Beaumont City Council Must Submit Honest, Accurate Reports. Submitting Fraudulent, Incomplete, Inaccurate Documents is a Crime.
CALIFORNIA WATER CODE SECTION 13267 ORDER: DIRECTIVE FOR INVESTIGATION FOR ADDRESSING BEAUMONT WASTEWATER TREATMENT PLANT CAPACITY
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The City provided no response to the November 20, 2015 letter.
On April 19, 2016, Regional Board staff issued a Notice of Violation (NOV) to the City for violating Standard Provision VI .A.15 of the Discharge Permit for failure to report within 90 days after the average daily dry weather flow into the plant beginning in March 2014 exceeded 75% of the Facility’s design capacity. The NOV requested the City respond by May 19, 2016.
On May 3, 2016, the City submitted its response to the NOV. As noted in the City’s response, Facility capacity has exceeded 75% since March 2014, yet no explanation was provided as to why the City failed to file the required 75% capacity report for more than two years. Currently, the Facility is averaging approximately 3.1 MGD which exceeds 75% of design capacity. The City reported in the May 3, 2016 response to the NOV that based on a worst-case scenario that took into consideration actual growth for 2014, the City will add no more than 500 dwelling units per year resulting in the current treatment plant capacity of 4 MGD being reached by 2024. This projection does not account for planned connections from commercial and industrial facilities.
Notwithstanding the City’s flow projections, Regional Board staff notes that Facility average dry weather flows increased by 0.3 MGD from February to March in 2014 and Board staff are concerned that a similar increase could cause an exceedance of the Facility’s capacity.
In addition, information on the City’s website under “Major Project Status as of February 16, 2016” indicates that as many as 11,304 dwelling units are under development and as many as 2,978 additional dwelling units are being proposed. According to the documents on the City’s website, “City of Beaumont Commercial and Industrial Landowner List,” there are approximately 1,300 acres of commercial and industrial development proposed. Taking into consideration these two website documents and estimating approximately 250 gallons per day per dwelling unit, the flows into the Facility could increase by as much as 3.6 MGD if all of the proposed developments are built and connected.
Therefore, pursuant to section 13267 of the Water Code, it is hereby ordered that the City perform and submit the following:
1) Conduct an inflow and infiltration study during the next wet season and identify appropriate actions based on the results. The results of this study and expected actions with a schedule for completion of the proposed actions shall be submitted to the Regional Board no later than May 30, 2017.
2) By October 17, 2016, provide an accurate estimate of potential dwelling units and equivalent dwelling units that will be added to the collection system for all planned development including residential, commercial and industrial development to include all development within the city as well as any development outside of the City. The City shall provide a schedule or tentative schedule for completion of each project that has the potential to increase treatment plant flows along with the projected discharge volume. The City shall also provide the associated development schedule for each project.
3) Provide a complete list of existing and proposed commercial and industrial facilities along with their respective SIC codes and respective wastewater flow to the Facility every 6 months by December 15th and June 15th beginning December 15, 2016. Each semi-annual report shall identify commercial and industrial daily wastewater flow and report those industrial and commercial facilities that exceed 5% of the average dry weather hydraulic or organic capacity of the facility. In addition, the report shall identify any existing or proposed categorical industrial users that contribute to the City’s Facility (https://www.epa.gov/eg/industrialeffluent-guidelines).
4) By December 31, 2016, submit a report, subject to the Executive Officer’s approval, identifying the City’s plan for preventing exceedance of the plant capacity. In that report, the City shall identify the unit operations that limit the Facility’s current design capacity as well as a contingency plan to address exceeding capacity should flows into the Facility approach design capacity.
5) By December 31, 2016, develop and submit a feasibility study that addresses the following two options for plant expansion: Option 1 – plant expansion to include advanced wastewater treatment and brine disposal; and Option 2 – the construction of new conveyance facilities to the Yucaipa Valley Water District wastewater treatment plant.
6) By May 31, 2017, complete a preliminary design for either option 1 or option 2 and submit that design to the Regional Board.
7) By December 31, 2017, provide a financing plan for the final plant expansion or regionalization, whichever is chosen. The City shall demonstrate that it has secured appropriate funding to complete either option 1 or option 2 no later than July 1, 2018.
8) By December 31, 2017, develop and submit to the Regional Board the final plant expansion project design, or the proposal for regionalization and an analysis of the effect of the City’s flows on Yucaipa Valley Water District, depending on which alternative is selected.
9) Provide a semi-annual report and supporting information to validate that the City’s average dry weather flows will not be exceeded prior to the completion of either option 1 or option 2 of the selected plant capacity expansion plan. These semi-annual reports shall be submitted by December 15th and June 15th of each year beginning in December 2016.
10) On a monthly basis and commencing on September 15th, 2016, provide 12 months of influent continuous pH and electrical conductivity (EC) readings as well as a certification that both the pH and the EC meter have been functioning and calibrated in accordance with SWA 846 Standard Methods. The pH and EC readings shall be reported in electronic format, preferably Microsoft Excel.
Failure to submit the required reports, plans and schedule to the Regional Board by the designated due dates may subject the City to administrative civil liability in the amount of up to $1,000 per day pursuant to Section 13268 (a) and (b) of the Water Code.
Section 13267 of the Water Code requires that reports be submitted under penalty of perjury. Every report must include a statement, ” I, [NAME}, certify under penalty of law that this document and all attachments were prepared by me, or under my direction or supervision, in accordance with a system designed to assure that qualified personnel properly gathered and evaluated the information submitted. Based on my inquiry of the person or persons who manage the system, or those persons directly responsible for gathering the information, the information submitted is, to the best of my knowledge and belief, true, accurate, and complete. I am aware that there are significant penalties for submitting false information, including the possibility of fine and/or imprisonment for knowing violations.”