CITY OF ALBANY Office of Audit and Control 24 Eagle Street, Room 111 Albany, NY (FAX)

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1 CITY OF ALBANY Office f Audit and Cntrl 24 Eagle Street, Rm 111 Albany, NY (FAX) T: Hn. Michael O Brien, Chair, General Services, Health, and Envirnment Cmmittee Frm: Leif Engstrm, Chief City Auditr Date: July 27, 2010 Re: June 24 Cmmittee Meeting Summary At yur cmmittee s request, I attended its June 24, 2010 meeting als attended by representatives f UAlbany and DASNY. The meeting fllwed up n my ffice s review f the UAlbany FGEIS with particular interest in the sewer and strmwater issues assciated with the new drmitry prject. The fllwing are my ffice s assessments f the psitives and negatives assciated with the different ptins fr the new drmitry s sanitary sewers. There is als a summary f the prpsed strmwater infrastructure fr the drmitry as well as the ther prjects cvered by the FGEIS. UAlbany has indicated that they plan t prvide cmments n this summary. I will frward thse cmments t yu when they are received. Optin 1. Cnnectin f sanitary sewers t the City f Albany sewer system at Western Avenue. Psitive N New Pump Statin, Lwer Energy Usage, and n Pump Replacement- This is the nly ptin that allws UAlbany t avid building a pump statin. Pump statins use energy and require maintenance and eventual replacement, all f which are expensive and have negative envirnmental impacts. Ample Dry-Weather System Capacity- In dry weather, there is ample capacity in the Wdville Pump Statin sewer system t accept the additinal flw frm the drmitry. Inflw and Infiltratin Mitigatin- As a cnditin f cnnecting at this lcatin, UAlbany is planning t pay fr the remval f sme strmwater inflw and infiltratin (I/I) frm Albany s sewer system. UAlbany has cmmitted t remving I/I vlumes f at least twice the drmitry s peak sanitary flw. The mnetary savings t the Water Bard are unknwn, but addressing I/I is expensive.

2 Albany Water Bard will have t address I/I issues in this sewer system. Additinally, this watershed and sewershed gaining imprtance s the issues are becming mre pressing. Assuming that the I/I being remved is prevented frm entering the sewers elsewhere, this actin shuld reduce the frequency and vlume f verflws at the Wdville Pump Statin. Sewer Fees- Additinal water and sewer fees generated by the new drmitry wuld g t the Albany Water Bard. Since UAlbany is planning t use a large number f the beds at the new drmitry t free-up space t accelerate its campus-wide drmitry rehabilitatin prgram, the new drmitry shuld nt add significantly t the Uptwn Campus s mnthly water/sewer usage fee, which was apprximately $275,000 in April. T prvide an idea f scale fr a drmitry water/sewer bill, Sayles Hall, a drm n Alumni Quad, pays water/sewer bills f $2,000 t $3,000 three times per year while Pierce Hall pays $1,000 t $2,000. (Alumni Quad at Partridge St. and Western Ave. pays the residential rate as a smaller vlume user while the Uptwn Campus pays the higher Tier 2 rate.) Negative Krumkill Creek Water Quality Issues- The cnnectin will send additinal sanitary sewage t the Wdville Pump Statin, which verflws int the Krumkill Creek during sme strm events. The Krumkill Creek has been determined t be an impaired r impacted waterbdy in many different ways: It was mved up t Part 1 f DEC s 303(d) List f Impaired Waters, which culd result in the impsitin f stricter water quality regulatins (TMDL) fr the watershed. (Meaning that UAlbany, Albany City, Guilderland, and Bethlehem culd be instructed by DEC t make specific - and cstly - changes t hw they deal with strmwater and pint surces f pllutin in the area that drains t the Krumkill Creek.) A 2007 study cnducted by aquatic bilgist Kelley Nlan and funded by DEC fund the Krumkill Creek t be impacted by industrial, municipal, and impundment surces f pllutin. The engineers develping the Albany Pl Cmbined Sewer Overflw (CSO) Lng Term Cntrl Plan (LTCP) did tests n the Krumkill Creek in 2009 and fund significant cncerns with bacterial lading CSO LTCP testing fund that during strm events, the Nrmanskill, dwnstream f the Krumkill Creek, is in vilatin f water quality standards fr fecal clifrm bacteria. CSO vs SSO Issues- The Western Avenue cnnectin wuld send additinal sanitary sewage t the Wdville Pump Statin, which is currently a DEC permitted CSO discharge pint. The CSO status is currently under review by DEC and it may be determined t be a Sanitary Sewer Overflw (SSO), which DEC cannt permit. The ramificatins f an SSO classificatin wuld be determined by discussins between the Water Bard and DEC. DEC is nt permitting any extensins f the Wdville Pump Statin sewer system until the CSO-SSO status has been determined. Office f Audit and Cntrl 2

