Testimony before the

Senate

Committee on Environment and Public Works

Subcommittee on Fisheries, Wildlife and Water

By

Donald M. Moline P.E., DEE

Director of Public Utilities

City of Toledo

April 30, 2001

I am Donald M. Moline and I am the Public Utilities Director for the City of Toledo. On behalf of Mayor Carleton S. Finkbeiner, I am pleased to provide you with some thoughts and ideas as they relate to wastewater infrastructure. More specifically, I would like to relay our experiences in treating or controlling wet weather events.

The City of Toledo’s wastewater system serves about 375,000 individuals. The wastewater treatment plant treats, on an average, 75 million gallons per day (MGD) with wet weather flow going up to 400 MGD.

The City of Toledo is currently involved in discussions to settle a lawsuit that was brought by the USEPA on October 29, 1991. The claim was that the City of Toledo had not been meeting the limits of it’s NPDES permit at the final effluent discharge to the Maumee River. The plant had just undergone a massive rebuilding effort, with federal assistance, and had not been in full compliance. Over the approximately 10 years of this lawsuit, the final effluent has come into significant compliance and therefore it’s discharge is not an issue. The focus of the debate then switched to the issue of bypassing.

During wet weather, most older, Midwestern cities that have combined sewers must bypass the treatment plant either from a CSO (combined sewer overflow) or a primary bypass at the plant itself. This practice is not unique to the City of Toledo. Wastewater treatment plant were not built to handle large raw water flows that happen relatively infrequent. The basic problem centers on the fact that there are very few ways to remedy this situation.

Wet weather facilities are only used during rain and the traditional biological treatment can not sit idly by waiting for rain. The alternative is to develop some different form of treatment or provide storage for wet weather flows with the idea of treating this water after the rain event has subsided. The City of Toledo was involved with both alternatives, our costs for this is over 80 million dollars.

The issue of bypassing was submitted to Judge James Carr in federal district court in Toledo. He ruled that bypassing was illegal if ‘feasible alternatives’ are available. This is a term contained within the Clean Water Act and he defined feasible alternatives to include building new treatment units or storage tanks. He stopped short of defining what measure would need to be undertaken or how much. He did, however, indicated that maximizing your existing treatment plant was not sufficient when it comes to feasible alternatives and bypassing. This has huge ramifications for the wastewater industry in general.

The USEPA has insisted that we build an equalization basin that would hold sufficient quantity of wastewater such that we could avoid most bypassing. This amounts to a 60 million-dollar basin.

In previous discussions, we had conceived and designed an alternative wet weather system that would treat the higher flows and return them to the Maumee River without the need for storage. We were going to combine our swirl concentrators with an Actiflow system to treat the water. We fully intend to ensure that the discharge would meet water quality standards such that no harmful effects would be produced. This alternative could have saved us at least 40 million dollars. The USEPA indicated that this was a good idea and that we should downsize just slightly the Actiflow system and combine it with the 60 MGD Equalization basin. The remedy went from our idea costing 30 to 35 million to their idea costing 80 million. The disappointing part about this is that there is little benefit to the water quality of the river. The reason that they would not agree to the Actiflow system alone was that we were not giving all of the wastewater secondary treatment and therefore it technically was a bypass. They would be willing to allow us to build such a system as long as we built an equalization basin too. They were standing on a technical definition that bypassing any treatment unit constituted a bypass regardless of the water quality impact or cost.

In essences, what we had proposed was not a bypass, but a blending of wet weather treatment system and the full secondary treatment. This in an important distinction in that the USEPA has recently informed Congress that the concept of blending should receive favorable consideration when looking at wet weather alternatives. In our particular case, the USEPA would only agree to blending provided we not only remedied the issues at the wastewater plant but also embarked upon a massive construction program in the collection system.

The previous discussion is only a portion of our lawsuit issues, but it serves to highlight some of the problems with completing wastewater infrastructure projects. The first topic that needs to be addressed is regulatory oversight. The USEPA in recent years has placed more emphasis on enforcement rather than water quality results. Meeting the technical definitions contained within rules and regulations is more important than water quality standards. There seems to be an imbalance between the technical assistance and the enforcement divisions within the agency. There needs to be more assistance, which will lead to greater cooperation in solving technical issues rather than achieving goals through the enforcement provisions. In our particular situation, we have experienced this with the bypass and blending issues. We believe that our alternative would have been able to provide the same water quality benefits at a much lower cost.

