CONSENT ORDER - OGC FILE NO 10-2683r.
BEFORE THE STATE OF FLORIDA
DEPARTMENT OF ENVIRONMENTAL PROTECTION
STATE OF FLORIDA DEPARTMENT )
OF ENVIRONMENTAL PROTECTION )
VS. )
CITY OF CLEARWATER )
IN THE OFFICE OF THE
SOUTHWEST DISTRICT
OGC FILE NO. 1.0-2683
CONSENT ORDER
This Consent Order is entered into between the State of Florida Department of Environ-
mental Protection ("Department") and City of Clearwater ("Respondent") to reach settlement of
certain matters at issue between the Department and Respondent.
The Department finds and Respondent admits the following:
The Department is the administrative agency of the State of Florida having the
power and duty to protect Florida's air and water resources and to administer and enforce the
provisions of Chapter.403, Florida Statutes ("F.S."), and the rules promulgated and authorized in
Title 62, Florida Administrative Code ("F.A.C."). The Department has jurisdiction over the mat-
ters addressed in this Consent Order.
2. Respondent is a person within the meaning of Section 403.031(5), F.S.
3. Respondent is the owner and is responsible for the operation of the Clearwater
Marshall Street Advanced Wastewater Treatment Facility, a 10.00 MGD wastewater treatment
facility with reclaimed water sent to the Clearwater Master Reuse System ("R001") and dechlo-
rinated effluent discharged to Stevenson Creek, thence to Clearwater Harbor ("D001"), collec-
tively known as "Facility." The Facility is located at 1605 Harbor Drive, Clearwater, Pinellas
County, Florida, 33755-1824. Respondent operates the Facility under Department Permit No.
FL0021857, which will expire October 12, 201.1. ("Permit"). The Permit constitutes authoriza-
tion to discharge to waters of the State under the National Pollution Discharge Elimination Sys-
tem.
4. Stevenson Creek, a tributary to Clearwater Harbor, is classified as a Class III ma-
rine water of the State, pursuant to Rule 62-302.400(10), F.A.C. Clearwater Harbor is classified
as a Class III marine water body, an Outstanding Florida Water, and an Aquatic Preserve, as es-
DEP vs. City of Clearwater
Consent Order OGC File No. 10-2683
Page 2 of 12
tablished by Chapter 72-663, Laws of Florida, and Rules 62-302.700(9)(b)25 and 62-
302.700(9)(h)32, . h'.A.C. Discharges of domestic wastewater to Stevenson Creek, and subse-
quently Clearwater Harbor, are governed by Section 403.086, F.S.
5. The Department finds that, from a review of the Discharge Monitoring Reports
("DMRs") submitted by Respondent for the Facility for the period of September 2009 through
May 2010, the following violations occurred:
a) The dibromo-chloromethane annual average limit of 46.0 gg/L was exceeded
each month from September 2009 through May 2010. Subsequently, the annual average
limit was also exceeded in June and July 2010.
b) The dichloro-bromomethane annual average limit of 24.0 gg/L was exceeded in
May 2010. Subsequently, the annual average limit was also exceeded in June and July
2010.
6. The Department's findings in paragraph 5 constitute violations of Chapter 403,
F.S., and Rules 62-302.530(35)(b)2. and 62-302.530(35)(b)5., F.A.C.
Having reached a resolution of the matter, Respondent and the Department mutually
agree and it is ORDERED:
7. By December 31, 2013, and thereafter, Respondent shall operate in compliance
with the Permit limit for dibromo-chloromethane, by reducing the sources of dibromo-
chloromethane, by treating to reduce dibromo-chloromethane so that the Facility's effluent com-
plies with the Permit limit for dibromo-chloromethane. Respondent shall take whatever correc-
tive actions are necessary to meet the limit for dibromo-chloromethane in the Facility's effluent.
However, if a permit revision or additional Department permit is required for the corrective ac-
tions, Respondent must obtain the permit revision or Department permit prior to placing the
modifications into operation. Respondent shall submit the appropriate information, applications,.
pertinent data, and responses to Department requests for additional information and comply with
the Permit limit for dibromo-chloromethane by December 31, 2013.
