HomeMy WebLinkAbout2025-234September 19, 2025
DeSantis
FLORIDA DEPARTMENT OF RonGovernor
Environmental Protection Jay Collins
Sean Lieske, Director
Indian River County Utilities
180127 1h Street
Vero Beach, FL 32960
sl i eske(a) indi anriver.g_ov
Lt. Governor
Southeast District
3301 Gun Club Road, MSC 7210-1 Alexis A. Lambert
West Palm Beach, FL 33406 Secretary
561-681-6600
Re: Indian River County Utilities and Collection System
DW Facility ID # FLA010431, FLA104388, FL0041637, FLA010435, FLSSOA483
Indian River County
Dear Mr.: Lieske
Enclosed is a Consent Order ("Order") prepared by the Department for resolution of the above -
referenced enforcement case. Please review this document and within 20 days of receipt return a
signed copy to the Department. All pages within the Order should be included with your returned
signed copy. Once fully executed, a copy of the final document will be forwarded to you.
Should you have any questions or comments, please contact Chelsea Justis at 561-681-6645 or
via e-mail at Chelsea.JustisAFloridaDEP.gov.
Sincerely,
Sirena Davila
Director, Southeast District
Florida Department of Environmental Protection
Enclosure: Consent Order
ec: Jose Vega, Environmental Compliance Analyst jvegaAindianriver.gov
Rich Meckes, Operations manager rmeckes(a),indianriver.gov
Mike Loveday, Wastewater Superintendent mlovedayC&indianriver.gov
wwwYloridaDEP.,zov
BEFORE THE STATE OF FLORIDA
DEPARTMENT OF ENVIRONMENTAL PROTECTION
STATE OF FLORIDA DEPARTMENT ) IN THE OFFICE OF THE
OF ENVIRONMENTAL PROTECTION ) SOUTHEAST DISTRICT
V. ) OCC FILE NO. 22-0150
INDIAN RIVER COUNTY )
SETTLEMENT AGGREEMENT
This Settlement Agreement (Agreement) is entered into between the State of
Florida Department of Environmental Protection (Department) and Indian River
County (Respondent) to reach settlement of certain matters at issue between the
Department and Respondent.
The Department finds and Respondent admits the following:
1. The Department is the administrative agency of the State of Florida
having the power and duty to protect Florida's air and water resources and to
administer and enforce the provisions of Chapter 403, Florida Statutes (F.S.), and the
rules promulgated and authorized in Title 62, Florida Administrative Code (F.A.C.).
The Department has jurisdiction over the matters addressed in this Agreement.
2. Respondent is a person within the meaning of Section 403.031(5), F.S.
3. Respondent is the owner and is responsible for the operation of the
following facilities: Indian River County Utilities Department Central (Gifford) WWTF
FLA010431, Indian River County Utilities Department North Regional WWTF
FLA104388, Indian River County Utilities Department West Regional WWTF
FL0041637, and Indian River County Utilities Department South Regional WWTF
FLA010435 and the Collection system FLSSOA483. These facilities are located in Indian
River County and have collections systems that service much of Indian River County.
4. The Department finds that the following violation(s) occurred:
DEP vs. Indian River County
Settlement Agreement, OGC No. 22-0150
Page 2
a. Sanitary sewer overflows or unauthorized discharges, in violation
of Rule 62-604.130, F.A.C., and F.S. 403.121(3)(b).
# SWO# Date Vol (gal)
1 2021-6812 12/3/2021 83,800
2 2022-3365 5/13/2022 41,472
3 2022-7182 9/15/2022 37,100
4 2022-7641 9/28/2022 302,392
5 2024-9105 10/09/2024 32,585
Surface Water
NA
Indian River Lagoon
Lateral J Canal
NA
NA
Cause
Broken FM
Tap Saddle Failure
Broken ARV
Broken FM (Corrosion)
Overflow at Central
(Gifford) WWTF due to
rain
b) Respondent's Emergency Response Plan did not have provisions
for sampling the receiving waters after each unauthorized discharge to surface waters,
and no sampling was conducted for various of the discharges. The Emergency
Response Plan did not include all the required information, in violation of Rule 62-
604.500(4)(b). Respondent has implemented the following as part of their Operation
and Maintenance Manual:
a) A Surveillance and SSO Detection Program which provides a
detailed description of the Respondent's collection system and includes surveillance
and SSO detection as well as the equipment needed to carry out the plan and the types
and frequency of monitoring to be performed. The assessment included an assessment
of the condition of existing connections, lift stations, and manholes.
