Loading...
RES 19-20-LCU007 ALL SIGNED LAS CRUCES UTILITIES BOARD RESOLUTION NO. 19-20-LC0007 A RESOLUTION APPROVING AN AMENDMENT TO RESOLUTION 11-12-006 TO INCREASE THE LIMITS OF ATMOSPHERIC HYDROGEN SULFIDE FOR THE ADMINISTRATIVE CHARGES ASSOCIATED WITH THE EXCEEDANCE OF HYDROGEN SULFIDE LIMITS FOR THE LAS CRUCES PUBLICLY OWNED TREATMENT WORKS. The Board of Commissioners for the City of Las Cruces Utilities, on behalf of the City of Las Cruces, is informed that: WHEREAS, on July 14, 2011, Resolution No. 11-12-006 was approved by the Las Cruces Utilities ("LCU") Board of Commissioners ("Board"), which established limits of atmospheric hydrogen sulfide ("H2S") and implementing administrative charges associated with the exceedance of H2S limits in order to provide odor and corrosive control measures within the wastewater system; and WHEREAS, currently the monthly amount of atmospheric H2S emitted in the collection system by Applicable Users ("AU's") of the LCU wastewater system is limited to a 7-day average of 5 ppm (5 mg/L) +/-10%. This 5 ppm limit is also the Corrective Action Level ("CAL") at which administrative charges are levied against the AU's; and WHEREAS, the atmospheric H2S emitted by the AU's wastewater is monitored using OdaLog meters that are rated for concentrations ranging from 0 to 1000 ppm. The OdaLog manufacturer lists the accuracy of these meters at 1% Full Scale (1000 ppm) with a + 2 ppm accuracy at 20 ppm (at standard temperature and pressure). A study regarding the accuracy of these meters, at varying concentration ranges of H2S, was performed by the Pollution Prevention Office ("PPO"). It was determined that these meters had a 36.6% error when reading the 5 ppm standard. With respect to administrative charges, the optimum concentrations with the least amount of LCU FY19 11/18 Rev. 2 LCU Board Resolution No. 19-20-LC0007 Page 2 of 4 percent error were found to be 50 ppm (0.48%), 25 ppm (2.68%), and 20 ppm (0.80%); and WHEREAS, the PPO recommends the establishment of H2S compliance measures similar to those used by the New Mexico Environment Department and the Environmental Protection Agency with respect to the enforcement of the Wastewater Discharge Permits. This would be accomplished by revising the existing 5 ppm CAL to establish a new H2S CAL of 25 ppm. Upon exceedance of the CAL, the AU would fall under a compliance period. When the 7-day average exceeds the 25 ppm CAL, the AU's will be given a Notice of Non-Compliance with a 7-day Compliance Period, during which time the AU's will take corrective measures as the PPO continues to monitor their H2S. This will allow the AU's time to make the necessary adjustments to come into compliance. After 7 days, if the 7-day H2S average remains 25 ppm or greater, administrative charges will be levied; and WHEREAS, this will allow a time period where provisions can be made to come into compliance. By allowing a compliance period, the PPO would be working with the AU's in a positive manner prior to levying punitive administrative charges. All the AU's are currently utilizing various measures to keep their H2S emissions in compliance, the most common of which is a bioxide treatment system. The PPO recognizes that these bioxide systems at times will experience equipment failures which would result in their 7-day average being non-compliant; and WHEREAS, Resolution No. 11-12-006, Exhibit "A", Part 2) Compliance Monitoring, the H2S concentration will be replaced with 25.0 milligrams per liter (25.0 parts per million); and WHEREAS, LCU staff is recommending the LCU Board approve Resolution No. LCU FY19 11/18 Rev. 2 LCU Board Resolution No. 19-20-LC0007 Page 3 of 4 19-20-LC0007, which will amend Resolution No. 11-12-006, and increase the limit of atmospheric 1­12S associated with administrative