8. Beginning the first full month after the effective date of this.Consent Order and
lasting through December 31, 2013, the interim limit for dibromo-chloromethane for effluent
discharged to surface waters from the Facility shall be 60.0 µg/L as an annual average. The Inte-
rim Discharge Monitoring Report, incorporated herein as Attachment I, shall be used for report-
DEP vs. City of Clearwater
Consent Order OGC File No. 10-2683
Page 3 of 12
ing the interim limit value. This interim limit does not act as a State of Florida Department of
Environmental Protection wastewater permit effluent limitation or modified permit limitation,
nor does it authorize or otherwise justify a violation of the Florida Air and Water Pollution Con-
trol Act, Part 1, Chapter 403, F.S., during the pendency of this Consent Order. In accordance
with the.Permit, the Interim DMR shall be mailed or hand delivered to the Department of Envi-
ronmental Protection once each month and must be received by the Department no later than the
28th day following the end of the reporting period (e.g., the August report would be due not later
than September 28th). In addition to submitting the DMRs to the Department in accordance with
the Permit, during the pendency of this Consent Order, Respondent shall submit copies of the
DMRs to the Southwest District of the Department, pursuant to paragraph 16 of this Consent Or-
der.
9. By December 31 2013, and thereafter, Respondent shall operate in compliance
with the Permit limit by reducing the sources of dichloro-bromomethane, by treating to reduce
dichloro-bromomethane so that the Facility's effluent complies with the Permit limit for dichlo-
ro-bromomethane. Respondent shall take whatever corrective actions are necessary to meet the
limit for dichloro-bromomethane in the Facility's effluent. However, if a Permit revision or ad-
ditional Department permit is required for the corrective actions, Respondent must obtain the
Permit revision or Department permit prior to placing the modifications into operation. Respon-
dent must govern its actions through submittal of appropriate information, applications, pertinent
data, and responses to Department requests for additional information to comply with the Permit
limit for dichloro-bromomethane by December 31, 2013, and thereafter.
10. Upon the first month after the effective date of this Consent Order and lasting
through December 31, 2013, the interim limit for.dichloro-bromomethane for effluent discharged
to surface waters from the Facility shall be 35.0 gg/I, as an annual average. The Interim Dis-
charge Monitoring Report, incorporated herein as Attachment I, shall be used for reporting the
interim limit value. This interim limit does not act as a State of Florida Department of Environ-
mental Protection wastewater Permit effluent limitation or modified Permit limitation, nor does it
authorize or otherwise justify a violation of the Florida Air and Water Pollution Control Act, Part
1, Chapter 403, F.S., during the pendency of this Consent Order. The Interim DMR shall be
mailed or hand delivered to the Department of Environmental Protection once each month and
DEP vs. City of Clearwater
Consent Order OGC File No. 10-2683
Page 4 of 12
must be received by the Department no later than the 28th day following the end of the reporting
period (e.g., the August report would be due not later than September 28th). In addition to sub-
mitting the DMRs to the Department in accordance with the Permit, during the pendency of this
Consent Order, Respondent shall submit copies of the DMRs to the Southwest District of the
Department, pursuant to paragraph 16 of this Consent Order.
11. On or before June 15 and December 15 of each year during the pendency of this
Consent Order and continuing until all corrective actions have been completed, Respondent shall
submit to the Department a written report containing information about the status and progress of
projects being completed under this Consent Order, information about compliance or noncom-
pliance with the applicable requirements of this Consent Order, including construction require-
ments and effluent limitations, and any reasons for noncompliance. These reports shall also in-
clude a projection of the work Respondent will perform pursuant to this Consent Order during
the 12-month period which will follow the report. Respondent shall submit the reports to the
Department pursuant to paragraph 16 of this Consent Order.
