'
•••ill.
F""-V
National Pollutant Discharge Elimination System
PERMIT EVALUATION AND FACT SHEET
May 2, 2007
U t vf
Oregon Department of Environmental Quality
Western Region
1102 Lincoln Street, Suite 210
Eugene, OR 97401
(541) 687-7342
State of Oregon
Department of
Environmental
Quality
Permittee:
City of Creswell
PO Box 276
Creswell, OR 97426
File Number: 20927
Current Permit:
NPDES Permit Number: 101639
EPA Reference Number: OR002754-5
Issue Date: December 28, 1998
Expiration Date: November 30, 2003
Source Information:
City of Creswell Wastewater Treatment Facilities
Source Contact:
West of Meadow Lane in Creswell
Roy Sprout; Public Works Superintendent
Phone: 541-895-2531
Proposed Action:
NPDES Minor Domestic Permit Renewal
Application Number: 984498
Date Received: May 29, 2003
Permit Writer:
Julie M. Bemdt
Phone: 541-687-7342
INTRODUCTION
The City of Creswell operates a municipal wastewater treatment facility located in Creswell, Oregon. Wastewater is
treated and discharged in accordance with National Pollutant Discharge Elimination System (NPDES) Permit
number 101639. The Permit for the facility was issued on December 28, 1998, and expired on November 30, 2003.
In accordance with OAR 340-045-0040, the permit will remain in effect until action is taken on this permit
application. The Department proposes to renew the permit.
FACILITY DESCRIPTION
Creswell has operated wastewater treatment lagoons at the current site since 1962. The original facility consisted of
a pumping station, a barminutor, a Parshall flume, a ten acre lagoon and a chlorine disinfection system. The
City of Creswell Evaluation Report
Page 2
barminutor and Parshall flume were located at 10th and A Streets. The treatment system was expanded in 1984.
Modifications included two additional ten acre lagoon cells, a flow control structure, and a chlorine contact basin.
Raw wastewater flows to the site through a gravity sewer which terminates at the raw sewage pumping station wet
well. The raw sewage pumping station is equipped with four submersible pumps. The pumps convey wastewater to
the lagoon cells which can be operated in paralleEseries mode, which is the normal mode of operation, or in parallel
mode. New piping withdrawal structures in each lagoon have also enabled the operator to control the depth from
which water is withdrawn and transferred from each lagoon, which enables better control to not withdraw from
layers in which excessive algae is present.
After sedimentation and biological oxidation in the three-ten acre lagoon cells, flow is directed to the chorine
disinfection system. Sodium hypochlorite is injected into the wastewater upstream of the contact basin which
provides adequate detention time for disinfection. A sodium bisulfite solution is injected following detention time in
the chorine contact chamber to remove chlorine residual from the effluent in order to meet the water quality standard
for chlorine toxicity.
During the winter months, treated effluent is discharged into an unnamed tributary of the Camas Swale Creek
(referred to in this report as Camas Swale). During the dry weather months, treated effluent is beneficially land
irrigated onto City owned pasture land under a Department approved Reclaimed Water Use Plan (RWUP).
Figure 1
0
*
1
V™'
* .
.¥"
t
w-
• ,J
UJ
. " ' , . ' ' 'l '•
j
;
t
t
••
,, ,
.V,
iT*******
Outran 001
"X.
r l
•
" i'
•
il
mm* „
At*
1
*
-ii
*
., .
*
>,„»*
Historical Operational Problems
Operational problems at the plant have resulted in violations ofthe permit effluent limitations. Some ofthe problems
are as follows:
City of Creswell Evaluation Report
Page 3
1. Algae production in the lagoons has resulted in excess effluent suspended solids which has resulted in
violations ofthe permit effluent limitations for Total Suspended Solids (TSS).
2. Excess TSS had resulted in violations of the BOD5 effluent limitations and has affected the performance
of the disinfection system.
3. Stationary lagoon effluent structures have required the operator to manipulate lagoon levels to maintain
desired withdrawal depth when discharging.
4. Irrigation site limitations have hindered summer irrigation volumes resulting in summertime pond levels
greater than originally planned.
5. Low flows in Camas Swale have resulted in past violations ofthe BOD5 dilution requirement because
the lagoons at times need to be discharged when not enough flow is present in the creek.
6. Effluent chlorine residual concentrations were in violation ofthe chorine toxicity water quality standard.
Because of the ongoing violations at the treatment plant during the last permit cycle, the Department entered into a
Mutual Agreement and Order (MAO) with the City in December 1998. The MAO was signed concurrent with the
issuance of the current permit. The MAO established a compliance schedule to address the deficiencies with the
plant in order that the permittee may come into compliance with the permit effluent limitations and conditions. The
MAO allows for relaxed interim effluent limitations during the period that the City is planning for upgrades to the
treatment facility. The MAO also establishes stipulated penalties for failure to meet the compliance schedule and for
failure to meet the interim effluent limitations. All other conditions ofthe permit apply during this time.
The MAO not only addressed the current violations ofthe permit, but also required that the City plan for upgrades to
comply with the Total Maximum Daily Load (TMDL) for the Willamette Basin and the Coast Fork Willamette
subbasin that was being developed at the time the MAO was signed. In accordance with the TMDL wasteload
allocations (WLAs) would be assigned for certain pollutants in order to meet the water quality standards in the
Willamette Basin. At the time, it was unknown if the City's discharge would be assigned a WLA. The MAO
stipulated that within a certain period of time after completion ofthe TMDL, the City would upgrade the facilities in
order to meet any conditions ofthe TMDL.
The Willamette TMDL was approved by the EPA in September, 2006. Certain pollutants were addressed in this
TMDL such as temperature which will be discussed later in this report. However, the water quality limited status for
dissolved oxygen in Camas Swale was not addressed in this TMDL. Therefore, the City will not be able to plan for
the second phase of upgrades until it is completed. The proposed permit will address those portions of the TMDL
that apply; however, the MAO and the schedule for upgrades to comply with the TMDL will remain in effect until
the TMDL assigns any applicable WLAs.
Treatment Plant Upgrades
The permittee submitted a Facilities Plan in 1999 prepared by West-Yost Engineers to address the problems listed
above. The improvements to the plant were planned to be completed in two phases. The City completed a number of
upgrades in May-June 2005 in accordance with Phase One ofthe facilities plan which included the following:
1. Construction of a new maintenance shop.
2. New piping withdrawal structures in each lagoon that enable the operator to control the depth from which
water is withdrawn and transferred from each lagoon.
3. Upgrading the influent headworks and influent flow monitoring equipment.
City of Creswell Evaluation Report
Page 4
4. Upgrading the chlorination facilities for disinfection and construction of a new de-chlorination system
which injects sodium bisulfite.
5. Improvement to the effluent flow monitoring system.
6. Purchase of composite samplers for influent and effluent sampling.
7. New electrical and back-up power systems.
Improved and new chemical storage facilities and delivery systems.
