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HomeMy WebLinkAboutMDOC - TSEP applicationDecember 15, 2004 Kenneth Olsen, Jr, Mayor City of Laurel PO Box 10 Laurel, MT 59044 M NTANA Department of Commerce COMMUNITY DEVELOPMENT DIVISION P.O. Box 200523 i- Helena. Montana 59620-0523 Phone; 4064141-2770 * Fax:4~)6-841-2771 Dear Mr. Olsen: Attached is the Department of Commerce's completed report describing how your application and project was scored in the Treasure State Endowment Program (TSEP) grant competition. It is included in the report that the Department will provide to the Legislature in January 2005. Also attached is the final technical review report completed by the engineers under contract with the Department. it provides greater detail concerning the scoring of Statutory Priorities #1 and #3. The Governor's Budget and Program Planning Office (OBPP) has projected that TSEP will have approximately $15.6 million during the next biennium to fund projects. That would mean that TSEP would be able to fund the first 39 projects, with projects #40 through ~42 being recommended for funding only if sufficient funds become available. However, the Legislature's Interim Revenue Committee projected a higher amount of $18,200,618 during the next biennium to fund projects. That would mean that TSEP would be able to fund all of the projects at the amount recommended by the Department. While the Department's recommendations to the Legislature will be based on the OBPP revenue projection, the Legislature is more likely to use the amount they projected when deciding on how many projects to fund. The Legislature will make the final decision on how many projects to fund through House Bill 11, which is the bill assigned to appropriate funds for the TSEP projects. The Legislature's Joint Long-Range Planning Subcommittee, which initially hears the bill, holds a public hearing on each project. The hearings have generally taken place early in the session, typically in January. At that time, applicants will have an opportunity to provide Legislators with information about their projects. We strongly recommend that each of you have a representative present at the hearing, in order to testify on behalf of your project and answer any questions committee members may have about your project. Failure to be represented at the hearing was looked upon negatively by the committee during the last session. The Department will notify you as soon as those hearings are scheduled. If you ara interested in following HB 11, you can track the bill yourself on the Internet by going to http:/llaws.leq.state.mt.us/pls/lawsO511awO203w$.startup. If you have any questions, please call me at 841-2785, or you can email me at jed,qcomb~,state.mt.us. Sincerely, Manager Treasure State Endowment Program Two attachments c: Crystal Bennett, MEA Jason Mercer, Morrison-Maierle This application received 3,180 points out of a possible 4,900 points and ranked 29th out of 47 applications in the recommendations to the 2005 Legislature. MDOC recommends the requested TSEP grant of $$00,000. Funding Type of Amount Status of Funds Source Funds TSEP Grant $ 500,000 Awaiting decision of legislature RRGL Grant $ 100,000 Awaiting decision of legislature City Local $ 433,000 Committed Project Total $ t,033,000 Median Household Income: $32,679 Total Population: 6,255 Percent Non-TSEP Matching Funds: 52% Number Of Households: 2,529 Monthly Percent of Monthly Percent of Rate Tar~let Rate Rate Ta~et Rate Existing Water Rate: $39.96 Target Rate: $56.37 Existing Wastewater Rate with proposed Rate: $30.10 TSEP Assistance: $72.06 128% Existing Combined Rate without TSEP Rate: $70.06 124% Assistance: $73.65 131% Project Summary History - The City of Laurel's wastewater collection system was originally constructed in 1910. A majority of the collection system is comprised of vitrified clay pipe and has been in service for 50 to 100 years. More recent additions have been made with PVC pipe. The treatment plant is approximately 20 years old. Problem - The City's wastewater system has the following deficiencies: increasing amounts of infiltration and inflow are impacting the capacity of sewer mains, undersized mains and mot intrusion within the collection system, [] failure or back-up of sewer mains have led to release of raw sewage in basements and homes, the two sewage lift stations are nearing the end of their useful life, during peak flow events the plant is not able to treat to permitted effluent limits, and [] several areas of the treatment plant have been identified as needing upgrades in the near future to ensure continued permit compliance. Proposed Solution - The proposed project would replace about 6,500' of trunk mains with new 24", 36" and 48" diameter mains. Note: The proposed solution does not resolve the problems related to the smaller diameter lines within the collection system, lift stations, or the upgrade of the treatment plant, which will be dealt with in other projects. Therefore, those deficiencies were not taken into consideration in the scoring of Statutory Priority #1. Governor's Budget Long-Range Planning Subcommittee Treasure State Endowrnent Program 173 Conclusion: The applicant sufficiently demonstrated that the public health and safety problems associated with the deficiencies in the wastewater system are likely to occur in the long-term if the deficiencies are not corrected, even though they have not been documented to have occurred yet. These Serious problems have a high probability of occurrence after chronic exposure and a moderate level of probability of occurrence in the near-term as a result of incidental, short-term or casual contact. Rationale: The MDOC technical review team noted that there are various deficiencies that could affect the public's health and safety, including: hydraulic surcharging of the primary ctarifier due to excessive groundwater infiltration, reduced ability to properly maintain rotating biological contactor units, poor treatment plant performance during peak flow events, and some increased potential for violation of discharge permit limits during peak flow events. Significant increases in influent flows at the treatment plant have been documented to occur due to the irrigation of pastures overlaying sewer trunk lines. These influent flows have caused surcharging of the primary c!a_rifi_er an_d are I£k_ely_~_o ceus~e~ _raw sCwag~ to b_e ove[tepped o_n to thegro~_nd or are likely to require that raw sewage be by-passed directly to the Yellowstone River. It is not clear from the PER if overtopping has ever occurred. The overtopping of sewage would likely be limited to the footprint of the existing wastewater treatment plant and would have a Iow probability of exposure to the general public. Overtopping represents a serious public health or safety problem that could cause illness, disease and environmental pollution. The hydraulic limitations of the pipeline between the primary clarifier and plant are not being repaired as part of this project and it is not clear if the problem would be completely eliminated by replacement of the trunk