charges in regards to the exceedance of H2S limits for the Las Cruces publicly owned treatment works. NOW, THEREFORE, Be it Resolved by the Board of Commissioners for the City of Las Cruces Utilities, on behalf of the City of Las Cruces: (I) THAT Resolution No. 19-20-LC0007 be approved, which will amend Resolution No. 11-12-006, and increase the limits of atmospheric H2S and the administrative charges associated with the exceedance of H2S limits for the Las Cruces publicly owned treatment works. III) THAT City staff is hereby authorized to do all deeds necessary in the accomplishment of the herein above. DONE AND APPROVED this loth day of October 2019. APPROVED: By Board Chair ATTEST: Secretary VOTE: Chair Little: Moved by Vice-Chair Archuleta: Commissioner Baumgarn: Seconded by Commissioner Carmichael: Commissioner Johnson: Commissioner Sorg: Commissioner Vasquez: LCU FY19 11/18 Rev. 2 LCU Board Resolution No. 19-20-LC0007 Page 4 of 4 APPROVED AS TO FORM: Sr. As i tant City A ey LCU FY19 11/18 Rev. 2 EXHIBIT "A" REVISED RULE FOR ATMOSPHERIC HYDROGEN SULFIDE (H2S) EMISSION CONTROL 1) This rule applies to Applicable Users (AUs) • AUs are defined as all entities that authorize the City to collect and treat their wastewater through a written agreement. 2) Compliance Monitoring - The City's Utility Staff shall monitor any identified location for a duration of seven days to determine the AU's compliance status of 1­12S to the standard of 25.0 milligrams per liter (25.0 parts per million) averaged over a 7-day period. Values in excess of this standard are Corrective Action Levels (CAL). 3) Compliance Period: Continuous 4) Notice of Determination - A monthly letter with the monitored 1­12S readings would be provided to AUs of the municipal sewer collection system indicating compliance status and any associated administrative charges. 5) Compliance Determination - The second instance of a CAL monitored reading will cause administrative charges to be applied. 6) Schedule of Administrative Charges - At the second instance of CAL, the following administrative charges shall take effect: • For the second instance exceeding the CAL, the administrative charge will be 20% of the total wastewater bill for that month. • For each continued instance exceeding the CAL, the administrative charge will be an additional 10% of the total wastewater bill for that month. • For example: 3rd instance = 30% , 4th = 40%. • AUs actively demonstrating corrective measures may request a waiver of administrative charges during implementation of such measures. 7) Upon the 101h instance exceeding the CAL, the Utility shall deem the AU beyond non-compliance. The City shall at that time undertake whatever corrective actions it deems appropriate to reduce H2S emissions at the AU location and shall bill the AU accordingly. ON of LaS Cruces MOUNTAINS Of OPPORTUNITY MEMORANDUM EXHIBIT "B" To: Jorge A. Garcia, Ph.D., P.E., Utilities Director From: Laura E. Montoya, Pollution Prevention Initials: Manager Date: September 23, 2019 File #: REG2001 Subject: Recommendation to Amend LCU Resolution No. 11-12-006 Resolution No. 11-12-006, establishing limits for atmospheric hydrogen sulfide (1­12S) and implementing administrative charges associated with the exceedance of H2S Limits for the Las Cruces publicly owned treatment works, dated July 14, 2011, currently limits the monthly amount of atmospheric H2S emitted in the collection system by Applicable Users (AU's) of the Las Cruces Utilities (LCU) Wastewater System to a 7-day average of 5 ppm (5 mg/L) ±10%. This 5 ppm limit is also the Corrective Action Level (CAL) at which Administrative Charges are levied against the AU. The atmospheric H2S emitted by the AU's wastewater is monitored using OdaLog meters that are rated for concentrations ranging from 0 to 