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Illicit Discharge & BypassEnforcement & Cost Recovery at
Portland Bottling Company
Brian LaurentPermit Manager
Bureau of Environmental Services
SEPTEMBER 2015
[email protected] 503.823.5655
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Environmental Services l Illicit Discharge & Bypass: Enforcement & Cost Recovery at Portland Bottling Company 2
Significant Figures: Proposed in 2014
Enforcement PenaltiesTotal: $142,300
Old Rules: 966 days x $100/day = $96,700
New Rules: 57 days x $800/day = $45,600
Cost RecoveryTotal: $307,616
Base Sewer: 21 MGals = $193,334
BOD Charges: 120 tons = $114,282
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Environmental Services l Illicit Discharge & Bypass: Enforcement & Cost Recovery at Portland Bottling Company 3
Significant Figures: Assessed in 2014
Enforcement PenaltiesTotal: $99,610
Penalties Assessed: $99,610
30% Reduction (VCA): $42,690
Cost RecoveryTotal: $190,624
Base Sewer Assessed: $190,624
BOD Charge Removed: $114,282
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Illicit Discharge & BypassEnforcement & Cost Recovery at
Portland Bottling Company
Brian LaurentPermit Manager
Bureau of Environmental Services
SEPTEMBER 2015
[email protected] 503.823.5655
Questions?
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Environmental Services l Illicit Discharge & Bypass: Enforcement & Cost Recovery at Portland Bottling Company 5
Portland Bottling Company @ NE Couch St.
NE Davis St
NE Couch St
NE 1
4th
AveN
E 1
2th
Ave
NE
13
thA
ve
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Environmental Services l Illicit Discharge & Bypass: Enforcement & Cost Recovery at Portland Bottling Company 6
Why Are They Permitted? PBC Facility Facts
Google Street Viewas of 2015
pH Neutralization Tanks
Process Start: 1924
Permitted: 1998
Closed: 2000
Out of Business: 4 Yrs
Re-Opened: 2004
Re-Permitted: 2005
Pollutants: pH, BOD
Flow: 10,000 gpd
pH Probe & Discharge Meter
Point of Compliance
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Environmental Services l Illicit Discharge & Bypass: Enforcement & Cost Recovery at Portland Bottling Company 7
• Sanitary connections along two sides:• NE Davis (plugged?)
• NE Couch (*permitted*)
• Pretreatment system for pH neutralization
• Six active water accounts: Primary acct on NE 14th Ave
• Sewer billing: Discharge meter at end point of treatment system
• BOD surcharge (sugar)
NE Davis St
NE Couch St
Why Permitted? Industrial Activity & Risk
NE 1
4th
Ave
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Environmental Services l Illicit Discharge & Bypass: Enforcement & Cost Recovery at Portland Bottling Company 8
PBC in 2013: pH Neutralization System
pH Probe
Discharge Meter
Pumps
Caustic
Acid
Paired Neutralization Tanks
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Environmental Services l Illicit Discharge & Bypass: Enforcement & Cost Recovery at Portland Bottling Company 9
PBC Plant: Dry Side of Pasteurizer
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Environmental Services l Illicit Discharge & Bypass: Enforcement & Cost Recovery at Portland Bottling Company 10
PBC: Pasteurizer Exit & “Broken” Chiller
Chiller Intended for Closed Loop Cooling
“Never Worked”
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Environmental Services l Illicit Discharge & Bypass: Enforcement & Cost Recovery at Portland Bottling Company 11
PBC: Runoff from Can Lines & Pasteurizer
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Environmental Services l Illicit Discharge & Bypass: Enforcement & Cost Recovery at Portland Bottling Company 12
2013 Inspection: Water & Sewer Data Review
Meter Type Start Date End Date Days Sewer Use (CCF)
City Water 19-Sep-13 22-Oct-13 33 4213
PBC Discharge 10-Sep-13 14-Oct-13 34 411
Is this the data you were hoping for? Yes, but…not quite.Billing needs customer to report early. Reporting periods are offset.
PBC DISCHARGE DATA REPORTING PERIOD
CITY WATER DATA REPORTING PERIOD
City Data
Only PBC Data
Only
Data Overlap For Typical Reporting Period
Approximate Billing Period
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Environmental Services l Illicit Discharge & Bypass: Enforcement & Cost Recovery at Portland Bottling Company 13
Inspection Prep: Water & Sewer Data Review
Reporting Period Overlap Days Gap Days % Overlap % Water as Sewer
Oct 2013 25 17 60% 10%
Sept 2013 21 17 55% 6%
Aug 2013 25 18 58% 2%
Are these the results you were expecting? Not even close!
