vvEPA
United States
Environmental Protection
Agency
Region 4
345 Courtland Street, NE
Atlanta, GA 30365
EPA 904/6-84 119
July 1984
Environmental
Impact Statement
North Jefferson
County, Kentucky
Wastewater Facilities
Final
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. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION IV
345 COURTLAND STREET
ATLANTA. GEORGIA 3O365
TO: ALL INTERESTED AGENCIES, PUBLIC GROUPS AND CITIZENS
Enclosed for your review and comment is the Final Environmental
Impact Statement (EIS) for proposed wastewater facilities for
North Jefferson County, Kentucky.
This EIS was prepared in compliance with the National
Environmental Policy Act and implementing Agency regulations.
In accordance with these regulations, the Final EIS will be
filed with EPA's Office of Federal Activities. Availability
of the EIS will then be announced in the Federal Register,
beginning a 30-day comment period. (The Federal Register
date is the same as the date of this notice.) EPA will take
no administrative action on this project until the close of
the comment period.
Your review of this document and any comments you may have
are appreciated. Please send all comments to Ronald J.
Mikulak, Project Officer, NEPA Compliance Section at the
above address.
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FINAL
ENVIRONMENTAL IMPACT STATEMENT
FOR
NORTH JEFFERSON COUNTY, KENTUCKY
Prepared By
U.S. Environmental Protection Agency
Region IV
Atlanta, Georgia
This EIS addresses proposed wastewater management facilities for
northern Jefferson County, Kentucky. Four major management alternatives
were evaluated in this EIS. These alternatives ranged from a continued
reliance on existing on-site systems and package treatment plants to a com-
plete regional conveyance and treatment system serving virtually the entire
study area.
The EIS selected alternative is a limited regional sewer system
that will relieve existing septic tanks and package plants in most of the
study area. At the option of local agencies, this system could be expanded
to serve future growth, but such an expansion would not be eligible for
federal funding under existing laws.
Comments or inquiries should be directed to:
Ronald J. Mikulak
Project Officer
NEPA Compliance Section
Environmental Assessment Branch
U.S. Environmental Protection Agency
Region IV
345 Courtland Street, N.E.
Atlanta, GA 30365
(404) 881-3776
Approved by
R. Jetj
Regional Administrator
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U.S. ENVIRONMENTAL PROTECTION AGENCY
REGION IV
ATLANTA, GEORGIA
FINAL
ENVIRONMENTAL IMPACT STATEMENT
FOR
NORTH JEFFERSON COUNTY, KENTUCKY
JUNE 1984
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vii
CONTENTS
Figures ix
Tables ix
Preface xi
1. Executive Summary 1
1.1 Existing Situation 1
1.2 Wastewater Management Alternatives 3
1.2.1 No-Federal-Action Alternative 5
1.2.2 201 Alternative 6
1.2.3 LSI Alternative 6
1.2.4 LS2 Alternative 8
1.3 Recent Changes in the Construction Grants Program 9
1.4 Basis for the Selected Alternative 9
1.5 Description of the Selected Alternative 9
1.6 Environmental Impacts and Mitigative Measures 11
2. Background and Purpose of the EIS 17
2.1 Background and History of the EIS 17
2.2 Purpose of the EIS 18
3. The Selected Alternative 19
3.1 Description of the Selected Alternative 19
3.1.1 Existing Needs 19
3.1.2 Future Needs 27
3.2 Environmental and Socio-Economic Impacts and Mitigation 27
4. Errata and Revisions to the Draft EIS 39
5. Public Comments and EPA Responses 41
5.1 Oral Comments 41
5.2 Written Comments 88
6. List of Preparers 131
References 133
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IX
FIGURES
1. Jefferson County, Kentucky 2
2. Proposed 201 Interceptors 4
3. LS2a Service Area 10
4. Regional Plant and Discharge Location 12
5. Proposed LS2a Interceptors 22
6. Treatment Plant Flow Schematic 25
TABLES
1. Cost Summary 13
2. Treatment Systems for Existing Subareas Under LS2a 20
3. Summary of Criteria Affected by the Selected Alternative 28
4. Summary of Criteria Affected Only by Certain Components of
the Selected Alternative 30
5. Index to the Public Hearing Comments 42
6. Summary of General Topics Covered by Oral Comments 44
7. Index to Written Comments 89
8. Summary of General Topics Covered by Written Comments 94
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xi
PREFACE
In accordance with federal policy, the metric system is used in this
report for expressing units of measure; equivalent measurements in the English
system are given in parentheses. Exceptions to this rule occur when measure-
ments have been specified in English units in legal or regulatory documents and
when standard construction material sizes are specified in English units. Such
measurements are introduced here as English units with the metric units given
parenthetically, but thereafter the metric units are used as the primary means
of expression. For reference, abbreviations and equivalencies of the units
used in this report are listed below.
1 inch (in.) = 2.54 centimeter (cm) 1 cm = 0.394 in.
1 mile (mi) =1.61 kilometer (km) 1 km = 0.621 mi
1 acre (ac) = 0.405 hectare (ha) 1 ha = 2.47 ac
1 gallon per day (gal/d) = 0.00379
cubic meter per day (m /d) i m3/d = 264 aal/d
1 million_gallons per day (mgd) = i m3/d = 0.000264
3,790 m /d mgd
1 mgd = 0.0438 cubic meter per _
second (m /s) 1 m /s = 22.8 mgd
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EXECUTIVE SUMMARY OF THE ENVIRONMENTAL IMPACT STATEMENT
FOR NORTH JEFFERSON COUNTY, KENTUCKY
Draft ( )
Final (X)
Environmental Protection Agency
Region IV
345 Courtland Street
Atlanta, Georgia 30365
Type of Action: Administrative Action (X)
Legislative Action ( )
1. EXECUTIVE SUMMARY
1.1 Existing Situation
The Louisville and Jefferson County Planning Commission has pro-
jected that the North County area (Figure 1) will be the major growth area of
Jefferson County over the next twenty years. The area, however, is experienc-
ing public health and water pollution problems caused by failing septic tank
systems and malfunctioning wastewater treatment plants.
On-site systems in the EIS study area number approximately 7,200 and
consist usually of a septic tank and a lateral-trench disposal field. On the
basis of infrared aerial photography, the areawide failure rate of these on-
site systems is estimated to be at least 15 percent. The failures are be-
lieved to be caused by unsuitable soils (depth to bedrock too shallow; perco-
lation rate too slow; water table too high), hydraulic overloading (effluent
discharge rate greater than percolation rate), or lack of maintenance (solids
overflow causing clogged soils).
Use of septic tanks in major new subdivisions was banned by the
Louisville and Jefferson County Department of Public Health in 1973, and their
use outside of such areas was discouraged unless no other treatment method was
feasible. In 1978 the Board of Health adopted new regulations restricting
septic tank use to lots of 5 ac (2 ha) or more for lots created after June 1,
1978.
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g|A
LEGEND
STUDY AREA
EXISTING MUNICIPAL WWTP
I. HITE CREEK
2 JEFFERSONTOWN
3. OKOLONA
4. MORRIS FORMAN
WWTP PROPOSED BY 201 PLAN
A. NORTH COUNTY
B. WEST COUNTY
\
O
2)
m
JEFFERSON COUNTY
KENTUCKY
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Small-area wastewater treatment plants in the study area serve
schools, institutions, parks, a shopping center, and residential areas. The
49 plants have an aggregate design flow of 0.21 m /s (4.9 mgd); all but five
of the plants are privately owned. Most of the plants fail to meet the re-
quirements of existing discharge permits, either because they are old and
starting to deteriorate, because they have not been upgraded to provide the
levels of treatment required by new permits, or because they are not operated
properly by the owners. All of the plants were built to serve as temporary
treatment units until regional sewers became available. As a matter of policy
Jefferson County and the Health Department regard all package treatment plants
as interim solutions. The Jefferson County Judge/Executive, the Chairman of
the Board of Health, and the Health Department have all confirmed this policy
in correspondence with EPA.
The southern portion of the study area is sewered and served by the
Morris Forman Wastewater Treatment Plant, a large regional facility (4.6 m /s;
105 mgd) owned by the Louisville and Jefferson County Metropolitan Sewer
District (MSB) and located southwest of and adjacent to Louisville. The
northeastern corner of the study area is served by MSD's Hite Creek Advanced
Wastewater Treatment Plant (0.19 m /s; 4.4 mgd).
1.2 Wastewater Management Alternatives
The objective of this EIS is to determine the most cost-effective
program for eliminating the public health problems caused by failing septic
tanks and for resolving the water quality problems caused by the small-area
treatment plants. Four areawide wastewater management systems were developed
as alternatives for eliminating existing problems and meeting future needs.
The four alternatives vary in the relative mix of three wastewater treatment
options: on-site systems, upgraded small-area treatment plants, and a North
County regional sewerage system. On-site systems were considered feasible in
only a few areas where the soil will tolerate properly installed and main-
tained disposal fields and where lot sizes are large enough—0.4 ha (1 ac)
and greater—to accommodate leachate fields of the size required by Kentucky
regulations. In such areas, failing systems could be rehabilitated to meet
the current, more-stringent design requirements. Small-area treatment plants
were considered feasible if they were designed to meet the discharge require-
ments specified by Kentucky's Natural Resources and Environmental Protection
Cabinet. For most existing plants, this would require upgrading the facility
and providing better operation. The regional sewerage system would consist
of a new wastewater treatment plant located on the Ohio River at the mouth of
Beargrass Creek and an interceptor system serving one or more of the main
creek basins in North County. The most extensive regional system would be
similar to the system proposed by the 1974 201 Plan (Figure 2).
The cost-effectiveness evaluation of the four alternatives considered
not only the monetary cost of the proposed management programs, but also the
environmental and socio-economic impacts, the reliability and technical feasi-
bility of the various treatment options, and the public acceptability of the
programs. The data given in the following summaries of the four alternatives
are based on prices and information available at the time the evaluation was
conducted (1980-1981). Areas served by the Morris Forman or Hite Creek treat-
ment plants and four small treatment plants in the Floyds Fork basin were not
included in these evaluations, because their treatment systems would be the
same for all four alternatives.
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G>
C
LEGEND
EXISTING INTERCEPTORS
PROPOSED INTERCEPTORS
WASTEWATER TREATMENT
PLANT SITE
PROPOSED
201 INTERCEPTORS
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1.2.1 No-Federal-Action Alternative
The first wastewater management alternative, the no-federal-action
alternative (often referred to simply as the no-action alternative), assumed
that no federal funds would be available for wastewater management and that
existing management methods would be continued. It also assumed that public
health problems would be minimized by relieving areas with failing septic
tanks, either by rehabilitating the failing systems or by abandoning them and
connecting the houses to new or existing small-area treatment plants. Future
development, in light of the Health Department restriction on septic tanks to
lots of 2 ha (5 ac) or more, would use package plants for wastewater treatment.
The estimated costs for this alternative are:
Capital Cost $141,000,000
Average Annual Operating Cost $ 4,100,000
Present Worth $113,000,000
Average Annual Household Cost $ 600
Environmental Impacts
The number of discharges to area streams will increase from the
current 49 to an estimated 70-80.
Socio-Economic Impacts
Short-term construction activities will affect most existing neigh-
borhoods. Conflicts may arise between local government and private interests
over who is to upgrade existing service or provide future service. All con-
struction will be funded by local government or private interests. Local en-
forcement activities will have to increase to meet the demands of 70-80 treat-
ment plants. Public health and nuisance risks are greatest for this alterna-
tive because of the higher probability of failure or improper operation for
such a large number of small-area treatment plants.
Technical Feasibility
This alternative has the lowest technical reliability because of the
large number of privately owned small-area plants. Sma.1.! -area plants are also
less flexible in meeting short-term variations because of less frequent and
less competent supervision.
Public Acceptability
This alternative probably has the least public acceptance because of
the large number of discharges to the area's streams, which are easily acces-
sible, and because of the presence of treatment plants in almost every commu-
nity. Local agencies and government also consider this alternative the least
acceptable.
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1.2.2. 201 Alternative
The second management alternative involved sewering virtually the
entire North County area and treating the wastewater at a new regional plant
located on the Ohio River at the mouth of Beargrass Creek. Such a regional
system was proposed in 1974 by the Water Quality Management Plan for Jefferson
County, Kentucky, and Clark and Floyd Counties, Indiana (the 201 Plan). All
septic tanks and package treatment plants would be abandoned and all houses
would be connected to the regional system, which would be operated by MSD.
Future development would also be connected to the system.
The estimated costs for this alternative are:
Capital Cost $163,000,000
Average Annual Operating Cost $ 1,800,000
Present Worth $ 93,000,000
Average Annual Household Cost $ 370
Environmental Impacts
Discharges to the area's small streams will be eliminated. A new
discharge directly to the Ohio River will occur, but at 0.1% of the river's
low flow. Construction impacts will occur along 95 km (59 mi) of interceptor
routes.
Socio-Ecpnomic Impacts
Construction activities will affect most existing unsewered areas
and recreational areas along stream valleys. Construction funding will be
split between EPA and local government. Public health risks will be virtually
eliminated as septic tanks and small treatment plants are abandoned.
Technical Feasibility
This alternative has greater technical reliability than the others,
because a large regional facility is usually operated more efficiently than
small-area plants. Short-term variations in operations and long-term process
changes can be made more easily because of close attention from a full-time,
professional staff. When problems occur, however, they can be of a larger
and more significant nature.
Public Acceptability
This alternative is probably the most acceptable to the local public,
because it relieves the concerns over failing septic tanks and polluted
streams. It has the strong endorsement of local agencies and government.
1.2.3. LSI Alternative
The third management alternative involves a limited regional sewer
system and some continued reliance on package treatment plants. The LSI al-
ternative relieves areas with significant numbers of failing septic tanks by
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connecting all developments in the Goose Creek, Little Goose Creek, and Muddy
Fork drainage basins to a regional sewerage system and by relieving the re-
maining few problem areas with package treatment plants. Under subalternative
LSla, future population would be provided with wastewater management facili-
ties similar to those described under the no-action alternative: Future sub-
divisions would be provided with collector sewers and small-area treatment
plants with surface water or land discharges; regional interceptor sewers
would be designed with capacity only for existing flows. Subalternative LSlc
would provide wastewater management for future populations adjacent to a re-
gional interceptor by providing adequate capacity for future flows in the re-
gional system. Future growth not adjacent to an interceptor would be served
by small-area treatment plants.
The estimated costs for the LSla and LSlc subalternatives are:
Capital Cost a) $157,000,000 c) $152,000,000
Average Annual Operating Cost a) $ 2,800,000 c) $ 2,700,000
Present Worth a) $100,000,000 c) $ 98,000,000
Average Annual Household Cost a) $ 450 c) $ 430
Environmental Impacts
Existing small plant discharges will continue in Harrods Creek only;
under LSla, future small plants will discharge into Goose, Little Goose, and
Harrods Creeks. A new discharge will occur directly into the Ohio River, but
at less than 0.1% of the river's low flow. Construction impacts will occur
along 52 km (32 mi) of interceptor routes.
Socio-Economic Impacts
Construction activities will affect existing unsewered areas and
recreational areas along all stream valleys except Harrods Creek. Construc-
tion funding will be split between EPA and local government. Local enforce-
ment activities for small plants will be about half of existing needs. Public
health risks from package plants and septic tanks will be greatly reduced or
eliminated in all but the Harrods Creek basin.
Technical Feasibility
This alternative is intermediate in technical feasibility between
no-federal-action and 201. The regional system offers reliability and flex-
ibility, but there are still many small-area plants, which are less reliable
and flexible.
Public Acceptability
This alternative is probably intermediate in public acceptance be-
tween no-federal-action and 201. The regional system relieves much of the
concern with failing septic tanks and polluted streams, but there are still
many small-plant discharges to the area's streams.
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1.2.4 LS2 Alternative
The fourth management alternative also involves a limited regional
sewer system and some continued reliance on package treatment plants. The
LS2 alternative relieves areas with existing package treatment plants and
areas with a significant number of failing septic tanks by connecting essen-
tially all existing development to the regional system. Under Subalternative
LS2a, future subdivisions would be provided with collector sewers and small-
area treatment plants; regional interceptors would be designed with capacity
only for existing flows. Subalternative LS2c would provide wastewater manage-
ment for future populations adjacent to> a regional interceptor by providing
adequate capacity for future flows in the regional system. Other future sub-
divisions would be provided with collector sewers and small-area treatment
plants.
The estimated costs for the LS2a and LS2c subalternatives are:
Capital Cost a) $160,000,000 c) $157,000,000
Average Annual Operating Cost a) $ 2,500,000 c) $ 2,100,000
Present Worth a) $ 98,000,000 c) $ 94,000,000
Average Annual Household Cost a) $ 450 c) $ 390
Environmental Impacts
Almost all existing small-plant discharges will be eliminated, but
future plants under LS2a will discharge into Goose, Little Goose, and Harrods
Creeks. A new discharge will occur directly into the Ohio River, but at less
than 0.1% of the river's low flow. Construction impacts will occur along
64 km (40 mi) of interceptor routes for LS2a and 71 km (44 mi) for LS2c.
Socio-Economic Impacts
Construction activities will affect existing unsewered areas and
recreational areas along stream valleys. Construction funding will be split
between EPA and local government. Local enforcement activities for small
plants will decrease to 10-40% of existing needs. Public health risks from
package plants and septic tanks will be greatly reduced or eliminated.
Technical Feasibility
This alternative is intermediate in technical feasibility between
LSI and 201. The regional system offers reliability and flexibility, but
there are still some small-area plants, which are less reliable and flexible.
Public Acceptability
This alternative is probably intermediate in public acceptance be-
tween LSI and 201. The regional system relieves much of the concern with
failing septic tanks and polluted streams, but there are still some small-
plant discharges to the area's streams.
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1.3 Recent Changes in the Construction Grants Program
Since the EIS process began, several significant changes have oc-
curred in EPA's construction grants program. In December, 1981, Congress
enacted and the President signed amendments to the Clean Water Act. Among
other things, these amendments provided for (1) a lower authorization for con-
struction grants than had occurred in previous years; (2) a reduction in the
federal share of construction costs from 75 percent to 55 percent for all
projects approved after September 30, 1984; (3) a prohibition on the use of
federal funds for conveyance or treatment capacity beyond that necessary to
serve the population existing at the time of the grant award, or 1990, which-
ever comes first; and (4) elimination of grants for conventional collector
systems after September 30, 1984, except that a governor may elect to use up
to 20 percent of a state's allocation for collectors or other previously eli-
gible projects.
Based on Kentucky's priority list for funding construction grants
projects, grant awards for North County facilities are unlikely to occur before
1987. For this EIS, therefore, it was assumed that (1) federal participation
will be a maximum of 55 percent of eligible costs; (2) conveyance and treatment
capacity will be eligible only to serve the needs existing at the time of grant
award, or 1990 at the latest; and (3) collector systems will not be eligible.
1.4 Basis for the Selected Alternative
The new construction grants regulations effectively eliminate the
201, LS2c, and LSlc alternatives from consideration as the federally funded
alternative, because they all include capacity for future growth through 2000.
Of the three remaining alternatives—LS2a, LSla, and no action—LS2a is the
selected alternative because it relieves the public health and water quality
problems in North County to the greatest extent. The selection of LS2a does
not preclude local authorities from providing a larger regional system such as
LS2c or 201. However, facilities or capacity for future growth or for exist-
ing areas not included in the LS2a regional system will not be eligible for
federal funding and must be provided entirely at local expense. Moreover, pro-
vision of federal funds for any future activities, including LS2a components,
will be subject to the laws, regulations, and funding levels applicable at the
time grant award is made.
Under current regulations, grant assistance will be provided for
facilities to serve the needs existing at the time of grant award, or the needs
existing in 1990 if the award occurs after 1990. Since it is impossible to
predict when grant awards will be made for North County facilities, "existing
needs" were considered to be the populations projected for 1990. These pro-
jections were made to provide an estimate of the maximum extent of grant
assistance and should not be interpreted as commitments of federal funds. The
actual funding level will be determined at the time of the grant award and
will be based on regulations applicable at that time.
1.5 Description of the Selected Alternative
The proposed interceptor would serve most of the existing population
in North County (Figure 3). Areas that would not be served include:
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LEGEND
NORTH COUNTY REGIONAL
SYSTEM
MORRIS FOREMAN AND
HITE CREEK SERVICE AREAS
ON-SITE SYSTEMS
| | SMALL-AREA TREATMENT
SYSTEMS
O
C
a)
m
LS2A SERVICE AREA
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11
1. Anchorage and Lake Louisvilla, which would remain on
septic tanks;
2. The northeastern corner of the study area, most of
which is presently served by the Kite Creek Wastewater
Treatment Plant;
3. Four areas in the southeastern corner of the study
area (Berrytown, Cross Creek, Running Creek, and
Starview Estates), which have their own small
treatment plants that lie in a different drainage
basin from most of North County; and
4. Two institutions (Bellwood Presbyterian Home and the
St. Thomas Orphanage) that are too far from the
proposed service area to be sewered cost-effectively.
The estimated 1990 service population for the LS2a system is 54,600, and the
total estimated wastewater flow is 25,000 m /d (6.5 mgd). The proposed North
County treatment plant would provide secondary treatment and discharge to the
Ohio River between Towhead Island and the John F. Kennedy Memorial Bridge
(Figure 4).
Wastewater management planning for future growth in North County will
be the responsibility of local agencies. The regional system could be enlarged
to accommodate that growth, but the enlargement would have to be funded
entirely at the local level. Updated (1983) costs were developed for the
LS2a, LS2c, and 201 regional systems to provide local agencies with informa-
tion on the relative costs of their options. Capital, operating, and annual
household costs are summarized in Table 1. The annual household cost includes
debt service on the capital cost of the treatment plant and interceptors,
ammortized assessment payments for collector sewers, and operating costs for
the entire system. The average annual household cost is not excessive accord-
ing to EPA guidelines, i.e., it is less than $680, which is 1.75 percent of
the area's median annual household income.
1.6 Environmental Impacts and Mitigative Measures
The various components of the LS2a alternative (interceptors, col-
lectors, treatment plant, future on-site systems, and future small-area
treatment plants) were compared against 41 environmental and socio-economic
criteria to determine the impacts of the alternative. Many of the criteria
were based on local guidelines for future growth and were not affected by the
proposed regional system, because the system only provides capacity for exist-
ing population and leaves future planning up to local agencies.
The most significant effects from the regional system would be ex-
pected from construction of the interceptors, which would be approximately
64 km (40 mi) in length. Mitigative measures to help preserve some of the
significant historic and natural features of the area are:
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NEW ALBANY
c
m
4^
••••••••••
••••*••••••
PROPOSED OUTFALL SEWER
5 MILES ABOVE NEW ALBANY INTAKE
WASTEWATER TREATMENT PLANT
WATER SUPPLY INTAKE
PROPOSED TREATMENT PLANT SITE
FALLS OF THE OHIO NATIONAL
WILDLIFE CONSERVATION AREA
\
REGIONAL PLANT
AND DISCHARGE LOCATION
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13
TABLE 1. COST SUMMARY
(1983 Dollars)
LS2a LS2c 201
Capital Costs
Treatment Plant $ 19,000,000 $ 21,000,000 $ 25,000,000
Interceptors 31,000,000 34,000,000 43,000,000
Collectors 63,000,000 76,000,000 99.000.000
Total $113,000,000 $131,000,000 $167,000,000
Federal Grant (at
55% of Allowable Costs) $ 26,000,000 $ 26,000,000 $ 26,000,000
Local Share 87,000,000 105,000,000 141,000,000
Average Annual Operating Costs
Treatment Plant $ 640,000 $ 660,000 $ 710,000
Interceptors & Collectors 190,000 210,000 260,000
Equipment Replacement Fund 220,000 250,000 270,000
Total $ 1,050,000 $ 1,120,000 $ 1,240,000
Average Annual Household Costs
Debt Payment
0% Federal Funding $ 220 $ 230 $ 250
55% Federal Funding 100 120 150
Assessment 210 260 370
Operating Costs 50 50 50
Total
0% Federal Funding $ 480 $ 540 $ 670
55% Federal Funding $ 360 $ 430 $ 570
Note: These costs have been updated to 1983 dollars and are, therefore, dif-
ferent from the costs of the alternatives presented in Sections 1.2.2
and 1.2.4, which are given in 1981 dollars.
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14
Archaeological Sites
1. Require certification from State Archaeologist and State
Historic Preservation Officer that interceptor construc-
tion will not affect known sites.
2. Require archaeological survey of certain interceptor seg-
ments.
3. Require notification of findings to EPA, State Historic
Preservation Officer, and State Archaeologist.
Historic Sites
1. Require certification from State Historic Preservation
Officer that interceptor construction will not affect
known sites.
2. Recommend consultation with State Historic Preservation
Officer about construction of certain collector systems in
neighborhoods with known sites.
Floodplains
Recommend minimizing amount of floodplain lost to treatment
plant and pumping station sites.
Wetlands
Require permit from U.S. Army Corps of Engineers for construc-
tion in Muddy Forks wetland, or statement from Corps that per-
mit is not necessary. Require consultation with the U.S. Fish
and Wildlife Service regarding interceptor construction.
Navigable Waters
Require permits from U.S. Army Corps of Engineers for stream
crossings or the discharge of dredge and fill material to
streams within the Corps jurisdiction.
Environmentally Significant Agricultural Lands
Recommend that interceptor corridor in Ohio River floodplain
be returned to pre-construction condition so that productive
use may continue.
Rare and Endangered Species
Require consultation with Kentucky Nature Preserves Commis-
sion before constructing certain interceptor segments that
pass through areas with sightings of plants or animals on
state list of rare and endangered species.
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15
Natural Areas
1. Require consultation with U.S. Fish and Wildlife Service
regarding interceptor construction in the Caperton swamp
forest and bottomland hardwood forests on the floodplain
terraces of the Ohio River.
2. Require consultation with Kentucky Nature Preserves Com-
mission about interceptor construction in areas of Muddy
Forks wetlands and lower Goose Creek valley.
3' Recommend specific mitigative measures for certain sig-
nificant natural features in stream valleys.
Parks
Require consultation with agencies operating certain parks
through which the interceptor will run.
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17
2. BACKGROUND AND PURPOSE OF THE EIS
2.1 Background and History of the EIS
In recognition of the limitations placed on orderly development
without comprehensive wastewater management planning, local agencies have
conducted two planning studies: the 1964 Master Plan and 1974 Water Quality
Management Plan (the 201 Plan).
