Document omgKDp0rLqZeOYYXbB6kkbkw7
COMPLIANCE EVALUATION INSPECTION REPORT U.S. ENVIRONMENTAL PROTECTION AGENCY, REGION 5
Purpose: NPDES Compliance Evaluation Inspection
Facility: Village of Onarga Sewage Treatment Plant 658 East 1600 North Township Road Onarga, Illinois 60955
NPDES Permit: IL0075108
Date of Inspection: July 26, 2022
EPA Inspectors: Val Dooling, Environmental Engineer, (312) 886-7167
Illinois EPA Inspector: Jeffrey Holste, Illinois EPA, (217) 278-5828
Facility Representative: Kevin Newman, Director of Public Works, (815) 471-7680
Report Prepared By: Val Dooling, Environmental Engineer
EPA Inspector Signature and Date:
VALERIE
Digitally signed by VALERIE DOOLING
_D__O_O__L_IN__G_____D16a_:t3e_8: :2_207_2-20_.50'_90.01_'6________________________
Approver Name and Title: Ryan J. Bahr, Section 2 Supervisor Water Enforcement and Compliance Assurance Branch
Approver Signature and Date:
Digitally signed by Bahr,
Bahr,
Ryan
Ryan Date: 2022.09.19
______________10_:5_2:_15_-_05_'00_' ________________________
TABLE OF CONTENTS I. INTRODUCTION ....................................................................................................................... 1 II. BACKGROUND........................................................................................................................ 1 III. OPENING CONFERENCE...................................................................................................... 3 IV. FACILITY DISCUSSION........................................................................................................ 3 V. SITE VISIT ................................................................................................................................ 4 VI. CLOSING CONFERENCE...................................................................................................... 5
LIST OF APPENDICES Appendix A: Photo Log Appendix B: Aerial Facility Image Appendix C: NPDES Permit IL0076813
Village of Onarga CEI Inspection - July 26, 2022
I. INTRODUCTION The purpose of the report is to describe, evaluate and document Village of Onarga Sewage Treatment Plant (STP)'s compliance with the Clean Water Act (CWA) and its National Pollutant Discharge Elimination System (NPDES) permit at its facility.
II. BACKGROUND The Village of Onarga holds NPDES Permit IL0076813 (Permit) for the Village of Onarga STP (Facility). The permit was effective September 1, 2018 and expires August 31, 2023. The facility discharges to an unnamed tributary to Spring Creek. The Onarga STP was designed as a 0.25 million gallon per day two-cell sequential batch reactor (SBR), with two aerated sludge tanks and two sludge filter beds. In 2014, EPA issued an Administrative Order (Order) to the Village of Onarga under Section 309(a) of the CWA which cited 155 effluent limit permit violations between January 2011- January 2014 for carbonaceous biochemical oxygen demand (CBOD), ammonia-nitrogen, total suspended solids (TSS) and dissolved oxygen. According to communication received in 2014, in response to the Order, the facility received a much lower flow than its design parameters and the North SBR was modified to act as an aerated equalization tank and the South SBR unit was converted to a single batch SBR.
Table 1 lists 55 Permit effluent limit exceedances occuring between May 2019 and July 2022 for fecal coliform, total suspended solids, ammonia nitrogen and CBOD. At the time of the original construction, the facility received a disinfection exemption from Illinois EPA (IEPA), which was revoked in 2013. The current Permit lists fecal coliform limits between May and October and at the time of the inspection there was no disinfection treatment at the facility. In February 2022, the Village of Onarga submitted to IEPA a Proposed Project Plan for Wastewater treatment plant upgrades which consisted of a grit removal and screening package plant, air release manhole and influent manhole relocation, replacement piping at the SBR and chlorine tank disinfection treatment. The plan expects construction of the upgrades to occur between November 2023 and September 2024.
