Update 2020-05-04: Press Release, Three weeks to comment on GA-EPD Valdosta wastewater Consent Order.

Update 2020-05-03: The entire GA-EPD Enforcement Order for Valdosta wastewater with fine 2020-04-13.

GA-EPD is fining Valdosta this time, for the first time ever. The persistent rumors from multiple sources were right about that.

Before anyone complains that the taxpayers will have to pay that fine, remember Valdosta has insurance, and so does the contractor that left the Remer Lane Pump Station offline back in December 2019, causing Valdosta’s biggest single spill since 2015.

Spill and Remer Lane Pump Station

And if the fine does get passed through to the taxpayers, maybe that will be incentive for the people of Valdosta to demand their city government stop spilling, by at least doing all the things this new Enforcement Order requires.

There is a comment period that opened Monday, April 27, 2020 through Wednesday, May 27, 2020. That’s right, Monday, and we only found out about it today, Friday Thursday. Thanks to GA-EPD for alerting us to this notice. The City of Valdosta doesn’t seem to have published anything about it.

If the actual Enforcement Order is online somewhere, can somebody please point me to it. Without that, I don’t know how anyone can comment coherently. I have filed an open records request with GA-EPD to get it.

Notice

This is apparently the Order that the U.S. EPA told us back on January 8, 2020, to expect “in weeks, not months.” Well, ten weeks or 2.5 months is better than never.

Let’s look at the “Requirements of Order“:

1. Pay penalty

   of $122,000.00. It’s more than nothing. And considering that in the last Valdosta City Council meeting of 2012 it was revealed that Valdosta had a budget surplus of more than $2 million, this fine should not a hardship for the city to pay, especially since it can probably get it from insurance.

2. Establish CMOM Program

   Apparently CMOM is Capacity Management, Operation, and Maintenance. Here is some guidance on what should be in a CMOM. Here’s an example CMOM agreement with Cobb County, GA. So Valdosta did not have a CMOM?

3. Revise SOPs for lift stations and spill reporting

   Earlier today I posted what appear to be Valdosta’s old Pump Station SOPs, dating back only to Version 1 of December 2019. We don’t yet know whether that Version 1 was before or after the big spill.

4. Include North Florida authorities in spill notification

   That’s good. But where’s the requirement to inform WWALS? And what is meant by “spill notification”? The early notification, or the press release a day later?

5. Post stream monitoring results

   Another rumor was that GA-EPD was requiring Valdosta to do that. Which would explain why Valdosta suddenly started posting water quality data a month or so ago, despite their story that they just decided to do so.

6. Submit schedule for construction of an additional EQ basin

   EQ is utility jargon for Equalization, and this EQ basin is the famous catch basin Valdosta is building at the entrance to its Withlacoochee Wastewater Treatment Plant (WWTP). The catch basin to hold 7.26 million gallons of wastewater, but we still don’t know whether that’s enough. Or, rather, how much rainfall will it take to overflow that catch basin?

   
   SITE and UTILITY PLAN

7. Establish weekly stream monitoring

   Well, I give Valdosta credit for monitoring three times a week, not just one. Let’s hope they continue doing that, and don’t use this Order as an excuse to drop back to only once weekly. Also, where does the Order require stream monitoring?

8. Complete pipe rehab projects

   Maybe in less than 100 years?

9. Complete SCADA installation

   That would be good. Maybe including checking the WWTP input to detect offline Pump Stations.

10. Create rehab schedule

    For what?

Enforcement Order EPD-WP-8904

See also on the GA-EPD website.

Facility	City of Valdosta
County	Lowndes County
Cause of Order	Spills & permit violations from April 4, 2014 to Dec 31, 2019
Requirements of Order	(1) Pay penalty (2) Establish CMOM Program (3) Revise SOPs for lift stations and spill reporting (6) Include North Florida authorities in spill notification (7) Post stream monitoring results (8) Submit schedule for construction of an additional EQ basin (9) Establish weekly stream monitoring (10) Complete pipe rehab projects (11) Complete SCADA installation (12) Create rehab schedule
Proposed Settlement Amount	$122,000.00
Legal Authority	Water Quality Control Act (including Surface Water Allocation)
Publication Date For Proposed Order	4/27/2020
Date Comment Period Closes	5/27/2020
Send Comments To	Mr. Lewis Hays Manager, Watershed Compliance Environmental Protection Division 2 Martin Luther King Jr. Drive SE, Suite 1152 East, Atlanta, GA 30334 Lewis.Hays@dnr.ga.gov 404-463-4953

 -jsq, John S. Quarterman, Suwannee RIVERKEEPER®

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