The 1964 Master Plan proposed eliminating on-site disposal systems
and small-area wastewater treatment plants in all areas developed to urban or
suburban population densities or developed for industrial use. Two major
treatment plants in addition to the existing Morris Forman (then named Fort
Southworth) plant were proposed. One was to serve the North County area, with
an estimated population in 2010 of 186,000 and no industry; the other was to
serve the "West County" area, the Pond Creek watershed, the South Fork of
Beargrass Creek outside the city limits of Louisville, and certain small areas
within the city. Several other small treatment plants were also proposed, in-
cluding one on Hite Creek in the North County area and at least three on
Floyds Fork.
In 1973 the Kentuckiana Regional Planning and Development Agency
initiated the preparation of a facility plan under Section 201 of the 1972
Federal Water Pollution Control Act (Public Law 92-500). The 201 Plan gener-
ally recommended implementation of the 1964 Master Plan: the three-plant
regional system with two interim facilities—Hite Creek and Jeffersontown—
that would be phased out by the end of the planning period.
In May 1975, following review of the 201 Plan by the Kentucky
Department for Natural Resources and Environmental Protection and EPA, it was
determined that the Kentucky portion of the Plan was substantially complete.
An Environmental Impact Appraisal was prepared by EPA documenting the decision
that an EIS was not required. This determination allowed EPA Region IV to
commit federal construction grant funds to several design and construction
projects in Jefferson County.
Following the 1975 approval of the 201 Plan by EPA, MSD entered a
phase of design and construction activities in the West County portion of
Jefferson County. In March 1977, the Southwest Jefferson County Homeowners
Association requested an EIS on the 201 Plan. EPA reviewed the concerns ex-
pressed by the citizens' group and determined that sufficient cause existed
to prepare an EIS on the Mill Creek portion of the West County area. A Notice
of Intent to prepare an EIS was issued by EPA in September 1977. A public
scoping meeting was held in February 1978, to allow citizens to present views
and give input to the EIS process. During this scoping process, and in subse-
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18
quent reviews of the adequacy of wastewater management planning carried out
for the 201 Plan, EPA determined that an EIS would also be necessary for the
North County portion of Jefferson County. A Notice of Intent was issued on
June 20, 1979, and a public scoping meeting was held at the Westport Road High
School on July 25, 1979. The EIS planning period was defined as 1980-2000.
2.2 Purpose of the EIS
Failing septic tanks and improperly operated treatment plants have
created public health and water quality problems in North County. The purpose
of this EIS is to determine the most cost-effective, environmentally sound
approach to alleviating those problems. The complete regional sewer proposed
by the 201 Plan will be considered as one alternative solution. Other alter-
natives will include less extensive regional systems and no regional system.
The EIS study has been documented in a series of four reports, in-
cluding (1) a review of wastewater management planning in the area and an in-
ventory of the present natural and cultural environment (U.S. EPA 1980b);
(2) the development of alternatives for wastewater management (U.S. EPA 1981a);
(3) the evaluation of the costs, benefits, and other impacts of the alterna-
tives (U.S. EPA 1981b); and (4) a description of the preferred alternative
(U.S. EPA 1983b). These reports were published as draft documents and dis-
tributed to the EIS Review Committee and two local libraries (Eline Branch and
Northeast Branch). The Draft EIS incorporating these four reports and identi-
fying the preferred alternative was publiched in December 1983.
A public hearing was held on February 7, 1984, at the Ballard High
School cafetorium, and oral comments were received on the Draft EIS. Written
comments were to be submitted by February 29, 1984.
The purposes of this document are to briefly summarize the EIS (Ex-
ecutive Summary), re-state EPA's selected action (Chapter 3), provide correc-
tions and revisions to the Draft EIS (Chapter 4), and respond to the comments
on the Draft EIS (Chapter 5).
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19
3. THE SELECTED ALTERNATIVE
3.1 Description of the Selected Alternative
3.1.1 Existing Needs
The 1981 amendments to the Clean Water Act do not allow federal fund-
ing of treatment system capacity for future growth. Funding of future projects,
therefore, will be based on the needs existing at the time the grant is awarded.
If the grant occurs after 1990, the award will be based on the needs existing
in 1990. In updating the description of the LS2a regional system, "existing
needs" were based on the populations projected for 1990. In essence, this rep-
resents the largest federally funded system possible under existing laws.
Since the LS2a regional system considered in the alternatives evaluation was
based on 1980 populations, the updated LS2a system is a larger system than that
evaluated previously. The flows and capacities used in this chapter are for
current planning purposes only—to provide an estimate of what proportion of
system cost may be eligible for grant funding. Actual future grants, of
course, will depend on actual needs at the time of grant award and on the laws
and regulations applicable at that time.
The extent of the proposed LS2a service area is shown in Figure 3.
Table 2 lists the treatment system proposed for each existing subarea under
the selected alternative. All but seven of the existing treatment plants
would be eliminated by the LS2a system. Extending the regional interceptors
to those seven plants would not be cost-effective. The North County area has
32 unsewered communities. Only two of these—Anchorage and Lake Louisvilla—
would not be sewered and connected to the regional system.
Regional Conveyance System
The selected alternative proposes a regional sewer system to serve
all existing (1990) development in the Muddy Fork basin, the Woodside Creek
basin, most of the Goose Creek basin, the Little Goose Creek basin, and the
Harrods Creek basin (Figure 5). The proposed interceptors total 64 km (40 mi)
in length, of which 2 km (1.3 mi) of the Muddy Fork interceptor are already in
place. Interceptor pipe sizes range from 8 in. (20 cm) to 48 in. (122 cm) in
diameter. A 1.2-km (0.7-mi) long, 20-in. (51-cm) diameter force main and a
0.22-m /s (5-mgd) pumping station are required south of Goose Creek to prevent
the trunk interceptor along the Ohio River from becoming too deep.
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20
TABLE 2. TREATMENT SYSTEMS FOR EXISTING SUBAREAS UNDER LS2A
Subarea
(1) Bancroft
(2) Barbour Manor
(3) Beha Cleaners
(4) Bellwood Presbyterian
Home
(5) Berrytown
(6) Brownsboro Meadows
(7) Central State Hospital
(8) Cross Creek
(9) Douglass Hills
(10) Dove Creek
(11) Falls Creek
(12) Foxboro
(13) Glenview Acres
(14) Glenview Bluff
(15) Glenview Hills
(16) Glenview Woods
(17) Green Spring
(18) Kite Creek
(19) Holiday Inn
(20) Holiday Manor
(21) Hounz Lane
(22) Hunting Creek North
(23) Hunting Creek South
(24) Ken-Carla
(25) Kentucky Childrens Home
(26) Louisville Country Club
(27) Muddy Fork
(28) Murray Hills
(29) New Market
(30) Norton Elementary School
(31) Plantation
(32) Plantation Hills
(33) Rolling Hills
(34) Running Creek
(35) St. Thomas Orphanage
(36) Shadow Wood
(37) Spring Valley Estates
(38) Springdale
(39) Standard Country Club
(40) Standard Oil Co.
(41) Starview Estates
(42) Thornhill
(43) Timberlake
(44) Walden School
(45) West Creek Apartments
(46) Westport High School
(47) Westport Services Co.
Treatment System
Connect to regional system
Connect to regional system
Connect to Morris Forman system
Upgrade or replace 20-m /d (0.006-mgd)
WWTP
Upgrade 240-m /d (0.064-mgd) WWTP
Connect to regional system
Connect to regional system
Upgrade 650-m /d (0.17-mgd) WWTP
Connect to Morris Forman system
Connect to regional system
Connect to regional system
Connect to Morris Forman system
Connect to regional system
Connect to regional system
Connect to regional system
Connect to regional system
Connect to regional system
Continue operation; no upgrading
necessary; may be expanded by MSD
Connect to regional system
Connect to regional system
Connect to regional system
Connect to regional system
Connect to regional system
Connect to regional system
Connect to regional system
Connect to regional system
Connect to regional system
Connect to regional system
Connect to regional system
Connect to regional system
Connect to regional system
Connect to regional system
Connect to regional system
Upgrade 110-m /d (0.028-mgd) WWTP
Replace 11-m /d (0.003-mgd) WWTP
Connect to regional system
Connect to regional system
Connect to regional system
Connect to regional system
Connect to regional system
Upgrade 380-m /d (0.10-mgd) WWTP
Connect to regional system
Connect to regional system
Connect to regional system
Connect to regional system
Connect to regional system
Connect to regional system
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21
TABLE 2. (Cont.)
Subarea
(48) Winding Falls
(49) Woodstone
(50) Anchorage
(51) Barbourmeade,
Brownsboro Farm
(52) Beachland, Mayfair Beach
(53) Blairwood Road
(54) Briarwood
(55) Brittany Woods
(56) Brownsboro Vista
(57) Cherokee Unit
(58) Colonial Terrace
(59) Creekside
(60) Crossgate
(61) Eastview
(62) Fair Meadows
(63) Glen Hill, Regal Hills
Glenwood Acres
(64) Glenview Estates
(65) Limewood Manor, Glenview
Manor, Glenwood
(66) Goose Creek
(67) Hills and Dales
(68) Indian Hills
(69) Juniper Beach
(70) Keeneland
(71) Kingswood
(72) Lake Louisvilla
(73) Lyndon
(74) Manor Creek
(75) Moorland, Whipps
Millgate
(76) Parkside
(77) Robinwood
(78) Riviera
(79) Riverwood
(80) Walbrook
(81) Warwick Villa
(82) Whipps Mill
(83) Wilder Estates
(84) Windy Hills
(85) Netherton Place
Treatment System
Connect to regional system
Connect to regional system
Rehabilitate on-site systems
Sewer; connect to regional system
Sewer; connect to regional system
Sewer; connect to Morris Forman system
Sewer; connect to regional system
Sewer; connect to regional system
Sewer; connect to regional system
Sewer; connect to regional system
Sewer; connect to regional system
Sewer; connect to regional system
Sewer; connect to Morris Forman system
Sewer; connect to Morris Forman system
Sewer; connect to Morris Forman system
(a)
Sewer and connect to regional system;
or rehabilitate on-site systems
Sewer and connect to regional system; or
rehabilitate on-site systems
Sewer; connect to regional system
Seweri connect to regional system
Sewer, ^; connect to regional system
Sewer and connect to regional system;
or rehabilitate on-site systems
Sewer; connect to regional system
Seweri connect to regional system
Sewer ; connect to regional system
Continue use of on-site systems
Already connected to Morris Forman
Sewer; connect to regional system
Sewer; connect to regional system
Sewer; connect to Morris Forman system
Sewer; connect to regional system
Sewer; connect to regional system
Sewer; connect to regional system
Sewer; connect to regional system
Already connected to Morris Forman
Sewer; connect to regional system
Already connected to regional system
Sewer; connect to regional system
Connect to regional system
(a)
Small-diameter sewers
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23
la addition to the regional interceptors, collection systems would
have to be installed in the existing unsewered areas that will connect to the
regional system. These collectors will generally be traditional 8- and 10-in.
(20- and 25-cm) gravity sewers; but small-diameter sewers (6-in.[15-cm]) may be
less costly in several subareas, as indicated in Table 2. An estimated 123 km
(77 mi) of collectors already exist in sewered areas, and a projected 103 km
(64 mi) of collectors would have to be placed in unsewered areas.
The estimated cost, in 1983 dollars, of the regional conveyance sys-
tem is $94 million, of which $31 million is for the interceptor system and $63
million is for the collector system.
Regional Treatment Plant
Discharge Limitations
3
The selected alternative includes the construction of a 0.28-m Is
(6.5-mgd) North County Wastewater Treatment Plant that would discharge into
the Ohio River. The discharge permit for this discharge would be written by
the Kentucky Natural Resources and Environmental Protection Cabinet and re-
viewed by the Ohio River Valley Water Sanitation Commission.
At this time, the consensus of the regulatory agencies is that the
effluent limitations for a discharge into the Ohio River from a North County
plant will be based on secondary treatment. EPA will only fund facilities for
treatment beyond secondary if a water quality model shows that advanced
treatment would be needed to meet water quality standards. Effluent
limitations for secondary treatment are presently defined in EPA regulations
as:
Biochemical oxygen Maximum effluent concentration
demand, 5-day (BOD) of 30 mg/L as a monthly mean
and a minimum reduction of 85%
in the influent concentration
Suspended solids Same as for BOD
pH 6.0 to 9.0
Fecal coliform Maximum effluent density of 200
bacteria organisms per 100 mL as a monthly
geometric mean and 400 organisms
per 100 mL as a weekly geometric
mean
Prior to design of the North County plant, the proposed discharge will have to
be re-evaluated on the basis of the regulations applicable at that time to see
what the effluent limitations will be.
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24
Treatment Process
Preliminary analyses in the alternatives evaluation stage showed
conventional activated sludge to be the most cost-effective liquid treatment
process and aerobic digestion to be the most cost-effective sludge treatment
process for North County. MSD has a study underway to determine an areawide
solution for sludge management, including all of its treatment plants. The
results of that study may affect the selection of a sludge treatment process
for North County. For estimating costs at this point the sludge was assumed
to be digested and dewatered at North County and then trucked to the Morris
Forman treatment plant for disposal. Before final design of a North County
plant, liquid and sludge treatment alternatives should be re-evaluated to de-
termine the most cost-effective process at that time. The unit processes
used for costing the proposed North County Wastewater Treatment Plant were:
preliminary treatment, influent pumping, circular primary clarifiers, conven-
tional activated sludge, circular secondary clarifiers, chlorination, effluent
pumping, sludge thickening, aerobic sludge digestion, and belt press dewater-
ing (Figure 6). The estimated cost, in 1983 dollars, for the regional treat-
ment plant is $19 million.
Plant Site and Discharge Location
The proposed treatment plant site (see Figure 4) consists of approx-
imately 40 ha (100 ac) located between Interstate 71 and the Ohio River in
the vicinity of Bandman Park and the State Railway Museum. It is divided
into three nearly equal sections by a railroad spur and a public road. Pre-
liminary design indicates that approximately 6 ha (15 ac) would be required
for all of the process civil works, equipment, buildings, service roads, and
levee. Thus any of the one-third sections could entirely accommodate the
treatment plant.
The selected alternative includes a shoreline outfall below Towhead
Island for discharge from the North County plant (see Figure 4). At river
mile 603, the discharge will be 2.4 miles downstream of the Louisville Water
Company's intake at Zorn Avenue (number 1 on Figure 4), the main water supply
source for the Louisville area. The average withdrawal at Zorn Avenue is 5.3
m Is (120 mgd). The North County discharge will be upstream of three water
intakes (numbers are keyed to Figure 4):
2. Colgate Palmolive industrial water intake (RM 603.7);
cooling water and boiler feed water is withdrawn
intermittently at a rate of 0.07 m /s (1.6 mgd).
3. Louisville Gas and Electric Company intake for the
Waterside Avenue Electricity Generating Station (RM
603.7); cooling water is withdrawn continuously at a
rate of 0.02 m /s (0.4 mgd).
4. Indiana Cities Water Corporation municipal water
intake at New Albany, Indiana (RM 608.9); average
withdrawal is 0.15 m /s (3.5 mgd).
The proposed discharge location satisfies the policy of the Kentucky Natural
Resources and Environmental Protection Cabinet to refuse permits for wastewater
discharges that would be less than 8 km (5 mi) above a municipal water supply
intake.
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•n
c
m
PUMPING
. RETURN SLUDGE STORMWATER
1 * *
METERING PUMP|NG j "
INFLUENT " 17^1 PRIMARY I _
— — — ' '
f
t * * -
PRIMARY SLUDGE j AERATION
1 ~~
4 — ' EXCESS
i r- *-
| I FLOTATION
j J THICKENING
^^W 1
GRAVITY f I
THICKENING | 1
1
LOO TRuc
w MORRIS
AEROBIC DEWATERING
DIGESTERS
I ^T STATION
t
CHLORINATION J T
StCONDAHY [ 9 |
1 FFFI KFNT
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OHIO
RIVER
r
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SLUDGE 1
K DEWATERED
-UDGE TO
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FLOW SCHEMATIC
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26
Other Treatment Plants
When the regional system is completed, all but six of the areas
currently served by small-area treatment plants will connect to the regional
system. Four of the remaining small-area plants discharge to the Floyds Fork
basin: Berrytown (5), Cross Creek (8), Running Creek (34), and ° ' -.-..:t
limitations for the six plants were determined by the Kentucky " •-_.„•.; - •
sources and Environmental Protection Cabinet. The limitation!.; . > , > :rom
plant to plant are:
Flow, gal/d (m3/d) BOD, !:,^l
Bellwood Presbyterian
Home 6,000 (23) 20
Berrytown 75,000 (280) 30
Cross Creek 172,000 (650) 25
Running Creek 110,000 (420) 1C
St. Thomas Orphanage 3,000 (11) 30
Starview Estates 100,000 (380) 30
Limitations that are the same for all six plants are:
Ammonia nitrogen (NH«N) 4 mg/L
Dissolved oxygen (DO; 7 mg/L
Fecal coliforms 200 organisms/I00 ml
pH 6.0 - 9.0
The regional treatment plant for subarea 18 discharges , •? Hite Creek,
a tributary of Harrods Creek; this plant will also continue opei ,,• "-on. No
upgrading is needed at Hite Creek, but MSB has indicated that ex; , :3ion may be
necessary. The effluent limitations determined by the Kentucky Natural Re-
sources and Environmental Protection Cabinet for the Hite Creek plant are
Flow 4.9 mgd (18,500 m3/d),
BOD 10 mg/L,
and the same limitations for NH_N, DO, fecal coliforms, and pH that are listed
above.
It is projected that the North, County population to be served by the
regional system will grow by more than 18,000 people between 1980 and 1990.
This growth will have to be served by interim on-site systems or small-area
treatment plants. If small-area plants are used to service all of this growth,
the plants will discharge about 7200 m /d (1.9 mgd) to the receiving streams.
The interim systems will be abandoned or salvaged and theit service areas
connected to the regional system when it is completed.
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27
The effluent limitations for these new small-area treatment plants
will depend on the effluent discharge rate and the discharge location. For the
alternatives evaluation, water quality model analyses were run by the Kentucky
Natural Resources and Environmental Protection Cabinet to determine discharge
limitations for North County. These analyses indicated effluent limitations
may be as restrictive as 10 mg/L BOD9 4 mg/L NH N, and 7 mg/L DO for some
plants. All plants would have to provide secondary treatment (30 mg/L BOD) as
a minimum.
On-SjLte_ Systems
Under the selected alternative two of the subareas currently served
by on-site systems will retain those systems. Aerobic tanks and sand mounds
are recommended for Lake Louisvilla (72). Rehabilitation of failed systems or
construction of community systems is recommended for Anchorage (50).
A complete evaluation of all possible causes of system failure is the
key to successfully correcting malfunctions. The troubleshooting process
should look at all components of the treatment and disposal facilities. Cor-
rective action may be as simple as making repairs to the septic tank or as
complex as installing a completely new system* For further informations see
the draft Preferred Alternatives Report (U.S. EPA 1983b) and the EPA design
manual for on-site systems (U.S. EPA 1980a).
3,1.2 Future_JNeeds_
For the purposes of this "Deport, future needs arise from the growth
occurring between 1990 and 2000—the time between the construction of the LS2a
system and the end of the EIS planning period. Under the selected alternatives
LS2a, conveyance and treatment capacity will be provided for existing (1990)
population only, so no future needs would be filled by the regional system.
The system actually constructed, however, may provide future capacity (such as
the LS2c alternative) and extend to more areas in North County (such as the
201 alternative) if the, capacity to serve future population is funded locally,,
Further information on the LS2c and 201 alternatives can be found in the Draft
EIS (U.S. EPA 1983a).
The selected alternative assumes future growth (beyond 1990) will
connect to small-area treatment plants for wastewater management. This growth
would occur in the area shown for small-area plants in Figure 3 and on undevel-
oped land within the regional system service area. Population growth in North
County between 1990 and 2000 is expected to be 12,300. If small-area plants
are buiit to serve all of this growth, discharges to area streams would in-
crease by 4S90Q m /d (1.3 mgd). Effluent limitations for these discharges will
be determined by the Y~ -«-"cky Natural Resources and Environmental Protection
Cabinet,
3. 2 Environmental and So_cj.o-Ecj3ngmjg_JEmpa
A list of 41 criteria for evaluating impacts was developed after a
review of federal regulations and the Louisville and Jefferson County Compre-
hensive Plan (LJCPC 1979). Eighteen of these criteria were affected in some
way by the regional system; the affected criteria and possible mitigative
measures are summarized in Tables 3 and 4. For the locations of the intercep-
tor segments mentioned in this section,, see Figure 5. More specific informa-
tion on the resources, impacts, and mitigative measures summarized in this
section are also available in Section 5.4 of the Draft EIS.
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28
TABLE 3. SUMMARY OF CRITERIA AFFECTED
BY THE SELECTED ALTERNATIVE
Criteria
Justification
Promotes multiple use of com-
munity facilities (LJCPC 1979
EPA Construction Grant Guide-
lines)
Promotes wise energy use
(LJCPC 1979)
10.
Reduced water pollution, ero-
sion, sedimentation
(LJCPC 1979)
12.
Avoids impacts to noise-
sensitive land uses
(LJCPC 1979)
28.
Preserves unique natural
areas (LJCPC 1979)
Criterion affected because sewer ease-
ments can be used for linear recreation
facilities and trails, or they cross
existing land uses which continue being
utilized after placement of the sewer.
No need for mitigation.
Criterion affected because of energy
needed to construct system and the
existing energy used for waste disposal
compared to efficient energy use at a
regional plant. Mitigation: Incorpor-
ate energy-saving measures into the de-
sign of the system.
Criterion affected because of potential
for erosion and sedimentation during
construction and because existing
sources of water pollution will be
removed from creeks. A new source of
pollution to the Ohio River will be
added. Mitigation: Best management
practices during construction to con-
trol erosion and sedimentation; proper
operation of regional treatment plant.
Criterion affected because the inter-
ceptors and collectors will be con-
structed through such noise-sensitive
land uses as residential areas. After
construction there will be no noise
impacts if facilities are operated
properly. Mitigation: Use temporary
noise barriers around jack hammers and
heavy machinery; make sure all equip-
ment has mufflers; limit construction
to normal working hours.
Criterion affected because virtually
the entire interceptor system runs
through forested stream valleys that
are the last remaining natural areas
in North County. Mitigation: Use
already cleared areas where possible;
minimize vegetation removal.
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29
TABLE 3. (Cont.)
Criteria
Justification
30.
Avoids excessive cost to home-
owner (EPA Construction Grant
Guidelines)
31.
Avoids disrupting community
services and facilities (EPA
Construction Grant Guidelines)
Criterion affected because the average
annual household payment, including
debt service and operating cost, will
be $360 per year. EPA criteria define
an expensive alternative as one that
exceeds 1.75% of median family income.
The median household income in North
County is $39,100 (updated to 1983
dollars), so an "expensive" project
would have an annual payment greater
than $680 per household. Mitigation:
None—unavoidable economic impact.
Criterion affected because of disrup-
tion of normal transportation patterns
during construction of sewer lines.
Mitigation: carefully planned traffic
and pedestrian circulation control and
phased closing of local streets with
adequate detours.
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30
TABLE 4. SUMMARY OF CRITERIA AFFECTED
ONLY BY CERTAIN COMPONENTS OF
THE SELECTED ALTERNATIVE
Criteria
System
Component
Effects
4. Preserves neighbor-
1 i.U'O*U.*J» t ',ii
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TABLE 4. (Cont.)
31
Criteria
System
Component
Effects
34. Avoids adversely
affecting aquatic
habitat (Fish and
Wildlife Coordi-
nation Act)
Interceptor segments
MF-1, MF-2, MF-3,
GC-1, GC-2
Interceptor segments
MF-1, MF-2, MF-3,
GS-1, GS-2, GS-3,
LG-1, LG-2, LG-3,
NC-2, NC-5, NC-6,
HC-1
These segments pass through
forested areas with suit-
able habitat for the en-
dangered Indiana bat; no
sightings of the bat are
reported from the study
area, however. Mitiga-
tion: See page 36.
These interceptor segments
run along stream segments
of local habitat impor-
tance. Mitigation: See
page 36.
Small-area treatment
plants
35. Avoids adversely
affecting terrestrial
habitats (Fish and
Wildlife Coordination
Act)
36. Avoids adversely
affecting recreational
resources (EPA Con-
struction Grant
Guidelines)
Interceptor segments
MF-1, MF-2, MF-3,
MF-4, MF-5, GS-1,
GS-2, GS-3, GS-5,
LG-1, LG-2, NC-1,
NC-2, NC-3, NC-4,
NC-5, NC-6, NC-7
NC-8, HC-1
Interceptor segments
MF-1, MF-4, GS-1,
GS-2, GS-3, GS-5,
LG-1, LG-2, LG-3,
LG-4, NC-6, NC-7,
NC-8, HC-1
Interceptor segment
GS-6
Those existing plants that
continue in operation or
future plants that may be
built will discharge pol-
lutants that may reduce
the habitat value of the
small creeks. Mitigation:
Strong enforcement of dis-
charge permits to encour-
age good operation.
These interceptor segments
run through stream valleys
of local habitat impor-
tance. Mitigation: See
page 36.
These interceptor segments
pass through forested
areas of high potential
for passive recreational
use. Mitigation: See
page 37.
This segment passes
through a county park and
a state park. Mitigation:
See page 37.
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32
TABLE 4. (Cont.)
Criteria
System
Component
Effects
36. (Cont.)
37. Avoids adverse
visual impacts
(EPA Construction
Grants Guidelines)
38. Avoids adversely
affecting archaeo-
logical resources
(National Historic
Preservation Act;
Executive Order 11593)
39. Avoids adversely
affecting agricultural
lands (EPA Policy to
Protect Environmentally
Significant Agricul-
tural Lands)
Small-area treatment
plants
Interceptor segments
MF-1, MF-2, MF-4,
GS-1, GS-2, GS-3,
GS-5, LG-1, LG-2,
NC-2, NC-3, NC-4,
NC-7, NC-8
Interceptor segments
NC-3, NC-4, NC-5,
NC-6, NC-7, NC-8,
GS-1, GS-4, GS-5,
GS-6, LG-1, LG-3,
LG-4, LG-5, LG-6,
HC-1
Interceptor segments
GS-5, NC-1, NC-2,
NC-3, NC-4, NC-5,
NC-6, NC-7
Those existing plants that
continue in operation or
future plants that may be
built will discharge pol-
lutants that may reduce
the aesthetic value of
creeks running through
recreational areas. Miti-
gation: Strong enforce-
ment of discharge permits
to encourage good opera-
tion.