Purchase of 215 acres of land for expanded irrigation. Construction and installation of new irrigation
pumping and spraying equipment and new flow monitoring systems.
Phase two of the upgrades will include the following options separately or in combination depending on the final
TMDL and the resulting permit requirements:
1.
2.
3.
4.
5.
Relocation of Outfall 001 to the Coast Fork Willamette with a new diffuser.
Relocation of Outfall 001 to a location in Camas Swale Creek with a new diffuser.
Aeration of one or all of the current lagoon cells.
Construction of some type of treatment unit to provide nutrient removal.
Construction of additional holding capacity to better contain and control flows at certain times of the
year.
The City will have between three to four years upon completion of the TMDL for Camas Swale Creek to complete
necessary upgrades to the plant to comply with any waste load allocation that may be assigned to the discharge.
Treatment Plant Flows
The current average dry weather design flow for the plant is 0.2 MGD. The engineer who designed the upgraded
facilities made a determination that the average dry weather design flow (ADWDF) ofthe plant is 0.8 MGD for the
design year 2022.
Based on review of the Discharge Monitoring Reports (DMR) for the period of June, 2005- April, 2007; current
actual average dry weather flow for that period (May 1 - October 31) was 0.426 MGD. The City irrigates
wastewater in the summer months. The City irrigates an average of 0.235 MGD onto the irrigation sites throughout
the summer on a monthly average.
The current actual average wet weather flow (November 1 - April 30) for that same time period was 1.04 MGD with
a maximum monthly flow of 1.53 MGD and a maximum daily flow of 3.5 MGD (See Attachment #1)
With the addition of the new irrigation site, the City should have adequate capacity in the summer months, and with
the completion of phase two upgrades, the stream flows should not play a significant role in limiting the amount that
the City can discharge in the winter thus increasing capacity during the wet months.
Inflow and Infiltration (I/I)
Creswell has historically been allowed a discharge during the month of May in the current and past NPDES permits.
Part of the planned treatment plant and irrigation system upgrades are designed to increase the capacity and
efficiency of the treatment plant itself to deal with high wintertime flows and to expand the irrigation fields to
provide adequate land for irrigation during the summer months. The City completed these requirements as follows:
•
The City purchased 215 acres of new land to expand the available land for irrigation. There is new
pumping and irrigation equipment in place to utilize this land for beneficial wastewater application.
City of Creswell Evaluation Report
Page 5
According to the facilities plan, the City's collection system does receive a significant amount of inflow. Inflow is
comprised of that portion of extraneous water that enters the piping from sources such as leaking manholes, illegal
roof connections and below grade connections to the sewer as opposed to infiltration which is largely comprised of
direct groundwater infiltration into the sewer piping. Inflow is typically considered cost effective to identify and
remove, while infiltration is typically not cost effective to remove.
The City's collection system currently receives infiltration that may reduce the treatment plant's hydraulic capacity.
In the facilities plan it was stated that the lagoon system provides a substantial amount of buffer capacity for
extraneous flows into the collection system and that it may be more cost effective for the City to treat flows rather
than pursue an aggressive EI removal program. The City will continue to identify EI into the system and work to
correct certain identified areas as part of an ongoing I/I removal program. Schedule B of the proposed permit
contains a requirement that the City report on I/I removal activities of the previous year and submit annual plans for
work planned in the following year.
Biosolids Management
Waste sludge accumulates in the treatment lagoon. A Biosolids Management Plan (BMP) must be submitted six
months prior to removing any biosolids from the lagoon. However, the City does not anticipate removing solids
during this permit cycle. The permittee will be required to monitor and report on the biosolids accumulation in
the lagoon on a yearly basis. No land application would be allowed under this permit until a Biosolids
Management Plan is submitted by the permittee and approved by the Department. The Biosolids Management
Plans ensure compliance with the federal biosolids regulations (40 CFR Part 503).
Pretreatment
The Creswell sewage treatment system does not have a formal pretreatment program. There are no categorical
industries discharging to the system and the facility is not experiencing toxic upsets. Therefore, there is no industrial
pretreatment survey recommended for this permit renewal.
Groundwater
A Groundwater Prioritization Evaluation was completed as part of this permit evaluation (see Attachment #2). The
permittee uses lined earthen lagoons for treatment of the wastewater. There is no recent data of the tightness of the
lagoons and whether or not there is excessive leakage that may be adversely impacting groundwater beneath the site.
A compliance condition is included in Schedule C ofthe proposed permit that requires the City to conduct a leak test
on the lagoons in order to demonstrate that they are not leaking in excess of the rate allowed by the Department's
groundwater rules. If the leak test determines that there is excessive leakage, the permittee may be required to
conduct a hydrogeologic characterization of potential impacts to drinking water sources or to line the lagoons to
remediate excessive leakage.
Schedule A of the proposed permit prohibits adverse impacts to groundwater. A condition in Schedule D states
that no groundwater evaluations will be required during this permit cycle.
Stormwater
Stormwater is not addressed in this permit. General NPDES permits for stormwater are not required for facilities
with a design flow of less than 1 MGD.
City of Creswell Evaluation Report
Page 6
Compliance History
The facility was last inspected on February 26, 2007 and was found to be operating in compliance with permit
limitations and conditions. The monitoring reports and files were reviewed for the period that this current permit has
been in effect. The following enforcement actions have been issued to the permittee during this permit cycle:
Violation Date
2/6/2001
7/1/2001
NON Date
9/5/2001
9/5/2001
7/3/2003
12/1/2003
7/3/2003
7/19/2004
HeisslflliiJfc,.
]. No monitoring/reporting; Class three 2. No tank alarm installed; Class two
Reclaimed water flooded neighbor's property. Reclaimed water system changed without review or
approval. Lagoons need maintenance (remove vegetation).
Monthly % TSS removal exceedence, permit limit is 65%. The wastewater plant achieved 58%.
Submitted incomplete DMR.
In July 1995, the City was issued a Notice of Permit Violation (NPV) as a result of the ongoing violations. To
resolve the NPV and because of the ongoing violations at the treatment plant during the last permit cycle, the
Department entered into Mutual Agreement and Order # WQWM-WR-96-154 (MAO) with the City of Creswell in
December 1998. The MAO was signed concurrent with the issuance ofthe current permit. The MAO established a
compliance schedule to address the deficiencies with the plant in order that the permittee may come into compliance
with the permit effluent limitations and conditions. The MAO allows for relaxed interim effluent limitations during
the period that the City is planning for upgrades to the treatment facility. The MAO also establishes stipulated
penalties for failure to meet the compliance schedule and for failure to meet the interim effluent limitations. All other
conditions ofthe permit apply during this time.
The MAO has been amended twice during the permit cycle due to unforeseen delays in the compliance schedule.
