HomeMy WebLinkAbout12092013 City Council Laydowns 1Z/qt 3 Nt"
��\I jj,�e THE STATE Department of Environmental
,? �' °fALAS� Conservation
. 1 DIVISION OF AIR QUALITY
t•. ,I ,,
GOVERNOR SEAN PARNELL AIR PERMITS PROGRAM
07119 :9y.r• 619 E.Ship Creek Avenue,Suite 249
Anchorage,Alaska 99802-0122
Main: 907.269.7577
Toll free: 866.241.2805
Fax: 907.269.7508
ntte://www.dec.state.ak.us
CERTIFIED MAIL: 7011 2000 0000 7045 8366
Return Receipt Requested
October 17,2013
William Casey,Director of Public Works
City of Seward
PO Box 167
Seward,AK 99664
ADVISORY LETTER
Subject: Air quality concerns regarding nuisance odors at City of Seward Lowell Point Sewer Plant, Complaint
Nos. 2511,2512, 2513,2514,2515,2516,2517,2518,2519,2520, 2521,2522,2523,2524,2525, 2529,
2530,2531,2532, 2533,2534,2535,2541. Enforcement Tracking No. 2013-1025-36-001
Dear Mr. Casey:
The Department of Environmental Conservation (DEC) Air Quality Office has received numerous air quality
complaints concerning nuisance odors emanating from the City of Seward Lowell Point Sewer Plant during the
summer of 2013.The DEC Waste Water Division has also received complaints and is working in conjunction with
the Air Quality Office.
Please be advised that the following state regulations apply to waste water treatment works emissions;
18 AAC 50.110.Air Pollution Prohibited.
No person may permit any emission which is injurious to human health or welfare,animal or plant life,or property,
or which would unreasonably interfere with the enjoyment of life or property.
AS 46.03.810 Air and Land Nuisances.
'a) A person is guilty of creating or maintaining a nuisance if the person:
(2) allows to be placed or deposited upon any premises owned by the person or under the person's control
garbage,offal, dead animals,or any other matter or thing that would be obnoxious or offensive to the
public or that would produce,aggravate,or cause the spread of disease or in any way endanger the health
of the community. 'wii.lifil:
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Y
Clean Air
City of Seward 2 October 17,2013
Advisory Letter
During the course of investigating the public complaints,the ADEC Division of Water Quality confirmed the
complaints while on site in Seward on August 31,2013. During our telephone conversation on September 9,2013,
you explained that a number of different problems were contributing to the treatment works odor coming from the
sewage lagoon.These issues included:
• An extreme algae bloom accompanied by an extreme die off
• Old,possibly malfunctioning blowers
• A sludge layer that needs to be dredged.
• Possibly an undersized facility.
You have shared with me that these are issues which will require long-term solutions with substantial investments.
However,the City of Seward has an obligation to operate the treatment works in compliance with Statutory and
regulatory requirements.
Please respond to the department within two week from receipt of this letter with the City's plan of action. As the
City of Seward formulates possible other solutions to these issues,apprise us of additional strategies planned and
actions taken to mitigate the odor problem.
If the Department continues to receive substantiated odor complaints regarding the City's treatment works
operations,the Department will consider other options to ensure compliance.
If you have any questions,please contact me by phone at(907) 269-7562,or by email at
a ndrew.mohrmannnu.alaska.gov.You may also contact Jeremy Ptak at (907) 269-3071 in my absence.
Sincerely,
4454444./
tA4*"451.44—
ndrew Mohrmann
Environmental Program Specialist
cc: Jim Baumgartner,ADEC/APP,Juneau
Jeremy Ptak,ADEC/APP,Anchorage
P. Moses Coss,ADEC/APP,Fairbanks
bcc: Mel Knapp,ADEC/WCP,Anchorage
\\ab-svr\groups\AQ\Permits\Awq-pernuts\Airfacs\COMPLAINTS\City of Seward Lowell Point Sewer Plant Nuisance Odor\City of Seward Lowell Point Sewer Plant
Nuisance Odor Advisory Letter.doca
•
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CITY OF SEWARD �, �:� • Main Office (907) 224-4050
PO. BOX 167 • Public Works (907) 224-4058
SEWARD. ALASKA 99664-0167 0 P • Water&Sewer(907)224-4094
• Fax (907) 224-5051
October 31, 2013
Andrew Mohrmann, Environmental Program Specialist
Department of Environmental Conservation
619 E Ship Creek Ave, Ste 249
Anchorage, AK 99802-0122 sent via email to andrew.mohrmanna,alaska.gov
Dear Mr. Mohrmann:
Re: Seward Lowell Point Lagoon Odors
Response to Your October 17 Advisory Letter
The City of Seward acknowledges that odors from our lagoon at Lowell Point were more substantial
than normal during a portion of last Summer, primarily in August. Some people reported to us,as
they did to DEC,that odors were even offensive at times.
We want you to know that we take our responsibility to deliver wastewater services seriously. That
includes not only operating safely and meeting the requirements of our permit, but also being a good
neighbor, in this case, particularly to those people who reside in or visit immediately adjacent areas
outside our City limits. And with few exceptions,which we note on our monthly Discharge
Monitoring Reports(DMRs),we have been operating within statutory and regulatory requirements.
We do not agree with your intimation that we are not.
Initial Responses by City
When we first received odor complaints we immediately responded by visiting the site and checking
on odors. I personally visited the lagoon and its environs several times. Although we seldom were
able to confirm the problem was as bad as reported,we recognize that meteorological conditions
change,and we might have missed the worst part during our observations. Additionally,we know that
people have different tolerances and sensitivities to odors.
We discussed the odor phenomenon with our engineer, Loren Leman, P.E. with Michael L. Foster&
Associates, and concur with his findings that the increased odors this summer,particularly those
generally associated with the"rotten eggs"smell of hydrogen sulfide, come primarily from an
unusual confluence of three conditions: 1)an extended period of warm weather,one that set a record;
2)high organic loading, now a tradition for Seward in the Summer; and 3)a large inventory of sludge
(biosolids)in the lagoon.
