HomeMy WebLinkAbout20070584.tiff •
,,-,,,,-,. . ,, ,-A\-_-.1./,, F�� JVA,Incorporated
��� 1319 Spruce Street
Boulder,CO 80302
February 14, 2007 Ph: 303.444.1951
Fax'.303.444.1957
Jennifer Miller, P.E., District Engineer Toll Free 877.444.1951
CDPHE WQCD-ES-B2
Web site:
4300 Cherry Creek Drive South www.jvajva.com
Denver, CO 80246-1530 E-mail.
info@jvajva.com
Re: Town of Mead Wastewater Treatment Plant Site Application— Response to CDPHE
Review Comments Principals
David M.Houdeshell
Dear Ms. Miller: Robert e Hennes
Thomas P Skinner
The purpose of this letter is to respond to your letter dated January 11, 2007 regarding the Thomas S.Soell
referenced project and to provide supplemental information regarding the identified issues Kevin A.Tone
so that the CDPHE can proceed with approval of this site application. In addition, this Cindera L.Ward
letter memorializes some discussion items from the subsequent meeting that was held on
January 23, 2007 wherein JVA and Town representatives discussed our responses with Structural Engineering
CDPHE staff, and provided the Division with additional information as noted herein. Jennifer Arndt
Daniel F Cooke
Prior to moving into the responses, we would like to point out that the Town has already Mark C.Cormier
undergone a thorough four-month review and public comment period with the North Front Kathy A.Gilnooly
Range Water Quality Planning Association (NFRWQPA). The NFRWQPA review process Heidi M Hall
addressed many of the same concerns and issues summarized in the Division's letter. The Derek D Henderson
NFRWQPA concerns concentrated on two major issues in great detail: the St. Vrain Michael R Hope
Sanitation District (SVSD) consolidation evaluation issue, and how to address the proposed Craig M Kobe
East I-25 Sanitation District issue. The Town has expended significant time and resources Brian D Kirtland
addressing these two issues and discussing them with the NFRWQPA evaluation committee Ronald F Manske
and members prior to obtaining approval for this site application. We strongly feel that the Michael J.McDonald
NFRWQPA has performed a thorough and proper review as required by Section 22.3(2)(d), David M Mier
and their review should not have to be revisited by CDPHE. In addition, we are Derek M Pedersen
questioning why the CDPHE is not following the spirit of its regulations in Sections 22.3(3) Thomas M Smith
and 22.3(4) which intends for the 208 planning agency to implement a coordinated review Terry L.stab,
and comment process for their region. The Town is one of the first communities to also
Jeannette M.Torrents
receive an approved Utility Plan from NFRWQPA under their new utility plan review
Sarah E.Watts
criteria, which the Town prepared in parallel with this site application, and the two plans
are congruent with each other.
Civil Engineering
The Town has concluded that it is cost effective and appropriate that it construct its own Jon C Driggers
wastewater treatment facility. Please note that neither the Town nor CDPHE has received John F Frazee
any letter from any party objecting to moving forward with the proposed wastewater Charles P Hager
project. The proposed site has been posted since August 1, 2006 and remains posted. Alaina K Mader
Additionally, we have received approval from all the required agencies as noted in Section Howard M McHenry
22.3(11)due to their signing"yes" on the submitted site application. aroyn A.Sullivan
Melissa F Tolve
Administration
Andrew P Krizman
Gregory A.Laurson
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C / Town of Mead Wastewater Treatment Plant Site Application
\- -- Response to CDPHE Review Letter
February 14,2007
Page 2 of 6
The Town and JVA's responses follow the numbered items in your letter.
1. A site application with the required approval signatures and a "yes" included on the site
application form from Weld County, NFRWQPA, and the Town of Mead was provided
to the Division in the meeting on January 23, 2007. Division personnel wanted
clarification on the Weld County approval comments, specifically Item 1. The Division
offered at the January 23, 2007 meeting to contact Weld County personnel to discuss the
implications and possible impacts of their site application approval comments, which the
Town must respectfully point out pertain to land planning issues, rather than the issue at
hand, which is water quality management. We believe the two conditions of approval
made by Weld County thus have no basis for consideration by the CDPHE when
addressing water quality management plans. Land planning issues have traditionally
been addressed in Colorado by counties and towns through various statutory mechanisms
that are separate from wastewater regulations. The Town strongly believes this is not an
issue that the CDPHE should be involved in.
