HomeMy Public PortalAboutExhibit MSD 80A - Surrebuttal Testimony Richard Unverferth, MSDMSD Exhibit No. MSD80A
2019 Rate Change Proceeding
RICHARD L. UNVERFERTH
Surrebuttal Testimony
Metropolitan St. Louis Sewer District
June 3, 2019
Table of Contents
Page
Wastewater Capital Improvement & Replacement Program (CIRP) ..........................................1
Surrebuttal Testimony of Richard L. Unverferth, MSD June 3, 2019
2019 Rate Change Proceeding 1 MSD Exhibit No. MSD 80A
Wastewater Capital Improvement & Replacement Program (CIRP) 1
2
Q1. Michael P. Gorman testified in rebuttal testimony that the District has discretion to 3
delay a number of projects within the CIRP into future years, specifically in fiscal years 4
2023 and 2024, and specifically in three areas: (1) wastewater solids combustion boiler, (2) 5
wastewater plant repair, and (3) capacity expansion. Does the District have that 6
discretion? 7
8
A. No, the District does not have that discretion. Deferring until after FY 2024 would risk 9
non-compliance with the Consent Decree, state and federal laws and regulations, and NPDES 10
permit compliance at treatment plants. 11
12
Please note that the “areas” identified by Mr. Gorman are really larger categories of 13
multiple projects, which during Direct Testimony Mr. Gorman confirmed were the following 14
projects: 15
• The “wastewater solids combustion boiler” that was referred to was the 16
fluidized bed incinerator project at the Bissell and Lemay wastewater treatment plants. 17
(MSD project 12565) 18
• The “wastewater plant repair” referred to were a number of wastewater 19
treatment plant repair projects at various wastewater treatment plants. (see Table MPG-3 20
page 2 of 2, MSD Exhibit MIEC 73) 21
• The “capacity expansion” referred to were projects related to the capacity 22
expansion of the Lower Meramec Wastewater Treatment Facility (MSD project 12255), 23
and the decommissioning of the Fenton Treatment Facility (MSD project 12170). 24
25
The Bissell and Lemay Fluidized Bed Incinerators project replaces incinerators originally 26
constructed in the 1970s. The operation of these incinerators is regulated by USEPA and 27
MDNR. 40 CFR Part 62 – Federal Plan Requirements for Sewage Sludge Incineration Units 28
Constructed on or Before October 14, 2010 (SSI Rule) was finalized in June, 2016, and required 29
new Maximum Achievable Control Technology (MACT) standards to be included in the Bissell 30
and Lemay plant operating permits. The SSI Rule defines a 50% threshold for the cumulative 31
cost of changes to existing incinerators before mandating replacement. As MSD has reached this 32
Surrebuttal Testimony of Richard L. Unverferth, MSD June 3, 2019
2019 Rate Change Proceeding 2 MSD Exhibit No. MSD 80A
threshold, future rehabilitation of the existing incinerators is prohibited. The District’s second 33
material amendment to the Consent Decree was negotiated to financially accommodate the 34
construction of new fluidized bed incinerators, by delaying a number of major Consent Decree 35
tunnel projects. This Consent Decree amendment states “the Parties agree that this proposed 36
Amendment is necessary because MSD currently incinerates 68,000 tons of sewage sludge 37
annually, utilizing multiple hearth incinerators. The Federal Plan Requirements for Sewage 38
Sludge Incineration Units Constructed on or before October 14, 2010, set forth at 40 C.F.R. Part 39
62, Subpart LLL (“SSI Rule”), issued by EPA in 2016, require MSD to replace its multiple 40
hearth incinerators. The replacement of these incinerators will occur in fiscal years 2021–2026 41
timeframe and is estimated to cost approximately $360 million in 2017 dollars.” Construction 42
funding for this project is budgeted in FY 2023, 2024, and 2025. The FY 2025 budget funds 43
construction work that will extend into FY 2026. The District has no discretion to delay this 44
project. 45
46
Regarding “wastewater plant repairs”, the District is obligated to operate and maintain its 47
facilities to stay in compliance with its regulatory obligations and wastewater treatment plant 48
permits. NPDES permit violations and negative environmental impacts could result from the 49
District’s failure to complete the treatment plant rehabilitation, repair and replacement projects. 50
The District utilizes an Asset Management approach and prioritization process in planning these 51
types of projects, as described in the Rate Commission Third Discovery Request (EXHIBIT 52
MSD 63A-D). This approach is intended to ensure that the most critically important projects are 53
funded first, while projects without an anticipated potential for near-term failure or that appear to 54
have minor consequences of failure are not funded. Based on the District’s efforts to prioritize 55
these projects, and the potential for NPDES permit violations and negative environmental 56
impacts at these facilities if these projects do not proceed, we do not have discretion to delay 57
these projects. 58
59
Regarding the “capacity expansion”, these projects are listed in the Consent Decree as 60
required projects. See following for the dates associated with these projects. The District has no 61
