Testimony before the
Senate
Committee on Environment and Public Works
Subcommittee on Fisheries, Wildlife and Water
By
Donald M. Moline P.E., DEE
Director of Public Utilities
City of Toledo
April 30, 2001
I am Donald M. Moline and I am the Public Utilities Director for the City of Toledo. On behalf of Mayor Carleton S. Finkbeiner, I am pleased to provide you with some thoughts and ideas as they relate to wastewater infrastructure. More specifically, I would like to relay our experiences in treating or controlling wet weather events.
The City of Toledo’s wastewater system serves about 375,000 individuals. The wastewater treatment plant treats, on an average, 75 million gallons per day (MGD) with wet weather flow going up to 400 MGD.
The
City of Toledo is currently involved in discussions to settle a lawsuit that
was brought by the USEPA on October 29, 1991.
The claim was that the City of Toledo had not been meeting the limits of
it’s NPDES permit at the final effluent discharge to the Maumee River. The plant had just undergone a massive
rebuilding effort, with federal assistance, and had not been in full
compliance. Over the approximately 10
years of this lawsuit, the final effluent has come into significant compliance
and therefore it’s discharge is not an issue.
The focus of the debate then switched to the issue of bypassing.
During
wet weather, most older, Midwestern cities that have combined sewers must
bypass the treatment plant either from a CSO (combined sewer overflow) or a
primary bypass at the plant itself.
This practice is not unique to the City of Toledo. Wastewater treatment
plant were not built to handle large raw water flows that happen relatively
infrequent. The basic problem centers
on the fact that there are very few ways to remedy this situation.
Wet
weather facilities are only used during rain and the traditional biological
treatment can not sit idly by waiting for rain. The alternative is to develop some different form of treatment or
provide storage for wet weather flows with the idea of treating this water
after the rain event has subsided. The
City of Toledo was involved with both alternatives, our costs for this is over
80 million dollars.
The
issue of bypassing was submitted to Judge James Carr in federal district court
in Toledo. He ruled that bypassing was
illegal if ‘feasible alternatives’ are available. This is a term contained within the Clean Water Act and he
defined feasible alternatives to include building new treatment units or
storage tanks. He stopped short of
defining what measure would need to be undertaken or how much. He did, however, indicated that maximizing
your existing treatment plant was not sufficient when it comes to feasible
alternatives and bypassing. This has
huge ramifications for the wastewater industry in general.
The
USEPA has insisted that we build an equalization basin that would hold
sufficient quantity of wastewater such that we could avoid most bypassing. This amounts to a 60 million-dollar basin.
In
previous discussions, we had conceived and designed an alternative wet weather
system that would treat the higher flows and return them to the Maumee River
without the need for storage. We were
going to combine our swirl concentrators with an Actiflow system to treat the
water. We fully intend to ensure that
the discharge would meet water quality standards such that no harmful effects
would be produced. This alternative
could have saved us at least 40 million dollars. The USEPA indicated that this was a good idea and that we should
downsize just slightly the Actiflow system and combine it with the 60 MGD
Equalization basin. The remedy went
from our idea costing 30 to 35 million to their idea costing 80 million. The disappointing part about this is that
there is little benefit to the water quality of the river. The reason that they would not agree to the
Actiflow system alone was that we were not giving all of the wastewater
secondary treatment and therefore it technically was a bypass. They would be willing to allow us to build such
a system as long as we built an equalization basin too. They were standing on a technical definition
that bypassing any treatment unit constituted a bypass regardless of the water
quality impact or cost.
In
essences, what we had proposed was not a bypass, but a blending of wet weather
treatment system and the full secondary treatment. This in an important distinction in that the USEPA has recently
informed Congress that the concept of blending should receive favorable
consideration when looking at wet weather alternatives. In our particular case, the USEPA would only
agree to blending provided we not only remedied the issues at the wastewater
plant but also embarked upon a massive construction program in the collection
system.
The
previous discussion is only a portion of our lawsuit issues, but it serves to
highlight some of the problems with completing wastewater infrastructure
projects. The first topic that needs to
be addressed is regulatory oversight.
The USEPA in recent years has placed more emphasis on enforcement rather
than water quality results. Meeting the
technical definitions contained within rules and regulations is more important
than water quality standards. There
seems to be an imbalance between the technical assistance and the enforcement
divisions within the agency. There
needs to be more assistance, which will lead to greater cooperation in solving
technical issues rather than achieving goals through the enforcement
provisions. In our particular
situation, we have experienced this with the bypass and blending issues. We believe that our alternative would have
been able to provide the same water quality benefits at a much lower cost.
A
second area that involves regulatory oversight is the issue of cost
effectiveness and scientifically based reasoning. Again, it has been our experience that these two concepts are
secondary to meeting the procedural criteria of the enforcement section. In discussions, everyone champions the idea
of applying good scientific evidence, sound engineering principals and cost
effective solutions to problems, however, in practice, these issues are not
given the weight or consideration which is appropriate. Often municipalities are forced to comply
with standard procedures that are based solely on approved treatment
techniques. This unyielding approach
ultimately leads to higher costs for wastewater infrastructure. The recently adopted CSO Policy has a better
approach. This policy talks of a
comprehensive and coordinated planning effort by the municipality, the
regulatory agencies and the public. It
allows for site-specific solutions and the need for flexibility to tailor
controls to arrive at the best solutions.