AREA FACILITY SETS WORLD RECORD
Recent analysis shows local beverage
plant achieves production efficiency
levels between 90-98%. Really?
or................Uncertainty level = 42%
Disclaimer: Confidence level = 58%
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Environmental Services l Illicit Discharge & Bypass: Enforcement & Cost Recovery at Portland Bottling Company 14
Industry Efficiency: Trends in Water Usage
0
1
2
Water Used per Unit (L) Other: Discharge/Losses
Lite
rs
“Other”
may
include:
Losses
• evaporation via cooling
systems & heat applications
• hydrated waste products
Discharge
• cooling water, boiler blowdown
• sanitation, clean-in-place CIP
• plant wash-down
• RO reject
PB
C 2
01
3
Coca-Cola Global
PB
C 2
00
8
PB
C 2
01
3
Coca-Cola
Global
PB
C 2
00
8
> 25%32%
50% < 50%
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Environmental Services l Illicit Discharge & Bypass: Enforcement & Cost Recovery at Portland Bottling Company 15
Let’s take a look: CCTV Camera Inspection
NE Davis St
NE Couch St
NE 1
4th
Ave
40 feet
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Environmental Services l Illicit Discharge & Bypass: Enforcement & Cost Recovery at Portland Bottling Company 16
High Rate of FlowGoing downstream (west) along NE Davis, a lateral located 40 feet from the manhole at shows a high rate of flow entering the sewer from the left side. The location coincides with a lateral mapped in the City GIS.
Nov 2013: Lateral at NE 13th & Davis St
Illicit Discharge in 2013: Inspections
+7FT=40FT
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Environmental Services l Illicit Discharge & Bypass: Enforcement & Cost Recovery at Portland Bottling Company 17
Connection mapped at 40ft Discharge confirmed at 40ft
Illicit Discharge in 2013: Connections
40 feet
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Environmental Services l Illicit Discharge & Bypass: Enforcement & Cost Recovery at Portland Bottling Company 18
Illicit Discharge in 2013: Pasteurizer Overflow
To:Treatment
System
From:Pasteurizer
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Environmental Services l Illicit Discharge & Bypass: Enforcement & Cost Recovery at Portland Bottling Company 19
Illicit Connection in 2013: Bypass pH Probe
pH Probe pH Probe
Open ValveOpen ValveOverflow
Tank
PHOTO: CLOSER TO OVERFLOW PHOTO: FARTHER FROM OVERLOW
Extra Valve!Option for
Continuous Bypass?!?
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Environmental Services l Illicit Discharge & Bypass: Enforcement & Cost Recovery at Portland Bottling Company 20
Illicit Connection in 2013: Bypass Flow Meter
DischargeMeter
Valve Closed by Operator
on Inspection
Overflow Tank
Open Valve
PHOTO: CLOSER TO OVERFLOW PHOTO: FARTHER FROM OVERLOW
Extra Valve!Option for
Continuous Bypass?!?
DischargeMeter
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Environmental Services l Illicit Discharge & Bypass: Enforcement & Cost Recovery at Portland Bottling Company 21
2013: It’s Like Déjà Brew All Over Again
Folk Wisdom
“Fool me once, shame on………shame on you. Fool me…….you can't get fooled again.”- GWB
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Environmental Services l Illicit Discharge & Bypass: Enforcement & Cost Recovery at Portland Bottling Company 22
2007: Pasteurizer Overflow to NE Floor Drain
City: Where does all this flow go?PBC: I don’t know. *shrugs* ¯\_(ツ)_/¯City issues Compliance Order
NE Floor Drain
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Environmental Services l Illicit Discharge & Bypass: Enforcement & Cost Recovery at Portland Bottling Company 23
2007: Compliance Order Requirements
• Inspect sewer connection at NE Floor Drain• Unauthorized connection direct to NE Davis? or
• Other unauthorized connection?
