Loading...
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: M i 7-. r• _______________t ' r -—f_LT tf. 4 , i r i r - - ".iRrC - .. Sewage Sludge Pile under Centrifuge Auger Chute - from inside plant Ae No' +fit .e r Sewage Sludge Pile adjacent to Pool of Water - from inside plant emf...♦ �1yra ' `.. • _4•..' tit r� S� ; i- ' .•, •v e _ r r-•... • ' t,31K.91 — j •C'.. . 'Yr-». • ..t 1. Y\M r y'VY. �.+ it wh ` 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. p k 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