LCA/ CITy OF ALLENTOWN - Home | Lehigh County Authority...PMTF Plastic Media Trickling Filter RMTF...
Transcript of LCA/ CITy OF ALLENTOWN - Home | Lehigh County Authority...PMTF Plastic Media Trickling Filter RMTF...
May 2016
Wastewater Capacity Program Sewage Facilities Plan (Act 537 Plan)
INTERIM FINAL REPORT
LCACITy OF ALLENTOWN
LCA 537 PLAN
INTERIM FINAL REPORT
1 OCTOBER 2016
CONTENTS
Page No
EXECUTIVE SUMMARYhelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip4 KEY FINDINGShelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip5
RECOMMENDED FOLLOW-UPhelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip6 2013 Studies
bull IPP Effluent Total Dissolved Solids (TDS) Assessmenthelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip7 bull Discharge to Jordan Creekhelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip7 bull Discharge by Land Applicationhelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip8 bull KIWWTP Expansionhelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip8 bull Preliminary Findingshelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip9
2014 Studies
bull DRBC Projected Effluent Limits for KIWWTPhelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip10 bull Living Filter Land Application Evaluationshelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip11 bull Conveyance Evaluationshelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip12 bull KIWWTP Modeling and Optimizationhelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip13 bull 2nd Year (2014) 537 Plan Findingshelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip15
2015
bull TDS Analysis and Source Controlhelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip15 bull Supplemental Land Application Evaluationhelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip16 bull Dry Weather Conveyance Analysishelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip16 bull Flow and Load Projections and 4 MGD Expansion Timinghelliphelliphelliphelliphelliphelliphelliphelliphellip17 bull 3rd Year (2015) 537 Plan Findingshelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip18 bull DEP Contactshelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip19
LCA 537 PLAN
INTERIM FINAL REPORT
2 OCTOBER 2016
APPENDIX
APPENDIX I DEP letter ndash Jordan Creek APPENDIX IIa LCA 537 Tech Memo (121913) APPENDIX IIb LCA 537 Status Meeting (111113) APPENDIX IIIa DRBC Memorandum (22814) APPENDIX IIIb DRBC Meeting Minutes and NH3 Proposal APPENDIX IIIc LCA Expansion ndash DRBC Winter Load Limits Final (22715) APPENDIX IV Living Filter (Dr Parizek) APPENDIX V LCA Conveyance Tech Memo (63015) APPENDIX VIa Intro and Section 2 Flows and Loadings APPENDIX VIb Process Modeling APPENDIX VIc Costs APPENDIX VId Mass Flow Evaluation and Mass Flow Diagrams APPENDIX VII Project Status Meeting (121514) APPENDIX VIII TDS ndash Source Control Memo (6213) APPENDIX IX Presentation ndash LCA Board (11915)
LCA 537 PLAN
INTERIM FINAL REPORT
3 OCTOBER 2016
Glossary of Acronyms amp Terms
AO Administrative Order
BAFS Biological Aerated Filters
CEPT Chemically Enhanced Primary Treatment
DEP Department of Environmental Protection
DRBC Delaware River Basin Commission
IPP Industrial Pre-treatment Plant
KISS Model Klinersquos Island Sewer System Model
KIWWTP Klinersquos Island Wastewater Treatment Plant
LOS Level of Service
MF Micro-Filtration
MGD Millions of Gallons per Day
NPV Net Present Value
NH3-N Ammonia Nitrogen
PMTF Plastic Media Trickling Filter
RMTF Rock Media Trickling Filter
RO Reverse-Osmosis
TDS Total Dissolved Solids
TN Total Nitrogen
TP Total Phosphorus
LCA 537 PLAN
INTERIM FINAL REPORT
4 OCTOBER 2016
EXECUTIVE SUMMARY Introduction In early 2013 anticipating a 4 MGD growth in the LCA service area the Lehigh County Authority in cooperation with the City of Allentown commissioned ARRO Consulting and their teaming partner AECOM to prepare a Sewage Facilities Plan (Act 537 Plan) The scope of the 537 Plan involved
bull Updating projections of combined Allentown and LCA service area growth bull Updating projected effluent limitations bull Evaluating treatment alternatives to accommodate a 4 MGD expansion bull Evaluating conveyance costs for the treatment alternatives bull Conducting Public Outreach to obtain stakeholder input bull Identifying a preferred approach
Previous capacity studies (April 2007)(December 2007) identified 4 alternatives for accommodating a 4 MGD expansion
1 Expand conveyance to the Klinersquos Island Wastewater Treatment Plant (KIWWTP) and expand the plant by 4 MGD to 44 MGD capacity
2 Upgrade the LCA Industrial Pre-treatment Plant (IPP) to produce an effluent meeting direct discharge requirements and discharge via Land Application
3 Upgrade the LCA Industrial Pre-treatment Plant (IPP) to produce an effluent meeting direct discharge requirements and convey and discharge to Jordan Creek and
4 Upgrade the LCA Industrial Pre-treatment Plant (IPP) to produce an effluent meeting direct discharge requirements and convey and discharge to the Lehigh River
These previous studies had identified direct discharge to Jordan Creek and expanding the KIWWTP as first and second choices respectively based on Net Present Value (NPV) NPVs are calculated by discounting future OampM costs to the present and adding capital costs so that the combination of capital and operating costs are reflected in a single number All of the NPVs are negative ie they represent net present costs as there are no revenues to offset capital or operating costs so the lower the NPV the more attractive it is Table 1 summarizes these results Table 1
Alternative (Dollars in millions) Capital PV OampM NPV Expand KIWWTP 625 105 730 Direct Discharge - Land Application 712 142 853 Direct Discharge - Jordan Creek 593 101 694 Direct Discharge ndash Lehigh River 962 106 1068
LCA 537 PLAN
INTERIM FINAL REPORT
5 OCTOBER 2016
Over the 2013 -2015 period a number of studies were undertaken to support 537 Plan development Details of these studies and their findings are chronicled in the following sections A summary follows Key Findings From an overall findings standpoint several findings standout
bull The IPP has a very high influent Total Dissolved Solids (TDS) content comprised of sodium salts TDS normally passes through traditional wastewater treatment and is cost-prohibitive to remove Direct discharge of a high TDS effluent to either land application or the Jordan River would create Secondary Drinking Water Standards compliance issues which render them impracticable and leaving only conveyance to and expansion of the KIWWTP and upgrading the IPP to direct discharge and conveyance to the Lehigh River as alternatives
bull An examination of innovative treatment technology alternatives for a KIWWTP 4 MGD expansion led to the finding that the capital cost could be reduced by approximately 20 such that the cost of a KIWWTP expansion was essentially equivalent to the cost of upgrading the IPP for direct discharge
bull It became clear that the wet weather compliance program that is being carried out concurrently with 537 Plan development effort overshadows the 537 Planning with respect to conveyance and the alternatives for a 4 MGD expansion should be viewed as an incremental expansion to the conveyance expansions required to achieve wet weather compliance Most of the conveyance system piping needs to be expanded and the incremental cost of enlarging conveyance piping to accommodate an additional 4 MGD is only $7 million ($84 million including incremental expansion of the Park Pump Station) in comparison to a $41 million cost for constructing a pump station and force main to convey to the Lehigh River
bull Table 2 below summarizes these costs Table 2
$ in millions Convey all Flow to KIWWTP
Convey all Flows Tributary to IPP to Lehigh (Force Main)
Incrementally expanded Park Pump Station and Conveyance
84 ndash
Force Main to Lehigh for all Flows Tributary
ndash 407
4 MGD KIWWTP expansion 262 ndash Upgrade IPP to direct discharge ndash 255 TOTAL 346 662
LCA 537 PLAN
INTERIM FINAL REPORT
6 OCTOBER 2016
bull Detailed flow projections were developed which indicated that LCA would not exceed its capacity allocation at the KIWWTP until 2025 and that the KIWWTP would not reach its current 40 MGD design capacity until considerably thereafter
bull The wet weather compliance program is still under active development and the preliminary findings relied on in 537 Planning may change considerably and
bull The Pennsylvania Department of Environmental Protection (PADEP) recommended a 537 Plan submission be delayed until the wet weather compliance program development is complete because any Plan completed now would most likely need to be redone and there is no immediate pressure to complete 537 Planning now
