Common use of Wastewater Treatment Plant Improvements Clause in Contracts

Wastewater Treatment Plant Improvements. Provide a thorough analysis of increasing the capacity of the Albany County Sewer District (ACSD) and Rensselaer County Sewer District (RCSD) Wastewater Treatment Plants to handle higher peak wet weather flows because this is one way to reduce the frequency and volume of untreated CSO discharges upstream in the collection system. A justification is required for the cut off point for secondary bypasses and/or a feasible alternatives assessment for the secondary bypasses. Appendix J of the LTCP addresses some WWTP improvements but does not mention anything about expansion of primary or secondary capacity. (ACSD, RCSD) GENERAL COMMENTS: (ALL) The Best Management Practices and implementation of the 9 minimum (or 15 minimum as numerated in the conditions in the permits) controls have not been fully developed. Many of the items in the LTCP should have been completed under a fully executed BMP. For example, the Dry Weather Overflows (DWOs) should have been addressed under the BMPs. The projects identified are expected to meet water quality standards and attain the best usage for the Xxxxxx River in the Albany Pool area. Revise the sequencing of the projects to address projects with the greatest benefit(s) first. The Proposed Implementation Schedule (Figure 9-3), needs to be modified to group projects into sub-categories that can easily be put into a schedule of compliance/consent order for the individual permits for the communities. Consideration of sensitive areas. There is no specific discussion of sensitive areas. However, the compliance strategy is based on achieving water quality standards at two potential beach sites during the recreation season. These beach sites could reasonably be assumed to be the sensitive areas of concern. The LTCP should refer to these sites as sensitive areas, and properly address them as such in accordance with the EPA CSO Policy and guidance. Wet Weather Operational Plan. There is no explicit operation plan included in the LTCP, nor is their explicit discussion of the future operation of the collection system and the WWTPs to manage CSOs or minimize their impacts. The LTCP needs to refer to status of BMP #5 (an approved Wet Weather Operating Plan) for each of the three sewer districts. Additionally, there needs to be an inter-municipal wet weather operating plan for the CSS to control and minimize CSOs. Justification for “laterally well-mixed” assumption. The Albany Pool LTCP treats the Xxxxxx River as laterally well-mixed in the impact assessment and modeling and asserts that little lateral variation was observed for bacteria concentrations during dry and wet weather (see, for example, Executive Summary subsections 2.1.1.1 and 2.1.1.3 as well as Chapter 2 subsection 2.4.4 and 2.6). Provide additional explanation, analysis and justification of the adequacy of the laterally well-mixed approach for assessing river bacteria compliance. KEY: ALB – Albany COHOES – Cohoes GI – Green Island REN – Rensselaer XXXX -- Xxxx WAT – Watervliet ACSD – Albany County Sewer District RCSD – Rensselaer County Sewer District DATE: October 13, 2011 Memorandum FROM: Xxx Xxxxxxx, Xxxx Xxxx PROJECT: TO: Xxxx Xxxxxxxxxx, EPA Region 2 CC: Xxx Xxxxxxx, Tetra Tech SUBJECT: Review of Albany Pool CSO LTCP