HomeMy WebLinkAboutDept of Commerce (3)M NTANA
Department of Commerce
COMMUNITY DEVELOPMENT DIVISION
P.O, Box 200523 * Helena, Montana 59620-0523
Phone: 4136-B41-2770 · Fax: 405~41-2771
December 22, 2006
Kenneth Olson, Mayor
City of Laurel
P.O. Box 10
Laurel, MT 59044
Dear Mayor OIson:
Attached is the completed report describing how your application and project was
scored by the Department of Commerce in the Treasure State Endowment Program
(TSEP) grant competition. It is included in the report that the Department will be
providing to the Legislature in January 2007. 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 complete
report that will be submitted to the Legislature is still in the process of being printed, but
one copy of it will be sent to the person you designated as your primary contact as soon
as it is available. However, the full report can currently be viewed on the TSEP web site
by going to: http://comdev.mt.gov/CDD_TSEP_Prj.asp.
The Legislature's Joint Long-Range Planning Subcommittee, which initially hears
House Bill 11 (the bill that appropriates funds for the TSEP projects), holds a public
hearing on each project. The hearing is your primary opportunity to plead your case
before the Legislature to fund your project. 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.
Attached is the schedule for the hearings, which have also been coordinated with the
Department of Natural Resources and Conservation. If you also applied for a
Renewable Resource Grant and Loan Program (RRGL) grant for your project, this will
be a combined hearing. The hearings will begin on Thursday, January 11 , at 8:00
a.m., in Room 350 of the Capitol. Please note the date and the time of your project's
hearing on the schedule.
With the exception of the projects at the very beginning in the morning, you should plan
to arrive a minimum of one-half hour before the scheduled time of the hearing, since
the hearing for your project could be moved up if other projects do not take as long as
planned. If you are unable to attend your hearing as scheduled, please let the TSEP
staff know as soon as possible so we can advise the Subcommittee and not have them
delaying the hearings unnecessarily. As with any legislative hearing, the schedule is
subject to unpredictable change. If any major changes occur, we will attempt to contact
you as soon as possible.
On the first two days of hearings, only ten minutes has been allocated per hearing for
projects that do not involve RRGL grants. Once we begin the joint TSEP/RRGL
hearings at the end of the second day, fifteen minutes has been allocated for each
project hearing. The allotted time allows for a very brief introduction by TSEP and
RRGL staff, testimony from applicants, and questions from the Subcommittee. If you
plan to have more than one or two people testifying, please keep in mind the amount of
time allocated for each hearing, limit the amount of testimony from each person, and
don't be repetitive.
The Subcommittee will not make a decision until they take executive action, which will
take place after all of the TSEP and RRGL project hearings have been completed. At
this point, it is scheduled for January 25th. After the Subcommittee takes executive
action on HB '11, the bill will go to the full House Appropriations Committee for a
hearing. Testimony at that hearing is typically for the bill as a whole, rather than for
individual projects. VVhile you are not prohibited from testifying at that hearing, we
encourage you to limit your testimony to the individual project hearings.
If you are interested in following HB 11, you can track the bill yourself on the Internet by
going to: http://laws.leg.mt.gov/pls/laws07/law0203w$.startup. If you have any
questions, please call me at 841-2785, or you can email me at jedgcomb@mt.gov.
Sincerely,
Jim Edgcomb, Manager
Treasure State Endowment Program
Attachments: Two Project Reports
Hearings Schedule
c: Scott Murphy, Morrison-Maeirle, Inc.
This application received 3,480 points out of a possible 4,900 points and ranked 30th out of 57
applications in the recommendations to the 2007 Legislature. MDOC recommends the requested TSEP
grant of $750,000.
Funding Type of
Amount Status of Funds
Source Funds
TSEP Grant $ 750,000 Awaiting decision of Legislature
SRF Loan $3,882,500 83r" on the SRF priority list
Project Total $4,632,500
Median Household Income: $32,879 Total Population: 6,255
Pement Non-TSEP Matching Funds: 84% Number of Households: 2,377
Monthly Percent of Monthly Percent of
Rate Target Rate Rate Target Rate
Existing Water Rate: $27.33 Target Rate: $57.62
Rate with Proposed
Existing Wastewater Rate: $42.40 TSEP Assistance: $81.66 142%
Rate without TSEP
Existing Combined Rate: $69.73 121% Assistance: $83.64 145%
Project Summary
History - Laurel's wastewater facilities are comprised of a collection system, two lift stations, and
treatment facility. The original plant was built in 1941, was upgraded in 1961 and was expandedwith
secondary treatment in 1985. All portions of the plant are now in excess of 20 years old, with the
exception of the plant drain pump, which was replaced in 2004. The collection system was originally
constructed in 1910, and the majority of it is comprised of vitrified clay pipe and has been in service for 50
to 100 years. Both pump stations are over 20 years old. In 2004, a new major intemeptor was added to
the collection system on the west side of town to alleviate an on-going overcepacity issue, and a portion
of trunk sewer was replaced on Railroad Street to reduce infiltration induced by focal flood irrigation. The
City is pursuing replacement of all major trunk mains into the treatment plant with a project in the fall of
2006. These lines currently collect an excess amount of infiltration due to flood irrigation in the fields
adjacent to the trunk mains.
