The URL can be used to link to this page

Home My WebLink AboutBOXELDER SANITATION DISTRICT, LAGOON SYSTEM EXPANSION - SITE PLAN ADVISORY REVIEW - 23-95 - CORRESPONDENCE - CITY STAFF (3)Plant Investment Fees Boxelder asked the City whether plant investment fees ("PIFs") would be charged Boxelder customers if DWRF provided treatment for all or a portion of Boxelder flows. This is a policy issue which would ultimately be decided by the City Council as a part of a negotiated wastewater service contract. Cooper Slough Line The City does not currently have enough revenue and expense information to comment on any proposed transfer of the Cooper Slough line to City. A letter from Boxelder to the City dated March 6, 1995, indicates that transfer of the Cooper Slough line and its future "revenue source" would somehow not be cost effective. The information required to assess such a transfer includes the following: 1) is there any debt outstanding on the line? 2) what is the line portion of Boxelder's PIF? 3) what is the service area for the line? and 4) does. Boxelder somehow subsidize service to other customers by revenues received from the line? General Comment -- Regional Plan Considering the changes which are taking place in northern Colorado, I would like to suggest that it may be prudent for the various wastewater service entities in the area to jointly develop a regional "201" plan. Such a plan could be very beneficial for the various wastewater service entities by addressing capacity, water quality, cost and other issues in a more integrated manner. It could be a mechanism to explore the pros and cons of regionalization. Developing and implementing such a plan could help avoid future conflicts between entities regarding facility expansion or water quality issues. Lastly, such a plan could be integrated with and supportive of the various land use plans which have been recently updated or are in the process of being updated. Cost of Service When comparing City cost of service with that of Boxelder, it is important to compare apples with apples. Unit operating expenses in the City wastewater reclamation division are $0.55 per thousand gallons (kGal). One would expect an advanced treatment facility such as the Drake Water Reclamation Facility ("DWRF") to cost more to operate than a lagoon system. In addition to the $0.55 per kGal, City customers also pay for revenue -funded capital and principal and interest on debt allocable to the DWRF. Revenue -funded capital and principal and interest on debt are the cash equivalent of depreciation' and return on rate base. Together, these two items comprise the amounts necessary to fund ongoing renewal and replacement of facilities to keep the system in good working order and protect the ability to continue to attract capital to the operation at least cost. Since the reported $0.15 per kGal that Boxelder states it spends on its lagoon system barely covers the cost of two staff positions, it is very likely that this unit . cost does not include other support functions, depreciation on plant and equipment, and return on rate base. A direct comparison of the 10.15 per kGal" and 10.85 per kGal" unit costs reported in Appendix B should be avoided. Without reviewing financial statements of Boxelder and developing an estimate of their rate base, it is not possible to estimate any changes in their rates that might result from either a "split flow" treatment concept or diversion of all of their flows from the lagoons to DWRF. Second, it is important to point out that unit costs of service must sum to the total unit rate charged to customers. For single-family residential customers, 1994 Boxelder rates were $19.00 per.month. City 1994 unmetered rates were $15.22 per month inside city and $22.83 per month outside city. Based on an estimated water usage of 9.2 kGal per month for all residential customers, this is equivalent to a unit rate of $1.65 per kGal for inside City customers, $2.07 per kGal for Boxelder customers and $2.48 for City customers. outside, city limits. As another example, 3/4-inch commercial customers in Boxelder pay $55.59 per month (without adjustment for irrigation) and similar City customers pay $27.60 per month based on average water usage of 19.3 kGal. This represents a unit cost of $2.88 per kGal for Boxelder and $1.43 per kGal for City. If indeed Boxelder runs the lagoon system for $0.15 per kGal, then there are other significant costs reflected in their rates not included in the treatment unit cost. To properly analyze the alternatives discussed in Appendix B, a full cost of service study of the Boxelder operation should be performed by an independent party. Only then can the costs be compared on an equal basis and the questions regarding "surcharges", "split flows", etc. be resolved. Often such an analysis forms the basis for beginning negotiations for a wastewater service contract. Comments on Site Application for Boxelder Sanitation District Plant Capacity Table 5-1 states the firm capacity of the plant is 4.61 MGD with three centrifugal pumps. What is the firm capacity if only two of the pumps are operable? Is that firm capacity sufficient for peak flows? There is no mention of backup power for the influent pumps. It may be prudent to have standby power sources. Chlorine Contact Time The 30 minute detention time requirement (CDPH&E) for disinfection is based on peak hour flows: The site application states that the chlorine contact basin is designed for 2.34 MGD, listed as design daily average flow. 'If peak hour flow is 4.35 MGD, as indicated in the site application, then the chlorination facility may not meet CDPH&E requirements for detention time. Discharge Permit Conditions Table 3-7 indicates the permitted values for pH range from 6 to 9. The lower pH limit is actually 6.5. Table A -II lists acute and chronic stream standards for various metals. The units are stated as mg/L; the correct unit is ug/L. Likewise, the units in Table A -IV should be ug/L. There is a disparity in permit conditions between Boxelder's discharge to the Cache la Poudre River via a short stretch of Boxelder creek, and Fort Collins' permit conditions for discharge to the same stream segment. Fort Collins' permit contains effluent discharge limitations on ammonia, while Boxelder has none. Fort Collins' suspended solids, fecal coliform, and chlorine limits are all lower than Boxelder. Copper limits are about 10 times lower, mercury limits are two times lower, and silver limits are five to ten times lower for Fort Collins than for Boxelder. Fort Collins requests that the same assumptions and calculations used for Fort Collins river discharge limits be applied when calculating Boxelder limits. Alternatives Analysis With regard to the evaluation of the alternative of consolidation with the City of Fort Collins, the site application lacks sufficient information to formulate a meaningful decision. A few comments regarding the evaluation are as follows: Utility Services Water & Wastewater April 13, 1995 Ed Schemm Assistant Director of Environmental Health 1525 Blue Spruce Drive Fort Collins, CO 80524 RE: Site Application for Boxelder Sanitation District Dear Mr. Schemm: Thank you for the opportunity to review the Site Application for Boxelder Sanitation District. Our comments on the application are attached. If you have any questions, please feel free to contact Gale McGaha Miller or me at 221- 6681. Sincerely, Michael B. Smith Water and Wastewater Utility Director CC: Rich Shannon, Utility Services Director Steve Comstock, Water Reclamation Manager Gale McGaha Miller, Water Quality Technical Manager Victor Sainz, Colorado Department of Public Health and Environment Dave Dubois, North Front Range Water Quality Planning Association P.O. Box 580 • Port COMI)S, CO 805„-0580 • ('03) �27-6681