A second area that involves regulatory oversight is the issue of cost effectiveness and scientifically based reasoning. Again, it has been our experience that these two concepts are secondary to meeting the procedural criteria of the enforcement section. In discussions, everyone champions the idea of applying good scientific evidence, sound engineering principals and cost effective solutions to problems, however, in practice, these issues are not given the weight or consideration which is appropriate. Often municipalities are forced to comply with standard procedures that are based solely on approved treatment techniques. This unyielding approach ultimately leads to higher costs for wastewater infrastructure. The recently adopted CSO Policy has a better approach. This policy talks of a comprehensive and coordinated planning effort by the municipality, the regulatory agencies and the public. It allows for site-specific solutions and the need for flexibility to tailor controls to arrive at the best solutions. The USEPA needs to fully embrace this approach to enhance technical assistance standpoint and reduce the need for regulatory enforcement.

In Toledo case, our proposed consent decree will cost the ratepayers over 400 million dollars. The City of Toledo is prepared to spend this amount. We have not finalized the decree because we are concerned that the overall cost will balloon to 600 or 700 million dollars. As I have previously indicated with our experiences, ballooning costs are a real possibility. To give you some idea of the impact of these costs to the City of Toledo, consider the following. The current overall debt of the entire City of Toledo over the last 100 years is around 423 million dollars. With the wastewater projects proposed, the City of Toledo will double its debt. This places a huge burden on the ratepayers. Over the next fifteen years, we anticipate our rates will more than double to provide enough funds to service the debt. We recently put out a Request for Proposals (RFP) for the engineering on these projects and that alone will cost 35 million dollars.

The amount of funds being request for infrastructure improvements may lead to the conclusion that the City of Toledo has neglected it wastewater system. This simply is not true. Toledo has been a proactive leader in wastewater improvements. We have installed storage tunnels for the combined overflow system (CSO) to catch the first flush and we have continually invested in our system. Over the last 20 years we have invested over 234 million dollars in infrastructure improvements.

The need for the water and wastewater capitol infrastructure improvements industry wide over the next five years amounts to an estimated $46 billion dollars per year. That equals 230 billion dollars over that five-year period. Clearly, there is a tremendous need. Since the early 1970’s, federal funding of water and wastewater projects has been steadily declining. It is time to reverse this trend. Congress needs to create a long-term, sustainable, and reliable federal funding structure. This should include things such as grants, low interest loans, loan subsidies, congressional earmarks, state revolving loan funds and refinancing opportunities. The federal government should ensure that the programs are fully funded, provide flexibility in their use and streamline the funding application process. At a minimum, the industry need 57 billion dollars from years 2003 to 2007 just to remain solvent.

In summary, congress should encourage the following:

1. Regulations that are based on sound scientific and engineering

principals.

2. Regulations that are based on water quality objective.

3. Regulatory actions that place an emphasis on cooperation rather than enforcement as outlined in the CSO Policy.

4. Federal funding that is long term and in sufficient quantities to

help meet the need of the industry.

5. Clarification of the language (blending, bypass issues) of the Clean Water Act to provide flexibility in meeting the demands of wet weather treatment systems.

6. Provide research and support for the use of new, innovative

technologies.

7. Provide federal grants because the need is so large.

8. Continue to educate the public of an often overlook area of public

health and environmental protection.

9. Allow communities to become a partner in the process, not simply

those who execute the plan.

10. And finally, put more emphasis on non-point source discharges

rather than continuing to try to extract water quality gains from

point source discharges that have been improved significantly in

the last 10 years. It simply does not benefit the environment to continue to follow this approach.

ATTACHMENT TO COMMENT

BY

DONALD M. MOLINE

APRIL 30, 2001

PROJECT DESCRIPTIONS

1. EAST SIDE and BAYVIEW PUMP STATION RENOVATIONS

These improvements involve the renovation of the East Side Pump Station (ESPS) and the Bay View Pump Station (BVPS). The majority of the work is structural and mechanical. The work will include the renovation of the vacuum priming systems at both pump stations, new windows and doors, new discharge valves on the raw sewage pumps 1, 3 and 4 at the ESPS and at all 5 pumps at the BVPS, new HVAC at both stations, new fencing and repair of the roadway at the ESPS.

The floor drain system at each pump station will be reconfigured so that they are separate from the wet well. Flow meters will be added for pumps 1 and 6 at each station. The vacuum pumps, discharge valves and flow meters will be automated and integrated with the plant's control system. The existing gas detection systems will be upgraded and alarms will be sent to the CO Building.

2. WINDERMERE PUMP STATION RENOVATION

This project involves the Windermere Pump Station (WPS). The work of this project includes the replacement of the two bars screens and conveyor system as well as the wet well dewatering pumps. The #2 and #3 raw sewage pump VFD's will also be replaced. The new VFD's will be able to communicate with the plant's PLC system using remote I/O. The two existing VFD's will be similarly configured. FPS will investigate the condition of all 4 raw sewage pumps and motors and recommend corrective action.