3 Regulatry Requirements Regarding Sewer Backups- The 7/3/09 letter frm DEC specifies the requirements fr cnnectins t and extensins f the City s cmbined sewer system. Thse requirements include prhibiting further cnnectins that wuld make the surcharging/backup prblems wrse in any ther areas f the City that have dcumented recurrent instances f sewage backing up int huses r discharges f raw sewage nt the grund surface frm surcharging manhles. There are at least six hmes in the Wdville Pump Statin sewershed that have participated in the City s Backwater Valve Grant Prgram, which requires recipients t have repeated events f cmbined sewage backup. The valves have been installed n Cambridge Street, Oxfrd Rad, and Carrll Avenue. T date this ffice is unaware f any engineering determinatin regarding the impact f this cnnectin n the backup prblems within this sewershed. Presumably, the prpsed reductin in I/I wuld reduce the frequency and vlume f backups, but it des nt address the pllutin levels in the sewage when it des back up int huses. There may be n impact, but that determinatin needs t be made befre cnnecting at Western Avenue. Pssible Pllutant Lading in Backups and Overflws- Hershberg&Hershberg made the determinatin that the additin f 136 GPM f husehld sanitary waste int the Hackett Bulevard Beaver Creek Sewer System t replace I/I flws wuld result in n detectable increase in BOD*. Hwever, the cncerns regarding the Krumkill Creek watershed and the Wdville Pump Statin sewer system d nt appear t have been addressed. Sanitary sewage frm the new drmitry wuld flw, untreated, int the Krumkill Creek during strm events. The Western Avenue cnnectin wuld increase the pllutant cncentratin at the Wdville Pump Statin when it verflws and it may increase the pllutant cncentratin f sewer backups. This ffice is unaware f any engineering determinatin as t whether the increased cncentratin at the Wdville Pump Statin wuld be measurable r whether there wuld be an impact at the sewer backup lcatins. If the increase in pllutant cncentratin at the Wdville Pump Statin is measurable, UAlbany wuld need t demnstrate that their mitigatin measures will ffset that increase befre cnnecting. Optin 2. Cnnectin f sanitary sewers t the Twn f Guilderland sewers at Western Avenue. Psitive Shrter Frce Main than fr Optin 3- Frce-main wuld be shrter than the frce-main t the Patrn Creek Interceptr. N Risk f Sewage Backup Impacts in Albany- Sewage frm the new drmitry wuld nt enter an Albany City sewer system with a histry f backups. Adequate Dry-Weather System Capacity- In dry weather, there is adequate capacity in the Guilderland sewer system t accept the additinal flw frm the *BOD is a measure f a type f pllutin. Office f Audit and Cntrl 3

4 drmitry. There are I/I issues in this sewer system and while there is sme capacity in wet weather, I/I mitigatin wuld need t be dne. Nt tributary t a CSO- Althugh there are sme I/I issues in this part f Guilderland, Optin 2 wuld send the sewage t the Patrn Creek Interceptr and it wuld nt enter a cmbined sewer system. The risk f verflws r backups is much lwer than in Optin 1 thugh nt quite as lw as in Optin 3. Lw Risk f Sewage Discharge t Impaired Waters- With Optin 2, there is little risk f sanitary sewage frm the new drmitry being discharged t either the Patrn Creek r the Krumkill Creek, bth f which are n Part 1 f the 2010 Final 303(d) Impaired Waters List. This ptin has slightly mre risk than with Optin 3, because there is risk f verflw when pumps break dwn. This ptin uses tw pump statins t deliver the new drmitry s sewage t the same place. Negative Pump Statin/Frce Main Cnstructin and Operatin- Requires UAlbany t spend mney t cnstruct a pump statin and frce main. Pump statins use energy, require maintenance and eventually require replacement, all f which are expensive and have negative envirnmental impacts. Guilderland I/I Mitigatin- There are I/I issues in that sectin f the Guilderland sewer system and UAlbany wuld have t pay fr mitigatin. Higher Sewer Fees- Guilderland s sewer rates are higher than Albany Water Bard s. Tw Pump Statins Used- Sanitary sewage wuld flw t the Patrn Creek interceptr thrugh tw pump statins (UAlbany and Guilderland) instead f the ne in Optin 3. Sewer Fees t Guilderland- Usage fees wuld be paid the Twn f Guilderland instead f the Albany Water Bard. (Als see fee discussin fr Optin 1.) N Wdville I/I mitigatin- UAlbany wuld nt pay fr I/I mitigatin in the Wdville Pump Statin sewer system. Optin 3. Cnnectin f sanitary sewers t the UAlbany Nrthern Interceptr and then t the Patrn Creek Interceptr. Psitive Ample Wet Weather Capacity- The Patrn Creek Interceptr has ample dry and wet weather capacity and takes sewage directly t the treatment plant. N impact n the Cmbined Sewer System- The Patrn Creek Interceptr is nt tributary t any CSO discharge pints. Very Lw Risk f Sewage Discharge t Impaired Waters- There is almst n risk f sanitary sewage frm the new drmitry being discharged t either the Patrn Creek r the Krumkill Creek, bth f which are n Part 1 f the 2010 Final 303(d) Impaired Waters List. N Risk f Sewage Backup Impacts- Sewage frm the new drmitry wuld enter an interceptr withut any histry f backups. Office f Audit and Cntrl 4