Problem - The City's wastewater system has the following deficiencies:
the Main/Elm Street lift station is about 40 years old and in need of some updating and repair,
the Village Sub lift station is about 20 years old and in need of some updating and repair,
the treatment plant grit removal and headworks are aging, have some safety issues, and better
technology is currently available,
[] primary clarifler piping is inadequate during hydraulic surges and causes some operational problems,
[] plant water supply system is inadequate for plant use and building fire protection,
[] the secondary rotating biological contactor treatment system does not have adequate redundancy to
allow for year round maintenance and may not have adequate treatment capacity to meet future
flows, and
Q the disinfection system at the treatment plant is not adequate to meet anticipated future discharge
permit requirements.
Proposed Solution - The proposed project would:
[3 replace the Main/Elm Street lift station,
Governor's Budget Long-Range Planning Subcommittee
Treasure State Endowment Program 172
[3 rehabilitate the Village Sub lift station,
rehabilitate the grit removal and headworks facilities,
[] improve the hydraulics of the primary clarifiers,
improve the plant water systems to allow for process water and fire protection, and
expand the existing rotating biological contactor system.
Note: Improvements tothe disinfection system will be postponed to a later phase. TherefOre, those
deficiencies were not taken into consideration in the scoring of statutory priority #1.
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. These serious problems have a high probability of occurrence after
chronic exposure and some reasonable 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 in the long-term, including aging lift stations in need of repair,
operational deficiencies with the headworks and clarifier piping, and lack of redundancy in the rotating
biological contactors. Deficiencies at the existing lift stations, specifically equipment age and condition
and the lack of a secondary power source, make failure of the sewage lift stations increasingly probably
over time. Failure could cause sewage to back up into residences, resulting in serious consequences
such as !llness and substantial property loss. Without improvements to correct hydraulic deficiencies and
adding secondary treatment equipment redundancy at the treatment plant, eventual process failure will
place downstream users at risk of exposure to partially treated or untreated wastewater, which is a clear
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 a 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 3r~ level
and received 216 points. (This analysis accounts for 40% of the score for Statutory Priority #2. Each of
the three sub-indicators are ranked and scored, with each accounting for 33% of the total score for
Indicator #1. Being ranked the lowest indicates the most severe household economic conditions and is
assigned the highest score. Being ranked 57th indicates that the applicant has the least severe household
economic conditions and is assigned the lowest score. The scores for each sub-indicator are added
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.)
[3 The applicant's Median HouSehold Income (MHI) is the 38th lowest of the 57 applicants.
D The percent of persons riving at or below the Low and Moderate-Income (LMI) level is 48.0%. The
applicant's relative concentration of persons living at or below the LMI level is the 21st
highest of the 57 applications.
D The percent of persons living at or below the Poverty level is 10.8%. The a~plicant's relative
concentration of persons living at or below the Poverty level is the 38"' highest of 57
applications.
Governor's Budget Long-Range Planning Subcommittee
Treasure State Endowment Program 173
Indicator #2. Target Rate Analysis: The applicant placed in the 3= level and received 324
points. (This analysis accounts for 60% of the score for Statutory Priodty #2. Each sub-indicator is
ranked and scored. Scores are assigned based on how much difference there is between the applicant's
user rate and the target rate. The number of points possible for Indicator #2 Js based on five levels. The
fifth highest level is assigned to the group of applicants furthest over the target rates.)
Conclusion: The applicant conclusively demonstrated that it has proposed an appropriate, cost-
effective technicar design that wiJl provide a thorough, long-term solution for its public facility needs. The
problems were well defined, the various alternatives were thoroughly discussed, and construction costs
were well documented and justified. There were no issues of any significance that were not adequately
addressed in the preliminary engineering report (PER).
Rationale: The MDOC technical review team thought the PER was complete and thorough. 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 effects were noted.
Conclusion: The applicant conclusively 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 resoumes.
Rationale: The applicant stated that the City is budgeting monies specifically for the purpose of
completing capital improvements plan (ClP) tasks, and has had to raise water and sewer rates to meet
the demands of the plan. The operating and maintenance (O&M) budgets for the wastewater system
have been adequate as evidenced by the needy $270,000 of reserve used to help fund replacement of
sewer main and the treatment plant drain pump in 2004. A sewer rate increase was approved in 2004 to
rebuild the reserves; the City has added more than $100,000 to the sewer replacement fund. The City
has also raised the cost of impact fees for new hook-ups.
The applicant stated that a new interceptor was added to the collection system on the west side of
town in 2004 to alleviate an on-going ovemapacity issue, and a portion of trunk sewer was replaced on
Railroad Street to reduce infiltration induced by local flood irrigation. The City is planning to award a bid
in the fall of 2006 to replace all major trunk mains into the treatment plant, with funding already in place.
The applicant stated that since 2003, the City has been planning for water system improvements by
implementing yearly water rate increases. An emergency situation in 2003 at the intake precluded the
possibility of waiting for grants and the City took out another loan of $2.54 million to add to existing loans
already exceeding $6 million for its water system. All individual service connections are metered. The
City has begun a preliminary engineering study on the water system.
The applicant stated that since the end of 2000 the City has completed a needs assessment survey,
a separate survey specific to recreation, a flood hazard mitigation plan, a comprehensive five-year CIP
that was updated in 2003 (including a structural evaluation of city buildings, and a road inventory and
evaluation, 2002), and drafts of a transportation plan and a growth policy. Due to length, the flood hazard
mitigation plan was not included in the applicationi; however, the resolution to adopt the plan was
included.
The applicant stated that the City has addressed the highest priorities of the ClP: the intake and the
affordable housing shortage. The lighting issue was dropped after the public hearing demonstrated lack
of support. The second highest priority, a PER for the water system, is expected to be completed this
summer along with several street repairs. The proposed project is consistent with the adopted CIP.