Recommended Follow-up Assuming a 5 year schedule for planning design and construction of a KIWWTP expansion it is recommended that reactivation of 537 planning be tentatively slated for 2020 This would be 5 years before projected LCA service area growth would exceed its current KIWWTP allocation Flow increases should be monitored and early achievement of 2020 projected flows be treated as a triggering point for resumption of 537 planning This approach has a built in contingency mechanism that makes it forgiving and workable should a further ahead-of-projection service area flow increases occur such that LCArsquos KIWWTP allocation is exceeded before an expansion is completed the current signatory allocation agreement provides for exceedance penalties to be paid to the other signatories which would not exceed the expected debt service on a KIWWTP expansion up to a 28 flow exceedance over the current 1078 MGD allocation See Appendix IX for calculations
LCA 537 PLAN
INTERIM FINAL REPORT
7 OCTOBER 2016
2013 STUDIES Preliminary 537 Plan work focused on updating projected effluent limitation criteria for Jordan Creek and the Lehigh River while projections for future growth in the Allentown and LCA service areas were being developed IPP Effluent Total Dissolved Solids (TDS) Assessment A review of IPP effluent quality records uncovered a heretofore unaddressed issue the IPP effluent has an unusually high TDS content Only limited data were available as of 2013 which dated back to 2009-10 but this data indicated that TDS levels were on the order of 1300 milligramsLiter (mgL) with a rising trend AECOM developed a supplemental sampling plan which LCA carried out to confirm TDS levels Sampling in in 2013 found TDS levels of 1800 mgL or over 3 times the Federal Secondary Drinking Water Standard of 500 mgL This increase was attributed to the growing level of industrially-sourced influent at the IPP Since the IPP effluent is conveyed to the KIWWTP where it is diluted to below 500 mgL there is no issue with respect to current operations however this finding had major implications for the prospect of direct discharge of the IPP depending on the alternative to be adopted Discharge to Jordan Creek Discussions with the Pennsylvania Department of Environmental Protection (DEP) led to a letter from the DEP (Appendix I) clarifying the hydrogeological study requirements that would be needed to determine if Jordan Creek is a ldquogainingrdquo or ldquolosingrdquo stream and that if it is a losing stream at the point of discharge the discharge would have to meet Pennsylvania Class A Reclaimed Water standards These standards would require considerable upgrading to the IPP to provide for nitrification denitrification and filtration Furthermore TDS would have to meet the Federal Secondary Drinking water standard of a maximum TDS concentration of 500 mgL To reflect these requirements ARRO developed the scope cost and schedule for the required Hydrogeologic study and AECOM developed preliminary cost estimates for the additional treatment required (over nitrification denitrification and filtration) to reduce TDS to below the 500 mgL limit The Hydrogeological study was estimated to take several years at a cost on the order of $500000 with a questionable likelihood that the study would produce results justifying a relaxation of the effluent standards TDS is not removed in conventional wastewater treatment rather it represents a pass-through what comes in with the raw influent leaves with the effluent To remove TDS Micro-Filtration (MF) followed by Reverse Osmosis (RO) is required AECOMrsquos preliminary estimate for adding MF + RO indicated that the NPV (cost) for the Jordan Creek alternative would increase by $33 million to over $100 million Moving it from first
LCA 537 PLAN
INTERIM FINAL REPORT
8 OCTOBER 2016
to a distant third in terms of relative attractiveness only slightly better than the most costly alternative of direct discharge to the Lehigh River The estimated $33 million increase reflects both a high capital cost and a high operating cost primarily due to the high power requirements to operate RO Discharge by Land Application The basis for Land Application of IPP effluent selected in studies prior to the 537 Plan was drip irrigation of agricultural lands relatively close to the IPP To facilitate drip irrigation filtration of the IPP effluent was required The capital cost associated with filtration resulted in a NPV $12 - $15 million higher than the Jordan Creek and KIWWTP Expansion alternatives Spray irrigation has a lower cost to establish the spray fields than drip irrigation and does not require filtration at the IPP however eastern Pennsylvania spray irrigation was traditionally limited to the growing season Since the IPP operates year-round to land apply only during the growing season would require 4 months of effluent storage At 4 MGD 480 million gallons of storage would be required The cost of providing this storage increased the cost of a spray irrigation-based land application system above the cost of the drip-based system As part of a technology review AECOM identified a land application program at State College Pennsylvania operated by Penn State that has been successfully operating for several decades using year-round spray irrigation which they called a ldquoLiving Filterrdquo Living Filter refers to the management of agricultural operations and crop rotation to facilitate nitrogen uptake thereby reducing the requirements for TN removal at the IPP and providing a beneficial reuse Adopting the Living Filter approach an LCA system would not need filtration at the IPP or 4 months of storage raising the prospect of reducing capital cost by approximately $20 million and making land application a preferred alternative Based on this finding the focus of evaluating land application shifted to evaluating the concept of adopting the Penn State Living Filter approach KIWWTP Expansion The largest uncertainty with respect to the KIWWTP was what effluent standards would be imposed by the Delaware River Basin Commission (DRBC) The KIWWTP is currently ldquograndfatheredrdquo under DBRC regulations Under these regulations an expansion or material change to the facility would trigger imposition of tighter standards Establishing new standards is interdependent with the collective loadings contributed to the River Basin by all discharges and governed by a ldquono backslidingrdquo policy with respect to River quality The DRBC uses a basin-wide model to assess the impact of changes in an individual discharge An assessment for a potential KIWWTP expansion was made in 2010 however it was generally recognized that the basin-wide model needed updating Recognizing the importance of updating and firming prospective DRBC-imposed KIWWTP effluent limits LCA agreed to contribute the cost of updating the model for the purpose of obtaining an opinion from DRBC as to prospective effluent
LCA 537 PLAN
INTERIM FINAL REPORT
9 OCTOBER 2016
limits (This is only an opinion as legally binding limits are only set through opening a docket and obtaining a formal determination) The results of the basin-wide modeling update were received in late 2014 and subsequently factored into KIWWTP evaluations Preliminary Findings In late 2013 these preliminary findings were summarized in a memorandum with the recommendation to defer further pursuit of the Jordan Creek alternative pending development of the more preferred alternatives and a presentation on the status of 537 Planning was made to LCA Staff and the Board This memorandum and the associated presentation are provided in Appendix II The memorandumrsquos recommendations for re-focusing the 537 Plan development effort were
bull Defer further evaluation of direct discharge to Jordan Creek bull Conduct an effluent sampling program at the IPP to determine the constituents
that contribute to the observed high TDS for the purpose of evaluating source control as a potential lower cost means of reducing TDS
bull Develop a sophisticated model of the KIWWTP for the purpose of optimizing and cost-reducing the capital cost of a 4 MGD expansion The GPS-X (Hydromantis) modeling platform was recommended Once a calibrated and validated model is developed alternate process configurations and treatment technologies can be quickly evaluated to sort through and confirm an optimized approach
bull Evaluate the ldquoLiving Filterrdquo approach to land application by engaging Dr Richard Parizek who was instrumental in developing and refining the Penn State program over a 3 decades-long effort and
