Title
Proposed Consent Order Regarding Wastewater Overflows (NB)
Staff will present the proposed Consent Order to the City Commission developed by the Florida Department of Environmental Protection (FDEP). The Consent Order is for violations regarding broken force mains and subsequent discharge of wastewater to the environment that occurred in July and August of 2013. The Consent Order requires GRU to pay administrative costs ($250), civil penalties ($7,500), conduct an engineering analysis of the existing force main, and develop and implement a valve exercising program for the force main system. The valve exercising program could result in significant long-term fiscal impacts including additional staff, vehicles, and equipment.
Explanation
On Friday July 26, 2013, GRU was called to investigate a wastewater odor at the 800 Block of SW 34th Street. GRU crews identified a leak on the 36" force main located just east of SW 34th Street. The leak was caused by a failure in a joint on a 36" diameter high density polyethylene (HDPE) pipe. The Commission received a presentation on August 1, 2013 detailing the events.
In addition, on August 13, 2013, an air release valve (ARV) on a 12" force main at the Gainesville Airport corroded and broke off. Approximately 58,000 gallons of wastewater was released from the force main as a result of this failed ARV. GRU crews responded and repaired the force main within 30 minutes of the reported failure.
As a result of these two incidents, the Florida Department of Environmental Protection (FDEP) has issued a proposed Consent Order. The Consent Order consists of the following elements:
1) Develop and implement a Valve Exercising Program;
2) Hire a Professional Engineer to conduct an analysis of joint deflections adjacent to the joint failure;
3) Pay the FDEP $250 in administrative fees; and
4) Pay the FDEP $7,500.00 in civil penalties or implement an in-kind project of at least $11,250.00.
We are requesting that FDEP modify several of the submittal dates for the Valve Exercising Program, the engineering analysis, and submittal of an in-kind project. A copy of the document depicting these proposed modifications has been included for your reference.
GRU will most also most likely opt to pursue an in-kind project in-lieu of the civil penalty that will be beneficial to our system and community as well as meeting the FDEP criteria of environmental enhancement, environmental restoration, or a capital/facility improvement project.
The Valve Exercising Program has the potential for significant long-term cost impacts. The valve exercising program could be conducted either by Utility Crews, (Two (2) additional Service Operators in the Wastewater Collection Department, and a service truck with valve exercising equipment), or by third-party contractual services. It is estimated that either approach will have the same budgetary impact of approximately $230,000 per year. In addition, there may be additional improvements, such as valve replacements, that will be required as part of the valve exercising program. The costs of these improvements are uncertain, but will be estimated as the program is developed.
Fiscal Note
The estimated fiscal impact includes adding two full-time employees in the wastewater collection area, purchasing a new vehicle, and valve exercising equipment. The staffing, vehicle, and equipment budgeted at $230,000 per year. In addition to these costs are potential costs associated with valve replacements that will be determined through program development and implementation. It is proposed that monies for these items would be included in the FY 2015 and subsequent budgets.
Recommendation:
1. The City Commission hear a brief presentation from staff on the elements of the proposed Consent Order; and
2. Authorize the Interim General Manager of Utilities or her designee to finalize the negotiation of the Consent Order and execute the Order on behalf of the City.