These interceptor segments
will pass through natural
areas of high scenic qual-
ity. Mitigation: See
page 37.
These interceptor segments
run through areas of
medium to high potential
for containing archaeolog-
ical sites. Further sur-
veying and testing is rec-
ommended; see page 34.
These sewer segments may
take agricultural lands
out of production during
construction of the in-
terceptor; but once the
sewer is in place, the
affected areas can return
to production.
Mitigation: Stockpile top
soil and use to landscape
to original grade; compen-
sate farmers for lost in-
come during construction
phase.
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TABLE 4. (Cont.)
33
Criteria
System
Component
Effects
40. Avoids adversely
affecting floodplains
and wetlands (Clean
Water Act; Executive
Order 11988; EPA
Policy Statement of
Procedures: Flood-
plains and Wetlands)
Interceptor segments
MF-1, MF-2, MF-3
NC-1, NC-2, NC-3,
NC-4, NC-5, NC-6,
NC-7, NC-8, HC-1,
TL-1, GT-1, GS-1,
LG-1
Interceptor segment
NC-2
Regional treatment
plant
These segments will be
placed in the Ohio River
floodplain. During con-
struction, there will be a
hazard to crews and equip-
ment, but early warning
and preparedness can avoid
major impacts. After con-
struction, the ground sur-
face will be returned to
its original contour so
there will be no effect on
floodwater movement.
Mitigation: None
required.
This segment runs near the
Muddy Fork wetland area,
the only known wetland in
the study area. Mitiga-
tion: See page 35.
The plant site is located
in the 100-year floodplain
of the Ohio River. Loca-
tions out of the flood-
plain are impractical
because of high pumping
costs. Mitigation:
Construct levee around
plant to protect it.
Impact on floodplain is
unavoidable.
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34
Several federal laws and regulations require that mitigative measures
be implemented on federally funded projects to protect certain resources of
national value:
Archaeological sites
Historic sites
Floodplains
Wetlands
Navigable waters
Environmentally significant agricultural lands
Rare and endangered species
Significant aquatic and terrestrial habitats
Wild, scenic, and recreational rivers
The North County area does not contain any officially designated wild, scenic,
or recreational rivers, so that category is not applicable here. All the
other categories are affected to some extent by the regional system, and ac-
tions to mitigate the effects are summarized in this section. These mitiga-
tive actions may be required of the grantee—i.e., the construction grant will
be contingent on the grantee implementing the action—or they may simply be
recommended for the grantee's consideration. In addition to the actions neces-
sitated by federal laws or regulations, certain actions are recommended to pre-
serve natural features of local significance. These mitigative actions are not
required by federal laws, but their implementation should satisfy local princi-
ples on environmental protection, as outlined in the Comprehensive Plan for
Louisville and Jefferson County.
Archaeological and Historic Sites
EPA-funded projects are subject to the requirements of Section 106
of the National Historic Preservation Act of 1966, the Archaeological and
Historic Preservation Act of 1974, Executive Order 11593, and regulations of
the Advisory Council on Historic Preservation (36 CFR Part 800). In essence,
these laws and regulations require mitigation of impacts to historic or archae-
ological sites on, or eligible for, the National Register of Historic Sites.
To fulfill these requirements, construction grants for any North County LS2a
interceptor segments will be contingent upon the grantee furnishing:
1. Certification from the State Archaeologist that the con-
struction will not affect any known archaeological sites
on or eligible for the National Register; and
2. Certification from the State Historic Preservation Officer
(SHPO) that the construction will not affect any known ar-
chaeological or historic sites on or eligible for the
National Register.
Interceptor segments MF5, MF6, GT1, GB1, GS2, GS5, PL1, LG1, NC3, NC4, NC6,
and NC7 have been identified as lying near currently designated historic sites;
see the Draft EIS (U.S. EPA 1983a) for details. In addition, for interceptor
segments NC3, NC4, NC5, NC6, NC7, NC8, GS1, GS4, GS5, GS6, LG1, LG3, LG4, LG5,
LG6, and HC1, the grantee shall submit a plan for conducting an archaeological
survey of the type recommended in the Draft EIS (U.S. EPA 1983a); the plan
shall have been approved by the State Archaeologist. Furthermore, the grantee
shall agree to inform EPA, the State Archaeologist, and the SHPO of the find-
ings of the survey, allowing a reasonable time for comment before construction
actually begins.
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35
The ii\ct£ ' i, • J -.• . of ?. 11 ec?.;;. - Ge\'-,,-;ts in several neighborhoods—-Glen-
view EstaC 3", RivarwcQ'?, . 'trJ Lao '--ill?, RiMwra, Wiady Hills—may affect houses
on or tiomiAac-'f-.i !".o >:!>fi y^; * ' ./ia ' ?..: "1.. tar,, It is recommended that the grantee
consult- with tiie Sca.'t '••>.'.'-".:...ti.--. r •...:-.a'-"-7av.ioti Officer about collector routes in
cb a s 6 ue i gli" > j t lio o d s,
Locating the MC5 piBiylrjg station j>nd the regional treatment plant in
the Oh1f> Rf;,,-/.- flnodnlcln ar<* \ni a voidable Impacts,,, Both locations will have
co feve flood ^rot.eetlon, preatDiisbi;-/ levees, and both sites will reduce flood-
plain ares, T: ±& r^c,,i(!7a;:ndt,;] i;hat rlic si'';? contained within the levee be
;/ep'.-. as <3-;d!. as jposiilllc so a,; <• o uL-siiaiza the loss of ^Icodplain.
Y;u,-, ou.ly kn-^.-m wei-lard o£ significant size in the study area, is the
Muddy Fo.\'c :^s.:U;,fl, r.l so ki'to-jp. as the Caperton. Sv?ainp. Construction in wetlands
requires ;* pftr.uit frc-_, the "Uf-, Afw/ Ccips of Engineerss as authorized by Sec-
r.ion 40'> ;•;" the jleer. 'T«;:a-.. Ac*;. Bcf)jre n grant will be approved for the NC2
intercept..' ;i:;gi,ieiit . r.:-e gcani sr; ia j. «qmjred to obtain a permit from the Corps
of Engineers or re s:/:.•„,'.; •: fj 9ta':flrBeL!l from the Corps that they have been cam-
suited G\v.r che rouL^ >./' ?.!:«' ini-.'-T.-or-trc end have determined that the construc-
tion does r,ir: reqvi;;;; : p.?n,-i.-.. "ef> S^cLi'« 5.^,4 of the Draff EIS for more
specii'ic 1.if o relation o; thi •; wr/ 1 f:,i,^.
The U,S, Atvr-/ (Joips of Engineers (see page 117) has identified the
following interceptor segments as paralleling streams within the Corps juris
diction: UC-6, NC-7. i'JC-8, MF-1, MF--3, CS~'., GS-2 , GS-3, LG-1, LG-2, LG-3S
LG--A, LG-"59^G~6, WS-3 , WG-l, GT-?« l»H-lr TL-U and HC-2. A permit from the
Corps will bo requj r?.._: foi s-iy cc«. r.sing f-r filling of streams within their
3uriad.°c.t ion ,
Tii=- I,n2a '"ffc'im'jl :-,jstew tt.il? ser'/o;; dsvelopraent existing at the
time the ^rani; t,? apprcve-L Fed era] funds, therefore, will not be supporting
iiifure -irv.'^c.proeri- of -iov.f cori^eittelly pigr- j f icant agricultural lands. Certain
intrtrcepi-ur ceg!Eencs; ^prti --u.lni Ij te the Ol-io River floodplains will pass
tnrough HJ gsn.I icani: 3: a run.' *••!•' j (sr- ; i, '-jp «".. , It. is recommended that the soil
in ttiPs- eo-i::!dcrs 1?^ ; r-' ->.}^d ;.i. --,,-„ -r- ^-tonr.-rrtsction condition so that pro-
ductive use-, of th-if t:- ^rfi no t^owi habitational
- -." cf .•-• .I'.jii cf the Indiana bets however,
, •• c^:r>; rovter? The bat is on the federal
krsowt. to establish summer (maternity) colo-
nies in old trees of stream bottoms within 20 miles of the study area'(MacGregor
1983), Severs! interceptor segments (MF1s 2S 3; GC1, 2; and others) contain
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36
habitats that appear suitable for summer colonies of this bat. Several miti-
gation steps are recommended to minimize potential adverse impacts to this
species:
1. Avoid removing huge old trees along stream bottoms and
ravines that might serve as nesting sites.
2. If old trees must be removed, avoid doing so in the
summer months when bats are likely to use trees as
nesting sites.
It is required that the grantee contact the Kentucky Department of Fish and
Wildlife Resources if there are conflicts with preserving suspected bat habi-
tat.
It is also required that the grantee consult with the Kentucky Nature
Preserves Commission when constructing interceptor segments where species of
local concern have been found:
Interceptor Segment Species
MF4, NC8 Louisville crayfish
MFl, NC2 Yellow-crowned night heron,
hooded merganser, least bittern,
king rail, pied-billed grebe
GS1, GS2 Ginseng
See Section 5.4.4 of the Draft EIS for more specific information on these habi-
tat areas.
Natural Areas
Locally important natural areas were noted in an environmental survey
of LS2a interceptor corridors (see Section 5.4.4 of the Draft EIS). The ravine-
slope and bottomland forests are locally significant as the last remaining major
natural areas in North County. Two particular areas—the Muddy Fork wetland and
the lower Goose Creek Valley—are being studied by the Kentucky Nature Preserves
Commission for possible designation as state nature preserves; it is required
that the Commission be consulted about project activities in these areas.
The Caperton swamp forest and the bottomland hardwood forests on the
floodplain terraces of the Ohio River have been designated as Category 2 re-
sources by the U.S. Fish and Wildlife Service (see page 129 ). Designation cri-
teria for Resource Category 2 are:
"Habitat to be impacted is of high value for evaluation
species and is relatively scarce or becoming scarce on
a national basis or in the ecoregion section."
The mitigation goal for Resource Category 2 is no net loss of inkind habitat
value. Before a grant will be approved for interceptor segments NC2-7, the
grantee is required to consult with the U.S Fish and Wildlife Service in order
to achieve the mitigation goal for Resource Category 2.
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37
The environmental survey also noted many significant natural features
for which mitigative actions are recommended:
Interceptor Segment
and Natural Feature
MF3, MF2
Mature sycamore grove;
multiple pools, snags,
ripples
GS5
Limestone Outcroppings
GS1, 2, 3
Mature ravine forests
LG3
Braided stream,
riffle-and-pool habitat
LG2
Natural ford and small
falls
HC1
Putneys Pond
NC8
North-facing bluffs:
waterfalls and signif-
icant aquatic and
terrestrial habitats
Recommended
Mitigation
Avoidance: locate sewer
along east side of road
Avoidance
Conduct biological survey
of specific route; minimize
clearing of vegetation,
particularly significant
trees, herbaceous groupings,
etc.; relocate important
species.
Avoid stream crossings;
keep sewer back from
stream bed
Avoid stream crossing;
control sediment runoff
upstream
Minimize disturbance of
woods between road and
pond
Avoidance: keep interceptor
on northern bank of Harrods
Creek; protect large trees;
move valuable herbaceous
plants
Recreational and Visual Resources
The GS6 interceptor traverses Hounz Lane County Park and E. P.
Sawyer State Park. The grantee is required to consult with the local and
state agencies responsible for operating these parks to select the most en-
vironmentally sound route and to minimize disruption of park activities. The
environmental survey also noted many forested areas that are significant
visual and recreational resources; see Section 5.4.4 of the Draft EIS for de-
tails.
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39
4. ERRATA AND REVISIONS TO THE DRAFT EIS
Page
3
7
7
19
32
36
76
98
102
177
203
223
224
237
242
Paragraph
1
2
2
5
2
4
4
3
3
3
2
2
Lines Corrections
A revised Figure 1 is provided in the Execu-
tive Summary of this document.
3-4 "...all but five of the plants..."
4 "...and located southwest of Louisville..."
3 "...available before 1987."
5 "...all but five of the plants..."
The third page of Table 7 was printed twice
and the second page omitted some printings of
the Draft EIS. The correct second page is
provided on the next page of this document.
18 "...shown in Figure Hh"
5 "...Hite Creek (18), Bellwood Presbyterian
Home (4), St. Thomas Orphanage (35), and the
four. . . "
15 " $10 /per son /year"
3 "...available before 1982.."
7-8 "The assessment is based upon assessable
units. An assessable unit is defined as "a
single-family residential lot, or equivalent,
on which no more than one single-family resi-
dence can reasonably be constructed." Proper-
ties other than single-family residential lots
shall be equated to assessable units, as de-
termined by MSD. Apartment units are deemed
ecjual to one-half an assessable unit. MSB's
assessment policy protects..."
7-8 "...small habitational sites may occur..."
7-8 "...small habitational sites may occur..."
1 "...require that mitigative measures..."
Table 60, column 2, third member should be
"...City of Windy Hills"
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TABLE 7. (CONT.)
Map Design Actual
Key Treatment Plant Flow (gpd) Flow (gpd)
19 Holiday Inn Motel 52,000 NA(a)
20 Holiday Manor Shopping Center 22,000 22,000
21 Hounz Lane Park 1,500 NA
22 Hunting Creek North 236,400 189,120
23 Hunting Creek South 167,600 91,200
24 Ken-Carla Subdivision(b) 10,000 10,000
25 Kentucky Children's Home 45,000 17,822
26 Louisville Country Club 13,500 13,500
27 Muddy Fork(b) 360,000 84,600
28 Murray Hills Subdivision 326,600 171,200
29 New Market Subdivision 80,000 80,000
30 Norton Elementary School 15,000 6,500
31 Plantation Subdivision 60,000 60,000
32 Plantation Hills Subdivision 30,000 30,000
33 Rolling Hills Subdivision 585,000 585,000
34 Running Creek Subdivision 110,000 10,000
35 St. Thomas Orphanage 3,000 1,000
36 Shadow Wood Subdivision 85,000 15,000
37 Spring Valley Estates 100,800 NA
Subdivision
38 Springdale Subdivision 60,000 800
39 Standard Country Club 15,000 15,000
Treatment Process
Liquid Sludge
Extended Aeration
Extended Aeration
Extended Aeration
Extended Aeration
Extended Aeration-
Lagoon
Extended Aeration
Trickling Filter
Septic Tank-Inter-
mittent Sand Filter
Extended Aeration-
Micro Strainer
Extended Aeration
Extended Aeration
Extended Aeration
Extended Aeration
Extended Aeration
Extended Aeration
Extended Aeration-
Mixed Media Filter
Trickling Filter
Extended Aeration
Extended Aeration
Extended Aeration-
Lagoon
Trickling Filter
Anaerobic Digestion
Aerobic Digestion
NA
Aerobic Digestion
Anaerobic Digestion
NA
Sludge Drying Beds
NA
Aerobic Digestion
Anaerobic Digestion
Aerobic Digestion
NA
NA
NA
Anaerobic Digestion
Anaerobic Digestion
NA
NA
Aerobic Digestion
Aerobic Digestion
NA
(a) Not Available.
(b) MSD owned and operated.
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41
5. PUBLIC COMMENTS AND EPA RESPONSES
5.1 Oral Comments
Oral comments on the Draft EIS were received at a public
hearing held on February 7, 1984, at the Ballard High School
Cafetorium. This section contains the transcript of the hearing,
including introductory statements made by representatives of EPA
and the Kentucky Natural Resources and Environmental Protection
Cabinet. Public comments and EPA's responses begin on page 60.
Table 5 is an index to the oral comments, and Table 6 summarizes
the general subjects mentioned by each commentor.
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TABLE 5. INDEX TO PUBLIC HEARING COMMENTS ON NORTH COUNTY DEIS
N>
COMMENT
CODE
LWC-1.
LWC-2.
LWC-3 .
DCS-1.
DCS-2.
NW-1.
KCT-1.
KCT-2.
KCT-3 .
LWV-1.
LWV-2.
LWV-3.
LWV-4.
LWV-5.
LWV-6.
LWV-7.
LWV-8.
LWV-9.
LWV-10 .
LWV-11.
LWV-1 2.
LWV-13.
LWV-14 .
WH-1.
WH-2.
WH-3.
PAGE(S)
61
61
61
63
63
64
66
66
66
67-68
69
69
70
70
71
71
71-72
72
72-73
73
73
73
73
74-75
75
77
COMMENTOR
Louisville Water Company
Louisville Water Company
Louisville Water Company
Dr. Carl Sturm
Dr. Carl Sturm
Neal Webster
K.C. Tsai
K.C. Tsai
K.C. Tsai
League of Women Voters
League of Women Voters
League of Women Voters
League of Women Voters
League of Women Voters
League of Women Voters
League of Women Voters
League of Women Voters
League of Women Voters
League of Women Voters
League of Women Voters
League of Women Voters
League of Women Voters
League of Women Voters
Winnie Hepler
Winnie Hepler
Winnie Hepler
NATURE OF COMMENT
Support LS2 type alternative
Alternative selected based on federal f-unding
Alternative selected based on federal funding
Construction grant priorities
Sewering priorities
Encourages building for growth
Elimination of 201 alternative
Modify 201 alternative for existing population
Divert additional flows to Kite Creek
Federal funding is EIS's major concern
EPA has wrecked 201 plan
Mill Creek EIS
EPA's share of funding
Small-area treatment plant malfunctions
EPA's share of funding
Clean Water Act amendments
EIS prevented local action
Local long-range planning
Intent of NEPA and Clean Water Act
Long-range planning
Technical feasibility of the selected alternative
Affordability of the selected alternative
Public health and environmental protection
What happens next
Water quality improvement
Enforcement of water quality standards
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43
w
Pi
£3
H
^ rx
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TABLE 6. SUMMARY OF GENERAL TOPICS COVERED BY ORAL COMMENTS
1. Louisville Water Company
2. Dr. Carl Sturm
3. Neal Webster
4. K.C. Tsai
5. League of Women Voters
6. Winnie Hepler
7. Elbert Johns
8. Mrs. Molesky
9. Cliff Sawyer
Pi
w
H
PH O1
04
CO
1
1
2
SMALL-
S
**"-» E~*
CO !Z
^ 1 1
<3 PH
H
O W
M Pi
H <
P-i
W
CO
2
EC
So
O 52
Pi M
O 'Z
W
^ f*^ ^-e
O\ W
•* rH H M
vO CO >
o w
H O Pd
1
2 1
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2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
NORTH JEFFERSON COUNTY, KENTUCKY
ENVIRONMENTAL IMPACT STATEMENT
FOR PROPOSED WASTEWATER FACILITIES
DRAFT EIS PUBLIC HEARING
FEBRUARY 7, 1984
BALLARD HIGH SCHOOL
LOUISVILLE, KENTUCKY
7:30 P.M.
REPORTER: ALICE J. BALLARD
KENTUCKIANA REPORTERS
125 South Seventh Street
Louisville, Kentucky 40202
(502) 589-2273
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INDEX
OPENING BY MR. HOWARD ZELLER
STATEMENT BY MR. RONALD MIKULAK
STATEMENT BY MR. RICHARD SHOGREN
(FROM THE CARDS)
Mr, Steve Hubbs
MR. TOM PRYOR (Yielded)
DOCTOR CARL STURM
NEAL WEBSTER
K. C. TSAI
SYLVIA WATSON (Yielded)
PATRICIA NIGHTINGALE
RALPH WILLIAMS (None)
WINNIE HEPLER
(Mr. Shogren's response)
MR. FRY (Abstained)
SYLVIA WATSON (Yielded)
(FROM THE FLOOR)
ELBER T. Johns
MRS. MOLESKY
CLIFF SAWYER
CLOSING BY MR. ZELLER
CERTIFICATE
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6
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30
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34
35
37
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50
51
54
57
59
Ui
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1 being prepared on the wastewater facilities
2 proposed in the 201 Facilities Plan prepared for
3 the Louisville-Jefferson County area by the
4 Kentuckiana Regional Planning and Development
5 Agency. The preparation of this EIS is
6 authorized by the Clean Hater Act and the
7 National Environmental Policy Act or HEPA.
8 The Clean Water Act
9 enables EPA to' fund up to seventy.-five percent
10 of the eligible costs for the planning, design
11 and construction of wastewater facilities. How-
12 ever, effective on October 1, 1984, this amount
13 will be reduced to fifty-five percent. The
14 planning phase of this process results in the
15 preparation of a facilities plan. In this
16 instance, the Kentuckiana Regional Planning and
17 Development Agency was designated as the local
18 agency responsible for facilities planning in
19 this area and the Louisville-Jefferson County
20 Hetropolitan Sewer District was charged with
21 the responsibility of implementing the 201 Plan
22 Proposal.
23 Now, the National
24 Environmental Policy Act or NEPA requires
25 federal agencies to prepare an environmental
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impact statement on major federal actions that
significantly affect the quality of the human
environment. Because of the environmental
complexities and water quality issues involved
in this project, Environmental Protection Agency
made the decision to prepare an EIS on the 201
Facilities Plan. Accordingly, in June of 1979,
the notice of intent to prepare EIS was
issued.
Pursuant to the guide-
lines of the President's Council on
Environmental Quality and the rules and
regulations of EPA with regard to the
preparation of EIS's, this public hearing is
being held to receive comments on the Draft EIS.
The Draft EIS is being discussed in this
public forum to encourage public participation
in the federal decision-making process and to
develop improved public understanding of all
federally funded projects.
In this regard the
Draft EIS was made available to the public, it
was at EPA's Office of Federal Activities, and
it was listed in the federal register on
December 30, 1983. The Draft EIS comment period
-------
1 will extend until February 29, 1984. The
2 comments received during this evening and during
3 the comment period will become part of the
4 official record on this project.
5 Any questions or issues
6 that are raised here at this hearing tonight or
7 during the comment period will, of course, be
8 answered in the final EIS when it is promulgated
9 at a later date.
10 Now, so that we all
11 have a full understanding and appreciation of
12 the project underway, and many of you I know
13 have been involved in this from the beginning in
14 scoping meetings and elsewhere. But,
15 nevertheless, before we begin with any testimony
16 on this. I'd like to ask Mr. Ron Mikulak who is
17 the Project Officer on this project and
18 associated very closely for a number of years to
19 give us a brief summary on the project. And
20 I'll ask Mr. Mikulak to do that now, please.
21 MR. MIKULAK: Thank
22 you, Mr. Zeller. Can you hear me in the back?
23
24 I would also like to
25 welcome you this evening and braving the chilly
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CXJ
elements in Louisville. As Mr. Zeller
indicated. I am the Project Officer for EPA on
this EIS. My office is also located in Atlanta.
What I would like to
do this evening before we start to receive
testimony from the floor is to provide you with
a brief overview and summary of the Draft EIS.
Many of you, I know, are very familiar with the
EIS and have followed the progress of the study
through the years. But some of you are new to
it, and, I think, if I provide a brief overview
and background of the study it might put things
in a little bit more perspective.
What I would like to
do is follow the outline that we have provided
in the handout that you should have picked up
when you came in this evening. The front cover
is the agenda followed by three pages of an
outline, which, if you follow, you will follow
closely with the comments that I make this
evening. The last three pages of the handout
are maps of the study area. The first is a
general location map of the North County study
area, as we call it, the northeastern part of
Jefferson County, Kentucky. The last two maps
-------
1 are proposed routing of interceptor lines for
2 the preferred alternative. The last map is a
3 schematic representation of what the different
4 service areas for different portions of the
5 preferred alternative involve.
6 I would like to, as
7 indicated by the agenda, go to the purpose of
8 the EIS, background of the study, the
9 alternatives that have been investigated,
10 changes in the Construction Grants Program and
11 the Clean Water Act that affect the decisions in
12 the EIS, the EIS preferred alternative, and,
13 finally, mitigative measures that are suggested
14 in the EIS.
15 The purpose of the
16 North County EIS was to identify and evaluate
17 wastewater management alternatives for the North
18 County study area of Jefferson County. And,
19 again, I think I noted in Figure 1 in the
20 handout. Through the EIS process a range of
21 alternatives were considered leading to the
22 selection of a cost-effective and
23 environmentally sound wastewater management
24 approach. I think it is important to point out
25 that the approach.we recommended in the EIS is one
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that represents the project that EPA could
support through our Federal Construction Grants
Programs.
In going back in time
for a few moments and looking at the project
background of the EIS
I'd first like to
mention the Clean Water Act. The Clean Water
Act was first passed in 1972 and further amended
in 1977 and 1981. The focus of the Clean Water
Act was to improve the quality of the nation's
waters. One mechanism that is available is
Section 201 of the Clean Water Act. Section 201
of the Act authorized the Environmental
Protection Agency to fund wastewater facilities
under what is called the Construction Grants
Program. In the Construction Grants Program,
seventy-five percent funding is made available
for planning, designing and constructing
wastewater facilities. To meet the mandate of
Section 201 of the Clean Water Act, state water
pollution control agencies designate local
planning agencies to develop wastewater
management strategies for a specific area.
These strategies are called 201 Plans.
-P-
VD
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10
1 As Mr. Zeller men-
2 tioned in his opening remarks, the Kentuckiana
3 Regional Planning and Development Agency, KIPDA,
4 was chosen as the 201 planning agency for
5 Jefferson County. And the Louisville and
6 Jefferson County Metropolitan Sewer District,
7 MSD, was chosen to implement the recommendations
8 of the 201 Plan.
9 Recommendations in the
10 201 Plan that was completed in 1974 for North
11 County involved the proposal of a new regional
12 North County treatment plant to serve virtually
13 all of the North County study area. The
14 treatment plant would be located on the Ohio
15 River and discharge treated wastewaters to the
16 river .
17 In 1975 EPA and
IB the Kentucky Department for Natural Resources
19 and Environmental Protection, which is now known
20 as the Cabinet for Natural Resources and
21 Environmental Protection, reviewed the 201 Plan
22 and determined it to be substantially complete.
23 This action led the way for EPA to commit
24 federal funds for design and construction
25 projects that were initiated in southwest
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Ul
o
11
Jefferson County.
Early in 1977, con-
current with project construction in Southwest
Jefferson County, various citizens groups
requested EPA to prepare an Environmental Impact
Statement. In 1977, EPA reviewed the concerns
of the citizens and issued a notice of intent to
prepare an EIS, Environmental Impact Statement
on facilities in southwest Jefferson County.