The most recent amendment (#2) was made on August 21, 2003. The amendment included recognition of the new
listing of Camas Swale Creek as being water quality limited for dissolved oxygen year round. The previous listing
had been for being WQL for DO only during the summer months.
The facility is considered to be in compliance with all permit limitations and conditions and the conditions and
schedules ofthe MAO.
Outfalls
Outfall 001
During the winter months, all wastewater discharged from the wastewater treatment plant is discharged through
Outfall 001 to the unnamed tributary ofthe Camas Swale Creek. The outfall discharges at RM 4. From the chlorine
contact chamber, wastewater flows through 440 feet of 24 inch pipe to the outfall. The outfall structure consists of a
concrete headwall which is 4 feet wide by 8 by 4.5 feet high. This flows into a four-foot wide by fourteen-foot long
open drainage ditch which flows to the Camas Swale.
In the current permit, the allowable mixing zone for this outfall is defined as that portion ofthe unnamed tributary of
Camas Swale Creek from twenty feet upstream to 500 feet downstream of the outfall. There is no defined Zone of
Immediate Dilution (ZID). Evaluation ofthe current mixing zone is discussed later in this report
Outfall 002 - Reclaimed Water
The City owns approximately 22 acres of pasture land west of the treatment lagoons which is approved for
summertime irrigation of treated effluent. Reclaimed water is beneficially irrigated in the summer months from
Outfall 002 in accordance with the Department approved Reclaimed Water Use Plan and Oregon Administrative
Rules (OAR) Chapter 340, Division 55. The irrigation system consists of stationary sprinklers and the vegetation
includes native grasses and shrubs.
City of Creswell Evaluation Report
Page 7
As part ofthe treatment plant improvements, the City purchased 215 acres of land at 33680 Dillard Road which is
located approximately three miles northeast ofthe plant. Two new turbine pumps are used to transfer the water to the
site. One of the pumps operates and the other is used as a standby. The pumping station wet well is hydraulically
connected to Pond #1 so that this pond provides storage for irrigation pumping.
The permittee's reclaimed water use plan has been approved by the Department. The permit requires annual reports
describing the effectiveness of the reclaimed water system to be submitted annually. Any changes to the approved
plan will follow the procedures outlined in Schedule D.
The reclaimed water will meet Level II reclaimed water standards in order to reduce Total Colifomi bacteria to not
more than 240 organisms per 100 ml in not more than two consecutive samples, and a seven-day median of 23
organisms per 100 ml. No discharge from the irrigation area to state waters is permitted.
All reclaimed water will be distributed on land for dissipation by evapotranspiration by following sound irrigation
practices so as to prevent:
•
•
•
•
•
Prolonged ponding of treated wastewater on the ground surface;
Surface runoff or subsurface drainage through drainage tile;
The creation of odors, fly and mosquito breeding or other nuisance conditions;
The overloading of land with nutrients, organics, or other pollutant parameters; and,
Impairment of existing or potential beneficial uses of groundwater.
Outfall 003
This outfall was an emergency overflow point listed in past permits. The current permit required that during
upgrades to the facility, overflows in the system be eliminated except as allowed under the Department's general
conditions. The City has rebuilt the piping in the influent wet well and headworks of the plant during the Phase 1
improvements. The size ofthe pumps have been increased. Therefore, the outfall will no longer be listed on the face
page ofthe permit as an emergency overflow point.
Pollutants Discharged
The current permit allows the City of Creswell to discharge treated effluent from the wastewater treatment plant to
the Camas Swale Creek from November 1 through May 31 each year and to land irrigation from June 1 - October
31. The current permit sets limits on the following pollutants for discharge to the Camas Swale Creek: Five-day
Biochemical Oxygen Demand (BOD5), Total Suspended Solids (TSS), and E. coli bacteria. The discharge is also
regulated for pH and pollutant removal efficiency. A requirement is included that the BOD dilution factor shall not
exceed one. The discharge in the proposed permit will also be regulated for total chlorine residual with a new
limitation.
RECEIVING STREAM
Treated wastewater is discharged to the unnamed tributary to Camas Swale Creek at RM 4.0. The discharge is
within the Willamette basin and Coast Fork Willamette sub-basin. Applicable water quality standards for Camas
Swale Creek are found in OAR 340-041-0340A. Included in Table 6 as beneficial uses for the Willamette Basin are:
Public domestic water supply,
Private domestic water supply,
Industrial water supply,
Irrigation,
Livestock watering,
City of Creswell Evaluation Report
Page 8
Fish and aquatic life (including salmonid rearing, passage and spawning),
Wildlife and hunting,
Fishing,
Boating,
Water contact recreation,
Aesthetic quality, and
Hydro Power
Section 303(d) ofthe 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. Water quality standards are based on protection of beneficial uses designated for that water
body. The Department has established a list of water bodies that do not meet one or more water quality
standards during the year in accordance with Section 303(d) of the Clean Water Act. The Willamette TMDL
was issued on September 21, 2006, and approved by the EPA on September 26, 2006.
The Camas Swale Creek in the area ofthe outfall is on the Department's List of Water Quality Limited Water
Bodies (also called the 303(d) List) as water quality limited for the following parameter:
Record ID
8527
Waterbody Name
Camas Swale Creek
River Mile
Oto 9.4
Parameter
Dissolved Oxygen
Season
October 1 - May 31
List Date I.isiinu Mains
2002
303(d) List
The following are the details ofthe listing:
Field
Waterbody Name
Sub Basin Name
River Mile
Parameter
Criteria
Season
Listing Status
Supporting Data
Details
Camas Swale Creek
COAST FORK WILLAMETTE
0 to 9.4
Dissolved Oxygen
Spawning: 11 mg/L or 95% saturation
October 1 - May 31
303(d) List
LASAR 15786 RM 0.1: 100% (5/5 samples) < 11 mg/L and 95 % saturation. LASAR 15785 RM 1.2:
100% (7/7 samples) < 11 mg/L and 95% saturation.
The TMDL for the Willamette basin or the Coast Fork Willamette River did not assign any waste load
allocations for any pollutants associated with dissolved oxygen. When a TMDL is completed for Camas Swale
Creek, a WLA will likely be assigned to the City for oxygen demanding pollutants. The MAO addresses this
status by requiring the City to complete any necessary upgrades to the plant once a TMDL is completed.