We have not removed sludge from this lagoon for 20 years. Warm weather increases the temperature
of the lagoon, increasing biological processes. Because blowers were sized for oxygen transfer,not
complete mixing under high sludge inventory, some biological activity occurs under anaerobic
conditions in sludge that has settled in certain areas of the lagoon bottom, particularly between the air
headers.These'`benthic"areas likely produced increased levels of hydrogen sulfide gas during
1
warmer weather. Indeed, Mr. Leman suggested odors would diminish as soon as temperatures
dropped—and that is exactly what has happened.
Plan of Action
We have previously provided DEC our Wastewater Facilities Operation& Maintenance Plan,
December 7,2011,and its Addendum No. 1,January 30,2013. We also provided our Wastewater
Facility Plan, Lowell Point Wastewater Treatment Facility,July 30,2012.These documents required
by permit identify our wastewater system, how to operate it, its capacity and limitations,and plan to
address conditions that may cause us to approach or violate permit conditions. We refer you to them
for detail.
On Table 3 in the Facility Plan(on Page 34)is a listing of recommended improvement options by
priority. We agree with this listing,particularly the first three. We have already taken steps under
Option 1 to manage wasteloads,to considerable success. Option 2 to remove sludge is our next
priority and we are also considering Option 3 to improve oxygen transfer and wastewater biokinetics
with fixed media. We have since revised the details of this plan a bit. We now also plan to purchase
new blowers,possibly with increased capacity,especially if we can reduce consumption of electricity
by using more efficient motors.These changes will be particularly effective during the Summer when
we need aeration help the most. For other details on our plan of action, see the attachment"Lowell
Point Lagoon Projects."
If I said during our September 9 telephone conversation that our blowers are possibly malfunctioning,
I may have misspoken.They are 30-years old,and although we have ongoing maintenance issues
with them,they are serving us well. We did measure dissolved oxygen(DO)depression during
August,and although our engineer assures us that even 2 mg/L is sufficient for driving aerobic
biokinetics,we recognize that this is below our permit minimum and might have contributed to the
condition for increased production of hydrogen sulfide in the benthic layer. We have purchased a new
DO meter and are working to increase oxygen in the lagoon and see that this does not happen again.
The City recently received an unsolicited proposal from the"Bio-Dome"manufacturer that might
have some merit. We will consider alternatives like this,particularly if it can be demonstrated that
treatment efficiency will increase,and odors and power requirements reduced. Some of our Lowell
Point neighbors have suggested that we install a floating cover over the 6-acre lagoon. Although we
have not excluded this idea conclusively, it is more expensive, and is not as likely a solution as others
we consider more appropriate.
Sludge Removal
We had previously planned to do sludge removal at both our Lowell Point and Seward Marine
Industrial Center(SMIC) lagoons this summer,but that work was delayed for two reasons: 1)we
learned in late Spring that sludge removal from a similar lagoon in Dillingham would cost$1.2
million. Although the geographic constraints for Dillingham are somewhat different from ours, we
concluded the$490,000 we had budgeted for both of our lagoons would likely be inadequate, so did
not even bid the job;and 2)about the same time Mel Knapp/DEC denied our request for a partial
bypass of the SMIC lagoon while removing its sludge,a project that has not occurred there for 25
years. We had planned to bid the projects at the same time,select one contractor,and coordinate the
work to reduce costs. We still are working on a solution for sludge removal at SMIC—and although
we do not yet have all the details worked out, know that it will be expensive, considerably more so
because of Mr. Knapp's denial. The City of Seward is pursuing funding for these projects.
2
Community Participation
In recognition of our responsibility to be a good neighbor,we have already had two events at which
we invited the public, particularly our Lowell Point neighbors,to hear how the lagoon operates,what
we believe the issues are,and our action plan.The first was a fairly informal gathering at the Lowell
Point lagoon on September 14. The second was a more formal meeting with presentation at
City Hall on October 2. We answered questions at both events and are enclosing a copy of our
PowerPoint presentation from the second meeting.
Closing
We welcome your interest in our wastewater system, particularly as you and others in the Department
share information and experiences from other similarly situated facilities in Alaska that may lead to
cost-effective solutions for us. If you receive other complaints about odors, we hope you will
communicate first with us as you"consider other options to ensure compliance."
In closing,while we accept our responsibilities, let's not lose sight of the fact that this is a sewage
lagoon. Some odors are inevitable,even when it is well operated.That is part of the risk on a
neighborhood that has developed considerably since the lagoon was built 33 years ago. Additionally,
solutions will require a substantial financial investment by the City of Seward. Planning, design,
financing,and construction take time. In the meanwhile,we will do our best to operate well with what
we have.
Sincerely,
W. C.Casey
Public Works Director
Attachments: Lowell Point Lagoon Priority Projects
PowerPoint Presentation for October 2,2013 Meeting
Copies: Jim Hunt, City Manager
Loren Leman, P.E., MLFA
3
I ZAit 1-(-
Mon, Dec 9 at 7 pm. City Council Chambers at City Hall.
My name is Jena Petersen, I live on Ravenquest Ave. at mile 6 here in Seward. I was recently elected the Chair-person for
your Seward Recreation Committee. We have the following report... (Distribute their copy of the report. Or should we
PowerPoint)
Honorable Mayor&Council members,The Recreation Committee has accomplished the following items since our
appointment by you in February, 2013. We created a mission statement; formed action teams; have received
presentations from the community and heard input on a number of recreation topics from the public.
We are "a special ad hoc citizen advisory committee appointed by our past Mayor."We have received training from the
clerk regarding the State of Alaska's Open Meetings Act.
Our mission is "to conceive, compile and advance recreation opportunities in the Seward area."
We elected a new Chair,Jena Petersen
We elected a new Vice or Deputy Chair,Jody Tuck, who was also elected to serve as our ADA specialist.
We moved our meetings to 12 noon, still meeting the first and third Wednesday of every month.
We established three Action Teams:
Rissie Casagranda and Jody Tuck will continue the work of putting together a 'Recreation Listing'for the Seward area.