bull Initiate evaluation of conveyance cost for conveying the additional 4 MGD to KIWWTP This was one of the more uncertain costs in previous evaluations and required refinement This evaluation had been deferred while awaiting further development of the collection system models (LCA and the City of Allentown were developing individual models for their systems) By late 2013 it was judged that modeling had reached sufficient precision for the purposes of selecting a preferred expansion alternative
LCA 537 PLAN
INTERIM FINAL REPORT
10 OCTOBER 2016
2014 STUDIES DRBC Projected Effluent Limits for KIWWTP DRBCrsquos completed a basin-wide model update an issued an initial opinion of prospective effluent standards on February 28 2014 A request for clarifications led to a July 28 2014 meeting to resolve remaining uncertainties The only unresolved issue coming out of the July 28 meeting was the appropriate wintertime ammonia standard The DRBC basin-wide model is focused on and validated with summertime conditions so a winter standard is somewhat arbitrary DRBCrsquos initial position was that the wintertime ammonia limit (ldquowinterrdquo defined as the 7-month period from October 1st to April 30th) should be the same differential (a 17 multiplier) between summer and winter historical averages applied as a multiplier to the new prospective model-based summertime standard This was challenged as only acceptable if the wintertime limit was based on a full 7 month average consistent with how the wintersummer differential was derived as opposed to the DRBC norm of monthly average limits After some further dialog resolution was reached in early 2015 with the DRBC electing to stay with a monthly limit but relaxing the multiplier to 30 the same (more defensible) summer-winter multiplier applied by the Pennsylvania Department of Environmental Protection This final determination was communicated in an email memorandum transmitted February 27 2015 In order to move forward with modeling and optimization studies for the KIWWTP during this extended dialog the more stringent standard 17 multiplier standard was used as a reference The February 28 2014 Memo minutes from the July 28 2014 meeting with relevant correspondence and the February 27 2015 final opinion memo (email) from DRBC are attached as Appendix III The following table shows DRBCrsquos 2010 opinion of prospective effluent limits (draft limits) triggered by a 4 MGD expansion to the KIWWTP compared with the 2014 opinion of prospective effluent limits (summertime monthly averages) Table 3 Parameter (mgL) 2010 Draft Limits (lbsday) 2014 Draft Limits (lbsday) Total Phosphorus (TP) 457 1092 Ammonia (NH3-N) 698 439 Total Nitrogen (TN) (no limit specified) 6463 The primary focus of KIWWTP modeling and optimization was focused on achieving the ammonia standard as it is the most stringent on a relative basis and requires more capital intensive modifications to meet It should be noted that the DRBC actually relaxed the draft Total Phosphorus limit between 2010 and 2014 The 2010 results were challenged as based on an assumed
LCA 537 PLAN
INTERIM FINAL REPORT
11 OCTOBER 2016
historical discharge when actual TP discharges were considerably higher Actual discharges were documented and the DRBC responded with the relaxed draft limit Living Filter Land Application Evaluations Land application was evaluated in two studies prior to the initiation of 537 Planning (February 13 2012)(December 2007) These studies identified 8 potential agricultural land application sites within a 3 mile radius of the IPP The initial assessment was that two or three of these sites could collectively accept 4 MGD of upgraded IPP effluent ARROAECOM engaged the services of Dr Richard Parizek Emeritus Professor of Geology and Geo-Environmental Engineering The Pennsylvania State University to evaluate these sites with two objectives
bull Determine the suitability of these sites to be utilized for land-application using year-round spray irrigation ie using the Penn State Living Filter approach which he was instrumental in developing and refining over a 3-decade period and
bull Assess the potential for natural recharge (net of precipitation minus evapotranspiration) to provide dilution of the high TDS content of the IPP effluent to 500 mgL Note that this was not a consideration in the pre-537 Plan studies as the high TDS content was not addressed Because TDS above 1000 mgL can compromise farming operations Dr Parizek used this value for the TDS content of the IPP effluent with the understanding that an at that time undefined source control program would reduce the TDS down to that level
Dr Parizek toured the 8 potential sites and based on area topography and observed outcroppings identified two more promising sites located near each other on opposite sides of Interstate 78 and just west of Route 100 for further evaluation As it turns out the geology and topography in the vicinity of the IPP have similar make-ups to that of the region surrounding State College so much of Dr Parizekrsquos experience was directly relevant Dr Parizek selected the two sites for further study based on available area with acceptable gradients hummocky terrain (which aids infiltration and minimizes the potential for runoff) and the availability of buffers between the land application site and receptors (drinking water wells and gaining streams) Dr Parizek revisited the two sites to catalog receptors and evaluate surrounding lands for potential to contribute dilution from recharge and studied available information from well logs and topographical and soil mapping data His found that the site south of Interstate 78 would only support 04 MGD of ldquoliving filterrdquo spray irrigation ndash too small for development but the site north of Interstate 78 could support 15 MGD of ldquoliving filterrdquo spray irrigation
LCA 537 PLAN
INTERIM FINAL REPORT
12 OCTOBER 2016
While 15 MGD falls well short of the capability to handle 4 MGD of expansion it raises the prospect of implementing Living Filter land application as a means of deferring a 4 MGD expansion of KIWWTP or reducing the size of a KIWWTP expansion To evaluate this prospect AECOM utilized cost data from previous studies to estimate the capital cost per MGD for a 15 MGD land application program By normalizing cost to millions of gallons per day (MGD) treated the relative attractiveness of proceeding with a more limited land application program to defer or reduce the size of an expansion at the KIWWTP was assessed Table 4 Alternative Scope Capital Cost
(2014 Dollars) (millions)
Capital cost per MGD treated (millions)
15 MGD Land Application Interstate 78-North Site
Pump Station Force Main Limited
Storage Spray Irrigation System
$183 $1217
4 MGD KIWWTP Expansion
Expanded Conveyance Upgrades at KIWWTP
$346 $865
Based on AECOM recommended cost-reducing technology This analysis led to the conclusion that there was no justification for implementing a smaller scale land application program Dr Parizek prepared a report with the details of his findings which is attached as Appendix IV Conveyance Evaluations As a result of the Jordan Creek and Land Application direct discharge alternatives being found disfavored due to TDS concerns effort focused on a comparison between the alternatives for conveyance to KIWWTP versus diversion of all flow tributary to the IPP with conveyance and discharge to the Lehigh River Diversion of all flows was assumed not just an additional 4 MGD to provide the greatest relief to the already wet weather-challenged conveyance system with a cost-effective incremental increase in pipe size for conveyance of all flows to direct discharge to the Lehigh River The analysis targeted achievement of the LCA wet weather level of service (LOS) defined as a maximum water surface at least three feet below the manhole rim in pipes 18-inch diameter or greater for a 10-year storm Modeling of alternatives in support of this analysis was conducted by ARCADIS using the KIWWTP Sewer System (KISS) model This model was developed by combining previously-existing models of the LCA and City of Allentown systems
LCA 537 PLAN
INTERIM FINAL REPORT
13 OCTOBER 2016
Alternatives included the following
bull Conveyance improvements to move all flow to KIWWTP (Alt 10) bull Conveyance improvements assuming diversion of all flows tributary to the IPP to
the Lehigh (Alt 12a) bull Conveyance improvements assuming diversion of all flows tributary to the IPP
but with three upstream storage tanks provided to reduce the scope of pipe upsizing needed (Alt 12b)
The following table summarizes the conveyance costs associated with these alternatives Table 5 Capital Cost in millions
Alt 10 ndash All flows to Klinersquos Island