The USEPA needs to fully embrace this approach to enhance technical
assistance standpoint and reduce the need for regulatory enforcement.
In
Toledo case, our proposed consent decree will cost the ratepayers over 400
million dollars. The City of Toledo is
prepared to spend this amount. We have
not finalized the decree because we are concerned that the overall cost will
balloon to 600 or 700 million dollars.
As I have previously indicated with our experiences, ballooning costs
are a real possibility. To give you some idea of the impact of these costs to
the City of Toledo, consider the following.
The current overall debt of the entire City of Toledo over the last 100
years is around 423 million dollars.
With the wastewater projects proposed, the City of Toledo will double
its debt. This places a huge burden on
the ratepayers. Over the next fifteen
years, we anticipate our rates will more than double to provide enough funds to
service the debt. We recently put out a
Request for Proposals (RFP) for the engineering on these projects and that alone
will cost 35 million dollars.
The
amount of funds being request for infrastructure improvements may lead to the
conclusion that the City of Toledo has neglected it wastewater system. This simply is not true. Toledo has been a proactive leader in
wastewater improvements. We have
installed storage tunnels for the combined overflow system (CSO) to catch the
first flush and we have continually invested in our system. Over the last 20 years we have invested over
234 million dollars in infrastructure improvements.
The
need for the water and wastewater capitol infrastructure improvements industry
wide over the next five years amounts to an estimated $46 billion dollars per
year. That equals 230 billion dollars
over that five-year period. Clearly,
there is a tremendous need. Since the early
1970’s, federal funding of water and wastewater projects has been steadily
declining. It is time to reverse this trend.
Congress needs to create a long-term, sustainable, and reliable federal
funding structure. This should include
things such as grants, low interest loans, loan subsidies, congressional
earmarks, state revolving loan funds and refinancing opportunities. The federal government should ensure that
the programs are fully funded, provide flexibility in their use and streamline
the funding application process. At a minimum, the industry need 57 billion
dollars from years 2003 to 2007 just to remain solvent.
In
summary, congress should encourage the following:
1.
Regulations
that are based on sound scientific and engineering
principals.
2.
Regulations
that are based on water quality objective.
3.
Regulatory
actions that place an emphasis on cooperation rather than enforcement as
outlined in the CSO Policy.
4.
Federal
funding that is long term and in sufficient quantities to
help meet the need of the industry.
5.
Clarification
of the language (blending, bypass issues) of the Clean Water Act to provide
flexibility in meeting the demands of wet weather treatment systems.
6.
Provide
research and support for the use of new, innovative
technologies.
7.
Provide
federal grants because the need is so large.
8.
Continue
to educate the public of an often overlook area of public
health and environmental protection.
9.
Allow
communities to become a partner in the process, not simply
those who execute the plan.
10. And finally, put more
emphasis on non-point source discharges
rather than continuing to try to extract water
quality gains from
point source discharges that have been improved
significantly in
the last 10 years.
It simply does not benefit the environment to continue to follow this
approach.
ATTACHMENT TO COMMENT
BY
DONALD M. MOLINE
APRIL 30, 2001
PROJECT DESCRIPTIONS
1.
EAST SIDE and BAYVIEW PUMP STATION RENOVATIONS
These improvements involve the
renovation of the East Side Pump Station (ESPS) and the Bay View Pump Station
(BVPS). The majority of the work is
structural and mechanical. The work
will include the renovation of the vacuum priming systems at both pump stations,
new windows and doors, new discharge valves on the raw sewage pumps 1, 3 and 4
at the ESPS and at all 5 pumps at the BVPS, new HVAC at both stations, new
fencing and repair of the roadway at the ESPS.
The floor drain system at each pump station will be
reconfigured so that they are separate from the wet well. Flow meters will be added for pumps 1 and 6
at each station. The vacuum pumps,
discharge valves and flow meters will be automated and integrated with the
plant's control system. The existing gas detection systems will be upgraded and
alarms will be sent to the CO Building.
2.
WINDERMERE PUMP STATION RENOVATION
This project involves the Windermere
Pump Station (WPS). The work of this
project includes the replacement of the two bars screens and conveyor system as
well as the wet well dewatering pumps.
The #2 and #3 raw sewage pump VFD's will also be replaced. The new VFD's will be able to communicate
with the plant's PLC system using remote I/O.
The two existing VFD's will be similarly configured. FPS will
investigate the condition of all 4 raw sewage pumps and motors and recommend
corrective action.
The existing generator control panel
will be replaced with a new panel equipped with automatic start and loading
features. Renovation of the HVAC
system, doors, windows and fencing will also be required. The hydraulic system will be renovated. The PLC and the telemetry system, the
lighting system and the security system will be upgraded. Finally, the project will include the
replacement of the existing flowmeter and installation of new gas detection
system.
