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Item 8D AGENDA ITEM # 8D AUGUST 23, 2010 JCEA MEMORANDUM Subject: Response to Comments on Table 12.1 Alternative Comparison from Final Report - TMDL Compliance Program Evaluation - City of Atlantic Beach Prepared for: City of Atlantic Beach, Florida Prepared by: J. Collins Engineering Associates, LLC (JCEA) Date: August 12, 2010 Executive Summary J. Collins Engineering Associates, LLC (JCEA) has reviewed & provided a response to Commissioner Carolyn Woods comments made during a Workshop meeting on August 3, 2010 concerning the phase -out of Buccaneer Wastewater Treatment Facility. The comments were regarding Table 12.1 from the "Final Report - TMDL Compliance Program Evaluation - City of Atlantic Beach ". General The comments on Table 12.1, though well thought out, did not address all the history of the TMDL Study. After reviewing all of the facts and studies completed during the TMDL process, the approved plan to phase out Buccaneer WWTP, construct the force main and upgrade WWTP #1 was, and still is, clearly the most cost - effective alternative to meet the TMDL Requirements. Note that the report is based on life cycle costs; revenues are not part of the study. Table 12.1 listed only the minimum capital improvements needed to implement nitrogen reduction upgrades. The report also stated there were other items, not listed in the table, but nonetheless necessary to keep the Buccaneer plant operational. These items included replacing plant tankage that is beyond its design life, and implementing approximately $3M worth of improvements noted in the 2006 Sewer Master Plan Update. During the Public Workshop & Presentation of HDR's TMDL Preliminary Design Report on 12/15/08, the slide presentation noted the Present Worth of $9.2M to keep Buccaneer in service vs. $952,000 to Phase out Buccaneer. After the presentation, it was the consensus of the Commission to support the consultant's recommendations and on March 16, 2009 the Commission approved the engineering contract for -Force main, flow shedding and abandonment of WWTP #2 1. COLLINS ENGINEERING ASSOCIATES, LLC PAGE 1 OF 2 AGENDA ITEM # 8D AUGUST 23, 2010 - Upgrading the existing WWTP #1 to meet advanced treatment standards for nitrogen Responses to the Specific Questions are: 1. "Capital Cost Decommissioning WWTP #2 does not include the $2.6M impairment loss for closing plant in year 3 instead of 15 years of use." o Impairment is an accounting term, referring to the book value of assets which affect taxes for private businesses, not public entities such as the City of Atlantic Beach. It has no affect on the capital, operating or life cycle costs of the WWTP facilities, and is not pertinent to the analysis of how to most cost - effectively meet the TMDL requirements. 2. "Cost Saving and life cycle analysis cost estimates assume operating at full capacity, when in reality this will probably never be realized. o Life cycle costing is typically done on a 20 -year cycle and the 20 -year design capacity, as that is the expected useful life of most wastewater treatment facilities. Note that operating costs used in the study were based on current actual operating costs at the time of the study. a. "Need to justify design so far beyond need." o The Florida Department of Environmental Protection (FDEP) will not issue a permit for a treatment plant designed at current capacity. Designs are based on a twenty year planning period per FDEP sanctioned guidelines of the "Recommended Standards for Wastewater Facilities." b. "Final TMDL report of March 2009 details in table 3.2 ww flow not to reach 2002 levels until well after 2027, section 3.5 attributes declining ww rates to sewer rehabilitation which continues and is expected to reduce flows by approximately 30 -40%, (this figure is not even included in the already reduced flow projections)." o While the 2006 Sewer Master Plan Update estimated an inflow /infiltration (I /I) rate of approximately 30% during rainfall periods, the extraneous I/I flows vary greatly during wet and dry periods. A specific average daily flow reduction for sewer rehabilitation cannot be determined. Even with a robust sewer rehabilitation program, only a portion of the I/1 is removed. It would not be prudent to use these estimates to make firm future reduced flow projections for WWTP planning. c. "Maximum capacity design standard was derived from the Comp Plan which is in strict contradiction to all empirical data given in all of the reports." o The maximum capacity design standard was not derived from the Comp Plan. The study used flow estimates from the 2006 Sewer Master Plan Update, the now approved CUP application, and the 2006 and 2008 Wastewater Plant Capacity Analysis Reports to provide a best estimate of future flows. The Comp Plan levels of service were used only as a comparison. 