Subsequent to that notice of intent EPA was
requested by various groups and agencies to
re-examine the scope of the EIS and in doing so
a public scoping meeting was held in February of
1978 to define the issues, determine the scope
of the project and ensure public involvement in
the agency decisions.
And, finally, in
May of '78 a notice of intent to prepare the
Mill Creek EIS was issued. And that
concentrated on facilities, again, in southwest
Jefferson County. However, because of
environmental complexities and issues raised in
the northeastern part of the county it was
determined in May of '78 and recognized at that
time that a North County EIS would be prepared.
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1 And, finally, in
2 June of '19 the North County notice of intent
3 was issued? July of '79 the North County scoping
4 meeting was held,- December of '83 the Draft EIS
5 was issued and February '84, this evening, we
6 are holding the Draft EIS public hearing. find
7 the final EIS is expected to be completed this
8 summer, summer of "84.
9 Kos, in going through
10 the scoping process of the EIS, I think it's
11 important to mention the several issues that
12 were raised by citizens and local and state
13 agencies. These included the evaluation of
14 wastewater management alternatives for the study
15 area? the location of v?astewater treatment
16 plants and discharge location, evaluation tf
17 effluent disposal, the cost associated with
18 wastewater management alternatives, the effects
19 of facility const i-,>ct ion and available
20 mitigation, the est s £>1 ishment of priority water
21 quality and public r.sajth probjso areas caused by
22 the numerous septir, tankf and opaiatino paci'ag;
23 plants in the ?.t;j'.y aiea.
24 Sow, putting the Lrs :,:
25 EIS preferred c, ~ -. :ni :;•;,- ' *i ae^specii V;
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think it might benefit the audience to
understand the kinds of existing wastewater
management practices that we see in the North
County area today. Currently, we see a mix of
small wastewater treatment plants? sometimes
called package plants. Also? septic tanks and
several regional facilities,
The regional facilities
I refer to include the Morris Focnsan Wastewater
Treatment Plant which is MSD!F one hundred and
five million gallon per day facility located
south of Louisville, It serves tha southern
portion of the North County stutfy area. You car*
see the area noted OR the last figure in the map
that indicates the service area that is served
by Morris Forman.
Additionally, there is
I
• the Hite Creek -- MSD's Bite Cre?'< four point
[ four million gallon per day vast evs r-st facility
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| that series the northeast porti or, o* the study
| area. The Hite Creek p.l?nt i «5 located near i;he
j intersection o€ Srov;*-
; discharges to Hite C r eeh,
Theie
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1 serve institutions, parks, shopping centers and
2 residential areas. The total combined flow of
3 these package plants approximates five million
4 gallons per day. All but four of the package
S plants are privately owned and they all
6 discharge to small area streams.
7 With reference to on-
8 site systems or septic tanks, there are over seven
9 thousand septic tank systems in the study area,
10 with the majority of these septic tank systems
11 being a septic tank lateral field serving
12 primarily residential areas.
13 One note on the mix
14 of facilities that we see now, in that in the
15 mid-1970's greater emphasis was placed on
16 package plants, the small wastewater treatment
17 plants that we see. Primarily because of two
18 reasons. First is the unavailability of public
19 sewers through a regional sewer system, and,
20 secondly, because of Health Department
21 regulations that effectively restrict the
22 development of septic tanks on lots that —
23 require lots greater than five acres.
24 Now, in determining
25 a cost effective and environmentally sound
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program for correcting public health and water
quality problems in the area four area-wide *
alternatives were developed as part of the EIS.
These four alternatives -- going on to the
second page of the outline. These four
alternatives vary in the mix of the three basic
wastewater management options that I outlined
previously; on-site systems, package plants and
regional systems. On-site systems were
considered feasible in only a few areas as
allowed by state and local regulations. Package
plants were considered feasible if designed to
meet specified discharge requirements.
A Regional North County
Wastewater Treatment Plant involves a new
treatment plant located on the Ohio River at the
mouth of Beargrass Creek and an interceptor
system serving one or more of the main creek
basins of the study area.
Of the four alternatives
that were considered.
The first is the No
Federal Action Alternative, sometimes shortened
to be termed as the No Action Alternative. The
No Action Alternative assumes that no federal
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1 funding is available and under those
2 circumstances the existing wastewater management
3 practices would continue. Small area package
4 plants would be the primary method of wastewater
5 management in the study area, with the number
6 increasing from the existing forty-nine to
7 roughly seventy or eighty by the year 2000.
8 The 201 Plan Al-
9 ternative is virtually the 201 Plan recommended
10 alternative and it assumes — sewering virtually
11 the entire existing and future population in the
12 North County study area and that wastewater
13 being treated at a new North County Treatment
14 Plant. All existing septic plants and package
15 plants and future development would be connected
16 with the year 2000 f.ov of approximately nine
17 million gallons per day.
18 Limited Sewered
19 Alternative II has the objective of relieving
20 all unsewered communities with significant
21 numbers of failing septic tanks and as many
22 package plants as feasible. Future population
23 under the LSI alternative would be served by
24 either package plants -- future package plants
25 which is termed LS1-A or by capacity
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accommodated at the new North County Treatme.it
Plant. That alternative or sub-alternative is
termed LS1-C. Depending on how future flow is
handled, either at package plants or at the
North County Treatment Plant, the new North
County Treatment Plant would be sized at
anywhere from five to six million gallons per
day and the number of package plants in the
study area would be anywhere from twenty-two to
twenty-six.
Under Limited Sewered
Alternative *2 (LS2). Again, the objective of
LS2 is to relieve all septic tank problem areas
and existing package plants. And, again, the
future population is served by package plants
under a sub-alternative LS2-A or the regional
plant under LS2-C. The new North County Plant
would be sized at either six point five to seven
point one HGD with roughly six to nineteen
package plants existing in the study area.
During the prepara-
tion of the BIS, Congress authorized changes to
the Clean Water Act that does affect the way
that the Construction Grants Program operates
and, in turn, affects decisions that we make in
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1 this EIS. There are three major changes that I
2 think bear discussion this evening.
3 The first being that
4 lower overall authorization for the grants
5 program than had previously been authorized was
6 seen in 1981, that is, the sum of money
7 available for the 201 Program had been reduced
8 in total. Number two, the Federal share of
9 seventy-five percent funding was reduced to
10 fifty-five percent funding. This reduction
11 becomes effective on October 1st, 1984. And,
12 third, there is a restriction on the use of
13 Federal funds for conveyance or treatment
14 capacity beyond the existing population at the
15 time of a Construction Grants Award or the year
16 1990. And this also becomes effective October
17 1st, 1984.
18 Another element that
19 is important in the overall decision process in-
20 volves Kentucky's priority list. The State agency In
21 Kentucky, the Division of Hater In the Cabinet
22 of Natural Resources and Environmental
23 Protection, establishes a priority list for
24 funding projects under EPA's Construction Grants
25 Program. Based on recent projections in the
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priority list, it is not expected that the North
County Proposal be funded until sometime beyond
1986. For this EIS and the decisions that we
make at this time in the EIS and looking at the
funding — or potential funding date for the
North County Project it is therefore assumed
that Federal participation in this project will
be at the fifty-five percent level and capacity
to serve needs at the time of the grant award or
1990 only will be eligible. The future
applications of these assumptions to any actual
project is subject, however, to the laws, the
regulations and funding levels applicable at the
time of grant award.
Based on the evalua-
tion of alternatives and looking at
environmental impact, the cost, operability and
reliability, changes in the Clean Hater Act, et
cetera, EPA made the decision to select
alternative LS2-A as the Draft EIS Preferred
Alternative. As shown in pictures two and three
of the handout, LS2-A proposes a new North
County Hastewater Treatment Plant to serve most
areas currently served by on-site systems and
package plants with the future population being
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1 served by new package plants. This alternative
2 represents the maximum funding position
3 available to EPA under current legislation in
4 relieving the water quality and public health
5 problems in the area.
6 It is very important
7 to note, however, that EPA's funding decision
8 does not prevent local authorities from
9 providing a larger regional system to include
10 sewer service for future growth. Any capacity
11 or facilities for future growth will, however,
12 not be eligible for Federal funding.
13 The LS2-A Alternative
14 proposes to serve all but seven of the area's,
15 forty-nine existing small area plants, and all
16 but two to five of the areas thirty-two
17 unsewered communities. The proposed North
18 County Wastewater Treatment Plant would be sized
19 at approximately six point five million gallons
20 per day and it is proposed to be located between
21 1-71 and the Ohio River at the mouth of
22 Beargrass Creek. The preferred discharge
23 arrangement includes a shoreline outfall below
24 Tow-Head Island at river mile 603.
25 The regional interceptor
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system would serve existing development in the
Muddy Fork basin, the Woodside Creek basin, most
of Goose Creek basin, the Little Goose Creek
basin, and Harrods Creek basin, and roughly
forty miles of proposed interceptors would be
required as part of the project.
The population to
be served by the six point five North County
Treatment Plant is estimated to be roughly
fifty-four and a half thousand people. Future
population, that is, population from the year
1990 to the year 2000 is estimated to be
approximately twelve thousand three hundred.
The means by which future populations are served
are, as I pointed out before, are local
decisions. The total estimated project costs for
LS2-A are roughly one hundred thirteen million
dollars. The EPA's grant amount, at fifty-five
percent funding, would be twenty-six million
dollars, with the local share at eighty-seven
million dollars.
Estimated household
costs for existing sewer populations. Those
populations now served by package plants, are
roughly a hundred and fifty dollars a year.
01
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1 Those existing unsewered communities would see
2 an annual costs of roughly one thousand dollars
3 per year. Combining that, for an average of
4 three hundred and sixty dollars per year.
5 Now, the discussion
6 of proposed mitigative measures will also
7 highlight some of the more significant impacts
8 associated with the preferred alternative.
9 Looking on the last page of the outline form of
10 the handouts.
11 The first involves
12 archaeological/historical sites. The
13 installation of several interceptor lines may
14 affect sites on the National Register of
15 Historic Places. For those particular
16 interceptors or interceptor segments surveys and
17 coordination with the State Historic Preservation
18 Officer and the State Archaeologist will be
19 required.
20 Floodplain impacts.
21 Flood protection measures for pump stations and
22 the North County Treatment Plant will be
23 required.
24 Wetlands. The Muddy
25 Fork wetland, located down along the lines of
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the Ohio River, any construction activity that
might involve the Muddy Fork wetland is required
to be coordinated with the Corps of Engineers as
well as with the Kentucky Nature Preserve.
Environmentally
significant agricultural lands. It is EPA's
policy to avoid the irreversible conversion of
environmentally significant agricultural lands
to other uses, to other non-agricultural uses.
Alternative LS2-A serves only existing
development, not future development that might
locate on these lands. Certain interceptors,
however, may pass through agricultural lands,
prime agricultural lands. In that case it is
recommended that those lands be returned to
pre-construction conditions.
Endangered species.
There may exist areas along the interceptor
segments that contain species of local concern
or potential habitats of endangered species.
In that case coordination with the Fish and
Wildlife Service and the Kentucky Nature
Preserve are required.
Natural areas. Two
particular areas, the Muddy Fork wetland and
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1 Lower Goose Creek Valley, are being studied by
2 the Kentucky Nature Preserve for possible
3 designation as state preserves. Coordination
4 with the Kentucky Nature Preserve is therefore
5 required.
6 Additionally, as part
7 of the EIS we conducted environmental surveys of
8 interceptor segments and noted many natural
9 features along the creek basins for which
10 specific mitigation actions are recommended and
11 these are detailed in the EIS, Draft EIS.
12 And, finally, Park
13 areas. Two parks, Hounz Lane Park and E. P.
14 Sawyer Park will be crossed by interceptors. It
15 will be required that appropriate state and
16 local agencies be consulted concerning these
17 park crossings.
18 Now, as a final note,
19 I would like to point out that during the
20 preparation of the EIS we did establish -- the
21 EIS review committee that was composed of many
22 citizens in the area, representatives of many
23 fifth and sixth class cities in the study area,
24 representatives of local agencies, state
25 agencies, environmental groups -- these people
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have worked with us throughout the years of this
EIS in attending meetings, reviewing reports,
providing us with comments and spending a good
deal of their time involving themselves in this
project. Many of these people are here this
evening and I would like to personally thank
those who were involved in the committee for
their efforts, their time, their patience and I
hope they think the effort was indeed worth it.
That will conclude my
comments. I would like to point out that we did
provide additional copies of the Draft EIS for
those of you who did not receive a copy in the
mail. If we have run out of copies at the
registration table please see me afterwards,
provide me with your name and address and when I
get back to the office tomorrow I will put a
copy in the mail and send one on to you.
Thank you so much.
HR. ZELLER: Thank you,
Mr. Hikulak. As most of you here know, the
Environmental Protection Agency and the State of
Kentucky share jointly in the responsibility for
environmental protection in Kentucky. And next
I would like to ask Mr. Shogren to make a
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1 statement for the record.
2 MR. SHOGREN: Thank you,
3 Howard. I just have a few brief comments to
4 make.
5 Hy name is Richard
6 Shogren and I am Director of the Division of
7 Water within the Kentucky Natural Resources and
8 Environmental Protection Cabinet. I am pleased
9 to be here this evening as a representative for
10 our new Cabinet Secretary, Charolotte Baldwin,
11 and also as a representative of Hike Talmi who is
12 Commissioner of" the Department for Environmental
13 Protection.
14 The Division of Water
15 has major responsibility for establishing a
16 priority system by which federal construction
17 grants for public wastewater treatment projects
18 are passed from EPA to local communities.
19 Federal construction grants are authorized under
20 the National Clean Water Act.
21 As discussed in the
22 EIS Summary, certain major changes occurred in
23 1981 which will have an impact on the amount of
24 Federal assistance that is available for any
25 future public wastewater treatment projects.
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The major financial impact will be a reduction
in the federal share of construction costs from
seventy-five percent to fifty-five percent for
all projects approved after September 30th,
1984.
Currently, Kentucky
receives thirty-one point one million dollars in
Federal assistance per year which can be used as
a part of the Federal Constructions Grants
Program. While this is a substantial amount of
money, Kentucky had available more than three
times that amount of money in 1976 and twice as
much money in 1978 and '79. Also, the indicated
statewide needs for wastewater treatment
facilities that are summarized in this annual
document, which is produced by the Division of
Water and Cabinet, the indicated statewide --
the needs that appeared on this year's
construction grants priority list were six
hundred and sixty-four million dollars.
Compared to these numbers the annual allocation
is a small amount of money. The current
Construction Grants list provides approximately
twenty million dollars per year to large
communities in the state for wastewater
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treatment facilities.
The North County Waste-
water Treatment System is ranked as the seventh
most importan project on the current priority
list with proposed funding beginning in 1987.
However, this f'inring schedule is based on three
higher priority p ejects being funded at a
fifty-five percent level after October 1st,
1984. These ttree projects — the Louisville
Metropolitan Sewer District's Morris Forman
Project, the West County Treatment Plant and the
Lexington-Fayette County Urban Government Town
Branch Plant may be eligible for seventy-five
percent EPA participation as continuation
projects initiated in 1984. If these projects
are funded at seventy-five percent funding and
if the current allocation of federal funds to
large communities continues at a level of
approximately twenty million dollars per year,
the North County Project would not be eligible
for Federal funding prior to 1990. This also
assumes that the current estimated cost of these
three major projects will not increase.
Jefferson County faces
major issues today in expanding its wastewater
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treatment facilities. The 1970's approach of
depending on available Federal funds will be a
difficult course to pursue given the reductions
that have occurred in recent years and the other
demands which exist within the State of
Kentucky. Careful consideration should be given
to the desirability of waiting for Federal
funds, which may be six years away from being
available, and the relative needs for wastewater
facilities in North Jefferson County given the
growth potential of this part of the county.
Division of Water is
ready, willing and able to provide whatever it
can in the way of technical assistance to
Jefferson County in terms of implementing and
reaching a decision on the schedule for needs
within the county.
Thank you very much.
MR. ZELLER: Thank you,
Mr. Shogren.
Before I go ahead and
accept testimony from the floor, let me make
sure that all of you present here have
registered as you came in. It's important that
we have a record of the meeting so that you can
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1 be notified of the action that follows this
2 meeting and also, of course, if you wish to
3 speak we use the cards to identify the speakers.
4 So that everyone has
5 an opportunity to epeak, I'd like to ask all of
6 the speakers to limit their testimony. If you
7 have a long written testimony, please submit
8 that for the record and try to summarize your
9 remarks.
10 As we proceed with
11 the hearing. I will generally try to call on
12 speakers in the order in which you registered.
13 And with this as a way of background, let me
14 start off by asking our first speaker, Mr.
15 Stephen Hubbs. All speakers I would ask to
16 appear at the podium, state your name for the
17 record and if you represent any particular group
18 or represent yourself, please indicate so.
19 Mr. Bubbs, we're
20 pleased to have you here today.
21 MR. HUBBS: Thank you,
22 Mr. Zeller.
23 My name is Steve Bubbs
24 and I am a Staff Engineer with the Louisville
25 Hater Company.
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1 I will be brief. There
2 hat. been a written statement nailed to the
3 Atlanta Office.
LWC-I * First, the Louisville
5 Hater Company favors any action that would
6 result in a decrease in any stream dischargee of
7 wastewater. This implies that we favor the I>S2
8 type of option. But the concenpt of exactly how
9 that solution to the problem is defined comes
10 about is something that I question.
LWc-2 11 First, it seems that
12 the favoring of LS2-/V over LS2-C ia one
13 primarily of funding. And I'm sensitive to that
LUC-3 14 type of a situation. But it seeme more
15 appropriate that a problem be defined first and
16 that solutions to that problem or alternate
17 solutions to that problem likewise be developed
18 and, then, baecd on the best alternative
19 solution for the problem then that n funding
20 level be sought for that type of problem.
21 It scene that in
22 this case there has been e level of funding
23 defined and then working backwards from that
24 point to a solution that fits that level of
25 funding, which, to me, ie not good, sound
LWC-1.
Comment noted.
LWC-2. The amount of federal funding would be the same for LS2a
and LS2c due to the 1981 change in the Clean Water Act regarding
the construction grants program.
i.WC-3. The problem was defined first in the draft Project
Background and Environmental Inventory Report published in
September, 1980. Alternate solutions were then developed in the
draft Alternatives Development Report published In January, 1981.
The cost-effectiveness was determined for each alternative in the
draft Alternatives Evaluation Report published in June, 1981.
The most cost-effective alternative was selected in the draft
Frefered Alternative Report published in July, 1983. Federal
funding was not considered during the cost-effectiveness analysts.
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1 engineering or good, sound planning.
2 That's basically the
3 comments that we had. We do have a little bit
4 of data that may not have been available to EPA
5 regarding bacterial quality on Goose and
6 Harrod'E Creek which we have accumulated over
7 the past couple of years and this information
8 has been provided.
9 Thank you.
10 MR. ZELLER: Thank you.
11 We appreciate your comments and, as I indicated
12 earlier, comments that we receive at this
13 hearing tonight and those that are submitted to
14 us in writing will be responded to in the final
15 Environmental Impact Statement and we appreciate
16 your comments.
17 Next, I'd like to call
18 on Tom Pryor.
19 MR. PRYOR: I would
20 like to yield at this time to the next speaker.
21 MR. ZELLER: All right,
22 sir.
23 The next speaker that
24 I would have is Doctor Carl Sturm.
25 DOCTOR STURM: Just a
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1 very brief statement, observation, what have
2 you.
DCS-I 3 The priorities
4 puzzled me. When I see these areas that have
5 had this situation for twenty, twenty-five,
6 thirty, thirty-five, forty years and why they
7 fall so low on the priority list, it boggles my
8 mind. And the other observation: Out in the
ocs-2 9 triangle between LaGrange Road, Hounz Lane and
10 Whipps Hill Road, they have been trying to get
11 scattered site housing there, and so finally
12 they have been building these houses and all of
13 a sudden a sewer comes through -- of some
14 description, I don't know what -- and I don't
15 know where it's going. I don't know who
16 evaluated the situation, whether you folks did
17 it or whom. But it is puzzling to me why
18 taxpayers that have been living in that locality
19 for fifteen, twenty, twenty-five, thirty years
20 are having scattered site housing, but they are
21 helping to subsidize and these people are
22 getting sewers and the people who have been
23 sitting there all those years are being
24 bypassed. To me that is absolutely inexcusable.
25 MR. ZELLER: Thank
DCS-1. The Kentucky Natural Resources and Environmental
Protection Cabinet creates the priority list for construction
grants.
DCS-2. Local agencies establish priorities for sewering
specific neighborhoods.
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you. I think that's an issue that probably
could be most appropriately addressed to the
Metropolitan Sewer District. Right at this
point in time I have no comment that I can make
on that. I would comment generaly relative to
the need for Construction Grants Funds. As you
know, the federal government has appropriated
for a number of years a flat amount of two point
four billion dollars annually for the
Construction Grants Program nationally and a
great many of the taxpayers dollars have gone
into these kinds of programs and the need still
exists and we continue to see the need and we will
for sometime. I share your concern on funding
as I know the State of Kentucky does, but we
continue to outstrip needs with dollars and
continue to work on that.
Thank you for your
comments.
is Mr. Neal Webster,
The next speaker I have
MR. WEBSTER: I am just
representing myself tonight. And I would like
to go on the record of encouraging the local
agencies to consider the further alternative of
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Comment noted.
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uw-1 I 1 building in for growth at this time. The
2 additional cost at this time see'ms more cost
3 effective than building another plant or
4 expanding another plant at some future time.
5 That's my only comment.
6 MR. ZELLER: Thank you,
7 Mr. Webster. That is a very appropriate
8 comment.
9 The next speaker I
10 have is Mr. K. C. Tsai with the University of
11 Louisville.
12 MR. TSAI: I speak
13 from my personal point of view. I am not
14 representing University of Louisville.
15 MR. ZELLER: I don't
16 believe we can hear you. Can you get a little
17 closer to the microphone and speak a little
18 louder, please.
19 MR. TSAI: I am
20 speaking from my personal standpoint. I am not
21 representing University of Louiville.
22 Can you hear me
23 all right now?
24 MR. ZELLER: Yes.
25 MR. TSAI: I have
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KCT-2
KCT-3
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1 two question. Number one is the 201 alternative
2 in the Draft is eliminated from consideration
3 simply because it didn't include some future
4 growth. My question here is: Can the 201
5 Alternative be designed based upon existing
6 population and/or the population of 1990 so that
7 it will be eligible for Federal funding? That
8 is my first question.
9 My second question
10 is: Can the Bite Creek Treatment Plant can be
11 used to handle some of the flow to the regional
12 treatment plant so that the cost of regional
13 treatment plant would be less?
14 MR. ZELLER: Thank
15 you. Thank you for your comments and your
16 questions. I am not going to try and respond to
17 those now. I don't think it is appropriate to
IB try to do that. He will respond to those in
19 the EIS that I indicated. I would suggest on
20 the kinds of questions that you asked, after
21 the hearing is over, if you come forward and
22 discuss those with Mr. Hikulak and with Mr.
23 Shogren, I think we have answers to those
24 questions.
25 MR. TSAI: Okay.
OS
KCT-1. The 201 alternative Includes capacity in the regional
sewec system for future growth and was considered. It Is a
local decision whether or not to build the 201 alternative.
Federal funds would be available only to the extent that
they would also be for the LS2a alternative.
KCT-2. Yes, that Is the LS2a alternative.
KCT-3. The Kite Creek treatment plant would have to be
expanded In order to treat sewage from the North County
regional plant service area. Sewage treated at the Hlte
Creek plant requires advanced treatment, whereas secondary
treatment is sufficient at the North County plant. Also,
flows from the North County plant's service area would have
to be pumped to the Hlte Creek plant. All of these factors
would make treatment at Hlte Creek more costly than
treatment at North County.
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LWV-1
37
1 MR. ZELLER: The next
2 speaker I have is Sylvia Watson.
3 MS. WATSON: I yield
4 my time.
5 MR. ZELLER: Thank
6 you.
7 The next speaker
8 I have is Patricia Nightingale.
9 MS. NIGHTINGALE:
10 I think I am going to say something after Ron's
11 kind remarks about helping with citizen input.
12 My name is Patricia Nightingale and I am
13 representing the League of Women Voters. We are
14 interested in citizen input and it has — we
15 believe that EPA has tried to put together a
16 citizen participatory process with these two
17 EIS's, the Mill Creek and the North County.
18 It's a little hard for me to separate them since
19 they both impact so heavily upon our county. So
20 I'd like to say just a little bit about both of
21 them.
22 As everybody
23 probably understands or may understand from Mr.
24 Shogren's remarks that this EIS is not so much
25 an environmental study as a revision of the
du;."V-l. See next page)
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LWV-1 1 county's Federal funding eligiblities, we
2 believe.
3 We did have a 201
4 --a master plan in Jefferson County. The 1964
5 master plan that Jefferson County was following,
6 which was with some revision after the Clean
7 Hater Act changed into the 201 study, which was
8 approved by local government, by the state and
9 by EPA in 1975.
10 In 1977 with that
11 decision to do the Mill Creek EIS that plan was
12 effectively suspended.
13 I'd like to read
14 to you what this present EIS — if you don't
15 have your full copy — has to say about the 201
16 Plan.
17 It says, "On the
18 201 alternative construction funding will be
19 split between EPA and local government with EPA
20 providing a greater share than for any other
21 alternative. Public health risks will be
22 virtually eliminated as septic tanks and small
23 treatment plants are abandoned. This
24 alternative has greater technical reliability
25 than the others. This alternative is probably
oo
LWV-1. An act of Congress revised federal funding eligibility;
the EXS recognizes these changes In the Clean Water Act.
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1 the most acceptable to the local public. it has
2 the strong endorsement of local agencies and the
3 government."
LWV-2 4 However, despite those
5 kind words, since 1977 for seven years EPA has
6 spent nearly a decade in wrecking this county's
7 master plan virtually beyond repair. In 1977
8 the Mill Creek EIS was begun. It was completed
9 two years ago with mixed results for Mill Creek
10 citizens. Citizens who were concerned about
11 spending money for sewers which the perceived
12 that they did not need were told that they would
13 not have to suffer the disruption of sewers
14 being built in their areas or to pay for those
LWV-315 sewers. That was the good news. The bad news
16 was that the underground aquifer was virtually
17 written off. It is described on Page 122 of
18 this current study as one of the major ground
19 water resources in the United States. Citizens
20 who have wells in southwest Jefferson County
21 were told that they would have to hook up to
22 Louisville Water Company water, they wanted safe
23 drinking water, because there will be future and
24 increasing pollution of that aquifer There
25 will continue to be pollution of the surface
LWV-2. The North County EIS did not change the 201 plan, which
can still be implemented by local agencies.
