HomeMy WebLinkAbout20090392.tiffNC W C,D
Northern Colorado Water Conservancy District
220 Water Avenue • Berthoud, CO 80513 • 970-532-7700 • fax 970-532-0942
February 2, 2009
Mr. Bill Garcia
Weld County Commissioners
P.O. Box 758
Greeley, CO 80632
Dear GOlitmnissiefier-Crareia:
As you are aware, the Northern Integrated Supply Project (NISP), which is sponsored by
15 water providers serving nearly 200,000 residents in the northern Front Range of Colorado, has
been involved in an Environmental Impact Statement (EIS) process for five years. A draft EIS
was issued in the spring of 2008 by the U.S. Army Corps of Engineers (Corps). The public
comment period is now complete. The Corps is presently reviewing the more than 2,000
comments.
NISP Participants are fully engaged in the EIS process and are committed to seeing it completed
in a fair, scientifically -based, defensible fashion. To properly analyze and evaluate issues that
were raised during the public comment period, NISP Participants contracted with Black &
Veatch Corporation, a nationally known science and engineering firm having recognized
expertise in water quality. Black & Veatch was retained to conduct independent studies of three
issues identified in the public's comments related to the project's alleged impact on water quality
in Horsetooth Reservoir and the Poudre River, as well as the cost of wastewater treatment. These
issues were primarily raised by the City of Fort Collins, the Environmental Protection Agency,
and the Colorado Department of Public Health and Environment.
In each case, Black & Veatch's scientifically -based analyses of the issues shows that the problem
is not of the magnitude represented in the public comments and can be easily addressed. The
attached fact sheet describes the three issues and summarizes the key conclusions by the
scientific and technical experts. Also enclosed is the letter to the Corps describing in more detail
each of the three principal issues, along with the technical analyses and conclusions reached. As
shown in the Black & Veatch analyses, the impacts caused by the implementation of NISP do
not rise to the level of significance as is alleged in the DEIS public comments addressing these
specific areas of concern. If you are interested in reading Black & Veatch's reports we will be
happy to provide them to you.
After several years of study and $5.5 million expended on the EIS process to date, it is the NISP
Participants' hope that the Corps will be able to finalize the EIS and issue its Record of Decision
and permit for the project sometime in 2009 or 2010. The NISP Participants are committed to
assuring that NISP is a carefully designed and environmentally sensitive project. They are also
committed to mitigating project impacts and to cooperating with others, where practicable, to
improve the environment. The Participants truly believe that NISP is the best way for their
communities to meet some of their future water needs.
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2009-0392
Commissioner Bill Garcia
February 2, 2009
Page 2
Our goal will be to keep you informed and updated as the EIS progresses throughout 2009.
Thank you for your interest in this project. If you have questions, please do not hesitate to
contact Ms. Julie McKenna (303) 898-8494, Mr. Brian Werner (970) 622-2229 or myself at
(970) 532-7700.
Sincerely,
Eric W. Wilkinson
General Manager
cps
Enclosures
NISP Fact Sheet
Re: Fort Collins comments on water quality and water treatment issues
(Technical analysis conducted by Black & Veatch Corporation)
Issue — NISP will increase total organic carbon levels in Horsetooth Reservoir requiring Fort
Collins to invest $50 to $90 million in infrastructure improvements and increasing their
operational costs to treat water by $3 million annually.
Conclusion
1. Any increase in Total Organic Carbon (TOC) concentrations in Horsetooth Reservoir
caused by the introduction of Glade Reservoir water into Horsetooth Reservoir would
be very small.
2. Fort Collins' own research and studies (reports prepared by their own staff) indicate
that its water treatment plant can successfully treat water that has much higher TOC
concentrations than that predicted in Horsetooth Reservoir as a result of the
introduction of Glade Reservoir water.
3. Improvements of $50 to $90 million (as suggested by Fort Collins) would not be
required, nor would the $3 million in annual operating costs.