The applicant stated that the problems to be resolved by the proposed project are not of recent origin
and are not due to poor maintenance; but, rather due to aging of the system. The treatment plant has
exceeded permit limits for a period of time, largely due to infiltration, capacity limitations, and increased
Governor's Budget Long-Range Planning Subcommittee
Treasure State Endowment Program
permit limitations. The maior trunk lines currently collect an excess amount of infiltration due to flood
irrigation in the fields adjacent to the trunk mains. The MDOC review team concluded that the City's O&M
practices related to the wastewater system appear to be adequate.
Conclusion: The applicant strongly demonstrated that the project would enable the local
government to obtain funds from sources other than TSEP. The applicant demonstrated serious efforts to
thoroughly seek out, analyze, and secure the firm commitment of alternative or additional funds from all
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
would hinder the applicant from obtaining the funds from the proposed funding sources. The MDOC
review team did not score this priodty higher primarily because TSEP funding was not considered to be
critical to the project, since the User rates without TSEP assistance would be less than 150% of the target
rate.
Rationale: The applicant is proposing a funding package consisting of a TSEP grant in combination
rd
with an SRF loan. The applicant ranked 83 on the SRF priodty list, and therefore, is eligible to apply for
the SRF loan. The applicant discussed the CDBG program, but stated that it did not meet the LMI
eligibility requirement of at least 51% benefited households. The applicant also discussed the RRGL
program, but did not think the proposed project would be competitive in that program.
The applicant stated that without the TSEP grant it would be very difficult to fund the project, since the
City already carries a large amount of debt and the user rate Would increase to 142% of the target rate
with the proposed project.
Conclusion: The applicant sufficiently demonstrated that the proposed project represents a general
infrastructure improvement that would indirectly increase business and job opportunities. The applicant
did not reasonably demonstrate how any specific businesses were dependent upon the proposed
improvements or how businesses would directly benefit by them. The applicant did not reasonably
demonstrate 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 long-term, full-time jobs. However, the proposed project increases the capacity of the
treatment plant for future growth.
Conclusion: The applicant inadequately demonstrated 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 there was a lack of documentation
indicating the community has been adequately informed of the rate increase in a timely manner.
Rationale: The applicant discussed several public hearings and meetings related to the proposed
project. The wastewater facility plan was discussed at meetings in July, August and September of 2002.
According to the minutes from a hearing in February 2003, a resolution to raise water rates was
presented for public comment; seven attendees spoke in opposition and none in favor of the increase.
Two additional public hearings were held regarding a CDBG grant application for wastewater
Governor's Budget Long-Range Planning Subcommittee
Treasure State Endowment Program 175
!_.ml~rove_m_~.n__t_s_ in Ap_r!!aqd May of 2003. Twenty-three people attended a hearing regarding the TSEP
application held in March of 2004, to present the overall project and discuss the various funding sources.
Copies of the minutes for each public hearing were included in the application, along with a notice for the
hearing in 2004 that was advertised twice in the Laurel Outlook. In addition, the applicant included copies
· of newspaper articlee and mailings that have been used to inform the public of the proposed project.
The applicant stated that a more recent public hearing regarding the proposed project was held at
6:30 p.m. on May 1,2006 in the council chambers at City Hall. The notice of the hearing was advertised
once in the Billings Gazette (a copy of which was included). The applicant stated that no comments were
made in opposition to the project during the hearing; however, only three people were in attendance (two
local officials and the consultant) according to a sign-in sheet. A handout of the presentation was
available and included in the application, which noted that an increase of up to $11.75 per household may
result from the proposed project. However, since only local officials and the consultant appeared to be at
the meeting and no minutes were provided, it could not be determined if any residents were informed of
the increase.
The applicant stated that the application included letters of support for the project; however, none
could be found in the application.
Although the 2000 needs assessment results showed that some respondents to the survey believed
that wastewater improvements were a high priority, it was not ranked as one of the top priorities of the
City. However, the 2003 CIP identified that sewer replacement on 1" Avenue was the highest ranked
wastewater improvement need.
Govemor's Budget Long-Range Planning Subcommittee
Treasure State Endowment Program 176
ENGINEERING REVIEW REPORT FORM
APPLICANT NAME: City of Laurel
TYPE OF PROJECT:Wastewater System Improvements
COMMENTS PREPARED BY: Thomas, Dean & Hoskins Inc. (Wade DeBoo, P.E.)
DATE: 9/2312006
TSEP Statutory Priority #1 - Projects that solve urgent and serious public health or
safety problems, or that enable local governments to meet state or federal health
or safety standards.
CDBG Criterion #2 - Need for Project
Applicant's t50 word statement: Serious public health and safety problems
clearly attributable to Laurel'e wastewater facilities are likely to occur without
completing the improvements proposed in the PER. Deficiencies at the existing
lift stations, specifically equipment age and condition and the lack of a secondary
power source, make failure of the sewage lift stations increasingly probably over
time. Failure could cause sewage to back up into residences, resulting in serious
consequences such as illness and substantial property loss. Without
improvements to correct hydraulic deficiencies and add secondary treatment
aquipment redundancy at the WWTP, process failure will place downstream users
fat risk of exposure to partially treated or untreated wastewater - a clear health
!risk. Since Laurel's WWTP serves all of the residents, the entire community
equally shares in the risks associated with the deficiencies. The proposed
projects are part of a prioritized long-range plan to eliminate all health and safety
problems with the wastewater facilities.