1000 ppm. The OdaLog manufacturer lists the accuracy of these meters at 1% Full Scale (1000 ppm) with a ± 2 ppm accuracy at 20 ppm (at standard temperature and pressure). A study regarding the accuracy of these meters, at varying concentration ranges of 1­12S, was performed by the Pollution Prevention Office (PPO). It was determined that these meters had a 36.6% error when reading the 5 ppm standard. With respect to administrative charges, the optimum concentrations with the least amount of percent error were found to be 50 ppm (0.48%), 20 ppm (0.80%), and 25 ppm (2.68%). Attached for your review is the Determination of the Method Detection Limit Study and the historical background. The PPO recommends the establishment of H2S compliance measures similar to those used by the New Mexico Environment Department and the Environmental Protection Agency with respect to the enforcement of the Wastewater Discharge Permits. This would be accomplished by revising the existing CAL of 5 ppm to establish a new H2S CAL, as listed in the options below, at which point the administrative charges would be levied. Two proposed options for levying administrative charges are: A) Set the CAL at 50 ppm. Upon exceedance of the 7-day average Goal Limit (5 ppm), the AU will be given a Notice of Non-Compliance; upon exceedance of the CAL (50 ppm), the AU will be given a Notice of Violation and administrative charges will be levied. AN EQUAL OPPORTUNITY EMPLOYER Jorge A. Garcia, Ph.D., P.E., Utilities Director Page 2 of 2 Recommendation to Amend LCU Resolution No. 11-12-006, File #REG2001 September 23, 2019 B) Set the CAL at 25 ppm. Upon exceedance of the CAL, the AU would fall under a compliance period. When the 7-day average exceeds the 25 ppm Action Limit, the AU will be given a Notice of Non-Compliance with a 7-day Compliance Period, during which time the AU will take corrective measures as the PPO continues to monitor the H2S. This will allow the AU time to make the necessary adjustments to come into compliance. After 7 days, if the 7-day H2S average remains 25 ppm or greater, administrative charges will be levied. In summary, Option A is less restrictive but offers no compliance period. Option B, which is more restrictive, allows a time period where provisions can be made to come into compliance. By allowing a compliance period, the PPO would be working with the AU's in a positive manner prior to levying punitive administrative charges. All the AU's are currently utilizing various measures to keep their H2S emissions in compliance, the most common of which is a bioxide treatment system. The PPO recognizes that these bioxide systems at times will experience equipment failures which would result in their 7-day average being non-compliant. The PPO can easily discern an equipment failure versus outright negligence by the AU when reviewing their 7-day H2S graphs (see Figures 1-6). Therefore, the PPO staff recommends your approval of Option B. Thank you for your consideration to this matter. If you have any questions or require additional information, lease contact me at 528-3596. Ll ! J Approved t Date Not Approved Date Jorge A. Garcia, Ph.D., P.E. Jorge A. Garcia, Ph.D., P.E. Utilities Director Utilities Director Attachments: Determination of the Method Detection Limit (MDL) of the H2S OdaLog Logger and the Optimum Concentration for Administrative Charges, Actual H2S Exceedances of Applicable Users, Hydrogen Sulfide Graphs (Figures 1-6), Resolution 11-12-006. LEM/tg cc: Carl N. Clark, P.E., Deputy Director Environmental & Initials: CL, Technical Support Study to Determine the Method Detection Limit (MDL) of the H2S OdaLog Logger and the Optimum Concentration for Administrative Charges By Laura Montoya, B.A. Chemistry, B.S. Microbiology and Damon Barnes, LAMED Certified Level IV