FROM: Robert Thompson, General Manager
Originator: Lan C. Wiborg, Director of Environmental Services
SUBJECT:
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TECHNICAL EVALUATION OF LOCAL LIMITS, SPECIFICATION NO. CS-2025-666BD
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GENERAL MANAGER'S RECOMMENDATION
recommendation
RECOMMENDATION: Recommend to the Board of Directors to:
A. Approve a Professional Consultant Services Agreement to EEC Environmental for Technical Evaluation of Local Limits, Specification No. CS-2025-666BD, for a total amount not to exceed $459,840; and
B. Approve a contingency of $68,976 (15%).
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BACKGROUND
Orange County Sanitation District’s (OC San) 2021 National Pollutant Discharge Elimination System (NPDES) Permit requires an updated Technical Evaluation of Local Limits (TELL) to establish local discharge limitations (Local Limits) for pollutants that could affect the integrity of the collection system, treatment plant and water reclamation operations, or endanger the safety of sewer workers and the public. The TELL requires extensive sample collection and analysis throughout OC San’s service area and treatment system to determine pollutants of concern and Local Limits. The updated Local Limits must be based on sound scientific and engineering principles and will undergo review by the federal, state, and local regulatory agencies as well as other stakeholders, such as industrial dischargers and the public.
OC San advertised for proposals on March 6, 2025. A proposal was received from one firm on April 17, 2025 and was evaluated in accordance with OC San's policies and procedures. The proposal received from EEC Environmental was deemed the proposal of best value in terms of meeting OC San' s project requirements. Staff recommend awarding a Professional Consultant Services Agreement to EEC Environmental for Technical Evaluation for Local Limits Development, Specification No. CS-2025-666BD for a total amount not to exceed $459,840.
RELEVANT STANDARDS
• Comply with environmental permit requirements
• Sound engineering and accounting practices, complying with local, state and federal laws
• Meet volume and water quality needs for the GWRS
• Maintain collaborative and cooperative relationships with regulators, stakeholders, and neighboring communities
PROBLEM
OC San needs to conduct a Technical Evaluation of Local Limits as required by its NPDES Permit.
PROPOSED SOLUTION
Approve a Professional Consultant Services Agreement to EEC Environmental for Technical Evaluation of Local Limits, for a total amount not to exceed $459,840, with a contingency of $68,976 (15%).
TIMING CONCERNS
OC San’s NPDES Permit expires in 2026, and updated Local Limits are needed to support OC San’s permit renewal application.
RAMIFICATIONS OF NOT TAKING ACTION
OC San will violate its NPDES permit requirements.
PRIOR COMMITTEE/BOARD ACTIONS
March 2014 - Awarded a Professional Consultant Services Agreement for Specification
No. CS-2013-592BD to Environmental Engineering and Contracting, Inc. (EEC) for Technical Evaluation for Local Limits Development, for a total amount not to exceed $148,504; and approved a contingency of $14,850 (10%).
ADDITIONAL INFORMATION
The scope of services includes developing Local Limits to protect against pass-through, interference, problems with the operation of OC San’s reclamation plants, interference with the collection system or biosolids disposal, and adverse conditions to worker health and safety. Local limits shall be developed by the Consultant, based on site-specific conditions at OC San's wastewater collection, treatment, and reclamation system to be consistent with U.S. EPA's 2004 Local Limits Development Guidance Manual and any additional obligations set forth by the OC San’s beneficial reuse initiatives and regulatory requirements. The Consultant shall identify and collect all necessary data. The selection was conducted in accordance with OC San's adopted policies and procedures.
Staff is requesting a 15% contingency based on the following:
1. California is actively revising its regulatory requirements for potable reuse to incorporate enhanced source control and pretreatment. These changes will likely prompt one or more re-calculations of the Local Limits for the affected contaminants.
2. As OC San continues to explore biosolids management options, Local Limits may need to be re-calculated as OC San modifies the proportion of biosolids allocated for composting, land application, deep well injection, and destruction by supercritical water oxidation.
This contract amount is significantly greater than the work in 2014. This is due to a large increase in sampling of domestic and industrial wastewater in the collection system along with tighter regulations, requiring more individual constituent testing and analysis. There is also more outfall analysis resulting from new operating modes at Plant No. 2 associated with lower effluent flows to the ocean due to increased reclamation.
CEQA
N/A
FINANCIAL CONSIDERATIONS
This request complies with authority levels of OC San’s Purchasing Ordinance. This item has been budgeted (Budget FY 2024-25 and 2025-26, Section 5, Page 7, Environmental Monitoring) and the budget is sufficient for the recommended action.
ATTACHMENT
The following attachment(s) may be viewed on-line at the OC San website (www.ocsan.gov) with the complete agenda package:
• Professional Consultant Services Agreement