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<br />. <br /> <br />. <br /> <br />. <br /> <br />Mr. Pat Klaers <br />February 5, 1993 <br />Page Two <br /> <br />· Construction of a WWTF to meet current effluent limitations (BOD = 25 mg/l and TSS <br />= 30 mg/l) and an effluent pipeline to the point that the Mississippi River is no longer <br />designated an "outstanding resource value" water (Le., Anoka City limits). <br /> <br />· Obtaining a variance from the non-degradation rules. <br /> <br />Unfortunately, none of these alternatives is particularly viable as will be explained below. <br /> <br />A stabilization pond system must store wastewater flow for a 180 day period. For a 3 MGD <br />flow this would result in over 400 acres of wetted surface. With dikes, buffer zones, etc., <br />figured in, approximately 600 acres of land would be required. This land requirement, in <br />combination with the expense of sealing the anticipated permeable soils in the Elk River area, <br />would result in a high cost to construct a stabilization pond system. <br /> <br />Land application is not a particularly viable option either, because even more land would be <br />required. Also, a land application system would require even more storage than would be <br />required for a stabilization pond system. <br /> <br />Construction of a WWTF to meet current effluent limitations (BOD = 25 mg/l, TSS = 30 <br />mg/l) and an effluent pipeline to near the Anoka City limits is not a viable alternative because <br />of the cost of the effluent pipeline ($4 million +). <br /> <br />The final alternative, that of obtaining a variance from the non-degradation rules, would result <br />in the least cost WWTF, both from a capital cost standpoint, as well as an operation and <br />maintenance cost standpoint. Gary Rott of the Minnesota Pollution Control Agency states in <br />the attached letter, "This rule (non-degradation) makes it very difficult for a discharger to <br />prove that the mass loading of his existing discharge should be permitted to increase." <br />Although this statement is discouraging, MSA feels that further research into the possibility <br />of obtaining a variance is warranted. Over the 20-year design life of the expanded WWTP, <br />the extra cost (capital and operation and maintenance) of a 9 mg/l BOD WWTF over a 25 <br />mg/l BOD WWTF will be in excess of $1 million. <br /> <br />Please let me know if you agree that MSA should conduct the research on a variance from <br />non-degradation rules. <br /> <br />Sincerely, <br /> <br />MAIER STEWART & ASSOCIATES, INC. <br /> <br />Bl!!t~