The existing generator control panel will be replaced with a new panel equipped with automatic start and loading features. Renovation of the HVAC system, doors, windows and fencing will also be required. The hydraulic system will be renovated. The PLC and the telemetry system, the lighting system and the security system will be upgraded. Finally, the project will include the replacement of the existing flowmeter and installation of new gas detection system.

3. BACK UP POWER FOR SECONDARY AND BLOWER REPLACEMENT

The back up power system should be able to supply all of the power required to operate the plant in a stand alone mode and peak shave. This project will also provide additional air blowers to increase the air supply capacity by 100,000 SCFM for the biological treatment process.

This project will require the successful bidder to perform the engineering services and provide an overall plan for the project to provide electrical power to include:

Electrical switching and distribution network, generation equipment with duel fuel ability, electrical substations, power transmission requirements, new air blowers, examination of air delivery system, removal of existing diesel engines and structural analysis of ME building to house the new equipment.

4. EQUALIZATION BASIN

The Consultant will design an equalization basin with a minimum capacity of 60 million gallons. The basin will be located either at the Harrison Marina site, on the golf course adjacent to the Bay View plant, or other feasible location. The basin will be designed to capture and store, during storm events, additional wastewater above and beyond the capacity of the existing plant for treatment at the wastewater plant once flow to the plant is reduced. The basin is expected to be utilized between 10 and 30 times a year. The rest of the year the basin will remain empty.

The equalization basin, actually a set of basins or tanks, shall be constructed of suitable material and shall have multiple dividers and gates with options to vary the basin size or number of individual basins or tanks to be used. Isolation gates, large valves, drainage pumps, feed pumps and weirs will be used to facilitate filling and draining of the individual basins. The Consultant will provide a basin or tank cleaning system to flush the solid content of the wastewater remaining after it is drained. This system must be maintenance free, automated and integrated with the plant’s control system.

When selecting materials for the basin, special design consideration shall be made for corrosion control. The basin will be filled and emptied often, providing the concrete with much exposure to corrosion and freeze thaw cycles. Gates, weirs, and other equipment shall be made of corrosion resistant materials or painted with corrosion resistant coatings.

The Consultant will review the existing pumping capacity of Bay View, East Side and Windermere pumping stations, preliminary treatment facilities, elevations of the existing main interceptors and force mains coming into the plant, and make a recommendation for improvements needed to fill and drain the equalization basin. The consultant shall look at and develop the most feasible method for additional preliminary treatment facilities which must be maintenance free, automated and integrated with the plant’s control system.

Odor control must be included. A life cycle cost study will be performed on all odor control options proposed by the Consultant. These options will include, but not be limited to, pre-aeration, chemical addition, odor retention basin, mixing systems, dry and liquid scrubbers. The facility must be maintenance free, automated and integrated with the plant’s control system.

The Consultant will investigate and make recommendations on a back-up power system for the equalization basin complex. The Consultant will perform a life cycle analysis on all options. This system will be integrated with the plant’s existing and planned back-up power systems. The system must be capable of an automatic start and loading sequence and an uninterruptable return to utility power upon command from the plant’s computer control system.

This project includes the preparation of a 401 and 404 permit for the Ohio EPA and Army Corps of Engineers should the project be located at the Harrison Marina site. The permits will include mitigation of lost water surface, sediment sampling, sediment characterization and the design of a retaining wall at the river.

Title work and appraisal of the properties associated with the Harrison Marina location have been ordered by the City. All other work to be performed by the Consultant.

5. SECONDARY CLARIFERS

The Consultant will design a new final tank designated as final tank #13. The final tank will be located next to final tank #12 and will be the same size and configuration. This project will be designed to increase the firm capacity of the final clarifiers from 170 MGD to 195 MGD.

This new final tank will be filled and emptied often, providing the concrete with much exposure to corrosion and freeze thaw cycles. The final tank will normally be put on-line during storm events or when other final tanks are out of service for maintenance. During dry weather flows the final tank will be empty.

This project will include the addition of one new sludge withdrawal pump and flow meter identical to the existing pumps and two new mixed liquor feed pumps. The new sludge withdrawal pump will be located in the Sludge Withdrawal Pump Station (SWPS). The pump will have its own variable frequency drive (VFD) and will be automated and integrated with the plant’s control system. The VFD will be located in the SWPS. Power for the VFD, pump and flow meter can be taken from Power Panel 4 or the lightning panel located in the SWPS.

