HomeMy WebLinkAbout98.06-26-2019 Board Meeting Item 11 Attachment 1 - Annual Biosolids Compliance Report.pdfBIOSOLIDS MANAGEMENT COMPLIANCE REPORT
ORANGE COUNTY SANITATION DISTRICT
Year 2018 EPA 40 CFR Part 503
TABLE OF CONTENTS
2018 BIOSOLIDS MANAGEMENT COMPLIANCE REPORT
Introduction ............................................................................................................................ 1
Organization and Function ..................................................................................................... 1
2018 Accomplishments .......................................................................................................... 1 Treatment Plants and Program Updates ................................................................................ 2 Biosolids Management ........................................................................................................... 4 Summary of Pollutants ........................................................................................................... 5
Determination of Hazardousness ........................................................................................... 5
Biosolids Management System .............................................................................................. 6 APPENDIX A Table 1: OCSD Biosolids Wet and Dry Tonnage Distribution for 2018, Plant No. 1 Table 2: OCSD Biosolids Wet and Dry Tonnage Distribution for 2018, Plant No. 2 Biosolids Monthly Compliance Report, January – December 2018 APPENDIX B OCSD’s Resource Protection Division, Pretreatment Program’s Annual Report, FY 2017-2018, Solids Management Program, Chapter 9 APPENDIX C
Summary of Priority Pollutants and Trace Constituents Analysis in Biosolids for 2018 APPENDIX D EPA Biosolids Annual Report Electronic Form for Reporting Year 2018, Plant No. 1 EPA Biosolids Annual Report Electronic Form for Reporting Year 2018, Plant No. 2
APPENDIX E Arizona Department of Environmental Quality Biosolids Annual Report Form for Reporting Year 2018 APPENDIX F Biosolids Program History
2018 BIOSOLIDS MANAGEMENT COMPLIANCE REPORT
Introduction Organization and Function
2018 Accomplishments Treatment Plants and Program Updates Biosolids Management Summary of Pollutants Determination of Hazardousness
Biosolids Management System
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Introduction
The Orange County Sanitation District (OCSD) treats and manages its biosolids, the nutrient-rich, organic matter recovered through the treatment of wastewater. OCSD’s Biosolids Program consists of processes to ensure solids are treated onsite and used offsite (recycled or disposed) in accordance with all regulations and best management
practices.
OCSD treats and manages its biosolids in accordance with OCSD’s National Pollutant Discharge Elimination System (NPDES) Permit No. CA0110604 (NPDES), Arizona Administrative Code Title 18, Ch. 9, Article 10 (R18-9), and EPA Code of Federal
Regulations Title 40 Part 503 (503).
The following sections summarize OCSD’s activities and performance for the compliance-reporting period of January 1 to December 31, 2018.
Organization and Function OCSD is a public agency that provides wastewater collection, treatment, and recycling services for approximately 2.6 million people in central and northwest Orange County. OCSD is a special district that is governed by a Board of Directors consisting of 25
board members appointed from
20 cities, 4 special districts, and 1 representative from the Orange County Board of Supervisors. OCSD has two plants that treat wastewater from residential, commercial and industrial sources.
During this last calendar year OCSD:
• Treated an average daily sewage influent flow of 184 million gallons per day (MGD), down 6 MGD from last year.
• Produced 291,488 wet tons of biosolids (56,010 dry metric tons), which equates to an average of 799 wet tons per day of biosolids, including digester cleanings managed as biosolids (765 tons per day excluding digester cleanings). 2018 Accomplishments
OCSD accomplishments this year include:
• Recycled of 100% of OCSD’s biosolids, including digester cleanings.
• OCSD was awarded with the National Association of Clean Water Agencies (NACWA) Platinum Award. NACWA is the nation’s leader in legislative, regulatory and legal advocacy on the full spectrum of clean water issues, as well as a top
technical resource for water management, sustainability and ecosystem protection interests. See OCSD’s Awards and Honors webpage for many other annual recognitions throughout the agency.
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• Project P1-101 began commissioning dewatering centrifuges in November 2018, as featured on the cover of this report.
• OCSD cleaned eight (8) digesters at both plants.
• OCSD’s Research Program reviews and funds research projects. The Program includes an ongoing iTAG (international Technology Approval Group) process. The research
evaluations and results are summarized in their annual reports (ocsd.com/research).