b) Respondent has implemented an Emergency Response Plan that
addresses the Respondent's preparation for, response to, follow-up for, and
documentation of unauthorized discharge events.
Having reached a resolution of the matter Respondent and the Department
mutually agree and it is
ORDERED:
DEP vs. Indian River County
Settlement Agreement, OGC No. 22-0150
Page 3
6. Respondent shall comply with the following corrective actions within the
stated time periods:
a) Within 60 days of the effective date of this Settlement Agreement,
submit to the Department an updated Emergency Response Plan that further
incorporates all requirements of Rule 62-604.500 (4)(b). The updated Plan shall include
the following:
i. How, when and for how long sampling of surface waters
will be conducted, who will collect samples and how the samples will be handled and
transported to a certified laboratory, including sampling when an unauthorized
discharge occurs after business hours, on holidays, or during inclement weather. The
Plan shall provide for sampling and analyses to begin within 24 hours. For tidally
influenced waters, the Plan shall provide for sampling to begin prior to the tidal change
immediately following the cessation of the unauthorized discharge.
ii. The available disinfection and odor control materials and
the instances in which they may be used: granular chlorine, lime, any other products;
aerators.
iii. The frequency of initial training, refresher training and
references to quick reference guides, if any, that are provided to the staff to help during
a response to a sanitary sewage overflow event.
iv. The procedure to notify the public of a sanitary sewer
overflow. Options could include signs, news media, social media etc.
V. The up-to-date inventory of equipment, supplies and staff
who has the authority to get personnel, equipment and materials to the site of the
sanitary sewage overflow.
vi. A schedule for implementing each of the elements in this
Paragraph, with all elements implemented no later than March 31, 2026.
7. Respondent's completion of all corrective actions required by paragraph 6
within the respective deadlines specified thereunder shall constitute full compliance
DEP vs. Indian River County
Settlement Agreement, OGC No. 22-0150
Page 4
with Rule 62-620 and 62-604, F.A.C. with respect to the specific violations addressed in
this Agreement.
8. Within 30 days of the effective date of this Agreement, Respondent shall
pay the Department $30,495.00 in settlement of the regulatory matters addressed in this
Agreement. This amount includes $29,995.00 for civil penalties and $500.00 for costs and
expenses incurred by the Department during the investigation of this matter and the
preparation and tracking of this Agreement. The civil penalty in this case includes 2
violations that each warrant a penalty of $2,000.00 or more. This penalty only addresses
violations occurring from December 2021 to -October 2024, any spills after this date
until the closing of the Settlement Agreement can be penalized via stipulated penalties.
9. Respondent agrees to pay the Department stipulated penalties in the
amount of $1,000.00 per day for each and every day Respondent fails to timely comply
with any of the requirements of paragraphs 6 of this Agreement. Additionally,
Respondent shall pay the Department stipulated penalties for any discharges of
wastewater from the WWTF and/or collection/ transmission system. Respondent shall
pay penalties as follows:
Amount p/day p/discharge
$1,000.00
$2,000.00
$5,000.00
$10,000.00
$15,000.00
Discharge Volume
up to 5,000 gallons
5,001 to 10,000 gallons
10,001 to 25,000 gallons
25,001 to 100,000 gallons
in excess of 100,000 gallons
The Department may demand stipulated penalties at any time after violations occur.