1
Village of Onarga CEI Inspection - July 26, 2022
Monitoring
Period End
7/31/2022 6/30/2022 5/31/2022 4/30/2022 3/31/2022 3/31/2022 3/31/2022 3/31/2022 2/28/2022 1/31/2022 1/31/2022 1/31/2022 12/31/2021 9/30/2021 9/30/2021 8/31/2021 7/31/2021 6/30/2021 5/31/2021 5/31/2021 5/31/2021 3/31/2021 3/31/2021 3/31/2021 2/28/2021 2/28/2021 2/28/2021 11/30/2020 10/31/2020 10/31/2020 10/31/2020 10/31/2020 9/30/2020 8/31/2020 7/31/2020 6/30/2020 5/31/2020 1/31/2020 1/31/2020 10/31/2019 10/31/2019 10/31/2019 9/30/2019 9/30/2019 8/31/2019 8/31/2019 7/31/2019 7/31/2019 6/30/2019 6/30/2019 6/30/2019 5/31/2019 5/31/2019 5/31/2019 5/31/2019
Parameter
Coliform, fecal general Coliform, fecal general Coliform, fecal general Solids, total suspended Solids, total suspended Nitrogen, ammonia total [as N] Nitrogen, ammonia total [as N] Nitrogen, ammonia total [as N] Solids, total suspended Solids, total suspended Solids, total suspended Solids, total suspended Solids, total suspended Solids, total suspended Coliform, fecal general Coliform, fecal general Coliform, fecal general Coliform, fecal general Solids, total suspended Solids, total suspended Coliform, fecal general Nitrogen, ammonia total [as N] Nitrogen, ammonia total [as N] Nitrogen, ammonia total [as N] Solids, total suspended Nitrogen, ammonia total [as N] Nitrogen, ammonia total [as N] BOD, carbonaceous [5 day, 20 C] Solids, total suspended Solids, total suspended Nitrogen, ammonia total [as N] Coliform, fecal general Coliform, fecal general Coliform, fecal general Coliform, fecal general Coliform, fecal general Coliform, fecal general Solids, total suspended BOD, carbonaceous [5 day, 20 C] Solids, total suspended Solids, total suspended Coliform, fecal general Solids, total suspended Coliform, fecal general Solids, total suspended Coliform, fecal general Solids, total suspended Coliform, fecal general Solids, total suspended Solids, total suspended Coliform, fecal general Solids, total suspended Solids, total suspended Solids, total suspended Coliform, fecal general
Table 1
Limit Description
Daily M aximum Daily M aximum Daily M aximum M onthly Average M onthly Average Weekly Average M onthly Average Daily M aximum M onthly Average M onthly Average M onthly Average Daily M aximum Daily M aximum M onthly Average Daily M aximum Daily M aximum Daily M aximum Daily M aximum Daily M aximum M onthly Average Daily M aximum Daily M aximum M onthly Average Weekly Average M onthly Average Daily M aximum M onthly Average Daily M aximum Daily M aximum M onthly Average M onthly Average Daily M aximum Daily M aximum Daily M aximum Daily M aximum Daily M aximum Daily M aximum Daily M aximum Daily M aximum M onthly Average Daily M aximum Daily M aximum M onthly Average Daily M aximum Daily M aximum Daily M aximum M onthly Average Daily M aximum Daily M aximum M onthly Average Daily M aximum M onthly Average M onthly Average Daily M aximum Daily M aximum
Permit
Limit
400 400 400 12 12 3.8 1.5 4.7 12 12 88 24 24 12 400 400 400 400 24 12 400 4.7 1.5 3.8 12 4.7 2.6 20 24 12 1.5 400 400 400 400 400 400 24 20 12 24 400 12 400 24 400 12 400 24 12 400 88 12 24 400
Reported
DMR Value
2420 1120 2420
15 14 13 13 20 15 16 93 28 36.8 13 2420 2420 2420 1050 31 15 72420 19 9.3 19 14 15 9.7 24 37 22 1.75 2420 2420 2420 2420 2420 2420 29 23 22 39 6900 13 6160 26 48400 13 48350 35 14 14540 792 13 35 14540
Unit
#/100mL #/100mL #/100mL
mg/L mg/L mg/L mg/L mg/L mg/L mg/L lb/d mg/L mg/L mg/L #/100mL #/100mL #/100mL #/100mL mg/L mg/L #/100mL mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L #/100mL #/100mL #/100mL #/100mL #/100mL #/100mL mg/L mg/L mg/L mg/L #/100mL mg/L #/100mL mg/L #/100mL mg/L #/100mL mg/L mg/L #/100mL lb/d mg/L mg/L #/100mL
Percent
Exceedence
605 280 605 125 117 342 867 426 125 133 106 117 153 108 605 605 605 263 129 125 18105 404 620 500 117 319 373 120 154 183 117 605 605 605 605 605 605 121 115 183 163 1725 108 1540 108 12100 108 12088 146 117 3635 900 108 146 3635