The Rec Corn extends thanks to volunteer Alyssa Jeswald,AmeriCorp volunteer,who put together the first draft of The
Listing spreadsheet and volunteered to enter the data collected by other committee members.They have given
themselves a deadline of January 15, 2014 to present their second draft to the whole Rec Corn.
Another Action Team led by Joe Allen will work with other groups and persons interested in promoting Mile Zero of the
Iditarod Trail and the Iditarod festivities in Seward.
A third Action Team led by Mica Van Buskirk will liaise with the informal Hockey/Ice Rink promoters to gain more
information regarding a how an ice rink can promote winter season tourism and positive economic impacts.
Policies and procedures were discussed including:
A. Moved to noon, hoping for improved attendance
B. Attendance policy
C. How to request"letters of interest" from possible new committee members
Tonight your agenda includes a request to extend the Recreation Committee's sunset to December 2014, if possible.
Throughout the past ten months we have received informal and formal presentations regarding the following items;
the Baseline Recreation Trail, the work of the Seward Prevention Coalition including their Action Team called
"Community Center", Ice Rinks& hockey tournaments to boost winter economy as well as many other recreational
resource options available to Seward youth through the eyes of the High School Principals, ADA access; the AVTEC
sauna at the Student Services Center and racquetball court to name a few.
To summarize, it has been a busy ten months for our committee. We have established ourselves, set up action
teams and already started to see results from our efforts. We look forward to what we will accomplish in the next
year,given your approval.
November 25, 2013
TO: CityMayor Bardarson and Members of City of Seward City
of Seward Council NOV 252013
FROM: Lynda Paquetton behalf of Lowell Point Residents and Property Owners
RE: Further details of the DEC meeting, background materials, and a timeline
Please accept my deepest heartfelt thanks to each and every one of you for your willingness to hear me out and
for speaking and/or meeting with me, regarding the situation with the Lowell Point Treatment Lagoon,the
meeting that DEC held with the City Administration on 11/5, and the Lowell Point residents hopes that the City
Council make sure a dredge of the LP Lagoon occurs prior to next tourist season 2014. We keep using dates of
April 30, 2014 as the deadline, because the Visitor Season involving Lowell Point starts in earnest in April, and is
well underway by May.
Anytime,and every time, we have made any suggestion to City Administration that something must be done
before summer 2014,we have been told,flatly, "NO;" at both the PW Open Houses we were told nothing would
be done until next fall 2014, "at the earliest." "There is no money, but if a health emergency were to happen,
money would start flowing immediately." When DEC Compliance and Wastewater Engineering staff met with
the City Administration on 11/5/13,they reinforced the need for a dredge to occur by summer of 2014,yet to
our shock and dismay,the Administration did not mention this to City Council on 11/12/13.
This is an effort to provide you with documentation and facts,to back up our claims, and provide a time line that
should help illustrate further the severity of the situation we, not just the residents and property owners of
Lowell Point, but everyone in a 10+ mile radius or wider of the City of Seward are living under.
You will find attached a Summary of Documents,which lists briefly the additional following attachments: A)
Timeline May 2012 to Present(dredge scheduled to no longer scheduled), B) a portion of MF Foster report
presented to Council in 2012, C) page from PW Open House 10/2/13, D) DEC Meeting agenda from 11/5/13, E)
transcript of a portion of Council Meeting 11/12/13, F) Notes from DEC phone conversation on 11/14/13,G) DEC
email, H) photo of exposed sewer lines in the Spruce Creek bed, I) summary of ML Foster projects illustrating a
lack of wastewater removal experience.
In conclusion,we are left with the following questions:
1) In May of 2012 it was announced by ML Foster to Council, that dredge for LP Lagoon would cost$200-$300K,
that the City had the money, and a plan,and the dredge was scheduled for fall of 2012. By spring of 2013 the
City has no money, no plan, no schedule to dredge, and costs are now estimated at$1.2-$1.5 Million. Who
signed off on these decisions and how do we reverse them?
2) How do we expedite action and cut through the red tape so we can get the dredge performed by spring 2014?
3) How does it makes sense to put lots of money into repairs beyond the dredge,when based on Attachment B,
we've outgrown the capacity of the LP pond and we should be rethinking the entire Septic system?
4)Why, given the severity of the need to "redesign" the City's entire septic system, do you use a firm that,while
well respected in the State, is not well known in the Wastewater Treatment arena, in Alaska (or elsewhere), and
has little in the way of experience,or projects, in wastewater management or removal. See Attachment I.
Summary of Attached Documents
A Summary of Attached Documents:
Attachment A:Timeline^'which illustrates that City Administration has known for years that they were violating
their wastewater Permit;that they had an idea of the cost, and the money to do the dredge and the dredge was
scheduled for fall of 2012; that the City has no money now, no idea what the job will cost now(although
estimates have quadrupled), and there is no schedule or plan now,for completing a dredge.
Attachment B: Presentation documents from ML Foster to City Council 2012 wherein it is reported that the
Lowell Point Lagoon has been out of compliance (violated its permit) starting in 2010; it further states that the
job will cost$200,000-$300,00 and that the City HAS the money and the dredge IS scheduled for Fall of 2012.
The report goes on to state that the LP Lagoon is too small, and that an expansion of services is needed to
accommodate the growth Seward has seen in the 30+years since it was designed.
Attachment C: Presentation documents from ML Foster/City of Seward to Residents at Treatment Pond Open
House on 10/2/13 where the severity of the situation is misrepresented with the statement of"meets permit
conditions." At this meeting, it was again suggested to those who had complained of odors, as it had been
suggested all summer,that we did not know what we were smelling and that there was no way it was the
Lagoon, but rather"rotting vegetation in the trees,or the beach at low tide."
Attachment D: Agenda from DEC meeting with Lowell Point residents regarding the City of Seward and the
Lowell Point Wastewater Treatment Facility on 11/5/2013 listing all the participants of DEC and the City
Administration in attendance when DEC met that afternoon at 2:30pm with City Administration.