3. BACK UP POWER FOR SECONDARY AND BLOWER
REPLACEMENT
The back up power system should be
able to supply all of the power required to operate the plant in a stand alone
mode and peak shave. This project will
also provide additional air blowers to increase the air supply capacity by
100,000 SCFM for the biological treatment process.
This project will require the
successful bidder to perform the engineering services and provide an overall
plan for the project to provide electrical power to include:
Electrical
switching and distribution network, generation equipment with duel fuel
ability, electrical substations, power transmission requirements, new air
blowers, examination of air delivery system, removal of existing diesel engines
and structural analysis of ME building to house the new equipment.
4.
EQUALIZATION BASIN
The Consultant will design an
equalization basin with a minimum capacity of 60 million gallons. The basin will be located either at the
Harrison Marina site, on the golf course adjacent to the Bay View plant, or
other feasible location. The basin will
be designed to capture and store, during storm events, additional wastewater
above and beyond the capacity of the existing plant for treatment at the wastewater
plant once flow to the plant is reduced.
The basin is expected to be utilized between 10 and 30 times a
year. The rest of the year the basin
will remain empty.
The equalization basin, actually a
set of basins or tanks, shall be constructed of suitable material and shall
have multiple dividers and gates with options to vary the basin size or number
of individual basins or tanks to be used.
Isolation gates, large valves, drainage pumps, feed pumps and weirs will
be used to facilitate filling and draining of the individual basins. The Consultant will provide a basin or tank
cleaning system to flush the solid content of the wastewater remaining after it
is drained. This system must be
maintenance free, automated and integrated with the plant’s control
system.
When selecting materials for the
basin, special design consideration shall be made for corrosion control. The basin will be filled and emptied often,
providing the concrete with much exposure to corrosion and freeze thaw cycles. Gates, weirs, and other equipment shall be
made of corrosion resistant materials or painted with corrosion resistant
coatings.
The Consultant will review the
existing pumping capacity of Bay View, East Side and Windermere pumping
stations, preliminary treatment facilities, elevations of the existing main
interceptors and force mains coming into the plant, and make a recommendation
for improvements needed to fill and drain the equalization basin. The consultant shall look at and develop the
most feasible method for additional preliminary treatment facilities which must
be maintenance free, automated and integrated with the plant’s control system.
Odor control must be included. A life cycle cost study will be performed on
all odor control options proposed by the Consultant. These options will include, but not be limited to, pre-aeration,
chemical addition, odor retention basin, mixing systems, dry and liquid
scrubbers. The facility must be
maintenance free, automated and integrated with the plant’s control system.
The Consultant will investigate and
make recommendations on a back-up power system for the equalization basin
complex. The Consultant will perform a
life cycle analysis on all options.
This system will be integrated with the plant’s existing and planned
back-up power systems. The system must
be capable of an automatic start and loading sequence and an uninterruptable
return to utility power upon command from the plant’s computer control system.
This project includes the
preparation of a 401 and 404 permit for the Ohio EPA and Army Corps of
Engineers should the project be located at the Harrison Marina site. The permits will include mitigation of lost
water surface, sediment sampling, sediment characterization and the design of a
retaining wall at the river.
Title work and appraisal of the
properties associated with the Harrison Marina location have been ordered by
the City. All other work to be
performed by the Consultant.
5.
SECONDARY CLARIFERS
The Consultant will design a new
final tank designated as final tank #13.
The final tank will be located next to final tank #12 and will be the
same size and configuration. This
project will be designed to increase the firm capacity of the final clarifiers
from 170 MGD to 195 MGD.
This new final tank will be filled
and emptied often, providing the concrete with much exposure to corrosion and
freeze thaw cycles. The final tank will
normally be put on-line during storm events or when other final tanks are out
of service for maintenance. During dry
weather flows the final tank will be empty.
This project will include the
addition of one new sludge withdrawal pump and flow meter identical to the
existing pumps and two new mixed liquor feed pumps. The new sludge withdrawal pump will be located in the Sludge
Withdrawal Pump Station (SWPS). The
pump will have its own variable frequency drive (VFD) and will be automated and
integrated with the plant’s control system.
The VFD will be located in the SWPS.
Power for the VFD, pump and flow meter can be taken from Power Panel 4
or the lightning panel located in the SWPS.
Flow is provided to final tank #12
using four low head high capacity pumps.
The Consultant must design two new wet wells, cross over piping and flow
meters for each of the two new mixed liquor pumps. Each pump will have its own variable frequency drive (VFD) and
will be automated and integrated with the plant’s control system. The VFD’s will be located in Gallery
Building #3. Power for the VFD’s, pumps
and flow meters can be taken from Power Panel 3 or the lightning panel located
there.
A splitter box to control flow to
each final tank will be needed along with all process and drainage piping,
valves and tank controls. The new tank
will be automated and integrated with the plant’s control system.
The Consultant will design a new
secondary diversion chamber to replace the existing diversion chamber. This chamber allows flow to be diverted from
the swirl concentrators to the aeration tanks.