Respondent shall pay stipulated penalties owed within 30 days of the Department's
issuance of written demand for payment and shall do so as further described in
paragraph 10, below. Nothing in this paragraph shall prevent the Department from
filing suit to specifically enforce any terms of this Agreement. Any stipulated penalties
DEP vs. Indian River County
Settlement Agreement, OCC No. 22-0150
Page 5
assessed under this paragraph shall be in addition to the civil penalties agreed to in
paragraph 8 of this Agreement.
10. Respondent shall make all payments required by this Agreement by
cashier's check, money order or on-line payment. Cashier's check or money order shall
be made payable to the "Department of Environmental Protection' and shall include
both the OGC number assigned to this Agreement and the notation "Water Quality
Assurance Trust Fund." Online payments by e -check can be made by going to the DEP
Business Portal at: http://www.fldepportal.com/go/pay/. It will take a number of
days after this order is final, effective, and filed with the Clerk of the Department before
ability to make online payment is available.
11. In -Kind Option for Offset of Penalties or Stipulated Penalties:
In lieu of making cash payment of $29,995.00 in civil penalties as set forth
in paragraph 8 above, Respondent may elect to offset this amount by implementing an
in-kind penalty project, which must be approved by the Department. An in-kind project
must be either an environmental enhancement, environmental restoration or a
capital/ facility improvement project and may not be a corrective action requirement of
the Agreement or otherwise required by law. The Department may also consider the
donation of environmentally sensitive land as an in-kind project. The value of the in-
kind penalty project shall be one and a half times the civil penalty off -set amount, which
in this case is the equivalent of at least $44,992.50. If Respondent chooses to implement
an in-kind project, Respondent shall notify the Department of its election within 15 days
of the effective date of this Settlement Agreement. Notwithstanding the election to
implement an in-kind project, payment of the remaining $500.00 in costs must be paid
within 30 days of the effective date of the Settlement Agreement. In the event that
Respondent elects to off -set civil penalties including stipulated penalties by
implementing an in-kind penalty project which is approved by the Department, during
the period that this Agreement remains in effect or during the effective date of any
Department issued Permit to Respondent whichever is longer (Prohibited Transfer
DEP vs. Indian River County
Settlement Agreement, OGC No. 22-0150
Page 6
Duration), Respondent shall not transfer or use funds obtained by the Respondent from
the collection of sewer rates for any purpose not related to the management, operation,
or maintenance of the Sewer System or to any capital improvement needs of the Sewer
System (hereinafter, Prohibited Transfer). Respondent shall annually certify to the
Department using the Annual Certification Form located on Exhibit B to this Settlement
that no Prohibited Transfer has occurred. In the event of any Prohibited Transfer, the In -
Kind project option shall be forfeited, and entire civil penalty shall immediately become
due and owing to the Department irrespective of any expenditures by the Respondent
in furtherance of the In -Kind project. If Respondent elects to implement an in-kind
project as provided in this paragraph, then Respondent shall comply with all the
requirements and time frames in Exhibit A entitled In -Kind Projects.
12. Pollution Prevention Option for Offset of Penalties or Stipulated
Penalties:
In lieu of making cash payment of $29,995.00 in civil penalties as set forth
in Paragraph 8, Respondent may elect to offset this amount by implementing a
Pollution Prevention (P2) Project, which must be approved by the Department. P2 is a
process improvement that reduces the amount of pollution that enters the environment;
by conserving resource (including water, raw materials, chemicals, and energy) use, or
by minimizing waste generation (including domestic and industrial wastewater, solid
and hazardous waste, and air emissions). A P2 Project must reduce pollution or waste
within the process beyond what is required by federal, state, or local law, in order to be
eligible for civil penalty offset under this Agreement. If Respondent chooses to
implement a P2 Project, Respondent shall notify the Department of its election by
certified mail within 15 days of the effective date of this Agreement. Notwithstanding
the election to implement a P2 Project, payment of the remaining $500.00 in costs must
be paid within 30 days of the effective date of the Settlement Agreement. If Respondent
elects to implement a P2 Project, Respondent shall submit a completed P2 Project Plan
(Plan) within 60 days of the effective date of this Agreement. The Plan must be
DEP vs. Indian River County
Settlement Agreement, OGC No. 22-0150
Page 7
completed using Exhibit B, "P2 Project Plan" template. In the event the Department
requires additional information to process the Plan described in this paragraph,
Respondent shall provide a modified Plan containing the information requested by the
Department within 30 days of the date of the request. If any balance remains after the
entire P2 credit is applied to the allowable portion of the civil penalty, Respondent shall
pay the difference within 30 days of written notification by the Department to
Respondent that the balance is due.
