removal -chemical
3 Secondary Clarifier
Filter -sand with backwash (Proposed)
1
Ultraviolet Light
2 Anaerobic Digester -complete mixed, heated - mesophilic
2 Storage Tank
Land Application
WASTE CONTRIBUTORS:
No waste contributors are listed for this permit.
TREATMENT PLANT OPERATORS:
Name Phone Class Expiration
Beadles, Kevin Ray 763-635-1171 Class B 1/1/2013
Clark, Christopher 763-516-4214 Type 4011/1/2012
Clark, Christopher 763-516-4214 Class B 4/1/2014
Flaherty, Nicholas James 612-720-2652 Class C 6/1/2014
Flaherty, Nicholas James 612-720-2652. Expired Class D 6/1/2011
Leirmoe, Gary D 763-635-1171 Type 404/1/2012
Leirmoe, Gary D 763-635-1171 Class B 4/1/2012
Stevens, Matthew Duane 320-290-4435 Type 4012/1/2011
.Stevens, Matthew Duane 320-290-4435 Class B 5/1/2014
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