This diversion chamber will be designed for a firm capacity of 25 MGD
with consideration being taken for future expansion. This chamber will include a flow monitoring device.
The Consultant shall investigate and
develop the most feasible method to provide flow to the diversion chamber then
to the aeration tanks. The chamber and
all associated equipment must be maintenance free, automated and integrated
with the plant’s control system.
6.
BALLASTED FLOCCULATION FACILITY
The Consultant will plan and conduct
a 12 month pilot study of the ballasted flocculation process. This will be done, if possible, with a truck
mounted test facility. From these
results, the Consultant will size the facility and begin design. The design of
the facility will last for an additional nine months. The study will also include various disinfection alternatives
including the use of ultraviolet light or sodium hypochlorite at the end of the
wet weather system.
The Consultant will design a wet
weather treatment facility (WWTF) composed of a ballasted flocculation process
sized to handle a firm capacity of 185 MGD of raw combined sewage. This facility will come on line when the
plant flow exceeds the 195 MGD and the equalization basin is full or when the
plant flow exceeds 195 MGD and the pumping capacity to the equalization basin
is exceeded. This facility will be
housed in its own building and will be located at the mooring basin site. This facility and all associated equipment
must be maintenance free, automated (if possible) and integrated with the plant’s control system.
The WWTF will include a final
effluent pump station with a firm capacity of 195 MGD. This station will be used when the river
level rises and interferes with the plant’s ability to discharge effluent. The plant effluent flow and the wet weather
treatment facility flow must be sampled separately, recombined and sampled
prior to discharging to the river. Post
aeration for the combined flows must maintain an effluent DO of 5 mg/l. The Consultant will determine, using life
cycle costs, the most economical pumping configuration and post-aeration
option. The pump station, aeration
system and all associated equipment must be maintenance free, automated and
integrated with the plant’s control system.
A new disinfection process for the
wet weather flows will be designed based on the results of the pilot
study. The Consultant will consider a
new disinfection process sized to handle the plant’s effluent flow along with
the wet weather flow. A life cycle cost
analysis will be performed on the disinfection alternatives. All necessary piping, pumps, controls,
chemical feed systems, contact tanks and buildings will be included under this
project. The disinfection system and
all associated equipment must be maintenance free, automated and integrated
with the plant’s control system.
The Consultant will review the
existing pumping capacity and preliminary treatment facilities and make a
recommendation for improvements needed to provide flow to the wet weather
treatment facility. If necessary, the
Consultant will perform life-cycle cost studies on various preliminary
treatment and pumping alternatives. All
pumping systems, preliminary treatment systems and all associated equipment
must be maintenance free, automated and integrated with the plant’s control
system.
Once the project is complete, the Consultant will
perform a two year full scale study titled the “Ballasted Flocculation Study.”
7.
GRIT AND SKIMMING TANK SEPARATION
The main objectives of I-45 are to
separate the plant's two skimming tanks into four independent skimming tanks/
grit tank process trains. A cross
channel complete with motorized slide gates will be installed to allow any of
the grit tanks to be routed through any skimming tanks when other tanks are off
line for repairs. The inlet gates to
the existing grit tanks are being replaced.
New skimming equipment will be
installed in each of the skimming tanks along with an automated tipping
tube. The primary clarifier scum
collection system is being converted back to a gravity drain system that will
discharge into a scum pit located outside of the pre-air building. Two scum chopper pumps will transfer the
scum to the grease concentrators. New
air flow meters and valve actuators will be installed on the air lines. A drainage pump station will be constructed
in the existing scum ejector pit to pumps located in the basement of the
pre-air building. This pump station
will be used to dewater the primary clarifier for maintenance.
The skimming tank collector
mechanism, tipping tube and motorized gates will be automated and controlled
through the plant's control system.
Reference OEPA permit to install
03-12308.
8.
IMPROVEMENTS TO CSO's
COLUMBUS CSO
The sanitary area from Manhattan
Blvd. south to Forest Cemetery and from Chestnut Street east to Counter Street
is served by a predominately separate sanitary sewer system, which drains into
the combined sewers east of Michigan Avenue on Columbus Street.
Drainage from the sanitary and
combined sewer systems travels to a 102" sewer located in Columbus Street
and on to a regulator located east of the intersection of Columbus and Summit
Streets. A 36" sewer, which
carries flow from a combined sewer area bounded by Summit, Chicago, Ontario,
and Troy Streets is believed to connect to the 102" sewer just west of
Summit Street. Storm overflows exit the
regulator through a 102" pipe and discharge into the Maumee River. A 24" diameter return line carries dry
weather flows from the regulator to an 87" sanitary interceptor located on
the east side of Summit Street.
The sanitary drainage for the
Columbus Street regulator is estimated to be 676 acres. The storm drainage is estimated to be 205
acres. Separation of the sanitary sewer
flow from the combined sewer is expected to result in overflow reduction.
The Columbus Street CSO Optimization Project includes verifying pipe
configuration, smoke and dye testing, recommendations to separate public
sources of inflow, look at separation of sewers and design improvements.
