Document Yjyb5ana1bork1qjvD8pD7bEK

United States Environmental Protection Agency Region 4 Enforcement and Compliance Assurance Division Water Enforcement Branch 61 Forsyth Street, SW Atlanta, Georgia 30303 Compliance Evaluation Inspection Report Project No. CV-FL0020427 - 12082022 Neptune Beach Wastewater Treatment Facility 2010 Forest Avenue Neptune Beach, Florida 32266 NPDES Permit Number: FL0020427 Date of Inspection: December 8, 2022 Title and Approval Sheet Title: Compliance Evaluation Inspection City of Neptune Beach, FL, Neptune Beach WWTF Approving Official: LAURIE JONES Digitally signed by LAURIE JONES Date: 2023.02.14 12:34:12 -05'00' (for) Jairo Castillo, P.E., Chief Wastewater Enforcement Section Water Enforcement Branch Inspector: Digitally signed by Sayre, Sayre, Dennis Date: 2023.02.13 Dennis 13:44:40 -05'00' Dennis Sayre, Environmental Engineer Wastewater Enforcement Section Water Enforcement Branch COMPLIANCE EVALUATION INSPECTION REPORT Neptune Beach WWTF, Project # CV- FL0020427 - 12082022 Contents 1. Introduction ................................................................................................................................................. 1 2. Participants .................................................................................................................................................. 1 3. Facility Description ..................................................................................................................................... 1 4. Inspection Procedures ................................................................................................................................. 2 5. Findings & Conclusions .............................................................................................................................. 2 A. Permit Review ...................................................................................................................................... 2 B. Records and Reports ............................................................................................................................. 3 C. Flow Measurement ............................................................................................................................... 4 D. Sampling ............................................................................................................................................... 4 E. Site Visit (Operation and Maintenance) ............................................................................................... 5 F. Sludge Handling ................................................................................................................................... 6 G. Effluent and Receiving Water .................................................................................................................. 6 6. Discussion ................................................................................................................................................... 7 Appendix 1. List of effluent violations. ........................................................................................................... 1 ii COMPLIANCE EVALUATION INSPECTION REPORT Neptune Beach WWTF, Project # CV- FL0020427 - 12082022 1. Introduction On December 8, 2022, representatives of the United States Environmental Protection Agency Region 4 and the Florida Department of Environmental Protection (FDEP) conducted a Compliance Evaluation Inspection (CEI) on the Neptune Beach Wastewater Treatment Facility (WWTF), owned and operated by the City of Neptune Beach (City). The inspection was conducted under the authority of Section 308 of the Clean Water Act (CWA), as amended. This report provides a summary of the inspection. 