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HomeMy WebLinkAboutIR 9684 INFORMAL REPORT TO CITY COUNCIL MEMBERS No. 9684 To the Mayor and Members of the City Council November 18, 2014 r� Page 1 of 4 �i �i7 Y •a SUBJECT: REVIEW OF POLICIES AND PROCEDURES BEING USED FOR rrn BIOSOLIDS LAND APPLICATION The purpose of this informal report is to brief the City Council on the policies and procedures in place to address recent issues related to the land application of biosolids by the City's Contractor, Renda Environmental, Inc. under the City's contract for the long-term solids dewatering, processing and disposal. The report also addresses the contractual requirements related to the transportation of the biosolids and alleged odor nuisances, and the remedies the City has available if Renda is found to be in non-compliance with the contractual terms and conditions. The City of Fort Worth itself holds the permit for the long-term solids dewatering, processing and disposal issued by Texas Commission on Environmental Quality (TCEQ) (Permit No. WQ0010494013). The City entered into a contract with Renda Environmental, Inc., (City Secretary Contract No. 20283) on May 27, 1994 to allow Renda to operate the City's biosolids facility and to provide dewatering and beneficial reuse of anaerobically digested biosolids produced at the Village Creek Water Reclamation Facility (VCWRF) for an initial period of six years. Since 2000, the City has amended and renewed its contract with Renda and is currently in its third and final five year renewal option which was approved by the City Council on April 6, 2010 by M&C C-24163. Then on November 12, 2012, City Council approved an additional 5 year extension to the contract until March 31 , 2020 by M&C C-25981. This extension was requested to insure the successful 12.5 year payback of the Johnson Controls Inc., Energy Saving and Performance Contract which place the major emphasis on success on the Gas Turbine/Steam Generation Heat Recovery system operated by Renda Environmental as part of the biosolids contract. Renda is required to comply with the City's permit terms and conditions as well as any federal, state and even local regulations. The permit requirements include following sewage sludge management practices. To help ensure that these practices are followed, the contract further requires that Renda have a technical approach and operating plan in place to include insect control, dust control, odor control, a public relations plan and sludge transport and disposal methods. The City may at any time request a copy of the plans to ensure compliance with the contract. Despite these mandates and others discussed below, the contract specifically states that the biosolids become the property of Renda at the time the sewage sludge enters Renda's storage tank for processing, and Renda then assumes full responsibility for the sludge. Because the City maintains the permit for the biosolids processing it is not completely immune from TCEQ regulations and enforcement. However, in the second renewal option and amendment to the contract, Renda agreed to indemnify the City for and from "all liabilities, claims, damages, losses, liens, fines, penalties, costs, causes of action, suits, judgments and expenses...for the services performed" under the contract. ISSUED BY THE CITY MANAGER FORT WORTH, TEXAS INFORMAL REPORT TO CITY COUNCIL MEMBERS No. 9684 To the Mayor and Members of the City Council November 18, 2014 r� Page 2 of 4 �i �i7 Y •a SUBJECT: REVIEW OF POLICIES AND PROCEDURES BEING USED FOR rrn BIOSOLIDS LAND APPLICATION In the process of moving the sewage sludge from the VCWRF, anaerobically digested biosolids are pumped to the biosolids facility, which is located approximately a mile north of the VCWRF. At the biosolids facility, the biosolids are dewatered using belt filter presses with polymer addition. After dewatering, lime is added to increase the pH of the biosolids for the control of pathogenic organisms. Biosolids are then stored onsite for a minimum of 24 hours before being transported to several land application sites in the surrounding area. The City has received complaints for odor and spilling of biosolids which have recently been brought to the attention of the City Council. TCEQ is dealing with the odor complaints directly with Renda and has issued notice of enforcement. The City is currently addressing the spilling of biosolids complaints. The contract with Renda requires that all transportation be done in a manner and with the appropriate equipment to "preclude the possibility" of spilling of any sort. The contract further states: that all spills are the responsibility of Renda, and that any spill must be cleaned up immediately. If Renda does not clean up the spill, the City has the inherent power to do so and require Renda indemnify the City for such cost. The City is currently in discussion with Renda on its spillage plan and specifically how Renda will come into compliance with the contract. If the City continues to find that Renda is not meeting its contractual requirements then the City may terminate for cause due to a material breach. The City must allow 14-days notice and time to cure the breach. If Renda cures the breach within a reasonable time, then