BPM Has Concerns On City Discharge Permit

Issue Date: November 14, 2019

The main discussion at the City of Peshtigo Water and Sewer Committee Meeting on Tuesday, Nov. 12 was a proposal from Ruekert - Mielke for River Crossing sewer lines.

There were Sanitary Sewer Overflows (SSOs) which occurred through the top of a manhole at a siphon river crossing in the City in 2019. The City immediately contacted the DNR and issued public notices about the overflows in a timely manner. The DNR appreciates the immediate corrective action and that the City has been working on the issue all summer and completed the items in the Notice of Noncompliance (NON).

The dates of the overflows were May 9 (7,200 gallons), July 15 (2,000 gallons), Sept. 13 (300 gallons), Sept. 22 (176,000 gallons) and Oct. 1 (10,680 gallons).

For the May, July and Sept. 13 and October overflows the wastewater infiltrated into the the soil on private property. The Sept. 22 overflow filled the depression around the manhole and overflowed into the Peshtigo River. This same area had overflows in April 2019 and in 2016. The structure was raised three feet after the 2016 overflows, which were caused by a partially plugged pipe in the May, July and Sept. 13 cases and because of high precipitation in the July, Sept. 22 and October overflows.

As a result of these happenings, the City has been working with Taryn Nall, Project Manager of Ruekert Mielke Municipal Infrastructure Management Firm for proposal of a sanitary sewer river crossing pre-design and design services. It was determined the existing river crossing is approximately 80 to 100 years old.

Nall discussed with the committee the details of the proposal, indicated they need to determine a plan and answered questions of the committee."In order to get across the river they have to get an estimate of the peak flows and establish what is needed to get across. We need to determine a differential to prevent surcharging of basements on the West side of the River. We have a lot of planning based on the information of what to use and the development".

Director of Public Works George Cowell brought up about screening systems that are not included in the proposal at present and will need to be an addendum to the proposal for non-disposals and disposals.

Nall said, "We are looking at screening systems and will talk to Cowell to see if they want to work in the screening systems into the proposal. I am really concerned about the head losses with putting in a screen system, but it is very important. The screening at a river crossing is kind of new but not a new process. It is normally done at a lift station or waste water treatment plant. I can provide the information on the screening and more information of the design of the river crossing".

"The hydraulic analysis is most critical. We have to take care of the peaks and dry time and have to be concerned about the flow and velocity in the pipes. Design is critical to maintain good flow throughout the year", Nall said.

Nall stressed they want comments throughout the whole process to make sure we are doing what the City wants. Committee member, Fred Meintz said, "It has to be done, we can't stall on this. We can study to death but we need construction". Committee member, Tom Gryzwa then asked if any grants were available.

Nall responded, "I submitted an ITA (Intent to Apply) and PERFS (Priority Evaluation and Ranking Formula) and we are up to 70 points and I can go back five years for potential forgiveness based on population and other factors to help get a low interest rate, but I can't promise any grant money. You have a situation where money will be available but in the form of an ITA. Funds will be available in late 2020 from the State Trust Fund Loan".

Gryzwa then questioned, "Are looking at construction in 2020"? and Nall responded, "It can be, early bidding is critical". Meintz then asked, "Do the engineering fees qualify for funding"? Nall replied, "All bidding, engineering and construction management can be included and quality for 20 year funding. This is a clean water funding project, you will get good rates in a trust fund loan".

Committee Member, Dan Seymour made a motion to accept the proposal for a professional pre-design study dated Oct. 30, 2019 not to exceed $18,700 and forward to Council for approval or discussion. The proposal does not include soil exploration work by a geotechnical consultant or assistance in obtaining easements or land acquisition. After discussion, the motion will be added to the agenda of a special council meeting being held Thursday, Nov. 14 at 1 p.m.

In a response to an updated Class C Wastewater Discharge Permit the City sent to BPM, Jim Koronkiewicz, BPM General Manager, responded with a letter dated Nov. 4 of several concerns with the modifications to the permits that BPM would like to address. BPM requested inclusion on the Water and Sewer Committee meeting agenda for Nov. 12 to discuss these items. Responses dated Nov. 12 were given at the meeting by Cowell.

1) What is the reason for providing a one year permit versus a three year permit as has been historical?

City Response: The City of Peshtigo has set the permit at a one year duration As you are aware from the testing dates previously provided by BPM, both PFOS and PFOA compounds were present in the grab sample taken at the discharge of the force main from the BPM facility on July 23, 2019. One year was chosen for permit duration to allow the City of Peshtigo to quickly address changing requirements and research on PFAS compounds. A one year duration for the permit provides the City of Peshtigo the opportunity to address changing standards or limits related to PFAS and set permit requirements in an expedient manner. In addition if increased costs are experience for handling bio-solids related to PFAS peels, the City of Peshtigo will be evaluating sampling test data for proration of cost based on the sources contributing PFAS compounds.