In addition, the Coast Fork Willamette River downstream of the discharge is listed on the 303(d) list for the
following parameters:
Record ID
5896
6048
7084
6853
6853
Waterbody Name
Coast Fork Willamette River
Coast Fork Willamette River
Coast Fork Willamette River
Coast Fork Willamette River
Coast Fork Willamette River
River Mile
Parameter
0 to 38.8 Temperature
Oto 31.3 Fecal Coliform
Oto 31.3 Mercury
Oto 38.8 Iron
0 to 28.5 Dissolved Oxygen
Season
Year round (non-spawning)
Winter/Spring/Fall
Year Around
Year round
Year Round
List Date
2004
TMDL Approved
1998
2004
TMDL Approved
City of Creswell Evaluation Report
Page 9
During the period of the City's discharge, the Coast Fork Willamette River is listed for Mercury, Iron, and
Temperature. The TMDL for dissolved oxygen and fecal coliform bacteria have been approved and waste load
allocations have been assigned to those sources that are contributing to the WQL status of the river. Any waste
load allocations based on the status of the Coast Fork will be determined upon completion of the future TMDL
for these WQL parameters.
Mixing Zone Analysis
Federal regulations (40 CFR 131.13) allow for the use of mixing zones, also known as "allocated impact zones".
When using mixing zones, acute toxicity to drifting organisms must be prevented and the integrity of the
waterbody as a whole may not be impaired. Mixing zones allow the initial mixing of waste and receiving water,
but are not designed to allow for treatment. EPA does not have specific regulations pertaining to mixing zones.
Each state must adopt its own mixing zone regulations that are subject to review and approval by EPA. In
States that lack approved mixing zone regulations, ambient water quality standards must be met at the end of the
pipe.
The Department has adopted the two-number aquatic life criteria and developed mixing zone regulations with
respect to that. The regulations are primarily narrative and essentially require the permit writer to use best
professional judgment in establishing the size of the mixing zone. Based on EPA guidance and the
Department's mixing zone regulations, two mixing zones may be developed for each discharge that reflect acute
and chronic effects: 1) The acute mixing zone, also known as the "zone of initial dilution" (ZID), and 2) the
chronic mixing zone, usually referred to as "the mixing zone". The acute mixing zone is designed to prevent
lethality to organisms passing through the ZID. The chronic mixing zone is designed to protect the integrity of
the entire water body as a whole. The allowable size ofthe mixing zone should be based upon the relative size
of the discharge to the receiving stream, the beneficial uses of the receiving stream, location of other discharges
to the same water body, location of drinking water intakes, and other considerations. More specific guidance is
available from EPA regarding criteria used in appropriately sizing a ZID. Primarily the ZID must be designed
to prevent lethality to drifting organisms.
The Department's mixing zone regulations state the mixing zone must be less than the total stream width as
necessary to allow passage of fish and other aquatic organisms. Early recommendations regarding the size of
the zone of passage originated from the Department of Interior (1968). They recommended a zone of passage of
75 percent of the cross-sectional area and/or volume of flow of the receiving stream. Based on this
recommendation, the Department's standard practice is to allow no more than 25 percent ofthe stream flow for
mixing zones.
The current permit provides for a mixing zone which is defined as that portion of the unnamed tributary of Camas
Swale Creek from twenty feet upstream to 500 feet downstream of the outfall. There is no defined Zone of
Immediate Dilution (ZID). The permit also requires at that the BOD5 dilution ratio not be less than 1. This is one of
the minimum design criteria that engineers use when designing a domestic wastewater plant with secondary
treatment. It also is included in permits where there is concern about inadequate flows in the receiving stream. The
ratio is calculated as follows:
Effluent BODs (in mg/L)
Stream Flow/Effluent Flow
In September 2000 the City submitted a report titled Water Quality and Mixing Zone Analysis prepared by West
Yost and Associates. This report was required as an NPDES permit condition to demonstrate that the facility
complies with acute and chronic standards for toxic substances within and at the edge of the zone of immediate
dilution, and the mixing zone, or what would be done in order to comply. The report was approved for this
purpose on July 10, 2000.
City of Creswell Evaluation Report
Page 10
The report used the EPA hydrodynamic computer modeling program, CORMIX, to evaluate the dilution achieved
for typical seasonal receiving water and effluent rates. A Streeter-Phelps model was also used to evaluate the
assimilative capacity of Camas Swale Creek. These models were run at a proposed outfall location to determine
whether or not the City could discharge to Camas Swale Creek within the limitations of the current permit and all
applicable water quality standards.
There is no historical flow data for Camas Swale Creek collected by the USGS. In order to gather data, the
consultant installed a temporary staff gauge at a bridge 1500 feet downstream ofthe proposed outfall location. A
survey ofthe stream's cross section and gathering of periodic water velocity and water depth measurements were
conducted so that the gauge reading could be accurately converted into calculated stream flows and indexed to staff
gauge readings. A flow curve was then developed that defined the relationship between the two.
This gauge can now be used to accurately adjust the discharge flow so that the dilution factor in the permit is met.
Based on the design flows in the permit and for the current plant, if the City achieves the 30:1 dilution required in
the permit, or the BOD dilution factor is less than 1, there is no reasonable potential for violations of the
temperature standard, the ammonia toxicity standard, the chlorine toxicity standard, or the dissolved oxygen
standard at the edge ofthe mixing zone.
Based on these evaluations, the mixing zone dimensions are proposed to remain the same. A ZID will not be
included at this time because the outfall location is projected to be moved during the second phase of facility
upgrades and a new mixing zone and a zone of immediate dilution (ZID) will be established at that time.
Anti-degradation Review
OAR 340-041-0004 describes the Environmental Quality Commission's (EQC) Antidegradation Policy for Surface
Waters. In summary, the policy is intended to guide the decisions that affect water quality such that unnecessary
degradation from point and nonpoint sources of pollution is prevented. The Department must make certain findings
and consider certain issues before renewing the permit to allow discharge to the river. This is to be in accordance
with the Department's "Antidegradation Policy Implementation Internal Management Directive for NPDES Permits
and Section 401 Water Quality Certifications (March, 2001)". The Department is obligated to review the request in
relation to other alternatives to the request, beneficial uses which may be impacted, and the potential impacts to the
water quality ofthe receiving stream.
The Camas Swale Creek is listed as not meeting the dissolved oxygen standard for spawning year round.
An Anti-Degradation review was done with this proposed permit renewal to ensure that the proposed permit
meets the intent of the policy and rule. For this type of domestic discharge, dissolved oxygen and temperature
were evaluated for a lowering of water quality (measurable change). As described below, these and other
individual parameters were evaluated to ensure the policy and rule was being met (See Attachment #3).
Dissolved Oxygen (DO)
A Streeter-Phelps dissolved oxygen spreadsheet model was used to determine if the discharge had the potential
to violate the dissolved oxygen standard. A dissolved oxygen depression less than 0.1 mg/L is considered
immeasurable.
During facilities planning, a Streeter-Phelps Model was used to predict instream DO levels (sag) at various
conditions including low flow conditions during the permitted discharge period. The Department also
conducted an evaluation using this model and it is included as Attachment #4.