Alt 12a ndash Upgrade IPP amp Force Main to Lehigh River
Alt 12b ndash Same as 12a but storage to reduce pipe upsizing
Total $307 $338 $329 Difference vs Alt 10
ndash $31 $22
Tapping fees for the 4 MGD expansion are not included in these numbers ARCADISrsquo nomenclatureAlternative labeling changed subsequent to the 2014 Study Alternate cost estimating yielded cost differences of $47 and $38 million respectively for Alt 10 versus Alts 12a and 12b so the table resolves uncerainty in favor of the 12a and 12b alternatives which still come out less preferred The most striking element of this table is the size of the estimated overall investment to achieve wet weather compliance (LOS) The corollary finding is that by ldquopiggybackingrdquo the increase in conveyance to accommodate an additional 4 MGD from the IPP on top of the increases in conveyance capacity required to achieve wet weather compliance (EPA Administrative Order) the incremental cost of conveying the incremental 4 MGD is reduced such that conveyance to and expansion of the KIWWTP is clearly favored The full derivation of the cost estimates presented above are contained in a Technical Memorandum ndash see Appendix V KIWWP Modeling and Optimization KIWWTP modeling was a primary thrust of the 537 Plan effort during 2014 Modeling is only valuable if rigorously calibrated (in the hands of an experienced modeler) using historical data then validated using a subsequent data set that was not used in calibration This takes considerable effort but paysoff quickly as many process simulations can be run quickly once calibration and validation are complete Studies prior to the 537 Plan (ldquoKIWWTP Expansion Evaluationrdquo ndash OMNI Environmental February 2011) identified an expansion approach based on installing Biological Aerated Filters (BAFS) downstream of the Plastic Media Trickling Filters (PMTFs) in parallel with
LCA 537 PLAN
INTERIM FINAL REPORT
14 OCTOBER 2016
the Rock Media Trickling Filters (RMTFs) The capital cost estimate for this approach is $36 million (escalated from 2010 study to 2014) While this is an established approach AECOM focused on utilizing a more innovative but proven technology sidestream deammonification in conjunction with Chemically Enhanced Primary Treatment (CEPT) and partial replacement of the rock media in the RMTFs with plastic media to increase nitrification capacity Modeling simulations confirmed that this was a robust reliable approach that can meet the prospective more stringent DBRC effluent limits with the following advantages over BAFs
bull Lower capital cost -- $26 million a $10 million reduction bull Lower energy requirements bull Lower chemical requirements (supplemental carbon) bull Higher digester gas production (available for cogeneration) bull Ability to phase investment ndash An initial Phase One project of $20 million (25
replacement of rock media) should meet needs for a decade or more with a straightforward Phase Two $6 million capital investment (2014 dollars ndash increasing rock media replacement to 375) to reach full buildout
Modeling simulations produced the following projected effluent concentrations at the Phase One project level (25 media replacement) and at 50 media replacement Table 6 KIWWTP GPS-X Simulations For replacing rock with Plastic Media
Coldest Max Month (Winter -- 11 deg C)
Coldest Max Month (Summer ndash 14 deg C)
Ammonia DRBC Limit (mgL) 282 094 Replacing one quadrant (25 Replacement)
84 46
Replacing two quadrants (50 Replacement)
20 028
Mass Load limits converted to concentrations at a Max Month flow of 56 MGD The conservative nature of these simulations should be noted These 56 MGD Max Month simulations reflect the highest monthly flow expected in a very wet month that also coincides with the coldest temperatures expected at a point in time when annual average flow reaches 44 MGD This is not expected to be reached by the 537 planning horizon of 2035 based on geometric projections of historical growth Rather 44 MGD is not projected to be achieved until 2056 Since a future KIWWTP expansion appears to be a clear winner with respect to a preferred alternative to accommodate a 4 MGD increase in LCA flows development of the KIWWTP model has been carefully documented See Appendix VI for the complete report
LCA 537 PLAN
INTERIM FINAL REPORT
15 OCTOBER 2016
2nd Year (2014) 537 Plan Findings The evaluations made and findings reached during 2014 (as discussed above) and recommendations for further study were presented to LCA and City of Allentown staff in December A streamlined version of the staff presentation was given to the Board that same month The more detailed staff presentation is attached as Appendix VII While the evaluations to date clearly pointed to proceeding with a 4 MGD expansion at KIWWTP several confirming studies were identified with guidance from LCA staff and the LCA Board which became the focus for 2015 studies
1 The high TDS content of the IPP effluent turned out to be one of the two most influential elements affecting selection of a preferred alternative for a 4 MGD expansion Investigation into source control as a potentially more cost-effective approach compared with the prohibitive cost of Reverse Osmosis (RO) was warranted
2 The benefits of ldquopiggybackingrdquo the increase in capacity to convey to the KIWWTP onto the much larger program to achieve the desired wet weather LOS were readily apparent however a dry weather analysis was needed to reinforce the findings and develop reference information that would provide guidance on allocating cost between the LCA signatories and
3 While the land application evaluation did not produce promising results considerable agricultural lands more distant from the IPP to the southwest had been identified that may contain sufficient acreage to develop a meaningful land application program Much of this land had the added advantage of being under agricultural preservation restrictions which would protect against pressures for urban development and loss of previously developed land application sites A Board member pointed out that this was a risk associated with the site north of Interstate 78
2015 STUDIES TDS Analysis and Source Control Extensive TDS sampling was conducted in 2014 not just measuring the TDS levels in IPP effluent but also contributions from the major industrialcommercial sources that discharge into to IPP collection system and additional IPP effluent sampling was conducted in 2015 These sampling events showed
bull While the 1800 mgL TDS level measured in 2013 may have been above average 2014-15 sampling showed that TDS was in the 1500-1600 range or three times the Federal Secondary Drinking Water Standard of 500 mgL
LCA 537 PLAN
INTERIM FINAL REPORT
16 OCTOBER 2016
bull The five largest industrialcommercial dischargers contributed over 75 of the TDS in final effluent with the largest contributing over one-half of the IPP effluent TDS (Measured levels are reported by discharger in Appendix VII)
bull The majority of the TDS was comprised of sodium salts Sodium is undesirable for land application and cannot be removed by methods other than Reverse Osmosis
Based on these findings a source control study was initiated for the largest industrial discharger A Technical Memorandum documenting this investigation is attached as Appendix VIII The industrial discharger cooperated in the study by sharing chemical purchases and their uses within the facility The controlling finding was that the majority of the TDS came from the use of sodium salts in their process This use was diverse and integral to their process so there is no practicable means of controlling TDS generation at the source exists Dr Parizekrsquos 2014 land application investigations were based on a successful source control program reducing TDS to the 1000 mgL range The finding that it was highly unlikely that substantial reductions from the 1500 mgL level could be achieved further confirmed that land application would not be feasible without substantial acreage for recharge and dilution and raised the concern that the high sodium levels would compromise farming operations Supplemental Land Application Evaluation A limited investigation into the availability of substantial suitable acreage to the southwest of the IPP for land application was conducted Key findings are summarized as
bull 678 acres of deed restricted agricultural preservation land was identified to the southwest of the IPP however ten times that (approximately 7000 acres) would be required to provide sufficient recharge and dilution to meet the 500 mgL standard
bull An additional 3 miles of conveyance is required to reach the agricultural area to the southwest of the IPP which would add an additional $3 million in conveyance capital cost