• As part of the implementation of the 2017 Biosolids Master Plan and as included in the General Manager’s Work Plan goal for Fiscal Year 2017-18, OCSD issued a request for proposal for a Professional Design Services Agreement for the Interim Food Waste Receiving Facility Project.
Treatment Plants and Program Updates
Reclamation Plant No. 1, located in the city of Fountain Valley, treated an average of 120 MGD of wastewater. Treatment Plant No. 2, located in the City of Huntington Beach, treated an average of 64 MGD of wastewater during the reporting period.
OCSD provided an average of 119 MGD to the Ground Water Replenishment System
(GWRS) and Green Acres Project (GAP), which purify OCSD’s secondary treated water from Plant No. 1 to meet drinking water standards for reuse. The GWRS is a joint project of OCSD and the Orange County Water District (OCWD). GWRS is the world's largest system for indirect potable reuse. The system takes highly-treated wastewater
that would have previously been discharged into the Pacific Ocean and purifies it using
a three-step advanced treatment process. OCWD’s GAP is a water reuse effort that provides recycled water for landscape irrigation at parks, schools and golf courses; industrial uses, such as carpet dying; toilet flushing; and power generation cooling.
Plant No. 1 diverted an average of approximately 60,000 cubic feet per day of primary
sludge from Plant No. 1 to Plant No. 2 via the inter-plant sludge line. The diversion is anticipated to end after Plant No. 1’s centrifuges come online. OCSD’s plants both produce anaerobically digested biosolids to provide compliance
with the “Class B Pathogen Reduction” and “Vector Attraction Reduction” definition for
“Class B” biosolids as defined in 40 CFR Part 503.32(b)(3) (PSRP 3) and 503.33(b)(1), respectively. In addition, Tule Ranch/AgTech’s standard operating procedure includes incorporation within 6 hours which meets 40 CFR Part 503.33(b)(10) requirement if OCSD’s treatment plants fail to meet the Vector Attraction Reduction standard.
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OCSD’s biosolids are digested for at least 15 days at a minimum of 95 degrees
Fahrenheit, with a volatile solids destruction of at least 38%. The resulting biosolids averaged about 19% total solids at Plant No. 1 and 21% total solids at Plant No. 1. More detailed data, including monthly averages, annual totals and analytical results, can be viewed in Figure 1 and Table 2 below, as well as in Appendices A, B, C, and D.
Digesters 6 and 8 were cleaned at Plant No. 1, and Digesters C, L, N, P, R, and T were cleaned at Plant No. 2 in 2018.
OCSD is commissioning new facilities that will replace the belt filter presses with new dewatering centrifuge facilities at Plant No. 1 and at Plant No. 2. The total percent solids of dewatered biosolids is anticipated to increase significantly in 2019, resulting in approximately one-third fewer wet-weight solids and biosolids trucks to manage. The
Plant No. 1 project is also installing pre-digestion centrifuges to thicken primary and
secondary solids, so the existing dissolved air floatation thickening units will be decommissioned. Additionally, the project is rehabilitating the Plant No. 1 truck loading facility. Both plants’ projects are anticipated to be complete in 2019.
The Irvine Ranch Water District (IRWD) discharges its untreated solids (sludge) to
OCSD. IRWD is currently constructing their own solids treatment facility and plans to cease sending their solids to OCSD when IRWD completes start-up of new solids handling facilities, now estimated for years 2019-2020. This cessation is anticipated to reduce Plant No. 1’s influent solids by ten to fifteen percent.
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Biosolids Management Biosolids produced at OCSD’s two treatment facilities were managed by the contractors listed below in Table 1.
Table 1- Biosolids Management Contractors
Tule Ranch / Ag-Tech 4324 E. Ashlan Ave. Fresno, CA 93726 Contact: Shaen Magan
Phone: (559) 970-9432
Email: kurt@westexp.com
Synagro - Nursery Products PO Box 1439 Helendale, CA 92342 Contact: Venny Vasquez
Phone: (760) 265-5210
Email: vvasquez@SYNAGRO.com
Liberty Compost 12421 Holloway Rd. Lost Hills, CA 93249 Contact: Patrick McCarthy
Phone: (661) 797-2914
Email: patrickmccarthy@mccarthyfarms.com
Synagro – Arizona Soils 5615 S. 91st Avenue Tolleson, AZ 85353 Contact: Craig Geyer
Phone: (623) 936-6328
Email: CGeyer@SYNAGRO.com
Inland Empire Regional Composting Authority 12645 6th Street Rancho Cucamonga, CA 91739 Contact: Jeff Ziegenbein Phone: (909) 993-1981
Email: jziegenbein@ieua.org
These biosolids management contractors provide OCSD with diversification and reliability and are therefore important partners to OCSD. Contractors submit their annual compliance reports directly to EPA, in accordance with OCSD’s NPDES permit
requirements. For this reporting period, OCSD’s biosolids were beneficially reused in
the areas following in Table 2. More detailed breakdowns are available in Appendices A and D.