Attachment E:Transcription of discussion of DEC meeting with City of Seward at City Council on 11/12/13 where
in City Administration disavows all knowledge of any pending Notice of Violation, and dismisses the meeting
with DEC as unimportant, and claims City has never violated the wastewater permit.
Attachment F: Notes from conversation with DEC on 11/14/13 reviewing from DEC's stand point the meeting
held with City Administration on 11/5/13, stating a demand for dredge by summer season 2014, and the Notice
of Violation that would be forthcoming.
Attachment G: Email from DEC 11/15/2013, stating charts displaying violations that they met with City over
went back at least 3 years (2013, 2012, 2011), perhaps further back.This provides further confirmation of
violations on the part of City of their wastewater permit.
Attachment H: Photo of Current Health and Environmental Disaster awaiting to happen ^'setting us up so
"money will start flowing"....?????This disaster waiting to happen was reported to City Administration this
spring by LP residents. I've mentioned this to several of you and as of 11/25, a little dirt work has occurred and
a few jersey barriers placed....The sewer pipe with raw sewage from town is still completely exposed, and
undercut by Spruce Creek.
Attachment I: A summary of ML Foster&Associates projects taken from their website
Attachment A—Timeline pg. 1
Timeline of the problems with the Lowell Point Treatment Lagoon:
May 2012 "' In May 2012 Loren Leman with ML Foster presented to City Council the summary of his
study. [Attachment B] He states that the Lowell Point Treatment Lagoon began violating its permit in
2010 and that it did so again in 2011; he states that the dredging of the pond is the#1 thing that needs
to happen, he states that the dredge will cost between $200,000 and $300,000. He further states that
the City has the money, and that the dredge is scheduled for completion in fall of 2012. He further goes
on to explain that the LP Lagoon has reached its maximum capacity and the City needs to expand its
wastewater facility. For reasons unclear, no dredge occurred as scheduled and now the costs have
quadrupled and scope of job changed significantly. Also worth note is that in this document there is no
mention of aerators or work being needed on them, or an inspection of the liner, all of which will
complicate, delay and raise the cost of any"dredge."
Fall 2012— In Fall of 2012 during the September flood,the inlet(raw sewage from town) pipe and
effluent(clean water going to outfall) pipe to the LP Lagoon were exposed by flooding, where they cross
the Spruce Creek riverbed.The damage and exposed pipes were reported to City staff in spring of 2013
and multiple times throughout summer of 2013.They remain exposed as of 11/25/2013.
Late Spring 2013— In late spring (May or early June) reports began being made to the City
Administration about excessive odors coming from the Lagoon. We were categorically brushed off with
statements of"it's the weather." No one that we are aware of received a truthful answer of"we knew
this might happen" or"We're sorry."
August—(into early September)2013—As complaints persisted into August, after it was clearly no
longer"the weather" we were told we didn't know what we were smelling. We were told by City
Administration and Staff,there was "rotting vegetation in the trees." We were told "it's the beach at low
tide."
August 20,2013—After weeks of rain and cool temperatures yet the Hydrogen Sulfide fumes persisted,
Lynda met with the Borough Mayor,who took the situation under advisement, and told us to contact
DEC as the next step. DEC told us to file "Nuisance Odor" reports. Twenty-two people filed reports
documenting the stench from all summer and fall. In response to those filings,DEC Air Quality wrote an
Advisory Letter to the City of Seward, and the City of Seward responded. No mention of this letter was
ever made to Council as far as we know.
September 14, 2013—The City held the first of 2 public Open Houses to discuss the problems with the
Lowell Point Lagoon. Again we were told that we didn't know what we were smelling; we were told
again that most likely it was rotting vegetation in the trees and the beach at low tide. When people who
have lived here since before the pond was built, disputed these claims,we were told we didn't know
what we were talking about. At this Open House the exposed pipes in Spruce Creek were brought up
and there was a complete lack of concern on the part of City staff as to the problem.
Attachment A —Timeline pg.2
September 2013' DEC Air Quality forwarded those 22+ Nuisance Odor complaints to DEC Wastewater
and DEC Wastewater after reviewing that past 4 or more years of data determined that the City has
violated their permit for at least the last 4 years,for 2 or more months every summer since 2010.
September&October 2013—At both Open Houses held by the City, we were told that the City has no
idea how much the dredge will cost, but the estimates now sit at 1.2 million to 1.5 million instead of
$200,000 to 300,00K from just 18 months earlier. We were given a handout that claimed no violations
had occurred (Attachment C). At the 10/2 Open House,we were promised a plan within 30-45 days. All
suggestions made by the public were categorically dismissed.The suggestion of performing a just a
dredge, instead of the now long list of work to be performed on the LP Pond,was dismissed.The City
Manager was adamant that NOTHING WILL HAPPEN BEFORE FALL of 2014.The public have been
treated rudely and with a total lack of respect or regard by some of the City Administration. Also
worthy of note: at both open houses statements were made by City Administration that "if there
were a health emergency,then the money would start flowing and we could get something done."
November 5, 2013 10:30am — DEC Wastewater and Compliance staff(3 members)(Attachment D) held
a meeting with Lowell Point residents to discuss the situation, prior to holding a meeting with the City of
Seward Administration. They were extremely supportive of our situation and insistent that the City
should take some action to remedy their deferred maintenance, before next tourist season 2014.They
told us of the Notice of Violation that is forthcoming to the City of Seward, but delayed due to schedules
of staff involved.
November 5,2013 2:30pm— DEC Wastewater and Compliance staff(3 members) held a meeting City
Administration advising them of the pending Notice of Violation and advising them that they must take
action to correct their violation by summer season 2014.
November 12,2013—At the City Council meeting,the City Manager made no mention of the Advisory
letter from DEC Air Quality, made no mention of any pending action from DEC Water Compliance as it
pertains to the City's Wastewater permit and categorically denied that there are any permit issues
whatsoever. "We have always been at or below Permitted requirements." Further he states that there is
no money,still currently no plan, and that the project although we have no idea what it will cost, is
estimated to cost$1.5 million. There is no schedule for any dredging project, and no mention of the
exposed sewer pipes in Spruce Creek. No mention of the "2nd Consultant"that City Council directed
Administration to Hire in the 10/28/2013 Council meeting; when questioned indicated they were still
working on the RFP for the 2nd consultant for$5,000.