2
Village of Onarga CEI Inspection - July 26, 2022
III. OPENING CONFERENCE On July 27, 2022 I (EPA) met with Jeffrey Holste of Illinois EPA (IEPA) at the Village of Onarga STP at 1:10pm. EPA showed credentials to Kevin Newman, the Director of Public Works. EPA explained that it would take photographs as part of the inspection and asked if anything discussed was Confidential Business Information and he responded that it was not.
IV. FACILITY DISCUSSION Mr. Newman took his position in May 2022 after the previous Director of Public Works retired. At the time of inspection, Mr. Newman is the only operator of the Village of Onarga STP and he stated that there is not a backup employee who can run the treatment plant on weekends and holidays. The Village also has a certified operator, who was not present at the inspection, but will be at the plant throughout the week and signs discharge monitoring reports (DMRs). Mr. Newman was not aware that EPA had an existing Administrative Order with the Village of Onarga since 2014 and earlier in 2022 had proposed a replacement Administrative Order on Consent.
Mr. Newman noted that high TSS and BOD occur in March and April when the weather switches. He stated when the ground thaws there is a lot of sand and dirt from groundwater infiltration. He stated that every residential connection in Onarga has a sewage grinder system (Photos 1 and 2). This system was originally installed by a contractor with a thin gasket on the pipe which can roll and not provide a sufficient seal so there is sand and dirt infiltration to the collection system. The public works department replaced the gaskets on each basin for nearly every residential connection. There are a total of approximately 500 residential connections with the grinder system, and only 10-15 still need a replacement gasket, but the record of which have been replaced is not kept. In addition to the gaskets, all the pumps on the grinders are 12 years old and Mr. Newman estimates that the pumps have a10-to-15-year lifespan. When a grinder motor needs to be rebuilt, Mr. Newman does keep a log to determine which residence it was taken from.
The facility does not keep written Standard Operating Procedures or written Operations and Maintenance manuals. In order to determine maintenance needs, Mr. Newman will walk through the treatment plant daily to ensure good working order. If repairs are needed, he will place a request with the City Engineer who requests it from the Board of Directors. There is not a documented maintenance or repair log.
The facility does not have an influent screen installed currently, and Mr. Newman states that rags keep jamming the motors. He will use a pool skimmer once a week to collect rags and debris from the north equalization tank. At the time of the inspection, one of the sludge aeration holding tank motors was not operational because it had been jammed by rags. According to Mr. Newman, the facility goes through a motor a year which costs approximately $2000 to $10,000 each time. He expects the bar screens on the new proposal to solve this issue.
I requested information on how the plant was operated and if there is still an issue with foam. Mr. Newman stated that foam is not an issue and attributes that to a decrease in sludge age. He
3
Village of Onarga CEI Inspection - July 26, 2022
keeps the aeration basin as its lowest level possible and keeps approximately two feet of sludge in the north basin. He pumps sludge from the south SBR tank to the north equalization tank approximately once a week and usually bases the frequency on the settleability and color of the foam. Mr. Newman stated that he is not able to meet the effluent limits without this step. Mr Newman states that there was some surging and would like to add another air release valve. This is part of the proposed upgrades plan.