Issue — NISP will cause lower flows in Poudre River requiring Fort Collins to spend $75 to $125
million in upgrades to their wastewater treatment plants based on less dilution capability of the
Poudre River.
Conclusion
1. NISP will have no impact on existing or future infrastructure or operating
requirements for the City's wastewater treatment plant operations.
2. Discharge requirements for the Fort Collins wastewater treatment plants are based on
low flows within the stream or river receiving the plant's discharge. For the Fort
Collins facilities, the specified low flow discharge standard is significantly lower than
the flows the NISP Participants have agreed must be in the Poudre River before NISP
will divert water. Thus, NISP will not impact the low flow discharge standards that
govern the Fort Collins discharge permits or plant operations.
3. Any required upgrades to the City's wastewater treatment facilities because of
changes to future potential water quality -based effluent limits, will he required
whether NISP is built or not.
Issue — Contaminated groundwater caused by an abandoned missile base near the Glade
Reservoir could possibly co -mingle with Glade Reservoir water and be delivered to Horsetooth
Reservoir or the Poudre River.
Conclusion
1. The concentrations of Trichloroethyene (TCE) in the groundwater are so low
that even without any collection and treatment system, the TCE levels in either
Glade or Horsetooth reservoirs would be undetectable.
2. If necessary a drain system for treating the water would easily be constructed to
mitigate any threat or potential threat posed by the contamination.
Northern Colorado Water Conservancy District
220 Water Avenue • Berthoud, CO 80513 • 970-532-7700 • fax 970-532-0942
January 16, 2009
Mr. Chandler Peter
U.S. Army Corps of Engineers
9307 South Wadsworth Boulevard
Littleton, CO 80128-6901
Dear Mr. Peter:
RE: NISP Comments - Technical Analyses of Total Organic Carbon (TOC), Trichloroethene
(TCE), and Wastewater Treatment Plant Impacts
The U. S. Army Corps of Engineers (Corps) has received a number of comments on the Draft
Environmental Impact Statement (DEIS) for the Northern Integrated Supply Project from the
City of Fort Collins, the Environmental Protection Agency (EPA), and the Colorado Department
of Public Health and Environment (CDPHE), that relate specifically to the City of Fort Collins'
drinking water quality and wastewater treatment concerns.
In an effort to better understand these issues and comments, the Northern Integrated Supply
Project (NISP) participants engaged the services of scientific and technical experts to review and
analyze those comments. This team of experts has many years of demonstrated and specialized
expertise and experience in drinking water and wastewater treatment technical processes and
regulatory compliance. Their analyses of the issues are included with this letter.
The DEIS comments are summarized in this letter, along with key conclusions from NISP
participants' team of technical and scientific experts.
Total Organic Carbon
Comments:
• During spring runoff, seasonally higher levels of Total Organic Carbon (TOC)
would be diverted from the Poudre River into the Glade Reservoir forebay and
then transported to Horsetooth Reservoir through the Glade-Horsetooth pipeline.
• Since the Glade-Horsetooth pipeline inlet to Horsetooth Reservoir would be
located at the north end of the reservoir, this water would not fully mix with the
rest of Horsetooth water and would find its way to the Soldier Canyon inlet,
which is also near the north end of the reservoir.
• The Fort Collins water treatment facility could not treat the water and meet
drinking water standards without investing in major infrastructure improvements
and increasing their operational costs.
Mr. Chandler Peter
January 16, 2009
Page 2
• The City of Fort Collins would need to spend anywhere from $50 to $90 million
for one-time plant improvements, as well as approximately $3 million for annual
operating expenses.
Technical Analysis:
• Although long-term, average TOC concentrations could range between 5 mg/1 and
6 mg/I, it is likely that lower avenges would result from physical, chemical, and
biological processes during detention in Glade Reservoir.