Flow is provided to final tank #12 using four low head high capacity pumps. The Consultant must design two new wet wells, cross over piping and flow meters for each of the two new mixed liquor pumps. Each pump will have its own variable frequency drive (VFD) and will be automated and integrated with the plant’s control system. The VFD’s will be located in Gallery Building #3. Power for the VFD’s, pumps and flow meters can be taken from Power Panel 3 or the lightning panel located there.

A splitter box to control flow to each final tank will be needed along with all process and drainage piping, valves and tank controls. The new tank will be automated and integrated with the plant’s control system.

The Consultant will design a new secondary diversion chamber to replace the existing diversion chamber. This chamber allows flow to be diverted from the swirl concentrators to the aeration tanks. This diversion chamber will be designed for a firm capacity of 25 MGD with consideration being taken for future expansion. This chamber will include a flow monitoring device.

The Consultant shall investigate and develop the most feasible method to provide flow to the diversion chamber then to the aeration tanks. The chamber and all associated equipment must be maintenance free, automated and integrated with the plant’s control system.

6. BALLASTED FLOCCULATION FACILITY

The Consultant will plan and conduct a 12 month pilot study of the ballasted flocculation process. This will be done, if possible, with a truck mounted test facility. From these results, the Consultant will size the facility and begin design. The design of the facility will last for an additional nine months. The study will also include various disinfection alternatives including the use of ultraviolet light or sodium hypochlorite at the end of the wet weather system.

The Consultant will design a wet weather treatment facility (WWTF) composed of a ballasted flocculation process sized to handle a firm capacity of 185 MGD of raw combined sewage. This facility will come on line when the plant flow exceeds the 195 MGD and the equalization basin is full or when the plant flow exceeds 195 MGD and the pumping capacity to the equalization basin is exceeded. This facility will be housed in its own building and will be located at the mooring basin site. This facility and all associated equipment must be maintenance free, automated (if possible) and integrated with the plant’s control system.

The WWTF will include a final effluent pump station with a firm capacity of 195 MGD. This station will be used when the river level rises and interferes with the plant’s ability to discharge effluent. The plant effluent flow and the wet weather treatment facility flow must be sampled separately, recombined and sampled prior to discharging to the river. Post aeration for the combined flows must maintain an effluent DO of 5 mg/l. The Consultant will determine, using life cycle costs, the most economical pumping configuration and post-aeration option. The pump station, aeration system and all associated equipment must be maintenance free, automated and integrated with the plant’s control system.

A new disinfection process for the wet weather flows will be designed based on the results of the pilot study. The Consultant will consider a new disinfection process sized to handle the plant’s effluent flow along with the wet weather flow. A life cycle cost analysis will be performed on the disinfection alternatives. All necessary piping, pumps, controls, chemical feed systems, contact tanks and buildings will be included under this project. The disinfection system and all associated equipment must be maintenance free, automated and integrated with the plant’s control system.

The Consultant will review the existing pumping capacity and preliminary treatment facilities and make a recommendation for improvements needed to provide flow to the wet weather treatment facility. If necessary, the Consultant will perform life-cycle cost studies on various preliminary treatment and pumping alternatives. All pumping systems, preliminary treatment systems and all associated equipment must be maintenance free, automated and integrated with the plant’s control system.

Once the project is complete, the Consultant will perform a two year full scale study titled the “Ballasted Flocculation Study.”

7. GRIT AND SKIMMING TANK SEPARATION

The main objectives of I-45 are to separate the plant's two skimming tanks into four independent skimming tanks/ grit tank process trains. A cross channel complete with motorized slide gates will be installed to allow any of the grit tanks to be routed through any skimming tanks when other tanks are off line for repairs. The inlet gates to the existing grit tanks are being replaced.

New skimming equipment will be installed in each of the skimming tanks along with an automated tipping tube. The primary clarifier scum collection system is being converted back to a gravity drain system that will discharge into a scum pit located outside of the pre-air building. Two scum chopper pumps will transfer the scum to the grease concentrators. New air flow meters and valve actuators will be installed on the air lines. A drainage pump station will be constructed in the existing scum ejector pit to pumps located in the basement of the pre-air building. This pump station will be used to dewater the primary clarifier for maintenance.

The skimming tank collector mechanism, tipping tube and motorized gates will be automated and controlled through the plant's control system.

Reference OEPA permit to install 03-12308.

8. IMPROVEMENTS TO CSO's

COLUMBUS CSO

The sanitary area from Manhattan Blvd. south to Forest Cemetery and from Chestnut Street east to Counter Street is served by a predominately separate sanitary sewer system, which drains into the combined sewers east of Michigan Avenue on Columbus Street.

