GA-EPD GORA response about Ray City wastewater permit violations 2021-04-05

Ray City has had a long string of wastewater violations, many each year, going back years, at its wastewater treatment plant on Cat Creek, just below Beaverdam Creek, and 8.36 Cat Creek miles upstream from the Withlacoochee River.

[Catwalk, Outfall, Fecal coliform]
Catwalk, Outfall, Fecal coliform

Most of them did not involve fecal bacteria, but two did, on monthly average, for December 2018 (see page 57), for August 2017 (see page 73). Curiously, none of these violations ever showed up in GA-EPD’s Sewage Spills Report, nor in its underlying spreadsheet going back to 2015, which is as far back as I have it. We have some idea why not about the January and February 2021 Total Suspended Solids (TSS) overflows, but not about the previous incidents.

In response to a Notice of Violation of September 22, 2020, on November 2, 2020, the City of Ray City told GA-EPD it was “in the process of developing a Corrective Action Plan (CAP) to address the issue of non-compliance with the 85% Minimum BOD removal rate stipulated in our NPDES Permit.“ The City proposed to change its sampling method to deal with “periodic low influent BOD levels”, and also to get on with dealing with the “high volumes of infiltration and inflow“ it says is the cause, including filing an application for a CDBG grant before the end of March 2021.

Thanks to Jay Howell of the EPD Southwest office in Albany for scanning and emailing to me the documents of my Georgia Open Records Act (GORA) request of last week. I asked for all the enforcement actions on Ray City that I found listed on EPA ECHO, (see the previous post) together with related correspondence. documents and emailing them to me yesterday. They are on the WWALS website. Update 2021-04-07: website page labels fixed for this GORA document.

This November 2020 CAP is apparently a new one, after the CAP accepted by GA-EPD on June 19, 2019, and submitted by the City on May 2, 2019:

Dear EPD

The City of Ray City is working on the following:

04/01/2019 thru 06/15/2019: Visual inspections of manholes.

05/13/2019 thru 06/15/2019: Smoke testing city sewer system in coordination with Georgia Rural Water. 06/15/2019 thru 07/15/2019: Identify areas in need of repair.

Will update CAP with additional timelines of sewer repair from the information gathered during visual and smoke testing.

That CAP was after a long chain of Notice of Violation Letters, including one on March 28, 2019, about a March 12, 2019 enforcement conference meeting with the Mayor, two of the City’s wastewater Operators, and two GA-EPD personnel.

On February 27, 2019, Ray City pled “extreme rainfall” for “December 30, 2018 thru January 30, 2019” for why its effluent totals were over the limits, and also “During the week of December 30, 2018 thru January 5, 2019, we went below PH limit and this was also contributed to the heavy rainfall the we received.” This was in response to a Notice of Violation of February 20, 2019.

Yet in January and February 2021, Ray City again had too much outflow due to rain events. Apparently there is still room for improvement. Maybe that CDBG grant will come through and fund more sanitary sewer system improvements.

The final document received is a Consent Order on Ray City of April 2017. There is probably more correspondence about that, but I’ll have to file a GORA with the Atlanta GA-EPD office to get it, if that turns out to be relevant.

Meanwhile, we have a more complete story about what’s going on with Ray City sewage.

I’d still like to know why none of these violations showed up in GA-EPD’s spill records.

 -jsq, John S. Quarterman, Suwannee RIVERKEEPER®

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