lines alone. However, it is likely that the majority of the problems with the primary clarifler are being eliminated by the proposed project. During peak flow events, treatment efficiency is likely reduced introducing some additional public health risk. The score for Statutory Priority #2 is based on a weighted analysis of two financial indicators with a total of 900 points possible. The scores for each of the two indicators are added together, with the total number of points possible for Statutory Priority #2 based on five levels. The fifth level is assigned to the group of applicants that reflect the greatest financial need. Indicator #1. Household Economic Condition analysis: The applicant placed in the third level and received 2t6 points. (This analysis accounts for 40 percent of the score for Statutory Priority #2. Each of the three sub-indicators are ranked and scored, with each accounting for 33 percent of the totar score for Indicator #1, Being ranked first indicates the most severe household economic conditions and is assigned the~ighest score: The scores for each-'$~ub-indtcator are ~dded-tOgether, with the total number of points possible for Indicator #1 based on five levels. The fifth highest level is assigned to the group of applicants with the most severe household economic conditions.) Median Household Income (MHI) ranked 34th out of the 47 applications. The percent of persons living at or below the Low and Moderate Income (LMI) level is 48.0 percent. The relative concentration of persons living at of below the LM! level ranked seventh out of the 47 applications. The percent of persons living at or below the Poverty level is 10.8 percent. The relative concentration of persons living at or below the Poverty level ranked 37th out of the 47applications. Indicator #2. Target Rate Analysis: The applicant placed in the third level and received 324 points. (This analysis accounts for 60 pement of the score for Statutory Priority #2. Each sub-indicator is ranked and scored. Scores are assigned based on how much difference there is between the applicant's Governor's Budget Long-Range Planning Subcommittee Treasure State Endowment Program 174 user rate and the target rate. The number of points possible for Indicator ¢Y2 is based on five levels. The fifth highest level is assigned to the group of applicants furthest over the target rate.) Conclusion: The applicant strongly demonstrated that it has proposed an appropriate, cost- effective technical design that will provide a thorough, long-term solution for its public facility needs. The preliminary engineering report (PER) is generally complete and there were only minor issues that were not adequately addressed. It does not appear that the issues would raise serious questions regarding the appropriateness of the solution selected by the applicant. Rationale: The MDOC technical review team noted that the comparison of alternatives was difficult to understand, and it was not clear what comparative ranking criteria were used to select the preferred alternative. For instance, there was no rationale for the alternative selections made for the trunk line or lift stations. A phased approach to resolving wastewater system problems in Laurel is in the process of being implemented. CDBG funds were being utilized in 2004 to install a new trunk sewer main on Alder Avenue, along with some other improvements. The applicant adequately assessed the potential environmental impacts. Any environmental concerns that were identified by the applicant were adequately addressed and no long-term adverse affects were noted. Conclusion: The applicant strongly demonstrated that it has made substantial past efforts to ensure sound, effective long-term planning and management of public facilities, and attempted to resolve its infrastructure problems with local resources. The MDOC review team did not score this priority higher primarily because it appeared that the applicant's planning efforts have only been in place for a relatively short time. Rationale: The applicant stated that it has had to raise water and sewer rates considerably in the past because of other projects: however, the applicant did not provide any specifics. The applicant stated that adequate operation and maintenance budgets have been maintained; in recent years, the City has added more than $100,000 to the sewer replacement fund. Reserves have allowed the City to construct the first phase of the wastewater improvements without additional rate increases. In anticipation of the proposed project and the depletion of the reserves, the City will be raising the sewer rates later in 2004 to rebuild its reserves and maintain reasonable operation and maintenance budgets; however, documentation for this future rate increase was not found in the application. The City has also been planning for water system improvements by implementing yearly water rate increases, beginning in 2003 through 2005. /MI individual service connections are metered. The applicant stated that it has completed a detailed capital improvements plan (CIP), a needs assessment, a separate recreation needs survey, a flood hazard mitigation plan, a draft growth policy, a draft transportation plan, and the City has begun a preliminary engineering study of the water system. A needs assessment was completed in 2000, with a separate needs survey specific to recreation in 2001. The CIP is a comprehensive five-year document adopted in 2003; the City has already addressed the highest priority of the ClP, the water intake structure, and its affordable housing shortage. A lighting special improvement district was dropped after the public hearing indicated a lack of support. The City is budgeting funds specifically for the purpose of completing projects identified in the CIP. The applicant stated that the problems to be resolved by the proposed project are not of recent origin. The entire collection system consists of aging pipe, which is not due to poor maintenance. The City has identified those trunk mains with the highest priority for replacement for this project. However, the applicant also stated that, historically, very little preventative maintenance was peRormed on the collection system. More recently, new public utilities staff has recognized the importance of routine Governor's Budget Long-Range Planning Subcommittee Treasure State Endowrnent Program 175 maintenance and has begun to proactively approach maintenance issues. The MDOC review team concluded that the City's O&M practices related to the wastewater system appear to be reasonable. Conclusion: The applicant strongly demonstrated that the project would enable the local government to obtain funds from sourees other than TSEP. The applicant demonstrated serious efforts to thoroughly seek out, analyze, and secure the firm commitment of alternative or additional funds from aJJ appropriate soumes to assist in financing the proposed project. The funding package for the proposed project is reasonable and appears to be viable. There are no major obstacles known at this time that wo?d hinder the applicant from obtaining