These findings give rise to the virtually inescapable conclusion that land application is not viable without implementing Reverse Osmosis to reduce TDS levels If at a future date Reverse Osmosis is implemented for other reasons land application using a Living Filter approach can be revisited Dry Weather Conveyance Analysis ARCADIS ran additional simulations using their KISS model of the combined LCA and Allentown collection systems based on dry weather flows using the same scenarios ndash full diversion of flows tributary to the IPP and pumping via forcemain to the Lehigh
LCA 537 PLAN
INTERIM FINAL REPORT
17 OCTOBER 2016
River compared to conveyance to the KIWWTP Analysis of these simulations using the same pipe sizing methodology employed for the wet weather analysis led to the following finding The capital cost difference between full diversion and conveyance to the KIWWTP favored conveyance to the KIWWTP by 3 to 7 $million reinforcing the finding arrived at in the wet weather analysis It should be noted that some conveyance pipe upsizing is required for dry weather flows without the 4 MGD expansion The derivation of this finding can be found it the conveyance alternatives technical memo Appendix V Table Y below is based on the higher estimate for Convey all Flows to KIWWTP and lower estimate for Lehigh Force Main (most favorable treatment for all flows tributary to IPP to Lehigh)
See
Appendix V Tables 8 10 and 11 for supporting information Even under the most favorable treatment for the Lehigh River direct discharge alternative and considering dry weather flows only conveyance of all flows to the KIWWTP and KIWWTP expansion is favored Flow and Load Projections and 4 MGD Expansion Timing In parallel with AECOMrsquos alternatives evaluations ARRO was working with the LCA and City of Allentown signatories to develop a long range flow projection for the IPP The details of this effort are reported separately The key findings are summarized below
bull Current LCA flows are only at 84 of its KIWWTP allocation of 1078 MGD bull Flows are expected to increase gradually and only reach allocation in 2025 bull Flows are not expected to increase to 4 MGD above current allocation until 2040
These findings are shown graphically below in Figure 1
$ in millions Convey all Flows to KIWWTP and Expand KIWWTP
Convey all Flows Tributary to IPP to Lehigh (Force Main) and Direct Discharge
Incremental expanded Park Pump Station and Conveyance
$368 ndash
Force Main to Lehigh for all Flows Tributary
ndash 407
4 MGD KIWWTP expansion $262 ndash Upgrade IPP to direct discharge ndash 255 TOTAL 630 662
LCA 537 PLAN
INTERIM FINAL REPORT
18 OCTOBER 2016
Figure 1
The implications of these findings are that
1 There is time to let the preferred approach of ldquopiggybackingrdquo increased conveyance to the KIWWTP onto the wet weather compliance program This program involves continuing to refine the collection system modeling and examining and optimizing alternatives as the signatories work to reduce I amp I
2 A Phase One expansion of the KIWWTP is likely not needed within the next 10 years (Although tighter effluent limits may be triggered by a material change to the facility which would trigger all or part of the Phase One scope)
3rd Year (2015) 537 Plan Findings The findings of the cumulative work over the three year period 2013 to 2015 were summarized in a presentation to LCA and Allentown staff and the LCA Board and by year-end 2015 to representatives of both the LCA and Allentown signatories This presentation is attached as Appendix IX These findings led to the following recommended path forward
LCA 537 PLAN
INTERIM FINAL REPORT
19 OCTOBER 2016
bull Defer pursuit of alternatives other than KIWWTP expansion bull Integrate conveyance capacity increase with Wet Weather (AO) program (there
is time to do so) bull Conduct public outreach to inform Stakeholders
DEP Contacts Subsequent to presenting the overall findings of 537 Planning to date in November 2015 follow-up contacts were made with the DEP to (a) reconfirm that the 500 mgL Secondary Drinking Water Standard for TDS could not be relaxed as part of a controlled land application program and (b) obtain guidance on proceeding with a 537 Plan contingent on the outcome of developing a firm wet weather compliance plan DEP provided the following guidance
1 The 500 mgL Secondary Drinking Water Standard could not be relaxed and would be applied at the point(s) of compliance ndash land application influence groundwater reaching drinking water wells or surfacing at gaining streams and
2 537 Planning including public comment would have to be repeated when modified by wet weather compliance implementation given that KIWWTP flows and loads are well below design capacity suspending 537 Planning until the wet weather program is better developed is advised
This latter guidance being consistent with the tentative conclusion reached by LCA staff has resulted in need to document the status of 537 work to date in preparation for suspending further study until the wet weather program is better developed andor service area growth militates reactivation This report is intended to satisfy the documentation requirement
APPENDIX
APPENDIX I DEP letter ndash Jordan Creek
APPENDIX IIa LCA 537 Tech Memo (121913)
AECOM 1700 Market Street Suite 1700 Philadelphia PA T 2153994370 F 2153994371 wwwaecomcom
Memorandum Date December 19 2013
To Ms Pat Mandes LCA
From Ralph Eschborn
Copy Robert Kerchusky LCA
William Bohner ARRO
Subject Lehigh County Authority 537 Plan 4 MGD Expansion Alternatives ndash Evaluations ndash Recommendations
Dear Pat
Based on our findings to date and guidance we received at the recent workshops held with the LCA staff and Board we recommend the following near-term actions and schedule Near-Term Actions
Defer further work on direct discharge to Jordan Creek ndash Based on the findings that ndash - The geological circumstances associated with discharge to Jordan Creek would require
a costly multi-year effort to determine if meeting secondary drinking water standards is avoidable
- A favorable determination is problematic given DEPrsquos stated position and - Meeting secondary drinking water standards through reverse osmosis in economically
highly disfavored as an alternative Jordan Creek is now a distant third or fourth choice in terms of attractiveness as an alternative for a 4 MGD expansion Accordingly no further work is planned until remaining uncertainties associated with the ldquofront runnersrdquo are resolved Front running alternatives are ndash
- KI expansion - Cost-reduced land application or - A hybrid of the two with consideration of phasing
Conduct an effluent sampling and analysis program at the IPP ndash 4 to 6 weeks of sampling is recommended commencing as soon as possible Sampling and analysis would be for the following effluent constituents ndash
December 19 2013
- Sodium - Calcium - Magnesium - Potassium - Chloride - Sulfate - TDS - Alkalinity
The analyses would be based on daily composites as was done for the TDS analyses conducted this past August The purpose is to characterize the cation and anion composition that makes up the high (1800 mgL) TDS concentrations observed in August This information is needed to evaluate the availability of any less costly alternatives to reverse osmosis for TDS reduction and assess the ability of land application to accommodate these high TDS levels Funding for this analytical effort would be outside of the ARROAECOM budget
Develop a GPS-X model of the Klinersquos Island facility ndash Based on our analysis of Klinersquos Island (KI) operating data (as summarized in a Quantitative Mass Flow Diagram or ldquoQMFDrdquo) no supplemental sampling is required in order to develop and calibrate a model Once developed and calibrated we will be positioned to quickly simulate and evaluate KI 4 MGD expansion treatment alternatives including added hybrid and phased cases and home in on a ldquoshort listrdquo of two or three attractive approaches for full evaluation Beyond this immediate ldquopayoffrdquo the model will be available as a powerful tool for future use This effort is budgeted in our Scope of Work
Conduct a preliminary assessment of a cost-reduced land application program modeled after the Penn State ldquoLiving Filterrdquo ndash This effort would entail engaging Dr Richard Parizek as a subconsultant Dr Parizek has been instrumentally involved in the three-decade-long Penn State program since its inception and will be able to quickly assess this potential including addressing the new issue regarding the impact of high TDS effluent Budget for Dr Parizekrsquos effort will be made available from reduced effort in the outreach program