Water and Wastewater Background: The Las Cruces Utilities (LCU) Pollution Prevention Office (PPO) has been monitoring the atmospheric hydrogen sulfide (H2S) emitted from the wastewater of Applicable Users (AU's) of the LCU Wastewater Treatment Facilities on a monthly basis since the inception of the 1-12S Resolution in September 2011. The AU's, as defined in the Resolution, are all entities that authorize the City to collect and treat their wastewater through a written agreement. To accomplish this, the PPO uses Odalog 1-12S Loggers/Meters which are designed specifically for continuous exposure in harsh wastewater environments. All the AU's use a force main as their conduit to transfer their wastewater to the LCU collection lines. Force mains, by the nature of their design, are inherent for producing H2S. Microorganisms require a source of oxygen for cellular respiration. As wastewater sits in the force main between pumping cycles, the microorganisms deplete the dissolved oxygen and begin to breakdown chemical compounds containing combined oxygen such as sulfates, the biproduct of which is dissolved hydrogen sulfide. This dissolved H2S is ultimately released in gaseous form due to the turbulence at the point where the force main dumps into the gravity line which is the location where the meters are placed for monitoring. These meters, purchased from Detection Instruments, are the only meters found that were designed to be placed in a wastewater collection system for multiple weeks while being exposed to 1-12S concentrations as high as 1000 ppm. The User Manual for the meters (attached) states their working range as 0-1000 ppm H2S with a resolution of 1 ppm and an accuracy of 1% of full scale with a 2 ppm accuracy at 20 ppm (standard temperature and pressure). Study: A study was performed to determine the variability of the accuracy of the 1-12S meters noting that 5 ppm is at the extreme lower end of the working range. For the scope of this study, all 25 of the PPO's meters were calibrated and tested over a period of 12 months using varying concentrations of 1-12S (50, 25, 20, 15, 10, and 5 ppm). This was performed during the normal monthly deployment of the meters for 1-12S monitoring. Each meter was calibrated prior to deployment using a 50 ppm 1-12S standard (per User Manual) followed by a 5-10 minute verification reading of one of the less concentrated standards. The meter was then placed into the manhole for the normal monthly monitoring purposes. After ten days, the meter was retrieved, the 50 ppm standard was read again to verify that the calibration had not shifted followed by reading the same less concentrated standard to check for accuracy. All this data was recorded for each meter. Results: Approximately 300 data points have been compiled into one table (Table 1) for ease of comparison. HzS 10 5 Standards 50 ppm 25 ppm 20 ppm 15 ppm Concentration ppm ppm Sample Size 127 40 23 23 54 30 Average Conc. 49.76 25.67 20.12 15.17 9.23 3.17 Standard Dev. 0.73 1.16 0.75 0.55 1.31 1.20 Median 50 26 20 1 15 10 3 % Error 0.48 2.68 0.80 1.13 7.7 1 36.6 Table 1: Statistical data of the all 1-12S standards tested. The optimum concentrations, with the least amount of percent error, were found to be 50 ppm (0.48% error), 20 ppm (0.80% error), and 15 ppm (1.13% error). History of Exceedances: The actual recorded H2S exceedances of the AU's are listed in Table 2 (attached) which gives the H2S concentration followed by the month/year of the exceedance. This table also shows that the last violation of any of the AU's occurred with Southern New Mexico Correctional Facility (SNMCF) with a concentration of 847 ppm in August 2015. SNMCF has entered into a Intergovernmental Agreement with LCU-PPO to supply Odor Control Support of their bioxide system which should