Drainage from the sanitary and combined sewer systems travels to a 102" sewer located in Columbus Street and on to a regulator located east of the intersection of Columbus and Summit Streets. A 36" sewer, which carries flow from a combined sewer area bounded by Summit, Chicago, Ontario, and Troy Streets is believed to connect to the 102" sewer just west of Summit Street. Storm overflows exit the regulator through a 102" pipe and discharge into the Maumee River. A 24" diameter return line carries dry weather flows from the regulator to an 87" sanitary interceptor located on the east side of Summit Street.

The sanitary drainage for the Columbus Street regulator is estimated to be 676 acres. The storm drainage is estimated to be 205 acres. Separation of the sanitary sewer flow from the combined sewer is expected to result in overflow reduction.

The Columbus Street CSO Optimization Project includes verifying pipe configuration, smoke and dye testing, recommendations to separate public sources of inflow, look at separation of sewers and design improvements.

PARKSIDE CSO

The Parkside CSO project is primarily concerned with the area around Calvary Cemetery which is served by separate sanitary sewer system. This area is located near the Upton and Bancroft as well as the Upton and Door intersections. The system in this area does overflow to the combined sewer system at Ottawa River and Monroe Street. The area serves approximately 600 acres of sanitary sewers.

The basic purpose of this project is to minimize inflow in this area, monitor the flow rate to ensure the inflow is minimized and then construct the required sanitary sewers to divert their flows directly to the interceptor.

This project has not been designed yet and it will be the responsibility of the Consultant to examine the area in detail and develop the project.

MAUMEE CSO

This CSO is located at Maumee Avenue and Orchard Street in South Toledo. This project has not been designed yet. The basic objective of this project is to reduce the overflow from this structure.

The return sewer line from this regulator is a 5,880 ft. long 18" diameter sewer with a slope of 0.25 %. Overflows from this regulator occur at lower rainfall levels than other regulators which service similar acreage. The overflows could be caused by flow restrictions such as sedimentation buildup, plugging by debris or excessive headloss. The exact cause needs to determined and corrected.

9. ELIMINATION OF SSO's IN POINT PLACE

The Director Findings and Orders from the Ohio EPA set forth the time schedule under which the City of Toledo must eliminate the SSO's that are in Point Place. This project is underway and to date, the City of Toledo has been able to meet all of the specified deadlines.

The project is divided into phases with a phase 1 completion date of January 2001. In this phase, the City of Toledo was to do intensive sewer cleaning and correct the deficiencies in the 116th Street interceptor as well as construct a relief pump station at Manhattan Boulevard. Phase 2 remediation will examine the results of the phase 1 investigations and suggest alternatives for corrective action along with the costs. A detailed plan for corrective construction will be submitted to OEPA for applicable permits by June 2003. Phase 2 improvements must be complete by November 1, 2006.

Another part of phase 2 is the River Road SSES work referenced below.

10. SSES in RIVER ROAD and MIDLAND AREA

This part of the SSO elimination project is centered on an area in South Toledo. The first phase of the project involves smoke testing and televising the sanitary sewers in this area. This portion of the project is currently underway. Phase 2 involves the collection of data, analyzing it and making recommendations to eliminate SSO. Phase 3 of the River Road project will be submission of plans and the construction of the remediation efforts by June 1, 2004. Phase 4 is a placeholder if the Phase 3 efforts need additional improvement. The final construction must be complete by November 1, 2006.

11. CSO SYSTEM WORK

This portion of the work involves implementing the results of a two-year collection system study to meet the objectives of the US EPA Combined Sewer Overflow Policy. The team will be required to first establish a Long Term Control Plan (LTCP) that addresses or considers the results of all of the studies listed herein and minimizes the overflows from the CSO's. This LTCP will take into consideration the characterization of the collection system through monitoring and modeling to achieve a through understanding of the sewer system, the response of the system to rain events, the characteristics of the overflows and the water quality impacts that result from CSO's. Many of the studies that we are asking the engineering teams to undertake speak directly to this goal. The LTCP must also address the issues of the nine minimum control standards for CSO's put forth by the US EPA.

Currently, the City of Toledo has combined sewers that serve approximately 17,600 acres. Three interceptor sewers collect dry weather flow from combined sewers at the regulator chambers. Wet weather combined flows discharge to the Maumee River, Ottawa River or Swan Creek at 31regulator overflow locations.

Extensive improvements to the collection system have included both major and minor projects resulting in the overall reduction of combined sewer overflows. The major projects with significant impact on overflow reduction include: the Ten Mile Creek Relief Interceptor, Windemere Pump Station, Swirl Concentrators, combined sewer outfall tide gates and regulator modifications.