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Summary of Pollutants
Since 1976, OCSD’s Pretreatment Program has been effective in lowering the average mass of metals discharged to the marine environment by 98% and the total mass of metals in the influent sewage by 86%, thereby ensuring OCSD’s biosolids can be recycled to farm fields with low metals concentrations. Furthermore, OCSD’s influent
wastewater meets drinking water standards for metals. Appendix B contains the
biosolids chapter of OCSD’s Pretreatment Program Annual Report (ocsd.com/SCAnnual, Chapter 9). OCSD’s monthly Biosolids Monthly Compliance Reports (Appendix A) compare the
concentration limits of the pollutants listed in 40 CFR 503 to OCSD’s average biosolids
concentrations for each plant. The average concentrations of all pollutants in OCSD’s biosolids are typically an order of magnitude below the conservative Table-1 Ceiling
Limits and Table 3 Exceptional Quality Limits found in 40 CFR Part 503, which were based on an extensive health risk assessment to ensure that biosolids are safe for
recycle to build healthy soil.
In accordance with OCSD’s NPDES permit, biosolids are also tested semi-annually for all pollutants listed under Section 307(a) of the Clean Water Act. Appendix C contains the summary of the priority pollutants analyzed in the plants’ biosolids.
Determination of Hazardousness Generally speaking, OCSD’s biosolids are several orders of magnitude below state and federal hazardous waste limits. However, OCSD performs semi-annual testing of an extensive list of organic and inorganic compounds to verify the continued non-
hazardousness of our biosolids. Legal Definitions OCSD’s 2012 Ocean Discharge NPDES permit requires OCSD to test its biosolids annually for hazardousness in accordance with 40 CFR Part 261. Hazardous waste is
also defined under the provisions of California Code of Regulations, Title 22, Chapter 11, Article 5, and Arizona Revised Statutes, Title 49, Chapter 5, Article 2. Determination
OCSD’s biosolids are determined to be non-hazardous based on the following:
• OCSD’s biosolids are not ignitable, corrosive, reactive, nor toxic in accordance with the federal regulatory definitions in 40 CFR Part 261.
• OCSD’s biosolids are tested at twice annually for the determination of
hazardousness. OCSD’s biosolids’ pollutant concentrations are significantly below the state and federal maximum contaminant concentrations for determining a hazardous waste. See OCSD’s biosolids monitoring data in Appendix C, Summary of Priority Pollutants and Trace Constituents Analysis.
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Biosolids Management System OCSD continues to utilize a biosolids management system approach to effectively administer its biosolids program. The following sections highlight OCSD’s continued commitment to the biosolids management system.
Communications OCSD has continued transparent communications during this reporting period.
• Monthly compliance reports and data are posted online (ocsd.com/nani).
• Two interested party newsletters were emailed and posted on OCSD’s website (https://www.ocsd.com/education/biosolids-program/e-newsletter-updates).
• OCSD shared timely updates including the annual compliance report, new biosolids videos, updated OCSD resources such as the biosolids allocation map
and Biosolids Contractor Requirements document, as well as when a biosolids compliance audit request for proposals was announced. Contractor Oversight Program OCSD has continued our strong contractor oversight program:
• No NOVs (Notice of Violations) for OCSD’s active biosolids contractors;
• Performed 12 contractor site inspections;
• Addressed and closed out 4 contractor issues;
• Addressed and closed out one inspection finding (one was reopened and is currently being addressed);
• Addressed and closed out 3 odor complaints (of which 2 were unfounded);
• Performed 55 hauling inspections, which reached 42 out of 52 active drivers (81%) this year. There are 11 active drivers (21%) who have earned a place on OCSD’s “Honor Roll” for excellence in their truck cleanliness, knowledge of
biosolids and emergency protocol by successfully passing 3 consecutive hauler inspections; and
• One contractor offsite incident occurred in January 2018, in which an estimated of 5 tons of biosolids were released and recovered. The final report was
submitted to Regional Water Control Board having jurisdiction in the area. Goals and Targets The 2014 – 2019 Five Year Strategic Plan is a guiding document that provides a framework that directs our work. Every two years, the Strategic Plan will be reassessed,
updated, and submitted for approval by the Board of Directors. The 2017 Strategic Plan
Update began with a consultant retained by OCSD conducting confidential interviews with interested Board members to identify issues or concerns. The Strategic Plan Update continued with a workshop and presentation of two issue papers. The Update
concluded with two Strategic Goals being identified as completed, no new goals being
adopted, and no modifications being made to OCSD’s levels of service. See www.ocsd.com/5yearstrategicplan or the OCSD Strategic Planning website (https://www.ocsd.com/services/strategic-planning).