alleviate any future exceedances. v C) � o 00 N C � O L—n >, i-i o p m O O Q) 00 — L O O M 4— � Q � 00 00 o m0 — (O lJ'1 N O 4.0 f° O a' �i co a- t� o N N U V o U N C � rn C Ln V Ov L1 u N N o rn m t 4- O bA Lin `� `- +' _O c� Ln o o v N > •Q li Ln a N 0) y.. N p N o _v {/� O CD r-I r-I Ll; N Qt r I cu O r-I 00 v m U O W v N Q (n N Na) _ U L.L.. N N U N o O o O O^Ln (p m e V i 00 V^'1 N O a U Co X 4 N 0 4- v � 0o m r� N O N N p W U Oin u L a U X f0 N z O O O v o Q) c ++ uNi w @ � O N V N OL LL t C fD U U c en vo+; , n Q m r 3 - a cC t _ > 3 z <n I— I I � a� I O 0 L I o _ U L O O I Q .{J Q LO D O a W = 4 � Q a 2S L 00 E O O � O O ca I - U Q g ) Q C 9 3 � O ru I s Q c6 R 4-J� S = Q T Q U N 8 I o 0 I rl L N N � f0 LL -o � g I � I . I 4-J I I Lf) I � 4-) I � I / � o I I � Q) � I ; 4-) | 2 � & - � I � _ I ! � I � 9 � ! � n w el ; R ' 4-J ` - 00 ) 4-J \ o E I � o ! &$ J ) | u � I k| S E u f - ! � } . j CY) 4 3 m k / � % N / | ' ro ■ ! ■ - } LL -o 0 � o � � � @ � � § o 4-J 0 � E _ | � , g � } �x | L w Cf) � ! E | � o I \ 4-J Q / / / {� M u ` o LJ» � . 0 0) cl I ` cl I Cf) Ln / � E U O - e / E / \ | LL 2 R I \ : � E � � D � I � � I I � I E o 4-J 0 I � U) 4-J �2 I E c o e I � CL I _ e � | § :Lj CL J o Q I 4-J I % / : | fa {| _0 § g � < 4-J fu \ � I ! 0 .2 C)_ ) 0 o I � § o g I � q r ' e � � § ■ o : | _-0 I �§ o a) I 0) � \ \ } { } ( � I = I Ln E 2 E Z) I } o « � m 20 0 I I 0 2 / U fU ® L- Q j - �\ 4-J / \ - � / § • u j ¢ I U) I . CL 2 I o u I � - 4-J w 4-J 2 I � E � CL C a _ \ % 3 / I moo : I g g fa o fa . u Q/i U. $ Q CL . . \ � E fu I \ R � � I ( 4- a F- c ! m o \ � o 2 u > fu c o / E u \ I / Ln e m E a) Q) Q) : \ g 0 o- E |' LL -0 / / ! § B ■ ■ ; ! ® ) � � O 4-J 4-J a-J � L g E L N OO a-J i — 4-) I — O � U R = L o) I J >� L � Q Lo O Q c M Q un UO rva O rLo °) CU = 70 cn fu (a O w — Lr) Q U d tLLi`e a U i (0 4-d U o� _ ate-+ (6 J O _ � N ,-I fa _ Q-CD 0, o o >1 Q c I g � = o � E 00 Ln a I o co Lo II Q Ln O cV m ATTACHMENT "A" LAS CRUCES UTILITY BOARD RESOLUTION NO. 11-12-006 A RESOLUTION ESTABLISHING LIMITS FOR ATMOSPHERIC HYDROGEN SULFIDE (1-12S) AND IMPLEMENTING ADMINISTRATIVE CHARGES ASSOCIATED WITH THE EXCEEDENCE OF H2S LIMITS FOR THE LAS CRUCES PUBLICLY OWNED TREATMENT WORKS. The Board of Commissioners for the City of Las Cruces Utilities, on behalf of the City of Las Cruces, is informed that: WHEREAS, 1-12S is dangerous to breathe and presents serious odor problems; and WHEREAS, 1-12S reacts with water to form sulfuric acid which in turn is corrosive and destructive to sewer collection systems; and WHEREAS, the Wastewater Utility uses a concentration of 5.0 parts per million (ppm) atmospheric to indicate the presence of 1-12S, based on previous studies prepared by consultants ; and WHEREAS, concentrations of 1-12S that are greater than 5.0 ppm cause malodorous conditions; and WHEREAS, odor complaints indicate potential concentrations of 1-12S in excess of 5.0 ppm; and WHEREAS, no 1-12S limits have been established for applicable users of the municipal sewer collection system; and WHEREAS, the Utility recognizes its responsibility in both maintaining both the integrity of the publicly owned treatment works infrastructure and reducing odor emissions; and WHEREAS, in order to further provide odor and corrosive control measures within the wastewater system, a resolution establishing 1-12S limits and administrative charges associated with exceeding 1-12S limits is required; and LCU Board Resolution No. 11-12-006 Page 2 of 2 WHEREAS, LCMC Section 28-199(a)(F)authorizes the Utilities Board on behalf of the City to adopt reasonable fees to implement provisions of the Liquid Waste Disposal Ordinance; and WHEREAS, LCMC Section 28-199 (b)authorizes the Utilities Board on behalf of the City to adopt documents that the Utilities Director requires to implement provisions