the funds from the proposed funding sources. The MDOC review team did not score this priority higher primarily because the TSEP funds were not considered to be critical to completing the project, since the applicant's user rates would be less than 150 percent of target rate. Rationale.: The applicant has proposed a funding package consisting of TSEP and RRGL grants in combination with Iocal:reserves._Tbe applicant stated thatthey_conside;ed additional sources of funding including SRF and RD loans, as well as a CDBG grant. They chose not to pureue the loans in order to keep user rates down. They are not presently eligible for CDBG because of an ongoing project. The applicant stated that the RRGL grant is not dependent upon the award of TSEP funds. However, with the TSEP grant being nearly half of the project funds, it would be very difficult to fund the project without the participation of TSEP considering that the City does not qualify for other grants at this time and the City already carries a large amount of debt with very high user rates. Conclusion: The applicant sufficiently demonstrated that the proposed project represents a general infrastructure improvement that would indirectly increase business and job opportunities. However, the applicant did not adequately document that any specific businesses were dependent upon the proposed improvements or how businesses would directJy benefit from them. In addition, the applicant did not adequately document that the proposed project would directly result in the creation or retention of any long-term, full-time jobs other than those related to the construction or operation of the wastewater system. The proposed improvements should maintain and possibly increase the taxable valuation of the project area. Rationale: The applicant stated that the proposed project would not directly result in the creation or retention of jobs, or directly result in business expansion. However, the applicant stated that with the treatment plant currently overloaded, the City is unable to provide services for additional growth. The City is expected to seea Jarge amount of growthin the near futura. The proposed improvements are necessary to altow for the additional growth as well as keep the wastewater facilities operating under state and federal requirements. The proposed project would maintain and encourage expansion of the private property tax base. The proposed project would previde additional capacity in the treatment plant, allowing for expansion of services. Conclusion: The applicant did not adequately demonstrate that the proposed project is a high priority and has the support of the community. The applicant documented that it held a public hearing or meeting, but did not inform the community about the cost of the project and the impact on user rates. The MDOC review team did not score this priority higher primarily because of lack of documentation that the community was informed of therate increase. Governor's Budget Long-Range Planning Subcommittee Treasure State Endowment Program 176 Rationale: The applicant stated that it has held numerous public hearings regarding the wastewater facilities. Two public hearings were held in 2002 regarding the wastewater facilities plan, which allowed the public to provide input at an early stage in the planning process. In addition, two public hearings were held regarding the CDBG grant application for wastewater system improvements in May and April of 2003. The applicant provided documentation of these headngs and meetings. A public hearing specifically regarding the TSEP grant application was held on March 2, 2004. At the headng, the engineer gave a presentation of the overall project and the requirements of {he various funding sources were discussed. Twenty-four persons attended the hearing. The applicant stated there were no opponents to the project at the hearing; however, that statement could not be verified since there were no minutes from the meeting found in the application. The applicant stated that the public was informed that there would be a minimum rate increase of $1.50 per household as a direct result of the proposed project; however, the MDOC review team could not find any documentation in the application to vedfy the statement, and the actual increase appears to be about $2.00 per household. In addition, the applicant stated they received several letters of support for the project; however, other than a letter from the city council, these letters were not found in the application. The legal notice and sign-in sheet for the hearing was provided with the application. Minutes from the council workshop on February 24, 2004, showed that the project was briefly discussed and the hearing in March was.announced. There were also four newspaper articles from 2001 regarding needs survey results and sewer rate increases; and four copies of the City's newsletter from about 2001 to 2003. The newsletters included updates on sewer issues including detailed information on the 2001 sewer rate increase; copies of the articles and newsletters are contained in the application. The City has adopted a comprehensive five-year CIP. The applicant stated that the City has made considerable efforts to allow public input and provide active citizen participation through the numerous public hearings and the needs assessment that was conducted in 2000. Governor's Budget Long-Range Planning Subcommittee Treasure State Endowment Program 177 TSEPICDBG TECHNICAL REVIEW REPORT APPLICANT NAME: City of Laurel TYPE OF PROJECT: Wastewater COMMENTS PREPARED BY: Dave Aune, Entranco DATE: 9~28~04 TSEP Statutory Priority #1 - Projects that solve urgent and serious public health or safety Iproblems, or that enable local governments to meet state or federal health or safety standards. CDBG Criterion #2 _ Need for Project Does a serious deficiency exist in a basic or necessary community public facility or service, such as the provision of a safe domestic water supply or does the community lack the facility or service entirely, and will the deficiencies be corrected by the proposed project? (Describe all deficiencies that will be addressed by the proposed project and the seriousness of those deficiencies. Bdefly note any deficiencies that will not be corrected by the project. Describe the seriousness of the deficiency. ) Comment: Sedous deficiencies do exist in the wastewater collection system including: · Twenty-nine miles of old and poor quality sewer mains. Most of the collection system was constructed prior to 1910 and consists of clay tile pipe. Other pipe materials include asbestos cement, concrete, steel, cast iron and some PVC. The pipe condition was somewhat documented by TV inspection, but only 1/14~ of the system has been TV inspected. Given the age of the pipe and type of construction materials, it is likely that the sewer mains are in poor condition. The poor condition of these sewer mains could result in blockage and or failure that causes sewer to backup into homes and businesses. · The poor condition of the collection system has resulted in the necessity to clean some