Influent flow is measured at the manhole by a mag-meter. Mr. Newman collects composite influent samples by filling up a bottle one-third full at a spicket after the mag meter (Photo 7). The effluent samples are collected at the receiving stream in the same manner. IEPA stated that the permit requires the composite samples to be collected in 100ml aliquots over an eight-hour time period. Mr. Newman expressed difficulty with this collection since the SBR cycles five times daily and the facility does not have a continuous effluent flow. The facility has already purchased a new autosampler which is in the warehouse and has never been used. The warehouse also contains a new incubator and desiccation equipment, although TSS and BOD are not analyzed on site.
The facility ships its samples to Pace Analytical Services in Peoria for analysis including its fecal coliform sample. IEPA noted that the fecal coliform has a 6 hour hold time and it may exceed its hold time if it is shipped. Mr. Newman also stated that he uses a YSI dissolved oxygen (DO) and Hach pH probe for on-site sampling of DO and pH and follows the instructions to calibrate prior to sample analysis. The DO and pH measurements are recorded on the laboratory results and filed onsite with DMRs.
V. SITE VISIT At 2:21pm, EPA, IEPA and Mr. Newman began to walk the facility premises starting at the influent, continuing to the north equalization tank, south SBR basin then the aerated sludge holding tanks and sludge drying beds, the receiving stream and ending at the dried sludge storage pile.
At the manhole where influent flow is measured by a mag-meter, Mr. Newman stated that the flow device is grounded with a lightning rod that had been installed after a prior lightning strike (Photo 6). At the north equalization tank, Mr. Newman stated that the aeration and mixing in the same tank results in some oxidated and anoxic zones. When EPA noted floating solids in the equalization tank (Photo 11), Mr. Newman stated that it was the result of intentionally pumping sludge into the equalization tank. At the south SBR tank, Mr. Newman pointed out some floating plastic which is not prevented from entering the system, since there is no screening system (Photo 10).
At the aerated sludge holding tanks, Mr. Newman noted that only one of the tanks was operational (Photos 12 and 13), and the other tank was not operational because the motor had been jammed by rags (Photo 15). At the sludge drying beds, Mr. Newman stated that sludge from one of the drying beds had just been removed to the storage piles two weeks ago (Photos 16 and 17). Mr. Newman stated that he used ashes from a compost burn to create a C-shaped berm around the sludge (Photos 22 and 23). The berm and sludge piles were located north of a compost area which was north of the facility.
4
Village of Onarga CEI Inspection - July 26, 2022
At the receiving stream, Mr. Newman explained how an effluent sample was collected in a bucket when the SBR was discharging (Photo 21). Mr. Newman also identified an effluent manhole which had previously been used for effluent sample collection. The facility tour ended at 3:10 pm. VI. CLOSING CONFERENCE EPA noted the following areas of concern:
1. The facility has numerous effluent exceedances as stated in Table 1. It has not been in compliance for fecal coliform and does not disinfect. 2. The facility does not have an influent screen and has had to repair and replace motors yearly due to rags at the treatment facility. There were plastic bits in the treatment unit. The Village of Onarga only has one full time operator. 40 Code of Federal Regulations (CFR) 122.41(e) states that the permittee shall at all times properly operate and maintain all facilities and systems of treatment and control. 3. The Permit does not specify whether 24-hour, 8 hour or flow proportional composite samples must be used. 40 CFR 122.21(j)(4)(viii) states 24-hour composite samples must be used. The facility collects composite samples with three aliquots. 4. The hold time on the fecal coliform samples may have been exceeded. EPA concluded the inspection, thanked Mr. Newman, and left the facility at 3:24 pm.