City of Creswell Evaluation Report
Page 11
Since the permit contains a restriction of discharge when the ratio of the dilution of the BOD is below 30:1, this
dilution was used in the model using 25% of that flow to model the portion of the river allowed for mixing in the
amended mixing zone described above. The discharge flow rate from the facility is based on double the estimated
Design Average Wet Weather Flow (DAWWF) for the facility which is 0.4 MGD. Therefore, the Department used
the dilution ratio of 7.5:1 for the effluent to Camas Swale Creek. The model was run at intervals of .25 miles for the
4 miles above the confluence of the Coast Fork Willamette River. All of the model runs demonstrated that the
estimated maximum DO sag created by the WWTP discharge was less than 0.1 mg/l.
When river flows are too low to discharge, the City will either store effluent or use land application of approved sites
for disposal.
Temperature Issues
Water temperature affects the biological cycles of aquatic species and is a critical factor in maintaining and
restoring healthy salmonid populations throughout the state. It is the policy of the Environmental Quality
Commission (EQC) to protect aquatic ecosystems from adverse temperature changes caused by anthropogenic
activities. The purpose of the temperature criteria listed in OAR 340-041-0028 is to protect designated
beneficial uses that are temperature sensitive, including salmonids in waters ofthe State.
The Department utilizes Fish Use Designation and Salmon and Steelhead Spawning Use Designations maps to
identify applicable temperature criteria for each basin. The Willamette Basin maps are contained in OAR 340041, Figures 340A and 340B, respectively. According to the newly approved use designation maps, spawning is
not a designated use for the Camas Swale Creek and therefore, the applicable numeric temperature criterion is
18°C for rearing and migration.
Winter Discharge Season
The Department's List of Water Quality Limited Water Bodies (also called the 303(d) List) for 2002 and 2004
indicate the Camas Swale Creek is not water quality limited for temperature at any time during the year.
The Willamette Total Maximum Daily Load (TMDL) was issued by the Department on September 21, 2006,
and approved by the EPA on September 26, 2009. The 303 (d) List for 2002 indicates the Willamette River is
water quality limited for temperature from April 1 through October 31. The City of Creswell does discharge
during this period from April 1 through May 31.
The Willamette TMDL included Waste Load Allocations (WLA) for discharges to tributaries in the Willamette
River Sub-basins. Therefore, in accordance with the Willamette Sub-basin TMDL Waste Load Allocations,
sources that discharge effluent warmer than ambient temperatures and applicable biologically-based criteria
must be evaluated for potential to contribute to exceedances of numeric criteria. Facilities found to have no
reasonable potential to warm the receiving water do not require a wasteload allocation and are allowed to
discharge within their current permit.
The City of Creswell's effluent temperature impacts were assessed for the discharge period during April 1
through May 31. The assessment was conducted in accordance with the Sub-basin TMDL Waste Load
Allocations by using a flow chart process contained in the TMDL as follows:
Does the point source discharge warm the river less than 0.3 °C above numeric criterion given 25% of
7Q10 flow? If yes, then the source is assigned an Allocation based on 0.3 °C and 25% of 7Q10 low flow or
the Department makes a determination of no reasonable potential for temperature increase and
therefore, the source may discharge at current level.
The Department calculated in-stream temperature increases (see Attachment #6a and b) using five times (5x)
the existing facility dry weather design flow of 0.2 MGD (1.0 MGD) to be conservative and account for higher
City of Creswell Evaluation Report
Page 12
wet weather discharge flows, a maximum effluent temperature of 20°C (higher than that which has been
reported to be conservative), 25% of the required dilution, and the actual required dilution at the edge of the
mixing zone (critical low flow), and the stream temperature criteria of 18°C. Based on the spreadsheet
calculations, the in-stream temperature increase is smaller than the allowable increase. Therefore, this facility
has no reasonable potential to violate the temperature standard. Based on this analysis, an Excess Thermal Load
limit has not been included in this permit and the City may continue to discharge at the current level. This also
demonstrates no lowering of water quality from temperature.
Finally, based on the above assessment the Department has also determined that the effluent discharge is in
accordance with OAR 340-041-0053 (2)(d) Temperature Thermal Plume Limitations as follows: Temperature
mixing zones and effluent limits authorized under OAR 340-04l-0028(12)(b) will be established to prevent or
minimize the following adverse effects to salmonids inside the mixing zone:
(A) Impairment of an active salmonid spawning area where spawning redds are located or likely to be
located. This adverse effect is prevented or minimized by limiting potential fish exposure to
temperatures of 13 °C or less for salmon and steelhead, and 9 °C for bull trout;
(B) Acute impairment or instantaneous lethality is prevented or minimized by limiting potential fish
exposure to temperatures of 32.0 °C or more to less than two seconds;
(C) Thermal shock caused by a sudden increase in water temperature is prevented or minimized by limiting
potential fish exposure to temperatures of 25.0 °C or more to less than five percent ofthe cross section
of 100 percent ofthe 7Q10 flow ofthe water body; the Department may develop additional exposure
timing restrictions to prevent thermal shock; and;
(D) Unless the ambient temperature is 21.0 °C or greater, migration blockage is prevented or minimized by
limiting potential fish exposure to temperatures of 21.0 °C or more to less than 25 percent of the cross
section of 100 percent ofthe 7Q10 low flow ofthe water body.
According to the Oregon Department of Fish and Wildlife (ODF&W) District Biologist, there are no active
salmonid spawning redds in the vicinity of the Creswell effluent discharge to the Camas Swale Creek. In
addition, the measured maximum effluent temperature of the discharge during this period is 20.0 °C, which is in
accordance with the Thermal Plume Limitations listed above.
To support the Thermal Plume limitations for C, above, the Department calculated the in-stream temperature
increase using the average total projected discharge of 1.0 MGD, the maximum observed effluent discharge
temperature of 20 °C, the applicable numeric criterion of 18 °C, and 5%> ofthe cross section of 100 percent of
the 7Q10 flow of Camas Swale Creek. This information was input into the thermal calculator spreadsheet to
determine if there is a reasonable potential to warm the river above the criterion (See Attachment #6c).
To support the Thermal Plume limitations for D, above, the Department used the thermal calculator spreadsheet
to determine the in-stream temperature increase using the same input data above, but using less than 25 %> of the
cross section of 100 percent ofthe minimum dilution requirement flow of Camas Swale Creek (See Attachment
#6d). Both spreadsheets indicated that there is no reasonable potential for the discharge to violate the criterion
and that the discharge is accordance with Thermal Plume limitations.
Chlorine Toxicity
Disinfection of the effluent with chlorine is the process the plant is designed to use in order to comply with the
waste discharge limitations for bacteria. The current facility uses sodium hypo-chlorite solution to disinfect the
treated wastewater. Chlorine is a known toxic substance and as such is subject to limitation under Oregon
Administrative Rules. The rule (OAR 340-041-0033(2)) states in part that toxic substances shall not be
City of Creswell Evaluation Report
Page 13
discharged to waters of the state concentrations that adversely affect public health, aquatic life or other
designated beneficial uses. In addition, concentrations of toxic substances shall not exceed the criteria listed in
Table 20 which were based on criteria established by the EPA and published in Quality Criteria for Water
(1986), unless otherwise noted.
