DWQ-2024-006761

Central Valley Water
Recla mation
Fa cility
gecErYq
sEP 2 3 2lJ24
Board Members
Debra Armstrong, Chair
Don Russell, Vice Chair
Kim Galbraith
Brett Hales
Cheryle Hatch
LeAnne Huff
Keith Lord
General Manager
Phillip Heck, Ph.D., P.E.\r"^n*S$'
September 16,2024
John Mackey, Director
Utah Division of Water Quality
P O Box 144870
Salt Lake Ciry, UT g4tl4 - 4970
Subject: Technology-Based Phosphorus Effluent Limits (TBPEL) Rule Variance - year 8 progress
Update
Dear Mr. Mackey:
Central Valley Water Reclamation Facility (CVWRF) is pleased to present this year 8 progress Update inaccordance with Paragraph I 1.C. of our Permit Variance which was issued from the Utah Division of
Water Quality on March 27,2017 . We believe this Update will document our due diligence towardsconstruction of a treatment facility designed to meet, and exceed, the TBPEL Rule requirements. The
system is also designed to address ammonia and total inorganic nitrogen (TIN) and is ixpected to produce
effluent ammonia of less than2 mglL and TIN of less than 10 mglL. The following activities were
completed by CVWRF over the past year:
1. TBPEL - Design and Construction Schedule - Performed by Brown and Caldwell (BC) andCVWRF
BC developed a project implementation and phasing plan showing the proposed BNR facilities in2016.
The project funding, pre-design, design and construction schedule for the iecommended facilities wasfurther refined in2018 through 202I as design progressed and construction was started. Design of allproject elements was completedin2022 and construction was underway on all the project components.
Over the past four years of construction, there were multiple delays due to COVID- 19 related issues,
equipment and construction materials supply issues, and the discovery of residual radioactive materials in
the Blower Building excavation as described in detail in the Year 6 Piogress Update (2022). While thesedelays are still affecting the overall project schedule, construction conditions improved significantly in
2023 and2024 and significant progress is being made on all aspects of the BNRproject.
Both Side-Stream Nitrogen Removal Project reactors have been started up. Reactor I has been operating
since the fall of 2023 and Reactor 2 is now being seeded and acclimating with the Anammox bacteria. It
is expected to be fully operational by the end, of 2024. There is still a delay in receiving electrical gear for
the project and the system is operating on a temporary electrical setup. Tlris delay is expected to postponefinal completion of the project :ur;rtil2025 when the electrical gear is ieceived.
The Side-Stream Phosphorus Project has also been completed and started operation in late fall of 2023.Operation of the side-stream processes has improved the performance of thi cunent liquid treatment
process and decreased the effluent levels of phosphorus, ammonia and total inorganic nit og"n. However,
800 West Central Valley Road, Salt Lake City, UT 84119-3379. [phone]. (801) g73-g280
without the full BNR process in operation, the treatment facility is not expected to be able to achieve
compliance with the TBPEL concentration of 1.0 mgL, annual average unlillate2025.
2. Design and Construction of the Biological Nutrient Removal (BNR) Process - January 2024 -
Present
Construction continued on the following project components:
o Blower Building (Alder Construction) - Construction began on April 22,2020 and is expected to
be fully complete in December of 2024. Blowers and all other systems within the building have
been installed but will need to wait for start-up until the BNR Basins Project is completed and
ready for start-up. CVWRF plans to occupy and move operational personnel into the building in
December 2024.
BNR Basins (Gerber Construction) - Construction began on July 14,2020 and is expected to be
firlly complete in May of 2026. The concrete work on all of the basins has been completed and
crews are working on the electrical distribution building and the mechanical and electrical
components of the basins such as piping and pumping systems, air distribution and diffuser
piping, conduits and wiring and control system installation.