lines on a monthly basis to prevent blockage and backups. These lines are referred to as one-month lines by the City and consume much of the City's O&M resources. There are approximately a dozen one-month lines totaling 5,190 feet in length. This represents approximately 1 mile out of the 29 miles of sewer main in the City. · Excessive infiltration of groundwater into the collection system. This infiltration is due to the poor condition of the sewer mains, the high groundwater in the project area and irrigation of pasture where sewer trunk lines are buried. Again, the poor condition of the sewer mains Js documented by TV inspection and the Engineer's observation of 54 manholes. The high groundwater is documented by the reference to the Montana Bureau of Mines Report and is consistent with the geology of the area. Wells or other groundwater elevation data may have provided some additional insight in which sections of the collection are or are not inundated in groundwater. The impact of irrigation in pastures overlaying sewer trunk lines was well documented by chart flow recorders at the plant and simultaneous observation by City staff of when farmers were irrigating these fields. The increased influent flow can be as much as 1.0 mgd in a 48 hour period. More specific figures on exactly what trunk lines and fields were being discussed in the narrative would have been helpful to the reviewer's understanding. The average non-irrigation season Iow flow (which is assumed by the PER to be mostly infiltration) for the system is approximately 291,000 gpd and the average irrigation season Iow flow is 1.14 mgd. The peak Iow flow occurs in July and is approximately 1.9 mgd. Tl~ese Iow flows were documented by ~¥¢/TP flow measurements and verify that the overall system does experience infiltration, but does not document how the infiltration is distributed throughout the collection system. The flow observations performed by the Engineer does document that infiltration is widespread throughout the collection system and are not easily remedied. The PER did not present infiltration rates for various drainage basins within the collection system or attempt to prioritize collection system improvements based on infiltration rates. It did correctly give priority to replacingthe trunk lines in_opeo fie!ds an~ repl~c~i~g ~e one-month lines, but it is unclear how subsequent sewer main priorities will be developed. Excessive infiltration hydraulically overloads the ~ANTP increasing the potential for treatment performance problems and the potential to overflow the primary clarifier, which results in direct discharge of sewage on to the ground. High infiltration also reduces the hydraulic capacity of the poor quality sewer mains increasing the potential for blockage, failure and sewage backups. Applicant Comment: The applicant responded that no additional perspective would have been gained by additional data on groundwater levels. Reviewer Response: The reviewer is of the opinion that a more complete description of which sections of the collection system are and are not inundated by groundwater provides additional perspective and would allow the City to know where to focus their collection system rehabilitation efforts in subsequent phases of the overall project. Such an effort may a#ow better prioritization of future collection system rehabilitation efforts and serve to develop a better approach for the City of Laurel, a~Tain in subsequent phase of the overall project. It also allows the funding agencies to better understand the nature of the problem and proposed solutions. To provide this information is relatively simple and can be done for a very Iow cost and has been done in several PER's submitted to the TS£P Program. Applicant Comment: The applicant also took exception to the comment that "the PER did not present infiltration rates for various drainage basins within the collection system or attempt to prioritize collection system improvements based on infiltration rates..." Reviewer Response: The reviewer preserffed this statement as a simple statement of fact to help characterize the level of effort presented in the PER and has not passed judgment as to significance of this issue. This information needs to be reported to the ranking committee and its relative significance needs to be discussed. It was raised because a future phase of the project discusses a program of collection system improvements. The reviewer is not sug~Testing a $150,000 or $250,000 study be performed as implied in the applicant's response. Basin flow monitoring and the calculation of infiltration rates can be a very simple process that costs a few thousand dollars and allows better prtoritizatlcn of future collection system improvements. Much value can be added with this very simple effort. Such a level of effort has been performed on numerous PER's submitted to this program in the past. The data provided in Table I-A in Appendix I is the level of effort envisioned by the reviewer, but it fell slightly short of the desired product in that it did not quantify the flows and establish infiltration rates such that the reviewer could easily draw the same conclusion as the applicant or such that better collection system priorities could be developed. We do reject the applicant's generalization that it ia common knowledge that old clay tile services and mains cannot generally be cost-effectively rehabilitated. Such rehabilitation efforts have been successfully accomplished throughout the Country and in Montana. In Montana, several communities have made significant gains on infiltration including Choteau, Townsend, Dillon and Hot Springs, to name a few. It is also important to recognize, that, ff unattended, infiltration problems just get worse until infiltration overwhelms e system. Even though we cannot eliminate infiltration in old clay lines, we must manage and control it by periodic rehabilitation of the sewer collactionsystem. Theapplicantdidagreatjobofdocumen#ngthatinf#tretion has been excessive in both the winter and summer months and, therefore, raised the bar on the level of analysis needed to address the problem. Finally, in an attempt to bring the infiltration comment into context with the problem to be solved, the reviewer stated in the initial review that, despite the lack of more detailed infiltration analysis, the PER identified the proper priorities in replacing the trunk lines and the one-month lines. · Sewer main hydraulic capacity is adequate for current and future uses within the City limits for the next 20 years, but will be limited should developments in the surrounding area become part of the City. This was reasonably well documented by a summary of the hydraulic model performed by the Engineer and by flow projections presented in the PER. · The Main/Elm Street lift station is ever 40 years old and pumps, pipes and controls are in poor physical condition. The station has no stand-by power and the only failure alarm is a red light at the station. ']'he inlet is constantly submerged and when the Village Subdivision lift station is operating, a larger