Loading...
HomeMy WebLinkAbout2005-057 ATTACHMENT 1 SCOPE OF WORK SOUTH RO PLANT CONCENTRATE DISPOSAL PERMIT RENEWAL Project Description and Understanding Indian River County ' s (IRC) South RO water treatment plant (Oslo Road) currently has a permit to dispose of concentrate to a surface water body under Florida Department of Environmental Protection (FDEP) Permit 31 -FL0037940 — Minor NPDES Non-POTW Discharge . The permit allows for 1 . 5 mgd maximum daily flow of concentrate disposal to the South relief canal and expires December 14 , 2005 . A permit renewal application, including supporting data, must be submitted at least 180 days (June 17 , 2005 ) before the expiration date of the permit in accordance with specific condition VII. C . 10 The concentrate, or byproduct of the water treatment process, is currently treated to remove hydrogen sulfide and increase dissolved oxygen. The treated byproduct is discharged through a 14" pipe, approximately 3 , 650 ft long into the Indian River County South Relief Canal, a Class III fresh water body. The outfall is downstream of a control structure and thence 10, 000 feet downstream into the Indian River, which is classified at that point a Class III marine body. Chlorination is performed to primarily eliminate the majority of hydrogen sulfide (H2S ), whereas air is injected into the stream to remove the remaining H2S and increase dissolved oxygen . A mixing zone is approved for three parameters : Gross Alpha, Combined Radium (Ra 226 and Ra228) and specific conductivity, all of which have different and distinct mixing zone limits . Turbidity and chromium were limits originally established under the original permit, however, based on historical levels measured well below standards , limits for these parameter were removed from the previous permit . Through discussions with staff, the South County RO plant has indicated historical failures of toxicity testing for mysidopsis bahia (mysid shrimp) and has reported these results to FDEP . Based on this, it is believed that ion imbalance toxicity exists and a variance for acute toxicity and/or a mixing zone for chronic toxicity will need to be addressed under this permit renewal process . IRC ' s current permit does not require testing for chronic toxicity. It is believed that FDEP will request that IRC conduct ion imbalance review and testing. SCOPE OF SERVICES In general , the following scope of services will include review of existing permit and pertinent data, meetings with FDEP and IRC staff, preparation and submittal of permit application including existing information (majority provided by IRC) , existing mixing models , and no changes in capacity or quality of concentrate, conducting ion imbalance water quality testing to address acute toxicity, toxicity investigation evaluation, and H:\044572009\South RO Plant Concentrate Disposal-revl .doc 1 responding to FDEP requests for additional information (RFI) . Task 1 — Data Collection and Permit Review Existing data relative to concentrate water quality and background water quality in the canal must be gathered and analyzed in order to present a concise case to FDEP for renewal of the permit . We will prepare a list of data and documentation needed for the preparation of the permit renewal application . Information such as drawings of the existing outfall, background water quality data, agreements allowing discharge to canal , treatment plant water quality, MOR ' s, Toxicity reports (SRT), historical concentrate water characteristic data, process diagrams , etc . , as a minimum , will be provided by IRC for use in preparing the permit application. IRC will provide this information as expeditiously as possible . KHA will review the existing operating permit and supporting documentation. We will review the permit conditions and historical concentrate water quality which will be used to assess the approach in preparing the application . Task 2 - Meetings An initial pre-application meeting with the Central District FDEP office in Orlando will be requested to discuss specific requests and general approach with issuing a renewal of this permit . We estimate up to ten meetings with FDEP during the permitting process . These meetings include preparation time as well as correspondence documenting the meetings and outcome of these meetings . The budget figure presented herein includes one meeting with the Tallahassee FDEP office which may be necessary. It is our experience that the District FDEP office will not conduct the technical examinations of data presented and will defer decisions to Tallahassee . Task 3 — Prepare Permit Application The application form for renewal of the permit is approximately 31 pages long and must include a number of supporting exhibits . Application forms 62 -620 . 910 ( 1 ) and 2CS 62 -620 . 910 ( 5 ) will be prepared and submitted. Portions of this application require extensive analysis of the concentrate for "regulated substances" . We will conduct water quality analysis, prepare draft applications for IRC review, include required documentation and attachments , reiterate mixing calculations previously submitted, and address ion-imbalance toxicity. The application fee to FDEP is $6 , 000 and is included in this task. The application will be submitted by June 17 , 2005 to FDEP and allow for review time from IRC staff. A draft application will be submitted to IRC for review by end of April 2005 . Lab costs for tests to be provided by Indian River County. Task 4 — Conduct Ion-Imbalance Testing (Toxicity Investigation Evaluation) H :\044572009\South RO Plant Concentrate Disposal-revl . doc 2 Based on discussions with staff, historical failures of toxicity testing for mysidopsis bahia (mysid shrimp) have occurred and were reported to FDEP . Follow up meetings with FDEP and IRC staff regarding the failures , have been conducted of which FDEP has suggested considering an ion imbalance review to determine the nature