Update 2021-04-07: GA-EPD GORA response about Ray City wastewater permit violations 2021-04-05.

The bad news: Ray City, Georgia, had not one, but two wastewater spills this year. The good news: they were both mostly treated effluent, and Fecal coliform levels were well within limits.

Process Flow, Spill Report, Map: Ray City, Cat Creek, Withlacoochee River

Why was it a spill, then? It exceeded limits of total suspended solids (TSS).

How did we find out about this? Informants (who shall remain nameless unless I confirm they want to be named) told us that Ray City Council minutes for January and February mentioned water quality tests being within GA-EPD limits, but did not say why this was relevant. But this appeared in the Berrien Press on March 24, 2021:

Ray City Spill Event 2021-01-04

Ray City Spill Event

On 1/4/2021 Ray City had a high rainfall event. On that day due to the rain and a higher than average TSS test approximately 88,000 gallons of treated wastewater exceeded our permit. This is considered a spill event. This took place in Cat Creek at the WITP. Ray City is taking all precautions to prevent this from happening again.

Page 3 Berrien Press

Tifton and Ashburn also had sewage spills that weekend, which did appear in GA-EPD’s Sewage Spills Report, although Ashburn was about a week late to report, as usual. Yet Ray City has never had a spill appear in that report, not only in since it became public a couple of years ago at our request, but also in GA-EPD’s internal records we previously retrieved going back to 2015. That makes me wonder how many spills Ray City has had during “high rainfall events” that never got reported.

So I contacted GA-EPD. Jay Howell responded. He is Water/Wastewater Manager at GA-EPD’s Southwest District in Albany, GA.

Location and type of Ray City wastewater plant

First, where is this Ray City wastewater plant? About a third of a mile downstream on Cat Creek from the Hubert F. Comer Bridge over GA 37, just west of Ray City.

Map: Ray City, Cat Creek, Withlacoochee River
in the WWALS map of the Withlacoochee and Little River Water Trail.

More specifically, just below where Beaverdam Creek (the creek that begins in Ray’s Mill Pond) enters Cat Creek, behind the New Ramah Primitive Baptist Church Cemetery.

Map: Detail, Ray City WPCP
in the WWALS map of the Withlacoochee and Little River Water Trail.

The Ray City WPCP is 8.36 Cat Creek miles upstream from the Withlacoochee River, which it enters 1.71 Withlacoochee River miles downstream from Franklinville Landing, and 8.74 river miles upstream from the US 41 (North Valdosta Road) bridge where Valdosta tests water quality three times a week.

Valdosta did show both Fecal coliform and E. coli higher than limits at that US 41 test site on January 4, 2021. But that probably wasn’t because of Ray City, whose bacterial levels were within limits. Tifton also spilled into the New River upstream from there on 2 and 3 January 2021, so that could have been the source, or it could have been manure runoff or some other source.

The Ray City wastewater plant is not a spray field. It’s a treatment pond, which according to the process flow schematic in the wastewater permit application, is divided into three sections (you can also see them on the above detail map):

ALL WASTEWATER TO THIS FACILITY IS PUMPED THROUGH THE INFLUENT PUMPING STATION AND RECEIVES TREATMENT IN A THREE CELL POND SYSTEM. THE CELLS ARE SEPARATED WITH CURTAIN BAFFLES AND THE FIRST TWO CELLS ARE AERATED. EFFLUENT FROM THE THIRD CELL IS CHLORINATED FOLLOWED BY DE-CHLORINATION PRIOR TO DISCHARGE TO CAT CREEK.

EXHIBIT B: Process Flow
PDF

Now you know why I got Ray City’s National Pollutant Discharge Elimination System (NPDES) permit from GA-EPD and published it.

January 2021 Ray City spill

GA-EPD’s Jay Howell explained that Ray City did report their test results for January in a timely manner. However, Ray City did not recognize that they had had a spill.

On about February 28, 2021, EPD determined from discharge monitoring that it was a major spill, and sent Ray City a notice of violation, invoking emergency requirements in its permit, including a newspaper announcement, stream monitoring, etc. See Ray City’s NPDES permit No. GA0033553, page 16, definition of major spill, type 1.

Page 17

Spills and Major Spills:

A “spill” is any discharge of raw sewage by a Publicly Owned Treatment Works (POTW) to the waters of the State.

A “major spill” means:

1. The discharge of pollutants into waters of the State by a POTW that exceeds the weekly average permitted effluent limit for biochemical oxygen demand (5-day) or total suspended solids by 50 percent or greater in one day, provided that the effluent discharge concentration is equal to or greater than 25 mg/L for biochemical oxygen demand or total suspended solids.
2. Any discharge of raw sewage that 1) exceeds 10,000 gallons or 2) results in water quality violations in the waters of the State.

Specifically, for 3-9 January 2021, total suspended solids (TSS) was 64 kilograms/day (kg/day), which is over the loading limit of 42.6 weekly average: see page 6 in the permit.

Page 07

The total effluents were also over the limit: 0.266 million gallons a day (MGD), well over the 0.125 MGD permit limit. They were over that lijmit for two weeks, and also monthly. Ray City also exceeded weekly and monthly biochemical oxygen demand (BOD) loading.