5
Village of Onarga CEI Inspection - July 26, 2022
Appendix A: Inspection Photo Log Village of Onarga
EPA Inspection July 26, 2022 All photos taken by Val Dooling, Environmental Engineer, U.S. EPA
Camera: RICOH WG-4 GPS
1: ONGA0284 Description: Spare basin from a residential sewage grinder system. Location: Warehouse storage Date/Time: July 26, 2022 1:37PM
A1
Village of Onarga CEI Inspection - July 26, 2022
2: ONGA0285 Description: Example of fixed gasket on basin as part of the residential sewage grinder system. Location: Warehouse storage Date/Time: July 26, 2022 1:38PM
A2
Village of Onarga CEI Inspection - July 26, 2022
3: ONGA0286 Description: Used grinders that are part of the residential sewage grinder system which have been removed and rebuilt. Location: Warehouse storage Date/Time: July 26, 2022 1:38PM
A3
Village of Onarga CEI Inspection - July 26, 2022
4: ONGA0287 Description: Original parameters for 2011 treatment plant as designed. Camera Direction: Down Date/Time: July 26, 2022 1:52PM
A4
Village of Onarga CEI Inspection - July 26, 2022
5: ONGA0288 Description: Origianl drawings for 2011 treatment plant as designed. Camera Direction: Down Date/Time: July 26, 2022 1:53PM
A5
Village of Onarga CEI Inspection - July 26, 2022
6: ONGA0289 Description: Influent flow meter manhole. Influent flow is measured by mag-meter. GPS Latitude: 40 44' 22" GPS Longitute: 88 0' 6" Camera Direction: South Date/Time: July 26, 2022 2:33PM
A6
Village of Onarga CEI Inspection - July 26, 2022
7: ONGA0290 Description: East wall of the SBR tanks. The spicket is where the influent sample is collected. GPS Latitude: 40 44' 22" GPS Longitute: 88 0' 6" Camera Direction: West Date/Time: July 26, 2022 2:34PM
A7
Village of Onarga CEI Inspection - July 26, 2022
8: ONGA0291 Description: North SBR unit which is functioning as an aerated equilization tank. GPS Latitude: 40 44' 22" GPS Longitute: 88 0' 9" Camera Direction: West Date/Time: July 26, 2022 2:36PM
A8
Village of Onarga CEI Inspection - July 26, 2022
9: ONGA0292 Description: Walkway between SBR units. Trip hazard pipe was installed when the North SBR tank was modified to an equilization tank and is expected to be removed as part of the proposed plan. GPS Latitude: 40 44' 22" GPS Longitute: 88 0' 9" Camera Direction: West Date/Time: July 26, 2022 2:36PM
A9
Village of Onarga CEI Inspection - July 26, 2022
10: ONGA0293 Description: South SBR side of unit was in a settling phase at this time of inspection. Note bits of plastic on surface. GPS Latitude: 40 44' 24" GPS Longitute: 88 0' 13" Camera Direction: South Date/Time: July 26, 2022 2:42PM
A10
Village of Onarga CEI Inspection - July 26, 2022
11: ONGA0294 Description: North SBR tank which is used as an equilization tank. Layer of floating solids on surface due to sludge pumped from South SBR tank. GPS Latitude: 40 44' 24" GPS Longitute: 88 0' 13" Camera Direction: North Date/Time: July 26, 2022 2:43PM
A11
Village of Onarga CEI Inspection - July 26, 2022
12: ONGA0295 Description: South end of the operational sludge aeration tank. GPS Latitude: 40 44' 21" GPS Longitute: 88 0' 6" Camera Direction: South Date/Time: July 26, 2022 2:44PM
A12
Village of Onarga CEI Inspection - July 26, 2022