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
sefiousness of those deficiencies. Briefiy note any deficiencies that will
not be corrected by the project. Describe the seriousness of the
deficiency. )
Comment: The following deficiencies are noted by the PER and amended PER.
Collection: The collection system is in very poor condition. The poor condition has
caused sewage backup into homes and allows large amounts of groundwater
infiltration to enter the collection system, which in turn causes problems at the
wastewater treatment plant. Two earlier phases have begun to address the
infiltration problem by making repairs at some of the worst known areas. The PER
also recommends an annual replacement of 4,000 feet per year of collection lines
over the next 30 years, which when complete will encompass 78% of the total
collection system. Costs for collection system repairs are not part of the work
currently requesting grant funds. This seems to be a very sedous deficiency that not
only utilizes collection system capacity and lift station capacity but also disrupts the
treatment plant process and capability.
The applicant responded that the recommended replacement of collection lines was
not directly related to the infiltration conditions and even if collection lines were
replaced it may not eliminate infiltretion because service line repair or replacement is
uncommon. The reviewer does not disagree with the approach recommended for
annual service line replacement. However, this is a serious deficiency that will not
be corrected by this project and this review report notes that point.
· Main/Elm Lift Station: The PER states that the Main/Elm Street lift station has
exceeded its design life and does not have emergency power capabilities. The lift
station is about 40 years old. A lift station failure could cause raw sewage to backup
into basements in the area. A mechanical failure combined with a lack of response
to the local alarm system could be very serious. The addition of an autodialer on the
alarm system and replacement of the mechanical equipment would significantly
reduce the chances of a lift station failure causing sewage to back up into
residences. The PER recommends complete replacement of the existing lift station.
· Villa,qe Sub Lift Station: The PER states that the Village Subdivision lift station is
nearing its useful life. The station is about 20 years old and does not have
emergency power capabilities. Lift station failure could cause raw sewage to backup
into basements in the area. A mechanical failure combined with a lack of response to
the local alarm system could be very sedous. The addition of an autodialer on the
alarm system and replacement of the mechanical equipment would significantly
reduce the chances of a lift station failure causing sewage to back up into
residences. The PER recommends rehabilitation of the existing lift station.
· Primary Clarifier Hydraulic Improvements: Piping between the primary clarifiers and
the RBC units is reportedly undersized for peak design flows. On occasion the
clarifler has overtopped spilling partially treated wastewater onto the ground.
· Plant Water: The PER states that the plant water and potable water systems are
both inoperable. The former leaves the plant operators without a reliable source of
non-potable process water and the later leaves the plant without adequate fire
protection. If a fire were to occur at the treatment plant, a lack of local fire protection
would greatly increase the chance for significant damage to the facility. The odds of
a significant fire occurring may be small but the result could be serious.
· Grit Removal and Headworks: The existing mechanically cleaned bar screen is
reported to be difficult to maintain. Inadequate safety equipment is installed or
available. A new unit could result in better collection of solids and improvements in
downstream solids handling processes. The PER states that maintenance of the
existing equipment is increasingly difficult and unsafe due to confined space entry
issues. As long as plant staff obtain needed safety equipment and follow safety
rules, the seriousness of this problem seems fairly small.
· RBC: The existing RBC process does not have enough redundancy to allow for
equipment maintenance during all times of the year. The PER states that the
existing equipment does not have the capacity of its original design nor the capacity
to meet the projected flows of the year 2025. The plant has occasional discharge
permit violations that are reported to be a result of the current RBC unit process. At
least part of the problem appears to be the result of extreme amounts of infiltration in
the influent that creates "weak" strength wastewater that is more difficult to treat to
the required standards. The result of this deficiency could mean one or more
discharge permit violations depending on specific circumstances.
The applicant commented that the existing RBC unit has adequate capacity to meet
current demands plus 10-15 percent additional flows / loads only if all units are in
service. The applicant stated that the lack of redundancy was not consistent with
general MDEQ2 design practice requirements, nor general good engineering
practice. The applicant also commented that they must time summertime
maintenance carefully to meet discharge permit limits and that this was a ~tdck" that
was not in the spirit of the discharge permit. In the reviewers opinion each of the
applicants comments is an issue that should be considered with regard to the level of
severity of the deficiency. The reviewer is unsure which MDEQ2 design practice the
applicant is referring to since the section was not referenced and good engineering
practice is very subjective. All things considered, the reviewer judges the problem
with the existing RBC units as moderately severe. It seems to be an important issue
but it currently has capacity and can be operated in a manner that typically meets
their legal obligations for treatment.
Other: The PER also addresses anticipated disinfection facility upgrades and
budgeting for routine maintenance, neither of which are currently requesting funds.
The disinfection changes are based on anticipated discharge permit changes that
are not yet finalized, so this item has appropriately been left to a later date.
b. Have serious public health or safety problems that are clearly 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 public health or safety
problems that can be attributable to any of the deficiencies that will be
corrected. Describe whether the problems have already occurred, or if
they haven't, describe 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? Aisc describe the degree of
seriousness the public health or safety problems represent.)
Comment: Following are comments for each portion of the proposed project.
Collection: The poor condition of the collection lines has caused sewage to backup
into homes, which is a sedous health and safety problem. Some repairs have
already taken place but the PER predicts that the problem will continue to remain
until old collection lines are repaired or replaced. The PER recommends replacing
the bulk of the collection system at a steady pace over the next 30 years.