The construction and activation of three independent CSO Abatement Pipeline Storage Tunnels are the most significant actions taken by the City to improve water quality of the Maumee River along with downtown waterfront area and of Swan Creek along the CSO reach.

12. TWO YEAR STUDY OF BALLASTED FLOCCULATION

The purpose of the two-year study is to establish the daily operating parameters and effectiveness of the new facility. In setting up the study, the Consultant will consider the manufacturers operating recommendations and use them as a reference point. The Consultant shall develop appropriate scientific mechanisms such that the data developed from this study will be valid in establishing the operating range of the facility. The Consultant will also establish the range of flows that can be properly treated in the facility.

The Consultant shall, 12 months after the start of our contract, submit to the US EPA a work plan for the testing of this facility. The plan shall include, but not be limited to (a.) the effectiveness of the facility to remove suspended solids, carbonaceous biochemical oxygen demand, total Kjeldahl nitrogen (TKN) and ammonia (b.) any difficulties encountered in or limitations involved with using these facilities over a range of flow conditions, chemical feed rates and other operational control parameters and (c.) measures that Toledo has taken to optimize the use of the facility.

After the study is complete, the Consultant will complete a written report that will be submitted to the US EPA within 60 days after proper consultation with the City.

13. FLOW CHARACTERIZATION STUDY

The flow characterization study is fully explained on pages 15 through 18 of the attached draft consent decree. The Consultant is advised to take note of the time requirements for (a.) the work plan within 30 days of our contract (b.) the one year time period for data collection and (c.) the requirement for the report within 30 days following the completion of the study.

The City of Toledo has installed flow-monitoring devices and has collected data regarding the amount of wastewater in the system during rain events. It is the responsibility of the Consultant, to review this information and determine the usefulness of this data and determine what additional data will need to be collected. The current data will be available for inspection at the Division of Water Reclamation.

14. WATER QUALITY STUDY AND MODEL

The City of Toledo, in conjunction with Limno-Tech, Inc. has already performed an extensive water quality study. This will form the basis of the work described in the draft consent decree on pages 18 through 21. The major new area of investigation will be sediment oxygen demand and its relationship to dissolved oxygen in Swan Creek and the Ottawa River. The Consultant will be required to closely review the previous work and coordinate the new investigations such that a comprehensive water quality report is obtained. The Consultant will also develop the proper water quality model after extensive impute from City representatives and consistent with the directions listed on pages 24-25 of the draft consent decree.

Here again, the Consultant is reminded to check the time frames and report requirements.

An Executive Summary of the water quality report is attached. A complete copy of the report is available at the Division of Water Reclamation.

15. HYDRAULIC MODEL

The Consultant will develop a hydraulic model of the collection system to be used in all phases of the evaluation of the system and the handling of wet weather flows. The detailed information of the requirements of the study are listed on pages 22-24 of the draft consent decree.

The Consultant will use the information developed in the flow characterization study as a basis for this model. To that end, the City of Toledo has some background information available for inspection at the Division of Water Reclamation.

16. LONG TERM CONTROL PLAN

The Long Term Control Plan seeks to integrate the various plans and models into one single document that addresses the reduction of flows from our CSO outfalls in order to comply with the CSO policy. The pertinent characterization of this document is found in the draft consent decree pages 25-31. It is the item which receives the most description in this document and is important to the City of Toledo as well as the US EPA.

The studies that are being performed as part of this work can be characterized as informational research. The flow characterization, water quality study and hydraulic models provide the informational basis upon which design and implementation can proceed. Once the information collection phase has been complete, the consultant will begin to evaluate the alternatives. This will require the engineering teams to concentrate their expertise to suggest the most effective yet most economical solution.

Following the conceptual design phase, there will be a review procedure and then detailed design. This design will require the integration of all of the talents of the entire team as well as the City of Toledo's efforts to produce an acceptable product.

Construction of the remedy of the sewer system will be completed in the second half of the project. At present, it is unclear what type of work or engineering will be necessary. It is, therefore, impossible for the Consultant to provide a price for these services. The City of Toledo has included, in this proposal, a mechanism for a price re-opener once the two-year study is complete (see CSO System Work). It is, however, possible for the Consultant to provide a price for the two year LTCP study.

17. PUBLIC PARTICIPATION PLAN

This is an aspect of the project that must not be overlooked. The development of a clear, concise communication mechanism could be the difference between acceptance and rejection of the project. The Consultant will be required to formulate a public relations plan that can effectively communicate the engineering ideas to the City of Toledo, the regulator agencies and the general public. It is in this area that the Consultant and the City must work especially close to provide a clear vision of the project.