3. "Revenue projections used in this report were based on which flow assumptions? o No revenue projections were included in the TMDL study. The study looked at capital and operating costs only. 4. "$1M reduction for sale of property in Alternative 1 is not valid, same $ amount should be shown for Alternative 3 because the asset is maintained by the City so the value is still present. This results in the actual dollar Capital Cost for Alternative 1 at $13,550,000 and for Alternative 3 $8,950,000. This is a $5M dollar savings. The additional operating cost of $115,848 per year would take 43 years to add up to $5m million dollars." o Although the column heading reads "Property Value," it was calculated as property sold and should actually read "Amount Received from Sale of WWTP Property." If Buccaneer WWTP stays in service, the sale of the property is not possible. The table values are correct as presented. ..J. (01.1.1yS F,maNd 1 .RING :%SSG( I 11 .5, I,L( PAGE 2OF2 AGENDA ITEM # 8D AUGUST 23, 2010 ``- JCEA MEMORANDUM Subject: Response to Comments on Table 12.1 Alternative Comparison from Final Report - TMDL Compliance Program Evaluation - City of Atlantic Beach Prepared for: City of Atlantic Beach, Florida Prepared by: J. Collins Engineering Associates, LLC (JCEA) Date: August 12, 2010 Purpose At the request of the City of Atlantic Beach, J. Collins Engineering Associates, LLC is herein providing our responses to the questions and concerns from Commissioner Carolyn Woods which were presented during a Workshop meeting on August 3, 2010. Commissioner Woods' comments concern a table from the "Final Report - TMDL Compliance Program Evaluation - City of Atlantic Beach ". The table in question, Table 12.1, is a summary of the alternative comparisons conducted during the TMDL Study. The Table 12.1 (from Final Report) with Commissioner Woods' comments is attached in Appendix A. General Response to Comments The comments made about Table 12.1 suggest that the decision to phase out the Buccaneer Wastewater Treatment Facility (WWTF) is not the best, most cost - effective TMDL Compliance alternative for the City of Atlantic Beach. These comments state that the Buccaneer WWTF should remain in service since it has, in their opinion, the lowest overall present worth cost. The comments on Table 12.1, though well thought out, did not include all the history of the TMDL Study. After reviewing all of the facts and studies completed during the TMDL process, the approved plan (to phase out Buccaneer WWTP, construct the force main and upgrade WWTP #1) was, and still is, clearly the most cost - effective decision to meet the TMDL Requirements. Table 12.1 listed only the minimum capital improvements needed to implement nitrogen reduction upgrades. The report also stated there were other items, not listed in the table, but nonetheless necessary to keep the Buccaneer plant operational. These items included replacing plant tankage that is beyond its design life, and implementing approximately $3M worth of improvements noted in the 2006 Sewer Master Plan Update. J. COLLINS ENGINEERING ASSOCIATES, LLC PAGE 1 OF 6 AGENDA ITEM # 8D AUGUST 23, 2010 RESPONSE TO COMMENTS - TABLE 12.1 - FINAL REPORT - TMDL COMPLIANCE PROGRAM EVALUATION Overview of Alternative Selection for TMDL Compliance The results of the Preliminary Design TMDL Compliance Report was presented by HDR/JCEA to the City Commission at a Workshop Meeting on December 15, 2008. After review and discussion, it was the consensus of the commission to support the recommendations of the consultants and request that an amendment to the engineering contract with HDR be prepared for commission approval at a regular meeting that would continue their work. The scope of the design work was: • Upgrading the existing Wastewater Treatment Plant #1 (1100 Sandpiper Lane) to meet advanced treatment standards for nitrogen removal • Constructing a force main and flow - shedding of existing lift stations to transfer flow from Wastewater Treatment Plant #2 (739 Renault) to Wastewater Treatment Plant #1 and • Properly abandon Wastewater Treatment Plant #2. At a regular Commission Meeting on March 16, 2009, the City Commission approved the HDR Contract for the design of: • Force main, flow shedding and abandonment of Wastewater Plant #2 • Upgrading the existing Wastewater Treatment Plant #1 to meet advanced treatment standards for nitrogen. Approximately 17 months after City Commission approval of the decision to consolidate all wastewater treatment operations at an upgraded WWTP#1 (including conversion of the Buccaneer WWTP to a pumping station), there are only now comments about the validity of the decision to phase out the Buccaneer WWTP. With further review of all the facts and studies completed during the TMDL study, it is clear that the decision to phase out the Buccaneer WWTP is sound and is the most cost - effective TMDL compliance solution. A brief