HomeMy WebLinkAbout13-026 Pursue Filtration to Address State of Washington Department of Health Water System Treatment Requirements Resolution 13-026
Surface Water Treatment Compliance
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RESOLUTION NO. 13-026
A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF PORT TOWNSEND,
WASHINGTON TO PURSUE FILTRATION TO ADDRESS STATE OF WASHINGTON
DEPARTMENT OF HEALTH (WSDOH) WATER SYSTEM TREATMENT
REQUIREMENTS FOR SURFACE WATER TREATMENT RULE COMPLIANCE
A. The Resolution provides City Council's decision to pursue filtration to address State of
Washington Department of Health(WSDOH) water system treatment requirements for
Surface Water Treatment Rule Compliance. The City Manager is directed to notify
WSDOH of the City's decision. The City Manager is also directed to: (1) Develop and
work with WSDOH to develop an action plan in connection with creating a`Bilateral
Compliance Agreement" (BCA); (2) Work with the City's consulting engineering firm
HDR to develop filtration alternative proposals and bring those proposals to City Council
for review and approval, and perform other follow-up actions directed by WSDOH in its
August 23, 2013 letter; and (3) Investigate additional funding from other sources to lower
the impact on customers from the increased treatment costs necessitated by having to
install filtration.
B. On July 15, 2013, following years of review of various options to address water system
treatment requirements, the Council authorized awarding the bid and contract with
Xylem-WEDECO Products for purchase of ultra violet (UV) equipment for the Water
Treatment Facility. That contract was on hold pending receipt of information from
WSDOH on additional watershed control requirements.
C. For the City to maintain its unfiltered status, it must demonstrate that it has adequate
control of the watershed. Since 1994,the City, in cooperation with the United States
Forest Service (USFS), has maintained control over the watershed. The WSDOH has
now changed its policy attention to question whether or not the current level of control is
adequate to remain unfiltered. The City Manager asked WSDOH to offer their opinion on
what the minimum level of control would be necessary to satisfy their new concerns with
watershed control.
D. On August 9, 2013, WSDOH reported its findings based on its inspection of the
watershed for the City's water system. The August 9 letter outlines what the minimum
requirements would be and what must be a part of a new watershed management plan to
allow for use of UV treatment and remain in a permitted unfiltered status.
E. Separately, as a follow-up to the annual inspection by WSDOH, WSDOH has now taken
to address their concerns with the City's actions and decision via a regulatory action.
WSDOH by letter dated August 23, 2013 letter provided formal notice to the City of a
pending regulatory action by WSDOH.
F. The WSDOH is finding that the City and United States Forest Service (USFS) do not
have currently adequate control over the watershed and therefore the City must do one of
two things: establish control of the watershed or provide filtration. They have ordered the
Resolution 13-026
Surface Water Treatment Compliance
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City to notify them no later than September 20, 2013 which option the City elects to
pursue. Based upon the City's action, they are ordering the City to enter into a"Bilateral
Compliance Agreement" (BCA).
G. WSDOH's August 23, 2013 letter stated: "This letter is not meant to be a reprimand.
You have always worked collaboratively with us and responded promptly to our requests,
and we value this partnership. This situation is mostly the result of the economic
downturn exposing a weakness in the City's watershed control program. The City relies
heavily on its partners to implement the CWPP but has no authority to make them
perform the duties described within. As budgets have declined and priorities have
shifted, many of the activities have not been performed and the City has limited resources
to fill in the gaps."
H. Staff has reviewed the watershed management expectations and the options of filtration
with WSDOH and the City's consulting engineers (HDR). The City Manager, the Public
Works Director and the consulting engineers all concur that the conditions and
expectations to maintain control of the watershed are not only expensive but
unachievable, and that filtration appears to be the only viable option for the City to
consider.
I. HDR has prepared a summation of filtration options and estimated costs. Staff concurs
with the recommendation that membrane filtration is the City's best alternative. Staff and
HDR have also addressed the timeline and ability to meet the objectives to develop the
site, construct a new reservoir, and comply with the Surface Water Treatment Rule.
J. The cost of filtration is estimated to add an additional $3 to $5 million dollars to the
LT2ESWTR project budget. The recent rate model approved by Council assumed that
UV would be $3 million more than what the engineer's 60% design cost estimate. Staff
had hoped that the possible cost savings with UV could have offered a rate reduction
from the scheduled increase in 2018. Forcing the decision to install filtration will not
allow this and may cause an additional increase. The recommended alternative will also
require pilot testing. This testing is not to see if it will work, but is designed to measure
performance to accurately size the system, hence the revised schedule to accelerate the
design and construction of the reservoir.
K. Staff is also recommending Council direct staff to look for additional funding from other
sources to lower the impact on customers. Under a BCA, the City would have additional
standing towards eligibility for preferred loans and grants. There is a Trust Fund loan of
$2.1 million in place for the reservoir. There is also a possibility that the City may to
seek a mitigation grant from the USFS in an amount equal to the expense currently
associated with watershed management.
L. The City Council reviewed this matter as a workshop meeting on September 9, 2013 and
a regular meeting on September 16, 2013. Following this review, and based on the
above, the Council accepts the recommendation of the City Manager and the Public
Works Director to adopt filtration to address water system treatment requirements
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Surface Water Treatment Compliance
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required by federal and state regulation.
NOW, THEREFORE, BE IT RESOLVED by the City Council of the City of Port
"Townsend as follows:
1. The City Council adopts filtration to address State of Washington Department of Health
(WSDOH) water system treatment requirements for Surface Water Treatment Rule
Compliance.
2. The City Manager is directed to:
a. Notify WSDOH of the City Council's decision.
b. Develop and work with WSDOH to develop an action plan in connection with
creating a`Bilateral Compliance Agreement" (BCA), and perform other follow-
up actions directed by WSDOH in its August 23, 2013 letter.
c. Work with the City's consulting engineering firm HDR to develop proposals to
filtration alternative proposals and bring those proposals to City Council for
review and approval.
d. Investigate additional funding from other sources to lower the impact on
customers from the increased treatment costs necessitated by having to install
filtration.
ADOPTED by the City Council of the City of Port Townsend at a regular meeting
thereof, held this 16`" day of September 2013.
r
David King, Mayor
Attest: Approved as to form:
1 rrt_
Pamela Kolacy, MMC John P. Watts
City Clerk City Attorney