LWV-3. Through the Mill Creek EIS, it was determined that
groundwater in southwestern Jefferson County was influenced
by septic tank use, but that it is still usable as a treated
drinking water source. EPA has neither the authority nor
the intention of "writing off" the aquifer.
Os
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1 streams from septic tank seepages and from the
2 dischargee of package treatment plants in those
3 areas.
4 Now, the North
5 County. What have we come up with after five
6 years in North County from 1979 to 1984? Here
7 is the Preferred Plan and this is what the study
8 says: "Construction funding will be split
LHV-4 9 between EPA and local government. EPA share
10 will be intermediate between LSI and 201.' That
11 needs a little translation. What that means is
12 that EPA's share of funding will be enormously
13 reduced. To continue quoting, "Local
LWV-5 14 enforcement activities for small plants will
15 decrease to ten to forty percent of existing
16 needs." What does that mean? Translation is
17 needed. Instead of forty-nine small area
18 package treatment plants it's figured that with
19 growth in the area as of this Preferred Plan
20 there will be nineteen small area plants. So
21 the Health Department will only have to worry
22 about forty percent as many malfunctions as we
23 currently have. Also, only the people who live
24 along Harrod's Creek. Goose Creek and Little
25 Goose Creek will get most of the stream water
LWV-4. The sumarles quoted here dace froa the draft Alternatives
Evaluation Report published in 1981 and sinply state the facts
applicable at that time. Since then the Clean Hater Act has
been changed so that the use of federal funds for conveyance or
treatment capacity beyond that necessary to serve existing needs
at the tine of grant award, or 1990, whichever cones first, is
prohibited. The level of federal funding for the LS2a, LS2c, or
201 alternative would be the sane under the new law.
LWV-5. There are 48 existing small-area plants, of which only 6
would reaiain under the LS2a alternative; only one of these dis-
charges to Goose Creek, Little Goose Creek, or Harrods Creek,
and that discharge is only 6,000 gallons per day. Whether or
not there will be future snail-area plants is a local decision,
and enforcement would be up to the local Health Department.
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LWV-6
41
1 pollution problems. Therefore, we have the next
2 sentence, I guess, which says: "Public health
3 risks from package plants and septic tanks will
4 be greatly reduced or eliminated." I think that
5 depends on where you live. "This alternative is
6 intermediate..." To continue quoting "This
7 alternative is intermediate in technical
8 feasibility between no Federal action and the
9 201. This alternative is probably intermediate
10 in public acceptance between no Federal action
11 and the 201." So after five years of study and
12 some four hundred and ninety thousand dollars,
13 we're getting a less attractive plan with less
14 Federal funding. We have a generally
15 meaningless unuseable plan with no new
16 information since 1977 except reported changes
17 in the Clean Water Act funding, which we could
18 have read for much less money.
19 This is an
20 especially frustrating example of how the EIS
21 process ought not to work or how surely it's not
22 suppose to work. It is true that the US
23 taxpayer has been spared the burden of paying to
24 help solve Jefferson County's health and
25 environmental problems. We can't blame all of
L.WV-6. No previous plans have contained any commitments of
federal funds for the North County area; it cannot, be said,
therefore, that the funding for LS2a is less than anything.
LWV-7. EPA has not revised the 201 plan. The 1981 Clean Water
Act amendments are important new facts concerning federal funding.
LWV-8. This EIS has had no effect on what the U.S. Taxpayer
has paid toward construction grant funding during this EIS
process. The amount of funds provided for Kentucky has also
not been affected by the EIS. These funds are spent according
to the State's priority list. Even if the EIS had been com-
pleted earlier, the project's position on the priority list is
such that construction grant funding is not expected until
after 1987. Furthermore, this EIS has not prevented local
agencies from taking actions with local funds.
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LUv-8 1 those on EPA. But, at the same time, the local
2 government and citizens have largely been
3 prevented fot seven years from taking any
4 substantial actions to solve our own problems.
5 Without a viable plan to follow, no doubt
6 community agencies will in retrospect be found to
7 have made many unwise decisions regarding future
8 development.
LWV-9 9 The master plan that
10 we have been following since 1964 has been
11 suspended and is no longer possibly reparable.
12 During these years, while nearly one million
13 federal dollars have been spent in paying for
14 the two EIS's, we've been given nothing very
IS practical or useful to replace it. Incredibly
16 the county is being faced now with the necessity
17 of doing its own study, of trying to salvage
18 some pieces of the destroyed plan and of finding
19 a practical replacement for long-range community
20 planning.
Lwv-lo21 Surely NEPA and the
22 Clean Water Act were never intended to sabotage
23 the efforts of a community which was trying to
24 follow a practical, technically feasible,
25 affordable, long-range plan to solve its
LWV-9. The Mill Creek and North County EISs address the existing
water quality problems of the community. The selected alterna-
tives of the EISs propose practical and useful wastewater
management approaches within the framework of current legislation.
Long-range community planning Is not an objective of the EIS
process, but It is a responsibility of local authorities.
LWV-10.
EPA concurs.
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LWV-11
LWV-12
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LWV-14
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environmental and health problems; a county
trying to provide for its future growth in a way
that would avoid repeating its mistakes and
creating similar problems in the future. But
that's what's happened to Jefferson County and
let's not neglect to tell it the way it has
really happened. It has saved Federal dollars,
as intended by Congress, in revising the Clean
Water Act. But this EIS has not given us a plan
that is needed for managing environmentally
sound growth in our community. It is not as
technically feasible as the plan that we once
had. It is not as affordable as the plan that
we once had. It does not protect public health
or the environment as much as the plan that we
once had. After seven interminable years and
nearly one million dollars it's discouraging to
realize that in our county, the Environmental
Protection Agency has been the single greatest
force during that time which has been working
against positive solutions to our environmental
and health problems, those problems associated
with wastewater disposal within this county.
Truly we have discovered that we cannot afford
this kind of environmental protection.
LWV-11. Long-range planning for environmentally-sound growth is a
local responsibility and was never an objective of the EIS.
LWV-12. The decreased feasibility of the LS2a alternative relates
to the number of future small-area treatment plants assumed to
occur if the 201 system is not built. Whether the small plants
or the 201 system is built is a local decision.
LWV-13. The LS2a alternative is more affordable than the 201
alternative, as shown in Table 52 of the draft EIS.
LWV-14. The LS2a alternative eliminates existing public health and
environmental problems. Planning for future environmental
protection is a local responsibility.
00
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1 (Applause)
2 MR. ZELLER: Thank you.
3 The next speaker is Mr. Ralph Williams.
4 MR. WILLIAMS: I don't
5 think there is no further comments necessary.
6 MR. ZELLER: The next
7 speaker I have, I believe, is — Winnie Hepler,
8 indicated perhaps who wanted to make a
9 statement. Have I read the name right?
10 MS. HEPLER: Yes. As
11 usual, I generally support what EPA is trying to
12 do. I think you are trying to salvage a
13 situation that has been created by local
14 politicians and developers and I think you're
15 trying to make the best of a bad situation and I
16 think the Preferred Alternative is the best we
17 can hope for, probably, considering the
18 economics of the day. I really appreciate the
19 great care the Impact Statement has given to the
20 environment and coordination with the Nature
21 Preserves people and Park people and I hope that
22 the local agencies will honor those when it
23 comes time to do the building.
WH-1 124 And, where do we
|25 go from here? I mean, is it just a matter now
(WH-1. See next page.)
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of waiting until the State, Frankfort provides
the money? I mean, and will it — I mean, what
I'm trying to get it is EPA going to keep after
us to improve the water quality or is it going
to sit back and wait now? Could you tell me
that?
MR. ZELLERj Let me ask
Mr. Shogren to respond to that. I think the
issue is with the State and on their priority
list and he has already addressed that but let
me -- if he wishes to do so, let me ask him to
respond to that.
MR. SHOGREN: The
Division of Water has as its major objectives
clean water and maintaining water quality. If
we found that streams within Jefferson County
were being polluted to a degree that was
unsatisfactory we would likely take some kind of
enforcement action against the appropriate
agency, which would normally be a point source
discharger, an existing discharger. If it was
pollution that was coming from septic tanks it
could lead to some action being encouraged
through the Health Department, being declared as
a health risk. So that is, you know, that's a
WH-l. If local agencies decide to implement one of the regional
sewer systems, USD is responsible for designing the system and
applying for construction grant funds. The availability of funds
at that time will depend on federal appropriations and North
County's position on the state priority list. Also see
Mr. Shogren's comments following In the transcript.
WH-2. Primary responsibility for enforcing water quality standards
lies with the State. Also see Mr. Shogren's comments starting on
transcript page 48.
•-J
Ln
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46
1 general response as to the way we deal with
2 existing dischargers.
3 When it comes to the
4 issue of available money the simple realities
I
5 /are that in my opinion local residents can no
6 / longer depend on the Federal Government to
7 / finance a major part of the construction cost
8 for sewers. When you look at your other
9 utilities, gas and electric, water, they are not
10 financed by the Federal Government; they're
11 financed by local residents who benefit from
12 that. When you're talking about wastewater
13 treatment, unfortunately, you're talking about
14 something that people are less likely to worry
15 about unless it becomes a real health problem.
16 It's something they want to put off. It's
17 something that in the early 70's was addressed
18 at the federal level with a major program. You
19 take Mr. Zeller's comments about two point four
20 billion dollars is funded annually; that's for
21 the whole country. And the needs that we have
22 in the State of Kentucky right now are six
23 hundred and sixty million dollars. In the last
24 three, four, five years, just because of the
25 pressures that we have at the Federal level, the
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responsibility is getting turned back over to
the states or to the local residents and you
can't depend, in my opinion, on Federal dollars
to make up a major part of what your local needs
are. You can, perhaps, lobby the State; but
right now the State does not have any assistance
program. He propose that in the Division of
Hater, a simple ten percent Construction Grants
Program. But you can read in the paper as to
what the State situation is. And that's not one
of the priority items right now.
I'll go back to
my statement. There are a lot of communities in
the State of Kentucky that are looking for
Federal funds. He evaluate those needs on a
priority basis according to the amount of
pollution that they produce. It's a weighted
formula that was determined based on EPA
guidelines but essentially defined by us, went
through a public hearing and a public comment
process, and when we use that formula North
County comes out seventh. It comes out pretty
far down. But there are a lot of other smaller
communities that are much farther down. The
list A which we are talking about, twenty
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1 million dollars for large communities, there's
2 something like seventy-five communities on it
3 that have needs. Our county is quite high. It
4 is seventh. There just isn't enough money. You
5 can't continue to depend on the Federal
6 Government as a source for constructing what is
7 the need that you have for sanitary sewers.
WH-3 8 MS. HEPLER: Is there
9 going to be any renewed enforcement of the
10 pollution laws in the interim?
11 MR. SHOGREN: At the
12 national level right now there is a great deal
13 more emphasis that is being placed on
14 enforcement. As far as the State is concerned
15 we are going to be exercising a more stringent
16 enforcement policy on local governments.
17 MS. HEPLER: Wonderful.
18 Fine.
19 MR. SHOGREN: If you
20 look at the last ten years, the success that the
21 State has had has been very great, and our state
22 is not much different from other states, in
23 terms of enforcement actions against industries,
24 because industries face the threat of being shut
25 down, of having to stop producing what they are
WH-3. Primary responsibility for enforcing water quality standards
lies with the State. Also see Mr. Shogren's comments following in
the transcript.
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1 selling. When it comes to municipal wastewater
2 treatment facilities it's much more difficult,
3 it's government versus government, which is
4 always a different issue. It's difficult to
5 levy penalties because those penalties simply
6 fall back to the citizen who pays a monthly
7 sewage treatment bill. It's difficult because
8 at the Federal level alone you would have a
9 program defined that says we're going to provide
10 you money to help you solve the Construction
11 Grants problems that you have. But right now at
12 the Federal level there is a new emphasis on
13 enforcement. You're going to see a policy, an
14 enforcement policy statement coming out of State
IS government within the next three months, if not
16 sooner, that defines actions that we will be
17 taking. It's not something that can be solved
18 overnight. It's taken many years to be getting
19 into this situation but it's going to be
20 addressed in a much more open and up-front
21 fashion than has been addressed in the past.
22 HS. HEPLER: That's
23 what I wanted to hear: there will be an
24 enforcement in the interim, so that construction
25 can begin. Thanks so much.
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EJ-1
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1 HR. ZELLER: Thank
2 you very much. Mr. Fry, you indicated earlier
3 you wished to pass and your name has come up
4 now.
5 MR. FRY: I will
6 abstain.
7 MR. ZELLER: Thank you,
8 sir. Sylvia Watson, did you wish to speak?
9 MS. WATSON: No.
10 MR. ZELLER: That's all
11 of the cards that were given to me as a result
12 of the registration on those individuals that
13 wished to speak. If I have overlooked anyone,
14 why, please raise your hand and let me know. Or
15 if at this time you would like to speak, our
16 purpose on holding this meeting — yes, sir —
17 if you do speak, I would ask you to come to the
18 podium and state your name for the record,
19 please.
20 MR. JOHNS: My name
21 is ElbertJohns from the community of Northfield.
22 I had just had one question. What is the
23 attitude of the Metropolitan Sewer District
24 toward the LS2-A?
25 MR. ZELLER: We have
EJ-1. MSB considers LS2a "to be a satisfactory alternative,"
although they are concerned that federal funds may not be available
by the time grant applications are made. See the USD comment
letter in Section 5.2.
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M-l
51
1 not at this time received an official comment
2 from USD. We will hear from them as a result of
3 that proposed alternative from the EIS and that
4 will be a matter of record in the final EIS when
5 it is promulgated. But at this time we have not
6 received their official comments.
7 Is there anyone else?
8 Yes, ma'am.
9 Can I ask you to come
10 to the podium, please, and state your name.
11 Technically, we're not suppose to answer
12 questions at these. We're suppose to develop a
13 record, but I feel compelled to try to have you
14 understand as much as you can about a very
15 difficult process and we try to do everything we
16 can.
17 MS. MOLESKY: I'm
18 Mrs. Molesky of Windy Hills. You mentioned
19 before that some of the people in the affected
20 areas were in on this, helping you all. Could
21 the people be advised of who in their area was
22 helping you?
23 MR. ZELLER: The names,
24 : believe, are listed in the Draft Environmental
25 Impact Statement and I have a copy of that here
oo
o
H-1.
See response following In the transcript.
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1 which I will give you...
2 MS. MOLESKY: (In-
3 terrupting) I had never heard of anyone who was
4 in on it.
5 MR. ZELLER: The process
6 in developing an EIS is a very orchestrated and
7 organized process. It involves scoping and
8 meeting with people in the area and...
9 MS. MOLESKY: (In-
|lO terrupting) Well, was it a picked few... Mr. Zeller:
11 On Page 242 in the back of the EIS is a list of,
12 it looks to me like, of about thirty or forty
13 people who were involved.
14 MS. MOLESKY: How were
15 they chosen?
16 MR. MIKULAK: The list
17 of community members shown on Page 242 of the
18 Draft EIS shows representatives of many of the
19 fifth and sixth class cities. There were mayors
20 and the chairmen or chairpersons of those
21 communities, as well as representatives of
22 several of our environmental groups, local agencies and
23 state agencies.
24 MS. MOLESKY: None
25 of the common ordinary people who reside in the
M-l.
See response following in the transcript.
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M-l | 1 areas were consulted?
2 MR. MIKULAK: Well,~in
3 establishing a review committee such as this, we
4 try to reach as many people as we can, and in
5 those efforts in trying to reach, as you say,
6 the common citizen, ordinary citizen, it is
7 difficult to chose the people that...
8 MS. MOLESKY: (In-
M-2 9 terrupting) Because I have made contact with
10 quite a few people in just the last couple of
11 days. I have run into only one person who has
12 had any trouble with their septic tank.
13 Everybody else is satisfied.
14 MR. HIKULAK: In
15 choosing the people, though...
16 MS. MOLESKY: (In-
M-2 17 terrupting) I chose these people just at
18 random. I can choose any special ones like is
19 in here that I see.
20 MR. MIKULAK: In chosing
21 the people in representing the various cities we
22 chose the chairmen or the mayors because they
23 represent the larger const ituency and can speak
24 with the people.
25 MS. MOLESKY: Yes, but
00
to
M-l.
See response following in Che transcript.
M-2. According to documentation available at the Health
Department and from an infrared aerial survey, Windy Hills has
the third greatest septic tank failure rate in the study area:
26%. (For details see the draft Alternatives Development Report.)
Within any area there will be people who do not have or who do
not know they have problems with their septic tanks.
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M-i I 1 do they consult their people?
2 MR. MIKULAK: It's
3 their responsibility. I can't speak for whether
4 they consulted their constituents.
M-l 5 MS. MOLESKYs I don't
6 think they consulted their people and that's why
7 I am getting around. The people should have
8 been consulted. We're the ones that are
9 concerned.
10 MR. ZELLER: I totally
11 agree. And, of course, you know the process is
12 through your elected officials and I would urge
13 you to let those people know of your thoughts.
14 Is there anyone else
15 who would like to comment or make a statement at
16 this time?
17 Yes, sir?
18 MR. SAWYER: My name
19 is Cliff Sawyer. I am the mayor of the City of
20 Northfield which has some of the problems that
21 you have been talking about. I probably have
22 missed a fine point here but between the monster
23 called the Federal Government and their little
24 monster called EPA and this thing we call —
25 whatever it is -- the natural resources that has
M-l.
See response following in the transcript.
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1 a new wonderful person heading it up. Where do
2 we go, whom do we talk to to focus some of our
3 concerns? We just are in a three-ring circus
4 here. Can you tell me tonight who has got the
5 lead role to do something about putting sewers,
6 sewage systems in the North County area?
7 MR. ZELLER: I think
8 we have discussed that earlier and I think the
9 State has the lead role through their priority
10 system in establishing sewer systems for this
11 area. I think we discussed that.
-1 12 HR. SAWYER: So, Mrs.
13 Baldwin, Shogren's boss is the person to talk
14 to?
15 HR. SHOGREN: Let me
16 comment in this way. If you wish to qualify for
17 a limited amount of State dollars HSD has the
IB lead role as a contact agency through the
19 Division of Water to get those limited dollars.
20 If you are talking about wanting to do someting
21 in a shorter time frame than the kinds of time
22 frames that I have indicated, the burden is on
23 you. It's on you as a local citizen who has
24 concerns for seeing improvements because you
25 have a water pollution problem. Now that falls
oo
CS-l.
See Mr. Shogren's response following in the transcript.
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1 back on local agencies. In Jefferson County you
2 have a Metropolitan Sewer District which is
3 committed to provide certain services out to the
4 existing limit and ultimately to serve major
5 parts of other portions of Jefferson County.
6 That's the agency to contact.
7 On the other hand, you
8 may have a local package treatment plant that
9 serves your unit that's not properly being
10 operated. If it's not properly being operated
11 you can go to the local Health Department or
12 you can come to the State Division of Water
13 and we will take enforcement action to make
14 sure it's properly operated.
15 Thank you.
16 MR. SAWYER: Who do we
17 talk to about putting into action and getting
18 done your program LS2 or whatever it is? Who
19 does that? MSD? You People? EPA?
20 MR. SHOGREN: The LS2
21 Option would be something that would be handled
22 by a regional sewer district which in Jefferson
23 County is right now the Metropolitan Sewer
24 District.
25 MR. ZELLER: Thank
CS-1.
See Mr. Shogren's response following in the transcript.
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you very much. This has been, I think, a good
hearing and an interested group and an involved
group. Is there anyone else at this time that
would like to make a statement?
If not, I will close
the hearing. As I indicated earlier, the
hearing record will remain open until February
29. Any written comments that we receive will
be considered as a part of the record and they
should be sent to Ron Hikulak. His name appears
on the handout that you received earlier and the
address is at the bottom of that agenda.
We thank all of you
again for your participation in the hearing.
Comments received this evening and during the
comment period will be carefully considered and
responded to in the final Environmental Impact
Statement. And the final EIS will consist of
the Agency's final decision, a summary of the
Draft EIS and any pertinent additional
information or evaluation developed since
publication of the Draft, revisions to the
Draft, comments received and EPA's responses and
the transcript of this hearing.
Those of you who
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commented tonight or submit written comments
will receive a copy of the final Environmental
Impact Statement.
Thank you again for
your attendance and your participation. The
panel will remain here for any questions if
anybody would like to come and ask those.
Thank you again.
I consider this hearing closed.
(MEETING ADJOURNED)
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STATE OF KENTUCKY )
) SS
COUNTY OF JEFFERSON )
I, ALICE J. BALLARD, a Notary Public
(Court Reporter) within and for the State of
Kentucky at Large, do hereby certify that the
foregoing DRAFT EIS PUBLIC HEARING was taken
before me at the time and place as stated in the
caption? that the said proceedings were taken
down by me in stenographic notes and afterwards
transcribed by me; that it is a true, correct and
complete transcript of the said proceedings so had;
that the appearances were as stated in the caption.
-> *?
WITNESS MY SIGNATURE this the „_'_ day of
February, 1984.
MY COMMISSION EXPIRES: August 14, 1984.
ALICE j. MALLARD
NOTARY PUBLIC
COURT REPORTER
State of Kentucky at Large
00
-------
88
5.2 Written Comments
The hearing record remained open through February 29, 1984, to
receive written comments. Letters were received after that date, but
all comments have been included here. Table 7 is an index to the written
comments, and Table 8 summarizes the general subjects mentioned by each
commentor. The comment letters and EPA's responses begin on page 96.
-------
TABLE 7. INDEX TO WRITTEN COMMENTS ON NORTH COUNTY DEIS
COMMENT
CODE
PAGE(S)
COMMENTOR
NATURE OF COMMENTS
SCS-1.
SCS-2.
96
U.S. Department of Agriculture, Soil
Conservation Service
U.S. Department of Agriculture, Soil
Conservation Service
LWC-1 .
LWC-2.
LWC- 3 .
LWC-4.
LWC- 5.
LWC- 6.
LWC- 7.
LWC- 8.
EP-1.
EP-2.
KHC-1.
KHC-2 .
KHC-3.
KHC-4 .
97
97
98
98
98
98
98
98-99
110
110
111
111
111
111
Louisville Water Company
Louisville Water Company
Louisville Water Company
Louisville Water Company
Louisville Water Company
Louisville Water Company
Louisville Water Company
Louisville Water Company
Eugenia Palmer
Eugenia Palmer
Kentucky Heritage Council and
The State Preservation Office
Kentucky Heritage Council and
The State Preservation Office
Kentucky Heritage Council and
The State Preservation Office
Kentucky Heritage Council and
The State Preservation Office
HB-1. 112 Mrs. H. Blair
USPHS-1. 113 U.S. Public Health Service
USPHS-2. 113 U.S. Public Health Service
USPHS-3. 113 U.S. Public Health Service
Quantification of farmland impacts
Soil erosion
Future deterioration of stream quality
Deterioration of groundwater quality
Stream water quality data
Supports LS2c alternative
Funding should not determine solution
Wastewater discharge effect on water quality
Prefers discharge location B in mid-river
Consider chlorination effects
Interim repairs to small-area plants
Septic tank maintenance
Provide preliminary archaeological report
Further assessments of archaeological
properties
Apply National Register criteria
Consult with Advisory Council
Needs sewers in Devondale
On-site systems maintenance
Effect on wells from on-site systems
Regional treatment plant impacts
oo
-------
TABLE 7. (Cont.)
COMMENT
CODE
LWV-1.
LWV-2.
LWV-3.
LWV-4.
LOT- 5.
LWV-6.
LOT- 7.
LWV-8.
LOT- 9.
LWV-10.
LWV-1 1.
LWV-1 2.
LWV-1 3.
LW-14 .
LWV-1 5.
LWV-16.
LWV-1 7.
LOT- 18.
LWV-1 9.
LWV-20.
LOT- 21.
COE-1.
COE-2.
COE-3.
LJCPH-1.
LJCPH-2.
PAGE(S)
114
114
114
114
114
115
115
115
115
115
115-116
116
116
116
116
116
116
116
116
116
116
117
117
117
118
118
COMMENTOR
League of Women Voters
League of Women Voters
League of Women Voters
League of Women Voters
League of Women Voters
League of Women Voters
League of Women Voters
League of Women Voters
League of Women Voters
League of Women Voters
League of Women Voters
League of Women Voters
League of Women Voters
League of Women Voters
League of Women Voters
League of Women Voters
League of Women Voters
League of Women Voters
League of Women Voters
League of Women Voters
League of Women Voters
U.S. Army Corps of Engineers
U.S. Army Corps of Engineers
U.S. Army Corps of Engineers
Louisville and Jefferson County
Department of Public Health
Louisville and Jefferson County
Department of Public Health
NATURE OF COMMENT
Federal funding is EIS's major concern
Defines cost-effective and environmentally
sound
Quality of 1974 201 plan vs. LS2a
1974 201 study re-affirmed 1964 Master Plan
EPA has wrecked the 201 plan
Mill Creek EIS
North County 201 revision
EPA's share of funding
Small-area treatment plant malfunctions
EPA's plan less attractive, meaningless,
and outdated
EIS prevented local action
Cost increase during EIS preparation
EPA chose federal dollar cost-effectiveness
This EIS is useless
Intent of NEPA and Clean Water Act
The EIS lost more than it saved
Spending of federal, state, and local dollars
Long-range planning
Technical feasibility of selected alternative
Af fordability of the selected alternative
Public health and environmental protection
Corps of Engineers projects
Interceptor design and construction alternatives
Corps of Engineers permit requirement
Material benefit to the community
Community support
-------
TABLE 7. (Cont.)
COMMENT
CODE
LJCPH-3.
LJCPH-4 .
LJCPH-5.
LJCPH-6.
LJCPH-7.
NREP-1 .
NREP-2.
NREP-3.
NREP-4 .
NREP-5.
NREP-6.
NREP-7.
KNPC-1 .
KNPC-2.
OSA-1.
OSA-2.
OSA-3 .