PARKSIDE CSO
The Parkside CSO project is
primarily concerned with the area around Calvary Cemetery which is served by
separate sanitary sewer system. This
area is located near the Upton and Bancroft as well as the Upton and Door
intersections. The system in this area
does overflow to the combined sewer system at Ottawa River and Monroe
Street. The area serves approximately
600 acres of sanitary sewers.
The basic purpose of this project is
to minimize inflow in this area, monitor the flow rate to ensure the inflow is
minimized and then construct the required sanitary sewers to divert their flows
directly to the interceptor.
This project has not been designed yet and it will
be the responsibility of the Consultant to examine the area in detail and
develop the project.
MAUMEE CSO
This CSO is located at Maumee Avenue
and Orchard Street in South Toledo.
This project has not been designed yet.
The basic objective of this project is to reduce the overflow from this
structure.
The return sewer line from this
regulator is a 5,880 ft. long 18" diameter sewer with a slope of 0.25
%. Overflows from this regulator occur
at lower rainfall levels than other regulators which service similar
acreage. The overflows could be caused
by flow restrictions such as sedimentation buildup, plugging by debris or
excessive headloss. The exact cause
needs to determined and corrected.
9.
ELIMINATION OF SSO's IN POINT PLACE
The Director Findings and Orders
from the Ohio EPA set forth the time schedule under which the City of Toledo
must eliminate the SSO's that are in Point Place. This project is underway and to date, the City of Toledo has been
able to meet all of the specified deadlines.
The project is divided into phases
with a phase 1 completion date of January 2001. In this phase, the City of Toledo was to do intensive sewer
cleaning and correct the deficiencies in the 116th Street interceptor as well
as construct a relief pump station at Manhattan Boulevard. Phase 2 remediation will examine the results
of the phase 1 investigations and suggest alternatives for corrective action
along with the costs. A detailed plan
for corrective construction will be submitted to OEPA for applicable permits by
June 2003. Phase 2 improvements must be
complete by November 1, 2006.
Another part of phase 2 is the River
Road SSES work referenced below.
10.
SSES in RIVER ROAD and MIDLAND AREA
This part of the SSO elimination
project is centered on an area in South Toledo. The first phase of the project involves smoke testing and
televising the sanitary sewers in this area.
This portion of the project is currently underway. Phase 2 involves the collection of data,
analyzing it and making recommendations to eliminate SSO. Phase 3 of the River Road project will be
submission of plans and the construction of the remediation efforts by June 1,
2004. Phase 4 is a placeholder if the
Phase 3 efforts need additional improvement.
The final construction must be complete by November 1, 2006.
11.
CSO SYSTEM WORK
This portion of the work involves
implementing the results of a two-year collection system study to meet the
objectives of the US EPA Combined Sewer Overflow Policy. The team will be required to first establish
a Long Term Control Plan (LTCP) that addresses or considers the results of all
of the studies listed herein and minimizes the overflows from the CSO's. This LTCP will take into consideration the
characterization of the collection system through monitoring and modeling to
achieve a through understanding of the sewer system, the response of the system
to rain events, the characteristics of the overflows and the water quality
impacts that result from CSO's. Many of
the studies that we are asking the engineering teams to undertake speak
directly to this goal. The LTCP must
also address the issues of the nine minimum control standards for CSO's put
forth by the US EPA.
Currently, the City of Toledo has
combined sewers that serve approximately 17,600 acres. Three interceptor sewers collect dry weather
flow from combined sewers at the regulator chambers. Wet weather combined flows discharge to the Maumee River, Ottawa
River or Swan Creek at 31regulator overflow locations.
Extensive improvements to the
collection system have included both major and minor projects resulting in the
overall reduction of combined sewer overflows. The major projects with
significant impact on overflow reduction include: the Ten Mile Creek Relief
Interceptor, Windemere Pump Station, Swirl Concentrators, combined sewer
outfall tide gates and regulator modifications.
The construction and activation of
three independent CSO Abatement Pipeline Storage Tunnels are the most
significant actions taken by the City to improve water quality of the Maumee
River along with downtown waterfront area and of Swan Creek along the CSO
reach.
12.
TWO YEAR STUDY OF BALLASTED FLOCCULATION
The purpose of the two-year study is to establish
the daily operating parameters and effectiveness of the new facility. In setting up the study, the Consultant will
consider the manufacturers operating recommendations and use them as a
reference point. The Consultant shall
develop appropriate scientific mechanisms such that the data developed from
this study will be valid in establishing the operating range of the
facility. The Consultant will also establish
the range of flows that can be properly treated in the facility.
The Consultant shall, 12 months
after the start of our contract, submit to the US EPA a work plan for the
testing of this facility. The plan
shall include, but not be limited to (a.) the effectiveness of the facility to
remove suspended solids, carbonaceous biochemical oxygen demand, total Kjeldahl
nitrogen (TKN) and ammonia (b.) any difficulties encountered in or limitations
involved with using these facilities over a range of flow conditions, chemical
feed rates and other operational control parameters and (c.) measures that
Toledo has taken to optimize the use of the facility.
