Q & A: Brush Creek Water Pollution Control Facility Upgrade and Expansion
1. Why must the Plant be expanded? When the plant was last updated in 1999, the project increased the capacity by 1.5 million gallons per day, along with a rehabilitation of the treatment process. That expansion and upgrade cost approximately $30M. The operating permits for the Plant issued by the Department of Environmental Protect, at that time, maintained similar regulatory requirements.
Even then, community growth and economic development projections predicted that further expansion would be necessary by 2013. In conjunction with a goal to delay the next expansion, efforts were undertaken to reduce flow to the Plant through the reduction of infiltration, and of stormwater in the collection system and subsequently pushed the expansion needs ahead to 2015. This is the last anticipated expansion and the Plant is expected to handle the projected needs of the Township through 2030.
2. Is this more than just an upgrade? Yes! The Plant runs under an Operating Permit called National Pollution Discharge Elimination System (NPDES). This program regulates discharges into the waters of the Commonwealth, and is managed jointly by the Pennsylvania Department of Environmental Protection (DEP) and the Federal Environmental Protection Agency.
Every five years the Plant must renew this Permit. Our current Permit expires in 2015. The PA DEP has discussed the possibility of significant changes to the permitting requirements that will have a profound impact on the costs of the Plant expansion. These costs would be in addition to our need to expand the capacity, and we would have to retrofit the existing process to meet these requirements. There are two major components of the proposed changes:
Blending – During high flow periods the Plant uses a by-pass process that allows for the extra flow through the Plant. This allows the Plant to handle flow at least 4 -5 times greater than what it can normally handle. Although that high-flow by-passes some of the treatment processes, the effluent discharged into Brush Creek meets all of the requirements, much due to the stormwater dilution factor of the incoming flow. The DEP is stating that blending will no longer be acceptable, meaning, we must significantly expand our on-site storage capacities.
Nutrient levels- These relate to the level of phosphorus and nitrogen that are removed from the influent (flow into the Plant) that leaves the Plant as effluent. The discussion is centered around the reduction of those nutrients in the effluent. Reducing those levels greatly increases the amount of treatment required, thus significantly impacting the costs of the upgrade.
3. What are the estimated costs? Pennsylvania’s Department of Environmental Protection recently issued new requirements affecting the plant’s flow rates and associated treatment methods during peak weather events. In addition, tighter limits on the release of nutrients – limits which are likely to grow even more restrictive, must also be satisfied for the plant to secure its operating permits. The alternatives – each of which come with an assortment of challenges – range from $50 million for a single-phase approach, to $65 million for a two-phase approach.
4. Could these costs be passed onto the developers? Pennsylvania state law dictates the amount that can be passed onto developers. This rate was increased, when the sewer rates were increased, from $1,784.00 to $2,478.00 per EDU (equivalent domestic unity).
5. Has the Township explored other means to pay for the Project? The sewer system is supported solely by its customers. General Fund money, or tax dollars, may not be used to support the sewer system, the same as sewer revenue may not be used to pay for police or other General Fund purposes. The Township will aggressively seek state and/or federal grants to support this project, however, the state and federal governments have significantly reduced grants to local government.
6. Doesn’t the State provide public sewer systems with operating subsidies? Yes, for many years the Commonwealth of Pennsylvania distributed operating subsidies to public sewer systems. The Township received approximately $400,000 a year from that source. However, those subsidies were discontinued in 2002.
7. How did the Township arrive at the current sewage rates? Project construction is expected to begin in 2015, meaning the Township will need to borrow to fund the project. The annual associated debt will be in the in the range of $1.5 to 1.8M a year, depending upon rates at the time. The sewer rate increase and developers fees will generate approximately that amount. In addition, the anticipated soft costs, for engineering and permitting fees, will be at least $2-3M until the construction bond is in place. The Township must pay those costs from current revenue and existing capital funds. Borrowing for those soft costs, through a long-term bond, is not considered a good financial practice.
8. Why are we just hearing about the Project? The proposed expansion has been discussed at the Board of Supervisors meetings for the past four years and most extensively during 2012-13 sessions, and covered extensively by the media and through Township communication avenues. But, now the project is a reality and the reality has translated into a rate increase for customers.
When the Township receives clear direction from the PA DEP, and the preliminary design can be completed, additional public discussions will occur. Current information will be posted to the Township website.
9. What if the DEP changes the discharge limits during the 2020 permit revision? During this upgrade design, the Township will consider processes that can be enhanced in the future to meet potentially more stringent DEP effluent limits.
10. How is the project design work proceeding? The Board of Supervisors required a competitive and transparent process to select the design professionals. A multi-stage process was established to select an engineering firm with the experience and expertise to match the Cranberry Township plant upgrade project criteria. Also, an oversight, advisory engineering firm was retained to ensure that all potential solutions are explored. Discussions concerning the project will be conducted during public meetings of the Supervisors.