In the draft consent decree there is a requirement that this public involvement be active during the planning and formulation of the LTCP. We believe that it is important to have this aspect functioning throughout the entire project.

The public relations efforts of this project will have as its fundamental charge the duty to explain to the public the benefits derived from the improvements being installed in the wastewater system. Large expenditures of public funds will be used to build the improvements and it is critical that we are able to explain how the environment will be improved.

The Consultant is instructed to present, with their proposal, a summary of this plan.

18. SEWER SYSTEM MONITORING AND REPORTING PLAN

This section will involve a timely reporting of any SSD to a body of water to the Ohio EPA. A reporting mechanism will need to be developed such that all of the pertinent information is recorded and conveyed to Ohio EPA.

This work will also involve a record keeping function during wet weather times and the responses that the Division of Sewers and Ditch Drainage provide to residential customers.

The details of the content of the Sewer monitoring can be found in the draft consent decree on pages 35-36.

19. SANITARY SEWER DISCHARGE RESPONSE PLAN

This work requires the consultant to develop a plan that will identify and establish procedures to handle any sanitary sewer discharges with the appropriate public notice. This plan will also include the provisions for limited access to the area, remediation if necessary, contingency plan for emergency response and dispatch of city personnel.

A summary of this work can be found in the draft consent decree on pages 36-38.

20. SANITARY SEWER O & M PLAN

This work entails the creation of a management, operation and maintenance ("MOM") plan for the collection system. The City of Toledo has clearly defined rules and procedures although most of these have never been collected in a single document. The Consultant will be required to work with the Division of Sewers and Ditch Drainage to compile and create the necessary document. It is expected that the Consultant can draw upon past experience to create this document.

This plan will include, but not be limited to, all aspects of the collection system operation including cleaning, televising, inspecting, corrective maintenance, information tracking, maintenance schedules and pump station inspections.

The summary of the elements of the plan are to be found on pages 38-42.

21. WWTP O & M PLAN

The Division of Water Reclamation does have an existing O & M plan that is current and does fulfill most of the provisions of this requirement. The Consultant will need to review these plans and determine if additional work will be necessary to comply with the outline provided in the draft consent decree on pages 42-43.

There are a number of anticipated changes such as a wet weather facility that are not part of our current plant and will need to be added as they are constructed. It will be the responsibility of the Consultant to continually update both the WWTP O & M plan and the Sewer System O & M plan as new processes or change are made.

22. WORK PLANS

The draft consent decree has listed in a number of the tasks, a work plan due within 30 days of the entering of the consent decree. A great deal of discussion was undertaken to describe the nature of these plans and detail necessary to comply with their submission. The US EPA indicated that these plans were to be approximately two pages in length and are to outline the approximate time frames and critical path issues to be followed. They are not a preliminary design nor are they expected to be done in a significant level of detail. They will, however, need to document a course of action that the US EPA can follow.

23. INDUSTRIAL WASTEWATER RELEASE MINIMIZATION PLAN

This work entails the review of our pre-treatment plan to ensure that we are minimizing the discharge of industrial pollutants through CSO's and SSD's. The current pre-treatment program is active and should provide most of this information. The Consultant can review this program at the Division of Environmental Services. A brief summary of the requirements is contained in the draft consent decree on page 38.

