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FACT SHEET and NPDES WASTEWATER DISCHARGE PERMIT EVALUATION

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FACT SHEET and NPDES WASTEWATER DISCHARGE PERMIT EVALUATION FACT SHEET And NPDES WASTEWATER DISCHARGE PERMIT EVALUATION Department of Environmental Quality Western Region - Salem Office 750 Front Street NE, Suite 120, Salem, OR 97301-1039 Telephone: (503) 378-8240 PERMITTEE: City of Falls City PO Box 160 Falls City, OR 97344 File Number: 28830 SOURCE LOCATION: Four miles east of Hwy 223 behind High School, Falls City, Oregon SOURCE CONTACT: Don Poe Telephone Number: 503-787-3631 PERMIT WRITER: Robert A. Dicksa Telephone Number: 503-378-5039 PROPOSED ACTION: Renewal of a National Pollutant Discharge Elimination System (NPDES) wastewater discharge permit SOURCE CATEGORY: Minor Domestic TREATMENT SYSTEM CLASS: Level I COLLECTION SYSTEM CLASS: Level I PERMIT APPLICATION DATE: January 28, 2005 PERMIT APPLICATION NUMBER: 982344 BACKGROUND Introduction The City of Falls City operates a wastewater treatment facility located in Falls City, Oregon (See Figure 1). Wastewater is treated and discharged to Little Luckiamute River in accordance with National Pollutant Discharge Elimination System (NPDES) Permit number 101808. The Permit for the facility was issued on May 19, 2000 and expired on January 31, 2005. The Department received a renewal application on January 28, 2005. The permit shall not be deemed to expire until final action has been taken on the renewal applications as per Oregon Administrative Rules (OAR) 340-045-0040. A renewal permit is necessary to discharge to state City of Falls City Evaluation Report Page 2 waters pursuant to provisions of Oregon Revised Statutes (ORS) 468B.050 and the federal Clean Water Act. The Department proposes to renew the permit. This permit evaluation report describes the basis and methodology used in developing the permit. This permit is a joint federal and state permit and subject to federal and state regulations. The Clean Water Act, the Code of Federal Regulations, and numerous guidelines of the Environmental Protection Agency provide the federal permit requirements. The Oregon Revised Statutes, Oregon Administrative Rules, and policies and guidelines of the Department of Environmental Quality provide the state permitting requirements. Facility Description The major treatment process used is the Recirculating Gravel Filter. The treatment facility consists of a main pump station, a 49,000 gallon recirculation tank, a 87 square foot recirculating Gravel Filter (RGF), an ultraviolet (UV) light disinfection unit, and a soil adsorption drainfield (approximately 12,000 lineal feet). The collection system is a Septic Tank Effluent Gravity (STEG) system. It consists of both commercial septic tanks and residential septic tanks. The facility was originally constructed in 1986. The current permit allows all flows up to and equaling 0.0532 MGD to be discharged from the RGF to the soil adsorption drainfield. During the winter months, all flows in excess of 0.053 MGD are supposed to flow through the UV light disinfection system and discharged to the Little Luckiamute River at River Mile 12.0. The maximum daily flow to the receiving stream shall not exceed 26,250 gallons per day. However, the treated effluent flow rates vary on a day to day basis during the winter discharge period and therefore the UV disinfection system receives intermittent flows. Because the UV disinfection system does not receive effluent flow on a continual basis, the system cycles on and off and does not function properly, resulting in inadequate disinfection. In the proposed permit, the Department is proposing to allow the City to direct the flow through the UV disinfection system starting on November 1st and running through April 30th. This would allow the UV system to operate continuously and provide better disinfection. Some of the flow would always go to the drainfield, but the majority of it would go to the Little Luckiamute River. When the plant flow nears the capacity of the UV system, the flow would then be diverted to the adsorption drainfield. The permitted mass loads will remain the same. Biosolids Management and Utilization The permittee's biosolids management plan was approved through a modification on May 5, 1998. The permittee currently contracts with a private DEQ licensed septage pumping and hauling management company. The permit requires that all septic tanks connected to the City's wastewater collection system are to be inspected and tested for depth of sludge and scum every two years. Each residential tank shall be pumped when 25% of the capacity of the tank is taken up with solids or every five years and each commercial septic tank shall be pumped when 25% of the capacity of the tank is taken up with solids or every four years. All septic tanks with screens shall be inspected every year. In addition, the Recirculating Gravel Filter (RGF) septage City of Falls City Evaluation Report Page 3 that accumulates in the dosing