12. Notwithstanding the time periods described in the paragraphs above, Respondent
shall complete all corrective actions required by paragraphs 7, 9 and 11 by December 31, 2013
and be in full compliance with Chapter 62-302, F.A.C., regardless of any intervening events or
alternative time frames imposed in this Consent Order
13. Within 60 days of the effective date of this Consent Order, Respondent shall pay
the Department $42,940.00 in settlement of the regulatory matters addressed in this Consent Or-
der. This amount includes $41,940.00 for civil penalties and $1,000.00 for costs and expenses
incurred by the Department during the investigation of this matter and the preparation and track-
ing of this Consent Order. The civil penalties are apportioned as follows: $31,770.00 for viola-
tion of Rule 62-302.530(35)(b)2., F.A.C., and $10,170.00 for violation of Rule 62-
302.530(35)(b)5., F.A.C. For the purposes of settlement, the Department is not assessing civil
penalties for those violations that occurred from August 2010 through the date of filing of this
Consent Order.
14. In lieu of making full cash payment of the civil penalties set forth in paragraph 13,
Respondent may, with prior approval of the Department, implement one or more in-kind penalty
projects for $31,455.00 of the settlement amount. An in-kind penalty project must be an envi-
DEP vs. City of Clearwater
Consent Order OGC File No. 1.0-2683
Page 5 of 12
ronmental enhancement, environmental education, environmental restoration or a capital facility
improvement project. The Department may also consider the donation of environmentally sensi-
tive land. The total value of the in-kind penalty project shall be at least one and a half times the
amount of the civil penalty that is being used for an in-kind project, which in this case, is the
equivalent of at least $47,183.00. In the event Respondent elects this option, it must so notify
the Department in writing within 30 days of the effective date of this Consent Order. Additional-
ly, Respondent shall remit the $11,485.00 in penalties and Department costs not subject to offset
by an in-kind penalty project within 60 days of the effective date of this Consent Order. If Res-
pondent elects to implement an in-kind penalty project, Respondent shall comply with the fol-
lowing procedures and time frames:
a) Within 90 days of the effective date of this Consent Order, Respondent shall sub-
mit to the Department one or more proposals for consideration as in-kind projects. The
proposal shall include a summary of benefits, proposed schedule for implementation and
documentation of the expected costs to be incurred to complete the project. These costs
shall not include those costs incurred in developing the proposal or obtaining approval
from the Department. The project must be approved by the Department to qualify as an
in-kind project.
b) If the Department does not approve the in-kind project, Respondent may cor-
rect/redress the deficiencies or may submit an alternative project proposal within 30 days
of notification that the project is not approved. If the in-kind project is not approved
within 150 days of the effective date of this Consent Order, Respondent shall make pay-
ment of the remaining civil penalties as set forth in paragraph 13 of this Consent Order
within 30 days of written notice from the Department.
C) Respondent shall complete the in-kind project within 365 days of Department ap-
proval or in accordance with the approved schedule submitted pursuant to subparagraph
14(a).
d) On or before June 15 and December 15 of each year during the pendency of this
Consent Order and continuing until the in-kind project has been completed, Respondent
shall provide the Department with a status report documenting the progress being made
DEP vs. City of Clearwater
Consent Order OGC File No. 10-2683
Page 6 of 12
on the implementation of the project. Respondent shall submit the status reports to the
Department pursuant to paragraph 16 of this Consent Order.
e) Respondent shall place appropriate signs during the implementation of the project
indicating that Respondent's involvement with the project is the result of Department en-
forcement actions. Respondent may remove the signs after the project has been com-
pleted. However, after the project has been completed, Respondent shall not post any
signs at the site indicating that the reason for the project was anything other than a De-
partment enforcement action. If a specific project does not involve a physical site, then
other similar type of public notification shall be required.
f) Respondent shall forfeit the right to avail itself of the in-kind penalty option if
Respondent fails to timely submit any requested information or documentation, fails to
complete implementation of the in-kind project or otherwise fails to comply with any
provision of this paragraph. The unpaid balance of the remaining penalty, excluding the
prorated amount for any completed in-kind project, as set forth in paragraph 13 of this
Consent Order, shall be due from Respondent to the Department within 30 days of notice.