13. Except as otherwise provided, all submittals and payments required by
this Order shall be sent to Chelsea Justis, Southeast District, Department of
Environmental Protection, 3301 Gun Club Road, MSC 7210-1, West Palm Beach, Florida,
33406 and SED.Wastewater@dep.state.fl.us.
14. Respondent shall allow all authorized representatives of the Department
access to the Facility and the Property at reasonable times for the purpose of
determining compliance with the terms of this Settlement and the rules and statutes
administered by the Department.
15. If any event, including administrative or judicial challenges by third
parties unrelated to Respondent, occurs which causes delay or the reasonable likelihood
of delay in complying with the requirements of this Settlement, Respondent shall have
the burden of proving the delay was or will be caused by circumstances beyond the
reasonable control of Respondent and could not have been or cannot be overcome by
Respondent's due diligence. Neither economic circumstances nor the failure of a
contractor, subcontractor, materialman, or other agent (collectively referred to as
"contractor') to whom responsibility for performance is delegated to meet contractually
imposed deadlines shall be considered circumstances beyond the control of Respondent
(unless the cause of the contractor's late performance was also beyond the contractor's
control). Upon occurrence of an event causing delay, or upon becoming aware of a
potential for delay, Respondent shall notify the Department by the next working day
and shall, within seven calendar days notify the Department in writing of (a) the
DEP vs. Indian River County
Settlement Agreement, OGC No. 22-0150
Page 8
anticipated length and cause of the delay, (b) the measures taken or to be taken to
prevent or minimize the delay, and (c) the timetable by which Respondent intends to
implement these measures. If the parties can agree that the delay or anticipated delay
has been or will be caused by circumstances beyond the reasonable control of
Respondent, the time for performance hereunder shall be extended. The agreement to
extend compliance must identify the provision or provisions extended, the new
compliance date or dates, and the additional measures Respondent must take to avoid
or minimize the delay, if any. Failure of Respondent to comply with the notice
requirements of this paragraph in a timely manner constitutes a waiver of Respondent's
right to request an extension of time for compliance for those circumstances.
16. The Department, for and in consideration of the complete and timely
performance by Respondent of all the obligations agreed to in this Agreement, hereby
conditionally waives its right to seek judicial imposition of damages or civil penalties
for the violations described above up to the date of the filing of this Agreement. This
waiver is conditioned upon Respondent's complete compliance with all the terms of
this Agreement.
17. This Agreement is a settlement of the Department's civil and
administrative authority arising under Florida law to resolve the matters addressed
herein. This Agreement is not a settlement of any criminal liabilities which may arise
under Florida law, nor is it a settlement of any violation which may be prosecuted
criminally or civilly under federal law. Entry of this Order does not relieve Respondent
of the need to comply with applicable federal, state, or local laws, rules, or ordinances.
18. The Department hereby expressly reserves the right to initiate appropriate
legal action to address any violations of statutes or rules administered by the
Department that are not specifically resolved by this Agreement.
19. Respondent is fully aware that a violation of the terms of this Agreement
may subject Respondent to judicial imposition of damages, civil penalties up to
$15,000.00 per day per violation, and criminal penalties.
DEP vs. Indian River County
Settlement Agreement, OGC No. 22-0150
Page 9
20. Respondent acknowledges and waives its right to an administrative
hearing pursuant to sections 120.569 and 120.57, F.S., on the terms of this Agreement.
Respondent also acknowledges and waives its right to appeal the terms of this
Agreement pursuant to section 120.68, F.S.