discretion to delay these projects. 62
63
64
Surrebuttal Testimony of Richard L. Unverferth, MSD June 3, 2019
2019 Rate Change Proceeding 3 MSD Exhibit No. MSD 80A
Lower Meramec River System Improvements – Baumgartner to Fenton WWTF Tunnel (Pg. E-65
28) 66
• Initial Design 8/20/2016 67
• Commence Construction 7/30/2020 68
• Complete Construction 7/9/2024 69
• Placement in Service 11/6/2024 70
Lower Meramec WWTF Expansion Phase II (Page E-29) 71
• Initial Design 3/13/2018 72
• Commence Construction 2/25/2021 73
• Complete Construction 2/10/2024 74
• Placement in Service 11/6/2024 75
Fenton Wastewater Treatment Plant Elimination (Page E-22) 76
• Initial Design 2/25/2021 77
• Commence Construction 8/14/2023 78
• Complete Construction 8/8/2024 79
• Placement in Service 11/6/2024 80
81
Q2. During the rebuttal testimony technical conference Nicole Young was questioned on 82
the overall percentage of the CIRP that is either CD related, Regulatory, or Other, what 83
are those percentages? 84
85
A. Previously provided in Appendix 7.2.2-4 of Exhibit MSD 1 have been summarized 86
below: 87
88
Surrebuttal Testimony of Richard L. Unverferth, MSD June 3, 2019
2019 Rate Change Proceeding 4 MSD Exhibit No. MSD 80A
Percentage of CD to Regulatory to others for each and all 4 years of the Rate cycle: 89
FY CD Regulatory Other Total:
2021 321,048,000 25,310,000 1,000,000 347,358,000
Percentage 92.4% 7.3% 0.3% 100%
2022 309,759,000 20,530,000 6,000,000 336,289,000
Percentage 92.1% 6.1% 1.8% 100%
2023 298,336,000 124,928,000 1,000,000 424,264,000
Percentage 70.3% 29.4% 0.2% 100%
2024 234,290,000 168,320,000 6,000,000 408,610,000
Percentage 57.3% 41.2% 1.5% 100%
Totals: 163,433,000 339,088,000 14,000,000 1,516,521,000
Percentage 76.7% 22.4% 0.9% 100%
90
Q3. During the rebuttal testimony technical conference Nicole Young was questioned on 91
the Bissell Trickling Filter Replacement project proposed in the upcoming rate cycle, and 92
the potential for utilization of existing aeration tankage that exists at the plant. Can you 93
provide the background that provides the basis for the scheduling of this project? 94
95
Need for New Trickling Filter Media 96
• The Trickling Filter (TF) Media Replacement was identified in the February 2014 97
WWTF Capital Improvement Plan document; in the 5-10 year timeframe (2024 98
would be 10 years). 99
• TF media was put online in 1992 and is 27 years old, it has reached end of life 100
and is showing signs of failure such as sections on top starting to crumble and 101
media pulling away from walls. There is no way to determine exact life 102
expectancy remaining without decommissioning one TF (making it inoperable) 103
and taking out five modules from each layer and sending in for testing. This 104
would not only reduce capacity but also have a significant cost. 105
• The manufacturer stated that when TF media has reached its end of life and fails it 106
is usually a catastrophic failure. They also felt if one goes the others are not far 107
behind. They stated TF media life expectancy is around 25 years. The media has 108
Surrebuttal Testimony of Richard L. Unverferth, MSD June 3, 2019
2019 Rate Change Proceeding 5 MSD Exhibit No. MSD 80A
lasted as long as it has because this media design was very hearty due to the 109
organic loading on the plant initially and then that loading was reduced by 110
AB/Inbev putting in their own pretreatment system. 111
• Lead time on media is 5-6 months as it is made to order and then there is the 112
install time & cost. So this is not a project easily done in an emergency failure 113
situation. 114
• There is treatment benefit to replacing as well. As the new media can be designed 115
for existing loading and we can use more cross flow media which allows for 116
better oxygen transfer, and better nutrient removal. And the Nutrient study 117
recommended Biological Treatment keeping TF and doing chemical removal. 118
119
Trickling Filter Media Replacement vs. Turning Back On Aeration 120
Aeration cannot go back on line due to the following: 121
• Aeration was designed as polishing units to follow TF, not to treat the full flow of 122
the plant without TF, so media replacement would still be required. This was 123
verified in the comprehensive nutrient study. 124
• Aeration is situated at a higher elevation than primary so it would require 125
pumping up to TF to aeration. 126
• All piping, expansion joints and aeration air valves would need to replaced 127
• There is an estimate of over $150K in tree removal as snails and trees were left to 128
grow after these basins were removed from service. 129
• Concrete repairs to aeration tanks will be required; the extents of repairs are 130
unknown. Assessments would need to be made after all trees are removed 131
• O&M cost of running aeration tanks is higher than TF. 132
• The comprehensive Nutrient study is summarized: The activated sludge would be 133
beneficial for future nutrient removal, however, the current tanks are too small 134
and would need to be replaced with bigger tanks, even needing the trickling filter 135
footprint, so demolition would be required. 136
137
Q4. Does this conclude your surrebuttal testimony? 138
A. Yes 139