So why did this spill not appear in GA-EPD’s Sewage Spills Report, which is published every weekday? Jay Howell was also puzzled by this, since the spill is in GA-EPD’s internal database from which that public Sewage Spills Report is drawn. Our best speculation is that since the public Report only goes back thirty days, and GA-EPD determined the 4 January 2021 spill was a spill more than a month after it occured, so when the software that extracts the Sewage Spills Report from the internal GA-EPD database ran, it did not pick up that spill.

February 2021 Ray City spill

Jay Howell wondered why I hadn’t asked about the February spill. I said because I didn’t know anything about a February spill, which also had not appeared in GA-EPD’s Sewage Spills Report.

The February spill was entered in GA-EPD’s internal database as zero gallons, which is how they handle spills for which the total amount is not yet known. It occured January 31 through February 6, 2021.

Effluent biochemical oxygen demand (BOD) was 22, more than 50% over the limit of 14.2 kg/day weekly average, and this was for every week of February. Plus total discharge (effluent flow) was 0.157 million gallons per day (MGD), well over the permit limit of 0.125 MGD. Ray City also exceeded monthly average flow and monthly BOD for February, as well as percent removal rate for BOD. GA-EPD issued a letter to Ray City about this on March 18, 2021.

But bacteral contamination was well within limits

The GA-EPD NPDES permit for Ray City sets bacterial limits in terms of Fecal coliform. Jay Howell says Ray City was well within those limits throughout January and February.

Some of those numbers are in EPA ECHO: https://echo.epa.gov/. Ray City’s January numbers are in there; February not yet. The way this works is GA-EPD puts it in its own internal database, which flows into the Integrated Compliance Information System (ICIS) database of the U.S. Environmental Protection Agency (EPA). EPA ECHO is the public portal of EPA ICIS.

Ray City Fecal coliform:

• January 84 monthly; highest 90; limit 400
• February 111 monthly; highest 115; limit 400

EPA ECHO also shows a list of enforcement actions from GA-EPD for Ray City.

Informal Enforcement Actions (5 Years)

• CWA ICIS-NPDES GA0033553 Base Program – Notice of Violation State 03/18/2021
• CWA ICIS-NPDES GA0033553 Base Program – Notice of Violation State 02/18/2021
• CWA ICIS-NPDES GA0033553 Base Program – Notice of Violation State 09/22/2020
• CWA ICIS-NPDES GA0033553 Base Program – Notice of Noncompliance Issued State 08/25/2020
• CWA ICIS-NPDES GA0033553 Base Program – Notice of Noncompliance Issued State 07/21/2020
• CWA ICIS-NPDES GA0033553 Base Program – Notice of Noncompliance Issued State 06/24/2020
• CWA ICIS-NPDES GA0033553 Base Program – Notice of Noncompliance Issued State 04/22/2020
• CWA ICIS-NPDES GA0033553 Base Program – Notice of Noncompliance Issued State 03/27/2020
• CWA ICIS-NPDES GA0033553 Base Program – Notice of Noncompliance Issued State 01/27/2020
• CWA ICIS-NPDES GA0033553 Base Program – Notice of Noncompliance Issued State 12/31/2019
• CWA ICIS-NPDES GA0033553 Base Program – Notice of Noncompliance Issued State 04/26/2019
• CWA ICIS-NPDES GA0033553 Base Program – Notice of Violation State 03/28/2019
• CWA ICIS-NPDES GA0033553 Base Program – Notice of Violation State 03/28/2019
• CWA ICIS-NPDES GA0033553 Base Program – Notice of Violation State 02/20/2019
• CWA ICIS-NPDES GA0033553 Base Program – Notice of Noncompliance Issued State 01/31/2019
• CWA ICIS-NPDES GA0033553 Base Program – Notice of Noncompliance Issued State 08/30/2018
• CWA ICIS-NPDES GA0033553 Base Program – Notice of Noncompliance Issued State 07/31/2018
• CWA ICIS-NPDES GA0033553 Base Program – Notice of Noncompliance Issued State 10/30/2017
• CWA ICIS-NPDES GA0033553 Base Program – Notice of Noncompliance Issued State 09/19/2017
• CWA ICIS-NPDES GA0033553 Base Program – Notice of Noncompliance Issued State 07/06/2016

Formal Enforcement Actions (5 Years)

• CWA ICIS-NPDES OTHER NPDES/GA0033553 Administrative – Formal GA-NPDENF004697 State Ray, City of (Ray City WPCP) (GA0033553) Consent Order 04/18/2017 1 04/18/2017 $0 $0

I have filed a Georgia Open Records Act (GORA) request with GA-EPD to get these documents. Jay Howell is working on it. I will publish those documents after I get them.

Jay Howell also says Ray City has hired an engineering firm, probably Coastal Engineering Consultants to work on modifications to the plant to meet permit limits. This is the same firm you see listed on the permit application diagrams.

He confirmed what I’d heard elsewhere, that Ray City is probably applying for a Georgia Community Development Block Grant (CDBG). That application was apparently due end of March 2021, with awards to be known in August or September. Many Georgia cities and counties apply to CDBG, so it is quite competitive. One hopes Ray City succeeds in getting a CDBG grant to fix its wastewater plant.

Ray City Council could have saved many people a lot of puzzlement by just telling people what was going on.

 -jsq, John S. Quarterman, Suwannee RIVERKEEPER®

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