13: ONGA0296 Description: North end of the operational aerated sludge holding tank. GPS Latitude: 40 44' 21" GPS Longitute: 88 0' 6" Camera Direction: North Date/Time: July 26, 2022 2:44PM
A13
Village of Onarga CEI Inspection - July 26, 2022
14: ONGA0297 Description: South SBR unit. GPS Latitude: 40 44' 21" GPS Longitute: 88 0' 7" Camera Direction: East Date/Time: July 26, 2022 2:48PM
A14
Village of Onarga CEI Inspection - July 26, 2022
15: ONGA0298 Description: Aerated sludge holding tank that was not working and smells septic. GPS Latitude: 40 44' 21" GPS Longitute: 88 0' 7" Camera Direction: North Date/Time: July 26, 2022 2:51PM
A15
Village of Onarga CEI Inspection - July 26, 2022
16: ONGA0299 Description: Dried sludge filter bed full. GPS Latitude: 40 44' 21" GPS Longitute: 88 0' 7" Camera Direction: West Date/Time: July 26, 2022 2:51PM
A16
Village of Onarga CEI Inspection - July 26, 2022
17: ONGA0300 Description: Dried sludge filter bed. This bed was emptied two weeks ago. GPS Latitude: 40 44' 20" GPS Longitute: 88 0' 6" Camera Direction: West Date/Time: July 26, 2022 2:53PM
A17
Village of Onarga CEI Inspection - July 26, 2022
18: ONGA0301 Description: Pre-saturation tank manhole. GPS Latitude: 40 44' 21" GPS Longitute: 88 0' 6" Camera Direction: Down Date/Time: July 26, 2022 2:55PM
A18
Village of Onarga CEI Inspection - July 26, 2022
19: ONGA0302 Description: RAS/WAS pump manhole. GPS Latitude: 40 44' 21" GPS Longitute: 88 0' 7" Camera Direction: Down Date/Time: July 26, 2022 2:57PM
A19
Village of Onarga CEI Inspection - July 26, 2022
20: ONGA0303 Description: Effluent meter manhole. Samples used to be taken at this point, but not currently. GPS Latitude: 40 44' 21" GPS Longitute: 88 0' 7" Camera Direction: Down Date/Time: July 26, 2022 2:58PM
A20
Village of Onarga CEI Inspection - July 26, 2022
21: ONGA0304 Description: Effluent discharge point at unnamed ditch tributarty to Spring Creek. Effluent samples are collected at this location. Note fish in the water. GPS Latitude: 40 44' 22" GPS Longitute: 88 0' 7" Camera Direction: Northwest Date/Time: July 26, 2022 3:00PM
A21
Village of Onarga CEI Inspection - July 26, 2022
22: ONGA0305 Description: Ash berm on the left in C-shape at dry sludge holding area. GPS Latitude: 40 44' 23" GPS Longitute: 88 0' 6" Camera Direction: West Date/Time: July 26, 2022 3:04PM
A22
Village of Onarga CEI Inspection - July 26, 2022
23: ONGA0306 Description: Dried sludge in the holding area within the C-shaped berm. GPS Latitude: 40 44' 23" GPS Longitute: 88 0' 6" Camera Direction: North Date/Time: July 26, 2022
A23
Village of Onarga CEI Inspection - July 26, 2022
Appendix B: Aerial Image
Note: Aerial image from Google Earth obtained September 6, 2022. Image does not represent conditions observed and is only to be used as a reference.
B-1
Village of Onarga CEI Inspection - July 26, 2022
Appendix C: NPDES Permit IL0075108
C-1
Village of Onarga CEI Inspection - July 26, 2022
C-2
Village of Onarga CEI Inspection - July 26, 2022
C-3
Village of Onarga CEI Inspection - July 26, 2022
C-4
Village of Onarga CEI Inspection - July 26, 2022
C-5
Village of Onarga CEI Inspection - July 26, 2022
C-6
Village of Onarga CEI Inspection - July 26, 2022
C-7
Village of Onarga CEI Inspection - July 26, 2022
C-8
Village of Onarga CEI Inspection - July 26, 2022
C-9
