Field Office Compliance - Assistance

Assistance ID - 6460
Des Moines Water Works - 310338211
9966 Maffitt Lake Dr Cumming, IA 50061
Dallas County

FO 5

Report
File Name File Type File Date Note
Comments
8/10/2009 From: Gastineau, Janet [DNR] Sent: Friday, August 07, 2009 8:56 AM To: Warren, James [DNR]; DNR FO5WS Cc: Lynam, Anne [DNR]; Thomas, Terisa [DNR] Subject: RE: DMWW SEP reporting and Sample points Filter applied is prior to filtration. I'm also OK with the CFE location even when running the ASR. -------------------------------------------------------------------------------- From: Warren, James [DNR] Sent: Thursday, August 06, 2009 3:08 PM To: DNR FO5WS Cc: Lynam, Anne [DNR]; Thomas, Terisa [DNR] Subject: RE: DMWW SEP reporting and Sample points Can someone from the Field Office please help with the questions below? I’ll be out of the office on Friday and Monday, so please respond to Gordon directly or maybe have Anne respond once a decision is made. Thanks. Jim Warren From: Warren, James [DNR] Sent: Monday, August 03, 2009 1:46 PM To: DNR FO5WS Cc: Lynam, Anne [DNR]; Thomas, Terisa [DNR] Subject: FW: DMWW SEP reporting and Sample points Please advise per the e-mails below. I have discussed this with Anne and our thinking is that TOC monitoring can be done at the CFE location when running the ASR. However, I was not sure what he was talking about when he referred to “filter applied water”. I assumed he was talking about individual filter sampling points. Please look this over and let me know if what you think. I’ll wait to hear from you before we send a response. Thanks. Jim Warren From: Brand, Gordon [mailto:[email protected]] Sent: Monday, August 03, 2009 11:26 AM To: Warren, James [DNR] Subject: FW: DMWW SEP reporting and Sample points I am forwarding this message to you as Terisa is out of office. Gordon Brand Senior Chemist Des Moines Water Works 515-283-8761 From: Brand, Gordon Sent: Monday, August 03, 2009 10:47 To: 'Thomas, Terisa [DNR]' Subject: RE: DMWW SEP reporting and Sample points Terisa, Another issue surfaced this morning regarding plant performance reporting at the McMullen Plant (TP02) during ASR operations. Typically, a sample of the combined filter effluent is used as the post treatment location. However, at McMullen, the ASR discharges into the CFE tunnel so that the CFE is a blend of both currently processed water a previously treated water (stored in the ASR aquifer). It is not possible to collect of CFE prior to ASR addition. We can get samples from individual filters but…. I would like to either collect filter applied water for TOC analysis (the permit says “and at a point no later than the point of combined filter effluent turbidity monitoring”) or go ahead and collect at the CFE since the ASR contribution is somewhat small (approximately 10-12% of total flow). The CFE would be indicating what is entering the clear well but not necessarily current removal efficiency. Gordon Brand Senior Chemist Des Moines Water Works 515-283-8761 From: Thomas, Terisa [DNR] [mailto:[email protected]] Sent: Thursday, July 23, 2009 10:21 To: Brand, Gordon Cc: McCurnin, Mike; Jones, Christopher Subject: RE: DMWW SEP reporting and Sample points Gordon, Per our phone conversation— We are primarily concerned with the Nitrate sampling in the SEP sampling. Go ahead and report these as S/EP 06 and we will reject any proposed violation for S/EP 03, since as you said, S/EP 06 is representative of both SEPs. There is no need to double report these. As far as the other sampling, such as Rads, IOCs, VOCs, SOCs, etc., what we’re looking for is what are the results WITH the ASR well and what are the results WITHOUT? For example, you will do SOC sampling 3rd Qtr 2009 for S/EP 06 and it won’t be due again for 3 years. This raised another question that I didn’t think through when we were on the phone—you had mentioned the worry of shutting down the ASR operations to collect S/EP 03 samples. I don’t think this is practical or necessary. However, to be able to see that difference, we would like S/EP results from when the ASR well isn’t running. To achieve this without asking you to shut down the ASR well during production time, I would recommend sampling early for your S/EP 03 requirements. For example, your S/EP 03 SOC and VOC samples are during 3rd Quarter 2010, which is likely when your ASR is running. You are always able to sample early (perhaps 1st or 2nd Qtr 2010) and your permit will re-sequence these so that if you sampled 1st Qtr 2010, they would be next due 1st Qtr 2013. I hope this makes sense. Call if you have additional questions. Terisa Thomas 515-725-0283 -------------------------------------------------------------------------------- From: Brand, Gordon [mailto:[email protected]] Sent: Wednesday, July 22, 2009 11:19 AM To: Thomas, Terisa [DNR] Cc: McCurnin, Mike; Jones, Christopher Subject: DMWW SEP reporting and Sample points Thanks for processing the new Des Moines Water Works permit so quickly. We have begun to recover water from the McMullen ASR facility. After reviewing the permit, I have several questions that I think I know the answer to but would like verification before we submit data. Just a little background about the two ASR facilities. The McMullen ASR recovery water is pumped into the treatment plant filter effluent tunnel where it is blended with processed water from the plant. Both the process water from the plant and recovered water from the ASR facility are chlorinated at this point. I am assuming that the clear well is part of treatment (as it provides the required CT before entering the distribution system). Therefore the McMullen ASR S/EP after treatment (06) is physically the same location as McMullen after treatment (03). During ASR operations, they are actually the same.? The primary purpose of the facility is to supplement the supply of water coming through treatment with recovered water during the period of high demand. As such, once we turn it on, our intent is to leave it on until the period of high demand is past and/or the we have depleted our reserve of stored water in the aquifer. This raised the following questions regarding our monthly sampling and reporting requirements for nitrate: 1. During the months of ASR operations, can the water leaving the plant be considered both SEP 03 and 06? 2. If so, could the monthly reporting requirements be one or the other depending on whether the ASR facility is operating? 3. If we have to report both SEPs during the months in which ASR recovery is occurring, can we report the same sample result for both SEP 03 and 06? 4. There is some concern that the DNR may require us to shut down the ASR facility for several days during operations in July through September for the purpose of collecting SEP 03 samples for reporting requirements. It seems to me that the intent is for us to sample (and report) monthly according to the source(s) we are using. 5. If for some reason we would want to start ASR recovery in June (to dilute high nitrate concentrations coming from the source waters), I presume that we would need to sample and report SEP 06 data in June during ASR operations (in addition to the SEP 03 sampling prior to ASR operations) but what are the implications for reporting the following year when early start up is not needed? Regarding the L.P. Moon ASR operations, I am assuming that the L.P. Moon Ground Storage facility is considered a distribution facility so that the SEP 05 sample is ASR recovered water (after chlorine and caustic addition) but before it enters this facility where it is blended with other “distribution” water before being pumped back into the piped distribution system. Please respond ASAP so we have begun recovery at McMullen and plan to recovery at L.P. Moon soon and want to sample and report as required. JANET GASTINEAU
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