The applicant commented that sewage backups are manageable and can be
handled by cleaning sewer lines monthly and that they will be replaced when it
becomes economically feasible and adequate capital is available.
Lift stations: The lift station problems are both potential problems that may occur at
some point in the future if proper maintenance does not occur. The PER documents
sewage backup into residences but does not state whether the cause was from lift
station failure or a result of the poor condition of the collection system. It is
presumed that the cause of the sewage backups was not a result of lift station failure
and thus is just a potential problem. Failure could cause sewage to back up into
services, resulting in sedous consequences such as illness, disease, and/or
substantial property loss. The proposed project includes complete replacement of
one lift station and a full rehabilitation of the other. It appears that the public health
components of the problems could be primarily solved with a lesser scope at each
station. The most sedous portions of the problem are related to the need for
mechanical equipment reliability (pump repair or replacement), emergency power
provisions, and remote monitoring of alarm conditions.
The applicant commented that complete replacement of the one lift station is
recommended because rehabilitation is not a viable alternative (based on
engineering judgment).
Primary Clarifier Hydraulic Improvements: Primary cladfier overtopping has
reportedly occurred. The frequency of occurrence is unknown.
Plant Water: Fire protection is not likely to be needed but in the unlikely event that it
does occur, it is a very important safety feature. Circular DEQ 2 does not appear to
require a fire protection system at a treatment plant but other building codes may
require it. The PER doesn't address the exact code or standard that may require fire
protection. The applicant commented that common sense is the justification for the
need for fire protection. The reviewer agrees that (as stated above) it is a very
important safety feature. However, when considering the severity of the issue it
should be noted that this is based on common sense instead of being a direct
violation of some law, code, standard or rule.
Grit Removal and Headworks: It is not apparent that the existing grit removal and
bar screen causes any serious public health and safety Concern. Improper safety
precautions in its use may cause harm to the plant operators. The proposed project
does include installation of some additional safety equipment that would alleviate the
safety concern for operators.
RBC: Worst case, a process failure or bypass at the wastewater treatment plant
could place downstream users at risk to exposure of untreated wastewater and
expose the public to health and safety issues such as illness and disease outbreak.
Failure or inadequate performance of the RBC process at the treatment plant could
cause a discharge permit violation. Some permit violations have already occurred,
but the cause of the violations seem to be as much a result of high infiltration rates
as lack of performance o[ the RBC. Continued permit violations are likely to occur
potentially on an increasing frequency as the population of the community expands.
As repairs are made to the collection system the reduction in I&l could partly or
entirely offset the impact of added population. The PER does not discuss this point
but it seems likely to be the case. The PER states, "the plant has had a good track
record of meeting its BOD and TSS concentrations, but often cannot meet percent
removal requirements during summer months when infiltration increases the plant
flow rate and dilutes the wastewater concentration" (page 6-25). Not meeting the
percent removal requirements seems less serious to public health than not meeting
concentration requirements. In fact DEQ lowered the percent removal requirements
in the last permit cycle based on the I&l conditions that were occurring. A request
could be made to reduce the percent removal requirements further.
4
The applicant commented that more violations woutd have already occurred if a 30-
day rolling average concentration standard was imposed upon them. tt is the
reviewers opinion that if the DEQ had felt it necessary to impose a rolling average
limit, then they would have already done so. Typically DEQ sets very rigid standards
in discharge perrnits. It seems unusua/ for an app/icant to self impose more stringent
standards upon themselves. Though not addressed by the applicant, /t is possible
that the rolling standard could be imposed during the next permit cycle, particularly if
the DEQ permitting section reviews the PER which documents the lack of a re/ling
standard as a problem.
Is the problem existing, continual, and long-term, as opposed to
occasional, sporadic, probable or potential? (Describe the nature and
frequency of occurrence.)
Comment: Each of the problems is addressed below.
Collection: The I&l problem and poor condition of the collection system is continual
and long term. As annual repairs are made the I&l problem should continue to
decline. This reduction may also improve the treatment plants pefiormance. I&l
occurs most dramatically every summer during irrigation season but appears to be
an issue to a lesser degree in the winter as well.
Lift Stations: The lift station problems are probable at some point if equipment is not
maintained (repaired or replaced), a backup power source is not provided, and
remote emergency alarm features aren't added. Based on the information provided,
it is impossible to predict whether a problem is eminent or if it will not occur for many
years. Some lift station components may have a design life exceeding 20 or 40
years. Mechanical equipment such as pumps will typically last between 10 and 30
years. The equipment design and quality and conditions of use will all factor heavily
on the true life. Wet wells and dry wells can be designed to last 50 or more years.
Not enough information was provided about the installations to make a judgment
about the true life expectancy of the various components of each facility.
The applicant questioned whether the above statement was setting a higher than
normal standard of documentation. The applicant also stated that the proposed lift
station improvements were based on several licensed engineer's judgment and
discussions with City staff. The reviewer does not question the engineer's nor City's
judgment with regard to the proposed improvements. The statement listed above is
the reviewers best attempt to answer question 'c' based on the reviewer's
knowledge of the topic and the information provided in the application. The PER
provided few specifics about the lift stations other than the judgment that they
exceeded design life and require replacement. These judgments may be 100%
correct but the reviewer feels that additional documentation could have been
provided that would have more clearly justified the proposed solution.
Primary Clarifier Hydraulic Improvements: The hydraulic capacity problem between
the primary clarifier and RBC unit will continue unless infiltration in the collection
system is reduced enough to eliminate the conditions that cause the problem.