2. Participants Name Dennis Sayre Adam Prestidge Stefen Wynn Colin Moore Herndon Sims Brian Cerny Herbert Johnson Ted Hughes Madison White MaryAnne Mills Organization EPA Region 4 City of Neptune Beach, Drinking Water/Wastewater (DW/WW) Division Chief City of Neptune Beach City of Neptune Beach FDEP FDEP FDEP FDEP FDEP FDEP email Sayre.Dennis@epa.gov wwchief@nbfl.us cm@nbfl.us colinmoore@nbfl.us Herndon.Sims@FloridaDEP.gov Brian.Cerny@FloridaDEP.gov Herbert.Johnson@FloridaDEP.gov Edward.CHughes@FloridaDEP.gov Madison.D.White@FloridaDEP.gov MaryAnne.M.Mills@FloridaDEP.gov 3. Facility Description The WWTF is an activated sludge wastewater treatment plant that consists of two biological treatment paths (Plant 1 and Plant 2), with common headworks, disinfection, and effluent disposal systems. The combined (Plant 1 and Plant 2) design capacity is 1.60 million gallons per day (MGD), according to the City's 2018 NPDES permit application. However, permitted capacity is limited to 0.90 MGD (discussed below in the Permit Review section) and the Outfall design capacity is limited to 1.40 MGD. Plant 1 and Plant 2 operate in parallel. Plant 1 is a 0.80 MGD design flow Integrated Fixed-Film Activated Sludge (IFAS) plant consisting of one Anoxic Tank, one IFAS Tank, two Secondary Clarifiers, and an Aerobic Digester. Plant 2 is an above ground package plant with two integrated tanks that was initially configured to operate as a contact stabilization plant or as an extended aeration plant. Plant 2 was not operational during the inspection due to ongoing efforts to rehabilitate and reconfigure the system to operate as a Modified Ludzak-Ettinger (MLE) process plant, which should enhance Plant 2's ability to treat for nutrients. The headworks consists of two mechanical screens following by grit removal equipment, an influent wet-well, two master lift stations (one station delivers to the Plant 1 and the other to the Plant 2), and two equalization tanks operating in series. 1 COMPLIANCE EVALUATION INSPECTION REPORT Neptune Beach WWTF, Project # CV- FL0020427 - 12082022 The effluent from both Plant's clarifiers is filtered through an Ultrascreen Microfilter before entering the Chlorine Contact Chamber. Disinfection is achieved using sodium hypchlorite and dechlorination is achieved using Sodium Bisulfate. The Chlorine Contact Chamber effluent dicharges into a 42,000-gallon Reuse Storage Basin, and one 2,000-gallon Hydro-pneumatic Tank prior to being discharged into the St. Johns River by the Effluent Pump and force main. Reuse water is currently only used internally within the WWTF. Figure 1: Aerial Display of the WWTF. 4. Inspection Procedures The overall objective of this CEI was to evaluate the condition and operational performance of the WWTF and the City's self-monitoring program and to offer compliance assistance as needed. Specific tasks included conducting interviews with WWTF staff, reviewing Discharge Monitoring Reports (DMRs) and other WWTF records, and conducting a site visit throughout the WWTF. 5. Findings & Conclusions The City has been in Significant Non-Compliance (SNC) for effluent limit exceedances of Total Nitrogen [as N] (TN) throughout the evaluation period for each month of December 2019 through December 2022. The WWTF was generally in good operational condition and appeared well maintained; Plant 2 was not operational and not evaluated. A. Permit Review The City's NPDES permit has an effective date of May 1, 2019, and an expiration date of April 30, 2024. The WWTF is classified as a major (greater that 1.0 MGD discharger); however it is currently limited in the NPDES permit to 0.90 MGD (Average Annual Daily Flow) (0.80 MGD for 2 COMPLIANCE EVALUATION INSPECTION REPORT Neptune Beach WWTF, Project # CV- FL0020427 - 12082022 the IFAS Plant 1 + 0.10 MGD for Plant 2) due to the nutrient removal capacities of the combined treatment facilities. The NPDES permit authorizes the City to upgrade Plant 2 to a Modified Ludzack-Ettinger process plant. Upon completion and placing into service, the permitted capacity of Plant 2 will increase to 0.45 MGD and the total (Plant 1 and 2) permitted capacity will be increased to 1.25 MGD. B. Records and Reports The EPA's Integrated Compliance Information System (ICIS) database shows the City to be in Significant Noncompliance for exceeding NPDES effluent limits for Total Nitrogen (TN). A complete list of effluent limit exceedances can be found