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4 <br /> <br />Collaborate with the City to develop a flexible strategy that reflects the City’s site-specific <br />challenges, facilitates compliance, and provides a practical schedule with adequate time to <br />implement improvements in an affordable manner. Maintenance of plant operations (MOPO), <br />asset management renewal and replacement needs, and the City’s other regulatory <br />requirements need to be considered in an integrated plan for meeting the PSNGP. <br /> <br />Key activities for Ongoing Optimization and Annual Report Support are as follows: <br />• Collaborate with City staff to plan, organize, design, implement, etc. the continuation <br />of optimization activities for the calendar year 2023. Planning should include activities <br />associated with expanded treatment process monitoring, bench scale testing, potential <br />pilot studies, supplemental carbon addition, swing zone modifications, full-scale <br />testing of concepts for nitrogen reduction within the existing facilities, as well as <br />modifications to existing facilities, effluent polishing, modifications to the Water <br />Research Foundation (WRF) testing trailer, etc. The target period for implementation <br />of selected activities is the summer of 2023. <br />o Assist the City with selection of design and sizing criteria, process simulations, <br />and other technical analyses to forecast potential operational characteristics and <br />performance. Develop performance objectives to be used for comparison with <br />subsequent optimization testing and for reporting under the PSNGP. <br />• Receive treatment process monitoring data from the City for the entire calendar year <br />of 2023 in early January 2024 including City staff operating conditions records, City <br />documented expenditures and staff time devoted to optimization, etc. (January 2024). <br />• Analyze the entire calendar year of 2023 treatment process data and document the <br />associated operational conditions. Re-calculate nitrogen discharge loadings to the <br />Snohomish River and Puget Sound. <br />o Compare to PSNGP Action Level for Everett. <br />o Determine whether or not any corrective action triggers require near-term <br />attention according to the PSNGP. <br />• Meet with City staff to review calendar year 2023 operations and treatment <br />performance data analysis (January 2024). <br />• Meet with the City to extract selected content from the Working Draft Nutrient <br />Optimization Plan for inclusion in the Second Annual Report (January 2024). <br />• Formulate the Second Draft Annual Report (February 2024). <br />• Meet with the City to review Second Draft Annual Report (February 2024). <br />• Revise and update the draft Annual Report and prepare for submittal to Ecology <br />(March 2024). <br /> <br />Similar activities would be repeated for subsequent years of optimization (calendar years <br />2025 and 2026) under the PSNGP until the end of the initial 5-year permit cycle on <br />December 31, 2026. <br /> 1.5 Develop Nutrient Reduction Evaluation (NRE) <br />The PSNGP calls for a Nutrient Reduction Evaluation (NRE) to be submitted to Ecology for <br />review by December 31, 2025. The NRE must assess site-specific main-stream treatment <br />plant upgrades, the applicability of side stream treatment opportunities, alternative effluent <br />management options, the viability of satellite treatment, and other nutrient reduction