Plant Water: With regard to fire protection, lack of adequate plant water is a
continual and potential problem.
Grit Removal and Headworks: As stated in the previous section the grit removal and
headworks facility does not seem to be a health and safety issue except for the plant
operators. Safety concerns for workers would be continual until that portion of the
problem is addressed.
RBC: The PER does not specifically state the frequency of occurrence of discharge
permit violations
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: Each of the problems is addressed below. The applicant commented that
issues at the treatment plant affect the entire community and that PER Figure 5-~ gives
a general idea of the contributory areas for each lift station.
· Collection: The collection system problems likely impact most of the community the
same. The persons living in the immediate vicinity of the worst condition pipe are
impacted more when it comes to potential for backup into residences. The impact
that I&l has on treatment should be the same for the entire community.
· Lift Stations:' The lift stations impact the users upstream of the lift stations.
Inadequate information is provided to determine the percentage of the community
that is served by each lift station.
· Primary Clarifier Hydraulic Improvements: Lack of piping capacity has little direct
impact on the community but whatever impact exists would be equal for the entire
community.
· Plant Water: Plant water has little direct impact on the community but whatever
impact exists would be equal for the entire community.
· Grit Removal and Headworks: Grit removal and headworks have litfie direct impact
on the community but whatever impact exists would be equal for the entire
community.
· RBC: The RBC unit has little direct impact on the community but whatever impact
exists would be equal for the entire community. Persons using the Yellowstone
River in the vicinity of the discharge point would have more potential tobe directly
impacted by discharge water quality.
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: No, the PER does not specifically state or document which, if any, health and
safety standards are being violated for any of the deficiencies discussed above. Section
5.3 and section 6.5 of the PER discuss in genera] terms the health and safety issues but
does not specify which standards, if any are being violated. Occasional discharge
permit violations are mentioned but evidence of permit violations wasn't provided in the
documentation.
The applicant stated, "We simply ask that the reviewers approach to health and safety
standard documentation for conditions that are clearly 'unsafe' be uniformly applied to
other documents. We are sure that the review committee will see to this end." The
applicant went on to acknowledge that documentation of permit violations was
inadvertently/eft out and argued that in past funding cycles this was an item that was
acceptable to leave out.
The reviewer agrees that the same standard should be applied to all applicants. It is the
reviewers opinion that it should be the responsibility of the applicant to specifically state
the health and safety standards which are being violated. It should not be the
responsibility of a reviewer to research all health and safety standards and evaluate the
application to determine which are met and which are not.
In this particular application much of the proposed work may not be a violation of a
specific health and safety standard. The original application addressed question 'e' in
part as follows:
The current condition of the wastewater facilities does not directly violate a state
or federal health or safety standard. However, failure of a unit process violates
MDEQ design standards and common sense practice. These standards are
established to protect public health and safety...
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: Discharge permits are set by the Department of Environmental Quality to
protect surface water quality. Violation of the permit could negatively impact other usem
of the surface water.
Is the proposed TSEP project necessary to comply with a court order or a
state or federal agency directive? (If yes, descdbe the directive.)
Comment: No.
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: The annual collection system replacement program that is recommended in
the PER is a good long-term management strategy to help reduce the infiltration
problem. The City could complete television inspections on the remaining 13/14tbs of the
collection system and complete additional I&l studies to better evaluate the collection
system problems. Pipe replacement could be targeted to the worst condition lines.
They could evaluate service line infiltration and replace leaky service lines if needed.
They could monitor effectiveness of the pipe replacement in reducing infiltration.
Connection of additional users to the City system could be limited or prohibited if
necessary. It may not be the preferred action, but it is an altemative in dealing with
increasing flow rates and organic loading.
Is there any other pertinent information that might influence the scoring of
this statutory priority?
Comment: The City has already completed one project and is scheduled to begin the
second in an effort to reduce infiltration in the collection system.
7
SUMMARY - STATUTORY
There are various deficiencies that could affect the public's health and safety, including
aging lift stations in need of repair, operational deficiencies with the headworks and
clarifier piping, and lack of redundancy in the RBC.
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
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 ali 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 is well organized and follows a logical sequence of discussion
but does not follow the standard outline format, which makes it more difficult for the
reviewer to locate each bit of required information. The PER evaluated all of the
components of the wastewater system. The PER plus amended PER amounted to
500 or more pages, which makes it time consuming to locate information. Some
information required in the outline was not located in the document. Following is a
list of the items that were missing.
· A copy of the latest MPDES comprehensive performance evaluation (CPE)
could not be located in the document. The applicant commented that latest
CPE is over a dozen years old and its inclusion could have caused confusion.
They stated that this should not be considered a deficiency.
· Lift station inflow rate or pump run time records were not provided. The
applicant stated that it was unclear how the reviewer would use this
information and that this should not be considered a deficiency. The reviewer
feels that this information could have provided additional information
regarding the conditions at the existing stations.
· A SewerCAD model was conducted to evaluate hydraulic capacity but a node
map was not included, which makes the model output data provided of little
use. The applicant questions how the reviewer may use this information and
suggested that its exclusion was not a deficiency. /fit had been included the
reviewer would have examined the information on a cursory basis to ensure
that it was consistent with the discussion in the report.
Water system usage was not compared with hydraulic loading to the plant as
required.
Discharge permit violation notices could not be found.
