Director Wyant,
In preparation for our call today with Treasurer Dillon’s office, ODWMA has developed the following for
consideration. We can provide any additional info you require during the meeting.
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ODWMA has reviewed the materials developed by the consultant Tucker, Young, Jackson, Tull, Inc, (TYIT) for Treasury
regarding the City of Flint and potential alternatives for public water supply. Based on our reviews, we have developed
the following comments to this point In our analysis:
1.
7.
The TYJT report does not contain the full scope of the Karegnondi Water Authority (KWA) raw water supply
system. TYIT concerns over raw water supply redundancy and rellablility are addressed to the satisfaction of
ODWMA under the full KWA proposal. Please note some portions of the overall project are being financed
independently by the Genesee County Drain Commission.
There are significant differences in contract language between KWA and Detroit Water and Sewerage
Oepartment (DWSD) with respect to the contracted maximum day demand capacity.
a. Under a KWA contract, a “maximum day” capacity of 18 million gallons per day (MGD) would fully satisfy
current demands of the City of Flint, without the need to supplement raw water capacity using the Flint
River. (18 MGD, average over a 30 day period).
b. Under a DWSD model contract, a “maximum day” capacity, even at 18 MGD, would not satisfy the
current demands for the City of Flint. (18 MGD, over any 24 hour period).
Restrictions in contracted capacity that would prevent the City of Flint from meeting peak demand requirements
present potential limits to economic development within the City of Flint, including possible connection bans
and water system extension bans. This information was previously conveyed to the City of Flint by OOWMA
staff.
All contract options with DWSD that are considered semi-competitive with the KWA contract do not fully supply
the City of Flint, and would require the City of Flint to meet a significant, if not majority, of Its water demands by
treating water from the Flint River. Continuous use of the Flint River at such demand rates would:
a. Pose an increased microbial risk to public health (Flint River vs. Lake Huron source water)
b. Pose an increased risk of disinfection by-product (carcinogen) exposure to public health (Flint River vs.
Lake Huron source water}
c. Trigger additional regulatory requirements under the Michigan Safe Drinking Water Act (LT2ESWTR}
d. Require significant enhancements to treatment at the Flint WTP, beyond those identified in the TYJT
report (see Item 5 below).
e. Water Resource Division is evaluating potential impacts to NPDES wastewater discharge permits In
downstream segments of the Flint River, as a result of decreased river baseflow caused by Flint WTP
use.
The TYIT report does not adequately address increased requirements and costs associated with using the Flint
River as a significant source for the Flint WTP, which are not necessary under a Lake Huron source water
scenario. This includes:
a. The need to provide softening treatment
b. Limitations on disposal options for lime softening sludge
c. Increased ozone capacity, UV disinfection
d. Additional backup power, more power required for Flint River operation
The Flint WTP must operate at some minimum level and within a range of flow rates to maintain treatment
effectiveness. Currently that minimum level is 9 MGD. This level may be reduced with additional capital costs to
modify the WTP, not addressed In the TYST report.
Allowing Flint WTP to blend water with DWSD sets a new precedent that could pose future consequences with
other DWSD customers.
Costs impacts to remaining OWSD customers would be similar under the proposed scenarios, only retaining 8
MGD of 30+ MGD total Flint/Genesee Co. demands, based on the following:
3
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a. Genesee County distribution system demands are pulling out of DWSD regardless of the decisions by
Flint WTP
b. Flint’s need to utilize the Flint River as a source
9. ODWMA anticipates cost savings under the KWA proposal will be leveraged to provide additional improvements
to the City of Filnt water distribution system, improving efficiency and providing additional cost benefits. The
KWA water withdrawal permit (2009-001) includes the required implementation of conservation measures that
would also drive these distribution system Impravements.
10. Major cost discrepancies in TYJT analysis
a. Engineering, Legal, Administration, Contingency — TYJT appears to have effectively double charged for
these costs in their KWA estimates without adequate Justification
b. Pumping facilities - TVJT cost estimate methodology does not appear to address !ccalized market costs
and does not distinguish fixed and variable costs in its comparison analysis.
11. Remaining OWSD customers in Lapeer County could potentially see water quality impacts as a result of Flint
joining KWA, if they remain with DWSD. However, indications to ODWMA are that these communities are
currently in final negotiations with KWA for service, which would make this a non-issue.
a. City Lapeer
b. City of Imlay City
Additional response to the TYJT report has also been provided by Rowe Engineering to Flint EFM, Mr. Ed Kurtz. (Copy
Attached} .
ODWMA has continued to meet on a regular basis with KWA, Genesee County, and the City of Flint regarding these
water supply proposals.
ODWMA will continue to provide any additional detailed analysis requested by Treasury or the DEQ Executive Office.
Stephen Busch, P.E.
Lansing and Jackson District Supervisor
Office of Drinking Water and Municipal Assistance
MDEQ
517-643-2314
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Stanton, Terry A. (T reasury)