As indicated in the revised site application, the project has received Weld County Public
Health Department approval. The use of the word "contingent" in their first sentence has
to be read in context with their second sentence. In their approval comment letter, Weld
County reserved the right to amend comments upon release of the Court's decision, but
did approve the project. Please understand that the Weld County Public Health
Department is in a delicate position since the Town of Mead and Weld County
Commissioners are currently involved in the lawsuit pertaining to the proposed East I-25
Sanitation District. The Town has been informed that the conclusion of this case might
take a couple years. This is a very complicated lawsuit and the information that pertains
to the litigation is explained on pages 11 and 12 of the Utility Plan.
The Town intends to be able to provide service to its entire 208 service area as stated
under item g. on page 11 of the Utility Plan. Concerns were raised in the NFRWQPA
review process that the Town of Mead was dependent on the proposed East I-25
Sanitation District area for the financing of the proposed Mead WWTF. That is not true,
because the initial phase of the proposed Mead WWTF is needed to serve the existing
Town customers and approved Town growth, mostly west of I-25. The proposed Mead
WWTF location will allow service to the entire 208 area, including the area east of I-25.
When service is needed for this area, the developers will be responsible for any new
infrastructure improvements to connect to the Town's WWTF, as would be the case for
any new developments.
As you are aware, the Town has a CDPHE compliance schedule which requires that a
new treatment facility be on-line by November 2009. The Town does not want to be out
of compliance with public health regulations and the CDPHE compliance schedule due to
an on-going court case which is not entirely relevant to the proposed WWTF. In
addition, the Town does not want to delay the proposed WWTF construction, since the
existing treatment plant is nearing permitted capacity.
7 Town of Mead Wastewater Treatment Plant Site Application
Response to CDPHE Review Letter
February 14,2007
Page 3 of 6
2. The Town has forwarded the Division, under a separate cover, the Lake Thomas facility
seepage rate testing report by Terracon, dated February 12, 2005. The seepage rate
testing report was sent to the Division soon after its completion to fulfill the Lake
Thomas compliance schedule. Please verify that the Division now has this report in its
files.
The Lake Thomas facility has not discharged to waters of the State since the Town took
ownership of the facility in 2001. This can be attributed to low influent flows and to
evaporation, not to excessive exfiltration. The Lake Ridge Condominiums have not been
marketed very well, and only five of the 29 units are presently occupied. The Town
requests that provisions of the discharge permit remain in force until such time as
discharge occurs. Because the Lake Thomas facility has such a low flow rate and has
not discharged, the Town does not see the need to address alternative service or
consolidation. The Town would also request that evaluation of solutions be performed
after the treatment plant has discharged for approximately six months, as stated on page
3 of the discharge permit rationale. The Lake Thomas facility has not had a problematic
history since the Town took over operations.
The 2001 Lake Thomas improvements consisted of stabilizing and repairing the banks of
the lagoon, repairing the influent and effluent structures, and replacing the old chlorine
contact chamber. The Town expended approximately $60,000 to refurbish this plant,
which had not been operational since 1998. The District Engineer at the time was aware
of the status of this treatment plant, and the Division should have on file a record of his
site visits.
3. A copy of the JR Engineering WWTP Facilities Study was provided to the Division at the
January 23, 2007 meeting. This study was primarily used as a tool to educate the Town
board members of the financial impacts of wastewater systems and to select a treatment
plant site.
The SVSD offer letter was supposed to be included in all the Appendix I binders and we
apologize if it was omitted from the submitted set. A copy was provided to the Division
at the January 23, 2007 meeting.
4. The Town has had difficulty obtaining a thorough and complete offer for service from
SVSD and, furthermore, an offer that has been approved by their Board of Directors. As
indicated above, a copy of the most recent SVSD offer later was provided at the January
23, 2007 meeting. The consolidation analysis was evaluated with SVSD input for
several years, including the analysis that was performed in the WWTP Facilities Study
dated February 4, 2005. The SVSD draft offers keep changing, most of them were made
orally and not in writing, and do not address all the costs which SVSD has previously
implemented for Town customers served through the current IGA.
The WWTP Facilities Study was started back in 2002 and has been updated several times
to address consolidation and treatment plant locations that will serve the Town and its
Town of Mead Wastewater Treatment Plant Site Application
Response to CDPHE Review Letter
February 14,2007
Page 4 of 6
208 service area. This study was first issued July 11, 2003 and updated July 23, 2004
and on September 29, 2004. The final draft was then approved on February 4, 2005. The
Town has expended significant funds trying to work with the SVSD over this timeframe,
and the Town has not yet obtained a complete and clear offer from the SVSD since this
process started in spite of their belief that they have. This resulted in the Town's efforts
in 2005 and 2006 to obtain the needed information for this analysis, the Utility Plan, and
this site application by searching out actual costs by itself from the SVSD's regulations,
master plan study and wastewater rate study as they appeared to be implemented. The
costs shown in Appendix I reflect our professional judgment and the results of our
research efforts into SVSD rates. The methodology is documented and based on
information from the aforementioned SVSD sources.