November 25,2013—As for the exposed sewage pipes flowing through Spruce Creek,the pending
"health emergency" remains at high risk. There was a little dirt moved around to make a ramp down to
the creek, and some jersey barriers placed at road level, but nothing further has happened to repair the
exposed sewer lines, at the writing of this timeline.
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'p1 Michael L. Foster & Associates, Inc.
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Survci'ors • General Contracting
July 30, 2012
W.C. Casey, Public Works Director
City of Seward
PO Box 167
Seward,AK 99664-0167
Lowell Point Wastewater Facility Plan
Seward, Alaska
MLFA Project No. SEWD-SEWD-015-0001
w1t
Dear Mr. Casey:
This wastewater facility plan is required by the APDES permit for your Lowell Point Wastewater
Treatment Facility. It addresses the issues listed in Section 2.3 of the permit, includes a lagoon
evaluation, and provides other elements normally required in wastewater facilities planning.
DEC gave you the option of planning for up to 20 years. At our suggestion, you chose a 10-year
planning horizon. This enables you to address improvements needed now and during the next
decade, while reducing unnecessary speculation on Seward's longterm future and the financial
commitments that go with that. The input we received from you, as well from the City Council
and interested public on May 29, was constructive and helpful—and confirms this approach.
The type of community Seward is, its location, and attractiveness as a destination for visitors and
recreationalists create unique challenges for you as a provider of wastewater services. Your
Lowell Point facility has exhibited resilience during its nearly 32 years of operation, but does not
have unlimited capacity. Additionally, some of the rules have changed. So changes will be
necessary.
We want you to be able to meet your permit obligations, serve your customers, and keep your
costs manageable. Our recommended plan will enable you to do that.
Sincerely,
MIC ,. L L.FO ER & ASSOCIATES, INC.
oren Leman, .E.
Project Manager
Attachment: Lowell Point Wastewater Facility Plan
13135 Old Glenn Highway,Suite 200 • Eagle River,AK 99577 • 907496-6200 • Fax 907-696-6202
• •
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July 27, 2012
To: W.C. Casey, Seward
Project File
4414141146
From: Loren Leman, P.E., MLFA
Re: Lowell Point Wastewater Facility Plan
May 29 Council Work Session Notes
SEWD-SEWD-015-0001
These are my notes from the work session/public meeting in Seward on May 29
regarding the Fact Sheet, essentially the draft wastewater facility plan.
After spending time with you and other Public Works staff at the Public Works office,
lagoon and Control Building, we went to the City Council meeting at City Hall. It started
at 5:30 pm.
Mayor David Seaward chaired the meeting. All Council members were present. Also
attending were City Manager Jim Hunt and Assistant City Manager Ron Long. Johanna
Kinney and Brenda Ballou were from the City Clerk's office. You, Nort and Carmen
represented your department. Perhaps up to 20 members of the public were also
present—primarily to discuss a student exchange program and the upcoming 100 year
anniversary celebration for the City of Seward. However, some attended specifically to
learn about wastewater facility planning. Each person had access to the 5-page Fact
Sheet we had developed.
After I was introduced I walked through the history of the wastewater facilities, their
performance over the years, the need for sludge removal, recent summer exceedances
(2010 and 2011), renewal of your discharge permit, and the reason behind facilities
planning—and what to expect. I noted the biggest challenges—BOD removal when
loading is high in the summer, fecal coliforms (without disinfection), and
Iinfiltration/Inflow during extended wet periods.
The main treatment options are to:
1. Manage the wasteloads. Perhaps some of this can be done by monitoring
dischargers of high strength waste. Another is for SGS to run side-by-side tests
for BOD, one with inhibition of nitrification to see if nitrogenous oxygen demand
(NOD) is a significant component of total BOD in the effluent. We postulate that
it is.
2. Remove sludge. This hasn't been done for 18+ years—and needs to be done.
You have been successful in acquiring access to loan funds and plan to do this
project after labor Day. The City should plan on doing this regularly,perhaps
every 5 years or so.
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City of Seward
Lowell Point Wastewater Facility Plan
Fact Sheet
Purpose
Producing a wastewater facility plan is one of the requirements of the Alaska Department of
Environmental Conservation (DEC) in permit AK0021890 issued to the City of Seward on June 24,
2011. A facility plan looks at existing conditions, identifies deficiencies,projects future needs, and
identifies priorities for capital improvements. The City of Seward has chosen a 10-year planning horizon.
Background
Seward wastewater is treated at the Lowell Point Wastewater Treatment Facility, almost 2 miles south of
the Alaska SeaLife Center(see Figure 1). This 6.5 acre aerated lagoon was originally constructed in
1980, has a volume of 30 million gallons, a depth of 22.5 feet,and a typical daily flow of 500,000 gallons
(0.5 mgd). Because of a failure of its liner,the lagoon had a major renovation in 1993 when it was
drained,sludge removed, liner replaced, and dividing wall, new air piping, and diffusers installed.
Performance
With very few exceptions, the lagoon has operated satisfactorily without major maintenance. And until
the summers of 2010 and 2011,the very few violations of permit requirements could usually be attributed
to a malfunction of a minor piece of equipment or an inadvertent operator oversight. However, in July
and August 2010, effluent Biochemical Oxygen Demand(BOD),a measure of the organic strength of
wastewater,slightly exceeded the permitted monthly average of 45 mg/L(parts per million). It again
exceeded this limit during July-September 2011 and in August fecal coliforms (FC),an indicator of
bacteriological contamination, also exceeded the permitted limit.
In some cases these exceedances may have been related to sampling anomalies,or the fact that only two
samples are usually collected each month, but more of them likely are from substantially increased and
•
sustained organic loading from transient summer populations. For both summers effluent quality
improved dramatically soon after Labor Day. Further information on plant performance and its capacity
is in Appendix E of the Wastewater Facilities Operation&Maintenance Plan, December 7,2011.