However, OAR 340-041-0053(2)(b)(A) states that the Department may allow a designated portion of a receiving
water to serve as a zone of dilution for wastewaters and receiving waters to mix thoroughly and this zone will be
defined as a mixing zone. The Department may suspend all or part of the water quality standards, or set less
restrictive standards, in the defined mixing zone, provided the water within the mixing zone is free of materials
in concentrations that will cause acute toxicity to aquatic life as measured by the acute bioassay method and
outside the boundary ofthe mixing zone is free of materials in concentrations that will cause chronic toxicity.
Furthermore, 40 CFR § 122.44(d) states that permit limitations must control all pollutants or pollutant parameters
which are or may be discharged at a concentration which will cause, have the reasonable potential to cause, or
contribute to an excursion above any state water quality standard, including state narrative criteria for water
quality. According to OAR 340-041, Table 20, chlorine concentrations of 11 pg/L can result in chronic toxicity
in fresh waters while 19 pg/L can result in acute chlorine toxicity in fresh waters.
The Phase 1 upgrades to the new facility included installation of a dechlorination system of sodium bisulfite being
injected into the chlorinated wastewater to reduce or eliminate residual chlorine. The Department determined
effluent chlorine residual concentrations based on an EPA spreadsheet taking into account dilutions at the edge ofthe
mixing zone and the ZID to establish limitations for acute and chronic concentrations that will meet the water quality
standard for chlorine toxicity (See Attachment #5a and b).
The limits are as follows:
Pollutant
Total Chlorine Residual
Limitations
Shall not exceed 0.019 mg/L daily maximum and 0.009 mg/L monthly average
The permittee should have little difficulty meeting these new limitations. In accordance with EPA Region X
guidance for establishing water quality based effluent limits (WQBEL) below analytical detection limits; the
Department is including the above limits in the permit but is using the promulgated Minimum Level (ML) as the
"compliance evaluation level". Daily maximum concentrations below 0.10 mg/L will be considered in
compliance with the limitation.
Ammonia
The State of Oregon has adopted the EPA 1999 ammonia criteria but the new criteria have not been formally
approved by EPA. Until that time, the existing toxicity standards currently contained in OAR Chapter 340,
Table 20 from the EPA 1986 Gold Book Criteria are used for ammonia toxicity limits that might be necessary in
a permit.
A reasonable potential analysis (See Attachment #5a) was conducted using the effluent and stream dilution data
as described in the sections above. Using the highest effluent ammonia data from 25 samples for ammonia, the
spreadsheet does not show that there is a reasonable potential to violate the ammonia toxicity standard at the
edge of the mixing zone and ZID. Therefore, no limit is included in this permit.
pH
The effluent limits for pH for the current and proposed permits are 6.0 to 9.0 for the facility. The Willamette
Basin water quality standards for pH are established in OAR 340-041-0326. The allowed ambient range is 6.5
to 8.5. The proposed permit limits pH to the range of 6.0 to 9.0. An evaluation of pH at the edge ofthe mixing
City of Creswell Evaluation Report
Page 14
zone shows that the facility will not cause a violation ofthe standard with a range of 6.0 to 9.0 (see Attachment
#7). This limit is in accordance with Federal wastewater treatment guidelines for sewage treatment facilities (in
40 CFR 133.102(c)) and is applied to the majority of NPDES permittee's in the state. Within the permittee's
mixing zone, the water quality standard for pH does not have to be met. The Department considers the proposed
permit limits to be protective of the water quality standard.
E. coli bacteria (Fecal Bacteria)
The Camas Swale Creek in the area ofthe discharge is not listed on the 303(d) list for fecal bacteria. The Coast
Fork Willamette River below the discharge is listed for this parameter. The bacteria standard is established to be
protective of the beneficial use of water contact recreation and the NPDES permit serves as the Bacteria
Management Plan for the discharge.
Summary
It is the Department's opinion that continued discharge into Camas Swale should not cause a measurable
decrease in the DO concentration or a measurable increase in temperature above the temperature criteria of the
Creek. All water quality standards will be met at the edge of the mixing zone or as otherwise required and
therefore, it is assumed that all beneficial uses for the receiving water body are being protected.
PROPOSED PERMIT DISCUSSION
Face Page
The face page provides information about the permittee, description of the wastewater, outfall location,
receiving stream information, permit approval authority, and a description of permitted activities. The permittee
is authorized to construct, install, modify, or operate a wastewater collection, treatment, control, and disposal system.
Permits discharge of treated effluent to the unnamed tributary of Camas Swale Creek at RM 4.0, and by spray
irrigation within limits set by Schedule A and the following schedules. All other discharges are prohibited.
A new LLID designation replaces the hydro-code in this permit to describe the Outfall location. Outfall 003 has
been removed as a listed outfall. The engineered overflow is still at this location, however; no overflows are
allowed from this source unless the cause of the discharge is due to storm events as allowed under Schedule
F.6.b.
OAR 340-49-025 lists the criteria for classification of wastewater treatment plants based on parameters
including, but not limited to type and complexity of process, design flow, population served, and effluent
requirements. The Department has incorporated the classification of the collection and treatment systems into
the NPDES discharge permit. In the current permit, the treatment system is considered Class I systems and the
collection system is considered a Class II system. The upgraded plant and collection system were re-evaluated to
determine the appropriateness ofthe current classification for operator certification requirements.
An evaluation ofthe current plant operations and systems results in an updated treatment plant classification of Level
II. (see Attachment #8). Treatment plant supervisor and operator(s) classification requirements will need to
meet the necessary criteria for this level of classification. This requires that the plant be supervised by one or more
operators who hold valid certification at or above this level. The collection system classification remains the same
(Level II).
Schedule A - Waste Discharge limitations:
Based on the Willamette Basin minimum design criteria, wastewater treatment resulting in a minimum of secondary
treatment is required from November 1 through April 30. Secondary treatment in Oregon is defined as monthly
average concentration limit of 30 mg/L for BOD5 and 30 mg/L for TSS. Lagoons are given special consideration in
City of Creswell Evaluation Report
Page 15
setting concentrations limits for TSS. The monthly average TSS concentration limit can be 50 mg/L with a weekly
average limit of 80 mg/L.
The facility's current permit mass load limits (monthly and weekly average and daily maximum) for BOD5 and
TSS are based on twice the design average dry weather flow (ADWF) of 0.2 MGD and the monthly average
BOD5 and TSS concentration limit of 30 mg/L and 50 mg/L, respectively. These limits will be retained in Phase
I of the proposed permit until the new upgraded facility is constructed and becomes operational after completion
of the TMDL for Camas Swale Creek.
The current and proposed permit limitations for BOD5 and TSS are as follows:
a.
