The city of Lompoc has agreed to fix deficiencies in its wastewater treatment plant operations after racking up 27 violations of the Clean Water Act uncovered by a U.S. Environmental Protection Agency investigation.
The violations stretch from June 2015 to June 2020 and involve effluent discharges, monitoring and reporting, operation and maintenance, pretreatment, and fats, oils and greases, according to an administrative order on consent issued by EPA Region 9.
City officials cooperated with the EPA investigation and have agreed to nine corrective actions that will correct current and prevent future violations, said Amy Miller, director of the Enforcement and Compliance Assurance Division for Region 9.
“It’s always better when we can reach agreement like we have here,” Miller said. “If not, then we can issue a unilateral order.”
City Administrator Jim Throop, who signed the administrative order Sept. 1, said the process went well, and the city reached agreement with the EPA on actions to remedy the violations.
He said the process went well because many of the things EPA wanted done were already in process.
“We went through [the order], and there had been some issues, primarily with staffing and experience,” Throop said. “But we have a new wastewater superintendent coming on Sept. 28 — he even has a PhD and has written a lot of papers on the subject.”
Throop said the city and a consultant were already working on an update of the sewer user ordinances. Once that’s done, they will start on a full enforcement ordinance.
“Of course, we’ll update the EPA on our progress as we are doing these things,” Throop said. “We should meet all the requirements. … It’s actually a good tool for the city.”
Maria Soledad Calvino, press officer for the EPA Region 9 Office of Public Affairs, confirmed that the order does not include a fine and only specifies changes the city must make to return to compliance with state and federal regulations.
“We are not issuing a penalty at this time,” Calvino said. “In general, we may issue a penalty at a later time after compliance is achieved. We are now focused on ensuring the city returns to compliance with the Clean Water Act.”
Miller said Lompoc did not have adequate programs for pretreatment to protect the plant from industrial pollutants and protect biological processes; to remove fats, oils and greases that can clog pipes and cause them to rupture; and to reduce the overall toxicity of effluent discharged from the plant.
Eric Magnan, manager of the Region 9 water enforcement section, said the EPA began investigating the Lompoc wastewater system following an inspection a little over a year ago that found violations in its effluent pretreatment.
The investigation turned up 17 primarily procedural pretreatment violations and five effluent violations for exceeding allowable levels on certain pollutants, including Di-2-ethylhexyl phthalate, or DEHP, which exceeded the monthly average limit during one monitoring period ending in December 2017.
DEHP, which is added to plastics to make them flexible, is believed to cause cancer, and of eight phthalates studied by the EPA, it is one of the three most toxic.
But the most frequent or “chronic” contaminant was Raphidocelis subcapitata, essentially a common green algae, which exceeded allowable levels by the greatest amount — 300% — in 17 monitoring periods between June 2015 and March 2020.
Other effluent violations involved oil and grease, which exceeded the monthly average limit in five monitoring periods between March 2017 and June 2020 and the maximum daily limit during two monitoring periods ending in September 2019 and June 2020.
The plant’s effluent also exceeded the maximum daily limit of nitrate in the period ending in February 2017 and the average weekly limit of un-ionized ammonia in two periods ending in November 2017 and September 2019.
Monitoring and reporting violations involved failing to take dissolved oxygen samples twice in 2019.
“Sometimes that’s a matter of not having good processes in place,” Magnan said. Operating and maintenance violations involved failure to provide adequate staff to operate the plant — in one instance the plant was staffed by 15 employees, when it requires 22 employees to be properly operated.
Lompoc also failed to implement a fats, oils and greases program at the plant.
To reach compliance with permits and regulations, Lompoc must make substantive changes to its pretreatment program, create an enforcement response plan, develop a fats, oils and greases program, prepare an updated budget, with staffing and equipment needs assessment, identify specific chemicals responsible for chronic toxicity and develop and implement a plan to reduce them.
The city also must submit quarterly reports on the status of its pretreatment program every year until the administrative order is terminated as well as a final report once all the provisions of the order have been met.