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CONSIDERATION OF AUTHORIZATION FOR THE CHAIRMAN OF THE NORMAN UTILITIES AUTHORITY TO EXECUTE ADDENDUM A TO CONSENT ORDER NO. 13-077 FROM THE OKLAHOMA DEPARTMENT OF ENVIRONMENTAL QUALITY FOR THE NORMAN WATER RECLAMATION FACILITY NO. S-20616, PERMIT NO. OK0029190.
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BACKGROUND: The Oklahoma Pollutant Discharge Elimination System (OPDES) permit for the Water Reclamation Facility (WRF), issued July 1, 2010 by Oklahoma Department of Environmental Quality (DEQ), required construction of new disinfection facilities and to attain compliance with final discharge limits by July 1, 2013. On August 12, 2014, Norman Utilities Authority (NUA) and the DEQ approved Consent Order (CO) 13-077 (attached) which included the following revised task completion schedule:
• Submit a Supplemental Environmental Project (“SEP”) work plan, with expenditures of at least $80,000, including a schedule for implementation by November 30, 2014;
• Complete construction of disinfection facilities by January 1, 2016;
• Attain compliance with final limits for Fecal Coliform by July 1, 2016;
• Complete construction of all facilities by January 1, 2017;
• Attain compliance with final limits for Total Suspended Solids and Ammonia by July 1, 2017.
All the above tasks have been completed and the NUA has been in compliance with all discharge limits for many months. Additionally, the DEQ and NUA agreed that the Supplemental Environmental Project (“SEP”) would include construction of a non-potable reclaimed water line from the WRF to the Yard Waste Composting Facility located south of the WRF. However, the SEP has not yet been completed for the reasons detailed below.
Initially, the proposed SEP was to pump treated effluent disinfected by chlorine to the Composting Facility. However, the existing effluent reuse pumps proposed to be used were unable to supply the required quantity of effluent; additionally, their use required a new chlorine feed point.
The use of the existing University of Oklahoma (OU) effluent pumps, which already have a chlorine feed, were then evaluated; however, issues with pump controls as well as contractual issues will OU eliminated this option.
Completion of the WRF project allowed consideration of another means to provide disinfected effluent to the Compost Facility. The NUA proposed the construction of pumping facilities on the 66-inch outfall line directly east of the Compost Facility. This concept required DEQ approval of a variance to use UV disinfected effluent in lieu of chlorinated effluent. In a letter dated July 18, 2018, both the Water Quality Division and the Land Protection Division the DEQ conditionally approved the variance request.
As a result, the NUA forwarded the following revised SEP schedule to the DEQ on November 16, 2018.
1. NUA approval of design contract - 12/11/18 (completed 12/08/18)
2. Submit 90% plans to NUA - 04/01/19 (received 03/29/19)
3. Submit plans and specifications to DEQ - 05/01/19
4. Obtain DEQ approval plans and specifications - 08/01/19
5. NUA consideration of construction contract - 11/12/19
6. Begin construction of improvements - 12/01/19
7. Complete construction of improvements - 06/01/20
8. Submit documentation of completion to DEQ - 07/01/20
DISCUSSION: On March 5, 2019, the NUA received proposed Addendum A to Consent Order (CO) 13-077 which set forth a new schedule for Completion of the Supplemental Environmental Project. Addendum A references only the final task to complete construction and forward documentation to DEQ by July 1, 2020.
RECOMMENDATION: The NUA believes compliance with the proposed schedule is achievable and recommends authorizing the Chairperson to sign Addendum A to Consent Order 13-077