historical summary follows: TECHNICAL MEMORANDUM (TM) #6 was prepared in October 2008. It describes the changes recommended to improve nitrogen removal at the Buccaneer WWTP. The TM compared: • Upgrading the Buccaneer WWTP to achieve the effluent nitrogen goal and continue to discharge to the St Johns River. This alternative could be valid for the design at a lower flow rate. • Close the Buccaneer WWTP and consolidate wastewater operations by rerouting raw wastewater to the upgraded Atlantic Beach No. 1 WWTP TM #6 FINDINGS - The results of the study indicated that the Buccaneer WWTP had not performed well when operated in a nitrogen removal mode. The challenge at the Buccaneer WWTP was to determine the J. COLLINS ENGINEERING ASSOCIATES, LLC PAGE 2 OF 6 AGENDA ITEM # 8D AUGUST 23, 2010 RESPONSE TO COMMENTS - TABLE 12.1 - FINAL REPORT - TMDL COMPLIANCE PROGRAM EVALUATION cause(s) for the poor performance and to determine the real nitrogen removal capacity of the existing system. After attempts to operate the WWTP to reduce total nitrogen (TN), it was determined that nitrification performance was inconsistent and erratic. The evaluation determined that a minimum of approximately $1,000,000 in upgrades /modifications would be required to achieve an average TN concentration of less than 5 mg/1 (as required by the FDEP). In summary, the findings of TM #6 indicated that although the life cycle costs of the two alternatives were close, closing the Buccaneer WWTP would results in a savings of $400,000 /yr. The TM recommended additional evaluation of Buccaneer WWTP in conjunction with upgrading the Atlantic Beach WWTP to determine the most economical solution. FOLLOW -UP EVALUATIONS - While TM #6 concentrated on the minimum costs to upgrade the Buccaneer WWTP to reduce nutrients, in November/December 2008 HDR/JCEA investigated if other non -TMDL related improvements would be required at the Buccaneer WWTP in order to extend the useful life of the plant 20 years. Extensive improvements to the Buccaneer WWTP were identified in the 2006 Sewer Master Plan (prepared by Brown & Caldwell Engineers). The capital costs were estimated at approximately $3,000,000. In addition, the existing steel tanks at Buccaneer WWTP would require extensive rehabilitation or replacement. The lowest cost was tank rehabilitation at $700,000, but this option would necessitate recurring repainting costs of $350,000 every 5 years. Therefore, the total cost to keep the Buccaneer WWTP in service was estimated to be approximately $6,000,000. PRESENTATION TO CITY COMMISISION on December 15, 2008: Buccaneer WWTP phase -out was addressed at this meeting. An exhibit "Present Worth Analysis WWTP #2" (Appendix A) was presented. The present worth analysis clearly demonstrated that the Buccaneer WWTP should be phased out based on the following: • Keep Buccaneer WWTP In Service - Capital Cost = $6.2 million - Present Worth Cost = $9.2 Million • Phase Out Buccaneer WWTP = 3.4 Million - Present Worth Cost = $0.9 Million • Difference - Keep Buccaneer WWTP In Service Cost $2,800,00 More Upfront & $8.3 Million in Present Worth Costs FINAL REPORT - The Final TMDL report was completed and submitted to the City in March, 2008. Table 12.1 was included in that report and identified that the phase out of Buccaneer WWTP was the most cost - effective alternative. While the table listed only the minimum capital improvements required to implement nitrogen reduction upgrades at the Buccaneer WWTP, the report specifically stated that there are other items that would further support the decommissioning of Buccaneer WWTP. The most critical issue was that much of the plant tankage is old (approaching 40 years) and it is presently beyond its design life. The 2006 Master Plan also identified approximately $3,000,000 worth of capital improvements required at Buccaneer WWTP. J. COLLINS ENGINEERING ASSOCIATES, LLC PAGE 3 OF 6 AGENDA ITEM # 8D AUGUST 23, 2010 RESPONSE TO COMMENTS - TABLE 12.1 - FINAL REPORT - TMDL COMPLIANCE PROGRAM EVALUATION Specific Responses to Comments Made on Table 12.1 The responses to the comments from the August 3, 2010 meeting are summarized below: 1. Capital Cost Decommissioning WWTP #2 does not include $2.6m impairment loss for closing plant in year 3 instead of 15 years of use. RESPONSE - Impairment is an accounting term, referring to the book value of assets, which affect taxes for private businesses. It has no affect on the capital, operating or life cycle costs of facilities, and is not pertinent to the analysis of how to most cost - effectively meet the TMDL. 2. Cost saving and life cycle analysis cost estimates assume operating at full capacity, when in reality this will probably never be realized. RESPONSE: At the beginning of the TMDL Compliance Study, City and Engineer agreed to evaluate all alternatives based on Life Cycle Costs - this was limited to upfront capital