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qD INDIAN RIVER COUNTY, FLORIDA DEPARTMENT OF UTILITY SERVICES Date: March 24, 2017 To: Jason E. Brown, County Administrator From: Vincent Burke, P.E., Director of Utility Services Prepared By: Arjuna Weragoda, P.E., Capital Projects Manager Subject: Florida Department of Environmental Protection (FDEP) Consent Order 17-0072 for the Indian River County West Regional Wastewater Treatment Facility DESCRIPTIONS AND CONDITIONS: Indian River County Department of Utility Services (IRCDUS) owns and operates the West Regional Wastewater Treatment Facility (WWTF) located on 8 1 Street, west of 82nd Avenue. The plant is currently permitted for 6.0 million gallons per day (MGD). The West Regional WWTF wetland system, adjacent to the plant, has a permitted 4.0 MGD annual average daily flow (AADF) discharge to the Lateral D Canal, Class III fresh waters. The West Regional WWTF and wetland system FDEP Permit No. FL0041637 was renewed April 12, 2016, with an expiration date of April 11, 2021. ANALYSIS: The subject permit has waste load allocations (WLA) assigned to the plant that restrict how IRCDUS and its wetland treatment system (WTS) contractor operate the system. The Total Maximum Daily Load (TMDL) point source allocations tied to the plant are very rigid and do not allow the county any capacity to deal with varying environmental conditions. For example, should there be a large rain event, precipitation containing atmospheric nitrogen is deposited onto the 135 acre site and must be absorbed by the system even though it is an additional source of nutrient load not attributed to the WWTF operations. Additionally, birds frequenting the site can add bio load to the water way. The permit conditions put TMDL restrictions on the WTS site that changed the way the WTS was allowed to cope with extreme conditions. IRCDUS, in its efforts to achieve permit compliance with the TMDL restrictions, has had to store water in the wetlands system in direct contrast with the way the system should be operated. When water is discharged from the site, the FDEP requires IRCDUS to take samples of the discharge to ensure not only that Class III surface water quality requirements are met, but also to ensure that the nutrient concentration, given a set flow rate, does not exceed the WLA. By solving one problem, the system has developed another. Fluctuations in the water flow through the system have created pools of stagnant water. As a result, vegetative communities in the wetlands cells are now struggling to survive. Stagnant water and decomposing plant matter have led to water quality exceedances attached to the permit, for which the FDEP is now requiring corrective action. In order to address some of these exceedances, IRCDUS has already taken actions such as: • Evaluated methods to operate the WTS given the restrictive nature of the permit. C:\Users\GRAN IC-1\AppData\Local\Temp\BCL Tech nologies\easyPDF 7\@BCL@00062301\@BCL@00062301.docx P42