Treated Effluent Outfall 001
(1) June 1 - October 31: No discharge to waters ofthe State (unless approved in writing by the
Department)
(2) November 1-May 31
Parameter
BOD5
TSS
Average Effluent
Concentrations
Monthly
Weekly
30 mg/L
45 mg/L
50 mg/L
80 mg/L
Monthly*
Average
lb/day
100
170
Weekly*
Average
lb/day
150
250
Daily*
Maximum
lbs
200
330
•
Average dry weather design flow to the facility equals 0.2 MGD. Winter mass load
limits based upon twice the design average dry weather flow to the facility equaling
0.40 MGD.
Calculations are rounded to two significant digits and are as follows:
(1)
BOD5 (November 1 - May 31)
(a)
(b)
(c)
(1)
0.40 MGD x 8.34 lbs/gal x 30 mg/l = 100 lbs/day monthly average
100 lbs/day monthly avg. x 1.5 = 150 lbs/day weekly avg.
100 lbs/day monthly avg. x 2.0 = 200 lbs/day daily maximum
TSS (November 1 - May 31)
(a)
(b)
(c)
0.40 MGD x 8.34 lbs/gal x 50 mg/l = 170 lbs/day monthly average
170 lbs/day monthly avg. x 1.5 = 250 lbs/day weekly avg.
100 lbs/day monthly avg. x 1.5 = 330 lbs/day weekly avg.
BOD and TSS Removal Efficiency
In addition to the concentration and mass load limits for BOD5 and TSS, the proposed permit requires a minimum
monthly average BOD removal efficiency of 85 percent and a TSS removal efficiency of 65%. These are the same
as in the current permit.
pH
The proposed permit discharge limits for pH are the same as the current permit. The Willamette Basin Water Quality
Standard for pH is found in OAR 340-041-0445 (2)(d). The allowed range is 6.5 to 8.5. The proposed permit limits
pH to the range of 6.0 to 9.0. This limit is based on Federal wastewater treatment guidelines for sewage treatment
City of Creswell Evaluation Report
Page 16
facilities, and is applied to the majority of NPDES permittees in the state. Within the permittee's mixing zone, the
water quality standard for pH does not have to be met. It is the Department's belief that mixing with ambient water
within the mixing zone will ensure that the pH at the edge ofthe mixing zone meets the standard, and the Department
considers the proposed permit limits to be protective ofthe water quality standard.
Fecal Bacteria
The current and proposed permit contains limits on E. coli limits for Outfall 001 that are based on the surface
water quality bacteria standard approved in January 1996. The limits are a monthly geometric mean of 126 E.
coli per 100 mL, with no single sample exceeding 406 E. coli per 100 mL.
The bacteria standard allows that if a single sample exceeds 406 E. coli per 100 mL, then the permittee may take
five consecutive re-samples. If the log mean ofthe five re-samples is less than or equal to 126, a violation is not
triggered. The new rule states that the re-samples should be taken at four hour intervals beginning as soon as
practicable (preferably within 28 hours) after the original sample was taken. Because the permittee does not
operate their own lab, a hardship clause allows the permittee to resample within 72 hours.
Chlorine
The proposed permit contains a chlorine limit as discussed earlier in this report and is as follows:
Pollutant
Total Chlorine Residual
Limitations
Shall not exceed 0.019 mg/L daily maximum and 0.009 mg/L monthly average
In accordance with EPA Region X guidance for establishing water quality based effluent limits (WQBEL)
below analytical detection limits; the Department is including the above limits in the permit but is using the
promulgated Minimum Level (ML) as the "compliance evaluation level". Daily maximum concentrations below
0.10 mg/L will be considered in compliance with the limitation.
Mixing Zone
The current permit provides for a mixing zone which is defined as that portion of the unnamed tributary of
Camas Swale Creek from twenty feet upstream to 500 feet downstream of the outfall. The permit also
requires at that the BOD5 dilution ratio not be less than 1. This is one of the minimum design criteria that
engineers use when designing a domestic wastewater plant with secondary treatment. It also is included in
permits where there is concern about inadequate flows in the receiving stream. The mixing zone dimensions
are proposed to remain the same.
Raw Sewage Overflows
No overflows are allowed from this source unless the cause of the discharge is due to storm events as allowed
under Schedule F.6.b. as described earlier in this report.
Groundwater
Schedule A prohibits any adverse impact on groundwater quality. A compliance condition is included in
Schedule C that requires a leak test to determine lagoon tightness. In addition, Schedule D of the proposed
permit states that no groundwater evaluations will be required during this permit cycle if no excessive leakage is
found.
Outfall 002 - Reclaimed Water
The utilization of treated effluent for agricultural purposes is regulated under OAR 340-55. Prior to irrigation of
the reclaimed water, the discharge must comply with bacteria limits based on protection of human health due to
human pathogens. For Level II reclaimed water, the limits include a weekly median of 23 total coliform per 100
mis with no two consecutive samples to exceed 240 total coliform per 100 mis.
City of Creswell Evaluation Report
Page 17
Treated wastewater shall be distributed on land, for dissipation by evapotranspiration and controlled seepage by
following sound irrigation practices so as to prevent:
•
•
•
•
•
Prolonged ponding of treated reclaimed water on the ground surface.
Surface runoff or subsurface drainage through drainage tile.
The creation of odors, fly and mosquito breeding or other nuisance conditions.
The overloading of land with nutrients, organics, or other pollutant parameters; all consumptive and
agronomic site loadings must be according to your approved RWUP.
Impairment of existing or potential beneficial uses of groundwater.
Specific crops, application rates and buffers are approved by the Department within the Reclaimed Water Use
Plan. The bacterial effluent limitations are achievable through proper operation and maintenance.
Schedule B - Minimum Monitoring and Reporting Requirements.
Schedule B describes the minimum monitoring and reporting necessary to demonstrate compliance with the
conditions of this permit. The authority to require periodic reporting by permittees is included in ORS
468.065(5). Self-monitoring requirements are the primary means of ensuring that permit limitations are being
met. However, other parameters need to be monitored to collect information when insufficient information
exists to establish a limit, but where there is a potential for a water quality concern.
In 1988, the Department developed a monitoring matrix for commonly monitored parameters. The matrix was
updated in 2004. Proposed monitoring frequencies for all parameters are based on this matrix and, in some
cases, may have changed from the current permit. The proposed monitoring frequencies for all parameters
correspond to those of facilities of similar size and complexity in the state.
The permittee is required to have a laboratory Quality Assurance/Quality Control program. The Department
recognizes that some tests do not accurately reflect the performance of a treatment facility due to quality
assurance/quality control problems. These tests should not be considered when evaluating the compliance ofthe
facility with the permit limitations. Thus, the Department is also proposing to include in the opening paragraph
of Schedule B a statement recognizing that some test results may be inaccurate, invalid, do not adequately
represent the facility's performance and should not be used in calculations required by the permit.