21. Electronic signatures or other versions of the parties' signatures, such as
.pdf or facsimile, shall be valid and have the same force and effect as originals. No
modifications of the terms of this Agreement will be effective until reduced to writing,
executed by both Respondent and the Department, and filed with the clerk of the
Department.
22. The terms and conditions set forth in this Agreement may be enforced in a
court of competent jurisdiction pursuant to sections 120.69 and 403.121, F.S. Failure to
comply with the terms of this Agreement constitutes a violation of section 403.161 (1) (b),
F.S.
23. This Settlement Agreement is a final order of the Department pursuant to
section 120.52(7), F.S., and it is final and effective on the date filed with the Clerk of the
Department unless a Petition for Administrative Hearing is filed in accordance with
Chapter 120, F.S. Upon the timely filing of a petition, this Settlement Agreement will
not be effective until further order of the Department.
Persons who are not parties to this Settlement Agreement, but whose substantial
interests are affected by it, have a right to petition for an administrative hearing under
sections 120.569 and 120.57, Florida Statutes. Because the administrative hearing
process is designed to formulate final agency action, the filing of a petition concerning
this Settlement Agreement means that the Department's final action may be different
from the position it has taken in the Settlement Agreement.
The petition for administrative hearing must contain all the following
information:
a) The name and address of each agency affected and each agency's file or
identification number, if known;
DEP vs. Indian River County
Settlement Agreement, OGC No. 22-0150
Page 10
b) The name, address, any e-mail address, any facsimile number, and telephone
number of the petitioner, if the petitioner is not represented by an attorney or
a qualified representative; the name, address, and telephone number of the
petitioner's representative, if any, which shall be the address for service
purposes during the course of the proceeding; and an explanation of how the
petitioner's substantial interests will be affected by the agency determination;
c) A statement of when and how the petitioner received notice of the agency
decision;
d) A statement of all disputed issues of material fact. If there are none, the
petition must so indicate;
e) A concise statement of the ultimate facts alleged, including the specific facts
the petitioner contends warrant reversal or modification of the agency's
proposed action;
f) A statement of the specific rules or statutes the petitioner contends require
reversal or modification of the agency's proposed action, including an
explanation of how the alleged facts relate to the specific rules or statutes; and
g) A statement of the relief sought by the petitioner, stating precisely the action
petitioner wishes the agency to take with respect to the agency's proposed
action.
The petition must be filed received at the Department's Office of General
Counsel, 3900 Commonwealth Boulevard, MS# 35, Tallahassee, Florida 32399-3000 or
received via electronic correspondence at Agency_Clerk@floridadep.gov, within 21
days of receipt of this notice. A copy of the petition must also be mailed at the time of
filing to the District Office at Southeast District Office 3301 Gun Club Road, MSC 7210-1
West Palm Beach, FL 33406. Failure to file a petition within the 21 -day period
DEP vs. Indian River County
Settlement Agreement, OGC No. 22-0150
Page 11
constitutes a person's waiver of the right to request an administrative hearing and to
participate as a party to this proceeding under sections 120.569 and 120.57, Florida
Statutes. Before the deadline for filing a petition, a person whose substantial interests
are affected by this Settlement Agreement may choose to pursue mediation as an
alternative remedy under section 120.573, Florida Statutes. Choosing mediation will
not adversely affect such person's right to request an administrative hearing if
mediation does not result in a settlement. Additional information about mediation is
provided in section 120.573, Florida Statutes and Rule 62-110.106(12), Florida
Administrative Code.
24. Rules referenced in this Agreement are available at
https://floridadep. og v/ogc/ogc/content/rules.
DEP vs. Indian River County
Settlement Agreement, OGC No. 22-0150
Page 12
APPROVED A^ TO FORM
AND.LEGAL SUFFICIEWC1Y
37
CHRIS O HER A. HICKS
ASSISTA C UNTY ATTORNEY
FOR THE RESPONDENT:
Pr' t ame JosepL E. Flescher
Chairman
Print Title
October 21, 2025
Date
FOR DEPARTMENT USE ONLY
DONE AND ORDERED this _ day of . 2025, in Palm Beach, Florida.