Deficiencies
Issues for improvement we have previously identified and discussed with City staff include:
1. Sludge needs to be removed.
2. The electronic temperature monitor should be calibrated to a laboratory-grade thermometer.
3. Operators should take Dissolved Oxygen(DO)readings in Cell 1.
4. pH should be cross-checked occasionally with the SGS lab on duplicate samples.
5. Addition of remote monitoring will assist operators and improve reliability and security.
6. The City should purchase a spare air blower.
7. Operators should make minor site repairs identified in our Wastewater System Evaluation report.
8. The Control Building needs regular housekeeping attention and clean-up.
9. Laboratory records and DMRs need to be reviewed carefully before submittal to DEC.
Wasteloads
The plant's typical winter load is 600 to 800 pounds of BOD per day, about what is expected from a
community the size of Seward with a resident population of 2,700. This loading is still considerably less
Michael L.Foster&Associates
Lowell Point Wastewater Facility Plan SEWD-SEWD-015-0001
Fact Sheet May 23,2012
Page 1
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than the winter design capacity of 1,200 pounds. However,during summer months the lagoon has
typically seen daily loads of 1,600 to 2,100 pounds,and even higher. Occasional high wasteloads can be
easily handled by the plant, because detention time in the lagoon at normal flow is up to 60 days, but
sustained high organic loading has an observable effect. The summer design capacity is estimated.to be
2,000 pounds, which has been exceeded during the last two summers.
Wasteloads are typically a function of population,unless a community has substantial contributions from
industrial or commercial dischargers. Nearly all of Seward's wastewater is domestic sewage(for
example, from toilets, showers,and sinks). And although Seward's resident population has been fairly
stable(it actually decreased by 4.8 percent from 2000 to 2010 according to the U.S. Census),transient
populations from tourist,recreational and seasonal visitors increased during this same time. These
populations have an effect on wastewater facilities.
Economic conditions will impact travel, and although these are difficult to predict,we believe it is
reasonable to assume current wasteloads will continue to be discharged during the next decade. They
might even increase,particularly if gas prices drop and national and global economies improve. We
believe it is prudent to plan for a sustained summer loading of 2,400 pounds of BOD per day. To meet
permit requirements consistently under these conditions, improvements are necessary.
We rank the following treatment improvement options in order of increasing cost. Their benefits,risks,
and costs are summarized in Table 1.
Treatment Options
1. Manage wasteloads. One low cost approach is to reduce summer discharges of high strength
wastes. This may mean banning septage discharge from customers outside the City limits. Any
septage from pumping inside the City limits, if it occurs,should be restricted to September
through April. Pumping from portable toilets should be strictly controlled. These wasteloads
should be identified and any odor-masking chemicals must be biodegradable and pre-approved
for discharge. Otherwise,biocides discharged in large quantities could hurt operation of the
lagoon. The City should also get a handle on loads generated and discharged by local cruise
operators("daytrippers")and discourage the use of garbage grinders.It should also change how
SGS Laboratory runs the BOD test. We recommend that SGS run a side-by-side test during the
summer months with nitrification inhibition in half of the effluent samples.
2. Remove sludge. This has not been done for more than 18 years—and typically an aerated lagoon
would be cleaned at least every five years. Accumulated sludge has an impact on the effective
volume of the lagoon,efficiency of its aerators, mixing,and storage or organics during the winter
and their release during spring warming. The City has loan funds to remove sludge,and is
planning on this project after Labor Day.
3. Install baffles.This is a reasonably low cost method to improve BOD removal,perhaps by as
much as 20 percent, or more. One or two baffles constructed of polyethylene ribbons(trade name
Bioreef)would be installed in the first lagoon cell,subdividing it into two or three"subcells."
These would serve several purposes: First,they would reduce short-circuiting of the wastewater
as it moves through the treatment process. Multiple cells typically produce a better quality
effluent. Second,they provide a fixed substrate on which additional microorganisms can grow
and further degrade the organic content of the wastewater as it passes through it. And third,they
would enable separation of the lagoon contents so sludge can be recycled from the second and
third subcells back to the first cell,perhaps with with floating clarifiers, increasing the
concentration of microorganisms in contact with influent wastewater,and enhancing treatment.
Michael L.Foster&Associates SEWD-SEWD-015-0001
Lowell Point Wastewater Facility Plan May 23,2012
Fact Sheet Page 2
4. Biological pre-treatment. This could reduce summer influent wasteloads by half,bringing
lagoon loading well within its design capacity. We have assumed modifications will include a
rotating screen,activated sludge aeration basin(75 feet long by 20 feet wide)and a 40-feet
diameter clarifier,with recycle pumps and controls. Other combinations of biological unit
processes are possible and should be considered if this option is pursued. Space is limited at the
current plant site,so land may need to be purchased.
5. Expand the lagoon. Land would need to be purchased east of the existing lagoons to provide
room. We have assumed this option will require a doubling of the current lagoon capacity.
Disinfection
Currently the City does not disinfect effluent from the treatment plant,yet with few exceptions it has been
able to meet its permit requirement for FC consistently. The new permit issued in 2011 reduced the
allowable FC concentration,creating more of a challenge during summer months. However, field testing
so far in Resurrection Bay confirms outfall dispersion modeling that Seward is still able to meet Alaska
Water Quality Standards for FC at the edge of the mixing zone.
We believe the observed permit excursions last summer will be improved sufficiently by other operational
changes so Seward will not need to provide effluent disinfection. However, if it is added,we suggest
onsite generation of sodium hypochlorite from saltwater and electricity. In 2008 we evaluated this as an
option for drinking water disinfection when and if the City decides to change out existing gas
chlorination. The outfall line is 3,500 feet long and will provide one hour of chlorine contact at normal
flow,perhaps eliminating the need for a separate chlorine contact chamber.
Table 1
Summary of Treatment Options
Opt ion Capital Cost Comments
Could reduce high strength loads with minimal
cost;run extra set of effluent BOD tests with
i—Manage Wasteloads $2,000
inhibition of nitrification for three summer
months(about$300).