Below is a discussion of some of the minimum monitoring requirements contained in the proposed permit:
Influent and Outfall 001 (Treated Effluent)
Daily monitoring of influent and effluent flow are required when discharging and calibration of the flow meters
annually are required in this permit.
Monitoring of the influent and effluent for BOD5 and TSS is retained at once per two weeks when discharging.
Pounds of effluent BOD5 and TSS must be calculated at the same frequency.
Federal secondary treatment standards require municipal sources to achieve a specific BOD5 and TSS removal
efficiency as a monthly average. Reporting of the removal efficiencies is required in the current permit and no
changes are proposed.
The proposed permit requires bacteria monitoring of the effluent for E. coli bacteria once per two weeks.
Monitoring for E. coli must be performed in accordance with one of the methods approved by the Department.
Monitoring of the influent and effluent for pH is required two times per week as in the current permit in
accordance with the monitoring matrix. Temperature monitoring of the effluent is also required two times per
week.
City of Creswell Evaluation Report
Page 18
Sampling and reporting of Total Chlorine Residual is required daily when discharging.
Flow is required to be monitored in the Camas Swale Creek daily if discharge is to occur through Outfall 001. The
flow is to be reported from the staff gauge and flow curve that were developed by the City's engineer. BOD dilution
ratio is required to be reported once per two weeks when the BOD samples are collected and used to gauge flow for
that two week period until the next sample.
Outfall 002 - Level 2 Reclaimed Water
The following monitoring is required when irrigating wastewater from Outfall 002:
Item or Parameter
Flow Meter Calibration
Quantity Distributed for
Irrigation
Quantity Chlorine Used
Total Chlorine Residual
pH
Total Coliform
Nutrients (TKN, N0 2 +N0 3 -N,
NH3, Total Phosphorus)
Minimum Frequency
Annually
Daily
Type of Sample
Verification
Measurement
Daily
Daily
2/Week
1/Week
Quarterly
Measurement
Grab
Grab
Grab
Grab
Biosolids
The permittee stores sludge in the facultative lagoons and does not have or need an approved biosolids management
plan until such time as sludge will be removed from the lagoons and used beneficially. This plan is necessary prior
to land apply sludge from the treatment system.
Six months prior to the removal of accumulated solids from the lagoons, the permittee shall submit to the
Department a biosolids management plan developed in accordance with Oregon Administrative Rule 340,
Division 50, "Land Application of Domestic Wastewater Treatment Facility Biosolids, Biosolids Derived
Products, and Domestic Septage". Upon approval ofthe plan by the Department, the plan shall be implemented
by the permittee.
Reporting
The reporting period is the calendar month. Discharge monitoring reports must be submitted to the Department
monthly by the 15th day of the following month. The monitoring reports need to identify the principal operators
designated by the Permittee to supervise the treatment and collection systems. The reports must also include
records concerning application of biosolids and all applicable equipment breakdowns and bypassing.
Schedule B of the permit includes the requirement for the submittal of two annual reports. The conditions are
standard language requirements concerning:
•
•
Annual report which details progress towards reducing inflow and infiltration.
Annual report describing the reclaimed water use activities.
Schedule C, Compliance Schedules and Conditions
The permit contains two compliance conditions with deadlines as follows:
City of Creswell Evaluation Report
Page 19
1) Six months prior to the removal of accumulated solids from the lagoon, the permittee shall submit to the
Department a biosolids management plan developed in accordance with Oregon Administrative Rule
340, Division 50, "Land Application of Domestic Wastewater Treatment Facility Biosolids, Biosolids
Derived Products, and Domestic Septage". Upon approval ofthe plan by the Department, the plan shall
be implemented by the permittee.
2). By no later than December 31, 2009, the permittee shall submit to the Department a Lagoon Leakage
Estimate Report. This report shall comply with the Department's Guidelines for Estimating Leakage
from Existing Sewage Lagoons, with the exception that the report may be prepared by an independent
qualified wastewater professional. If the leakage estimate is 0.125 inches per day or less then no further
groundwater investigation is necessary during the term of this permit. If the leakage estimate is greater
than 0.125 inches per day, then within eight months of notification by the Department, permittee shall
submit either plans and specifications for corrective measures (such as pond lining or replacement of the
system) or a Preliminary Groundwater Assessment and Hydrogeologic Characterization Report. Based
on the Department's review of the Report, additional characterization and/or monitoring may be
required.
The other condition requires the permittee to meet the compliance dates established in this schedule or notify the
Department within fourteen days following any lapsed compliance date.
Schedule D - Special Conditions
The proposed permit includes six special conditions. They concern biosolids management, operator certification, a
reclaimed water use plan, a landscape irrigation exemption from OAR 340-055, groundwater monitoring, and
notifying the Department of any malfunctions.
Schedule F, NPDES General Conditions
All NPDES permits issued in the State of Oregon contain certain conditions that remain the same regardless of
the type of discharge and the activity causing the discharge. These conditions are called General Conditions.
These conditions can be changed or modified only on a statewide basis. The latest edition of the NPDES
General Conditions is July 2005 and this edition is included as Schedule F of the draft permit.
Section A contains standard conditions which include compliance with the permit, assessment of penalties,
mitigation of noncompliance, permit renewal application, enforcement actions, toxic discharges, property rights
and referenced rules and statutes. Section B contains requirements for operation and maintenance of the
pollution control facilities. This section includes conditions for proper operation and maintenance, duty to halt
or reduce activity in order to maintain compliance, bypass of treatment facilities, upset conditions, treatment of
single operational events, overflows from wastewater conveyance systems and associated pump stations, public
notification of effluent violation or overflow, and disposal of removed substances. Section C contains
requirements for monitoring and reporting. This section includes conditions for representative sampling, flow
measurement, monitoring procedures, penalties of tampering, reporting of monitoring results, additional
monitoring by the permittee, averaging of measurements, retention of records, contents of records, and
inspection and entry. Section D contains reporting requirements and includes conditions for reporting planned
changes, anticipated noncompliance, permit transfers, progress on compliance schedules, noncompliance which
may endanger public health or the environment, other noncompliances, and other information. Section D also
contains signatory requirements and the consequences of falsifying reports. Section E contains the definitions
used throughout the permit.
PERMIT PROCESSING/PUBLIC COMMENT/APPEAL PROCESS
The beginning and end date of the public comment period to receive written comments regarding this permit,
and the contact name and telephone number are included in the public notice. The permittee is the only party
City of Creswell Evaluation Report
Page 20
having standing to file a permit appeal. If the Permittee is dissatisfied with the conditions of the permit when
issued, they may request a hearing before the EQC or its designated hearing officer, within twenty days of the
final permit being mailed. The request for hearing must be sent to the Director of the Department. Any hearing
held shall be conducted pursuant to regulations of the Department.