STATE OF FLORIDA DEPARTMENT
OF ENVIRONMENTAL PROTECTION
Sirena Davila
Director, Southeast District
Filed, on this date, pursuant to section 120.52, F.S., with the designated Department
Clerk, receipt of which is hereby acknowledged.
Clerk
Copies furnished to:
Lea Crandall, Agency Clerk
Mail Station 35
Date
Lea.Crandall@dep.state.fl.us
DEP vs. Indian River County
Settlement Agreement, OGC No. 22-0150
Page 13
Exhibit A
In -Kind Projects
In -Kind Projects
Proposal
A. Within 60 days of the effective date of this Settlement Agreement, Respondent
shall submit, by certified mail, a detailed in-kind project proposal to the Department for
evaluation. The proposal shall include a summary of benefits, proposed schedule for
implementation and documentation of the estimated costs which are expected to be
incurred to complete the project. These costs shall not include those incurred in
developing the proposal or obtaining approval from the Department for the in-kind
project.
Proposal Certification Form
B. The proposal shall also include a Certification by notarized affidavit from a
senior management official for Miami -Dade County who shall testify as follows:
My name is (print or type name of senior management official)
and do hereby testify under penalty of law that:
1. I am a person with management responsibilities for Indian River County
budget and finances. During the eighteen -month period prior to the effective
date of Settlement Agreement OGC Case No.: 22-0150 there has not been any
transfer or use of funds obtained by Indian River County from the collection of
sewer rates for any purpose not related to the management, operation, or
maintenance of the Sewer System or to any capital improvement needs of the
Sewer System.
2. I am aware that there are significant penalties for submitting false
information, including the possibility of fine and imprisonment for knowingly
submitting false information in this certification.
Sworn to and subscribed before me, by means of ❑ physical presence or ❑
online notarization, this day of , 20_ by
Personally, known or by Production of the following Identification
DEP vs. Indian River County
Settlement Agreement, OGC No. 22-0150
Page 14
Notary Public, State of Florida
Printed/typed or stamped name:
My Commission Expires:
Commission/Serial No.:
Annual Certification Form
My name is
and do
(print or type name of senior management official)
hereby testify under penalty of law that:
1. I am a person with management responsibilities for Indian River County
budget and finances. During the twelve-month period immediately preceding
the notary date on this Certification, there has not been any transfer or use of
funds obtained by Indian River County from the collection of sewer rates for any
purpose not related to the management, operation, or maintenance of the Sewer
System or to any capital improvement needs of the Sewer System.
2. I am aware that there are significant penalties for submitting false
information, including the possibility of fine and imprisonment for knowingly
submitting false information in this certification.
Sworn to and subscribed before me, by means of ❑ physical presence or ❑
online notarization, this day of , 20_ by
Personally, known or by Production of the following Identification
Notary Public, State of Florida
Printed/typed or stamped name:
My Commission Expires:
Commission/Serial No.:
C. If the Department requests additional information or clarification due to a
partially incomplete in-kind project proposal or requests modifications due to
deficiencies with Department guidelines, Respondent shall submit, by certified mail, all
requested additional information, clarification, and modifications within 15 days of
receipts of written notice.
D. If upon review of the in-kind project proposal, the Department determines that
the project cannot be accepted due to a substantially incomplete proposal or due to
substantial deficiencies with minimum Department guidelines; Respondent shall be
DEP vs. Indian River County
Settlement Agreement, OGC No. 22-0150
Page 15
notified, in writing, of the reason(s) which prevent the acceptance of the proposal.
Respondent shall correct and redress all the matters at issue and submit, by certified
mail, a new proposal within 30 days of receipt of written notice. In the event that the
revised proposal is not approved by the Department, Respondent shall make cash
payment of the civil penalties within 30 days of Department notice.