• TOC concentrations in Horsetooth Reservoir might increase from the historical
baseline value of 3.0 mg/I to somewhere between 3.07 mg/I and 3.16 mg/1.
• The City of Fort Collins has successfully developed and implemented a
coagulation scheme in its water treatment operations for treatment of Poudre
River water as high as 13 mg/1 TOC.
• Treating blends of Poudre River and Horsetooth Reservoir waters (after receiving
Glade Reservoir water) at the Fort Collins water treatment facility would likely
result in only a marginal increase in optimal alum (coagulant) dosage, estimated
in cost increases of less than $3,500 per year.
• Installation of additional TOC treatment processes would not be necessary to
meet all applicable state and federal drinking water standards using currently -
available treatment processes and proven facility operating practices.
Summary:
• Any increase in TOC concentrations in Horsetooth Reservoir caused by
introducing Glade water would very small.
• Fort Collins' own research and studies indicate that its treatment plant can
successfully treat water that has much higher TOC concentrations.
• Improvements of $50 to $90 million would not be required, nor would $3 million
for annual operating costs.
Trichloroethene
Comments:
• Groundwater contaminated with Trichloroethene (TCE) would co -mingle with
Glade Reservoir forebay waters.
• Since the Glade Reservoir forebay water would be delivered to Horsetooth
Reservoir, the Fort Collins water treatment facility would have to treat TCE-
contaminated water.
• Glade Reservoir would cause the migration of TCE-contaminated water to the
Poudre River.
Mr. Chandler Peter
January 16, 2009
Page 3
Technical Analysis:
• Although it is difficult to project if NISP operations will affect the TCE plume
migration, if any contaminated groundwater were to flow into the Glade Reservoir
forebay, the TCE concentration in the forebay, after blending with diverted
Poudre River water in the forebay, would be nearly two orders of magnitude (100
times) less than the drinking water maximum contaminant level. After mixing
with Horsetooth Reservoir water, the TCE concentration would be less than the
method detection limits (undetectable).
• Since TCE treatment is relatively simple and straight -forward, a drain system to
collect and convey the contaminated groundwater for treatment could easily be
constructed, if needed.
Summary:
• The concentrations of TCE in the groundwater are so low that even without any
collection and treatment system, TCE concentrations in Glade or Horsetooth
Reservoirs would be undetectable.
Wastewater Treatment
Comments:
• Lower flows in the Poudre River would result in more restrictive wastewater
treatment plant discharge limitations because of less dilution capability of the
river.
• Major improvements would be needed at the wastewater reclamation facilities to
treat the wastewater to a greater degree and discharge higher quality effluent.
These improvements will cost the City of Fort Collins $75 to $125 million.
• Annual operation costs required to obtain higher levels of treatment would be
significant.
Technical Analysis:
• Wastewater treatment plant discharge requirements are based on CDPHE, Water
Quality Control Commission, regulatory in -stream low flows. Due to the junior
priority of NISP water rights, these regulatory low flows will not be affected.
• Since the Poudre River is an "effluent dominated stream," Fort Collins must
essentially meet stream standards at the point of discharge regardless of in -stream
flow levels.
• Potential future ammonia limits will not be dependent on the quantity of flow in
the river.
• The Drake Wastewater Treatment Facility does not discharge to the Poudre River,
but rather to the Fossil Creek Reservoir Inlet Canal.
Mr. Chandler Peter
January 16, 2009
Page 4
Summary:
• NISP will have no impact on existing or future infrastructure or operating
requirements for the City of Fort Collins' wastewater treatment operations.
• Future potential water quality -based effluent limits for nutrients (ammonia) may
require upgrades to the wastewater treatment plants. These upgrades will be
required with or without NISP.
This technical information is being provided as we proceed through the remaining phases of this
EIS process. If you have questions please feel free to contact Mr. Carl Brouwer, Project
Manager.
Sincerely,
Eric W. Wilkinson
General Manager
cps
Enclosure
cc: Carl Brouwer
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