ATTACHMENT TO COMMENTS

BY

DONALD M. MOLINE

APRIL 30, 2001

							PROJECT COST (In Thousands of Dollars)
PROJECT	2000	2001	2002	2003	2004	2005	2006	2007	2008	2009	2010	2011	2012	2013	2014	2015	TOTAL
(Wet Weather Improvements)
1. Mooring Basin Construction	$-	$5,350	$3,000	$-	$-	$-											$8,350
2. 60 MG Equilization Basin	$-	$7,000	$4,000	$10,000	$25,000	$24,000											$70,000
3. Pump Station and Swirl Concentrators	$-	$650	$2,700	$1,000	$300	$-											$4,650
4. Final Tank No. 13	$-	$600	$1,200	$4,500	$1,000	$-											$7,300
5. Wet Weather Treatment Facility	$-	$410	$6,000	$13,000	$3,400	$100											$22,910
6. Final Effluent Pump Station	$-	$500	$2,200	$2,000	$500	$-											$5,200
TOTAL	$-	$14,510	$19,100	$30,500	$30,200	$24,100											$118,410	$118,410
(Other WWTP Improvements)
1. Secondary Plant Improvements	$3,800	$3,800	$2,200	$-	$-	$-	$-	$-									$9,800
2. Skimming Tank Separation	$295	$4,100	$-	$-	$-	$-	$-	$-									$4,395
3. Major Pump Station Renovation	$135	$1,420	$2,400	$500	$-	$-	$-	$-									$4,455
4. Back-up Power System	$-	$580	$3,000	$200	$-	$-	$-	$-									$3,780
5. WAS Thickening Renovations	$-	$-	$300	$3,000	$-	$-	$-	$-									$3,300
6. ME BldgRenovation/Blower Replacemt	$-	$620	$500	$3,000	$1,200	$-	$-	$-									$5,320
7. Blower Building Renovation	$-	$-	$-	$500	$3,000	$-	$-	$-									$3,500
8. Detritor/Grit Tank Replacement	$-	$-	$-	$-	$1,000	$3,000	$6,000	$5,000									$15,000
TOTAL	$4,230	$10,520	$8,400	$7,200	$5,200	$3,000	$6,000	$5,000									$49,550	$49,550
(Sanitary Sewer Overflow Elimination)
1. Point Place Phase 1 Construction	$4,100	$-	$-	$-	$-	$-											$4,100
2. Point Place Phase 2 Study-Construct.	$-	$100	$500	$6,400	$7,000	$6,000											$20,000
3. River Road/Detroit Av SSO Elimination	$800	$1,000	$1,500	$750	$750	$750											$5,550
TOTAL	$4,900	$1,100	$2,000	$7,150	$7,750	$6,750											$29,650	$29,650
(Interceptor Inspection/Rehabilitation)
1. Swan Creek Interceptor Rehabilitation	$3,300	$2,500	$800	$-	$-	$-											$6,600
2. Remaining Interceptor Inspect/Rehab	$-	$600	$2,000	$2,000	$2,000	$2,000											$8,600
TOTAL	$3,300	$3,100	$2,800	$2,000	$2,000	$2,000											$15,200	$15,200
(I/I Reduction Program)
1. Sewer System Evaluation Survey	$-	$650	$650	$650	$650	$650	$650	$-	$-	$-							$3,900
2. Sewer Rehabilitation Program	$-	$-	$2,000	$2,000	$3,000	$3,000	$3,000	$3,000	$2,000	$1,000							$19,000
TOTAL	$-	$650	$2,650	$2,650	$3,650	$3,650	$3,650	$3,000	$2,000	$1,000							$22,900	$22,900
(CSO Abatement Program)
1. Columbus, Parkside & Maumee Reduct.	$-	$250	$3,000	$1,500	$1,000	$-	$-	$-	$-	$-	$-	$-	$-	$-	$-	$-	$5,750
2. Ottawa River CSOs - Phase 1	$-	$250	$250	$5,000	$8,000	$7,000	$5,000	$-	$-	$-	$-	$-	$-	$-	$-	$-	$25,500
3. Ottawa River CSOs - Phase 2	$-	$-	$-	$-	$-	$250	$2,000	$5,000	$3,250	$-	$-	$-	$-	$-	$-	$-	$10,500
4. W. Side Maumee (CSOs # 32 & 33)	$-	$-	$-	$-	$-	$-	$500	$3,000	$4,000	$2,500	$-	$-	$-	$-	$-	$-	$10,000
5. W. Side Maumee (CSOs # 23 to 26)	$-	$-	$-	$-	$-	$-	$-	$1,500	$6,000	$15,000	$8,000	$-	$-	$-	$-	$-	$30,500
6. Downtown Tunnel (CSO 1&2) Upgrade	$-	$-	$-	$-	$-	$-	$-	$-	$500	$2,000	$5,000	$2,000	$-	$-	$-	$-	$9,500
6. E.Side Maumee River (CSOs # 7 to 9)	$-	$-	$-	$-	$-	$-	$-	$-	$-	$5,000	$15,000	$30,000	$20,000	$-	$-	$-	$70,000
7. E.Side Maumee River (CSOs # 4 to 6)	$-	$-	$-	$-	$-	$-	$-	$-	$-	$-	$-	$3,000	$10,000	$20,000	$17,000	$-	$50,000
8. Swan Creek Tunnels Upgrade	$-	$-	$-	$-	$-	$-	$-	$-	$-	$-	$-	$-	$1,000	$6,000	$10,000	$8,000	$25,000
TOTAL	$-	$500	$3,250	$6,500	$9,000	$7,250	$7,500	$9,500	$13,750	$24,500	$28,000	$35,000	$31,000	$26,000	$27,000	$8,000	$236,750	$236,750
TOTAL COST SUMMARY	$12,430	$30,380	$38,200	$56,000	$57,800	$46,750	$17,150	$17,500	$15,750	$25,500	$28,000	$35,000	$31,000	$26,000	$27,000	$8,000	$472,460	$472,460
ssfund.capproj.15yr