costs, current and future operation and maintenance costs and the cost of money (discount rate). Life cycle costing is typically done on a 20 -year cycle and the 20 -year design capacity, as that is the expected life of most facilities. In the life cycle evaluations, estimates were based on the full capacity. Note that operating costs used in the study were based on current operating costs at the time of the study. a. Need to justify need to design so far beyond need. RESPONSE: The Department of Environmental Protection will not permit a treatment plant designed at current capacity. Designs are based on a twenty year planning period per guidelines of the "Recommended Standards for Wastewater Facilities." b. Final TMDL report of March 2009 - details in Table 3.2 ww flow not to reach 2002 levels until well after 2027, section 3.5 attributes declining ww rates to sewer rehabilitation which continues and is expected to reduce flows by approximately 30- 40 %, (this figure is not even included in the already reduced flow projections). RESPONSE: While the 2006 Sewer Master Plan Update estimated an inflow /infiltration rate of approximately 30% during rainfall periods, a specific flow reduction for sewer rehabilitation cannot be determined. Even with a robust sewer rehabilitation program, only a portion of the infiltration is removed. It would not be prudent to use these estimates to make firm future reduced flow projections for the WWTP improvements. c. Maximum capacity design standard was derived from the Comp Plan which is in strict contradiction to all empirical data given in all of the reports. RESPONSE - Under the City's recent renewal of the St. Johns River Water Management Districts' (SJRWMD) Potable Water Consumptive Use Permit (CUP), SJRWMD soundly rejected the use of unsubstantiated per capita water consumption data from the City's Comprehensive Plan. Current population data and actual water use records are the only acceptable data to be used. This also is the same position of FDEP. In summary, Comprehensive Plan data was NOT used in the reports. J. COLLINS ENGINEERING ASSOCIATES, LLC PAGE 4 OF 6 AGENDA ITEM 11 8D AUGUST 23, 2010 RESPONSE TO COMMENTS - TABLE 12.1 - FINAL REPORT - TMDL COMPLIANCE PROGRAM EVALUATION 3. Revenue projections used in this report were based on which flow assumptions? RESPONSE: The TMDL Compliance Report was NOT a utility rate study. Customer revenues did not enter into any of the studies or conclusions presented. • $1M reduction for sale of property in Alterative 1 is not valid, same $ amount should be shown for Alternative 3 because the asset maintained by the city so the value is still present. This is $5 m dollar savings. The additional operating cost of $115,848 per year would take 43 years to add up to $5m million dollars. RESPONSE: Although the particular column heading reads "Property Value ", what this value actually represents is the "revenue received from sale of the WWTP property". In the alternatives analysis, which assumes that the Buccaneer WWTP would stay in service, the sale of the city property is not possible. The inclusion of $1,000,000 of revenue from the sale of the property in this alternative would therefore be incorrect. The table as presented is correct. CLARIFICATION TO TABLE 12.1 - In order to further explain our response to the comments concerning Table 12.1, a new table "Exhibit 1 - Clarifications to Table 2.1" is included in Appendix A. This table clearly shows how much more costly it would be to maintain the Buccaneer WWTP in service. In addition, another new table "Exhibit 2 - Clarifications to Table 2.1 - Sale of Property Added to All Alternatives" shows that including the sale of the property (which is not possible in the alternative where the WWTP remains in service) would have no effect on the determination of the most viable and cost effective solution, namely, to phase out Buccaneer WWTP. CONCLUSION: The "comments" regarding Table 12.1, however well intentioned, would not affect the economics of the decision to close Buccaneer WWTP. There is clearly extensive work required to keep this plant in service for the planning period; work which would cost approximately $3 million more than the option to close the plant and reroute wastewater to WWTP#1 (Keep in service cost of $6.2 million vs. Phase out cost $3.4 million). It is recommended that the City Commissioners accept this report as final closure on the issue of whether the right decision was made regarding closure of the Buccaneer WWTP. The City is presently under a strict TMDL Compliance Schedule. The re- opening of the alternative selection process would no doubt delay meeting this state - mandated schedule as well as increase the City's capital costs for doing so. J. COLLINS ENGINEERING ASSOCIATES, LLC PAGE 5 OF 6 AGENDA ITEM # 8D AUGUST 23, 2010 APPENDIX A .J. 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