2) BPM Inc has always complied with testing for days of operation with samples retained for "off operation" days. This is normally five days per week, excluding weekends and all Holiday shutdowns. why is the testing being requested at 365 days per year? Does the City do testing 365 days per year?

City Response: The City is requesting the seven day per week testing to verify quantities of material being discharged to the sanitary sewer collection system. The tests verify the quantities of waste that is being discharged. The quantities are utilized to calculate billing invoices to BPM. The City of Peshtigo is requiring the seven day per week sampling to provide the most accountable and accurate procedures. As you are aware, the proposed rate revision would decrease the amount of fixed charge for BPM and shift costs to the quantities utilized, therefore the City is requesting additional sampling for accountability. In reference to the City of Peshtigo, the laboratory is staffed seven days per week. The laboratory tests are performed to verify that discharges are within our permit feel for effective treatment. Tests are diversified at the plant involving set up and reading on different days. Presently the City of Peshtigo sets up the sampler for BODs on Sunday through Thursday, samples are prepared for BODs on Monday through Friday and results for BODs are read on Saturday through Wednesday. Other required laboratory tests include staff working on TSS Monday through Saturday, Chlorination tests seven days per week and PH tests five days per week.

3) We understand the heightened level of concern over the PFAS contamination in local waters. Our question is why do most tests being done identify 24 items in the chemical screen and this permit identifies 36? Please explain how this was determined and the significance of it. Are there other business/entities being required to do additional testing of their wastewater?

City Response: The requirement for a 36 compound screening parallel the tests being performed on influent and effluent in the state of Wisconsin at this time. A copy of two correspondence received in regard to the expanded compounds is available to review. Early testing by the WDNR and the City of Peshtigo utilized a 24 PFAs compounds screenting, however recent testing performed by the State Laboratory of Hygiene at the Peshtigo WWTP utilized a 36 compound screening. They City of Peshtigo has proposed establishing limits on one other entity, which has since ceased discharge all together. At present three additional locations are being evaluated and additional investigative testing is being performed by the City at two of the facilities.

4) It is BPM's intent to share information regarding test results so practical limits may be set by the City. At this time PBPM requests a copy of the results of the City's recent testing from various locations throughout Peshtigo including the Mill's effluent line.

City Response: A request for copies of records for testing data can be directed to the City Clerks/ Treasurers Office.

After the responses were read, Koronkiewicz replied, "I am surprised with the answers given today with no time to respond. We will comply with the seven day per week and will be responding back with a written document of what our intent is". "Discharge paperwork was never signed and when we receive other data from the Clerks office, we will review that"? Cowell responded with, "It's a permit".

Koronkiewicz then replied, "There will be a written response". He also questioned what other areas will be tested? Cowell responded, "We will be testing other facilities on Aubin Street and Oak Street". Right now in the Public eye it looks like BPM is the major contributor to the PFAS contamination!" Koronkiewicz replied. Cowell said, "That is not my intent, it is because of the volume and the way it comes in we were able to sample it easily".

Gryzwa said, "This will be something on going". Mayor Cathi Malke asked Gryzwa, "Would you entertain having an evening meeting to allow citizens the opportunity to ask questions? That would allow more people to attend as the majority of people work during the day. I have received several phone calls from citizens and businesses alike wanting answers." Gryzwa responded, "In the history of the committee, it has never been done, the council members don't hold their meetings at night, we can discuss it but at this time we are keeping ours the same". Malke replied, "It now supersedes a lot of issues we are having and it would be advantageous to the citizens to be able to comment and ask questions"

Cowell advised the 2019 Sanitary Survey Report for the Water Supply serving the City of Peshtigo and notice of non-compliance completed by the DNR went real good and they were very pleased with the inspection.

He also reported testing was completed per a letter of request from Martin Shafer, Senior Scientist at UW-Madison and Wisconsin State Laboratory of Hygiene (WSLH) the State Laboratory of Hygiene. He requested the City to collect a sub sample of 24 hour effluent and influent composites and collect grab samples of both effluent and influent sludge samples. The study is being done by the University at no charge to the city to better understand the presence, transport and fate of PFAS in the environment and the principal investigator on the study of PFAS cycling within the municipal wastewater treatment facilities all at no cost to the City.

Cowell stated they will be sampling this week a third site on Maple Street by one of the businesses to get down stream and check for PFAS to determine if it is a controlled or input situation. Our system is not designed to treat the PFAS.

The next meeting of the Water and Sewer Committee will be held on Tuesday, Dec. 10.

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