PAGE(S)
119
119
119
119
119
120
121
121
121
121
121
121
122
122
123
123
123
COMMENTOR
Louisville and Jefferson County
Department of Public Health
Louisville and Jefferson County
Department of Public Health
Louisville and Jefferson County
Department of Public Health
Louisville and Jefferson County
Department of Public Health
Louisville and Jefferson County
Department of Public Health
Kentucky Natural Resources &
Environmental Protection Cabinet
Kentucky Natural Resources &
Environmental Protection Cabinet
Kentucky Natural Resources &
Environmental Protection Cabinet
Kentucky Natural Resources &
Environmental Protection Cabinet
Kentucky Natural Resources &
Environmental Protection Cabinet
Kentucky Natural Resources &
Environmental Protection Cabinet
Kentucky Natural Resources &
Environmental Protection Cabinet
Kentucky Nature Preserves Commission
Kentucky Nature Preserves Commission
Office of State Archaeology
Office of State Archaeology
Office of State Archaeology
NATURE OF COMMENT
Failing septic tanks
Growth and urban development
PL92-500
Reduced federal funding
Future growth and development
Sludge management
Shively Wastewater Treatment Plant
Revision
Discharge limits for small-area treatment
plants
Morris Forman Wastewater Treatment Plant
Revision
Supports LS2a alternative
Impacts and mitigative measures
Interceptor corridors
Archaeological surveys
Historic archaeological resources
Grumet and Mistovich reference
-------
TABLE 7. (Cont.)
COMMENT
CODE
PAGE(S)
COMMENTOR
NATURE OF COMMENT
KDH-1.
MSD-1.
MSB-2.
MSB-3.
MSB-4.
MSB-5.
MSB-6.
MSB-7.
MSB-8.
MSB-9.
MSD-10.
MSD-11.
MSD-12.
MSU-13.
MSB-14.
124
125
126
126
126
126
126
126
126
127
127
127
127
127
127
Kentucky Transportation Cabinet,
Department of Highways
Louisville and
Metropolitan
Louisville and
Metropolitan
Louisville and
Metropolitan
Louisville and
Metropolitan
Louisville and
Metropolitan
Louisville and
Metropolitan
Louisville and
Metropolitan
Louisville and
Metropolitan
Louisville and
Metropolitan
Louisville and
Metropolitan
Louisville and
Metropolitan
Louisville and
Metropolitan
Louisville and
Metropolitan
Louisville and
Metropolitan
Jefferson County
Sewer Bistrict
Jefferson County
Sewer Bistrict
Jefferson County
Sewer Bistrict
Jefferson County
Sewer District
Jefferson County
Sewer Bistrict
Jefferson County
Sewer Bistrict
Jefferson County
Sewer Bistrict
Jefferson County
Sewer Bistrict
Jefferson County
Sewer District
Jefferson County
Sewer Bistrict
Jefferson County
Sewer Bistrict
Jefferson County
Sewer Bistrict
Jefferson County
Sewer Bistrict
Jefferson County
Sewer Bistrict
Transportation facilities
Level of federal grant funding
Netherton Place development
Shively Wastewater Treatment Plant
Erratum
Revision
Revision
Revisions
Erratum
Revision
Errata
Revisions
Running Creek Wastewater Treatment Plant flows
On-site systems impact
Errata
-------
TABLE 7. (Cont.)
COMMENT
CODE
MSD-15.
MSD-16.
MSD-17.
MSD-18.
MSD-19.
MSD-20.
DOI-1.
DOT-2.
DOI-3.
PAGE(S)
127
128
128
128
128
128
129
129
129
COMMENTOR
Louisville and Jefferson County
Metropolitan Sewer District
Louisville and Jefferson County
Metropolitan Sewer District
Louisville and Jefferson County
Metropolitan Sewer District
Louisville and Jefferson County
Metropolitan Sewer District
Louisville and Jefferson County
Metropolitan Sewer District
Louisville and Jefferson County
Metropolitan Sewer District
U.S. Department of Interior
U.S. Department of Interior
U.S. Department of Interior
NATURE OF COMMENT
Household costs
Kite Creek Wastewater Treatment Plant flows
Interceptor lengths
Errata
Revisions
Archaeological surveys
Mineral resources
Septic tank abandonment
Resource category 2 mitigation
-------
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AGRICULTURAL LAND/SOILS
SURFACE WATER/
GROUNDWATER QUALITY
SMALL-AREA TREATMENT
PLANT/SEPTIC TANKS
HISTORIC/ARCHAEOLOGICAL/
RECREATIONAL RESOURCES
FUTURE GROWTH/PLANNING
CONSTRUCTION GRANTS/
FEDERAL FUNDS
1964 MASTER PLAN/
1975 201 PLAN
COST
NEPA/CWA
PERMITS
SUPPORTS LS2a
IMPACTS/MITIGATIVE MEASURES
MINERAL RESOURCES
SUPPORTS SEWERS
ERRATA/REVISIONS
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SMALL-AREA TREATMENT
PLANTS/SEPTIC TANKS
HISTORIC/ARCHAEOLOGICAL/
RECREATIONAL RESOURCES
FUTURE GROWTH/PLANNING
CONSTRUCTION GRANTS/
FEDERAL FUNDS
SUPPORTS LS2c
1964 MASTER PLAN/
1975 201 PLAN
COST
NEPA/CWA
PUBLIC HEALTH
COMMUNITY SUPPORT
PERMITS
SUPPORTS LS2a
IMPACTS/MITIGATIVE MEASURES
MINERAL RESOURCES
ERRATA/REVISIONS
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-------
LOUISVILLE WATER COMPANY
•435 SOUTH THIRD STREET • LOUISVILLE, KENTUCKY 4O3O2
5O2- 582-2431
February 6, 1984
Ronald J. Mikulak, Project Officer
Environmental Assessment Branch
EPA, Region IV
345 Court land Street, N.E.
Atlanta, Georgia 30365
Re:
EPA-R,- '.' :•:.
ATLANI; . '- •
Draft U.S. E.P.A. Environmental Impact
Statement for North Jefferson County
Kentucky Wastewater Facilities of
December 1983
Dear Sir:
The Louisville Water Company engineering staff has reviewed the EIS for
the north county waste water treatment facilities.
From a public water supply point of view, the concept of problems in the
north county area differs somewhat from those from a general sanitary view
LWC-1 point. Deterioration of stream quality in Goose Creek and Harrods Creek can
result in a subsequent deterioration in water quality at the Louisville Water
Company Crescent Hill water intake structure. This problem would be expected
to be caused by failing septic tanks and improperly operated package
treatment plants. Noting that the north county area is identified as the
primary growth area for Jefferson County in the next 20 years, the problem
with future deterioration of stream quality would likely be magnified unless
remedial action is taken.
LWC-2 A secondary problem that affects the potential utilization of water
resources available to the Louisville Water Company involves inappropiate use
of the aquifer between the B. E. Payne Plant and the Crescent Hill Plant.
Although this aquifer is not currently used for water supply, several
investigations into this potentially useful source of water in recent years
indicates the interest that the Louisville Water Company has in the aquifer.
As has been discussed with Jefferson County Public Health officials in the
past, the Louisville Water Company would like to retain this stretch of the
aquifer for a possible future water supply. Thus, any actions taken that
would result in a planned deterioration of water quality in this aquifer
should be discouraged.
The Louisville Water Company has accumulated water quality data on the
Ohio River over an extensive time period. Data provided graphically in the
LWC-1.
Remedial action to correct existing problems Is provided
by the LS2a alternative. Wastewater management planning for
future growth is a local responsibility.
LWC-2.
The selected alternative does not take any actions that
would result in a planned deterioration of water quality in
this aquifer. For the selected alternative, eKisting wastewater
management systems in the area between the B.E. Payne plant and
the Crescent Hill plant will be sewered by the regional system.
Discharges to the groundwater from failing septic tanks will be
virtually eliminated by the LS2a system. Wastewater management
for future growth is a local responsibility.
-------
LWC-3
LWC-4
LWC-5
LWC-6
LWC-7
LWC-8
Appendix indicates that long term bacteria counts in the Ohio River remained
basically stable until the 1975-1976 calendar year. Due to the extremely high
bacteria counts found during this period, the Louisville Water Company
initiated further'investigations to determine possible causes of this
excursion from baseline. (See Appendix) These data indicate that the bacterial
quality of the Ohio River at the B. E. Payne Plant (up stream of Goose Creek
and Harrods Creek) was generally of better quality than that at the Cresent
Hill intake (down stream Goose Creek and Harrods Creek). While these data
indicate that the bacteria quality of Goose Creek and Harrods Creek is
generally poorer than than of the Ohio River, it could not be concluded that
these two creeks were the sole cause of the water quality deterioration
experienced by the two plants.
In consideration of the problem definition, the Louisville Water Company
feels that the LS2c alternative provides the most logical and engineeringly
sound soulution to the problem. The concept of LS2a does not recognize
problems that are likely to occur with the continued proliferation of package
wastewater treatment plants in the north county area. Any plan that considers
action toward alleviating existing problems without due consideration of
future problems does not represent sound planning or engineering judgment. It
is recognized that the constraints placed upon federal funding do not allow
for facilities to be planned for future growth. It is felt, however, that the
availability of funding should not be the ultimate determinate in the solution
of a problem. It is far more prudent to define the desired level of effort
(goals) and to seek appropriate funding to satisfy these goals.
The Louisville Water Company considers any waste water discharge that may
adversely affect water quality at either of Its Intakes to be unacceptable
from a public health standpoint. The discharge from the proposed regional
waste water treatment plant at either location A or B (figures 10, EIS) would
be unlikely to affect water quality at our Crescent Hill facility under normal
hydraulic conditions. However, the possibility of reverse flows under low
stream flow conditions and the possibility of contaminants from discharge
point A reaching the Louisville Water Company Crescent Hill Intake have been
sited In a earlier MSD report (See attachment). Therefore, the discharge
location at point A is considered undesirable.
The discharge at location B would be more desirable than that at location
A, In that the distance between the discharge and the Crescent Hill intake is
nearly doubled from that at discharge point A. It would be desirable to
extend the discharge at point B into the higher velocity section of the
stream, as opposed to having a shore discharge. Such action would further
reduce the possibility of wastewater discharge affecting water quality at the
Crescent Hill location.
In the treatment of wastewater for surface stream disposal consideration
should be given to the over all effectiveness of chlorlnatlon on the quality
of water for all intended purposes. A good deal of controversy has developed
over the effectiveness of waste water chlorination in the disinfection of
pathogens. It is often feared that chlorination simply destroys those
indicator organisms which are highly susceptible to chlorine, while not
necessarily destroying virus and more chlorine resistant pathogens.
LOUISVILLK WATER COMPANY
00
LWC-3. The water quality data provided graphically in the Appendix
that accompanied the Louisville Water Company's coiranent supports
previous information published in Task Reports for this EIS.
LWC-4. The EPA selection of the LS2a alternative does not preclude
a local decision to build a regional system that provides for
future growth and avoids a proliferation of package plants.
Future wastewater management is a local responsibility.
LWC-5. Selection of the LS2a alternative recognizes the maximum
extent of federal funding permissible by federal law. Due con-
sideration of future problems is a local responsibility that is
not precluded by this decision. EPA feels, however, that the
availability of funding, local or federal, does ultimately
determine the solution to a problem. The LS2a alternative will
solve the existing problem; planning to avoid future problems is
a local responsibility.
LWC-6. EPA concurs.
LWC-7. B is the recommended discharge location for the North County
regional plant. Comments on the discharge location of the North
County plant were solicited from the Louisville Water Company in
a letter of February 25, 1982. The Water Company responded in a
letter of April 16, 1982, that they would not be opposed to any
discharge point downstream of Beargrass Creek. Discharge location
B is approximately 1 mile downstream of Beargrass Creek.
Local-scale hydraulic modeling of the Ohio River was not a
part of the EIS. Based on available information, a mid-river dis-
charge is not cost-effective due to the high cost and effect on
navigation. If the Louisville Water Company has done modeling to
show that the condition described in the letter can occur, then
the actual discharge point can be changed during design.
LWC-8. Chlorination is an accepted method for disinfection of sewage.
It was used in this EIS for developing costs to be representative
of actual construction costs. The most cost-effective method of
disinfection, as well as other treatment processes, should be
determined during design of the North County plant.
-------
8 (Wastewater chlorlnation has been Identified as a potential source of organic
|contaminants that may affect human and marine life.
Louisville Water Company appreciates the opportunity to comment on this
EIS, and hopes that the comments and data are helpful In the Identification of
the problems as viewed by the Louisville Hater Company.
If you have any further questions, please feel free to contact me.
Yours very truly.
Vice President-Chief Engineer
FCC/htl
Attachments
APPENDIX
Item 1: Yearly Average Bacterial Quality of
Ohio River at Crescent Hill Intake
Item 2: LHC Interoffice memo on samplings
of Goose 4 Harrods Creeks from
From W. E. Vaughn to S. A. Hubbs: 11/17/81
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-------
LOUISVILLE WATER COMPANY
(INTER-OFFICE COMMUNICATION)
To
November 17. 1981
Steve Hubbs/File
From • Willard Vaughan
Re: Bacterial Comparison Between Crescent Hill Filter Plant
and B. E. Payne Water Treatment Plant
Introduction
A review of past data has indicated that the CHPP bacteria
levels are higher than that of BEPWTP. Figures 1-4 graphically
show this for four different tests over an 18-month time period.
The major difference in the two sets of data can only be accounted
for by some form of continuous contamination.
The theory was proposed that the contamination was coning
from some specific point source. There are only two major point
sources between BEPWTP and CHFP; Goose Creek and Harrods Creek.
Initial biological sampling was performed on August 10 and Sep-
tember 14 with a full scale sampling program begun on September 28
to test the theory.
Methods
Goose Creek samples were taken from the old River Road
Bridge which is just a few feet north and parallel to the current
River Road Bridge. Harrods Creek samples were taken from the
south end of the docks at Captain's Quarters restaurant off River
Road. The one lane bridge of River Road crossing Harrods Creek
was not used because it was considered unsafe by the sampler due
to traffic. Samples were taken basically once a week, and dates
are indicated on the attached Figures.
A sample bomb was used to raise the sample from about two
feet below the surface. Two 100 ml autoclaved sample bottles were
first filled by the autoclaved sample bomb for biological tests.
Then, a 1.5 liter sample bottle for wet chemistry, a 250 ml sample
bottle with approximately 5 ml of H2NO3 for metals, a 500 ml brown,
screw cap bottle for trihalomethane potential, one clear, teflon
lined crimp capped bottle with thiosodium sulfate for the ORSANCO
EWODS Program. Organic sampling was also begun on BEPWTP Raw Water
to provide more consistent datum points than what is normally taken.
C
To: Steve Hubbs/File
Fr: Willard Vaughan
Nov. 17, 1981
Page Two
Figures 5 through 8 indicate that the biological water
quality of both Goose Creek and Harrods Creek are of a poorer
quality than that of either CHFP or BEPWTP.
Figures 9 through 11 incidate that Goose Creek is pre-
dominantly a groundwater fed stream, due to the higher hardness.
Higher Fluoride levels may be due to discharges of domestic
wastewater previously treated by the Louisville Water Company.
The higher levels of phosphate indicate sewage effluent. Harrods
Creek water quality is more closely associated to Ohio River
water quality.
Results of the organic data will be covered in a follow-up
report.
Discussion
Biological samples are taken and analyzed daily for both
CHFP and BEPWTP. On Figures 5 through 8 only the daily results
of CHFP and BEPWTP which correspond to the days which Goose
Creek and Harrods Creek were sampled are shown. It was origi-
nally thought that this may be incorrect due to fluctuations
which occur daily in the Ohio River. Figure 12 indicates the
Standard Plate Count for BEPWTP for the months of August through
October. It can be seen that the line indicated on Figure 5
follows a trend line of Figure 12 closely. So it was found to
be unnecessary to graph each day for CHFP and BEPWTP. A check
was made to make sure that the points of CHFP and BEPWTP graphed
on Figures 5 through 8 were not maximum or minimums of the week in
question.
Fluoride levels are shown on Figure 11 for the Ohio River
as opposed to CHFP and BEPWTP. This is because Fluoride is a
stable compound and varies very little within a local environ-
ment.
-------
To: Steve Hubbs/File
Fr: Willard Vaughan
Nov. 17, 1981
Page Three
Conclusion
Hydrological Data
The deterioration of the water quality of the Ohio River
is probably, directly related to the amount of discharge from
Goose Creek and Harrods Creek. It is significant that during
the sample period the weather was extremely dry. This most
likely led to low flow of both streams. This cannot be veri-
fied because there is no hydrological data taken on Goose
Creek. A hydrologic sampling station does exist on Harrods
Creek. This station is located in the headwaters, however,
which is a considerable distance from the sampling site on
River Road. Without this direct hydrological data, it will be
necessary to estimate stream discharges from the two streams
based upon rainfall.
Hydrological flow data is available for the Ohio River
through the Corp of Engineers at McAlpine Dam. There has not
been any form of modeling performed to analyze the flow patterns
of the River between McAlpine Dam and the BEPWTP. It is believed
that the flow may be channelled (due to streamline flow), flow-
ing along the south side of the Ohio River (Kentucky side) into
.which both Goose Creek and Harrods Creek feed.
fa
Water Quality
Both creeks have problems in regard to water quality.
Goose Creek has at least three sewage treatment plants which,
even if working correctly, would have a major impact on the
stream. Boating is heavy on Harrods Creek as can be seen by
the large number of boats docked to the banks.
Even taking all this into consideration it does not seem
to be enough to provide the amount of deterioration in the Ohio
River, as indicated in Figures 1-11. It is possible that there
are other sources of pollution other than the point sources of
Harrods Creek and Goose Creek. An example of this is the boats
docked at the Louisville Boat Club. Laws have been inacted to
prevent any discharge but it is believed these laws are often
broken. This type of pollution cannot be measured, only esti-
mated, and not too accurately.
To: Steve Hubbs/File
Fr: Willard Vaughan
Nov. 17, 1981
Page Four
Recommendations
Sampling which had been on a weekly basis is now on a
bi-weekly basis. But this data can only give indications of
the overall problem source. Stream flow models for Goose Creek
and Harrods Creek should be developed to give a better under-
standing of the amount and velocity of their flows. The Ohio
River near the creeks (if possible) should be modeled to see if
there is a channel due to streamline flow.
The modeling of the creeks and the Ohio River will take
money and time; but, a clear unhypothetical answer can only be
found by this type of investment.
Willard C. Vaughan
WCV/cr
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ATTACHMENT
O
oo
Excerpt from 1940 USD report discussing
the possibility of reverse flow on the
Ohio River near Bluegrass Creek.
REPORT
or THE
COMMISSIONERS OF SEWERAGE
OF
LOUISVILLE
llovMiUii.1.
D. SCIIOI.TZ
Mayor
INTERCEPTING SEVERS
AND
SEWAGE TREATMENT
November 19. 1910
LOUISVILLE. KENTUCKY
tier-Works Intake. Above the
water should be of such a cpial-
afe for drinking after a hi;.'!)
ions, there were high monthlv
nes during four months of the
- were made, the hiirh counts
it per 100 c.c. The average of
• c.c. as reported in Chapter X.
as reported by the Louisville
11135 to 1030. ranged from l.O'll
.. average culi-atrogcnc-. index
water, taken from the Mem-
.Honing table. It is M-C-II ih.a
•he index varied from 3.100 to
idual yearly averages ontMdc
;.RBIM.lCK HIVE!! \V.\TEK AT
•.XT. LAWRENCE. MASS.
5.7M
t.TIK"
IM! 1
*"* (
19JJ i
1'JIC
5.100
S-^OO
n.soo
11,M«
1A 11*111
Lawrence in 1936. Metcalf &
,;i,€Slion that il ifimld licilinir.
• • ictiltr sapl'ly fr»M «" ""I"'1'
if the city were not ready to
>f\ cloning a ne* source, "then
• lit volume of river water so as
•.tractive •supply should be iim-
strviclcd immediately." The works required |>ro\ided floc-
cut.ition. activated carbon treatment, pre- and |)o.ft'treat-
mcnt »ith lime, .sedimentation after coagulation, rapid *aml
filtration and pre- and po.st-ch)orination. in addition to the
existing slow sand liltiatiou and chlonmitiou.
In the case of Laurence, (he principal pollution comc-
from the untreated sewajie of Lowell, a city of about ICO.tMtO
some eiv'hl miles upstream. In thi.s case the pollution indi-
cated by a .L'txen cnli.acn>^'ciie<. index is uorse than thai at
the Louisxille intake, because of the human origin 01 a
greater proportion of the former.
For further com|ian>on reference is made to a Ntudv nt' a
inimln-r of mnniciiKd water pnriiicatmn plants on the »Irc.il
Lakes and Ihc Ohio River, by 1). W. Streeler (J). who con-
cluded thai "for waiiT nM|iiirinir liltration. the averat'c I!.
coli index of the raw water as delivered for treatment. «licn
considered o\cr a si)riiilic.intlv lunv |icnod of time, such :i~
a \ear. shimhl in no case exceed 3.1)011 |«r 100 c.c., and the
B.coli index of such a water should not exceed 20.(MMI per
100 c.c. iluriiic more than 5 per cent of the period cuii-
sidcred." Accorilingly. the raw water at Louisville s
intake is approitchint; the limit set by Strecter.
Considering the sources and extent of pollution of the
Ohio Kiver at Louisville, the high decree of treatment i>i\en
the water, and the city's good typhoid record, we beliete
(hat. the water flowing donn the Ohio Ruer to the intake
is satisfactory at present. Consideration is s;i\cn below to
the effect ol reversal of flow in the ri\er.
Upper I'iNil belira Wafer-Works Intake. Ordinarily the
extent of pollution at the nater-uorks intake increases as
the rner flow increases due to greater surface runoff, .scour-
ing out of deposits on the bottom of the river, and £>horu*r
time of travel for pollution from upstream uith corrcs|ioml-
inj-'h less o|>|K>rtiinity for sedimentation and death of bac-
teria. Occasionally, however, high counts hate been ob-
Ni'rved at the intake at times ol extremely low rher Him.
This sug.'i.'f'ts the |xissibility that sewage front Louisville
-------
may at such times be carried upstream to t|lc intake bv a
reversal of flow in the river.
In Table 20 is given the average daily ri\er discharge on
days when this was 5.000 c.f.s. or less together with the esti-
mated minimum flow past the dam durinu tne^e days for
July and August, 1930. as estimated by the Corp* of En-
gineers. This table shows 26 days when the dailv flow was
from only 2,100 to 5.000 c.f.s. and many days when the mini-
mum flo« past the dam was reported to be as low as 300 to
400 c.f.s. for several hours.
The low minimum rates of flow past the dam. riOO to 400
c.f.s.. are caused by the shut-down of the power plant. On
certain days when the power plant was shut ilnnn the rec-
ords do not show any flow in the river, but it is estimated by
the Corps of Engineers that there was a flow pa.-,t the dam
of 300 c.f.s., during these periods.
Computations which take into account the direction and
velocity of the wind and the river velocity indicate that, with
the river elevation maintained at pool stage for navigation.
with very low river flow and with only gentle to moderate up-
stream winds, the occurrence of a reversal of flow in the
river for a sufficiently long time to carry sewage now reach-
ing the upper pool to the water-works intake is a distinct
possibility.
On account of the possibility of reversal of flow in the
river, we recommend that for the protection of Louisville's
water supply the sewage from outlets now discharging into
the upper pool be intercepted before its discharge, and con-
veyed to a point below the dam rather than treating this
sewage at a plant so located that its effluent would discharge
into the upper pool.
Loner Pool. New Albany obtains its water supply through
an intake located just below the Portland Locks and down-
stream from the discharge of much of the sewage of Louis-
ville. It is certain that sewage from Louisville must reach
the New Albany intake.
The purification plant for the New Albany supply provides
preliminary sedimentation, pre-chlorination, flocculation.
TABLE 20. — AVERAGE AMI Mr
AT LOUISYH.LL AT TIJIKS \vr
5.000 C. F. ?.
Date.
I'isn
Julv 13
1ft
20
21
22
23
25
31
Aug. 2
3
5
7
10
12
13
14
15
16
17
19
20
21
22
23
24
26
30
'Estimated flow
OH LESS. Dl'IMN
A\rtji:P el.ilh
lHn elite h.iin
If ( s 1
3.000
4.000
2.800
:;.noo
2.800
2.800
4.900
3.000
2.500
4.500
1.000
2.950
3.500
2.100
3.700
4.GOO
4.600
4.0(10
4.200
4.200
2.400
2.800
5.100
2.900
4.100
3.500
3,100
in Ohm Kivri el.
5hm down, as slinwn li> icimelp 'I
tReroids elo no
of the povvpi plant
Ilieie was a flow
shul'down petiods
show any Dow )•
on t)i<*s" d.iles li
pnst the dum of
This is leakaE'
-------
Louisville, r.entucky
Febr-ary 9, 199*
Mr. Honald J. hikulak. Project Officer
Environmental Assessment Branch, EPA Kegion IV
>*5 Courtland Street, N.£.
Atlanta, Georgia 30J65
Dear Mr. Hilulak.
I want to congratulate yo- on the fine job you and your colleagues
did on the Draft EIS for North Jefferson County, Kentucky, wastewater
facilities. I read it witn a reat deal of interest, and I learned a lot
about my neigh orhood that I didn't previously know. I also have a ^raa
appreciation of tne problems involved wnen an area such as ours needs to
have sewers installed.
I attended the February ? meeting at ballard High School, but can't
say that I enjoyed that as much. I share the frustratio-is expressed concerning
what to do next. In light of Mr. Shogren's preaiction that we'll probauly
have to live with your "No Federal Action Alternative" until about 1990,
EP-1 II wish you could offer some temporary solutions. Aren't tnere interim
I repairs tnat can be made to existion small treatment plants tnat will cut
down on .ne pollution that they proauce? Also, what are your recommendations
EP-2 for individual septic tanks that are no longer working properly? Is it
feasible for individual lots to install leaching or evapotranspiration beds?
Can tms be done with a small group of lots? Hy neighbors and I need to
know what we can do to keep our neighborhood from stinking from now until
1990 -- and it has to be soraetning within our economic means, bonfire Drive
Is not in tne affluent Indian Hills areal
Perhaps you already Know that about eight nouses on the we t side of
Bonfire Drive (those backing up to little hud-iy Creek) are being put on the
sewers beln& installed for rfindsong subdivision. Unfortunately, those are
not the houses in tne area with problem septic tanks. It is understandable
tnat tney are incensed at bei.ig required to hitch onto sewers that ti.ey don't
feel that tney need, while effluent Iron septic tanks across tne street a .d
up-hill from t .em are pouring foul smelling drainage into their front jards.
