The following pages are my responses to some of the information in this report that I feel are wrong. The documents that I have included to support my positions were either used in this report and misrepresented, or available before the reports release and not used. 

 

 

 

Coos County Solid Waste Feasibility Study

 

  1. Incinerator Condition Assessment – page 2 – It is encouraging to read that ACS recognizes the skill of the staff at our site, and the structural soundness of the incinerators.  To address the ONLY major point of concern that ACS had; it should be understood that the plant has been operating this way for more than 15 years.  We have never been able to run more than about 3 weeks without needing to shut down and clean out the fly ash.  Although it would be nice to be able to run longer, and it is agreed that longer runs would decrease maintenance costs, the fact that the equipment is in as good a condition as it is after 20 years of operation for two of the burners, and 15 years for the third, there should be NO question that if we were to open a new trench we would be able to continue to operate as we have for the last 20 years!.

 

  1. Tipping Building Condition Assessment – pages 3&4 – I believe this assessment falls short of identifying everything that would need to be removed in order to accommodate the type of drive-up loading area for a 65’ to 75’ tractor trailer combination depicted in the drawing in Appendix B.  Not mentioned in the bullets on pages 3 & 4 are the plant office, the backup power generator, the water skid (with a raised concrete foundation), 5 foot deep pits under each of the three burners, two coolers, a mixer and their related hardware, and at least a portion of the scrubbing system.  I do not believe there were any official estimates from licensed contractors to establish the accuracy of the costs projected on page 4, and it is my belief that these figures are too low.

 

 

  1. BHDS On-site Ash Landfill – page 4 – This paragraph references a letter from Pickets Engineering indicating that Ash Trench 3 is approximately 85% full, with a life expectancy of 4 to 5 years.  However there is another document generated by the Coos County Surveyor Karlas E. Seidel on February 8, 2010 that should have been made available to URS before the official release of this study (see attached document).  Using the monthly ash production figures that were used in the January 27, 2006 survey (see attached document), done by the same surveyor, the remaining space available in Ash Trench 3 is approximately 8 years. This document is extremely important to both the concern that we don’t have the time required for the permitting process of opening a new trench, and the costs outlined in this study to continue operating as we do now.

 

  1. Table 2: Advantages and Disadvantages of Each Alternative – page 7 – Alternative #1 : “Disadvantages” –

 

·        Bullet 1 - We have not yet saved the money necessary to fund the agreed to Post-Closure Financial Assurance Obligation. By adding 10 to 15 years of operation we will be able to save more for that obligation. I believe this would be an ADVANTAGE!.   

·        Bullet  2 – The cost for on-site ash disposal is incorporated into the operating budget. It only becomes a true liability if we were to cease operating without a sufficient financial reserve to pay for extended monitoring. 

·        Bullet 3 – Incinerator upgrades and monitoring system upgrades and replacements have been incorporated into the operating budget in the past. While significant upgrades could require Capital expenditure, routine maintenance and repair of the incinerators can continue to be performed by employees.  With the information in paragraph 3 funding for a new cell is no longer an immediate need. And finally, there is no evidence in any of the references used to establish closure/post closure costs that those costs will increase with the construction of a new trench. 

·        Bullet 4 – This report used a document generated by Kathleen Robertson titled “BHDS Planning Level Costs” (see attached document).  This document is very specific in its information, and at complete odds with the cost figures in bullet 4.  In #1 it states that the probable cost of final cover construction is $2.5 million +.  In #2 it states that if a side slope liner were added to the existing trenches the final cover cost would probably be $3.6 million.  In summery she states that developing the wedge area would only be about $1.1 million.  The cost to develop a new ash cell in this bullet is GREATLY over stated!.

 

  1. Cost Analysis – pages 8&9 – Alternative #1: Based on the information provided in the above mentioned documents the majority of this section changes or is eliminated completely.  The $3,782,000 cost for the ash cell should be $1,100,000, however, unless this study is suggesting the money come from the general fund, this expense should not be factored into the cost per MSW ton as it would likely be secured through a bond or some other type of tax measure.  Table 3 on page 9 lists ALL alternatives and a breakdown of their related costs, again Total Capital Cost would change significantly, and I feel it should be eliminated entirely as it would not come out of the general fund. Annual Operational Cost would also be greatly reduced or eliminated.  Ash Cell Closure Cost would only be relevant IF we were closing ash trench 3, and if the wedge between ash trenches 1,2 & 3 was used Ash trench 3 would not require any closure and ash trenches 1 & 2 would only require a liner on its sideslope. Final closure could be extended to 2025 or later.  Finally, we have operated on an average annual income of approximately $2,100,000 for the last three years and we charge just $79 per ton.  If we are only averaging 22,500 tons of MSW per year our income should only be approximately $1,777,500 per year.  Does this mean that public refuse was not included in the yearly totals?.

 

 Again, the actual current cost per ton of MSW at the Beaver Hill site is $79, and with this new survey showing that there is approximately 8 years left in ash trench 3, I believe we have time to research funding options and continue incinerating MSW.  One additional source of revenue for funding the new trench and possibly adding to the closure fund would be to do as URS suggested on page 10 of this study and raise the tipping fee.

 

                              

 

 
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