in Appendix 1 for the period from December 2019 through December 2022 based on data compiled from DMRs. The City also exceeded effluent limits for Enterococci, Total Residual Chlorine, Whole Effluent Toxicity, and Total Phosphorus as outlined in Appendix 1. ICIS data can be reviewed on the EPA's Compliance History Online (ECHO)1 public website. The EPA further reviewed reported DMR values for TN loading reported in pounds/year (lb/yr) and calculated using a 12 month running total. Table 1 shows monthly load and total annual waste load allocations. Note the months of April 2020 and December 2022 were reported with an incorrect decimal place. No other reporting period total annual waste load calculations were affected by this error. Monitoring Parameter Period End Date Description 1/31/2020 Nitrogen, total [as N] 2/29/2020 Nitrogen, total [as N] 3/31/2020 Nitrogen, total [as N] 4/30/2020 Nitrogen, total [as N] 5/31/2020 Nitrogen, total [as N] 6/30/2020 Nitrogen, total [as N] 7/31/2020 Nitrogen, total [as N] 8/31/2020 Nitrogen, total [as N] 9/30/2020 Nitrogen, total [as N] 10/31/2020 Nitrogen, total [as N] 11/30/2020 Nitrogen, total [as N] 12/31/2020 Nitrogen, total [as N] 1/31/2021 Nitrogen, total [as N] Table 1. Reported TN values. Permit Limit Value (Annual totals lb/yr) 13559 13559 13559 13559 13559 13559 13559 19000 19000 19000 19000 19000 19000 DMR Reported Value (lb/yr) 18672 18719 18033 17.826 16975 16045 15267 15090 15085 15456 15401 15387 16149 DMR Reported Value (lb/mo) 1682 1739 1617 1289 826 693 692 810 877 1747 1635 1834 2444 1 https://echo.epa.gov 3 COMPLIANCE EVALUATION INSPECTION REPORT Neptune Beach WWTF, Project # CV- FL0020427 - 12082022 Monitoring Parameter Description Period End Date 2/28/2021 Nitrogen, total [as N] 3/31/2021 Nitrogen, total [as N] 4/30/2021 Nitrogen, total [as N] 5/31/2021 Nitrogen, total [as N] 6/30/2021 Nitrogen, total [as N] 7/31/2021 Nitrogen, total [as N] 8/31/2021 Nitrogen, total [as N] 9/30/2021 Nitrogen, total [as N] 10/31/2021 Nitrogen, total [as N] 11/30/2021 Nitrogen, total [as N] 12/31/2021 Nitrogen, total [as N] 1/31/2022 Nitrogen, total [as N] 2/28/2022 Nitrogen, total [as N] 3/31/2022 Nitrogen, total [as N] 4/30/2022 Nitrogen, total [as N] 5/31/2022 Nitrogen, total [as N] 6/30/2022 Nitrogen, total [as N] 7/31/2022 Nitrogen, total [as N] 8/31/2022 Nitrogen, total [as N] 9/30/2022 Nitrogen, total [as N] 10/31/2022 Nitrogen, total [as N] 11/30/2022 Nitrogen, total [as N] 12/31/2022 Nitrogen, total [as N] Table 1 (cont.): Reported TN values. Permit Limit Value (Annual totals lb/yr) 19000 19000 19000 19000 19000 19000 19000 19000 19000 19000 19000 19000 19000 19000 19000 19000 19000 19000 13559 13559 13559 13559 13559 DMR Reported Value (lb/yr) 16320 16947 18030.3 19167 20063 21587 22442 24020 24298 23686 23310 23952.2 25307 24947 26002 28009 30241 30498 30474.32 29845.24 29478.24 30402.88 30.612 DMR Reported Value (lb/mo) 1910 2245 2317.3 1962 1667 2135 1666 2457 2025 1023.67 1457 3085.36 3266 1884 3372 3969 3898 2393 1660.58 1827.92 1658.48 1948.31 2139 NPDES permit limit for TN is 13,559 lb/yr (total annual sum), however FDEPs Consent Order OGC File No. 20-0773, allowed an interim limit of 19,000 lb/yr for the duration of the initial Consent Order (discussed in the Discussion section of the report). C. Flow Measurement Influent and effluent flow is measured using magnetic flow meters. Effluent flow measured 0.61mgd (instantaneous reading). D. Sampling The composite samplers used for influent and effluent sampling are ISCO portable sampling units. Samples are collected for analysis by Advanced Environmental Laboratories, Inc. The EPA 4 COMPLIANCE EVALUATION INSPECTION REPORT Neptune Beach WWTF, Project # CV- FL0020427 - 12082022 reviewed the Chain of Custody (COC) sheet and subsequent lab report for enterococci grab samples collect on November 3 and 28, 2022, and for composite samples collected on November 4, 2022. The COC sheets include the sample collection time/date but does not have a box to indicate the begin time/date of the composite sampling, (Figure 1); however, the start time/date is recorded in