The Town acknowledges that SVSD has been working on a master plan and rate study
since 2005. However, the studies' completion dates and adoption of study findings,
including a revised rate structure, have been delayed. Given the approaching compliance
schedule deadline, the Town used the best information available and cannot afford to wait
longer for updates. The Town should not be held responsible or delayed because SVSD
is not fully organized for potential service negotiations.
The Town also needs to re-iterate that there are multiple non-monetary issues involved
with a potential consolidation that are described on pages 31-33, Items a through m, of
the Utility Plan.
5. Present worth analysis procedures that have been established by the EPA use the specific
operation and maintenance costs for each treatment entity. We have used operation and
maintenance costs consistently for both alternatives.
The SVSD O&M cost were estimated based on the April 2006 Sewer Rates and Related
Charges for the St. Vrain Sanitation District Report (SVSD Sewer Rate Study)
completed by The Engineering Company (TEC). Relevant sections of this study were
included in Appendix I. The projected SVSD Sewer Rate Study detailed annual
operating expenses, which were used as an accurate basis for estimating O&M costs for
the SVSD consolidation option. Expanding on the explanation in the second paragraph
of page 30, the SVSD Sewer Rate Study projected 2008 cost ($566,320) was multiplied
by a ratio of flows to determine a proportional share of the 2008 O&M cost ($257,000).
The 2008 flow proportional O&M cost was lowered by roughly one operator's salary to
$200,000. The adjustment was made since the incremental flow increase should not
necessarily relate to a proportional need for WWTF operators. A table showing the 2008
SVSD projected budget, flow proportional O&M budget, and adjusted O&M budget has
been attached.
6. The methodology for this present worth comparison was required to satisfy the
NFRWQPA for approval of the Utility Plan by the utility review committee. The
NFRWQPA requested that the tap fee costs and capital construction costs be separated
for ease of comparison. Consequently, Table 8A is a comparison of expenses that Mead
Town of Mead Wastewater Treatment Plant Site Application
Response to CDPHE Review Letter
February 14,2007
Page 5 of 6
customers will experience (tap fees and immediate construction costs) and Table 8B is a
comparison of capital costs for each respective Utility. Table 8A presents the amount
that Mead customers will pay for service through tap fees at either Mead or SVSD. In
comparison, Table 8B is the capital infrastructure costs for service at either Mead or
SVSD. Both alternatives serve the west side of I-25, and sewer line costs to convey flow
to each treatment facility are included in Table 8B. Both cost comparison tables show
that the Town has no economic incentive to consolidate with SVSD.
Please understand that this comparative evaluation is for the 0.5 MGD capacity and the
necessary infrastructure for the initial phase. The SVSD alternative requires a much
larger scope of piping and lift station infrastructure in the initial phase than the Town of
Mead alternative because of the distance and topography involved to reach the SVSD
facility.
In the future, the Town plans to install a lift station on the east boundary as shown in
Figure 4. This analysis did not include this lift station since it is not necessary for the 0.5
MGD capacity and future flows from this area are not known. We recognize that the
SVSD alternative would provide service to the eastern portion of our 208 planning area
from the onset, but this benefit comes at a significant cost. The reason the SVSD
alternative is so expensive is because of the additional infrastructure that is necessary to
transport flows to the SVSD. The Town had to consider that it may be many years before
these additional costs for building the infrastructure east of I-25 could be recovered from
development east of 1-25. In comparison, the Town alternative is affordable and does not
require the additional infrastructure and associated costs until development occurs.
7. The calculations for line 1 in Table 8A is shown on pages 4 and 5 in Appendix I. The
SVSD letter stated that they would provide up to 700 free taps for existing customers.
However, the analysis used the 2006 existing Mead customer base of 612 taps, as shown
in Table 2.
8. The Implementation Plan schedule is as follows:
• Site Approval —February 2007 (anticipated)
• 30% Design Submittal — Submitted December 2006 and CDPHE response
expected by April 2007
• Discharge Permit Application — Submitted February 2007 (after Site Approval)
and CDPHE response expected by August
• Final Design Submittal— May 2007 with CDPHE response before July 2007
• Bid Documents Available—Early June
• Construction—Start July 2007 with facility startup by July 2008
The Town would request the assistance from the CDPHE to meet these scheduled dates
due to having received an Energy Impact Grant for one million dollars that must be
expended prior to the end of 2007. A copy of the Energy Impact Grant letter was
provided to the Division in the January 23, 2007 meeting.
fk- \ , Town of Mead Wastewater Treatment Plant Site Application
��1WJ Response to CDPHE Review Letter
February 14,2007
Page 6 of 6
9. The Town has ownership and legal control of the proposed site. The deed was included
in Appendix G. The outfall and WWTF discharge will occur on the Town's property
and is shown in its approximate location on Figure 7 following page 35. This discharge
location is also shown in the PEL letter on page 2 of 10 as the "east 1-25 location" for the
two possible discharge points. A copy of the plat has been attached for the Division's
files.
