260395 WHI7E - CITV CLERK 1 ((('''��� ■/ypR■^'
PINK � - FINANCE COl1C1C11 ��x H `y�
'� BLUERY - MAYORTMENT GITY OF SAINT PAUL File NO. S,�P`�
. ' Gouncil esolution
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Presented By a
Referred To Committee: Date
Out of Committee By Date
WHEREAS, The City of St. Paul during 1972 was billed by the Metropolitan
Sewer Board for a volume of flow which included all surface water entering into
the Treatment Plant through St. Paul 's combined system as well as all infiltration
entering sewers owned by the Metropolitan Sewer Board but located within the City
Limits and
WHEREAS, The Metropolitan Sewer Act, Chapter 449, 1969 Session Laws provides
for adjustments to be made to sewage volume for surface water and for other
reasons, and
WHEREAS, The City of St. Paul is being billed for infiltration into sewers
owned by the Metropolitan Sewer Board, although the City's flow contribution is
only a portion of the total flow, and
WHEREAS, The Metropolitan Sewer Board in the past two years has not made
proper adjustment for these flows, therefore, be it hereby
RESOLVED, That the City of St. Paul , acting through its Mayor, appeal the
City's 1972 and previous years Metropolitan Sewer Board Cost Ailocations as
provided in Section 8, Subdivision 2 and Subdivision 8 of the Metropolitan Sewer
Act, and be it - ..
FURTHER RESOLVED, That the Metropolitan Sewer Board adopt as adjustments
to the City's volume the estimate calculated by the City of St. Paul and continue
to use these estimates until more complete data has developed, and be it
FINALLY RESOLVED, That copies of this resolution be sent by the Mayor to
all merr�ers of the Metropolitan Sewer Board.
COUIVCILMEN Requested by Department of:
Yeas Nays
Hunt � Pub 1 i c Works
Konopatzki In Favor
Levine
Meredith J Against BY
Sprafka Daniel J. Dunford
Tedesco
Mme.President Butler �F C 2 9 1972 Form Approve y City Att y
Adopted by Council: Date
Cert' ied sed by Co ary BY
By
App v by r: Date �i � 3 Appr v by fo io to Council
By BY
PUBUgHED JAN 6197
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December 29, 1972
Mr. Milton Honsey
Chairman
Metropolitan Sewer Board
350 Metro Square Building
St. Paul , Minnesota 55101
Dear Mr. Honsey:
This letter constitutes an official appeal on the City �f St. Paul 's
�971 and 1972 Sewer Service Cost Allocations. Qur appeal is based on the
f'callowing two categories� Surface `�Jater and lnfiltration.
6 . StJRFA�E WATER (STORP� RUNOFF, STREAMFLOW, A�dD LriKE OVERFL04JS)
Dur�ng 1972 and also 1y7j , St. Pau1 tras been billed for its total
flow to the Metro Treatment Plant including both sanitary sewage and surface
water. This is not in accordance with the Metropolitan Sewer Act
(Chapter 449, 1969 Session Laws) . According to Section A, Subdivision 2,
municipalities will be bitled in proportion to the total volume estimated to
be discharg e d, but adjusted as follows: The total volume wilt be decreased
by any amount of surface water estimated by the Board to be discharged by a
local government unit from a combined storm and sanitary sewer system. This
has not been done. To date St. Paul has been charged at the full treatment rate
for its surface flow. The volume of storm runoff can be estimated by comparing
dry weather and wet weather days using meter and rain data. The volume of
streamflow and lake overflows can be estimated by using data compiled by the
City and by making additional measurements.
Furthermore, the same section of the Sewer Act provides that those
municipalities which discharge surface water to a Metropolitan Treatment
Plant will be bilted for such surface water based on an equivalent volume of
sanitary sewage flow. This equivalent volume is to be determined by the Board
from available engineerinq data. It is our position that the Sewer Act
requires that the equivalent volume of sanitary sewage be estimated for
surface flow and that an adjustment be made on this basis. Until an estimate
is made by the Sewer Board, St. Paul should not be charged for such surface
water, or alternativety, some interim equivalent should be adopted until
the Board determines that engineering data is available. Although the City
of St. Paul has done some studies on combined and storm water quality, the
Act specifically places the responsibility for determining surface water
equivalent on the Sewer Board.
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•_ Preliminary estimates made by the City during 1_97?_ indicate that storm
runoff contributes an equivalent loading of approximately 27� of the normal
loading at the Treatment Plant based on ratios of storm to dry weather flow
for Bod, Suspended Solids and Total Coliform. Similar calculations for
lakes and streamflow indicate an equivalent loading of just under 25%, Other
studies initiated by the City shor�� that the City's storm water contribution
to the treatment plant is approximately 3.3 MGD, while streams and lakes
generate about 5.5 MGD.