g) Respondent shall notify the Department within 30 days of completing the project
of the project's completion and request a verification letter from the Department. Res-
pondent shall submit supporting information verifying that the project was completed in
accordance with the approved proposal and documentation showing the actual costs in-
curred to complete the project. If upon review of the notification of completion the De-
partment determines that the project cannot be accepted due to incompleteness or sub-
stantial deviation from the approved project, Respondent shall be notified in writing of
the reasons that prevent acceptance of the projects. Respondent shall correct and redress
all matters in the Department's written notice and submit by certified mail a new notifica-
tion of completion within 15 days of receipt of the Department's notice. If upon review
of the new submittal the Department determines that any in-kind project is still incom-
plete or not in accordance with the approved proposal, the in-kind penalty payment op-
tion will be forfeited and the corresponding amount of civil penalties shall be due from
Respondent to the Department within 30 days of receipt of the Department's notice. If
the actual costs incurred in completing the project are less than the approved amount of
DEP vs. City of Clearwater
Consent Order OGC File No. 10-2683
Page 7 of 12
the in-kind project, Respondent shall remit cash payment of the prorated difference to the
Department within 30 days of the project completion. Otherwise, the Department shall
provide a letter to Respondent acknowledging completion of the project.
15. Respondent agrees to pay the Department stipulated penalties in the amount of
$250.00 per day for each and every day Respondent fails to timely comply with any of the re-
quirements of paragraphs 7, 9, 11 or 27 of this Consent Order. Respondent also agrees to pay the
Department stipulated penalties in the amount of $2,500.00 per month for each and every month
Respondent fails to meet the interim limit for dibromo-chloromethane or dichloro-
bromomethane. A separate stipulated penalty will be assessed for each violation of this Consent
Order. The Department may demand stipulated penalties at any time after violations occur.
Respondent shall pay stipulated penalties owed within 30 days of the Department's issuance of
written demand for payment, and shall do so as further described in paragraph 16, below. Noth-
ing in this paragraph shall prevent the Department from filing suit to specifically enforce any
terms of this Order. Any stipulated penalties assessed under this paragraph shall be in addition
to the civil penalties agreed to in paragraph 13 of this Order. Respondent shall make all pay-
ments required by this Order by city check, cashier's check, or money order. Payment instru-
ments shall be made payable to the "Department of Environmental Protection" and shall include
both the OGC number assigned to this Order and the notation "Ecosystem Management and Res-
toration Trust Fund.
16. Except as otherwise provided, all submittals and payments required by this Con-
sent Order shall be sent to Mr. Joseph Squitieri, Environmental Manager, Domestic Wastewater
Section, Department of Environmental Protection, Southwest District Office, 13051 North Tele-
com Parkway, Temple Terrace, Florida, 33637-0926.
17. Respondent shall allow all authorized representatives of the Department access to
the Facility and the Property at reasonable times for the purpose of determining compliance with
the terms of this Consent Order and the rules and statutes administered by the Department.
18. The Department, for and in consideration of the complete and timely performance
by Respondent of all the obligations agreed to in this Consent Order, hereby conditionally
waives its right to seek judicial imposition of damages or civil penalties for the violations de-
scribed above through the date of filing of this Consent Order for the effluent quality exceed-
DEP vs. City of Clearwater
Consent Order OGC File No. 10-2683
Page 8 of 12
antes addressed in this Consent Order or addressed in the Department letter, dated July 14, 201.0,
inspection reports, or DNMs generated through the date of filing of the Consent Order. This
waiver is conditioned upon Respondent's complete compliance with all of the terms of this Con-
sent Order. Notwithstanding, Respondent's failure to properly budget or appropriate funds will
not act to relieve or excuse Respondent for the non-performance of its obligations hereunder.