Our personal situation is not acute, though we feel our days may be
numbeeed in liLht of tne fact that our septic system is 28 years old. There
are only two of us living at 56W Bonfire, and we nave had tne tank pumped
re ularly every two years, and so far, have had no symptoms of malfunction.
However, we dislike the smell of the neighborhood on rainy days, and rebret
the obvious signs of pollution in the beautiful little tributary of Muddy
Creek that flows through our back yard, rie would api-reciate any suggestions
you can make.
rfould you please put my name on ..our list to receive a copy of your
final cJS. if I am not already on it oy virtue of being on the list that
received a copy 01' the Draft.
Tours sincerely
c/
Mrs. Harry h. paLner
5604 bonfire Drive
Louisville, Kentucky 40207
h-1
r-1
O
EP-1. It is technically feasible for small plants to meet the
effluent limits set forth in their NPDES permits. The changes
necessary to do this would have to be determined on an individual
basis. The Louisville and Jefferson County Public Health
Department enforces proper operations of small-area treatment
plants.
EP-2. See p.188 and Figure 21 of the Draft EIS for determining
causes of and corrective action for system failures. Evap-
otranspiration beds are probably not feasible for the Louisville
area because the amount of rainfall exceeds the amount of
evapotranspiration. If land is available, a community system is
technically feasible; however, it may be difficult to implement.
-------
KHC-1
KHC-1
KHC-2
Page 2.
Valerie A. Wickstrom
February 9, 1984
HERITAGE
MEMORANDUM
TO:
FROM:
DATE:
RE:
Valerie A. Wickstrom, Commissioner's Office
Department for Environmental Protection
Mary Cronan Oppel, Director
Kentucky Heritage Council and
State Historic Preservation Officer
February 9, 1984
Draft Environmental Impact Statement
North Jefferson County Wastewater Facilities
KHC-3
KHC-4
A report of the preliminary archaeological survey of the Interceptor
Corridors should be submitted to the State Historic Preservation Officer
for review, comment and approval. This office cannot evaluate the
archaeological recommendations proposed in the Draft Environmental
Impact Statement until we are afforded the opportunity to examine the
survey report.
Furthermore, it is the responsibility of the U. S. Environmental Protection
Agency to be in compliance with the Advisory Council on Historic Preserva-
tion's Rules and Regulations for the Protection of Historic and Cultural
Properties (36 CFR, Part 800) pursuant to the National Historic Preservation
Act of 1966, the National Environmental Policy Act of 1969 and Executive
Order 11593.
As early as possible before the Environmental Protection Agency makes a
final decision concerning this project and, in any event prior to taking
any action that would foreclose alternatives or the Advisory Council's
ability to comment, the Environmental Protection Agency should take the
following steps to comply with the requirements of Section 106 of the
National Historic Preservation Act.
1. Consult with the State Historic Preservation Officer by making
available for review and comment the preliminary survey report
referenced in the Draft Environmental Impact Statement.
2. In consultation with the State Historic Preservation Officer
conduct any further assessments deemed necessary to locate and
evaluate potentially eligible archaeological properties which
may be affected by the proposed project.
(continued)
FEB13T-V ' '
3. In consultation with the State Historic Preservation Officer
apply the National Register criteria to all properties which
may possess historical or archaeological values within the
area of undertakings potential environmental impact.
4. For all listed or eligible National Register properties,
the Environmental Protection Agency should, in consultation
with the State Historic Preservation, apply the criteria of
Effect and Adverse Effect.
5. If it is determined that No Adverse Effect or Adverse Effect
exists then the Environmental Protection Agency must
consult the Advisory Council as specified in Section 800.4 C,
through D of the Council's Regulations.
The Kentucky State Historic Preservation Office looks forward to cooperating
with the Environmental Protection Agency on this project.
KHC-1. The report of the preliminary archaeological survey was
first published in the draft Preferred Alternative Report and
was also included in the Draft EIS.
KHC-2. Once interceptors are designed, further investigations
will be required for certain segments, as listed in Section
5.4.3 of the • ft EIS.
KHC-3. The Kantueky Heritage Commission, the Louisville
Landmarks Commission, and the Jefferson County Office of Historic
Preservation were consulted for locations of all cultural resources
listed on the National Register of Historic Places and all recent
nominations of eligible properties. These properties are listed in
Section 4.12 of the draft EIS.
KHC-4. Consultation with the State Historic Preservation Officer
will be required as a grant condition for the LS2a interceptor, as
specified in Section 5.4.6 of the draft EIS. It is not possible
to make decisions on specific effects at this point, because the
exact routes of the interceptors are not known.
I
THE KENTUCKY HERITAGE COUNCIL THE STATE HISTORIC PRESERVATION OFFICE FRANKFORT, KENTUCKV 40«>r 150315M-7005
-------
HB-1
HB-1. Apple«ood Lane IB In subarea 62, which Is recomnended for
sewering and connecting to the Morris Fornan system. The
Louisville and Jefferson County Metropolitan Sewer District Is
the local agency that would Implement this action.
-------
DLPARTMENT OF HEALTH i. HUMAN SERVICES
Public Health Scunco
JPHS-1
PHS-2
Centers for Disease Control
Atlanta GA 30333
February 15, 1984
Mr. Ronald J. Mikulak
Project Officer
Environmental Assessment Branch
U.S. Environmental Protection Agency
Region IV
345 Courtland Street, N. E.
Atlanta, Georgia 30365
Dear Mr. Mikulak:
We have reviewed the Draft Evironnental Impact Statement (EIS) for the
Proposed Wastewater Management Facilities for North Jefferson County,
Kentucky. We are responding on behalf of the U.S. Public Health Service and
are offering the following comments for your consideration in preparing the
Final EIS.
According to the EIS, the falling septic tanks and improperly operated
treatment plants have created public health and water quality problems in
North County. We understand that "the purpose of the EIS is to determine the
most cost-effective approach to alleviating these problems." We are in
support of those improvements necessary for Wastewater treatment practices and
to minimize potential adverse public health and water quality effects.
However, satisfactory safeguards must be Incorporated into the project to
minimize potential adverse public health risks.
It is indicated that there are serious problems with septic field performance
in North County and that the area may be suffering from serious water quality
problems as a result. In the interim, what measures will be taken to Improve
the conditions of the falling on-site systems? What local legal requirements
exist to assure adequate maintenance of on-slte systems, such as periodic
pumping of septic tanks?
In view of the seriousness of the local septic tank failure problems and
because of poor soils, high water table, shallow depth to bedrock in certain
areas, and the hydrologlc connection between septic tanks and the underlying
limestone aquifers which are fractured and jointed, the public health
implications that may be associated with possible contamination of ground
water resources from septic tank systems should be assessed. The potential
effects of on-site systems upon local private and community wells should be
evaluated to determine if the quality of local ground waters is suitable for
the protection of public health. Private wells and community wells that could
be affected by contaminants and/or pathogens from upgradient on-slte systems
should be sampled to determine if any interim health protective measures need
to be implemented.
USPHS-3
Page 2 - Mr. Ronald J. Mikulak
Figure 5 of the EIS shows the proposed North County Regional Treatment Plant as
being near Bandman Park and the State Railway Museum. The environmental impact
of this plant upon these public lands and any residential properties in the
vicinity of the plant should be discussed in the Final EIS. Noise (treatment
plant and truck), odor, and any other environmental impacts that would be
associated with this plant and/or transport of waste treatment materials and
sludge should be considered in this discussion.
We appreciate the opportunity to review the Draft EIS. Please send us one copy
of the Final EIS when it becomes available. Should you have any questions about
our comments, please call Mr. Robert L. Kay, Jr., at (404) 452-4161.
Sincerely yours,
Joe K. filler
Acting'Chief, Environmental Affairs Group
Environmental Health Services Division
Center for Environmental Health
USPHS-1. Maintenance of septic tank systems is a local responsibility,
under the purview of the Louisville and Jefferson County Health
Department.
USPHS-2. In the environmental inventory, it was estimated that less
than 0.4 percent of the residences in the study area draw their
water from wells and cisterns. Drinking water and public health
have traditionally been local responsibilities. No information
has been found to indicate any public health problems with water
supply in the North County study area, nor has the Health
Department indicated that such problems exist.
USPHS-3. Impacts resulting from the North County regional plant were
discussed in the draft Alternatives Evaluation Report. The
overall impact was not determined to be significant, mainly
because the treatment plant site is not near a residential area.
There should be no noise or odor problems from a properly designed
and operated treatment plant.
U)
-------
ItS South Ewin,A«n« • Louiivffle. Kentucky 40206 • Phone (502) 895 S21I
OF tOUISVILlE AND JEFFERSON COUNTY
MEMO TO: Mr. Ronald J. Mllculak, Project Officer
Environmental Assessment Branch
EPA, Region IV
345 Courtland Street, N.E.
Atlanta, Georgia 30365
FROM: The League of Women Voters of Louisville and Jefferson County
RE: Comments on the Draft Environmental Impact Statement for
North Jefferson County, Kentucky
December, 1983
DATE: February 16, 1984
LWV-1 (This E.I.S. is not so much a study of environmental issues as it is a revision of
IJefferson County's federal funding eligibility. The emphasis has been upon "cost
effective", defined primarily as the most cost effective use of federal dollars.
The second listed objective (p. 7), "environmentally sound", apparently means that
minimal degree of environmental soundness required by federal and state laws and
regulations which will entail the least expenditure of federal dollars.
LWV-3 (Descriptions in this document of the 201 Alternative and EPA's Preferred Alternative
I show major differences in the quality of Jefferson County's 1974 EPA guided 201
I plan and EPA's revised 1984 plan for Jefferson County. It should be noted that
LWV-4 (Jefferson County's 201 study, begun in 1973 in compliance with the Clean Water Act,
(generally re-affirmed the county's 1964 Master Plan. In 1975, the 201 plan was
I approved by local, state and federal officials.
Page thirteen of this document says in its summary evaluation for the 201 Alternative:
"Construction funding will be split between EPA and local government, with
EPA providing a greater share than for any other alternative. Public health
risks will be virtually eliminated as septic tanks and small treatment plants
are abandoned. . . This alternative has greater technical reliability than
the others . . . This alternative is probably the most acceptable to the
local public. . . It has the strong endorsement of local agencies and
government."
LWV-1.
LWV-2.
LWV-3.
LWV-4.
An act of Congress revised federal funding eligibility;
the EIS recognizes these changes in the Clean Water Act.
The most cost-effective alternative is defined as the
system with the lowest present worth unless nonmonetary costs
are overriding. The present worth calculations did not consider
federal funding. EPA has not defined cost-effectiveness as "cost-
effective use of federal dollars." The selected alternative
entails the greatest expenditure of federal funds allowed by law.
EPA has not revised any plans. Planning is a local
responsibility. EPA has determined the cost-effective solution
to existing problems, as required by law. EPA does not know what
is meant by "major differences in the quality..."
The history of wastewater management planning in the study
area is given in Section 2.1 of the Draft EIS.
LWV-5
Despite these generally positive words (with the notable exception
of the funding split), EPA has spent the past seven years, neai
wrecking the 201 Plan virtually beyond repair.
LWV-5.
;jn .
The North County EIS did not change the 201 plan, which can
still be implemented by local agencies.
EPA-r,i"J.31. JV
ATLANTA, CA.
-------
LWV-6
In 1977, 201 construction was halted and the Mill Creek 201 Revision was begun.
This EIS was completed two years ago with mixed results for Mill Creek citizens.
The good news was that citizens who perceived that they had no need for sewers were
told that they might keep their septic tanks. The bad news was that EPA condoned
continuing and increasing pollution of the underground aquifer, described on page
122 of this North County document as "one of the major groundwater resources in
the United States11. Hundreds of families were told that they must abandon their
wells for drinking water purposes and pay for Louisville Water Company service.
Moreover, surface streans in the area would continue to suffer pollution from septic
tank seepage and some package plant discharges. Lack of sewers would limit future
business and industrial growth. Whereas the original 201 Study was completed in
two years, the study of the Mill Creek portion required five years and about half a
million federal dollars. TW se dollars were costs to EPA, and do not reflect add-
itional costs of local and jtafe agencies which provided time and most of the raw
information used.
LWV-9
LWV-10
LWV-11
"Construction funding will be split between EPA and local government; EPA's
share will be intermediate between LSI and 201." [Translation: EPA's share of
funding will be enormously reduced from the 201 Plan]. "Local enforcement
activities for small plants will decrease to 10-40Z of existing needs." [Trans-
lation: instead of 48 small area plants there will be about 19 small area plants,
so the Health Department will only have to worry about approximately 40% mal-
functions as currently occur. Also, only the people who live along Harrods
Creek, Goose Creek and Little Goose Creek will get most of these stream-
water problems. These facts could be used to defend the general truthfulness
of the next sentence, which would not be true for every section of the county).
"Public health risks from package plants and septic tanks will be greatly reduced
or eliminated. . . This alternative is intermediate in technical feasibility
between no-federal-action and 201 . . . This alternative is probably intermediate
in public acceptance between no-federal-action and 201."
By EPA's own account in this document, after five years of study and over half a
million federal state and local dollars, we are being presented with:
. A less attractive plan with less federal funding.
A generally meaningless plan with no important new information supporting
201 plan revision, other than the 1981 Clean Water Act Amendments which
altered the Construction Grants Program.
. An outdated plan based on too short a planning period (from 1980-2000) to
be of any practical use.
Surely, this is an especially fr*trating example of how the E.I.S. process was never
intended to be used. Undoubtedly the worst frustration for local citizens has been
knowing that the Mill Creek and North County ElS's never should have required so
long. A more expeditious approach could have produced either one, both, in a two-
year time period or less. It is trie that seven years of delay in local sewer funding
has spared the U.S. Taxpayer a great burden in paying to help solve Jefferson County's
health and environmental problems. However, for seven long years during this E.I.S.
process, local government and citizens also have been prevented from taking any
LWV-6.
Through the Mill Creek EIS, it was determined that groundwater
in southwestern Jefferson County was influenced by septic tank use,
but that it is still usuable as a treated drinking water source. EPA
has neither the authority nor the intention of "writing off" the aquifer.
LWV-7.
LWV-8.
LWV-9.
This is not a 201 revision; it is an environmental impact
statement for the North County area of the 201 Plan.
The summaries quoted here date from the draft Alternatives
Evaluation Report published in 1981 and simply state the facts
applicable at that time. Since then the Clean Water Act has been
changed so that the use of federal funds for conveyance or treatment
capacity beyond that necessary to serve existing needs at the time of
grant award, or 1990, whichever comes first, is prohibited. The level
of federal funding for the LS2a, LS2c, or 201 alternative would be the
same under the new law.
Of the 48 existing small-area plants, 6 would remain under the
LS2a alternative; one of these discharges to Goose Creek, Little Goose
Creek, or Harrods Creek. Whether or not there will be future small-
area plants is a local decision, and enforcement would be up to the
local Health Department.
LWV-10. This is not "EPA's own account." Moreover,
o No previous plans have contained any commitments of federal
funds for the North County area; it cannot, be said, there-
fore, that the funding for LS2a is less than anything.
o EPA has not revised the 201 plan. The 1981 Clean Water Act
atnmendments are important new facts concerning federal
funding.
o The length of the planning period is defined in federal
regulations. Planning beyond 20 years requires speculation
that could lead to imprudent spending of present funds.
LWV-11. This EIS has had no effect on what the U.S. Taxpayer has paid
toward construction grant funding during this EIS process. The amount
of funds provided for Kentucky has also not been affected by the EIS.
These funds are spent according to the State's priority list. Even
if the EIS had been completed earlier, the project's position on the
priority list is such that construction grant funding is not expected
until after 1987. Furthermore, this EIS has not prevented local
agencies from taking actions with local funds.
-------
LWV-11 substantial actions to solve our own problems. Community agencies, faced with
constant decisions regarding future community growth and development, have been
forced to make such decisions without any viable long-term plan to follow. No
doubt they wjlll be found, in retrospect, to have made many unwise and costly
decisions.
LWV-12 It has been particularly devastating to local hopes for solving water quality and
health problems that the costs for wastewater facilities have soared so greatly
during this un-productive hiatus. The Engineering News Record Construction Cost
Index shows that such costs have risen, since 1977 by a factor of 1.59, or cost at
least SOX more. Since 1979, the Cost Index increase has been 1.30. Fully aware
LWV-13 of the increasing dollar costs of inflation impacts upon Jefferson County citizens,
EPA virtually ignored this factor while conducting Its leisurely studies. In so
doing. EPA chose to achieve federal dollar cost-effectiveness at the expense of
total dollar cost-effectiveness as the final goal of its actions in Jefferson County.
LWV-14 The resulting draft North County EIS must be disappointing even to EPA. After seven
years and approximately one million federal dollars spent in destroying a 201 plan,
nothing very useful has been found to replace it. Incredibly, Jefferson County
is now faced with the necessity of doing its own study in order to find a practical
replacement for its 1964 Master Plan.
LWV-15 Surely NEPA and the Clean Water Act were never Intended to sabotage the efforts
of a community trying to follow a practical, technically feasible, affordable long-
range plan to solve its environmental and health problems. These laws were never
intended,, either, to prevent a community from trying to provide for Its future growth
In a way that would avoid repeating its past mistakes: pollution from septic tanks
and mal-functioning sewage treatment plants on small streams.
LWV-161 However, that's what has resulted from EIS's conducted by EPA in Jefferson County.
I While these EIS's have saved federal dollars, as intended by Congress in revisions
Ito the Clean Water Act, far more has been lost than has been saved. Although many
LWV-17|federal, state and local dollars have been spent by EPA, while costly time elapsed:
LWV-18j . This plan is not the long-range plan needed for environmentally sound
| growth in our community.
LWV-19| . This plan is not as technically feasible as the plan which we once had.
LUV-20| . This plan is not as affordable as the plan that we once had.
LWV-211 . This plan does not protect public health or the environment as much as the
I plan that we once had.
After 7 interminable years and such enormous costs, it is discouraging to realize
that in our cointy the Environmental Protection Agency has been the single greatest
force working against positive solutions to our wastewater-related environmental and
health problems. Truly, we have discovered that we can not afford this kind of
environmental protection.
KWV-12. EPA does not dispute the fact that construction costs have
risen over the course of the EIS. Building now just to avoid
inflated costs in the future Is seldom, if ever, good public policy.
LWV-13.
LWV-H.
LWV-15.
Inflation affects federal dollars the same as total dollars.
EPA did not choose "federal dollar cost-effectiveness." The present
worth analysis was done using total dollars; federal funding was not
a factor.
EPA is not disappointed with the results of the draft North
County EIS. The EIS did not take 7 years or 1 million federal
dollars, and it did not destroy or change the 201 plan. The North
County EIS addresses the existing water quality problems of the
community. The selected alternative proposes a practical and useful
wastewater management approach within the framework of current
legislation. Long-range community planning is not an objective of
the EIS process, but it is a responsibility of local authorities.
EPA concurs.
LWV-16.
EPA does not agree that local efforts have been sabotaged,
that community planning has been prevented,
been lost than saved.
or that far more has
LWV-17.
EPA has not spent state or local dollars.
LWV-18. Long-range planning for environmentally-sound growth is a
local responsibility.
LWV-19. The decreased feasibility of the LS2a alternative relates to
the number of future small-area treatment plants assumed to occur
if the 201 system is not built. Whether the small plants or the
201 system is built is a local decision.
LWV-20. The LS2a alternative is more affordable than the 201
alternative, as shown in Table 52 of the draft EIS.
LWV-21. The LS2a alternative eliminates existing public health and
environmental problems. Planning for future environmental
protection is a local responsibility.
Yrances Wagner,President
Patricia
Natural Resources Chair
-------
DEPARTMENT OF THE ARMY
LOUISVILLE DISTRICT. CORPS OF ENGINEERS
P O BOX 59
LOUISVILLE. KENTUCKY 40201
February 17, 1984
ORLPD-R
Mr. Ronald L. Mikulak, Project Officer
Environmental Assessment Branch
Environmental Protection Agency
Region A
345 Courtland Street, N.E.
Atlanta, Georgia 30365
Dear Mr. Mikulak:
We have reviewed the Draft Environmental Impact Statement (DEIS) on
proposed wastewater facilities for northern Jefferson County, Kentucky.
COE-ll The proposed action will not affect any projects of the Louisville
I District Corps of Engineers. However, the potential scope of work warrants
specific comments relative to Section 10 and Section 404. Failure to address
certain environmental aspects could result in the necessity to prepare a
supplement to the DEIS as part of the permit review procedure.
This project involves work in a wetland and installation of utility lines
in navigable waterways. Further, based on the preliminary interceptor align-
ments shown in the DEIS, it is possible that modification to the channel
alignment could be a preferred alternative to facilitate construction.
COE-2 The EIS should specifically address the following:
a. The 404b(l) guidelines associated with all fill work particularly
the wetland fill.
b. The disposal or storage area for the material dredged from the
waterway.
c. The boating safety measures to be employed on Harrods Creek and
Goose Creek relative to vessels transiting the construction area.
d. The alternative of using a modified channel alignment for reaches
where numerous crossings would be necessary; or where installation in the
stream channel is contemplated.
e. The extent in acres of the wetland which would be impacted.
f. The alternatives considered for avoiding the wetland and the reason
why it could not be avoided.
COE-31 An application for a permit should be submitted for all fill work
(performed in the wetland and for the streams in the following interceptor
COE-31 reaches: NC-6, NC-7, NC-8, MF-1, MF-3, GS-1, GS-2, GS-3, LG-1, LG-2, LG-3,
JLG-4, LG-5, LG-6, WS-1, WG-1, GP-2, PH-1, TL-1 and HC-2.
Any questions on permit matters concerning this project should be
directed to the above address. Regulatory Functions Branch, ATTN: Mr. D. L.
Hawkins, OKLOP-FP, or by calling (502)582-5452.
Thank you for the opportunity to comment.
Sincerely,
, \*>*~ft*-i
Dwayne G. \Uee
Colonel, Corps of Engineers
District Engineer
COE-1.
Comment noted.
COE-2. Specific construction activities will be addressed during
design, when Interceptor alignments are more precisely determined.
COE-3. EPA concurs; see Sections 1.6 and 3.2 of the Final EIS.
Note that this comment lists an interceptor segment—GP-2—that
does not exist. It was assumed that this was meant to be GT-2.
-------
* PO VOX ITO4
LOUISVILLE KY «O2O1
DEPARTMENT OF PUBLIC HEALTH
LOUISVILLE AMD JEFFERSON COUNTY
400 KABT GRAY STHEKT
February 17, 1984
' • WALLACE JK . M D
00
LJCPH-1
LJCPH-2
Mr. Ronald J. Mikulak, Project officer
Environmental Assessment Branch
Environmental Protection Agency
Region IV
345 Cortland Street, N.E.
Atlanta, GA 30365
Re
Draft EIS for North Jefferson
County, Kentucky
Dear Mr. Mikulak:
Ten years ago, in 1974, this community submitted to your agency,
and received approval, of a Water Quality Management Plan (201
Plan) for the development of a liquid waste disposal system for
this community. As of this date, no material benefit is evident
within this community. In fact, it is quite apparent that the
community leadership and official agencies concerned with the
problem must now start the process of informing the public,
gaining their support and developing plans with major adjustments
in the original plan concepts. In fact, gaining community
support is going to be considerably more difficult as a result of
Environmental Impact Statements for the Millcreek Watershed and
North Jefferson County.
For seven of these ten years, material progress in improving
wastewater disposal capability for this community has laid
dormant while these two statements have slowly moved to
completion. Each study has taken approximately five years to
complete. During these seven years of study, the average annual
inflation rate for construction probably stands minimally at 10%.
As early as December, 1988, a letter from the Chairman of this
Board, Mason C. Rudd, to you, expressed concern for some
directions the consulting group was taking in developing the
North County Environmental Impact Statement. Your response of
January 16, 1981, called attention to an opportunity for local
government and local agencies, citizens, environmental groups and
community leadership, to have the opportunity to review and
comment on all material developed for the Environmental Impact
Statement. Comments have been made repeatedly. The final
LJCPH-1. The Pond Creek sewers, which are part of the 201 plan, have
been built.
LJCPH-2. The process of informing the public was an integral part of
this EIS. In fact, public opinion to date has been in favor of a
public sewer system in the North County study area. The L52a
alternative is responsive to the opinion that existing development
should be connected to a regional sewer system. The 201 alternative
can be implemented without any major adjustments if local agencies
choose to do so.
-------
Page 2
product, however, has failed to address many of the expressed
LJCPH-3 local concerns. The original 201 Plan for this area addressed
all areas with failing septic tank systems contributing to non
point source pollution. The final North County Environmental
Impact Statement preferred plan, does not. The final plan again
LJCPH-4 | limits consideration of the growth and urban development of this
Icommunity. The original 201 Plan provided for such growth.
LJCPH-5 As with the South West EIS, it appears that the original
objective of PL 92-500 has been abandoned. The objective of both
LJCPH-6 Jefferson County studies has been justification of reduced
Federal funding for construction of a collecting and treatment
system to meet the needs of this area. This justification not
LJCPH-7 only consumed seven years in a high inflation period, but also
developed recommendations which this community's leadership
believes detrimental to the future growth and development of this
area. It also creates impediments to the efforts to gain public
support for future plans.
Sincerely,
LJCPH-3. The EIS selected alternative does address all areas with
failing septic tank systems.
LJCPH-4. The EIS does not limit local agencies from implementing
any plan they consider necessary for future growth.
LJCPH-5. PL92-500 has been amended by Congress several times. The
LS2a alternative virtually eliminates water pollution from
existing sources, which is consistent with the objective of the
current revision of the Clean Water Act.
LJCPH-6. The North County EIS is not a Justification for reduced
federal funding for construction of a collection and treatment
system to meet the needs of the area. The federal funding
amount is the same for both the LS2a and 201 alternatives.
LJCPH-7. This EIS does not make recommendations for future growth
and development. Planning for future growth is a local
responsibility.
T.S. Wallace, Jr.,\M.D.
Director of Health
TSW:jlg
Mayor Harvey I. Sloane, M.D.