After the study is complete, the
Consultant will complete a written report that will be submitted to the US EPA
within 60 days after proper consultation with the City.
13.
FLOW CHARACTERIZATION STUDY
The flow characterization study is
fully explained on pages 15 through 18 of the attached draft consent
decree. The Consultant is advised to
take note of the time requirements for (a.) the work plan within 30 days of our
contract (b.) the one year time period for data collection and (c.) the
requirement for the report within 30 days following the completion of the
study.
The City of Toledo has installed flow-monitoring
devices and has collected data regarding the amount of wastewater in the system
during rain events. It is the
responsibility of the Consultant, to review this information and determine the
usefulness of this data and determine what additional data will need to be
collected. The current data will be
available for inspection at the Division of Water Reclamation.
14.
WATER QUALITY STUDY AND MODEL
The City of Toledo, in conjunction
with Limno-Tech, Inc. has already performed an extensive water quality
study. This will form the basis of the
work described in the draft consent decree on pages 18 through 21. The major new area of investigation will be
sediment oxygen demand and its relationship to dissolved oxygen in Swan Creek
and the Ottawa River. The Consultant
will be required to closely review the previous work and coordinate the new
investigations such that a comprehensive water quality report is obtained. The
Consultant will also develop the proper water quality model after extensive
impute from City representatives and consistent with the directions listed on
pages 24-25 of the draft consent decree.
Here again, the Consultant is
reminded to check the time frames and report requirements.
An Executive Summary of the water
quality report is attached. A complete
copy of the report is available at the Division of Water Reclamation.
15.
HYDRAULIC MODEL
The Consultant will develop a hydraulic model of the collection system
to be used in all phases of the evaluation of the system and the handling of
wet weather flows. The detailed
information of the requirements of the study are listed on pages 22-24 of the
draft consent decree.
The Consultant will use the
information developed in the flow characterization study as a basis for this
model. To that end, the City of Toledo
has some background information available for inspection at the Division of
Water Reclamation.
16.
LONG TERM CONTROL PLAN
The Long Term Control Plan seeks to
integrate the various plans and models into one single document that addresses
the reduction of flows from our CSO outfalls in order to comply with the CSO
policy. The pertinent characterization
of this document is found in the draft consent decree pages 25-31. It is the item which receives the most description
in this document and is important to the City of Toledo as well as the US EPA.
The studies that are being performed
as part of this work can be characterized as informational research. The flow characterization, water quality
study and hydraulic models provide the informational basis upon which design
and implementation can proceed. Once
the information collection phase has been complete, the consultant will begin
to evaluate the alternatives. This will
require the engineering teams to concentrate their expertise to suggest the
most effective yet most economical solution.
Following the conceptual design
phase, there will be a review procedure and then detailed design. This design will require the integration of
all of the talents of the entire team as well as the City of Toledo's efforts
to produce an acceptable product.
Construction of the remedy of the
sewer system will be completed in the second half of the project. At present, it is unclear what type of work
or engineering will be necessary. It
is, therefore, impossible for the Consultant to provide a price for these
services. The City of Toledo has
included, in this proposal, a mechanism for a price re-opener once the two-year
study is complete (see CSO System Work).
It is, however, possible for the Consultant to provide a price for the
two year LTCP study.
17.
PUBLIC PARTICIPATION PLAN
This is an aspect of the project
that must not be overlooked. The
development of a clear, concise communication mechanism could be the difference
between acceptance and rejection of the project. The Consultant will be required to formulate a public relations
plan that can effectively communicate the engineering ideas to the City of
Toledo, the regulator agencies and the general public. It is in this area that the Consultant and
the City must work especially close to provide a clear vision of the project.
In the draft consent decree there is
a requirement that this public involvement be active during the planning and
formulation of the LTCP. We believe
that it is important to have this aspect functioning throughout the entire
project.
The public relations efforts of this
project will have as its fundamental charge the duty to explain to the public
the benefits derived from the improvements being installed in the wastewater
system. Large expenditures of public
funds will be used to build the improvements and it is critical that we are
able to explain how the environment will be improved.
The Consultant is instructed to
present, with their proposal, a summary of this plan.
18.
SEWER SYSTEM MONITORING AND REPORTING PLAN
This section will involve a timely reporting of any SSD to a body of
water to the Ohio EPA. A reporting
mechanism will need to be developed such that all of the pertinent information
is recorded and conveyed to Ohio EPA.
This work will also involve a record
keeping function during wet weather times and the responses that the Division
of Sewers and Ditch Drainage provide to residential customers.
The details of the content of the
Sewer monitoring can be found in the draft consent decree on pages 35-36.
19.
SANITARY SEWER DISCHARGE RESPONSE PLAN
This work requires the consultant to
develop a plan that will identify and establish procedures to handle any sanitary
sewer discharges with the appropriate public notice. This plan will also include the provisions for limited access to
the area, remediation if necessary, contingency plan for emergency response and
dispatch of city personnel.
A summary of this work can be found
in the draft consent decree on pages 36-38.
