HomeMy WebLinkAboutContracts & Agreements_233-2006_CCv0001.pdf SETTLEMENT AGREEMENT
THIS SETTLEMENT AGREEMENT (the "Agreement") is made and entered into as of
October 17 , 2006 (the "Effective Date") by and between the SOUTH COAST AIR QUALITY
MANAGEMENT DISTRICT (the "District") and CITY OF REDLANDS ("CITY").
RECITALS
A. The District is a political subdivision of the State of California created by the
legislature to exercise responsibility for comprehensive air pollution control within the area of
the South Coast Air Basin, with its headquarters located at 21865 Copley Drive, Diamond Bar,
California 91765-0940,
B. The CITY is a California municipality which owns and operates a landfill-gas
fired 1350 BHP, Internal Combustion Engine (ICE). The combustion system is monitored by a
Continuous Emission Monitoring System (CEMs). The combustion system can operate up to 24-
hours per day to supply electricity to operate the City of Redlands wastewater Treatment and
Recycling Facility and to supply power to heat water used in the digester. In addition, the CITY
operates a landfill and digester gas flaring system. The facility is located at 2151 Nevada Street,
Redlands, CA 92373. The CITY uses a mailing address of P.O. Box 3005, Redlands, CA
92373-8112.
C. The CITY operates the landfill gas combustion system which includes the ICE
and the CEMs under Permit to Operate No. F61745, A/N 390032. Conditions 12 and 21 of that
permit requires the CITY to conduct annual performance tests and furnish the SCAQMD written
results of such performance tests within 30 days of the anniversary of the initial test per Rule
1150.1 requirements. Condition 17 of that permit requires that the monitoring system shall
comply with the requirements of SCAQMD Rule 218.
D. The CITY was required to perform the annual testing of the ICE and the testing of
the CEMs no later than March 2006 but Respondent has not performed the testing as required by
the Rule and Permit requirements,
F. The CITY is in the process of repairing the ICE and the ICE has not been
operating since approximately February 2006.
NOW, THEREFORE, in consideration of the foregoing Recitals and the mutual
covenants, agreements, and releases set forth herein, and for other good and valuable
consideration, the receipt and sufficiency of which are hereby acknowledged, the parties agree to
the following:
I Penalty. The CITY agrees to pay a monetary penalty to the District, as follows:
A. For the on-going operation commencing
I October 18 �, 2006, the
CITY will pay the sum of$100 per day of non-compliant operation. The
payments shall be made according to the following schedule:
CITY OF REDLANDS—SETTLEMENT AGREEMENT Page I
[H13 Case#3976-3/'Facility ID#095243]
Period Covered Due Date
February 1-September 30, 2006 October 15, 2006
October 1-31, 2006 November 15, 2006 E
November 1-30, 2006 December 15, 2006
December 1-31, 2006 January 15, 2007
Januar. 1-31, 2007 February 15, 2007
February 1-28 2007 March 15, 11-007
B. The CITY shall not operate the ICE more than seven (7) days without
commencing emission (Rule 1150.1) testing and without commencing
(Rule 218.1) testing on the CEMs.
C. The CITY shall schedule testing for November 7-8, 2006 and complete the
testing unless prevented by means beyond the control of the CITY. If
delayed, the CITY shall complete the testing as soon as possible
thereafter.
D. The CITY shall notify the District [Attn: Linda Dejbakhsh, AQ Engineer
11, Telephone No. (909) 396-2614 and Rick Gluck, AQ Inspector 11,
Telephone No. (909) 396-2361] at least ten (10) days prior to the testing
and immediately upon any change in the dates.
2. No Admission of Liability. This Agreement does not constitute an admission by
any party of liability or responsibility. It is acknowledged that each party's covenants,
agreements, and releases set forth herein is in consideration of this Agreement and is given for
the purpose of avoiding the costs and expenses of any further legal proceedings.
3. No Party Deemed Drafter. The parties acknowledge that the terms of the
Agreement are contractual and are the result of negotiations between the parties and their
respective counsel. Each party and their respective counsel cooperated in the drafting and
preparation of the Agreement.
4. Authority to Execute. Each party represents and warrants to the other party that
the signatories to the Agreement have been duly authorized to execute the Agreement on behalf
of the entities identified below.
5. Counterparts. This Agreement may be executed in counterparts, each of which
shall be deemed to be an original, but all of which shall constitute one and the same document.
The parties may execute and deliver this Agreement by transmitting an authorized signature by
facsimile ("fax"), and copies of this Agreement signed and delivered by means of faxed
signatures shall have the same effect as copies executed and delivered with original signatures.
6. Reserves the RiLyht. The District reserves the right to rely upon the alleged
violation and may offer proof thereof in connection with any future administrative or judicial
proceeding.
7. Timely Payment. If timely payment is not made, the Agreement is void and the
District may proceed on the underlying violations and seek the maximum penalties authorized by
the Health and Safety Code.
8. Binding, This Agreement is binding on any and all successors in interest to the
owner/operators entering into the Agreement.
CITY OF REDLANDS—SETTLEMENT"AGREEMENT Page 2
[IIB Case#3976-3/Facility ID#095243]
9. Notices. All notices, requests, and other communications which may be given
under or concerning this Agreement shall be made in writing and shall be deemed to have given
when received. In each case notice shall be sent to:
For CITY OF REDLANDS:
Greg Gage, Capital Projects Manager
City of Redlands Municipal Utilities Dept.
P.O. Box 3005
Redlands, California 92373
Telephone No.: (909) 798-7698
Facsimile No.: (909) 798-7670
Email: g,g a
., v geCacityofredlands.org
William Song
SCS Energy
3900 Kilroy Airport Way, Suite 100
Long Beach, CA 90806-6816
Telephone No.: (562) 426-9544, Ext. 3088
Facsimile No.: (562) 988-3183
Email: wsoru,,(i%scsen_,,ineers.com
For the DISTRICT:
Carol L. Engelhardt, Esq.
Senior Deputy District Prosecutor
South Coast Air Quality Management District
District Prosecutor's office
21865 Copley Drive
Diamond Bar, California 91765-0940
Telephone No.: (909) 396-3400
Facsimile No.: (909) 396-2961
Email: cengelhardtLi�;aqmd.gov
The District and the CITY hereby execute this Agreement by their authorized
representatives.
CITY OF REDLANDS
ATTEST:
Dated: October 17, 2006 By: (Z�
J 'n Harrison, Mayor Lo7fe Poyze Clerk
SOUTH COAST AIR QUALITY
MANAGEMENT DISTRICT
Dated October V-7, 2006 By:
Carol L. Engelhardt
Senior Deputy District secutor
CITY OF REDLANDS —SETTLEMENT AGREEMENT Page 3
[1113 Case#3976-3,'Facility ID#095243]