and type of failures . Based on our experience, we recommend proceeding with a toxicity investigation evaluation (TIE) since ion imbalance is most likely the culprit of the existing toxicity failures and not a result of toxic substances in the concentrate . Through the testing evaluation, we can additionally identify if toxic substances, such as residual chlorine, may be the cause of the toxicity failures . The FDEP Guidance Manual provides a rigid procedure to be followed in conducting bio- assay testing to determine if ion imbalance toxicity is present . This testing will be conducted by Aqua Survey Laboratories located in Flemington, NJ as they have shown an ability in the past to accurately conduct this testing . Water quality testing is also required in order to identify the amount of seawater ions present in the sample of concentrate . This testing must be accurate and results provided within 24 hours . The effort for this task includes bio-assay testing, preparation of report, water quality parameter testing, sample collection, shipping, lab coordination, and final report review. Task 5 — Respond to RFI ' s Due to the unpredictable nature of these permit renewals for concentrate disposal to surface waters, considerable time and effort can be expended for responses to requests for additional information. A variance for acute toxicity will be requested under the application renewal . Without the TIE, it cannot be determined at this point if a mixing zone for chronic toxicity will be required; however, the necessary work to address chronic toxicity is included in this scope. Initial calculations to support a mixing zone for toxicity will be provided under this scope . Effort beyond addressing chronic toxicity to FDEP can be provided as additional scope . We anticipate up to two requests for additional information which does not include additional modeling, water quality analysis , re-do ' s of the bio-assay testing, and any complex modeling FDEP may require above and beyond what is typically required for these permit, which is beyond the work described herein . Should the permitting process drag out beyond a reasonable time frame and involve extensive coordination and additional responses beyond what is listed herein with EPA, this is considered a additional scope and can be negotiated under a separate work order. SCHEDULE We anticipate submittal of draft application to IRC staff by end of April 2005 to mid May 2005 . The permit application will be submitted to FDEP by June 17 , 2005 . We will respond to BFI ' s in accordance with FDEP protocol . INFORMATION PROVIDED BY OWNER • Copies of all plant permits H :\044572009\South RO Plant Concentrate Disposal-revl . doc 3 , t • Monthly operating reports and water quality test results • Copies of all notices , violations , etc with FDEP regarding concentrate discharge • Receiving waters monitoring reports • Permits, easements , authorization for use of relief canal FEES Consultant will provide these Services as described herein on an hourly basis utilizing the attached hourly rates (Exhibit 2) with upset limits as outlined below : Task Upset Limit ($) 1 . Data Collection and Permit Review $ 4 , 500 2 . Meetings $ 159000 3 . Prepare Permit App (incl $6k app fee) $ 17 , 500 4 . Conduct Ion-Imbalance Testing $ 20 ,000 5 . Respond to RFI ' s $ 12 , 000 Total $ 68,000 We will provide these services in accordance with our Continuing Services Contract with Indian River County date April 6th, 2004 and Kimley-Horn and Associates, Inc . H :\044572009\South RO Plant Concentrate Disposal-revl . doc 4 WORK ORDER NUMBER 6 This Work Order Number 6 is entered into as of this 8th day of February , 2005 pursuant to that certain Continuing Contract Agreement for Professional Services entered into as of April 6 , 2004 ("Agreement") , by and between Indian River County, a political subdivision of the State of Florida ("COUNTY") and Kimley-Horn and Associates Inc . ("CONSULTANT") . The COUNTY has selected the Consultant to perform the professional services set forth on Attachment 1 , attached to this Work Order and made part hereof by this reference . The professional services will be perfonned by the Consultant for the fee schedule set forth in Attachment 1 , attached to this Work Order and made a part hereof by this reference . The Consultant will perform the professional services within the timeframe more particularly set forth in Attachment I . attached to this Work Order and made a part hereof by this reference all in accordance with the terms and provisions set forth in the Agreement . Pursuant to paragraph 1 . 4 of the Agreement, nothing contained in any Work Order shall conflict with the terms of the Agreement and the terms of the Agreement shall be deemed to be incorporated in each individual Work Order as if fully set forth herein. IN WITNESS WHEREOF, the parties hereto have executed this Work Order as of the date first written above . CONSULTANT BOARD OF COUNTY COMMISSIONERS Kimley-Horn and Associates Inc . OF INDIAN RIVER COUNTY By ` BP 4 S. Thomas S . Lowther, Chairman Title : iz U Approved : 02 - 08 - 2005 Attest : J . K. B � 1'Cierk `dfLau�i , � ILI By Deputy Clea �, '•. ,• „ Approved : , r , seph A Baird, County Adr3nistrator Approved as to form and legal sufficiency: Z,7�le 60f,"; CMarian E . Fell , Assistant County Attorney Exhibit 2 Mniley Horn & Associates, Inc. Hourly Rates 2004 Classification Rate Support Staff $ 45.00 - $ 52 .50 Senior Support Staff $ 52 . 50 - $ 70 . 00 Technician/Draftsman 2 $ 55 . 00 - $ 75 . 00 Senior Technician $ 75 . 00 - $ 90 . 00 CADD Operator $ 62 . 50 - $ 72 . 50 Senior CADD Operator $ 75 . 00 - $ 85 . 00 Designer $ 85 . 00 - $ 92 . 50 Professional 1 $ 70 . 00 - $ 82 . 50 Professional 2 $ 87 . 50 - $ 100 . 00 Registered Professional $ 100 . 00 - $ 115 . 00 Senior Professional $ 115 . 00 - $ 165 . 00 Principal $ 150 . 00 - $ 185 . 00 H :\044572009\South RO Plant Concentrate Disposal-revl .doc 5