of the Liquid Waste Disposal Ordinance. NOW, THEREFORE, be it resolved by the Board of Commissioners for the City of Las Cruces Utilities, on behalf of the City of Las Cruces: (1) THAT, the Rule for Atmospheric Hydrogen Sulfide(H2S) Emission Control attached hereto as Exhibit "A" is approved and adopted as of August 1, 2011. (11) THAT, Utilities Department staff is hereby authorized to do all deeds necessary in the accomplishment of the herein above. DONE AND APPROVED this 14th day of July' 01-1. % /A ! „ By Board Chair ATTEST: Secretary VOTE: Chair Little: Ave Moved by C'ar7Pna Vice-Chair Cadena: Ay Commissioner Ericson: Absent Commissioner Hayes: Aye Seconded by Sorg Commissioner Pedroza: Aye Commissioner Sorg: Ave Vacant: A PROVED AS TO FORM: UtilifLes Attorney EXHIBIT "A" RULE FOR ATMOSPHERIC HYDROGEN SULFIDE (H2S) Emission Control 1) This rule applies to Applicable Users (AUs) • AUs are defined as all entities that authorize the City to collect and treat their waste water through a written agreement. 2) Compliance Monitoring — The City's Utility Staff shall monitor any identified location for a duration of seven days to determine the AU's compliance status of H2S to the standard of 5.0 milligrams per liter (5.0 parts per million); (+/- 10%) averaged over a 7 day period. Values in excess of this standard are Corrective Action Levels (CAL). 3) Compliance Period: Continuous 4) Notice of Determination —A monthly letter with the monitored H2S readings would be provided to AUs of the municipal sewer collection system indicating compliance status and any associated administrative charges. 5) Compliance Determination — The second instance of a CAL monitored reading will cause administrative charges to be applied. 6) Schedule of Administrative Charges — At the second instance of CAL, the following administrative charges shall take effect: For the second instance exceeding the CAL, the administrative charge will be 20% of the total wastewater bill for that month. ➢ For each continued instance exceeding the CAL, the administrative charge will be an additional 10% of the total wastewater bill for that month. ➢ For example: 3�d instance = 30%, 4th instance = 40%. ➢ AUs actively demonstrating corrective measures may request a waiver of administrative charges during implementation of such measures. 7) Upon the 1 oth instance exceeding the CAL, the Utility shall deem the AU beyond non-compliance. The City shall at that time undertake whatever corrective actions it deems appropriate to reduce H2S emissions at the AU location and shall bill the AU accordingly. MW Cft wx� v of Las Cruces MOUNTAINSym OF OPPORTUNITY LAS CRUCES UTILITIES BOARD OF COMMISSIONERS ACTION FORM For Meeting of October 10, 2019 (Adoption Date) TITLE: A RESOLUTION APPROVING AN AMENDMENT TO RESOLUTION 11-12-006 TO INCREASE THE LIMITS OF ATMOSPHERIC HYDROGEN SULFIDE FOR THE ADMINISTRATIVE CHARGES ASSOCIATED WITH THE EXCEEDANCE OF HYDROGEN SULFIDE LIMITS FOR THE LAS CRUCES PUBLICLY OWNED TREATMENT WORKS. BACKGROUND: On July 14, 2011, Resolution No. 11-12-006 was approved by the Las Cruces Utilities ("LCU") Board of Commissioners ("Board"), which established limits of atmospheric hydrogen sulfide ("112S") and implementing administrative charges associated with the exceedance of 1-12S limits in order to provide odor and corrosive control measures within the wastewater system. Currently the monthly amount of atmospheric 1-12S emitted in the collection system by Applicable Users ("AU's") of the LCU wastewater system is limited to a 7-day average of 5 ppm (5 mg/L) +/-10%. This 5 ppm limit is also the Corrective Action Level ("CAL") at which administrative charges are levied against the AU's. The atmospheric 1-12S emitted by the AU's wastewater is monitored using Odal-og meters that are rated for