The City, therefore, feels that a reduction, determined by applying an
interim equivalent factor of 25q to 27� to its surface water volume
(8.8 MGD total) , is justified, until a more permanent value can be determined.
II . INFILTRATION
The City of St. Paul also is appealing its 1971 and 1972 Bill based on
the fact that the City has been billed for all infiltration entering into
all Metropolitan Sewers within the City Limits, with the excep�ion of the
Joint Interceptor.
The City feels that all arguments and foctors that went into determining
the need for an infiltration quantity to be applied to the Joint Interceptor
are also applicable to all other Metropolitan Sewe�-s within St. Paul .
Historicaliy, St. Paul has been given a reduction for infiltration entering
the Joint Interceptor within St. Paul , because St. Paul daes not own this
sewer. Therefore, it was considered proper that St. Paul should pay no more
than its share based on volume, for infiltration within the Joint Interceptor.
This argument must also apply td all Metropolitan Interceptors within the
City limits. Section 8, Subdivision 8 of the Metropolitan Sewer Act clearly
provides for this type of an adjustment.
When the Metropolitan Sewer Board purchased the jointly-used interceptors
within the City Limits, they did not reimburse the City based on construction
costs but rather at a gratly depreciated price which was supposedly reflectinn
their age and conditian. Therefore, by taw, the Metropolitan Sewer Board owns
and is responsible for these depreciated sewers and for their operation. The
Sewer Board bought aged sewers at a lo�,rer pricF and, therefore, must accept
the responsibility for the problems connected with aged sewers. This, of
course, includes the higher infiltration rates that are to be expected as
sewers age. The fact that St. Paul uses these Metropolitan Sewers as collectors ,
is no more relevant in the case of these sewers than it is in the case of the
Joint Interceptor. We feel that whether they are used as a collector or not
is immaterial since they are not City sewers; they are owned by the Metropolitan
Sewer Board and used by several municipalities.
Data concerning infiltration rates for these sewers can be estimated
using studies and figures based on local data and engineering references. For
example, some reports have shown that 24 inch pipe may experience an infiltra-
tion rate of 4,000 to 36,000 gallons per mile per day. Other studies have
indicated ranqes of f rom 1240 to 240,000 gallans per mile per day. Another
study showed infiltration rates of up to 1 ,400,000 gal )ons per mile per day.
Computations based on the infi )tration factor used for the Joint Interc�ptor
indicates that its infiltration rate is approximately 170,000 gallons per
mile per day. The Public Works Staff has made ealculat,ions on Metro olit
P an
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Sewers within St. Paul , excluding the Joint Interceptor, which indicate that
the infiltration from these sewers constitutes an additional volume of flow
to the treatment plant of approximately 2,000,0�0 gallons per day. This
figure was estinated by using the same factor per ineh mile per day that was
used on the Joint Intercept�r. lde urge that this value (2 MGD) be adopted
as an interim value until more detailed estimates can be made.
!Je understand that American Pipe Services has been hired by the Board
to nake a study of infiltration into the P•letropolitan Sewer System. lJhen
their study has been completed, the data can be used to modify the interim
estimate. However, we feel it would be unfair to make St. Paul wait until
this study is completed.
tt is the City's cont�ntion that both of these appeals are justified.
The Sewer Act provides for such adjustments and our estimates support these
appeals. tJe urge that these estimates be used until more complete data is
devE�1 oped by the 6oa rd.
Yaurs very trul
awrence D. Cohen
�layor of St. Paul
DJ Ul P.P/gh
cc: Members of t4etropolitan Sewer Soard
a2- � ° `� � 5
January 2, 1973
Metropolitan Sewer Board
350 Metro Square Building �
St. Paul, Minn.
Gentlemen:
Enclosed are copies of a resolution of the St. Paul City
Council, C.F. 260395, wherein the City actin� through the Ma.yor
appeals St. Paul's 1972 and previous year's Metropolitan Sewer
Board cost allocations.
Please distribute copies oP this resolution to all members of
the Metropolitan Sewer Board.
Very truly yours,
City Clerk
ABO:ml
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JanuaxY 2� 1973
A4ayor Lawrence D. Cohen
Deax Sir:
Attached is a copy of a resolution oP the Council, C.F. 260395,
adopted December 29, 1972, pertaining to an Appeal to the
Metropolitan Sewer Board on cost allocations.
Very truly yours,
City Clerk
ABO:ml