E. Within 120 days of the effective date of this Settlement Agreement, Respondent
shall obtain approval for an in-kind project from the Department. If an in-kind project
proposal is not approved by the Department within 120 days of the effective date of this
Settlement Agreement, then Respondent shall make cash payment of the civil penalties
within 30 days of Department notice.
F. Within 180 days of obtaining Department approval for the in-kind proposal or in
accordance with the approved schedule submitted pursuant to paragraph A of this
attachment, Respondent shall complete the entire in-kind project.
G. During the implementation of the in-kind project, Respondent shall place
appropriate sign(s) at the project site indicating that Respondent's involvement with the
project is the result of a Department enforcement action. Respondent may remove the
sign(s) after the project has been completed. However, after the project has been
completed Respondent shall not post any sign(s) at the site indicating that the reason
for the project was anything other than a Department enforcement action.
H. In the event Respondent fails to timely submit any requested information to the
Department, fails to complete implementation of the in-kind project or otherwise fails to
comply with any provision of this paragraph, the in-kind penalty project option shall be
forfeited, and the entire amount of civil penalties shall be due from the Respondent to
the Department within 30 days of Department notice. If the in-kind penalty project is
terminated and Respondent timely remits the $29,995.00 penalty, no additional
penalties shall be assessed for failure to complete the requirement of this paragraph.
I. Within 15 days of completing the in-kind project, Respondent shall notify the
Department, by certified mail, of the project completion and request a verification letter
from the Department. Respondent shall submit supporting information verifying that
the project was completed in accordance with the approved proposal and
documentation showing the actual costs incurred to complete the project. These costs
DEP vs. Indian River County
Settlement Agreement, CGC No. 22-0150
Page 16
shall not include those incurred in developing the proposal or obtaining approval from
the Department for the project.
J. If upon review of the notification of completion, the Department determines that
the project cannot be accepted due to a substantially incomplete notification of
completion or due to substantial deviations from the approved in-kind project;
Respondent shall be notified, in writing, of the reason(s) which prevent the acceptance
of the project. Respondent shall correct and redress all the matters at issue and submit,
by certified mail, a new notification of completion within 15 days of receipt of the
Department's notice. If upon review of the new submittal, the Department determines
that the in-kind project is still incomplete or not in accordance with the approved
proposal, the in-kind penalty project option shall be forfeited, and the entire amount of
civil penalty shall be due from the Respondent to the Department within 30 days of
Department notice. If the in-kind penalty project is terminated and Respondent timely
remits the $29,995.00, no additional penalties shall be assessed for failure to complete
the requirements of this paragraph.
DEP vs. Indian River County
Settlement Agreement, OGC No. 22-0150
Page 17
Exhibit B
P2 Project Summary (Summary)
(Facility)
(Address)
(Telephone)
(Preparer Name/Title)
A. Project Description: (Summarize P2 Projects selected. Describe the processes or
operations to be modified, and the specific changes to be made. Include details such as
the specific equipment to be installed, materials to be substituted, and the actual
changes to be made to processes or operations. Include manufacturer or vendor
information, and specifications.)
B. Environmental and Economic Benefits: (Explain why and how each Project
proposed constitutes P2.
Specify how each material, chemical, water and energy is saved, and from which
processes or operations. Specify how each solid and hazardous waste, industrial
wastewater and air emissions is generated, the waste type, and from which processes or
operations. Describe generally in paragraph format.
Estimate the annual savings in resources - raw materials, chemicals, water, and energy at
the process or operation front end. Estimate the annual reductions in wastes - solid and
hazardous waste, wastewater, and air emission reductions at the process or operation
back end.
Figures quoted should represent weights or volumes annually, and should be equalized
for production rate changes. Associated cost savings should be included. Describe
specifically using the tables provided.
Complete the first table for each Project individually. Add or average corresponding
figures from each Project table to complete the Summary table, for multiple Projects.)