portion of the main is surcharged (a sewer map would have helped the reviewer understand the extent of this condition better). The valve vault is occasionally submerged as well. Capacity is adequate for the 20 year design life with no expansion ofthe existing City limits. The poor condition ofthe lift station increases the possibility of failure and resulting sewage backup in homes and businesses. The lack of emergency backup power and the poor alarm featuree also increase the potential for sewage backups. · The Village Subdivision lift station is nearly 20 years old and in satisfactory condition, but nearing the end of its service life. This lift station also has only a flashing red alarm light and the backup generator is not automated. Capacity is adequate for the 20 year design life. For the same reasons as discussed for the Main/Elm street lift station, this lift station also increases the Potential for sewage backup into homes, but to a lesser degree. · The WWTP generally has adequate capacity to service the needs of the City for the next 20 years if the City limits are not expanded. The hydraulic capacity of the WWTP is slightly exceeded. The WWTP is generally able to meet its permit limits except during the summer when infiltration flows are high. The plant always satisfies permit concentration limits and nondegradation load limits, but does not always meet the percent removal criteda for BCD and TSS, especially during the high flow pedods of the summer months. · Because the plant is over its hydraulic capacity, it is very difficult to perform maintenance on the RBC units because the plant will violate its permit limit for BCD and TSS when one unit is taken out of service. Due to nondegradation Icad limits, the Wvv'rP would need to significantly improve treatment efficiency to service an area larger than the current City limits. The plant has some immediate improvements that must be made to keep the facilities running and maintain the community's investment in the plant. These include replacement of the plant drain pump station, improvements to the plant water and potable water systems, new bar screens and grit chamber, improvements to the disinfection system, pipe repairs between the primary clarifier and the RBC units, and improvements to the RBC system. The proposed project does not solve all of the deficiencies identified in the PER and described above. The overall PER project has been divided in a Phase lA, lB and 2. Phase lA is currently being developed and it replaced some of the trunk lines in irrigated fields thereby solving 40% of the 1.0 mgd infiltration surge that is experienced at the plant. Phase lA also addressed the problem with potential failure of the WWTP drain pump station by replacing it. Applicant Comment: The applicant requested that the next three paragraphs of the original review report be removed since they address the degree to which the proposed project resolves treatment plant percent removal deficiencies or, in other words, the degree to which reducing peak flews at the plant will improve treatment plant performance. Reviewer Response: The paragraphs of interest were initially included to address the application's claim that treatment plant efficiency would be improved by the proposed project. This claim was made in the problem statement of the uniform application and therefore, required that the reviewer comment on the degree to which this particular problem is solved. The applicant has acknowledged that the proposed application did not intend to claim significant improvement to treatment plant efficiency and therefore we have eliminated much of the language of these paragraphs. The TSEP project proposed herein will address only one component of Phase lB of the PER and that is replacement of the remaining trunk lines in the open irrigated pastures. This will eliminate the remaining 60% of the infiltration peak flow being experienced at the WWTP. This will reduce the potential for the primary clarffier to overtop and release sewage directly on to the ground. The PER did not document if tills has ever occurred, but it was suggested on page 6- 20. However, we do agree with the applicant that the potential to overtop the primary clarifier is significant. In the statutory priority 1 section of the application, the impact of excess groundwater on the repair and maintenance of the RBC units is discussed and it is suggested that reducing the peak flows would reduce the potential for permit violations. The reviewer can agree that the risk of permit violations is reduced by eliminating peak flows, but as outlined below, a high base flow remains and it is therefore difficult to sayhow much benefit is gained. The ranking committee ~ may have to rely on a more practical assessment of this benefit based on discussion with the operations staff presented in the application and collective professional experience. The project will eliminate the 4.0 mgd (48 hour surges) being experienced at the WWTP. These surges, based on the discussion on page 5-g of the PER, appear to be an occasional addition to the base irrigation season infiltration flow. That is, the flows were reported to increase from 2.0 mgd to 3.0 mgd during pasture irrigation and then dropped back'to 2.0 mgd, which is very close to the July peak Iow flow of 1.9 mgd reported on page 5-8 of the PER. The majority of the total base infiitretion is coming from the collection system as a whole and not just the trunk lines being replaced. The proposed project does not address the hydraulic limitations (described as a bottleneck in PER) of the pipeline between the primary clarifier and the RBC units. Applicant Comment: The applicant took exception to this last sentence and it was modified. Reviewer Comment: This statement was intended by the reviewer to be a simple statement of fact as to the analysis provided in the PER. The bottleneck was raised as an issue in the PER and does cause the reviewer some concern as to whether it would be continue to cause surcharging. A few calculations presented in the PER or a description of pipe sizes or any detail may have relieved this concern. The applicant suggests that the reviewer speculates on an unlikely condition and it very well may be unlikely, but how is the reviewer to know this without some description of the "bottleneck condition"presented as a problem. However, whether or not some additional surcharging may persist, the proposed project clearly reduces the surcharging problem to a significant degree and reduces the potential for ove/fopping. The review did recognize that the surcharge condition caused by piping will be addressed in a subsequent phase of the project. Have serious public health or safety problems that are cleady attributable to a deficiency occurred, or are they likely to occur, such as illness, disease outbreak, substantial property loss, environmental pollution, or safety problems or hazards? (Describe the twill be corrected. Describe whether the problems have already occurred, or if they haven't, descrfbe the likelihood of their occurrence. For instance, is the public health or safety