Biosolids Program Policy
The Biosolids Program Policy, originally adopted in 1999 and amended several times over the years, is a policy committing the agency to support biosolids beneficial reuse (organics recycling). The most recent commitments, OCSD Resolution 13-03
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(www.ocsd.com/policy), and OCSD’s performance relative to these commitments are
reported below.
Table 3 – Policy Performance
Policy Commitment 2018 Performance
1. Commit to sustainable biosolids program.
Support the recycling of biosolids.
OCSD has demonstrated effective pretreatment, water and solids treatment operations, compliance, capital improvements, technology research and planning, and biosolids contractor oversight programs.
See this year’s accomplishments at the beginning of this report.
2. Strive to balance financial, environmental, and societal
considerations when making biosolids decisions.
On a day-to-day basis, OCSD is weighing these considerations and looking out for issues that would alter the balance. For instance, allocating our biosolids to our diverse locations considers this “triple bottom line,” but also considers contractors performance and the 2017 Master Plan’s Ten Tenets. 3. Utilize a biosolids management
system to maintain a sustainable and
publicly supported biosolids program.
OCSD continues to maintain our biosolids management system as outlined in this section. OCSD is currently listed as a Graduate of the National Biosolids Partnership’s certification program (www.biosolids.org).
4. Diversify portfolio of offsite biosolids management options with multiple biosolids contractors, markets, facilities, and maintaining fail-safe
back-up capacity of at least 100% of its daily biosolids production.
See Table 2 for breakdown of our active biosolids management options.
See Ten Tenets reporting table below.
OCSD maintained more than 10 times (1000%)
our daily biosolids production in failsafe facility capacity. OCSD also maintained about 33% extra
hauling capacity.
5. Research and implement ways to reduce the volume of biosolids at the
treatment plants to minimize the
need for offsite management.
As mentioned in the “Treatment Plants and Program Updates” section above, OCSD’s production of biosolids is anticipated to drop by about one-third once the centrifuges are fully commissioned in 2019. OCSD’s Research program actively seeks opportunities for process area improvements, including solids. OCSD is continuing to monitor the Supercritical Water Oxidation technology (www.scfi.eu) and the progress towards a feasible pilot plant. 6. Support continuing research of biosolids benefits and potential safety concerns.
OCSD continued our support of the Northwest Biosolids’ library (www.nwbiosolids.org). The library contains references to over 2,600 biosolids-related research articles references.
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Table 3 – Policy Performance Policy Commitment 2018 Performance
Northwest Biosolids sends a monthly theme-
based, relevant summary of research to its members, so we can easily digest pertinent
scientific information and better communicate with interested parties. Northwest Biosolids also has a
free monthly e-Bulletin for non-members. In 2015, based on extensive research, the Northwest
Biosolids association published a public-friendly risk brochure explaining how long it takes for
workers and other “exposed populations” to accumulate a dose-equivalent of pharmaceuticals
or personal care products from exposure to biosolids (most in the thousands to hundred-
thousands of years). This publication remains one of the best references to address emerging
constituents of concern.
OCSD updated our outreach video in 2018, and included expanded information on the safety of
biosolids. Biosolids 2-part video. Part 1: How biosolids are created from sewage treatment plant
solids, OCSD’s biosolids production, and where OCSD’s biosolids are recycled. Part 2: Biosolids
benefits and safety and the onsite processes used to land apply and compost biosolids.
7. Demonstrate the benefits of biosolids
compost by using it at the District’s facilities.
OCSD maintains compost piles at each plant. This compost is available to our employees and our landscape contractor to demonstrate the benefits of compost. OCSD encourages employees to share their compost use photos. OCSD continues to long-term monitoring of our composted biosolids demonstration planter that contains drought-tolerant and native species.
Ten Tenets of OCSD’s Biosolids Management Plan Read more on OCSD’s Ten Tenets and the Biosolids Master Plan at ocsd.com/bmp.