tanks, pump station, and recirculation tank shall be evaluated on annual basis and pumped at a minimum of once every five years. The septage tank pumping and hauling company pumps the tank into the truck and adds lime for stabilization. Mixing takes place within the tank truck when the truck is driven over rough dirt roads to the application site. The pH is maintained at 12 for the first 30 minutes and then 11.5 or above for an additional 90 minutes prior to application. The septage may then be land applied on DEQ approved beneficial use sites. The solids from the RGF components may be land applied on pasture land and the septic tank solids may be land applied on land used for hay crop. There are three septage storage tanks located at a 17 acre site owned by the City. The tanks are used only for emergencies (i.e. plugged lines or when the septic tank has to be completely pumped out). The contents of these tanks are mixed with lime by using pumps to pump the sludge back and forth from the hauling truck. The sludge is then land applied to the approved beneficial use sites. The proposed permit will require in Schedule B that the permittee keep a record of locations where the septage is applied including the date, quantity and location on a site location map. Inflow and Infiltration (I/I) The City entered into a MAO with the Department in 2004 to address excessive inflow/infiltration into the collection system which was hydraulically overloading the treatment plant. The MAO allowed the City two years to evaluate the system and correct deficiencies; that work has been completed. However, based on high winter flows; it appears that the approach was not successful. Minimal amounts of I/I were eliminated. In accordance with paragraph 18 of the MAO, the MAO is to terminate 60 days after completion of the schedule contained in paragraph 7.a. of the MAO. The Department recently terminated the MAO on May 21, 2007, and the City is now required to meet all of the limitations of the current and proposed NPDES permit. The Department recommends a long- term program that will completely replace the collections system based on life expectancy (usually 60 to 80 years). The replacement program should be directed at the oldest sub-basins or those in the worst condition. Therefore, Schedule C of the proposed permit will contain a compliance condition requiring the permittee to submit within one year of permit issuance, an approvable plan and schedule for an on-going collection system replacement program. In addition, Schedule B of the proposed permit will require that the permittee submit an annual report on inflow and infiltration reduction activities. Pretreatment The permittee does not have a formal pretreatment program, nor is one required for this source. Outfalls City of Falls City Evaluation Report Page 4 Outfall 001 The proposed permit allows the treatment facility to discharge treated effluent through Outfall 001 to the Little Luckiamute River at River Mile (RM) 12.0 during the winter months (November 1-April 30). All wastewater up to and equaling 0.02625 MGD will be discharged to Outfall 001. All flow in excess of 0.02625 MGD will be discharged to Outfall 002, the soil adsorption drainfield. No discharge to state waters is allowed from May 1-Ocotber 31 without written authorization from the Department. Receiving Streams/Impact The City of Falls City discharge is within the Willamette Basin and Middle Willamette Sub-basin. The designated beneficial uses of the receiving stream are: public and private domestic water supply, industrial water supply, irrigation, livestock watering, fish and aquatic life (including salmonid rearing, passage, and spawning), wildlife and hunting, fishing, boating, water contact recreation, aesthetic quality and hydro power. The water quality standards for the Willamette Basin (OAR 340- 041-0340) were developed to protect the beneficial uses of the basin. Section 303(d) of the Clean Water Act requires the establishment of a Total Maximum Daily Load (TMDL) in water bodies in which the technology based effluent limitations are not stringent enough to implement the water quality standards. The Willamette TMDL was issued on September 21, 2006, and approved by the EPA on September 26, 2006. OAR 340-041-0345 states no wastes shall be discharged and no activities shall be conducted which cause violations of the water quality standards in the Willamette Basin. The Little Luckiamute River is not included on the Department's List of Water Quality Limited Water Bodies (also called the 303(d) List) as water quality limited for any parameters at any time of the year. The TMDL does not address the Little Luckiamute River specifically because it was not listed for any parameters, however; the TMDL addresses temperature in the portion that includes Willamette Basin tributaries. This is discussed further below. Antidegradation Review OAR 340-041-0004 describes the Environmental Quality Commission's (EQC) Antidegradation Policy for Surface Waters.
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