problem imminent,, near-term, long-term, or may potentially occur at some point in the future? Also describe the degree of seriousness the public health or safety problems represent.) Comment: Significant increases in influent flows at the WWTP have been documented to occur due to the irrigation of pastures overlaying sewer trunk lines. These influent flows have caused surcharging of the pdmary cladfler and are likely to cause raw sewage to be overtopped on to the ground or are likely to require that raw sewage be by-passed directly to the Yellowstone River. It is not clear from the PER if overtopping has ever occurred. This condition represents a serious public health or safety problem that is likely to cause illness, disease and environmental pollution. The hydraulic limitations of the pipeline between the primary cladfier and RBC unit is not being repaired as part of this project and it is not clear if the problem will be completely eliminated by replacement of the trunk lines alone. However, it is likely that the majority of the problem with the primary clarifier is being eliminated by the proposed project. During peak flow events, treatment efficiency is likely reduced introducing some additional public health dsk. Applicant Comment: The applicant has provided more information on the fo#owing sentence "/t is not c/ear from the PER if overtopping has ever occurred". Review Response: This information was genera/in nature with the intent to emphasize the likelihood of the c/arifier overtopping. The review agrees u4th the applicant's c/aim and it is clearly stated in the review comments above that surcharging of the primary c/ad#er is probable and a se~ous public health concern. However, it is the reviewe/~s responsibility to a/so describe the degree of documentation and that is why the sentence is included in the review. Is the problem existing, continual, and long-term, as opposed to occasional, sporadic, probable or potential? (Describe the nature and frequency of occurrence.) Comment: The condition of the trunk lines underlying the irrigated fields is existing, continual and long-term. Because the practice of irrigation occurs occasionally, the problem with peak flows is only experienced occasionally. High base infiltration flows are experienced on an existing, continual and long-term basis. Is the entire community, or a substantial percentage of the residents of the community, seriously affected by the deficiency, as opposed to a small percentage of the residents? (Describe the number of residents affected by the problem.) Comment: The entire community of Laurel is impacted by the deficiency along with any downstream users. Is there clear documentation that the current condition of the public facility (or lack of a facility) violates a state or federal health or safety standard? (If yes, describe the standard being violated.) Comment: Direct by-pass of raw sewage to the Yellowstone River or overtopping raw sewage on the ground would be a direct violation of the MPDES discharge permit and a violation of a state and federal health standard. It is not clear whether this condition has ever occurred. Not meeting the percent removal permit criteria orpermit concentration limits are also violations of state and federal health standards, however, it is has not been documented that the proposed project will eliminate such violations. Reduced peak flows do reduce the probability of permit effluent concentration violations, but the extent of this benefit is difficult to determine. Does the standard that is being violated represent a significant threat to public health or safety? (For each standard being violated as listed in e., identify the public health or safety problems associated with it.) Comment: The by-pass of raw sewage or overtopping raw sewage onto the ground represents a significant threat to public health. Not satisfying percent removal criteda or violations of permit concentration limits are also significant threats to public health, but the degree of risk is dependent on the degree to which these limits are violated. The PER did not present specific permit violation data. Is the proposed TSEP project necessary to comply with a court order or a state or federal agency directive? (If yes, describe the directive.) Comment: There is no court order or state or federal agency directive. Are there any reliable and long-term management practices that would reduce the public health or safety problems? (Describe any reliable and long-term management practices that would reduce the public health or safety'problems.) Comment: No. According to the application the City has tried to manage the excess groundwater flow into the plant by utilizing the freeboard available in the pdmary clarifier until the peak subsides. However, the peaks into the plant have steadily increased and will eventually exceed their ability to manage. Is there any other pertinent information that might influence the scoring of this statutory priority? Comment: 6 SUMMARY - STATUTORY #t There are various deficiencies that could affect the public's health and safety, including: hydraulic surcharging of the pdmary clarifier due to excessive groundwater infiltration, reduced ability to properly maintain RBC units, poorer treatment plant performance during peak flow events and some increased potential for violation of discharge permit limits dudng peak flow events. Based on the scoring criteda for wastewater projects, these types of deficiencies are likely to result in serious problems that have a moderate level of probability of occurrence in the near-term as a result of incidental, short-term or casual contact. The overtopping of sewage would likely be limited to the footprint of the existing wastewater treatment plant and would have a Iow probability of exposure to the general public. The health and safety problems are considered to likely occur in the long-term if the deficiencies are not corrected. The MDOC scoring team determined that a level 3 score is appropriate for these types of deficiencies and the potentially resulting health and safety problems. TSEP Statutory Priority #3 - Projects that incorporate appropriate, cost-effective technical design and that provide thorough, long-term solutions to community public facility needs. ICDBG Criterion #3 - Project Concept and Technical Design Does the PER provide all of the information as required by the Uniform PER outline, and did the analysis address the entire system in order to identify all potential deficiencies? (Describe any information that is required to be in the Uniform PER outline that is missing. State whether the entire system was addressed, and describe any parts of the system not dealt with and the reason why if known.) Comment: The PER conducted a reasonably complete and thorough analysis of the collection, treatment and sludge management facilities serving the City of Laurel and generally followed the PER Outline. The PER identified all deficiencies and provided a reasonably complete evaluation of alternatives. A phased approach was recommended to resolve the deficiencies identified