Following a recent story concerning Discovery Bay’s Community Services District violations of safety and water quality regulations and procedures arising from a sewage spill in the Lakeshore area of Discovery Bay, Below find details of Facility Inspection findings from October 9, 2008 for the Discovery Bay Facility. The report was sent to both the CSD and Southwest Water, the current facility operator. Residents ask how did it got so bad under current CSD leadership controlled by David Piepho, who, after denying over and over there was no problem, was first in line to take credit for a proposed special investigation.
“After our recent inspection/complaint investigation I informed you verbally of our preliminary findings on October 9, 2008. Per your request, I am providing you with a list of those findings in writing. Again, I would like to emphasize that these are preliminary findings and that we will form our final conclusions and recommendations after reviewing all the documents that we are seeking. A written request for those documents has been submitted via e-mail earlier today.
The first three finding relate to general safety over which the Water Board does not have regulatory authority. Nevertheless, I am obligated to point them out.
We identified a couple potential safety hazards in the headworks area at Plant No. 1.
The MCC cabinets near the emergency generator (Plant 1) should be kept closed, and preferably locked.
We noticed liquid in the covered containment area for the old chlorine tank at Plant 1. It was unclear if the liquid was water or a chlorine solution, however, it should be cleaned up and properly disposed.
UV tubes next to the chlorine building should be properly disposed of.
Housekeeping at Plant 1 was extremely poor.
It appears that this facility is used as a disposal site for debris and abandoned equipment.
After several months of work, the new SCADA system still does not appear to be fully functional.
The reliability of the existing SCADA system is also questionable.
When the main power was intentionally disconnected during our October 9 visit, neither system registered a power failure alarm (at least the operator on duty could not identify it). However, the SCADA system did indicate that the emergency generator was running.
The assistant Facility Manager noted that he still frequently finds the SCADA phone lines disconnected. This needs to be mitigated immediately.
One of the four rotors (brush aerators) has been out of service for several months. Another appears to be only marginally operational. The June 2008 Self- Monitoring-Report attributed the high ammonia concentration in the effluent to problems with two rotors (resulting in low dissolved oxygen).
There was no record of corrective maintenance work orders for those two aerators in the computerized maintenance management system.
The UV system does not appear to be adequately maintained.
The Fischer Porter system was missing at least seven ballasts in Bank B alone. Additionally, LED indicator lights on the remaining ballasts showed that at least 11 UV tubes in Bank B were not working at the time of our visit. These deficiencies are likely to cause non-compliance with the permit’s coliform requirements.
The local alarm for Banks A and B (Fischer Porter system) indicated “low intensity warning” and “low- low intensity alarm.” “Low-low intensity” is a serious alarm that apparently had not been addressed for an extended period of time.
You indicated that the UV system alarms were probably not connected to the SCADA system (this still needs to be confirmed). Regardless, there should be an SOP on identifying and correcting these alarms.
The intensity reading for Bank B showed 20% for each rack. The intensity reading for Bank A showed intensity reading of 40 and 60% for racks 1 and 2. These readings are well below what is required for reliable disinfection.
Intensity meter for Bank C was not operational at the time of our visit.
The Trojan UV system could not be evaluated because the monitor was almost impossible to read. One alarm appeared on the screen, however we were unable to determine the cause of the alarm condition. I believe that the very poor resolution/visibility on the screen was caused by problems other than lighting/glare conditions (although these were definitely contributing factors).
DO and pH meters are not calibrated prior to all compliance analyses.
Plant staffing is inadequate as indicated by a 12-page backlog of work orders.
There is also an indication that this backlog does not include all the outstanding work orders.
In general, there is a lack of written Standard Operating Procedures (SOPs) describing routine tasks and emergency response procedures. Although some of the SOPs may be found in the O& M manual, some operators do not appear to be familiar with them.
It is acknowledged that the Facility Manager is currently working on developing new SOPs and updating the existing ones.
The training of operators is inadequate.
There are strong indications that a significant amount of training (of new operators) is being done by an Operator-In-Training.
Operators should be professionally trained in process control, calibrations, sampling, SCADA, emergency response and particularly in the operation and maintenance of the UV systems.
The operators (including the Facility Manager) were not adequately familiar with the reporting requirements following non-compliance events (such as overflows).
Reporting of the July 7-18 overflow (spill) did not comply with either the State or Regional Water Boards’ regulatory requirements.
Operators must understand and acknowledge that the permit prohibits discharge of effluent to the Reclamation District 800 drainage ditch.
Please let me know if you disagree with any of these findings or if any of the identified problems have already been corrected.
Boris Trgovcich
Office of Enforcement
State Water Resources Control Board
(916) 714-2983
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