Valdosta has sent GA-EPD a check for the $56,139.30 fine and the information required by the other four conditions of the September 15, 2023, Consent Order on Valdosta for the One Mile Branch fish kill and various sewage spills.
Maybe these Standard Operating Procedures (SOPs) will help further reduce Valdosta sewage into creeks and the Alapaha, Alapahoochee, and Withlacoochee Rivers.
Here is the City of Valdosta’s summary of its responses to the conditions in the Consent Order. I haved added links to the referenced documents.
City of Valdosta Consent Order EPD-WP-9424.
Condition 1. The Utilities Department sent a check to EPD ON 10/16/23.
Condition 2. The Environmental Department has updated the industrial inspection program we have also purchase more samplers so we can distribute them to be able to monitor the industrial users to pinpoint the ammonia and where it is coming from. We have submitted a plan to EPD which is attached for your review.
Condition 3. The City of Valdosta Industrial Pretreatment Program Enforcement Response Plan outlines the procedures that will be used to identify, document, track, and respond to noncompliance. The Enforcement Response Plan also provides guidance for selecting the enforcement action most appropriate for a given violation. We have submitted a SOP for compliance and enforcement procedure which is attached for your review.
Condition 4. We have a SOP in place which includes procedures for Utilities Department personnel to follow in the inspection/monitoring of a Contractor’s Temporary Bypass Pumping System for diverting sanitary sewage flow around any construction/repair activity. The SOP is attached for your review. We have also submitted the standard specifications for Water and Sewer Construction for bypass pumping for you review.
Condition 5. We have Operation and Maintenance Manuals and SOP’S for each plant Withlacoochee (SOP-Withlacoochee-WPCP.pdf, Withlacoochee-ERP.pdf) and Mud Creek (SOP-Mud-Creek-WPCP-2.pdf, Mud-Creek-ERP.pdf) both are attached for your review.
All these documents are on the WWALS website.
GA-EPD sent these documents at 8:09 AM this morning, in response to a Georgia Open Records Act (GORA) request I sent Friday, which was a holiday. So GA-EPD responded within 9 minutes.
The document most interesting to me is STANDARD OPERATING PROCEDURE (SOP): INSPECTION/MONITORING OF CONTRACTOR’S TEMPORARY SEWER BYPASS PUMPING SYSTEM, Issue Date: 9/26/23 Revision: 0 Review Frequency: Annual.
Why? Because for years Valdosta has blamed many things on its contractors. Yet who hired them? Who is supposed to oversee them?
This new SOP, dated less than two weeks after the new Consent Order, may finally establish some city oversight of contractors. For example,
3.4 Central Maintenance Lift Station Operators
The Lift Station operator is responsible for the operation (inspection/monitoring) of all the City’s wastewater lift stations. These individuals are responsible for performing the following procedures in this SOP. This individual has State of Georgia Wastewater Collection System certification.
This SOP details, “A. Lift Station Operator shall perform inspections of the temporary bypass pumping system and operation twice daily Monday through Friday and once daily on weekends/holidays. Inspections shall include at a minimum:….”
“B. Inspections shall be documented in the operation log at the time that the inspection(s) are performed.”
If this SOP had been in place in December 2019, that 4-day million-gallon sewage spill that led to the 2020 Consent Order might not have happened.
It is worrying that the Bypass Pumping Standard Spec. repeatedly insists on Contractor being responsible for many things. But maybe that is to set up the final section, about indemnifying and holding harmless the Owner, i.e., the City of Valdosta:
8. CONTRACTOR’S RESPONSIBILITIES REGARDING SANITARY SEWER OVERFLOWS
The Contractor shall be responsible for and shall indemnify and hold the Owner harmless for any sanitary sewer overflow occurring as the result of the work performed. The Contractor is responsible for any sewer discharge to the surface due to failure in bypass hose, piping or other equipment. Any discharge from air release valves shall be contained. The Contractor shall ensure that raw sewage will not spill on the ground or into any bodies of water, channels, or conduits of conveyance of storm water during the performance of this work. Prior to removal of the bypass pumping pipe, the Contractor shall empty all sewage into the sewer system.
The Contractor is responsible for and shall indemnify and hold the Owner harmless for any sanitary sewer discharge to the environment due to a failure in the equipment and/or bypassing operation.
In the event of a sanitary sewer overflow, the Contractor shall contact the Owner‘s representative immediately. If there is a sanitary sewer discharge to the environment due to a failure in the equipment and/or bypassing opera�on, the Contractor shall reimburse the Owner all costs related in any way to compliance with laws, regulatory requirements, and/or court orders and decrees associated with the overflow or discharge event. The costs include but not limited to water quality monitoring, signage, cleanup, fines, legal fees, claims and reporting. In the event that the peak flows during the bypass pumping opera�on exceed the projected peak flow figures previously provided by the Owner and a sanitary sewer overflow event occurs when the Contractor‘s equipment is operating correctly, the Contractor will not be held liable for the sanitary sewer overflow or discharge.
-jsq, John S. Quarterman, Suwannee RIVERKEEPER®