• If discharging via unauthorized connection:A. Plug drain & re-route to existing point of compliance, or
B. Install new sampling manhole along NE Davis lateral
Follow-Up Call About Their Progress• PBC: I don’t know. *shrugs* ¯\_(ツ)_/¯• Surprise Inspection
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Environmental Services l Illicit Discharge & Bypass: Enforcement & Cost Recovery at Portland Bottling Company 24
2008: Dye Inserted at NE Floor Drain
Connection Confirmed• PBC decides against
installing a sampling manhole along NE Davis
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Environmental Services l Illicit Discharge & Bypass: Enforcement & Cost Recovery at Portland Bottling Company 25
2008: Compliance Order Actions
• Plug NE Floor Drain (Mechanical Style: Threaded/Expanding)
• Re-Route to Existing Point of Compliance
• Install Discharge Meter
• Late Compliance Order Report (Minor Enforcement)
Flow Reporting Supports Compliance
• Discharge = 50% of Water Use
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Environmental Services l Illicit Discharge & Bypass: Enforcement & Cost Recovery at Portland Bottling Company 26
2013: Initial Enforcement for Illicit Discharge
• Notice of Violation Class 1 (Major Enforcement - $800)
• Plug NE Floor Drain (Permanent / Concrete)
Before
Drain Open
After
Drain Sealed
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Environmental Services l Illicit Discharge & Bypass: Enforcement & Cost Recovery at Portland Bottling Company 27
2014: Return to Compliance & Follow-Up
• Discharge = 24% of Water Use in 1st Quarter• 24% Identified as “Expected Sewer Use”
Assessment of Long-Term Violations
• Violations Enforced by Extent through Time• $100/day x 966 days + $800/day x 57 days
• Estimate Cost Recovery for Sewer Use• 21 Million Gallons x Base Sewer Rate
• 120 Tons BOD x Custom Rate
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Environmental Services l Illicit Discharge & Bypass: Enforcement & Cost Recovery at Portland Bottling Company 28
0%
25%
50%
75%
100%
0
20,000
40,000
60,000
80,000
100,000
120,000
140,0002008 -
Q3
2008 -
Q4
2009 -
Q1
2009 -
Q2
2009 -
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Q4
2010 -
Q1
2010 -
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2011 -
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2012 -
Q4
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Q4
Dis
ch
arg
e a
s P
erc
en
t of W
ate
rG
allo
ns p
er
Day
Discharge as Percent of Water Use
Water Use at City Meter
Discharge Reported by PBC Meter
Enforcement. PBC ordered to re-plug drain.
Reported use drops. Meter malfunction & “recession”. (50% -> 17%)
Compare Water & Sewer: Extent of Violation
_ 24% of Water “Expected” as Sewer _
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Environmental Services l Illicit Discharge & Bypass: Enforcement & Cost Recovery at Portland Bottling Company 29
0
20
40
60
80
100
120
140
160
Ju
n-0
8
Se
p-0
8
Dec-0
8
Ma
r-09
Ju
n-0
9
Se
p-0
9
Dec-0
9
Ma
r-10
Ju
n-1
0
Se
p-1
0
Dec-1
0
Ma
r-11
Ju
n-1
1
Se
p-1
1
Dec-1
1
Ma
r-12
Ju
n-1
2
Se
p-1
2
Dec-1
2
Ma
r-13
Ju
n-1
3
Se
p-1
3
Dec-1
3
Ma
r-14
Ju
n-1
4
Millio
ns o
f G
allo
ns
Cumulative Water Use at City Meter
Typical/Expected Sewer Use (24% of Water)
Cumulative Discharge Reported by PBC Meter
2015: Water Use & Sewer Reports Diverge
Cost RecoveryEnforcement
"Unreported Sewer Use“
estimated at 21 MGals
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Environmental Services l Illicit Discharge & Bypass: Enforcement & Cost Recovery at Portland Bottling Company 30
Significant Figures: Proposed in 2014
Enforcement PenaltiesTotal: $142,300
Old Rules: 966 days x $100/day = $96,700
New Rules: 57 days x $800/day = $45,600
Cost RecoveryTotal: $307,616
Base Sewer: 21 MGals = $193,334
BOD Charges: 120 tons = $114,282
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Environmental Services l Illicit Discharge & Bypass: Enforcement & Cost Recovery at Portland Bottling Company 31
Appeals: Voluntary Compliance Agreement
• Enhanced Wastewater Management
• pH Treatment & Compliance Probes x 2
• Installation of SCADA System
Adjustments Penalties & Billing
• 30% Reduction of Civil Penalty
• Elimination of BOD Cost Recovery
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Environmental Services l Illicit Discharge & Bypass: Enforcement & Cost Recovery at Portland Bottling Company 32
Significant Figures: Assessed in 2014
Enforcement PenaltiesTotal: $99,610
Penalties Assessed: $99,610
30% Reduction (VCA): $42,690
Cost RecoveryTotal: $190,624
Base Sewer Assessed: $190,624
BOD Charge Removed: $114,282
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Environmental Services l Illicit Discharge & Bypass: Enforcement & Cost Recovery at Portland Bottling Company 33
PBC in 2015: Treatment System & SCADA
pH Probesx 2
DischargeMeter
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Environmental Services l Illicit Discharge & Bypass: Enforcement & Cost Recovery at Portland Bottling Company 34
PBC in 2015: Treatment System & SCADA
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Illicit Discharge & BypassEnforcement & Cost Recovery at
Portland Bottling Company
Brian LaurentPermit Manager
Bureau of Environmental Services
SEPTEMBER 2015
[email protected] 503.823.5655
Thank You. Questions?