concentrations ranging from 0 to 1000 ppm. The Odal-og manufacturer lists the accuracy of these meters at 1% Full Scale (1000 ppm) with a +/-2 ppm accuracy at 20 ppm (at standard temperature and pressure). A study regarding the accuracy of these meters, at varying concentration ranges of 1-12S, was performed by the Pollution Prevention Office ("PPO"). It was determined that these meters had a 36.6% error when reading the 5 ppm standard. With respect to administrative charges, the optimum concentrations with the least amount of percent error were found to be 50 ppm (0.480/o), 25 ppm (2.680/o), and 20 ppm (0.80%). Continue on additional sheets as re uired Name of Drafter: Department: Phone: Carl N. Clark a' Utilities 528-3548 Account Number: Amount of Expenditure: Budget Amount: N/A N/A N/A Strategic Plan Goal / Objective / Strategy Addressed: N/A Performance Bud et Goal / Objective Addressed: N/A Department Signature Phone Department Signature Phone Utilities 528-3512 Bud et / 1 541-2300 Assistant Le al 541-2128 City Manager 541-2271 City Manager 541-2076 LCU 5/18 Rev.4 LCU Board Action Form Page 2 The PPO recommends the establishment of H2S compliance measures similar to the those used by the New Mexico Environment Department and the Environmental Protection Agency with respect to the enforcement of the Wastewater Discharge Permits. This would be accomplished by revising the existing 5 ppm CAL to establish a new H2S CAL of 25 ppm. Upon exceedance of the CAL, the AU would fall under a compliance period. When the 7-day average exceeds the 25 ppm CAL, the AU's will be given a Notice of Non-Compliance with a 7-day Compliance Period, during which time the AU's will take corrective measures as the PPO continues to monitor their H2S. This will allow the AU's time to make the necessary adjustments to come into compliance. After 7 days, if the 7-day H2S average remains 25 ppm or greater, administrative charges will be levied. This will allow a time period where provisions can be made to come into compliance. By allowing a compliance period, the PPO would be working with the AU's in a positive manner prior to levying punitive administrative charges. All the AU's are currently utilizing various measures to keep their H2S emissions in compliance, the most common of which is a bioxide treatment system. The PPO recognizes that these bioxide systems at times will experience equipment failures which would result in their 7-day average being non-compliant. LCU staff is recommending the LCU Board approve Resolution No. 19-20-LC0007 which will amend Resolution No. 11-12-006 and increase the limit of atmospheric H2S associated with administrative charges in regards to the exceedance of H2S limits for the Las Cruces publicly owned treatment works as shown on the Revised Rule for Atmospheric Hydrogen Sulfide (H2S) Emission Control. SUPPORT INFORMATION: 1. LCU Resolution No. 19-20-LC0007. 2. Exhibit "A" - Revised Rule for Atmospheric Hydrogen Sulfide (H2S) Emission Control. 3. Exhibit "B" - Recommendation Memo and corresponding attachments to Jorge A. Garcia, Ph.D., P.E., Utilities Director. 4. Attachment "A" - Resolution No. 11-12-006 with Exhibit "A". BOARD OPTIONS: 1. VOTE 'AYES" - Will approve Resolution No. 19-20-LC0007 which will amend Resolution No. 11-12-006 and increase the limits of atmospheric H2S and the administrative charges associated with the exceedance of H2S limits for the Las Cruces publicly owned treatment works. 2. VOTE "'NO" - Will reject Resolution No. 19-20-LC0007 and will not amend Resolution No. 11-12-006 to increase the limits of atmospheric H2S and the administrative charges associated with the exceedance of H2S limits for the Las Cruces publicly owned treatment works. Staff will require strategic guidance. (Continue on additional sheets as required)