DEP vs. Indian River County
Settlement Agreement, OGC No. 22-0150
Page 18
(Project Name)
Annual Resource Consumption Comparison
Item
Quantity Used al/ lb/
kwh-s ecif
Purchasing Cost $
Percent
M
Reduction
Before
After
Reduction
Before
After
Reduction
Water
Chemicals
Materials
Energy
Total Annual Cost Savings =
Annual Waste Generation Com arison
Item
Quantity Generated (gal/ lb/ tons-
specify)
Disposal Cost ($)
Percent
(%)
Reduction
Before
After
Reduction
Before
After
Reduction
Hazardous Waste
Industrial Wastewater
Industrial Wastewater
Solid Waste
Solid Waste
Air Emissions
Total Annual Cost Savings =
Total Annual Avoided Cost Savings =
Summary of All P2 Projects
Annual Resource Consumption Comparison
Item
Quantity Used al/lb/kwh-s
ec'
Purchasing Cost $
Percent
M
Reduction
Before
After
Reduction
Before
After
Reduction
Water
Chemicals
Materials
Energy
Total Annual Cost Savings =
Annual Waste Generation Com arison
Item
Quantity Generated (gal/lb/tons-
specify) Disposal Cost ($)
Percent
(%)
Reduction
Before
After
Reduction Before
I After
Reduction
Hazardous Waste
Industrial Wastewater
Solid Waste
DEP vs. Indian River County
Settlement Agreement, OGC No. 22-0150
Page 19
Air Emissions
Total Annual Cost Savings =
Total Annual Avoided Cost Savings =
C. Project Cost: (Include per Project the itemized, subtotal and Project total costs. A
projected payback period in months or years needs to be included.
Provide a grand total cost for all Projects and an averaged projected payback period, for
multiple Projects. Use list or table format for all.)
D. Project Reporting:
1. Within 30 days of completing the P2 Project, the Respondent shall submit
to the Department a P2 Project Final Report that includes the following:
a. A confirmation that the information presented in Sections A -C of
the Summary is unchanged, or an updated version with the sections changed
appropriately. A statement that the Project(s) was/were implemented successfully. An
explanation of any problems encountered and corrections applied. A statement
indicating the date the Project was started and also the date completed.
b. Attached expense reports, receipts, purchasing instruments and
other documents itemizing costs expended on preparing and implementing the Project.
2. The Department shall review the Final Report and determine:
a. Whether the project was properly implemented; and
b. Which expenses apply toward pollution prevention credits.
3. A $1.00 pollution prevention credit for each $1.00 spent on applicable
costs will be applied against the portion of the civil penalty that can be offset.
a. The following costs are applicable as P2 credits toward the civil
penalty offset amount:
i. Preparation of the P2 Project;
ii. Design of the P2 Project;
iii. Installation of equipment for the P2 Project;
iv. Construction of the P2 Project;
v. Testing of the P2 Project;
vi. Training of staff concerning the implementation of the P2
Project; and
vii. Capital equipment needed for the P2 Project.
b. The following costs shall not apply as P2 credits toward the civil
penalty offset amount:
P2 Project;
i. Costs incurred in conducting a waste audit;
ii. Maintenance and operation costs involved in implementing the
iii. Monitoring and reporting costs;
DEP vs. Indian River County
Settlement Agreement, OGC No. 22-0150
Page 20
iv. Salaries of employees who perform their job duties;
v. Costs expended to bring the facility into compliance with current
law, rules and regulations;
vi. Costs associated with a P2 Project that is not implemented;
vii. Costs associated with a P2 Project that has not been approved
by the Department; and
viii. Legal costs.
C. If any balance remains after the entire P2 credit is applied to the
allowable portion of the civil penalty, Respondent shall pay the difference within 30
days of written notification by the Department to the Respondent that the balance is
due.
E. Project Termination:
1. The Department may terminate the P2 Project at any time during the
development or implementation of it, if the Respondent fails to comply with the
requirements in this document, act in good faith in preparing and implementing the
project, or develop and implement the P2 Project in a timely manner. The Respondent
may terminate the P2 Project at any time during its development or implementation.
2. If the P2 Project is terminated for any reason, Respondent shall pay the full
balance of the allowable portion of the civil penalty within 30 days of written demand
by the Department.