19. If any event, including administrative or judicial challenges by third parties unre-
lated to Respondent, occurs which causes delay or the reasonable likelihood of delay in comply-
ing with the requirements of this Consent Order, Respondent shall have the burden of proving
the delay was or will be caused by circumstances beyond the reasonable control of Respondent
and could not have been or cannot be overcome by Respondent's due diligence. Neither econom-
ic circumstances nor the failure of a contractor, subcontractor, materialman, or other agent (col-
lectively referred to as "contractor") to whom responsibility for performance is delegated to meet
contractually imposed deadlines shall be considered circumstances beyond the control of Res-
pondent (unless the cause of the contractor's late performance was also beyond the contractor's
control). Upon occurrence of an event causing delay, or upon becoming aware of a potential for
delay, Respondent shall notify the Department by the next working day and shall, within seven
calendar days notify the Department in writing of
a) the anticipated length and cause of the delay,
b) the measures taken or to be taken to prevent or minimize the delay, and
c) the timetable by which Respondent intends to implement these measures.
If the parties can agree that the delay or anticipated delay has been or will be caused by circums-
tances beyond the reasonable control of Respondent, the time for performance hereunder shall be
extended. The agreement to extend compliance must identify the provision or provisions ex-
tended, the new compliance date or dates, and the additional measures Respondent must take to
avoid or minimize the delay, if any. Failure of Respondent to comply with the notice require-
ments of this paragraph in a timely manner constitutes a waiver of Respondent's right to request
an extension of time for compliance for those circumstances.
20. This Consent Order is a settlement of the Department's civil and administrative
authority arising under Florida law to resolve the matters addressed herein. This Consent Order
is not a settlement of any criminal liabilities which may arise under Florida law, nor is it a set-
DEP vs. City of Clearwater
Consent Order OGC File No. 10-2683
Page 9of12
tlement of any violation which may be prosecuted criminally or civilly under federal law. Entry
of this Consent Order does not relieve Respondent of the need to comply with applicable federal,
state, or local laws, rules, or ordinances.
21. The Department hereby expressly reserves the right to initiate appropriate legal
action to address any violations of statutes or rules administered by the Department that are not
specifically resolved by this Consent Order.
22. Respondent is fully aware that a violation of the terms of this Consent Order may
subject Respondent to judicial imposition of damages, civil penalties up to $10,000.00 per day
per violation, and criminal penalties.
23. Respondent acknowledges and waives its right to an administrative hearing pur-
suant to Sections 120.569 and 120.57, F.S., on the terms of this Consent Order. Respondent also
acknowledges and waives its right to appeal the terms of this Consent Order pursuant to Section
120.68, F.S.
24. No modifications of the terms of this Consent Order will be effective until re-
duced to writing, executed by both Respondent and the Department, and filed with the clerk of
the Department.
25. The terms and conditions set forth in this Consent Order may be enforced in a
court of competent jurisdiction pursuant to Sections 120.69 and 403.121, F.S. Failure to comply
with the terms of this Consent Order constitutes a violation of Section 403.161(1)(b), F.S.
26. This Consent Order is a final order of the Department pursuant to Section
120.52(7), F.S., and it is final and effective on the date filed with the Clerk of the Department
unless a Petition for Administrative Hearing is filed in accordance with Chapter 120, F.S. Upon
the timely filing of a petition, this Consent Order will not be effective until further order of the
Department.
27. Respondent shall publish the following notice in a newspaper of daily circulation
in Pinellas County, Florida. The notice shall be published one time only within 15 days of the
effective date of the Consent Order. Respondent shall provide a certified copy of the published
notice to the Department within 10 days of publication.