Housekeeping task that has not been done for 18
2—Remove Sludge $200,000-$300,000 years;may improve plant performance,possibly
reducing summer effluent BOD considerably.
Creates smaller compartments,provides fixed
3—Install Baffles $200,000-$300,000 media substrate for microorganism growth;may
reduce effluent BOD by 20+%. Could adapt
later with sludge recycling.
Use high-rate activated sludge process during
4—Biological Pre-treatment $2 to$2.5 million summer months to reduced BOD loading to
lagoon;will require more land,operator
attention,and aeration.
Essentially a duplication of the existing lagoons;
5—Expand Lagoon $4.5 to$6 million will require almost the same amount of
additional land and more aeration.
Effluent Disinfection $80,000-$100,000 Will notbe required if the plant can meet FC
limits;this will also have ongoing O&M costs.
Michael L.Foster&Associates SEWD-SEWD-015-0001
Lowell Point Wastewater Facility Plan May 23,2012
Fact Sheet Page 3
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Meeting Between Lowell Point Residents and the Alaska Department of Environmental Conservation
Regarding the City of Seward, Lowell Point Wastewater Treatment Facility
November 5, 2013
Agenda
At the completion of this meeting,the participants will have:
• Discussed the concerns of Lowell Point residents and businesses regarding odor issues from the
Lowell Point Wastewater Treatment Facility(LP WWTF) during the past two summers.
• Clarified DEC Division of Water's responsibilities in regard to regulating the LP WWTF.
• Clarified DEC Division of Water's objectives in meeting with the City of Seward regarding LP
WWTF.
1. Introductions.
2. Discuss odor problems during the past several summers.
3. Discuss interactions between Lowell Point residents/businesses and the City
4. Discuss ways DEC can support residents and businesses in solving odor issues before the 2014
business season.
5. Discuss the responsibilities of different DEC Divisions and how they can work together to deal with
the odor issue.
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Attachment E — City Council Mfg 11/12/13
City Council Meeting 11/12/13
Transcribed from audio recording off City Website by LyndaP:
Public Comments by Paul Paquette:
Last Tuesday 3 people from DEC Water Quality met with Lowell Point Residents to discuss our
concerns regarding the LP Treatment Facility. They reassured us that we are not alone out here
and that people at the Governor's office know about the problem with the Lowell Point
Wastewater Treatment Facility. DEC told us that the City of Seward has been out of compliance
enough that they will be issuing a Notice of Violation. One of the Managers said was that the
number one thing that has to be done to the LP Treatment facility, is to dredge it. The first step
is to write up a Request for Proposal to get some competitive bids for the sludge removal. You've
got to find out what this project is going to cost. Twenty two years of deferred maintenance has
only added to the cost of this project. This project is already well known,throughout the State.
There are companies that do this type of work: the desludging and disposal of this waste.
Emerald Alaska in Palmer is one company we talked to that know all about the lagoon and the
problems it's having. Depending on testing of the sludge, it could all be put on a train and taken
to Palmer, or taken to Whittier and put on a barge and taken to Oregon, depending on the testing.
Please,write up your RFP and get this ball rolling. We very much appreciate what the Council
has done so far in directing the Management to hire another consultant. On October 2, in a
meeting with the City of Seward,we were told that you would have a plan to present to the
public within 30-45 days. We are hoping this plan, will include a Request for Proposal for the
desludging of the LP lagoon.
Later in the Meeting:
Dave Squires,City Council to Jim Hunt City Manager: Mr. Paquette said in his presentation,
he said that DEC that they were getting ready to fine us, or looking at getting ready to give us a
notice that we would be under a fine? [Transcriber note: Mr. Squires was Fire Chief for City of
Seward for many, many, years, so he's well aware that ultimately a NOV can lead to fines, and
may be aware the City might prefer to pay the fines rather than fix violations, and has
presumably jumped ahead a bit in his question.]
Jim Hunt, Seward City Manager reply to Mr. Squires: "I am completely unaware of
that allegation. I was at the meeting. I was with WC, I don't know where that information
came from. I was at that, DEC was sitting in your seat, WC, staff and myself - at no time
with Loren, and you know, three members of DEC was any Violation mentioned.
Because, as Loren said to them, by the records, we have been in compliance. I don't
know if they mean compliance for aromatics? or discharge. (comment from Ron Long,
inaudible) Right...and Notice of Violation does not uh, mean we have to pay a fine....and
I don't know... are they saying we're in violation of aroma or discharge? I know our
effluent discharge has been AT and UNDER our permit levels. So, I'm not aware."
[Attachments D, F and G refute the City Administration's Claims]
I
Attachment F^'Gene McCabe 11/14/13 pg. 1
Notes from phone conversation Lynda and Gene McCabe, DEC had on 11/14/2013
Background:
At the City Council meeting on 11/12/13 we expected that the City Council would be made
aware of the details of the meeting the DEC held with the City Administration and Public Works
department on 11/5/13, because of the importance of the content of that meeting and the
pending Notice of Violation to the City of Seward.
We were told the reason DEC chose to hold the meeting when they did (on 11/5/2013) is that
the timing to address the items in the pending Notice of Violation (NOV) is critical with the
impending arrival of summer season 2014. The drafting and serving of a NOV is time consuming
and the DEC Staff person in charge of the NOV(Stephanie Mann) had shoulder surgery
scheduled for 11/7/13 and anticipated being out of work for 4-6 weeks. Additionally,the
Program Manager in the Compliance Division of DEC (Mel Knapp), intended to leave DEC on
11/8/13 to take other employment.
Since the required "fix" (dredging of the Lowell Point Lagoon) MUST be performed prior to
summer of 2014, DEC chose to give the City a verbal Notice in advance of the actual paperwork,
so that they would know what was coming and could start immediately addressing the problem
and get a dredge scheduled and performed by the required deadline of summer 2014.
