CC 2012-12-11 Items Rec'd at Mtg. -4, ev.d iiiii(rz,
CSI: Center for Sludge Information / . Q. .
Advocacy through Acquisition,Analysis and Articulation of Information re:
Land Application of Sewage Sludge
6604 Portola Rd.,Atascadero,Calif.93422
ph# (805) 466-0352,email: csi @thegrid.net
to: Arroyo Grande City Council
Grover Beach City Council
Oceano Community Services District
re: Unsatisfactory Sewage Sludge Storage at SSLOCSD
• USEPA Compliance Evaluation Inspection (CEI) Report
• CCRWQCB Investigation
date: 12-9-12
On 3-14-12, a USEPA contactor conducted an investigation of the South San Luis
Obispo County Sanitation District's sewage treatment plant, and found the method
of sewage sludge storage unsatisfactory as a potential source of groundwater
contamination, (available on request). Sewage sludge is dumped directly on the
ground outside the centrifuge building, in violation of the plant's permit.
On 12-3-12, I visited the site and took photographs from without and within the
plant demonstrating that centrifuge-ejected sewage sludge, dumped directly on the
ground, is co-mingling with pooled surface water.
This practice must be immediately discontinued. The SSLOCSD must
immediately place a trailer under the centrifuge auger chute to prevent sewage
sludge contact with the ground, and speed up the removal schedule.
Please exercise your responsibility by making the authority and funding available
to install a trailer under the SSLOCSD's centrifuge auger chute, and initiate more
frequent sewage sludge removal.
Please place this matter on your next agenda. Refer to the SSLOCSD website
(http://sslocsd.org/) to acquire its 12-5-12 Agenda and Board Packet.
Below: CSI letter to SSLOCSD on 12-5-12.
to: South San Luis Obispo County Sanitation District Board of Directors
re: 12-5-12 Agenda Item 5-A - NPDES Compliance Evaluation Inspection (CEI)
Report: Unsatisfactory Rating
• Sewage Sludge Storage Deficiencies & Remediation
date: 12-5-12
It is imperative that the SSLOCSD immediately cease storing sewage sludge
directly on ground adjacent to the Arroyo Grande Creek levee.
The proximity of the sewage sludge storage area to Arroyo Grande Creek
presents the potential for chronic leaching of contaminants into the associated
groundwater system. The possibility of levee breaches near the sewage plant
present the potential for acute contamination of the downstream environment.
•
CSI examined the US EPA/CCRWQCB CEI Report, and visited and photographed
the site on 12-3-12, from without and within the plant. It is evident that sewage
sludge is mixing with pooled surface water in the storage area, as demonstrated by
the photos below.
(note date on photos 12-2-12 is wrong - correct date is 12-3-12)
Sewage Sludge Dumped on Ground - from creek levee:
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Sewage Sludge Pile under Centrifuge Auger Chute - from inside plant
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Sewage Sludge Pile adjacent to Pool of Water - from inside plant
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The 12-5-12 Superintendent's Report (Agenda item #4) relates a desire to place
a trailer under the centrifuge auger chute to prevent sewage sludge contact with
the soil surface. This should be accomplished as soon as possible, before more
rains. This should not wait until summer, as suggested in the Superintendent's
Report.
The District Administrator's 12-5-12 Staff Report regarding the 3-14-12 CET
Report states, "A Major Budget item for a new lagoon lining is currently included in
the current FY 2012-13 budget but was delayed because of the construction of a
retaining wall in the lagoon area...". The Staff Report also states, "a new concept
for the lining project has been suggested by operations staff... a concrete loading
area for the centrifuge to dump directly into standby trailers that will be hauled out
when filled. This project's concept is being reviewed by Staff and will be brought to
the Board for authorization to proceed after the first of the year.". Action on this
matter should be prioritized to speed up the time line for completion as soon as
possible.
The Staff Report also states, "The follow-up action recommended by the EPA is
to rate SSLOCSD as a 'Two (2)' or Medium priority ('paperwork and minor
deficiencies') for follow-up". This rating is included in the 5-21-12 PG
Environmental letter to the CCRWQCB in Table 1, as "Rating 2 - Medium Priority
Follow-up". This letter also describes "Rating 1-High - Identified deficiencies
threaten human health and environment, high priority for a follow-up inspection by
Regional Board inspectors.". The SSLOCSD should act on this matter as if the
deficiencies received a Rating 1-High.
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The CEI Report lists two items under the heading "Major Findings", one of
which pertains to sewage sludge storage (page 3):
Biosolids / Solid Waste Handling & Disposal
1. Central Coast Water Board Order No. R3-2009-0046, Section VI.C.5.a
requires that solids and sludge treatment, storage, and disposal or reuse
shall not create a nuisance, and shall not result in groundwater
contamination. Biosolids did not appear to be adequately stored and
contained, and resulted in a possible threat for groundwater contamination.
The Discharger was not storing the biosolids processed by the centrifuge
on the engineered drying beds, as stated in the permit. Rather, piles of
biosolids from the centrifuge system were stored on a porous surface;
located adjacent to the Arroyo Grande Creek levee, and approximately 45
yards north of Arroyo Grande Creek (refer to Photos 3 through 5). The
primary on-site Facility representative stated that since the installation of
the centrifuge, the drying beds are no longer necessary and are maintained
as backup to the centrifuge. He also stated there are plans to pave the
biosolids storage area, but no timeline has been set.
The CEI Report contains the "Unsatisfactory" rating for sewage sludge storage
(page 18):
BIOSOLIDS/SOLID WASTE HANDLING AND DISPOSAL: OVERALL RATING: U
4. Storage at Facility:
b. Controls leachate, runoff, and public access U
4b. Biosolids are stored on a porous soil surface, and
have the potential to contaminate groundwater (refer to
Photos 3 through 5). Refer to the 'Major Findings -
Biosolids/Solid Waste Handling and Disposal' section of
this report for details.
Notes:
This section was rated "unsatisfactory" due to checklist item
4b.
The SSLOCSD should rate this matter as a high priority, immediately cease
dumping sewage sludge on the ground, place a trailer under the centrifuge auger
chute, and proceed to prepare the storage area with an impervious surface as soon
as possible.
David Broadwater
CSI - Center for Sludge Information
Atascadero