20.
SANITARY SEWER O & M PLAN
This work entails the creation of a
management, operation and maintenance ("MOM") plan for the collection
system. The City of Toledo has clearly
defined rules and procedures although most of these have never been collected
in a single document. The Consultant
will be required to work with the Division of Sewers and Ditch Drainage to
compile and create the necessary document.
It is expected that the Consultant can draw upon past experience to
create this document.
This plan will include, but not be
limited to, all aspects of the collection system operation including cleaning,
televising, inspecting, corrective maintenance, information tracking,
maintenance schedules and pump station inspections.
The summary of the elements of the
plan are to be found on pages 38-42.
21.
WWTP O & M PLAN
The Division of Water Reclamation
does have an existing O & M plan that is current and does fulfill most of
the provisions of this requirement. The
Consultant will need to review these plans and determine if additional work
will be necessary to comply with the outline provided in the draft consent
decree on pages 42-43.
There are a number of anticipated
changes such as a wet weather facility that are not part of our current plant
and will need to be added as they are constructed. It will be the responsibility of the Consultant to continually
update both the WWTP O & M plan and
the Sewer System O & M plan as new processes or change are made.
22.
WORK PLANS
The draft consent decree has listed
in a number of the tasks, a work plan due within 30 days of the entering of the
consent decree. A great deal of
discussion was undertaken to describe the nature of these plans and detail
necessary to comply with their submission.
The US EPA indicated that these plans were to be approximately two pages
in length and are to outline the approximate time frames and critical path
issues to be followed. They are not a
preliminary design nor are they expected to be done in a significant level of
detail. They will, however, need to
document a course of action that the US EPA can follow.
23.
INDUSTRIAL WASTEWATER RELEASE
MINIMIZATION PLAN
This work entails the review of our
pre-treatment plan to ensure that we are minimizing the discharge of industrial
pollutants through CSO's and SSD's. The
current pre-treatment program is active and should provide most of this
information. The Consultant can review
this program at the Division of Environmental Services. A brief summary of the requirements is
contained in the draft consent decree on page 38.
ATTACHMENT TO COMMENTS
BY
DONALD M. MOLINE
APRIL 30, 2001
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PROJECT
COST (In Thousands of Dollars) |
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PROJECT |
2000 |
2001 |
2002 |
2003 |
2004 |
2005 |
2006 |
2007 |
2008 |
2009 |
2010 |
2011 |
2012 |
2013 |
2014 |
2015 |
TOTAL |
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(Wet Weather
Improvements) |
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1. Mooring Basin Construction |
$- |
$5,350 |
$3,000 |
$- |
$- |
$- |
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$8,350 |
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2. 60 MG Equilization Basin |
$- |
$7,000 |
$4,000 |
$10,000 |
$25,000 |
$24,000 |
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$70,000 |
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3. Pump Station and Swirl Concentrators |
$- |
$650 |
$2,700 |
$1,000 |
$300 |
$- |
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$4,650 |
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4. Final Tank No. 13 |
$- |
$600 |
$1,200 |
$4,500 |
$1,000 |
$- |
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$7,300 |
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5. Wet Weather Treatment Facility |
$- |
$410 |
$6,000 |
$13,000 |
$3,400 |
$100 |
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$22,910 |
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6. Final Effluent Pump Station |
$- |
$500 |
$2,200 |
$2,000 |
$500 |
$- |
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$5,200 |
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TOTAL |
$- |
$14,510 |
$19,100 |
$30,500 |
$30,200 |
$24,100 |
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$118,410 |
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$118,410 |
(Other WWTP
Improvements) |
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1. Secondary Plant Improvements |
$3,800 |
$3,800 |
$2,200 |
$- |
$- |
$- |
$- |
$- |
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$9,800 |
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2. Skimming Tank Separation |
$295 |
$4,100 |
$- |
$- |
$- |
$- |
$- |
$- |
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$4,395 |
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3. Major Pump Station Renovation |
$135 |
$1,420 |
$2,400 |
$500 |
$- |
$- |
$- |
$- |
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$4,455 |
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4. Back-up Power System |
$- |
$580 |
$3,000 |
$200 |
$- |
$- |
$- |
$- |
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$3,780 |
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5. WAS Thickening Renovations |
$- |
$- |
$300 |
$3,000 |
$- |
$- |
$- |
$- |
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$3,300 |
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6. ME BldgRenovation/Blower Replacemt |
$- |
$620 |
$500 |
$3,000 |
