SITE INFORMATION AND CORRESPONDENCE

Home Browse Search

Mr. Mike Owens • - 2 - • 15 May 2001 ' Finding#25 has been corrected to indicate drainage into ASB No.2. Comments included in Mr. Hayes' e-mail of 14 May 2001 3. Your comment no. 2 in your letter of April 23rd regarding discharges fro [sic] sludge dewatering states "Prior to discharge to ASB No. 2, the leachate will be sampled and analyzed to ensure that it meets the effluent limits in the WDRs"; Finding No. 25 states, in part, "Sampling of the sludge wastewater will be conducted to assure that the influent limitations for Pond I are not exceeded. " Previous correspondence has addressed the fact that the finding should be referenced to ASB #2 instead of Overflow Pond #1. Beyond that, however, neither the existing or the proposed WDRs contain influent concentration limits for discharges or influent to ASB #2. The only effluent concentration limit contained in the WDRs is applicable to the effluent from ASB #2. The WDRs require that the concentration of TDS in ASB #2 shall not exceed 1,100 mg/L on an average daily basis and shall not exceed a maximum of 2,110 mg/L in anyone day. The WDRs also state that dissolved oxygen in the upper 1.0 foot of ASB No.I and No.2 shall be maintained at a minimum of 1.0 mg/L. According to Mike Owens, current data indicates that the concentration levels of TDS in both ASBs has been averaging between 500 and 600 mg/L. The amount of wastewater generated by sludge dewatering, based on conservative,preliminary calculations is anticipated to be very small(50,000 gallons per day) compared to the capacity of ASB #2, which is approximately 3,000,000 gallons and the average daily discharge of the wastewater treatment system of 2,000,000 gallons per day. Based on simple mass balance calculations and the extensive amount of waste characterization done to date, it is very unlikely that wastewater generated by sludge dewatering would have a significant impact on effluent water quality from ASB #2. Therefore we suggest that Finding No. 25 be revised to eliminate the last sentence Finding No. 25 has been revised, first to indicate that sludge decant wastewater will be routed to a drainage that flows to ASB No.2. The last sentence of the finding has also been revised to read, " Sampling of the sludge wastewater will be conducted to monitor the influent to ASB No. 2 and to assure that the effluent limitations from ASB No. 2 to irrigation and percolation fields are not exceeded. While the WDRs did not set limits on the influent to ASB No. 2, sampling the decant from the sludge is important because discharge to ASB No.2 is considered a discharge to land. Failure to conduct the described monitoring would be a violation of the revised WDRs. Additionally, Mr. Hayes' e-mail of 14 May 2001 includes two comments specific to the 23 April 2001 letter from Regional Board staff. First, Mr. Hayes indicates that Fox River"seeks reasonable assurance that resources and funds applied to the closure will not be at risk if the closure of the impoundment is conducted in accordance with the closure plan that has been submitted." The Regional Board stated in the 23 April 2001 letter that based on the analytical data submitted we have agreed with Fox River's conclusion that the sludge material remaining in the impoundment is inert. Additionally, we have conditionally concurred with the Closure Plan submitted in February 2001. Beyond the statements already given in the 23 April 2001 letter, the Regional Board can provide no other assurances regarding the closure. The Discharger (Fox River) is responsible for accurately and thoroughly characterizing the