Commence conveyance modeling now with the ldquoas isrdquo LCA and COA models ndash This effort as originally envisioned entails assessing infrastructure needed for a ldquono net increaserdquo to system wet weather surcharging and overflows with a 4 MGD increase in dry weather flows conveyed to KI The preliminary estimate of this infrastructure cost needs to be refined to reduce uncertainty and confirm KI expansion as a ldquofront runnerrdquo The current conveyance system models in particular the COA system model need further upgrading This effort will take 12-18 months While this effort is needed for a cost-effective compliant design for the overall wet weather system the level of sophistication and precision in the current models is
December 19 2013
sufficient for the narrower task of firming the conveyance cost for KI expansion alternatives Residual uncertainty can be addressed with erring to the conservative side on infrastructure requirements We recommend moving forward now to avoid delay to the 537 planning process This effort is budgeted in our Scope of Work At such time as the refined integrated LCACOA model is in place if KI expansion prevails as the preferred approach the ldquono net increaserdquo infrastructure can be superseded as part of a more cost-effective integrated system approach
Schedule Overall the ARROAECOM team is striving to hold to the original schedule which targeted May 2014 for public comment on a draft 537 Plan To date conveyance system modeling and treatment facility alternatives evaluation have been on ldquofloatrdquo while awaiting wet weather model improvements and firming of future effluent standards respectively Updating and confirming future effluent standards has been a primary focus since outside agencies (DEP DRBC) are involved and the schedule is not within our control until we have their formal inputsupdates With Jordan Creek being deferred the largest uncertainty to the schedule is obtaining DRBC guidance In recent communication with DRBC they reported a significant issue arose as a result of updating their watershed model to replace their low estimated value for KI effluent phosphorus with actual effluent P concentration data This triggered a major recalibration which took several weeks but is now reportedly resolved They indicated they will have guidance for us in early January Building off of this date we need to activate both the conveyance modeling and alternative evaluations promptly to minimize schedule delay We foresee the following schedule
By end of January ndash - Complete IPP cationanion effluent sampling and analysis - Complete familiarization with COA wet weather model (ARCADIS) - Complete KI model development and calibration and - Receive preliminary assessment on feasibility of a high TDScost-reduced ldquoLiving
Filterrdquo land application system
By the end of February ndash Identify casesscenarios for evaluation This would entail ndash - An expansive look at options afforded with hybrid approaches (eg some land
application partial expansion of KI) phasing and utilization of the ldquopenalty clauserdquo in the COAKI signatory agreements and
- A workshop with LCA staff to screen the array of options identified down to a list of candidates for evaluation
December 19 2013
By the end of April ndash - Complete conveyance modeling and firm cost of conveyance for KI alternatives - Run KI modeling simulations develop ldquoshort listrdquo for full evaluation - Develop land application preliminary design review with DEP
By the end of May ndash - Develop budgetary opinions of probable construction cost and Present Values for the
ldquoshort listedrdquo alternatives and - Hold workshops with LCA staff and Board to review findings
APPENDIX IIb LCA 537 Status Meeting (111113)
copy2013 ARRO
LCA amp City of AllentownWastewater Capacity Program
Sewage Facilities (Act 537) Plan
Project Status Update
Monday November 11 2013 Lehigh County Authority Offices
1200 pm
2 copy2013 ARRO
Todayrsquos Agenda
1 Introductions
2 Jordan Creek Alternative
3 Conveyance Matters
4 IPP and Klinersquos Island WWTP
5 City of Allentownrsquos Continuing Role
6 TimingSchedule
3 copy2013 ARRO
Jordan Creek Alternative
History (See 100113 memo) ndash How we arrived herendash November 7 2012 - Initial discussions with PaDEP
ndash May 30 2013 ndash PaDEP defines Two (2) options
bull Assess impacts from discharge ndash 4 phased tasks
bull Drinking water standard
Tasks ndash Create 4 reports PaDEP approvals occur in phases
4 copy2013 ARRO
Jordan Creek Alternative
Develop a proposed Monitoring Plan - Where the creek is ldquolosingrdquo and ldquogainingrdquo flow and how will this determination be made
bull Discharge point
bull Downstream monitoring
bull Drill plan
bull Monitoring schedule amp sampling protocol
bull Timeline for implementation
5 copy2013 ARRO
Jordan Creek Alternative
Create Creek Assessment Protocol Report ndash How will the low flow conditions in the creek will be defined and reported
bull Establish the Q7 10 low flow value
bull Hydrologic modeling
bull Establish ldquonormalrdquo and the ldquoQ7 10 conditionrdquo
bull Data collection amp sampling
bull Creek chemistry
bull Data reporting
6 copy2013 ARRO
Jordan Creek Alternative
Prepare a Discharge Evaluation Report ndash How does the discharge impact creek groundwater chemistry
bull Rate of recharge to the local aquifer
bull Creek water chemistry ndash as defined by Creek Assessment Protocol Report
bull Discharge chemistry ndash as defined by wastewater engineer
bull Impacts to the creek (comparison)
7 copy2013 ARRO
Jordan Creek Alternative
With positive results prepare a Discharge Impacts Report - How will the creek and groundwater be monitored to ensure that an adverse condition is not created from the discharge
bull Creek will be monitored sampled and potentially remediated after the discharge is installed
8 copy2013 ARRO
Jordan Creek Alternative
Costs 65 years = $159700 115 years = $249700ndash Proposed Monitoring Plan = $5000
ndash Creek Assessment Protocol Report = $44700 for one year with costs increasing $18000 each year required to achieve a Q7 10 condition
ndash Discharge Evaluation Report $10000
ndash Discharge Impacts Report $10000
Cost are exclusive of monitoring site access costs (easements Right of Way legal etc) For budgetary purposes a minimum of $100000 should be anticipated
9 copy2013 ARRO
Jordan Creek Alternative
Timeline = Minimum of 65 years amp Maximum of 115 years ndash Proposed Monitoring Plan 6 months for development submission and
approval
ndash Creek Assessment Protocol Report A workable timeframe is 5 yearshowever there is the possibility that data collection could occur for 10 years
ndash Discharge Evaluation Report 6 months for development submission and approval
ndash Discharge Impacts Report 6 months for development submission and approval
10 copy2013 ARRO
Conveyance Matters
Conveyance Issues
Lehigh County Authority Model
City of Allentown Model
Plan ndash Update future flows amp Upgrade COA Model (Arcadis) ndash Familiarize with WRA model (several days)
ndash Add Groundwater Module (several weeks)
ndash Flow monitoring amp full integration (18 months)
DECISION Stay on schedule with wide-range estimate or wait 18 Months
11 copy2013 ARRO
IPP and Klinersquos Island WWTP Evaluation of Alternatives
Parallel Effort ndash Effluent Limits and Facility Profiling - Facilities
3 year data analyses for KI and IPP
Completing quantitative profiles of flows loads amp step-by-step treatment performance (Quantitative Mass Flow Diagrams)
QMFDs
Modeling ndash Recommending modeling KI hold off on IPP
Supplemental Sampling
bull Not Required for KI
bull Some gaps for IPP -- will make recommendation
bull TDS sampling completed ndash need Cation-specific sampling
12 copy2013 ARRO
IPP and Klinersquos Island WWTP Evaluation of Alternatives
LCA IPP ndash Effluent TDS Data2009-2010
13 copy2012 ARROcopy2013 ARRO
IPP and Klinersquos Island WWTP Evaluation of Alternatives
14 copy2013 ARRO
IPP and Klinersquos Island WWTP Evaluation of Alternatives
Parallel Effort ndash Effluent Limits and Facility Profiling - Effluent Limits
Exploring Cost-Reduced Land Application (PSU ldquoliving filterrdquo model ndashwinter application virtually eliminates storage)
DRBC ndash Agreement on modeling to update EECs (NMC)
DEP interaction re Jordan Creek -- Secondary Drinking Water Standards ndash 500 mgL TDS
Jordan Creek IPP Treatment Alternative
ndash 4-fold reduction
ndash Conventional Technology = Reverse Osmosis
15 copy2013 ARRO
IPP and Klinersquos Island WWTP Evaluation of Alternatives
Parallel Effort ndash Effluent Limits and Facility Profiling