Table 4 – Ten Tenets of Biosolids Management Performance
Policy Commitment 2018 Performance
1. Allocate up to 50 percent
of biosolids per biosolids
contractor.
Each contractor received less than 50% of OCSD’s biosolids.
See Table 2 for relative tonnage distribution this year. See
OCSD’s current map of where OCSD’s biosolids are allocated at
ocsd.com/map.
2. Allocate up to 50 percent
of biosolids to each
geographic end use
market.
Sixty percent (60%) of OCSD’s biosolids were are turned into compost at four (4) regional facilities. Combined, these facilities’ distributed over 246,740 tons of composted biosolids in the following geographic markets:
• 39.5% (net 24% including land application biosolids below) to Riverside County,
• 35% (net 21%) to Kern County,
• 8.9% (net 5.3%) to Los Angeles County,
• 7.5% (net 4.5%) to San Bernardino County,
• 5.3% (net 3.2%) to Arizona, Maricopa County,
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Table 4 – Ten Tenets of Biosolids Management Performance Policy Commitment 2018 Performance
• 2.2% (net 1.3%) to San Diego,
• 1.5% (net 0.9%) to Orange County, and
• 0.2% (net 0.1%) Madera County. The remaining 40% of OCSD’s biosolids were used to raise
crops, producing 2,316 tons of seed and ethanol crops for use in Arizona.
3. Maintain at least three (3)
different biosolids
management facilities at
any time.
OCSD maintained five (5) different management facilities. See
Table 2 for relative tonnage distribution this year. See OCSD’s
current map of where OCSD’s biosolids are allocated at
ocsd.com/map.
4. Maintain at least two (2)
different biosolids
management practices at
any time.
OCSD maintained two (2) different management practices,
composting and land application (direct farming of feed crops
with biosolids). See Table 2 for relative tonnage distribution this
year. See OCSD’s current map of where OCSD’s biosolids are
allocated at ocsd.com/map.
5. Maintain at least two (2)
different hauling
companies within the
biosolids management
portfolio.
OCSD and its biosolids management contractors utilized three
(3) different hauling companies (GIC, Tule Ranch/Western
Express, and Denali).
6. Maintain at least 200
percent contingency
capacity at end use sites.
OCSD maintained an average of about 1100% contingency
capacity.
7. Maintain 20 percent fail-
safe hauling capacity.
OCSD maintained an average of 33% fail-safe hauling capacity.
8. Track and encourage
development of emerging
markets and/or end uses
for biosolids, especially
for local end use options.
OCSD entered discussions with Anaergia, who is planning to
redevelop a Rialto facility to receive food waste and biosolids to
produce electricity and biochar. The facility is expected to come
online in 2020. OCSD also had discussions with potential
partners in Imperial County and are tracking Irvine Ranch Water
District’s dryer and Los Angeles County Sanitation District’s
composting facility in Kings County.
In 2018, OCSD’s composting partner, Inland Empire Regional
Composting Authority (IERCA), expanded their buy-back
program to OCSD member cities and agencies. This program
offers discounted compost to incentivize the local use of
compost. IERCA provided bagged compost for OCSD’s “State of
the District” event, and the two agencies’ staff informed
attendees of the need to buy-back locally-sourced organics.
9. Allocate up to 10 percent
of total biosolids
production for
participation in emerging
markets, including
In 2018, OCSD added Anaergia as a location to our hauling
contract (see previous item also). No tonnage was allocated to
emerging markets or pilots this year, however, OCSD is aware
and monitoring several potential opportunities for future
allocation of OCSD’s biosolids.
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Table 4 – Ten Tenets of Biosolids Management Performance Policy Commitment 2018 Performance
participation in pilot or
demonstration projects.
10. Explore partnerships with
area soil blenders to
allow incorporation of
OCSD’s Class A product
into local markets.
OCSD is following the work being done by San Francisco Public
Utilities Commission to research and develop their temperature-
phase anaerobically digested biosolids soil blend product
research, recipe, and roll-out the product to local markets.
OCSD’s efforts will follow suit at the appropriate time since
OCSD facilities are expected to be commissioned in about 2030.
OCSD Plant No. 2 Biosolids Demonstration Planter
ORANGE COUNTY SANITATION DISTRICT
Laboratory, Monitoring & Compliance Division
10844 Ellis Avenue
Fountain Valley, California 92708-7018
714.962.2411
www.oscd.com