$1,200 |
$- |
$- |
$- |
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$5,320 |
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7. Blower Building Renovation |
$- |
$- |
$- |
$500 |
$3,000 |
$- |
$- |
$- |
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$3,500 |
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8. Detritor/Grit Tank Replacement |
$- |
$- |
$- |
$- |
$1,000 |
$3,000 |
$6,000 |
$5,000 |
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$15,000 |
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TOTAL |
$4,230 |
$10,520 |
$8,400 |
$7,200 |
$5,200 |
$3,000 |
$6,000 |
$5,000 |
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$49,550 |
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$49,550 |
(Sanitary Sewer
Overflow Elimination) |
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1. Point Place Phase 1 Construction |
$4,100 |
$- |
$- |
$- |
$- |
$- |
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$4,100 |
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2. Point Place Phase 2 Study-Construct. |
$- |
$100 |
$500 |
$6,400 |
$7,000 |
$6,000 |
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$20,000 |
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3. River Road/Detroit Av SSO Elimination |
$800 |
$1,000 |
$1,500 |
$750 |
$750 |
$750 |
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$5,550 |
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TOTAL |
$4,900 |
$1,100 |
$2,000 |
$7,150 |
$7,750 |
$6,750 |
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$29,650 |
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$29,650 |
(Interceptor
Inspection/Rehabilitation) |
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1. Swan Creek Interceptor Rehabilitation |
$3,300 |
$2,500 |
$800 |
$- |
$- |
$- |
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$6,600 |
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2. Remaining Interceptor Inspect/Rehab |
$- |
$600 |
$2,000 |
$2,000 |
$2,000 |
$2,000 |
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$8,600 |
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TOTAL |
$3,300 |
$3,100 |
$2,800 |
$2,000 |
$2,000 |
$2,000 |
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$15,200 |
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$15,200 |
(I/I Reduction
Program) |
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1. Sewer System Evaluation Survey |
$- |
$650 |
$650 |
$650 |
$650 |
$650 |
$650 |
$- |
$- |
$- |
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$3,900 |
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2. Sewer Rehabilitation Program |
$- |
$- |
$2,000 |
$2,000 |
$3,000 |
$3,000 |
$3,000 |
$3,000 |
$2,000 |
$1,000 |
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$19,000 |
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TOTAL |
$- |
$650 |
$2,650 |
$2,650 |
$3,650 |
$3,650 |
$3,650 |
$3,000 |
$2,000 |
$1,000 |
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$22,900 |
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$22,900 |
(CSO Abatement
Program) |
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1. Columbus, Parkside & Maumee Reduct. |
$- |
$250 |
$3,000 |
$1,500 |
$1,000 |
$- |
$- |
$- |
$- |
$- |
$- |
$- |
$- |
$- |
$- |
$- |
$5,750 |
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2. Ottawa River CSOs - Phase 1 |
$- |
$250 |
$250 |
$5,000 |
$8,000 |
$7,000 |
$5,000 |
$- |
$- |
$- |
$- |
$- |
$- |
$- |
$- |
$- |
$25,500 |
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3. Ottawa River CSOs - Phase 2 |
$- |
$- |
$- |
$- |
$- |
$250 |
$2,000 |
$5,000 |
$3,250 |
$- |
$- |
$- |
$- |
$- |
$- |
$- |
$10,500 |
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4. W. Side Maumee (CSOs # 32 & 33) |
$- |
$- |
$- |
$- |
$- |
$- |
$500 |
$3,000 |
$4,000 |
$2,500 |
$- |
$- |
$- |
$- |
$- |
$- |
$10,000 |
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5. W. Side Maumee (CSOs # 23 to 26) |
$- |
$- |
$- |
$- |
$- |
$- |
$- |
$1,500 |
$6,000 |
$15,000 |
$8,000 |
$- |
$- |
$- |
$- |
$- |
$30,500 |
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6. Downtown Tunnel (CSO 1&2) Upgrade |
$- |
$- |
$- |
$- |
$- |
$- |
$- |
$- |
$500 |
$2,000 |
$5,000 |
$2,000 |
$- |
$- |
$- |
$- |
$9,500 |
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6. E.Side Maumee River (CSOs # 7 to 9) |
$- |
$- |
$- |
$- |
$- |
$- |
$- |
$- |
$- |
$5,000 |
$15,000 |
$30,000 |
$20,000 |
$- |
$- |
$- |
$70,000 |
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7. E.Side Maumee River (CSOs # 4 to 6) |
$- |
$- |
$- |
$- |
$- |
$- |
$- |
$- |
$- |
$- |
$- |
$3,000 |
$10,000 |
$20,000 |
$17,000 |
$- |
$50,000 |
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8. Swan Creek Tunnels Upgrade |
$- |
$- |
$- |
$- |
$- |
$- |
$- |
$- |
$- |
$- |
$- |
$- |
$1,000 |
$6,000 |
$10,000 |
$8,000 |
$25,000 |
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TOTAL |
$- |
$500 |
$3,250 |
$6,500 |
$9,000 |
$7,250 |
$7,500 |
$9,500 |
$13,750 |
$24,500 |
$28,000 |
$35,000 |
$31,000 |
$26,000 |
$27,000 |
$8,000 |
$236,750 |
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$236,750 |
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TOTAL COST
SUMMARY |
$12,430 |
$30,380 |
$38,200 |
$56,000 |
$57,800 |
$46,750 |
$17,150 |
$17,500 |
$15,750 |
$25,500 |
$28,000 |
$35,000 |
$31,000 |
$26,000 |
$27,000 |
$8,000 |
$472,460 |
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$472,460 |
ssfund.capproj.15yr |
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