No documentation or clear explanation of specific issues was provided to
back up the claim that the lift stations and other plant equipment has a 20
year useful life. The app/icant stated that 20-year life expectancy is standard
engineering practice and that this is shown by the fact that PERs consider 20-
year planning periods and SRF loans are typically for 20-years. The reviewer
does not agree that standard life expectancy for all engineering items
evaluated in a PER is 20 years. In addition some funding agencies allow for
loan terms of 30 or 40 years. It does not seem reasonable to blanket facility
life expectancy to 20-years just because that is the term of a loan. Collection
systems, wet wells and structures can often have life expectancies far
exceeding 20-years.
The applicant provided the fo#owing comment regarding the next three bullet items:
A facility plan (PER) is intended to be a high /eve/ overview of engineering
approaches. We streng/y be#eve that the type of analyses or alternative
screening described in the (fo#owing three bullets) as being 'missing' for these
elements are more aptly hand/ed at the pre-design stage, or simply through
engineering judgment at a later time. A facility plan for e comp/ex mechanical
WW-I'P simply cannot address ali the detailed design issues suggested. It is
neither cost-effective, nor appropriate. The PER does present alternative
analysis for unit processes that affect p/ant effluent performance, approach to
effluent quality, etc. We ask that these three bullets be stricken from the write
up.
The reviewer agrees with much of the applicant's argument. However, the review
committee as a whole should make the judgment on this issue. It seems reasonable to
defer some of these items to a more detailed study. However, it may not be fair to other
applicants to simply write off these issues. The cost of the items that were not evaluated
in detail may be as much as the cost of entire projects in other applications. The PER
outline does not state that certain types of issues have a waiver from the alternative
screening process.
· No alternative screening was provided for some of the proposed action items
such as: grit removal and headworks facility improvements, primary clarifier
hydraulic improvements, and plant water system improvements.
· No alternatives were evaluated for some of the proposed action items such
as: grit removal and headworks facility improvements, primary clarifier
hydraulic improvements, and plant water system improvements
· Not all reasonable alternatives were discussed as required in the alternative
screening section; such as: discussion of alternative means of providing
secondary power to the lift station, comparison of various lift station types,
and inclusion of an alternative that would address just the most serious
maintenance issues for the lift station problems.
· A sound justification was not provided for eliminating "Natural" treatment
alternatives. Although natural systems such as slow rate and rapid rate land
application may not be suitable as a substitute for the current discharge
permit they could have potential asa supplement to the existing mechanical
process. No discussion of this potential was provided, even though the report
noted that agricultural land is currently being irrigated in the vicinity of the
treatment plant.
The applicant provided a lengthy comment regarding this issue. If this comment
had been included in the PER, it would have provided additional justification for
not considering "Natural" treatment or disposal in more detail. The applicant
commented that MDEQ does not recognize land application as treatment but
could be a viable disposal means. Though land application is not treatment, it
may require a lower level of pretreatment than discharge to surface water which
may have a significant affect on process decisions at a mechanical treatment
plant. It remains the reviewers opinion that additional discussion and / or
analysis would have been appropriate for this item.
· The impact that I&l reduction would have on the treatment plant was not fully
discussed. The applicant stated that the reduction of I&l would help the
WVVTP. It would have been helpful if the PER had provided more information
about the reduction of I&l and what impact that would have on the treatment
facility. How much I&l reduction is expected due to the projects already
completed and how much reduction is anticipated with future collection pipe
replacement projects? This may not have entirely achieved the goals of the
project but some additional discussion could have provided a stronger
argument for the project.
· Detailed cost estimates were not provided for all of the alternatives, including
the grit removal and headworks modifications, the primary clarifiers hydraulic
improvements, and the plant water system improvements. The applicant
suggests that these items are beyond the level of detail required in a PER.
The reviewer disagrees. Even if detailed alternative comparison is not
justified, it seems reasonable to expect that a detailed cost estimate or at
least some discussion about the detailed scope such as pipe diameter, pipe
length, type of grit removal system envisioned, type of headworks changes
envisioned, etc.
· O&M costs and present worth analyses were not provided for some of the
alternatives including: grit removal and headworks facility improvements,
primary clarifier hydraulic improvements, and plant water system
improvements.
A comparative analysis was not provided for the following action items: grit
removal and headworks facility improvements, primary clarifie[ hydraulic
improvements, and plant water system improvements.
· Hydraulic calculations showing compliance with DEQ standards were not
provided as is required. The applicant questioned whether calculations were
required at the PER level The PER Outline section V.D. lists the
requirement that sufficient information to determine compliance with DEQ
design (hydraulic) requirements be provided. Calculations not provided
include collection system capacity versus design standards, calculations
showing the lift station flews versus capacity, calculations of hydraulic
capacity of the various unit processes at the W-FP.
· Meeting minutes from the 2006 public hearing were not provided.
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,
l0
and what deficiencies will remain upon completion of the proposed
project? (Describe any deficiencies that will not be resolved by the
proposed project. Describe any plans for resolving those deficiencies in
the future.)
Comment: The PER included master planning information. The proposed project
represents a logical phase of the recommended improvements. The major deficiency
that remains is the continued groundwater infiltration. The PER proposes that it be
addressed on a slow and steady basis over the next 30 years.
Are the deficiencies to be addressed through the proposed project the
deficiencies identified with the most serious 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.
