D.B. Western Texas, Inc.
May 18, 2015
To: City of Coos Bay
From: DBWT
RE: WWTP CB2 Alternative – North Spit Alternative
Good morning,
Once again Coos Bay City Manager, Roger Craddock, has taken the liberty to interpret DBWT’s CB-2 North Spit WWTP Project proposal without consulting with Mr. Beetham on details. So, once again he has misinterpreted a proposal that has introduced a solution to a regional water quality problem in Coos Bay at a cost benefit to citizens.
Please consider the following:
- Previous feasibility studies paid for by the City and Port regarding a North Spit WWTP do not in any way compare to the scope of DBWT’s proposal to develop a technologically advanced WWTP facility that exceeds EPA NPDES standards, now and into the future. Mr.Craddock clearly states in his report a regional North Spit WWTP and ocean outfall needs to be built. Now is the time for that legacy event to occur, increased cost will come with any future development. DBWT is committed to a Design Build Operate construction Timeline provided in Roger’s report. Federal and State agency permits required for this project can be submitted and managed parallel to save time, we expect 18 months on the outside.
- Bob Braddock’s letter in response to Mr. Craddock’s pointed questions does not state JCEP doesn’t have an interest in a North Spit WWTP. In fact the letter says “To be clear, if the City or any other credible party offered wastewater treatment services that would be more economic than what Jordan Cove is presently paying to self-perform this work, we would seriously consider”.
- Mr. Craddock excluded DBWT’s current cost comparison in this report (see attachment).Whether this was deliberate is irrelevant. City Councilor’s deserve the facts to educate themselves on such an important matter impacting over 15,000 people for decades to come.
- DEQ and City staff stating the estuary will not benefit by removing 15 MGD of wastewater treatment effluents is absurd. Stating non-point sources are the real problem is partly true, but effluents loaded with viruses, bacteria and residuals like synthetic estrogen, pharmaceuticals, caffeine, phosphates, street drugs, and treatment chemicals, day in and day out, “is” adversely affecting human health and marine life.
- DBWT submitted a Public Records Request 2 weeks ago for the CB2 mixing zone survey; City staff indicated the report should be available at the end of next week. Knowing in 1973 H6 Engineering’s design build outfall plans state a 24″ corrugated steel pipe was installed, we suspect it has failed. If so a Sec. 404 joint-application will have to be submitted to USACOE and ODSL for the in water work, this may elevate the Cities EA to an EIS delaying the project for some time.
- DBWT has contacted DEQ on the Design –Build requirements for Oregon, we will fully comply with the rules for cities fewer than 30,000 people. DBWT will follow the steps of facilities planning, pre-engineering, and the final engineering with DEQ approvals at each step. The basic SBR design, facilities planning, and pre-engineering have been completed, somemodifications will be required. DBWT is working with Professional Engineers whom have completed this process many times. Maybe the consultants used by the City staff believe it should take 6 years as they suggest, and maybe this is why the City has worked on this process for 11 years and they claim it will take them another 3 years to complete; for a grand total of 14years. We would suggest a full audit of the City’s expenditures over the past 11 years and why it has taken them so long to get to this point. This assumes that they do not have additional delays caused by a potential new in water Sec. 404 permit process and EIS to complete. Our consultants feel this may be a record for the state of Oregon.
- Our Professional Environmental Consultants predicts a 12-18 month permitting process. DBWT will be disinfecting wastewater to a much higher standard. The effluent will be cleaner to an ocean outfall than the Cities planned design. DBWT will construct a “State of Art” engineered Ocean Outfall discharging effluent 1 mile offshore into 60-70 ft. deep water. Wewill contract with the foremost Engineer of Record whom wrote the manual for EPA on Ocean outfalls, he is excited to join our team. The City’s estuary outfall with 5 diffusers discharging into water 11 ft deep at MLW and spread over 30 feet hardly compares, and it does not meet FDA standards for commercial shellfish operations. EPA 820-R-15-098 written on April 17, 2015 shows in Tables 21 and 22 the poor efficiency of an open channel UVC with laminar flow (similar to the City’s design) and compare with what DBWT will be providing.
In closing and considering the long term economic impact to citizens, who will be saddled with double the cost of sewer rates at the end of the Cities current plan, please reconsider your position. This will create an adverse environmental consequence of a wrong decision, and we are offering a next step. We invite City Councilors, City staff, and their consultants to join DBWT and their team of Professional Engineers and Environmental Consultants to engage in a public forum venue and present factual information and true merits of each proposal to the citizens of Coos Bay.
Regards,
Mr. Dennis Beetham
DBWT – President and CEO
Cc: City Manager – Roger Craddock