What happened on 11/12/13:
At the City Council meeting, City Manager briefly mentioned the meeting, did not mention any
pending NOV and when questioned claimed there is no NOV and that there has been no
problem with compliance.The City Manager when speaking of odor issues, also made no
mention to Council that they City had already received an "Advisory Notice" from DEC
Department of Air Quality in reaction to the 22 Nuisance Odor reports, and that the City had
sent an Official Response back to DEC Air Quality.
Follow up with DEC and notes from the phone conversation on 11/14/13:
Shocked and dismayed by the lack of transparency,forthrightness and disclosure on the part of
City Administration, Lynda called Gene McCabe and reviewed from DEC's point of view what
was said at the meeting with the City Administration on 11/5/13. Mr. McCabe reviewed DEC's
notes and the following are Lynda's notes from that phone conversation [Although this is
"hearsay"for you at this point,you may contact Gene McCabe directly to verify(see
Attachment G for Gene's email and phone)]:
City Manager, Public Works Director, PW Assistant, and PW Lagoon Operator, and the three DEC
representatives as listed on Attachment D were in attendance.
DEC stated that the primary contributor to the odor problem is the sludge inventory. The
directive that DEC will issue in forthcoming NOV will require the City remove the sludge PRIOR
Attachment F—Gene McCabe 11/14/13 pg.2
to the 2014 tourist season. DEC was made aware of the "wish list"the City has in relationship to
work on the Lowell Point pond (aerators, liner inspection, etc.), and their plans to do both LP
and SMIC as one project, however,the requirement of the NOV will be to perform the dredge,
specifically on the Lowell Point Lagoon. The City may add other things to the project ONLY IF IT
WILL NOT DELAY THE DREDGE which must occur prior to tourist season of 2014. Additionally the
directive from DEC was to DECOUPLE the projects of de-sluding the Lowell Point Pond,from the
SMIC pond and deal with the Lowell Point Pond ASAP. Further direction includes a phased
approach if there is work beyond the dredge and desludging that needs to occur at the Lowell
Point Pond.
According to the engineer at DEC, blower capacity is not a significant part of the problem and
fixing the aerators will have a low impact on solving the odor problems.This and other issues
such as liner inspection, should be done, if at all, at a later time, unless the doing of such will
NOT delay the desludging.
The City has been issued a permit to operate this treatment lagoon by the State of Alaska;
management by disaster, and an attitude of waiting for things to become a health emergency,
so "money will flow," is no way to operate said permit.The threat to human health that the City
Administration has chosen to subject us all to is unacceptable.
As a side discussion,we discussed the resignation of Mel Knapp from DEC Compliance. In
addition to the delay Stephanie Mann's absence while recovering from surgery is causing, in the
actual generation of the NOV,there is also some discontinuity while waiting for the
appointment of a new Compliance Program Manager. In the meantime, Sharon Morgan,
(907)465-5530, Water Quality Programs, Program Manager,will also fill in as the Compliance
Program Manager.
Gene also indicated he would be reporting on the meeting that DEC held with the City of
Seward,to the Director of Division of Water at DEC, Michelle Bonnet Hale. (This report has
happened.)
Ct c'l'1 Yh Q 01--6
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A few follow up Questions
Mccabe, Gene C (DEC) <gene.mccabe@alaska.gov> Fri, Nov 15, 2013 at 11:35 AM
To: "ak.angels.care@gmail.com" <ak.angels.care@gmail.com>
Lynda,
I think Mel's graphs, for the most part, looked back about 3 years. Some of them went back a little further.
I just went to see if I could find them, but I wasn't able to. I didn't get an electronic copy, but I'll see if I can find
them.
There really are a lot of folks here working this... I just provided the update I was talking about to our Director.
Cheers!
Gene
Gene McCabe
Engineering Support & Plan Review
907-269-7692
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Attachment I — ML Foster Project Experience
Summary of ML Foster&Associates Projects as taken from their website on 11/22/13
During the discussions we have been reassured by the City,that ML Foster is a "good, reputable" firm.
That has never been at issue, nor was it ever our intent to imply otherwise. Our question is: How equipped are
they,to properly help the City of Seward specifically,with their wastewater desludging and removal issues?
When confronted with the odor issue and suggestions of pond covers, they were completely unaware of many
of the new advances and options to control odor,which is what raised concerns initially, along with some of the
other things said. In research the we've conducted in Alaska,they are not a familiar firm to the Alaska
Wastewater Community nor have they been used by any of the Cities in Alaska with similar settings or issues
such as Kodiak, Dillingham or Valdez.Their suggested solution for the disposal of the City's sludge is unfeasible.
On their Projects Page, http://mlfaalaska.com/Prolects.htm,they list Lowell Point Water System,which at this
point remains on paper. Lowell Point has spent thousands of dollars with ML Foster, but as yet, have not broken
ground on anything. The other project listed on this page is Ninilchik Water&Sewer Improvements. This would
appear to be a potable water project that has reached completion and a new(as in brand new) sewer system
that may be now in the process (not a redesign or upgrade).
Completed Projects appear as stars on the map. By clicking them you find:
1) Annette Island Packing Company Fish Plant Upgrade
2) Sitka Harbor Mountain Road final design
3) Anchorage:
a. Port of Anchorage tank demolition and soil removal
b. Ship Creek Hatchery geotechnical and civil engineering litigation support
c. Environmental consulting services for an electrical intertie project between Anchorage and
Kenai Peninsula
d. Civil, geotechnical and environmental engineering services to the AWWU Norfolk and Creekside
booster stations
4) Denali National Park:
a. Soil investigations in 3 areas inside the park
b. Construction management services for replacement of the Eilson Visitor's Center
c. Performed a feasibility study for water&sewer improvements in the surrounding locals of
Anderson, Clear, Ferry, Healey, Nenana Canyon, McKinley Park, Carlo Creek& Panguinugue
5) Eilson Airforce Base
a. Warm Storage building design
b. Environmental monitoring well installation at Moose Creek
c. Manchu Road geotechnical investigations
d. Constructing new road at Take Off pad
6) North Slope— Engineering drawings and calculations for well units
7) Hooper Bay—On site investigations and evaluated 9 structures owned by City of Hooper Bay to
determine economic and social value of each structure