Treatment Alternative - RO
Coagulation + Sedimentation rarr MFUF rarr RO
ndash All 3 steps CAPEX = $65gal
minus Last 2 (Red) CAPEX = $25gal
minus 4 MGD CAPEX = $10 Million
OPEX = $1601000 gal rarr x 10^3 x 4 MGD x 365= $23 millionyr rarr $23 million Present Worth Cost
TOTAL PW = $33 Million
16 copy2013 ARRO
IPP and Klinersquos Island WWTP Evaluation of Alternatives
Parallel Effort ndash Effluent Limits and Facility Profiling
Present Worth of Alternatives
Uncertaintiesndash Klinersquos Island 4 MGD Conveyance Cost (included but needs validation)
ndash Cost Reduction Potential for Land Application (~ $20 million PW reduction)
ndash TDS Impact on Land Application
ndash Lower Cost TDS treatment ndash Source Control Lime softening
ndash Potential to further reduce KI Cost ndash Phasing New Technology Split Flows (2 MGD Land App 2 MGD KI)
$ MillionsKlinersquosIsland
Land Application
Jordan Creek LehighRiver
CAPEX 625 712 593 962
OPEX (PW) 105 142 101 106
PW 73 853 694 1068
TDS Removal 33
PW 1024
17 copy2013 ARRO
IPP and Klinersquos Island WWTP Evaluation of Alternatives
Shifting Focus
bull Evaluate cost-reducing potential for ldquoLiving Filterrdquo approach
bull Develop New Hybrid Scenarios for KI KI+LA split
Action Items for Consideration
Evaluate TDS impact on Land Application
Develop Klinersquos Island Model
IPP Supplemental Sampling ndash Cation Concentrations
Preliminary assessment of Source Control
Proceed with Collection System Simulations
18
City of Allentownrsquos Role
City of Allentownrsquos Continuing Role in the Planning Process
copy2012 ARRO
19 copy2013 ARRO
Schedule
Schedule
APPENDIX IIIa DRBC Memorandum (22814)
Page 1 of 5
DELAWARE RIVER BASIN COMMISSION
MEMORANDUM
TO William Muszynski PE David Kovach PG Shane McAleer PE
Mail Log Reference(s)
FROM Namsoo Suk PhD
THROUGH Thomas Fikslin PhD
DATE February 28 2014 SUBJECT NMC to EWQ analysis for LCArsquos new 4 MGD discharge (Revised)
DRBC staff performed No Measurable Change (NMC) to Existing Water Quality (EWQ) evaluations as requested by the Lehigh County Authority (LCA) to determine the DRBC-required effluent limits for several options associated with LCArsquos projected increase of 40 MGD of wastewater disposal needs LCA requested effluent limitations for four potential discharge alternatives (Scenarios A B C D)
A a new 40 MGD discharge located at river kilometer 265 upstream of the mouth of the Lehigh River
B a new 40 MGD discharge located at river kilometer 216 upstream of the mouth of Jordan Creek
C a 40 MGD expansion to the existing City of Allentown (Klinersquos Island) WWTP (expanding from 40 MGD to 44 MGD)
D a substantial alteration or addition to the existing City of Allentown WWTP (while maintaining current permitted flow of 40 MGD)
Similar evaluations were performed in 2010 However LCA has provided addition information concerning actual flows and effluent quality and requested that the DRBC develop the SPW requirements using the new information The new information from LCA resulted in revisions to the DRBC estimated grandfathered (GF) loads that would be assigned to the City of Allentown WWTP Table 1 below provides the values for the key parameters in the previous and current version of the model
Page 2 of 5
Table 1 Grandfathered (GF) effluent concentrations and loads for the City of Allentown (PA0026000)
City of Allentown MGD
NH4 NO3 ON OP IP TP TN Flow
Effluent Concentration
ugL
Grandfathered (Old)
307 2300 16000 2400 650 350 1000 20700
Grandfathered (Revised)
316 1350 15060 3350 410 2770 3180 19760
Difference (Revised - Old)
+ 09 - 950 - 940 + 950 - 240 + 2420 + 2180 - 940
Load lbsday
Grandfathered (Old)
307 589 4099 615 167 90 256 5303
Grandfathered (Revised)
316 356 3972 883 108 730 839 5211
Difference (Revised - Old)
+ 09 - 233 - 128 + 269 - 58 + 641 + 582 - 92
Model update
The revision to the GF loads assigned to the City of Allentown required the re-calibration of the Lehigh River Water Quality Model (LRWQM) since the wastewater flow and loading from the City of Allentown is a substantial contribution to the BCP The re-calibrated model version named LRWQM_2014 includes other updates as listed below
Updated GF and locked-in loads based on issued dockets as of December 2013 Reassigned headwater concentrations based on observed data collected by Aqua-PA in 2012 Reassigned diffuse source loads based on observed data collected by Aqua-PA in 2012 Used best professional judgment for the assignment of unmonitored headwaters and diffuse
sources Reassigned default GF effluent concentration for ammonia nitrogen from 057 mgl to 12 mgl The model was re-calibrated for each tributary where instream water quality data was available
and for the mainstem of the Lehigh River
Scenario Simulation Results
City of Allentown WWTP
SPW effluent loadings for the City of Allentown under Scenarios A B C and D are summarized in Tables 2 and 3 below
Total effluent loads a sum of GF loads and Non-Grandfathered (NGF) (also referred to as incremental) loads for the City of Allentown with LCArsquos 40 MGD alternative discharge scenarios are summarized in Table 2
Page 3 of 5
Total effluent concentrations for the City of Allentown with LCArsquos 40 MGD alternative discharge scenarios are summarized in Table 3 for informational and design purposes
LCArsquos New 40 MGD Discharge
Effluent conditions for a new 40 MGD discharge (under alternative discharge scenarios ldquoArdquo and ldquoBrdquo) are summarized in Tables 4 and 5 There is no grandfathered allocation for the new 40 MGD discharge
Allowable effluent loads for a new 40 MGD discharge under alternative discharge scenarios ldquoArdquo and ldquoBrdquo are summarized in Table 4
Allowable effluent concentrations for a new 40 MGD discharge under alternative discharge scenarios ldquoArdquo and ldquoBrdquo are summarized in Table 5 for informational and design purposes
Page 4 of 5
Table 2 Total effluent loads for the City of Allentown with LCArsquos 4 MGD alternative discharge scenarios (Note The below load limits would be effective when the Klines Island plant expands or performs a substantial alterations or addition)
Total effluent loads for the City of Allentown for (GF + NGFs under 4 scenarios)
Flow Effluent load (lbsday) MGD NH4 NO3 ON OP IP TP TN
Grandfathered GF 316 3560 39715 8834 1081 7305 8386 52110 Allentown when LCAs 4 MGD plant into Lehigh River (A) GF+NGF 400 4121 45814 10657 1887 8216 10104 60592 Allentown when LCAs 4 MGD plant into Jordan Creek (B) GF+NGF 400 4226 45639 10657 1887 8216 10104 60522 Allentown when LCAs 4 MGD loads to Allentown WWTP with expansion to 44 MGD (C)
GF+NGF 440 4388 48719 11525 2271 8650 10922 64632
Allentown when LCAs 4 MGD loads to Allentown WWTP without expansion (maintain 40 MGD) (D)
GF+NGF 400 4261 46515 10867 1993 8356 10349 61644
Table 3 Total allowable effluent concentrations for the City of Allentown with LCArsquos 4 MGD alternative discharge scenarios (Note Allowable concentrations are provided for informational and design purposes)
Allowable effluent concentrations for the City of Allentown for (GF + NGFs under 4 scenarios)
Flow Effluent concentrations (ugL)
MGD NH4 NO3 ON OP IP TP TN Grandfathered GF 316 1350 15060 3350 410 2770 3180 19760 Allentown when LCAs 4 MGD plant into Lehigh River (A) GF+NGF 400 1235 13724 3193 565 2461 3027 18151 Allentown when LCAs 4 MGD plant into Jordan Creek (B) GF+NGF 400 1266 13672 3193 565 2461 3027 18130
Allentown when LCAs 4 MGD loads to Allentown WWTP with expansion to 44 MGD (C)
GF+NGF 440 1195 13268 3139 619 2356 2974 17601
Allentown when LCAs 4 MGD loads to Allentown WWTP without expansion (maintain 40 MGD) (D)
GF+NGF 400 1277 13934 3256 597 2503 3100 18467
Page 5 of 5
Table 4 Allowable effluent loads for the 40 MGD LCA Plant under two direct discharge scenarios
Allowable effluent loads for the 40 MGD LCA Plant Flow Effluent load (lbsday) MGD NH4-N NO3-N ON OP IP TP TN
NGF load when the LCAs 4 MGD plant into Lehigh River (ldquoArdquo) NGF 40 267 2904 868 384 434 818 4039 NGF load when the LCAs 4 MGD plant into Jordan Creek (ldquoBrdquo) NGF 40 317 2821 868 384 434 818 4006 Table 5 Allowable effluent concentrations for the 40 MGD LCA Plant under two direct discharge scenarios (Note Allowable concentrations are provided for informational and design purposes)
Allowable effluent concentrations for the 40 MGD LCA Plant Flow Effluent concentrations (ugL) MGD NH4-N NO3-N ON OP IP TP TN
EEC1 for the LCAs 40 MGD plant into Lehigh River (ldquoArdquo) NGF 40 800 8700 2600 1150 1300 2450 12100 EEC2 for the LCAs 40 MGD plant into Jordan Creek (ldquoBrdquo) NGF 40 950 8450 2600 1150 1300 2450 12000