DEP vs. City of Clearwater
Consent Order OGC File No. 10-2683
Page 10 of 12
STATE OF FLORIDA DEPARTMENT OF ENVIRONMENTAL PROTECTION
NOTICE OF CONSENT ORDER
The Department of Environmental Protection ("Department") gives notice of agency ac-
tion of entering into a Consent Order with the City of Clearwater pursuant to Section 1.20.57(4),
Florida Statutes. The Consent Order addresses exceedences of water quality standards in the ef-
fluent discharged to Stevenson Creek and Clearwater Harbor from the Clearwater Marshall
Street Advanced Wastewater Treatment Facility located at 1605 Harbor Drive, Clearwater, Pi-
nellas County, Florida, 33755. The Consent Order is available for public inspection during nor-
mal business hours, 8:00 a.m. to 5:00 p.m., Monday through Friday, except legal holidays, at the
Department of Environmental Protection, Southwest District Office, 13051 North Telecom
Parkway, Temple Terrace, Florida, 33637-0926.
Persons who are not parties to this Consent Order, but whose substantial interests are af-
fected by it, have a right to petition for an administrative hearing under sections 120.569 and
120.57, Florida Statutes. Because the administrative hearing process is designed to formulate
final agency action, the filing of a petition concerning this Consent Order means that the
Department's final action may be different from the position it has taken in the Consent Order.
The petition for administrative hearing must contain all of the following information:
a) The OGC Number assigned to this Consent Order;
b) The name, address, and telephone number of each petitioner; the name, address,
and telephone number of the petitioner's representative, if any, which shall be the address
for service purposes during the course of the proceeding;
C) An explanation of bow the petitioner's substantial interests will be affected by the
Consent Order;
d) A statement of when and how the petitioner received notice of the Consent Order;
e) Either a statement of all material facts disputed by the petitioner or a statement
that the petitioner does not dispute any material facts;
f) A statement of the specific facts the petitioner contends warrant reversal or
modification of the Consent Order;
g) A statement of the rules or statutes the petitioner contends require reversal or
modification of the Consent Order; and
h) A statement of the relief sought by the petitioner, stating precisely the action
petitioner wishes the Department to take with respect to the Consent Order.
The petition must be filed (received) at the Department's Office of General Counsel, 3900
Commonwealth Boulevard, MS# 35, Tallahassee, Florida 32399-3000 within 21. days of receipt
of this notice. A copy of the petition must also be mailed at the time of filing to the Southwest
District Office at 13051 North Telecom Parkway, Temple Terrace, Florida, 33637-0926. Failure
to file a petition within the 21-day period constitutes a person's waiver of the right to request an
administrative hearing and to participate as a party to this proceeding under sections 120.569 and
120.57, Florida Statutes. Before the deadline for filing a petition, a person whose substantial in-
terests are affected by this Consent Order may choose to pursue mediation as an alternative re-
medy under section 120.573, Florida Statutes. Choosing mediation will not adversely affect such
person's right to request an administrative hearing if mediation does not result in a settlement.
Additional information about mediation is provided in section 120.573, Florida Statutes and Rule
62-110.106(12), Florida Administrative Code.
DEP vs. City of Clearwater
Consent Order OGC File No. 10-2683
Page 11 of 12
28. Rules referenced in this Consent Order
ittt}?: lti?N ??Ae'p.state.II.us/Ic;L,al%ltule.5%rulelistnuiii.lltm.
are available at
FOR THE RESPONDENT:
V ?®
?4G
Frank V. ibb d
Mayor
City of Clearwater
DONE AND ORDERED this ?1 day of January, 2011, in Hillsborough County,
Florida.
STATE OF FLORIDA DEPARTMENT
ENVIRONMENTAL PROTECTION
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Southwest District r rO%r? ,?,M ni5 lra+in>l
Filed, on this date, pursuant to section 120.52, F.S., with the designated Department Clerk, re-
ceipt of wh,i:,h is'Areby acknowledged.
Lcx ft
Clerk Date
Countersigned: CITY OF CLEARWATER
. tc UWV By: A. _4?_ 'fit
tank Hibbard William B. Horne 11
City Manager
DEP vs. City of Clearwater
Consent Order OGC File No. 10-2683
Page 12 of 12
Approved as to form:
Leslie K. Dougall-S'd
Assistant City Attorn
Copies furnished to:
Lea Crandall, Agency Clerk, Mail Station 35
Attest: °F
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Rosemarie Call
City Clerk
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