the operator's log. Figure 1: Advanced Environmental Lab COC sheet cut-out. . Inspectors observed one of the WWTF's staff set up and test one of the portable composite samplers to verify that the equipment is pulling the correct amount of volume, or at least 100mL per pull. The sampler was set to pull 110mL samples but pulled a volume of 500mL. Post inspection correspondence with the City's DW/WW Division Chief shows that the City approved a purchase order for a stationary composite sampling unit (HACH model AS950) on December 9, 2022 for sampling effluent. Chronic Whole Effluent Toxicity sampling protocol in the permit is not consistent. Section I.1 stipulates that Chronic Whole Effluent Toxicity, 7-Day IC25 (Americamysis Bahia and Menidia Beryllina) is to be collected by grab sample. Whereas Section 1.A.19.c. (Sampling Requirements) states, "(1) For each routine test or additional follow-up test conducted, a total of three 24-hour, flow-composite samples of final effluent shall be collected and used in accordance with the sampling protocol discussed in EPA-821-R-02-014, Section 8." E. Site Visit (Operation and Maintenance) (All Photo references can be found in Appendix 2) A WWTF site visit concentrated on Plant 1 and common components of Plants 1 and 2 since Plant 2 was down for renovation. The WWTF appeared well maintained. All major systems were operational apart from Plant 2, unless otherwise stated below. The following observations were noted: There is an auxiliary generator located on-site that can provide power to continue to treat sewage in the event of a power outage. The generator is exercised every Tuesday under load. A MUNOX system was installed approximately one year ago. The MUNOX system injects nitrobacter bacteria into the waste stream to aid in nitrogen removal, (Photo 1). The influent composite sampler is a portable unit and appears to be in good condition, (Photo 2). This sampler was not tested for accuracy of volumetric pulls. Observed effluent composite sampler test described above, (Photo 3). Observed the following equipment/systems throughout the WWTF: o Headworks and grit removal system. 5 COMPLIANCE EVALUATION INSPECTION REPORT Neptune Beach WWTF, Project # CV- FL0020427 - 12082022 o Bleach pump room. The City is planning to replace the current single walled chlorine tanks with double walled tanks. o Return Activated Sludge (RAS) system. o MicroC system. The MicroC system injects a proprietary carbon source into the treatment train (at the RAS system) to augment Biochemical Oxygen Demand (BOD) removal during low BOD events, such as low flow conditions and wet weather conditions. o Waste Activated Sludge pump and pipes. o IFAS tank, (Photo 4 and 5). This IFAS uses free floating media (round balls) in the Mixed Liquor Suspended Solids (MLSS) in the activated sludge tank to facilitate biomass growth and strengthen the treatment process. Nitrobacter and other biomass clings to the balls to aid BOD removal and denitrification. The DW/WW Division Chief remarked that the media is due for change-out. The MLSS concentration is currently targeted at 2500 mg/L to facilitate higher Dissolved Oxygen levels that enables the plant to convert a higher amount of influent ammonia (NH3) to Nitrates (NO3). o The IFAS blowers consist of two main blowers and a supplemental (smaller) blower. The supplemental blower was recently added and is not yet operational. The supplemental blower was added to aid in Dissolved Oxygen (DO) content in the MLSS. Raising the DO level using the supplemental pump, once online, should allow the MLSS to maintain a higher concentration of 3000 to 3500 mg/L, allowing for a more efficient biomass. o The operator used a sludge-judge to measure the sludge depth in one of two clarifiers, (Photo 6). The sludge depth measured approximately 2 feet. o The Ultrascreen Microfilter, which is a 6-disc, 5-micron filter, removes solids from the effluent of the clarifiers prior to entering the Chlorine Contact Chamber. Disc back-wash is discharged into a dedicated tank for recirculating back into the WWTF. The discs require periodic