Sunday, March 02, 2008
Emil the Scientist Weighs In; Proposals "Too Voluminous" for Web
The Oconee County Board of Commissioners on Tuesday night will make the most important decision yet on the upgrade of the Rocky Branch sewage treatment plant when it decides whether to accept the recommendation of the Selection Committee it appointed to review the bids for the engineering design of the plant.
That Committee has recommended that HSF Engineering of Snellville be awarded a $572,000 contract for the upgrade. The Committee also recommended an alternate design, rather than the design used at the County’s only other sewage plant on Calls Creek.
The design of the plant is crucial, for it determines the quality of the water that will be released from the plant and discharged into Barber Creek. The County has a permit from the state Environmental Protection Division for discharge of up to 1 million gallons per day of effluent into the Creek.
The design employed also determines how much water the County can store and not release into the Creek when it is flooded.
Friends of Barber Creek has repeatedly asked that the County treat the water to the highest quality technology allows and hold water in times Barber Creek is flooding.
Friends of Barber Creek has used the F. Wayne Hill sewage plant in Gwinnett County as a standard because the EPD has imposed the most stringent standards in the state on this plant, which discharges into Lake Lanier.
Data released to be in September by Oconee County Utility Department Head John Hatcher, at the request of BOC Chairman Melvin Davis, show that the Oconee County Calls Creek plant generally meets or exceeds those standards.
Oconee County has repeatedly touted the Calls Creek plant as a model, and it said that Rocky Branch would use the same technology. The County began to hedge in late summer of 2007, however, indicating that the plant is expensive to operate.
In the Request for Proposal for the upgrade the County issued on November 16, 2007, the County allowed firms to submit alternative designs as long as they included some form of membrane filtration, which the County has said allows the Calls Creek plant to achieve such a high level of treatment.
HSF "highly recommended" the alternate design because "It is less expensive to build" and is "much more reliable and less expensive to operate and maintain." The HSF proposal refers to the original design as a MBR (membrane bio-reactor) and proposed instead a Qualifluent membrane design.
The difference, according to the HSF proposal, is that the MBR design "places membranes in "mixed liquor" with concentrations from 8,000 to 10,000 milligrams per liter while the Qualifluent membrant plant, which uses pretreatment prior to membrane filtration, places the membranes in effluent at 30 mg/l.
The result, according to the proposal, is much longer membrane life with the same quality of effluent.
Hatcher reported to the BOC at its meeting of February 26 that the construction cost for the plant will be $8 million. The HSF proposal lists a cost of $9 million for the base design but no figure for the alternate design.
On the morning of February 27, I sent Hatcher an email asking him to if he could provide data on the effluent from the plants that HSF is operating or has built using the same technology as will be used at Rocky Branch. I said I was seeking the "same type of data you provided me on Calls Creek."
Hatcher wrote back on the afternoon of the 28th that:
"I do not have any operating data from the plants that HSF has constructed because these plants do not use membrane filtration and would not be a good comparison to the effluent of Calls Creek. While his plants have met reuse requirements, the effluent is not filtered to the same quality that the membranes achieve at Calls Creek. Please keep in mind that many types of plants are able to produce water that meets re-use standards but the Rocky Branch design as proposed would treat to a much higher quality than is required. Any comparison between the HSF plants and Calls Creek would be apples and oranges."
After Commissioners Jim Luke and Chuck Horton intervened and asked for clarification, Hatcher sent an email message on Friday afternoon saying:
"I'm working on getting data from a plant using the Siemens CMF-S membranes which are the 'drinking water' membranes that would be used on the back end of Rocky Branch to polish the water leaving the clarifier. As soon as I get the data, I will forward this to everyone."
The issue of water storage also has produced an interesting turn. The County has repeatedly said it would have sufficient storage capacity on site so it would not have to release water into a flooded creek.
Emil Beshara, the County’s Public Works Director, on Friday said in an email that my concerns about the release of water from Rocky Branch into a flooded creek are not "based on sound science" and that the County would not hold water in times of flooding.
Here are two paragraphs from the lengthy message (WWTR is waste water treatment plant):
"The storage capacity that is designed into every WWTP is there for a purpose- to provide a means to avoid discharge to the receiving water body in the event of a plant malfunction. If that storage capacity were to be intentionally reduced because the BOC simply wanted to placate your concerns that are not (at least so far) based on sound science, we would be losing available storage capacity that could be desperately needed in the event of a plant malfunction. I asked you specifically about other permitted WWTPs that employ this practice because I am interested in whether EPD would even allow such action as it would consume design storage capacity for reasons other than storage of off-specification effluent.
"EPD evaluates stream flow capacity, and sizes wasteload allocations based on such, so they would appear to disagree with your assertion that discharge would have any significant impact during times of flood. I’m not implying that you (or they) are wrong, but since we are dealing with science here, you’ll have to produce some real numbers in order to make your point. My evaluation of your concerns in this regard to date is that it would be inappropriate to direct on-spec effluent to the storage facilities due solely to flood conditions. Not only does it appear (by my initial impression and your own admission) that the result would be a small, incremental impact, but the result of mixing specification effluent with off-spec would require re-treatment of the stored product."
In a subsequent message, Beshara even criticized the RFP itself for including membrane filtration, which he said was an unnecessary expense for the County. He was not working for the County when the RFP was drafted, he said.
The County administration has wrapped the whole process of making the decision on this design in secrecy, refusing to release any information on the bids to the public until the day after the Feb. 26 meeting.
At the January 29 meeting of the BOC, Chairman Davis said all bids would be put on the County’s web site after the February 26 meeting, but it did not do that. County Administrative Office Alan Theriault said at that meeting the nine bids were too "voluminous."
I reviewed all of them and copied parts of each of them on February 29 at the courthouse. Counting pages is hard, since many uses spacers, but none appeared to be longer than 50 pages, and most are in the 40-page range. All, it appears, were produced electronically, and the County could have requested electronic copies had it wanted to make them available to citizens.
I specifically asked on February 27 for an electronic copy of the HSF proposal, but my request was never acknowledged. I copied the full proposal on the 29th. I needed 43 pages to copy the full text, oversized charts, and the addendum.
Here is what Chairman Davis said on the 29th:
"I want to reemphasize that when the final recommendations are made to this BOC, all proposals and bids will be public at that time and placed on the web site for review, and the BOC will not act on that proposal on that particular night or recommendation to allow plenty of time for public input."
Many of these questions could have been answered earlier, had there really been "plenty of time for public input."