the contract may not be terminated. The contract defines a material breach to include the failure to comply with any federal, state or local law, regulation, rule or order and that failure has a material adverse effect. The City may terminate or suspend the contract for Renda's failure to provide and maintain sufficient labor and equipment to properly execute working operation. (If the City chooses to exercise the right to terminate for this reason it must serve notice on the surety and allow the surety to assume the contract.) And the City does have the right to terminate for convenience upon notice to Renda, who then has 60 days to issue a termination claim against the City. In response to an increase in the number of reported complaints over the last year, the City has also retained the services of a multi-faceted international engineering consulting firm (ARCADIS), which specializes in infrastructure, water, environment and buildings to conduct a biosolids odor investigation to determine the likely cause(s) of the increase in odor. The City has noticed a decline in biosolids cake concentration leaving the biosolids facility and has also had ARCADIS investigate the possible causes of this decline and whether it is related to the increase in odor complaints. Since the Oct. 14 staff presentation to the Infrastructure and Transportation Committee (ITC), ARCADIS has completed its investigation, which included the following: ISSUED BY THE CITY MANAGER FORT WORTH, TEXAS INFORMAL REPORT TO CITY COUNCIL MEMBERS No. 9684 To the Mayor and Members of the City Council November 18, 2014 r� Page 3 of 4 �i �i7 Y •a SUBJECT: REVIEW OF POLICIES AND PROCEDURES BEING USED FOR rrn BIOSOLIDS LAND APPLICATION 1. A review of recent studies or work performed at VCWRF and the dewatering facility. 2. A review of historical data from all City water treatment plants (WTPs), VCWRF, and the biosolids facility. 3. A site investigation of the biosolids facility. 4. Odor sampling at the dewatering facility and biosolids land application sites. Based on its review and a review of past biosolids and odor work by other consultants, ARCADIS believes that the decrease in dewatered cake percentage since 2010 and the increase in reported odor complaints at the biosolids land application are related, and are primarily a result of a decrease in the amount of metal salts no longer being discharged to the VCWRF. To mitigate the increase in odors experienced as a result of the decline in metal sludge in the VCWRF influent, ARCADIS has recommended to the City the following: 1. Continue to perform site inspections. 2. Consider the addition of ferric chloride, which has been shown to reduce odors and reduce polymer demand. Further study on the optimal location(s) for ferric chloride dosing should be investigated as it can provide several benefits to the VCWRF including improved primary clarifier performance. 3. Investigate improvements that could be made to reduce the shear on the polymer (such as polymer feed location) during the belt press process. The current polymer used at the VCWRF is polyacrylamide based polymer which generates odorous compounds upon lime addition. Investigate the effectiveness as well as the cost and operational implications of an alternate type polymer which does not. 4. Review current lime mixing practice to identify methods to improve mixing (longer mixing time, better incorporated in to biosolids) which has been shown to improve biosolids stability and reduce odor generation. 5. Investigate the cause of variability in the variant solid content of the plant influent. If this is better understood VCWRF may be better able to make changes in operations to counteract the impact of the variation where solids handling performance is appears to generally be lower. ISSUED BY THE CITY MANAGER FORT WORTH, TEXAS INFORMAL REPORT TO CITY COUNCIL MEMBERS No. 9684 To the Mayor and Members of the City Council November 18, 2014 r� Page 4 of 4 �i �i7 Y •a SUBJECT: REVIEW OF POLICIES AND PROCEDURES BEING USED FOR rrn BIOSOLIDS LAND APPLICATION 6. Perform a review of primary clarification, thickening, digestion, and dewatering processes with the goal of optimizing these processes as much as feasible to maximize settling in the thickening process, digester destruction, biosolids dewaterability and minimize polymer demand. This would likely minimize biosolids transport costs and associated odors. The Water Department is taking steps to make some of these changes over the next 15-30 days. We will have short-term cost information included in the biosolids update scheduled for the December 9 ITC presentation. In addition to these recommendations, the Water Department is working closely with Renda to make the necessary changes to its operations for compliance with the recent changes made to the TCEQ regulatory requirements for biosolids and land application. The Water Department is in the process of getting a vacant position filled that will assist with compliance monitoring associated with this contract. If you have any questions concerning this information, please contact Andy Cronberg, Interim Water Director at 817-392-5020 or andy.cornberg@fortworthtexas.gov. David Cooke City Manager ISSUED BY THE CITY MANAGER FORT WORTH, TEXAS