change-out. The Microfilter system lacks redundancy. o The influent to the Chlorine Contact Chamber contained small floating particles, indicating that the Microfilter discs may be at or near the end of their service life, (Photo 7). There is a Reject Basin next to the Chlorine Contact Chamber that can be used to pump effluent back into the WWTF if the effluent is not treated sufficiently. F. Sludge Handling Waste sludge is collected in the Digester Tank. The City installed a new ProMix polymer system to aid in dewatering the sludge prior to mechanical dewatering. The City uses a 2-meter belt press to dewater sludge. Dewatered sludge is conveyed to a dumpster and periodically hauled to local landfills. Sludge hauling manifests are maintained on site. G. Effluent and Receiving Water The City is permitted to discharge effluent from Outfall D-001 to the St. Johns River as described above. The discharge at the end of the force main (into the river) is not accessible; however, the effluent in the Reuse Storage Basin prior to pumping into the force main appeared to be clear, viewed from the Chlorine Contact Chamber. 6 COMPLIANCE EVALUATION INSPECTION REPORT Neptune Beach WWTF, Project # CV- FL0020427 - 12082022 6. Discussion The FDEP issued the City a Consent Order (CO), OGC 20-0773, on August 11, 2020 (effective date), to address chronic effluent exceedances of TN. The CO requires the City to "submit a compliance plan (Plan) to meet final effluent limits for Total Nitrogen and all other parameters as specified in the Permit." The final compliance date in the CO is set to be two years of the effective date of this Order (or August 11, 2022), however, FDEP has drafted an Amended CO, as evidenced in a FDEP letter to the City dated November 11, 2022 (Subject: Department of Environmental Protection v. City of Neptune Beach, Facility ID No. FL0020427, OGC File No. 20-0773) that will extend the final compliance date, which is pending the City's signature. The DW/WW Division Chief informed the EPA that the delay in signing the document is due to City Manager vacancy. The previous City Manager signed the CO for the City on August 6, 2020 and has since vacated the position. The EPA recommends the following: Replace the Ultrascreen Microfilter discs to alleviate the floating fines observed in the Chlorine Contact Chamber, should, upon inspection, the discs be at the end of their service life. Work with FDEP to correct the Whole Effluent Toxicity sampling protocol in the NPDES permit. Submit corrections to the April 2020 and December 2022 TN, as shown in Table 1, to FDEP's e-reporting system, (this is a permit requirement). Communicate with the FDEP regarding signature authority for the Amended CO. Specifically, what other official of the City, other than the City Manager, can sign the document and what needs to be done to make that change in the draft Amended CO. Consider purchasing and installing an additional microfilter system to create redundancy in the treatment train. Redundant systems will reduce wear and tear on the mechanical components as well as increase the filter discs service life and provide a back-up to facilitate maintenance. Lack of redundancy may severely hamper operations in the event of a catastrophic failure. END OF REPORT 7 Appendix 1. List of effluent violations. Permit Limit Parameter Description Value Chlorine, total residual 0.5 (before Dechlor) Enterococci: group D, 35 MF trans, M-E, EIA Enterococci: group D, 140 MF trans, M-E, EIA IC25 Static Renewal 7 Day Chronic Menidia 100 menidia IC25 Static Renewal 7 Day Chronic 100 Mysidopsis bahia IC25 Static Renewal 7 Day Chronic 100 Mysidopsis bahia IC25 Static Renewal 7 Day Chronic Menidia 100 menidia Nitrogen, total [as N] 13559 Nitrogen, total [as N] 13559 Nitrogen, total [as N] 13559 Nitrogen, total [as N] 13559 Nitrogen, total [as N] 13559 Nitrogen, total [as N] 13559 Nitrogen, total [as N] 13559 Nitrogen, total [as N] 19000 Nitrogen, total [as N] 19000 Nitrogen, total [as N] 19000 Nitrogen, total [as N] 19000 Nitrogen, total [as N] 19000 Nitrogen, total [as N] 19000 Nitrogen, total [as N] 19000 