TBPEL Rule Variance - Year B Progress Update
Page 2
Mechanical and electrical work is also being completed on the RAS/WAS Selector Structure and
Pump Station and on replacing the RAS pumps in the existing RAS Pump stations with larger
pumps for the BNR process. Additional RAS lines and tie-ins to existing RAS piping has also
been completed. Because of project delays in2020-2022 related to COVID-19, startup of the full
BNR process is now expected to occur in late 2025 or early 2026. A modified permit with
interim limits through June 30,2026 was received in October 2023 to account for delays in
construction and process startup.
Side-Stream Phosphoras Removal Process (Alder Construction) - Construction began in June of
2021 and is complete. While startup occurred in November of 2023, the system will not be
removing a significant amount of phosphorus from the dewatering filtrate until the BNR process
is operational and retaining the phosphorus in the waste activated sludge feed to the digesters.
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Side-Stream Nitrogen Removal Process (Alder Construction) - Construction began in September
of 202I and is expected to be fully completed in 2025 . Startup of the first reactor occurred in
August of 2023 and the second reactor in September 2024. The system is expected to remove 15
to 20 percent of the total facility influent ammonia load recycled to the influent from the biosolids
dewatering process. This will result in a similar reduction in TIN compounds in the facility's
effluent. Final project completion will not occur until electrical gear that has been delayed is
received in2025.
l{AS and Primary Sludge Fermentation Struining and Thickening Facility (Archer Western
Construction) - Construction began in April 2022 and is expected to be completed in the summer
of 2025. The Thickening Building construction has been completed and construction is currently
underway on the mechanical and electrical components within the building.
3. Financial Planning and Bonding-2017 throtgh2025
In July 2017, CVWRF received $35 million in bond proceeds to initiate detailed design and construction
of the BNR and related facility rehabilitation projects. CVWRF then pursued the second round of
publicly issued bonds, totaling $38.5 million which were issued in July of 2019.
TBPEL Rule Variance - Year B Progress Update
Page 3
Concurrently, CVWRF pursued a state revolving fund (SRF) loan and received approval from the Water
Quality Board for $65 million of SRF loan monies. South Salt Lake City also received separate approval
for approximately $l I million in SRF grant and loan monies that were applied to the BNR project.
In the spring of 2027, CVWRF completed a third round of bond funding with a public issue bond in the
amount of $150 million and two private placement bonds in the amounts of $25 million and $23 million,
respectively, for a total of $ I 98 million which was expected to fund the projects through the end of
construction. However, bids for the Side-Stream Nitrogen Removal Project and the WAS and Primary
Sludge Thickening and Straining Project came in approximately $20 million over the combined estimated
budget for the two projects. Additionally, bids for our Biosolids Dewatering Equipment Replacement
Project also came in higher than originally estimated.
In2024, CVWRF completed an evaluation of digester capacity and the results showed a capacity deficit
when the additional waste activated solids generated by the BNR process is included. CVWRF will be
rehabilitating Digester 5, which has not been in use for over 20 years, to address the capacity deficit and
is planning on converting Digester 5 and the two egg shaped digesters to thermophilic operation to
increase their capacity. These projects have added an estimated $ l8 million to project costs.
Inthe2023 TBPEL update CVWRF estimated a $60 million funding shortfall. With the Digester 5
rehabilitation and thermophilic upgrade this funding shortfall is now approximately $80 million. We are
currently going out for a final round of bonding in December of 2024 in the amount of $80 million to
complete the BNR, Biosolids Dewatering Equipment Replacement project and Digester 5
Rehabilitation/Thermophilic Digestion project. We have hired Zions Bank Public Finance as financial
advisors for this transaction.
We believe that the summary of work and capital investments described above satisfactorily demonstrates
our due diligence towards design and construction of treatment works that will meet or exceed the TBPEL
Rule. We welcome any questions or comments you may have with regard to the foregoing. Please let us
know should you require additional information.
Sincerely,
/.a*'f //?'+
Phillip Heck, Ph.D., P.E
General Manager
Brandon Heidelberger, P.E.
Assistant General Manager
cc: Central Valley Water Reclamation Facility Board of Trustees
Mr. Graham Gilbert, Esq., CVWRF Attorney
Mr. Dan Griffin, P.E., Utah DWQ