in the PER which included Phases lA, lB and 2. These phases are described in paragraph 1 .a. Paragraph l.a. also provides a detailed discussion of each deficiency identified and the degree to which the proposed solution solved these deficiencies such that the TSEP Program is able to rank only the problems solved. To that end, there is significant ovedap in the evaluation of Priority #1 and Pdodty # 3 and the reader is referred to paragraph l.a for a discussion of the proposed solution. In general, the PER was good, but lacked some information for better documentation as explained in paragraph 1 .a. and the following paragraphs. Does the proposed project completely resolve all of the deficiencies identified in the PER? If not, does the proposed project represent a complete component of a long-term master plan for the facility or system, and what deficiencies will remain upon completion of the proposed project? (Describe any deficiencies that will not be resolved by the proposed project. Descrfbe any plans for resolving those deficiencies in the future.) Comment: As described in detail in paragraph 1 .a. of this review, the proposed project does not resolve all of the deficiencies identified in the PER. It will not resolve concerns with the age and condition of the majodfy of the collection system, the O&M demands of the one-month sewer 7 mains, deficiencies with the lift stations, infiltration within the majority of the collection system, and treatment and collection capacity for growth outside the City limits. Those deficiencies not resolved herein have been included in subsequent phases and are part of a comprehensive plan of improvement The PER did identify priorities for replacement of trunk lines underlying irrigated fields and the one-month lines described in paragraph 1.a. Phase lA of the PER phased approach is in the process of being implemented. The project proposed in this TSEP application is the highest priority of Phase 1.B. and includes the replacement of the remainder of the trunk lines that underlie irrigated fields. Applicant Comment: According to the application, the proposed project is intended to reduce the potential for prtmery clarifier surcharging, eliminate permit violations and to allow the proper maintenance of the RBC units. The applicant has pointed out that the uniform application incorrectly described elimination of permit violations as a project goal and asked that the PER score not be reduced due to this oversight. Reviewer Response: It is important to point out that the response to statutory priority 1 in the application also made several references to improved RBC maintenance. As demonstrated in text throughout this review report, the reviewer clearly understood all of the phases of the project and correctly gave the PER credit for solving identified problems as part of a long term, phased project. However, it is the reviewers responsibility to clearly point out the specific problems claiming to be solved as part of this project end those that are actually being solved. The applicant's reference that the reviewer is confusing the goals of the multi-phased, long-term rehabilitation plan with the specific goals of the proposed TSEP project is not consistent with the text provided throughout this review report (see this section and the comments in l.a) and is also inconsistent with the applicant's acknowledgement that the uniform application did claim that the project would allow the plant to come into compliance with it's permit limits. Therefore, the reviewer is obligated to clarify. However, the reviewer is of the opinion that the PER score should not suffer from inaccurate problem statements in the application. The PER clearly documented that peak plant influent flows were due to irrigation activity on fields overlaying major collection system trunk lines. The impact of these peak flows on primary clarifier performance is clear and understandable. It may still be difficult to take one of the RBC treatment trains out of sen/ice without violating the permit concentration limits, but we agree with the applicant that eliminating peak flow will reduce the potential for permit violations. Again, the degree to which this is a benefit is difficult to say given that there is still a significant groundwater flow component. The reviewer also agrees with the applicant's claim that treatment plant efficiency is reduced during peak flow events and elimination peak events will improve efficiency, but the extent of this improvement is limited to peak f/ow events and will not allow the plant to meet effluent limits. Are the deficiencies to be addressed through the proposed project the deficiencies identified with the most sedous public health or safety problems? If not, explain why the deficiencies to be addressed through the proposed project were selected over those identified with greater public health or safety problems. (Describe anypublic health or safety problems that are not to be resolved by the project. Describe the why the applicant has decided not resolve those problems.) Comment: Yes, the PER presented a phased approach that addresses the most serious deficiencies in proper order. The proposed project is the highest priority of Phase 1.B. Phase 1.A is in the process of implementation. 8 Excess groundwater from irrigation of fields overlaying major trunk lines causes peak flow events that cause surcharging of the primary clarifier and increases the possibility of raw sewage overtopping on to the ground or being by-passed to the Yellowstone River. These are serious public health concerns. Were all reasonable alternatives thoroughly considered, and does the technical design proposed for the alternative chosen represent an efficient, appropriate, and cost- effective option for resolving the local public facility need, considering the size and resources of the community, the complexity of the problems addressed, and the cost of the project? (Describe the level of analysis performed to determine an appropriate solution. Describe in more detail any missing information that would have made the analysis better and why.) Comment: The collection system alternatives analysis was difficult to understand and it was not clear what comparative ranking criteria were used to select the preferred alternatives. For examplel there were two alternatives (rehabilitation or replacement) selected for addressing the deficiencies with the Main/Elm lift station. Each alternative was discussed on pages 7-7 and 7- 8. A capital cost for each alternative is presented in table 7-1 on page 7-16. That ends the alternatives analysis with no comparative ranking discussion. Then on page 9-1 the preferred Main/Elm lift station altemative is the replacement alternative with no discussion on how that selection was made. A detailed analysis is not needed, but any kind of discussion regarding how the selection is made would be useful. The same approach was used for the selection of the preferred trunk line alternative, Again, two alternatives were identified, a single large pipe system to serve the current service area and an expanded