Since these loadings are not included in approved dockets it is important to note that simulation results may change as DRBC obtains more information on headwaters diffused sources point source discharges etc for the Lehigh River watershed or if any new or expanded wastewater discharges within the model domain are proposed
APPENDIX IIIb DRBC Meeting Minutes and NH3 Proposal
LCACity of Allentown Act 537 Plan
Delaware River Basin Commission Meeting (DRBC) July 22 2014 ndash 200 PM
Meeting Minutes
Attending
Shane McAleer DRBC
Namsoo Suk DRBC
Ralph Eschborn AECOM
Pat Mandes LCA
Bob Kerchusky City of Allentown (COA)
Liz Cheeseman ARRO
Tim Bradley KleinfelderOmni
Edward Becker ARCADIS
Bill Muszynski DRBC
Brian Chamberlain COA
Note Attachment 1 ndash Meeting LogSign‐in Sheet
Attachment 2 ndash July 18 2014 Email Response from Shane McAleer RE LCA 4MGD Expansion ndash
Prospective DRBC Effluent Limits ndash (Used as meeting agenda)
Attachment 3 ndash Wintertime mass flow calculations factor for Ammonia
Attachment 4 ndash EPA Guidelines for setting effluent limits
Attachment 5 ndash Proposed wintertime (October through April) ammonia mass load limit
Introductions
A Purpose Review Shane McAleerrsquos email response dated July 18 2014 for clarifications
to prospective DRBC effluent limits for LCA 4 MGD expansion
Note The meeting and meeting minutes directly reflect the layout of the email
correspondence attached (Attachment 2) If further clarification or discussion was not
required a corresponding number is not included The reference to the ldquoMemordquo is to the
DRBC February 28 2014 Memo subject ldquoNMC to EWQ analysis for LCArsquos new 4MGD
discharge (Revised)rdquo
1b1) Grandfathered (GF) Flow
Mr Becker requested clarification that summer months were May through
September and Winter Months were October through April Mr McAleer
confirmed
1b2) GF Loads
The data that was used was the data LCA provided to DRBC
2)a) LCA noted that the data that was used included an unusually warm year
1c Clarification was provided that TP loads were based on the summer time period
3a Reference was made to the following statement ldquoTherefore the ammonia load
limit in the winter will be 17 times the load limit for each of the discharge scenarios laid
forth in the Memordquo
LCA expressed concern with regard to the Ammonia load limit in the winter
being 17 times the load limit for each of the discharge scenarios Mr Becker
said that a more appropriate averaging on load rather that concentration results
in a ratio greater than 2 Mr Beckerrsquos calculations are attached as Attachment 3
Mr Eschborn asked how the limits will be implemented for a permit
Mr Muszynski stated usually PA DEP places limits on concentration based on a
ratio of a monthly limit DEP limits may not be tied into DRBC limits DRBC looks
at mass loading of the discharge Results would be reported monthly against a
monthly standard (Monthly = TMDL x 30)
Mr Bradley asked if calculations can be performed similarly to an EPA guidance
document Mr Bradley also stated that he has NJ data from a similar project
that used this method The relevant portion of the EPA guidance document is
attached as Attachment 4
The contributors to wintertime variability in ammonia loadings were discussed
Operations Temperature and pH Low wintertime temperatures adversely
affect the nitrification (ammonia removal) process
Mr Muszynski asked how LCA would like to see the ammonia limit calculated
Mr Muszynski recommended that LCA come back with a proposal suggesting a
calculation method He indicated he would be open to considering a winter
ammonia mass load limit being over a 6‐month period (180 days x TMDL) to deal
with the anticipated variability See Attachment 5 for proposal
Dr Suk requested the NJ Data that Mr Bradley referenced Mr Bradley agreed
to look into
4 Clarification was made on which parameters would receive seasonal load limits
DRBC will set seasonal load limits on Ammonia only Non‐seasonal parameters are
Nitrate Total Phosphorus and Total Nitrogen
Mr Muszynski DRBC summarized the request
1 Some adjustment to the proposed 17 factor for setting wintertime ammonia
limit
2 The use of an extended winter averaging (over 6‐7 months)
Mr McAleer said if LCA has additional data they could send it over to DRBC Mr
Eschborn said LCA currently does not have any more data to send
Mr Eschborn asked how DRBCrsquos current monitoring is going Dr Suk responded saying
there are mixed results They will have trends by the end of the year
Ms Mandes requested a list of Wastewater Treatment Facilities (WWTFs) in DRBC
drainage area Dr Suk said he can provide a list to LCA
Mr Muszynski stated that the loading amounts are on a first come first serve basis
Mr Eschborn asked how many WWTFs have made substantive alterations
Dr Suk responded 5 in Lehigh County area and average 5 ndash 10 year
Mr Muszynski stated that substantive alterations consisted of the need for a WWTFrsquos
capacity to be increased andor WWTF design flow is not changing but major equipment
changes are made
DRBC is committed to water quality management Nutrient trading is not limited to
point sources
Mr McAleer noted that future NPDES draft permits will consist of the incorporation of
the DRBC concentration amounts into NPDES permit In the long run there will be no
docket only an NPDES permit
There was discussion with regard to dockets and if they could go longer than 5 years
Mr Muszynski stated no compliance schedule can go over 5 years without a court order
B Recap Plan Action Items Schedule
a Action Items Draft meeting minutes to everyone for review [LCA]
b DRBC analysis and proposing of a wintertime ammonia limit for the Act 537 Plan
c Schedule is January 2015 Draft Act 537 Plan
Adjournment
Attachment List
1 Attachment 1 ndash Meeting Log Sign‐in Sheet
2 Attachment 2 ndash July 18 2014 Email Response from Shane McAleer RE LCA 4MGD
Expansion ndashProspective DRBC Effluent Limits
3 Attachment 3 ndash Wintertime mass flow calculations factor for Ammonia
4 Attachment 4 ndash EPA Guidelines for setting effluent limits
5 Attachment 5 ndash Proposed Wintertime Ammonia Limit
Attachment 1 ndash Meeting LogSign‐in Sheet
Attachment 5 September 2 2014
BASIS ndash Wintertime Ammonia Limit
Ammonia analyses provided to DRBC for periods Oct‐April 2010‐11 2011‐12 and Oct‐Jan 2012‐13
Summer monthly load discharge averaged 304 lbsd with a range of 227 lbsd to 554 lbsd
Winter monthly load discharge averaged 616 lbsd with a broad range of 306 lbsd to 1139 lbsd
Winter peaking factor based on average loads = 203 (616304)
GRANDFATHERED + Non‐GRANDFATHERED LOAD ndash 44 MGD
LCA proposes a wintertime limit to be based on 7 month average October through April
LCA proposes a wintertime peaking factor using the same data set that DRBC used but more appropriately based on mass load averaging rather than concentration
DRBC 2010 DRBC Prelim 2014 LCA Proposed
Summer Winter Summer Winter Summer Winter
lbsd 698 ndash 4388 746 4388 8908
mgL 19 ndash 12 20 12 24
Summer defined as May through September Wintertime peaking factor of 17 Wintertime peaking factor of 203
APPENDIX IIIc LCA Expansion ndash DRBC Winter Load Limits Final (22715)
From McAleer ShaneTo Eschborn RalphCc Kovach David Suk Namsoo Muszynski BillSubject LCA Allentown Expansion evalaution - DRBC Seasonal Wintertime Load LimitsDate Friday February 27 2015 32540 PMAttachments image002png
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RalphI have confirmed with DRBC Staff that for the Allentown WWTP 4 mgd expansion evaluation we will be imposing summer and winter load limits for Ammonia The winter load allowances will be based on a 31 ratio Winter to Summer identical to the ratio of winter to summer effluent concentration and load limits included in the NPDES permit for the Allentown WWTP The Ammonia load limits in pounds per day provided in Tables 2 and 4 of DRBCrsquos February 28 2014 memo will be applied to the summer months (May through September) The Ammonia load limits for the winter months (October through April) will be three times the summer load limits in pounds per day Effluent concentrations in Tables 3 and 5 of the memo provided for information and design purposes will be similarly adjusted This is a larger ratio for winter to summer Ammonia than the previously-discussed 17 which was based on actual data This would be for all 4 scenarios the Allentown WWTP scenarios (re-build at 40 mgd and expansion to 44 mgd) and the new WWTP discharge scenarios (Jordan Creek and Lehigh River) The load limits in pounds per day will be applied as a monthly average Please note that we will not be instituting an overall winter load limit in pounds as you requested This will be memorialized in an updated memo If you have any questions do not hesitate to contact me Sincerely