Nitrogen, total [as N] 19000 Nitrogen, total [as N] 19000 Nitrogen, total [as N] 19000 Nitrogen, total [as N] 19000 Nitrogen, total [as N] 19000 Nitrogen, total [as N] 19000 Nitrogen, total [as N] 19000 Nitrogen, total [as N] 19000 Nitrogen, total [as N] 13559 Nitrogen, total [as N] 13559 Nitrogen, total [as N] 13559 Nitrogen, total [as N] 13559 Phosphorus, total [as P] 4015 Phosphorus, total [as P] 4015 Phosphorus, total [as P] 4015 Unit mg/L #/100mL #/100mL % % % % lb/yr lb/yr lb/yr lb/yr lb/yr lb/yr lb/yr lb/yr lb/yr lb/yr lb/yr lb/yr lb/yr lb/yr lb/yr lb/yr lb/yr lb/yr lb/yr lb/yr lb/yr lb/yr lb/yr lb/yr lb/yr lb/yr lb/yr lb/yr lb/yr Monitoring Fequency Monitoring Period End Date MIN 5day/wk 5/31/2021 MO GEO MEAN 5/31/2021 MO MAX 5/31/2021 MIN S/A 9/30/2022 MIN S/A 5/31/2020 MIN S/A 9/30/2022 MIN S/A 9/30/2022 Annual Total Annual Total Annual Total Annual Total Annual Total Annual Total Annual Total Annual Total Annual Total Annual Total Annual Total Annual Total Annual Total Annual Total Annual Total Annual Total Annual Total Annual Total Annual Total Annual Total Annual Total Annual Total Annual Total Annual Total Annual Total Annual Total Annual Total Annual Total Annual Total 12/31/2019 1/31/2020 2/29/2020 3/31/2020 5/31/2020 6/30/2020 7/31/2020 5/31/2021 6/30/2021 7/31/2021 8/31/2021 9/30/2021 10/31/2021 11/30/2021 12/31/2021 1/31/2022 2/28/2022 3/31/2022 4/30/2022 5/31/2022 6/30/2022 7/31/2022 8/31/2022 9/30/2022 10/31/2022 11/30/2022 5/31/2022 6/30/2022 7/31/2022 DMR Reported Value 0.3 163 200 37.05 44.47 74.17 37.05 18541 18672 18719 18033 16975 16045 15267 19167 20063 21587 22442 24020 24298 23686 23310 23952.2 25307 24947 26002 28009 30241 30498 30474.32 29845.24 29478.24 30402.88 4231 4060 4149 % Exceeded Violation Severity 40 Noncompliance Effluent Violation 366 Noncompliance Effluent Violation 43 Noncompliance Effluent Violation 63 Noncompliance Effluent Violation 56 Noncompliance Effluent Violation 26 Noncompliance Effluent Violation 63 Noncompliance Effluent Violation 37 Significant Noncompliance Effluent Violation 38 Significant Noncompliance Effluent Violation 38 Significant Noncompliance Effluent Violation 33 Significant Noncompliance Effluent Violation 25 Significant Noncompliance Effluent Violation 18 Significant Noncompliance Effluent Violation 13 Significant Noncompliance Effluent Violation 1 Significant Noncompliance Effluent Violation 6 Significant Noncompliance Effluent Violation 14 Significant Noncompliance Effluent Violation 18 Significant Noncompliance Effluent Violation 26 Significant Noncompliance Effluent Violation 28 Significant Noncompliance Effluent Violation 25 Significant Noncompliance Effluent Violation 23 Significant Noncompliance Effluent Violation 26 Significant Noncompliance Effluent Violation 33 Significant Noncompliance Effluent Violation 31 Significant Noncompliance Effluent Violation 37 Significant Noncompliance Effluent Violation 47 Significant Noncompliance Effluent Violation 59 Significant Noncompliance Effluent Violation 61 Significant Noncompliance Effluent Violation 125 Significant Noncompliance Effluent Violation 120 Significant Noncompliance Effluent Violation 117 Significant Noncompliance Effluent Violation 124 Significant Noncompliance Effluent Violation 5 Noncompliance Effluent Violation 1 Noncompliance Effluent Violation 3 Noncompliance Effluent Violation COMPLIANCE EVALUATION INSPECTION REPORT Neptune Beach WWTF, Project # CV- FL0020427 - 12082022 Appendix 2: Photo Log Photo 1. MUNOX system storage tank and supply pump. Photo 2: Portable ISCO composite sampler located at the Headworks. Photo 3. Effluent composite sampler test. 2 COMPLIANCE EVALUATION INSPECTION REPORT Neptune Beach WWTF, Project # CV- FL0020427 - 12082022 Photo 4. IFAS re-aeration zone. Photo 5. IFAS post anoxic zone and re-aeration zone. 3 COMPLIANCE EVALUATION INSPECTION REPORT Neptune Beach WWTF, Project # CV- FL0020427 - 12082022 Photo 6. Sludge judge measuring the sludge blanket depth at approximately 2 feet off the bottom of the clarifier. Photo 7. Influent of the Chlorine Contact Chamber. Note small floating particles. 4