Thank you for meeting with the Town and Town representatives on January 23, 2007 to discuss the
site application review. We expect that these responses will allow you to proceed with the approval
of this site application. If you require additional information please do not hesitate to contact our
office.
Sincerely,
JVA, Inc
¢Acs-e
evin A. Tone, .E.
ice President
Enclosures
cc: Michael D. Friesen- Mead Town Manager
Jim Wright -J. B. Wright and Associates
Connie O'Neill —NFRWQPA
Rob Masden—Weld County Commissioner
Kent Kuster—CDPHE
Brad Simons - CDPHE
2008 Adjusted 0.5
2008 Projected 2008 0.5 MGD Flow MGD Flow
Item O&M Budget Proportional Cost Proportional Cost
Auto and Truck Expense $ 4,200 $ 1,909 $ 1,909
Cleaning $ 2,280 $ 1,036 $ 1,036
Conference/Seminars $ 1,800 $ 818 $ 818
Consultant Fees $ - $ - $ -
Contract Labor $ - $ - $ -
Contract Services $ 1,500 $ 682 $ 682
Dues/Subscriptions $ 600 $ 273 $ 273
Employee Education/Training $ 1,260 $ 573 $ 573
Equipment Maint and Repairs $ 14,000 $ 6,364 $ 6,364
Equipment Rental $ - $ - $ -
Laboratory-Equipment $ 2,000 $ 909 $ 909
Laboratory-Supplies $ 7,400 $ 3,364 $ 3,364
Legal $ - $ - $
Licenses and Fees $ 8,658 $ 3,935 $ 3,935
Maintenance and Repairs-Lift Station $ 6,000 $ 2,727 $ 2,727
Maintenance and Repairs-Plant $ 4,800 $ 2,182 $ 2,182
Maintenance and Repairs-Old Plant $ 600 $ 273 $ 273
Maintenance and Repairs-Ops Bldg $ 2,600 $ 1,182 $ 1,182
Maintenance and Repairs-Headworks $ 1,000 $ 455 $ 455
Maintenance and Repairs-Wetlands $ 600 $ 273 $ 273
Meals $ 500 $ 227 $ 227
Mileage $ 120 $ 55 $ 55
Miscellaneous $ 2,000 $ 909 $ 909
Payroll Expenses-401K $ 7,566 $ 3,439 $ 3,439
Payroll Expenses-Health/DentalNision $ 16,936 $ 7,698 $ 7,698
Payroll Expenses-Life/AD&D $ - $ - $
-
PayrollExpenses-Medicare $ 2,620 $ 1,191 $ 1,191
Payroll Expenses-Payroll Taxes $ 3,613 $ 1,642 $ 1,642
Payroll Expenses-PERA Contr. $ 18,067 $ 8,212 $ 8,212
Payroll Expenses-Salaries $ 180,664 $ 82,120 $ 26,065
Payroll Expenses-SUTA $ 542 $ 246 $ 246
Payroll Expenses-Workman's Comp $ 613 $ 279 $ 279
Payroll Expenses-SickNacation $ - $ - $ -
Postage and Shipping $ 640 $ 291 $ 291
Safety $ 6,000 $ 2,727 $ 2,727
Sewage Collection/Bio-solids Removal $ 64,000 $ 29,091 $ 29,091
Studies-Master Plan $ - $ - $ -
Supplies-Office $ 3,435 $ 1,561 $ 1,561
Supplies-Operating $ 16,487 $ 7,494 $ 7,494
Telephone- Lift Station $ 962 $ 437 $ 437
Telephone-Operations Building $ 4,100 $ • 1,864 $ 1,864
Telephone-Headworks Building $ 60 $ 27 $ 27
Testing $ 15,000 $ 6,818 $ 6,818
Trash removal $ 1,200 $ 545 $ 545
Travel $ 1,500 $ 682 $ 682
Uniforms/Clothing $ 2,100 $ 955 $ 955
Utilities-Old Plant $ 10,694 $ 4,861 $ 4,861
Utilities-Operations Building $ 85,995 $ 39,089 $ 39,089
Utilities-Headworks $ 55,456 $ 25,207 $ 25,207
Utilities-Lift Station $ 2,756 $ 1,253 $ 1,253
Utilities-Plant $ 397 $ 180 $ 180
Total $ 563,320 $ 256,055 $ 200,000
File contains
oversized map
Please see original file
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