County Judge/Executive Mitch McConnell
Board of Health Members
Mr. Gerald Neal
-------
CHANLOITE E BAIDWM
MAATMA LAVM Cot IMS
GovtHNO*
NATURAL RESODRCBS AMD ENVIRONMENTAL PROTECTION
ENVIRONMENTAL REVIEW
I-
Is
C
COMMONWEALTH OF KENTUCKY
NATURAL RESOURCES AMD ENVIRONMENTAL PROTECTION CABINET
OFFICE UF THE SECRETARY
FRANKFORT. KENTUCKY 4oeoi
TEUPHONI 'Soil M4 DtO
February 17, 1984
Ronald J. likulak. Project Officer
Environmental Assessment Branch
EPA, Region IV
345 Courtland Street, N.E.
Atlanta, Georgia 30365
Dear Mr. Mikulak:
The Kentucky Natural Resources and Environmental Protection Cabinet
(NREPC) serves as the state clearinghouse for review of environmental
documents for Kentucky State Rovernroent. Enclosed are the comments that
the Cabinet has received on the Draft Environmental Impact Statement -
North Jefferson County, Kentucky Wastewater Facilities from various
State agencies.
The Cabinet appreciates the opportunity to comment on this Draft
EIS. If you have any questions, please contact me at (502) 564-3350.
Sincerely,
VAW/mdk
Division of Waste Management
NREP-J
Valerie A,, Hickstrom
Environmental Review Coordinator
Comments en Draft EI5
North Jefferson County. Kentucky
Wastewater Facilities
The report states that the digested and dewatered sludge from the preferred
regional sewer system alternative plan for North Jefferson County Wastewater
facilities will be trucked to the Morris Forman Treatment Plant for disposal. The
plans should clearly identify whether this sludge would be recycled into the Morris
Forman Wastewater Treatment Plant or be stored there for ultimate disposal by
Morris Forman plant authority.
The Division of Waste Management regulates the disposal of sludge for
wastewater treatment facilities. A permit would be required from this Division for
the disposal of sludge at a solid waste disposal facility.
NREP-l. For the purpose of evaluating alternatives, the EIS
assured dry sludge would be trucked to the Morris Forman
treatment plant for disposal. The actual disposal method
used at the North County plant will depand on cost-effectiveness
studies done during design of the plant and on the results of
MSB's regional sludge disposal study. All applicable state
permits must be obtained by HSD.
if!)
-------
NATURAL RESOURCES AND ENVIRONMENTAL PROTECTION
ENVIRONMENTAL REVIEW
Division of Water
Project Number: 84-2
Project Title: DEIS, North Jefferson County Waste water Treatment Facilities
The Division of Water has reviewed this DEIS. The Division's comments respond
to specific points and discuss the preferred alternative.
NREP-2
Page 3.
SPECIFIC POINTS
Figure 1 Jefferson County
The Shively wastewater treatment plant, indicated on the map, has been
abandoned for several years.
NREP-3JPage 19.
1.3 Recent Changes in the Construction Grant Program Paragraph 2
"1986" should be "1987".
NREP-4
NREP-5
Pages 65 to 69 Table 14. Discharge Limitations for Small-Area Treatment Plants
The Division of Water notes that the data presented in this table were supplied
by the Division to Gannett, Fleming, Corddry, and Carpenter.
Page 73
3.1.5 Regional Treatment Plant Paragraph 3
The DEIS states that the Ohio River Valley Sanitation Commission Ohio River
model indicates that secondary treatment (85% removal of biochemical oxygen demand and
suspended solids) would be sufficient for the Morris Forman wastewater treatment plant.
Because of that plant's size, the Division of Water believes ORSANCO has stated that
additional treatment (to obtain 92% removal of BOD and SS) is necessary.
NREP-6JPage 177
NREP-7
Page 98 to 101
5.1.1 Recent changes in the Construction Grants Program Paragraph 2
"1986" should be "1987".
PREFERRED ALTERNATIVE
3.2.3 LS2 Alternative
Page 177 to 240 5. The Preferred Alternative
The Division of Water agrees with the selection of alternative LS2a as
preferred. LS2a appears to be a reasonable choice. The Division of Water's regulatory
program will be enhanced as a result of the reduction, anticipated in LS2a, of the number of
small area wastewater treatment plants.
NREP-2. Comment incorporated in revised Figure 1; see Section 1.1.
NREP-3. Comment incorporated in the Final EIS; see Section 1.3.
NREP-4. The data were attributed to KNREPC on page 62 in Section 3.1.3
of the Draft EIS.
NREP-5. Morris Forman is currently operating under a simple requirement
for secondary treatment. ORSANCO is considering revisions to its
regulations that could result in a requirement for 92 percent removal
during summer months.
NREP-6. Comment incorporated into the list of revisions for the DEIS;
see chapter 4.
NREP-7.
Comment noted.
Manager, Permit Review Branch
Division of Water
Date
-------
MTHA LAVMC C04.LI*
QOVCRNOM
COMMONWEALTH OF KENTUCKY
KENTUCKY NATURE PRESERVES COMMISSION
4O7 BROADWAY
FRANKFORT. KENTUCKY 40001
February 2, 1984
KNPC-1
KNPC-2
Ms. Valerie A. Wickstrom
Commissioner's Office
Department for Environmental Protection
Fort Boone Plaza, IS Reilly Road
Frankfort, Kentucky 40601
Dear Ms.Wickstrom:
This is in response to your request for environmental review of
the Draft E.I.S. for North Jefferson County, Kentucky, wastewater facilities.
The basic information that is provided in the document appears to be
complete and accurate. The site specific analyses of impacts contained in
this draft E.I.S. were adequate though the mitigative measures proposed are
vague and would likely be difficult to enforce during construction.
We are, however, disturbed that alternative interceptor corridors
were not discussed. The stream bottoms of Jefferson County are some of the
few undeveloped areas in Jefferson County, and as such they support
important environmental resources. In particular Goose Creek, Little Goose
Creek, and to a lesser degree, Harrod's Creek, contain relatively undisturbed
habitats possibly worthy of protection. Certainly, the cessation of pollution
into these streams is an important and desired benefit; however, this does not
have to be at the expense of the natural communities along their
watercourses. Routes along existing corridors and right-of-ways are proposed
in several areas in the plan and serious consideration should be given to using
this approach instead of stream bottom corridors.
If we can be of further assistance, please let us know.
Sincerely,
Richard R. Hannan
Director
RRH/bda/jbs
KNPC-1. EPA has no authority to enforce mitigative measures except
where federally protected natural areas exist or where specific
grant conditions have been included. Detailed archaeological and
vegetation surveys are routinely conducted during design of a
project. The opportunity exists to further consult with the Kentucky
Nature Preserves Commission and others to establish more specific
mitigative measures.
KNPC-2. Stream corridors are the least costly locations for sewers.
An environmental survey of conveyance corridors was conducted to
determine areas particularly sensitive to construction, and
interceptor corridors were given a value rating based upon the
significance of the natural resources in the corridor. Recommendations
for mitigation of impacts were made relative to the significance of
the resource; see Section 5.4.4 of the Draft E1S. During design the
use of existing rights-of-way will be investigated, and these surveys
will be coordinated with the Kentucky Nature Preserves Commission and
other agencies as appropriate; however, the use of existing rights-
of-way is not always possible.
-------
Response to Natural Resources & Environmental Protection Cabinet Environmental
Review /<84-2; Draft EIS—North Jefferson County, Kentucky Wastewater Facilities,
December 1983.
OSA-1.
Comment noted.
OSA-1
OSA-2
OSA-3
We at the Office of State Archaeology concur with the Draft EIS of the North
Jefferson County, Kentucky, Wastewater Facilities. In particular, we agree
that intensive archaeological surveys by competent archaeologists should be
conducted on the interceptor corridors as well as other proposed construction
areas (i.e. treatment plants). Furthermore, we approve of the proposed pre-
construction surveys of floodplain areas which include deep testing techniques
to locate buried archaeological deposits. It has been noted, however, that
the proposed archaeological investigations as stated in the EIS (p. 169) would
be directed at prehistoric site resources. It is our opinion that historic
archaeological resources are equally important and should not be overlooked or
slighted as potentially significant sites.
Finally, the EIS refers to a preliminary survey by Grumet and Mistovich (1980).
This office does not have a copy of this report. If possible, we would like
the opportunity to examine this document.
OSA-2. EPA concurs that historic archaeological resources are
equally important; the citation to p.169 is not clear, however.
OSA-3. A copy of the referenced report has been sent to Dr. Clay.
Dr. R. B. Clay
Office of State Archaeology
U. of K.
Lexington, Kentucky 40506
-------
Stephen Reeder
XKKKKXK
COMMISSIONER
COMMONWEALTH OF KENTUCKY
TRANSPORTATION CABINET
DEPARTMENT OF HIGHWAYS
FRANKFORT. KENTUCKY 40822
February 8, 1984
Floyd G. Poore
XXXXR>3CX«
SECRETARY
Ms. Valerie A. Hickstrom
Office of the Secretary
Natural Resources i Environmental Protection Cabinet
Fifth Floor, Capital Plaza Tower
Frankfort, Kentucky 4060!
Dear Ms. Wickstrom:
Subject: Draft EIS, December, 1983 - Wastewater Facilities
North Jefferson County, Kentucky
The Kentucky Department of Highways has completed its review of the subject
proposal.
KDH-I Because of the potential for future conflicts and the need to coordinate
individual sewer projects developed by the subject plan, we urge that proper
consideration be given to transportation facilities which may be affected by
such projects.
The Department of Highways is responsible for controlling both public and
private usage of the State road system rights-of-way. Any firm, individual, or
governmental agency desiring access to a State road or desiring to perform any type
of work on State right-of-way must have in his possession at all times a copy of
the permit, authorization letter, and detailed drawings of work to be done. This
issuing of a permit is neither an automatic action nor a foregone conclusion. Each
case is considered on its own merits, considering the reasonable rights and respon-
sibilities of both the traveling public and the applicant desiring to encroach upon
the State right-of-way.
We encourage the use of private property for placement of utility facilities
where possible and practical; but we realize that in some instances highway rights-
of-way are the only reasonable places to locate the proposed utilities. In these
cases, we expect the conscientious efforts of both the applicant and the contractor
to minimize adverse effects on the roadway and on the traveling public due to
construction of the applicant's project.
Since State maintained roads may be affected by future sewer projects associated
with this plan, any proposed access or encroachment should be coordinated at the
earliest possible stage with our District Highway Office. This early coordination
can, in many instances, prevent project conflicts and delays.
Ms. Valerie A. Uickstrom
Page 2
Encroachment regulations are found in the Department's Permits Manual. For
construction situations affecting the flow of traffic, requirements for maintaining
traffic control may be found in the Manual for Uniform Traffic Control Devices, a
nationwide regulatory manual. Both manuals may be seen at Highway District Offices
or purchased for $10.00 and $18.00, respectively, from the Division of Management
Services, State Office Building, Frankfort, Kentucky 40622, phone number (502)
564-6927. If there are any questions about any of our comments, please phone me
at (502) 564-2932.
Sincerely yours.
Thomas A. Scott. P.E.
Division of Design
TAS:lk:xx
cc: H. R. flonhollon
KDH-1.
Coordination with the Department of Highways will occur
during design.
-------
Louisville dud Jet'ersun C >unty '100 South Sixth Slrrct 50? 587 0591
Mptropolitarr Sewer District Louisville. Kentucky 40?u?
February 29, 1984
MSD-1
Mr. Ronald J. Mikulak
Project Officer
Environmental Assessment Branch
EPA Region IV
345 Courtland Street, N.E.
Atlanta, Georgia 30365
Re: North Jefferson County, Kentucky Draft EIS
Dear Mr. Mikulak:
We have reviewed the Draft Environmental Impact Statement for
North Jefferson County, Kentucky.
In general, the Preferred Alternative - LS 2a - proposes a limited
version of the 201 Plan and, as such, appears to be a satisfactory
alternative. However, the financial feasibility, in light of your
assumed 55% level of federal grant funding, is questionable. It
appears that federal funds for North County will not be available
for North County until 1987, based on the current State Priority
List. By that time, there may very well be rm federal funding
available for sewering the North County area.
Enclosed are our comments regarding the technical contents of the
report.
Since
Neumayer
Acting Executive Director
CAN/jkc
Enclosure
cc: MSD Board
"An equal opportunity employer M/F/H/V"
MSD-1. The 55% level of federal funding was used because it is the
current level established by federal law. EPA cannot predict what
future federal funding levels or appropriations will be. MSD may
make other assumptions if it decides to re-examine the financial
feasibility of any sewering plan.
KJ
Ui
-------
Draft Environmental Impact Statement
North Jefferson County, Kentucky
MSD-2
MSD-3
HSD-6
MSD-;
3 - 4
MSD-4 7
MSD-5 7
17
USD-7 | 29
MSD-81 30
MSD-71 30
MSD-7 31
MSD-41 32
MSD-7J 32
MSD-7 38
39 - 41
MSD-J 59
Comment
Plant No. 85 - Netherton Place is undeveloped, but page
32, 5th paragraph, says it was built in 198E. Page 100,
which is the recommendations' list for small WTP's for the
preferred alternative (LS-2a) does not show Netherton
Place. None of the alternatives shows a recommendation for
Netherton Place and none of the figures shows an inter-
ceptor to relieve it. What's going to happen with this WTP?
Figure 1 - Delete Existing Municipal WWTP 4, Shively.
This plant was abandoned and the system connected to
MFWTP in 1976
1st full paragraph, line 3 - Change "four" to "six"
2nd full paragraph, line A - Morris Forman WTP is NOT
"...located south of Louisville." Change to "southwest of
and adjacent to"
Table 5, ENVIRONMENTAL IMPACTS - For clarification,
revise last line to read: "64 km (40 mi.) of interceptor
routes for LS2a, and 71 km (44 mi.) for LS2c."
1st paragraph, line 5 - Change "more than 50" to "88"
No. 1, line 2 - Change "benefitted" to "benefited"
No. 4, line 5 - Change "of" to "on"
No. 8 - Question validity of statement. Believe you have
reference to KRS 107.020(5)(e) which reads: "...(e) pay-
ment of attorney's fees, underwriting and fiscal agency
fees, trustee's fees, rating service fees if approved by the
fiscal court,..."
Section 2.2 Wastewater Treatment Plants, paragraph 3,
line 5 -Change "four" to "six"
Paragraph 5, line 1 - Add "1983" following "October 1,"
Paragraph 2 - First two sentences are wrong. NPDES Per-
mits specify: "Monthly Averages for BOD,- and SS and
Weekly Averages which are 50% higher than Trtonthly Aver-
ages." They do not specify: "Daily Averages and Daily
Maximums twice the Daily Averages."
Table 8 - Change heading: "Daily Average (mg/L)" to
"Monthly Average (mg/L)"
1st paragraph, last sentence - For clarification, add "with a
vacuum system" following "comparison"
MSD-2. The Netherton Place treatment plant was built In 1982, but it
does not yet operate because its service area has not been developed.
Netherton Place was not listed in Chapter 3, because at the time the
Alternatives Evaluation Report was written It had not been built. In
Chapter 5—The Preferred Alternative—it was assumed that Netherton
Place would be developed by 1990 and connected to the regional system,
as indicated in Table 41, page 179. If Netherton Place Is not
developed at the time of grant award or 1990, whichever comes first,
then capacity for Netherton Place would not be federally funded.
MSD-3. Comment incorporated in revised Figure I; see Section 1.1.
MSD-4. The correct number is five; see Chapter 4 for correction.
(Hite Creek is not considered a small-area plant.)
MSD-5. Conment has been Incorporated Into the FEIS; see Section 1.1.
MSD-6. Comment has been incorporated into the FEIS; see Section 1.2.4.
MSD-7. Comment noted.
MSD-8. Benefitted is acceptable (Webster's Collegiate Dictionary).
-------
2/27/84
Draft Environmental Impact Statement
Page 2
MSD-10 76
MSD-9 j 81
MSD-11 94
MSD-10 gg
MSD-12 99
MSD-9 J101
MSD-10 J102
MSD-13 108
MSD-14
110
MSD-11 1115
MSD-14 130
MSD-I4 J131
MSD-9 |l3g
MSD-15 165
Comment
At end of line 4 - For clarification, add "sanitary" following
"Any reduction in"
Sentence following No. 4 - Change "Figure 11" to "Figure
10"
2nd full paragraph, line 4 - Change "analysis" to "analyses"
Table 21 - Rotate Table 180°; change heading on fourth
alternative from "LS 2c" to LS1c"; put * in front of "*Hite
Creek" and "*Floyds Fork" and add footnote: "*Same for
all six alternatives"; add a "TOTALS" line for all 12
columns
Section 3.2.3, 1st paragraph, 2nd sentence - What about
subareas 4 and 35 which also will not be connected to
NCWTP or MFWTP?
Subarea (34) - Running Creek is listed as a 28,000 gpd
WTP. Table 14 on page 68 lists it as a 110,000 gpd WTP.
Section 3.3, line 4 - Change "or" to "and"
Last line - Change "$10/person" to "$10/person/year"
Table 26, Hydrology, On-Site Systems - Change "...will
decrease as systems are eliminated." to "...will decrease
as failed systems are rehabilitated or eliminated."
Table 27, Family Income/User Charge - Under Regional
Sewerage, change "from" to "for", and under Small Area
Treatment Plants, change "from" to "for" (twice)
Last paragraph is wrong. MSD is the only public owner
not subject to the PSC. See KRS 278 010(3)(f)
Existing Water Quality Conditions, 1st paragraph - Change
"Middle Branch of Beargrass..." to "Middle Fork. . . "
2nd paragraph, line 1 - Change "plant" to "plants"
1st paragraph, last line - Change "-preserve'1 to "-pre-
serves"
3rd paragraph - Your assumptions are invalid because you
include federal share of capital cost for "...on-site rehabili-
tation, and collectors..."
MSD-9. EPA does not agree.
MSD-10. See Chapter 4 for correction.
MSD-11.
Comment noted.
MSD-12. The actual flow is 28,000 gpd; the permitted flow is
110,000 gpd.
MSD-13. EPA disagrees. Flows will decrease when systems are
eliminated; rehabilitation will not necessarily decrease flows.
MSD-14.
EPA concurs.
MSD-15. The average annual household costs in Chapter 4 were
calculated in 1981 for the draft Alternatives Evaluation Report
and were based on regulations in effect at that time. These costs
wrre recalculated in 1983 to reflect the changes in federal funding
laws; the revised costs were presented in Section 5.3 of the DEIS.
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2/27/84
Draft Enviromental Impact Statement
Page 3
MSD-17
MSD-18
MSD-19
203
204
USD-19| 207
MSD-20 J222-224
MSD-18 I 223
MSD-18 I 224
MSD-18| 237
MSD-18 I 242
Comment
3rd paragraph - Hite Creek WTP has a design flow of 4.4
mgd, not 4.9
There are a few differences regarding sewer lengths be-
tween Table 43 and Figure 20. They are as follows:
Design Table 43-Length
DS-1 530
IN-1 420
LG-1» 9,280
RT-1 760
PL-1 1,410
Figure 20- Length (scaled)
(feet)
1,100
2,650
32,800
2,000
3,800
* Includes entire Little Goose Creek Interceptor
Assessments, 1st paragraph, line 7 - Statement is wrong -
MSD does not assess based on square feet of lot. We
assess based on "Assessable Units." An "Assessable Unit"
is defined as "A single*family residential lot, or equivalent,
on which no more than one single-family residence can
reasonably be constructed. Properties other than single-
family residential lots shall be equated to assessable units,
as determined by MSD. Apartment units are deemed equal
to one-half an Assessable Unit." The size of the lot is not
a factor.
Table 50 - Under LS2c and 201 add »0%(a)" and »55%(a)"
the same as you did for LS2a
Table 52 - (Same as for Table 50)
For consistency, add "after route has been staked" in
NC-6, NC-8, GS-1, LG-1 and HC-1
GS-4/GS-5/GS-6 - Change "habitational areas" to habita-
tional sites"
LG-3/LG-4/LG-5/LG-6 - Change "habitational areas" to
"habitational sites"
Section 5.4.6, 1st line - Change "mitigated" to "mitigative"
Table 60, 2nd column, 3rd member - Change "Wendy Hills"
to "Windy Hills"
ECE1/U
00
MSD-16. The number 4.9 la correct in the context of thts section,
because It was the flow used by KNREPC to calculate effluent
limitations.
MSD-17. The lengths of sewers given in Table 43 were not obtained
by measuring the lengths on Figure 20. Figure 20 is merely a
visual representation of what is described In the text. The
lengths in Table 43 were measured from MSD maps with a much larger
scale than 1 inch equals 4,000 feet and were used for costing
purposes only. The actual length of Interceptors will be
determined during design.
MSD-18.
See Chapter 4 for corrections.
MSD-19.
Comment noted.
MSD-20.
EPA disagrees; pedestrian surface survey and shovel testing
may be done before or after route is staked. Deep testing need
only be done after route is staked so as to minimize use of heavy
equipment and presence of deep pits. The surface survey may
indicate the need for further deep testing.
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United States Department of the Interior
OFFICE OF ENVIRONMENTAL PROJECT REVIEW
Sootheul Region / Suite 1384
Rlchiid B. RumD Fedcril BuUdinj
75 Sprint Slieet. S.W. / AtlinU, Ci. 30303
FEB24 QQ4
DOI-1
DOI-2
DOI-3
IR-84/68
Mr. Ronald J. Mikulak, Project Officer
Environmental Assessment Branch
Environmental Protection Agency
345 Courtland Street, NE
Atlanta, Georgia 30365
Dear Mr. Mikulak.:
We have reviewed the Draft Environmental Impact Statement for
Wastewater Facilities, North Jefferson Count?, Kentucky, and have the
following ocranents.
Mineral Resources
Since 1975, mineral deposits in Jefferson County have yielded
limestone, sand and gravel, and clay. Cement is produced from one
plant in the county. The preferred alternative would include a
wastewater interceptor system, the exact routing of which should take
into account known mineral deposits and processing plants. Thus, it
is suggested that a survey and an evaluation of mineral resources be
made in the area. We believe that with proper planning the project
would produce no major conflict with mineral resources or development.
Also, we suggest that the statement should nrtrlress the need for proper
care in abandoning septic tanks and drainfields or other onsite
treatment facilities.
Fish ana Wildlife Resources
There are two areas that concern fish and wildlife resources within
the study area: (1) the Caperton swamp forest on Muddy Fork in the
vicinity of Indian Hills Trail, and (2) the bottomland hardwood forest
areas on the f loodplain terraces of the Ohio River (especially the
mature bottomland forest located near the town of Prospect). The
wetland and bottomland hardwood forest habitats occurring in these
areas fall into Resource Category 2 of the U.S. Fish and Wildlife
Service Mitigation Policy; the mitigation goal for this category is no
net loss of in-kind habitat value. In keeping with the mitigation
policy, it is recantnended that either these habitat areas be avoided
completely or that all losses to these habitats be canpensated by
replacement of the same kind of habitat value so that the total loss
of such in-kind habitat value will be eliminated. Specific ways to
achieve compensation for such habitat losses include (1) physical
DOI-3
modification of replacement habitat to convert it to the sane type
lost; (2) restoration or rehabilitation of previously altered habitat;
(3) increased management of similar replacement habitat so that the
in-kind value of the lost habitat is replaced; or (4) a combination of
these measures.
Thank you for the opportunity to conment on this statement.
Sincerely yours.
James H. Lee
// Regional Environmental Officer
DOI-1. From the preliminary survey of Interceptor corridors,
disruption of any processing plants or actively worked mineral
deposits is not expected. Construction of interceptors should
not significantly conflict with future working of deposits
because of the limited amount of land consumed by the interceptor
route.
DOI-2. It may be prudent for homeowners to fill in abandoned
septic tanks when they connect to the public sewer. Guidance in
such activities would be provided by HSD and/or the Health
Department.
DOI-3. Consultation with the U.S. Fish and Wildlife Service will
be required as a grant condition for interceptors constructed in
the Caperton swamp forest and the bottomland hardwood forest areas
on the floodplain terraces of the Ohio River. See Section 3.2 for
the revised requirements.
NJ
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131
6. LIST OF PREPARERS
U.S. ENVIRONMENTAL PROTECTION AGENCY
Robert B.
Ronald J.
Daniel B.
Howard
Mikulak
Ahern
Chief, NEPA Compliance Section
Project Officer
Chief, North Area Grants Manage-
ment Section
GANNETT FLEMING CORDDRY AND CARPENTER, INC.
Thomas M. Rachford, P.E., Ph.D.
David L. Sheridan, P.E., Ph.D.
Stephen G. DeSesa
Jeff Elseroad
"John W. Jacobs
Larry C. Wills
Ronald R. Wright
John J. Boland, P.E., Ph.D.
Senior Project Manager
Project Manager
Environmental Engineer
Environmental Engineer
Environmental Scientist
Environmental Planner
Environmental Engineer
Consultant—Professor of
Geography and Environmental
Engineering at the Johns
Hopkins University
CLAUDE TERRY & ASSOCIATES, INC.
Claude E. Terry, Ph.D.
Louise B. Franklin
R. Gregory Bourne
James P. Butner
Robert J. Hunter
R. Michael Morgan
Project Executive
Project Manager
Environmental Scientist
Environmental Scientist
Environmental Scientist
Landscape Architect
OSM ARCHAEOLOGICAL CONSULTANTS, INC.
Carey B. Oakley
President
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133
REFERENCES
Louisville and Jefferson County Planning Commission (LJCPC). 1979. The
Comprehensive Plan: Guided Growth and Redevelopment for Louisville
and Jefferson County.
MacGregor, J. 1983. Non-Game Wildlife Program, Kentucky Department of Fish
and Wildlife Resources. Frankfort. Personal communication.
U.S. EPA. 1980a. Design Manual: Onsite Wastewater Treatment and Disposal
Systems. Washington, D.C.
U.S. EPA. 1980b. Project Background and Environmental Inventory Report for
the North County Area Environmental Impact Statement, Jefferson County, Kentucky
(Draft). EPA Region IV, Atlanta.
U.S. EPA. 198la. Alternatives Development Report for the North County Area
Environmental Impact Statement, Jefferson County, Kentucky (Draft). EPA Re-
gion IV, Atlanta.
U.S. EPA. 1981b. Alternatives Evaluation Report for the North County Area
Environmental Impact Statement, Jefferson County, Kentucky (Draft). EPA Re-
gion IV, Atlanta.
U.S. EPA. 1983a. Draft Environmental Impact Statement for North Jefferson
County, Kentucky, Wastewater Facilities. EPA Region IV, Atlanta.
U.S. EPA. 1983b. Preferred Alternative Report for the North County Area Envi-
ronmental Impact Statement, Jefferson County, Kentucky (Draft). EPA Region
IV, Atlanta.
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