5 Sewer Fees- Additinal water r sewer fees generated by the new drmitry wuld g t the Albany Water Bard. Please refer t Optin 1 fr details. Only One Pump Statin- Optin 3 nly requires the new drmitry s sanitary sewage t pass thrugh ne pump statin t arrive at the Patrn Creek Interceptr. Optin 2 wuld require it t pass thrugh tw pump statins. Negative Pump Statin/Frce Main Cnstructin and Operatin- Requires UAlbany t spend mney t cnstruct a pump statin and frce main. Pump statins use energy, require maintenance and eventually require replacement, all f which are expensive and have negative envirnmental impacts. Lnger Frce Main- Optin 3 requires UAlbany t spend the mney t cnstruct a lnger frce main than Optin 2 while n frce main is required fr Optin 1. N UAlbany Funding fr Wdville I/I mitigatin- UAlbany wuld nt pay fr I/I mitigatin in the Wdville Pump Statin sewer system. Please refer t the I/I discussin fr Optin 1. Equal Treatment It is imprtant t respnd t the assertins regarding equal treatment with Albany Medical Center (AMC) made in the May 11, 2010 letter frm UAlbany. There are significant differences between the tw sites sewer systems and watersheds and the fllwing pints need t be cnsidered: The Wdville Pump Statin sewer system is f a different design and was cnstructed in a different era than the sewer system at AMC. When it verflws, the sewage frm AMC is discharged int the Hudsn River, which is nt in Part 1 f the 303(d) List while sewage flwing t the Wdville Pump Statin des flw t an impaired water bdy. DEC has rdered the Water Bard t make individual determinatins with regard t the impacts f each sewer extensin n verflws and backups. At the AMC site there is n realistic alternative t cnnecting t the Cmbined Sewer System (CSS) while UAlbany s new drmitry prject has very realistic alternatives t discharging t the CSS. Strmwater Issues The FGEIS dcument has n specific details in its discussin f strmwater facilities fr its many prpsed prjects. Cnsidering that UAlbany s strmwater flws exclusively t tw water bdies listed n Part 1 f the (d) Impaired Waters List (the Krumkill and Patrn Creeks), this is an versight that shuld be crrected. The new drmitry s strmwater facilities detailed in the Strm Water Pllutin Preventin Plan (SWPPP) that was submitted t NYSDEC included tw retentin pnds t treat the strmwater befre discharging it t the strm sewer system and then t the Krumkill Creek. That prpsal wuld have sent all f the additinal runff generated by the new buildings and parking lts int Krumkill Creek and then int the Nrmanskill. This was f cncern because bth creeks have Office f Audit and Cntrl 5

6 ersin and flding issues created by the vlume and velcity f runff during strm events. (This is in additin t the water quality issues utlined abve.) In a very psitive develpment, UAlbany has decided t imprve their plans fr the new drmitries and have cmmitted t, at a minimum, installing rain gardens and building the parking lts using prus pavement. These are excellent steps in the right directin because bth practices allw water t infiltrate int the grund rather than being channeled t the creeks. By keeping mre strmwater n site and allwing it t infiltrate int the grund, UAlbany is mving t prtect the creeks frm further damage. UAlbany has generally gd sils fr infiltrating strm water int the grund and has the ptential t be an example f sustainable strmwater management. By including green infrastructure in their strmwater plans fr the new drmitries, UAlbany is mving in the right directin in prtecting the Krumkill and Nrmanskill Creeks. In the lng-term, UAlbany shuld examine a system-wide green infrastructure prgram t address strmwater runff frm all f the cnstructin prjects prpsed in the FGEIS. Office f Audit and Cntrl 6

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