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: Table 8-1 lists the near-term treatment facility improvements that were
recommended. None of these improvements included the required alternative screening
or formal screening discussions, not even a no action discussion. There may be no
reasonable altematives, but the report did not seem to address this point. Alternatives
for some of these items must exist; such as, alternative style gdt and headworks
equipment and arrangements, alternative methods of achieving the hydraulic upgrade
for the clarifier, and altematives for the plant water system such as a new well or locating
the restriction in the existing water supply line. As discussed above, more detail
comparing natural systems such as slow rate and rapid rate land application seems to
be justified.
The applicant stated,
"We do not believe that the level of analysis suggested is appropriate or
necessary in a PER for the items noted. Detailed analysis was performed on all
important issues that related to large project elements that affect effluent quality
or cost. We really believe that the items being called out as insufficient are
simply unfair for a report of this type looking at the complex treatment and
effluent quality issues analyzed.
The reviewer agrees with much of this point. However, one applicant's major issue is
anotheFs minor issue. Since the PER outline does not discuss how these type of issues
l!
should be handled any different/y, the review report has made note of them. The cost of
these items which the app/icent refers to as minor adds up to more than $500,000.
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 PER included information on two different population scenarios, a lower
bounds (LB) population and an upper bounds (UB) population. The City determined that
the LB scenario was the desired scenario. However, the solution for the RBC facility is
different for the LB scenario than for the UB scenario. The report discusses this fact and
the issues associated with the difficulty of predicting population growth. A concern exists
that the LB solution proposed may not be optimized with a longer term scenario or a
h!gher population growth scenario.
The applicant points out that any population and growth projections have associated
uncertainty. They go on to say, "The comments in this paragraph would seem to 'mark
down' the approach and proposed solution for honestly and accurately pointing out ~fsks
to the community. These risks are inherent in any solution even when they may not be
so honestly pointed out."
The intent of the reviewer is to honestly point out this situation in response to question
'e'. The applicant apparently felt it a warranted to evaluate a LB and an UB population
scenario. Since this type of analysis is not typically completed in a PER, it seems to
indicate that the applicant has a higher than typical level of concern about the accuracy
of growth projections.
The selected RBC alternative includes the use of proprietary patented equipment made
by Parkson Coroporation (data attached to Appendix P of the amended PER). The PER
includes a copy of a pilot study that was conducted in New Jersey on this equipment in
2003. MDEQ is sometimes resistant to approve equipment that has not been
extensively tested specifically in Montana. The reviewer presumes the proposed
technology is quite new since it was not mentioned in the original PER but then becomes
the recommended alternative in the amended PER.
There is some concern that cost control could be maintained when specifying a
proprietary equipment that will not have open competition during the bid process. The
applicant clarifies that the cost estimates in the PER have considered the lack of
competition for this equipment.
The PER assumes a 50% reduction will be achieved through I&l reduction activities such
as replacing the trunk mains. It is not clear from the PER what exact work this 50%
reduction corresponds to. What are the consequences if the actual reduction is much
larger or much smaller?. The report does not address this question.
The PER explains the substantial I&l impact on the existing flows then goes on to
estimate the current per capita flow of 146 gpcd. The PER also discusses the wintertime
flow rate is 115 gpcd which likely includes sizable amount of I&l. When projecting
t2
design flow rates for future populations it then utilizes these same per capita flow rates
for additional users adding to the system. This approach doesn't seem appropriate.
Additional users would more likely be contributing more traditional flows of 100 gpcd or
less. As more people connect to the system they will likely connect by adding new
service lines and new collection mains that are constructed to today's more stringent
leakage standards than what is serving the existing population. Thus, it seems that the
PER may have overestimated the future design flow rates somewhat. The impact on the
overall conclusions of the report are not certain.
The applicant responded to the preceding paragraph by stating,
"... The (per capita flow) conclusion is based on engineering judgment that could
be debated. Comparison of the approach that was taken in the PER and the
approach suggested by the reviewer results in similar, although not identical,
total flow numbers, depending on the assumptions made about the level of
infiltration reduction. We would suggest that the numbers in the PER are
acceptable and other reasonable approaches (as suggested by the reviewer)
would not result in estimates that would materially affect the results or
conclusions in the PER"
/t remains the opinion of the reviewer that it is impossible to determine the impact that
this issue would have on the recommended alternative without substantial additional
effort. An overestimated per capita flow rate of 46 gpcd across the anticipated increased
population of 1,651 yields an overestimated design flow of about 76,000 gpd. This
amount off/ow does not seem insignificant but its impact on the recommended solution
or its cost cannot easily be evaluated.
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 problems that were not discussed that could delay the
project.)
Comment: No. Detailed cost estimates were not provided for the gdt removal and
headworks facility, the primary clarifiers hydraulic improvements, the plant water system
improvements, or the RBC with Geo-Reactor units. A review of these cost estimates
was not possible since the information was not included. The implementation schedule
was adequate.
The applicant states, 'We have endeavored to provide adequate contingency and cost
escalation factors to ensure that the project is well funded."
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 carried out or which
could add significantly to project costs? (Does it appear that the Uniform
Environmental Checklist was adequately completed? Were all of
environmental concerns noted in the Uniform Environmental Checklist
]3
adequately addressed in the PER? Describe the impact this project
would have on the environment.)
Comment: Yes, environmental problems have been adequately addressed. No
apparent environmental or technical problems were noted.
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: N/A.
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:
SUMMARY - STATUTORY #3
The MDOC scoring team felt that the preliminary engineering report was complete, and
that there were no issues of any significance that were not adequately addressed. The
MDOC scoring team determined that a level 5 score is appropriate given the lack of
questions and issues concerning the PER.
14