service area and a parallel two pipe system. For the parallel system, the first pipe would serve the needs within the existing City limits and the second pipe would serve an expanded service area. As in the previous example, a discussion was presented along with capital costs, but no comparative analysis of the alternatives. Then on page 9-1 the single pipe alternative was presented as the preferred alternative. For the same reasons it is not clear why alternative T2B was selected over T2A on page 9-3. Several alternatives for the replacement of the one-month lines were also presented, but it is not clear how alternative C1A was selected in Table 9-1 on page 9-3. For all pipeline alternatives, the selection of trenchless technologies versus open cut and pipe bursting were deferred to the design stage. Basically, Chapter 7, the alternatives analysis for the collection system, was a general discussion of all that could be considered in addressing collection system deficiencies, most of which is complete and sufficient, but presented no rational for the alternative selections made. With that said, the preferred alternatives selected will solve the problems identified, but it.appears determining, which alternative is most efficient, ~ppropriate and cost effective will be performed in the design phase. The alternatives analysis for the WWTP was the more traditional PER approach, but did add a few twists. The alternatives analysis for present worth did not include salvage values, but provided a reasonable narrative of why it was not necessary to include them in the analysis. The difference in O&M costs were considered in the present worth analysis for each alternative not the total O&M cost. This approach was different than most PER's, but seems to result in a reasonable comparison of the cost effectiveness of each alternative. All reasonable alternatives appeared to be considered and current and future regulatory requirements were properly addressed. More detail comparing the cost of connecting to Billings versus upgrading the existing plant would have been good. Applicant Comment: The applicant took exception to the review comment that the collection system alternative analysis was lacking. The applicant states that there are really no true 9 collection alternatives to compare. Reviewer Response: However, chapter 7 does list specific alternatives. We agree with the applicant that collection system alternatives are often not as definitive as treatment alternatives and do not warrant the same comparative rigor and we acknowledged this point in the review by saying a detailed review is not necessary but any narrative discussion would have been useful. Accordingly, to be fair, the reviewer chose to clearly describe how the alternatives were presented and how they were integrated into the implementation section of the report to allow the ranking committee to discuss the issue. We stand by the accuracy of the information presented in the review and rely on open discussion in the ranking committee to help determine the significance of the issues raised. While we agree that collection system alternatives do not need to be compared with the same rigor as treatment alternatives, and while a matrix may not always be necessary, some narrative could have been provided to describe how alternatives presented in Chapter 7 became preferred alternatives in Chapter 8. The reviewer is not suggesting that a detailed alternatives analysis is necessary for the entire collection system, but is suggesting that specific alternatives were identified for trunk lines and lift stations and they could have been compared in more detail. The review was very specific in the information lacking and the applicant's response to those specifics is that alternative T2B was selected based on capital cost. Finally, several PER's have evaluated various collection system alternatives and do compare open trench, pipe lining and pipe bursting alternatives. Does the technical design proposed thoroughly address the deficiencies selected to be resolved and provide a reasonably complete, cost-effective and long-term solution? (If the proposed technical design proposed does not thoroughly address the identified deficiencies or provide a reasonably complete, cost-effective and long-term solution, describe why.) Comment: The technical design cleady resolves the primary deficiency of overtopping the primary cladfier and reduces the potential for permit violations. The benefit of reduced potential for permit violations is difficult to assess. Are all projected costs and the proposed implementation schedule reasonable and well supported? Are there any apparent technical problems that were not adequately addressed that could delay or prevent the proposed project from being carried out or which could add significantly to project costs? (Describe any costs not adequately discussed or any prob/ems that were not discussed that could de/ay the project.) Comment: The costs were based on bid tabulations from similar projects in the area and on discussions with suppliers. The cost estimates appear reasonable. The project schedule appears appropriate. Have the potential environmental problems been adequately assessed? Are there any apparent environmental or technical problems that could delay or prevent the proposed project from being carded out or which could add significantly to project costs? (Does it appear that the Uniform Environmental Checklist was adequately completed? Were a# of environmental concerns noted in the Uniform Environmental Checklist adequately addressed in the PER? Describe the impact this project would have on the environment.) Comment: Thero are no apparent environmental or technical problems that could significantly delay or prevent the proposed project from being carried out. uniform checklist appears to be adequately completed. 10 For projects involving community drinking water system improvements, has the conversion to a water metering system for individual services been thoroughly analyzed and has the applicant decided to install meters? In those cases where individual service connection meters are not proposed, has the applicant's PER thoroughly analyzed the conversion to a water metering system and persuasively demonstrated that the use of meters is not feasible, appropriate, or cost effective? Comment: The City of Laurel is metered. Is there any other pertinent information that might influence the scoring of this statutory priority? (For example, were there any known previous studies completed to document the problem and if so, were the conclusions different from the PER)? Comment None SUMMARY-STATUTORY#G The MDOC scoring team felt that the preliminary engineering report was generally complete, however, the MDOC scoring team felt that there were some minor issues that were not adequately addressed, including: better comparison of alternatives, costs of alternatives and description of the reasons for selection of the preferred alternative. The MDOC scodng team determined that a level 4 score is appropriate given the minor issues raised concerning the PER. 11