xvEPA
United States
Environmental Protection
Agency
Region 8
1860 Lincoln Street
Denver, Colorado 80295
Environmental
Impact
Statement
Appendix
EPA 908/5-79-002C
June, 1980
Final
Northglenn Water Management Program
City of Northglenn, Colorado
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EPA - 908/5-79-002C
FINAL ENVIRONMENTAL IMPACT STATEMENT
NORTHGLENN WATER MANAGEMENT PROGRAM
CITY OF NORTHGLENN, COLORADO
APPENDIX
EPA
Prepared by
U.S. Environmental Protection Agency
Region VIII
1860 Lincoln Street
Denver, Colorado 80295
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INTRODUCTION
This volume of the Northglenn Water Management Program Environmental
Impact Statement contains supporting information and documents for the
summaries, conclusions, and decisions presented in the main volume of the
EIS.
Much of' the information presented herein was developed subsequent
to the issuance of the draft EIS for public review, and in anticipation
or in response to comments received from individuals, organizations and
groups, and government agencies at the local, regional, state and federal
level.
Written comments received together with EPA's responses to these
comments are contained in Appendix A. Appendix B and Appendix C are taken
from the Draft EIS and contain basic information necessary to support
impact analyses. Appendix C through Appendix J present new information,
and Appendix K and Appendix L are draft agreements necessary to implement
the project. Appendix M is an analysis of another water supply alternative
submitted by opponents to the plan but too late to be included in Chapter 3.
Appendix N is an analysis by Northglenn's engineers in response to the
review of the proposed system performance presented in Appendix E.
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ACKNOWLEDGEMENTS
Because of the magnitude of the effort required to produce this
environmental impact statement, it is an impossible task to acknowledge
all of the people and agencies who contributed to the final product.
A heart-felt thanks is extended to the individuals who have contributed
and assisted in the completion of this monumental effort. A special
thanks is offered to all of the secretaries without whose patience and
long hours the project could not have been competed.
DISCLAIMER
This report has been reviewed by the EPA, Region VIII, Water
Division and approved for publication. Mention of trade names
or commercial products does not constitute endorsement or recommendation
for use.
DOCUMENT AVAILABILITY
This document is available in limited quantities through the
U. S. Environmental Protection Agency, Environmental Evaluation
Branch, 1860 Lincoln St., Denver, Colorado 80295. This document
is also available to the public through the National Technical
Information Service, Springfield, Virginia 22161.
ii
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TABLE OF CONTENTS
LETTER RECEIVED FROM PAGE
Colorado Historical Society A-l
The Rocky Mountain Fuel Company A-2
The Rocky Mountain Fuel Company A-3
United States Department of the Interior
National Park Service A-4
Department of Health Education and Welfare
Region VIII A-5
City of Thornton A-6
Department of Housing and Urban Development A-8
Department Of The Army A-9
Jerome Goldstein, Editor of Compost
Science/Land Utilization A-ll
Davis, Graham & Stubbs A-12
Davis, Graham & Stubbs A-19
City of Westminster, Colorado A-25
Joseph D'Orazio A-27
Holly Wm. Hall, Mayor, Town of Fredrick A-29
Adolph Coors Company A-37
Town of Firestone, Weld County A-43
The Great Western Sugar Company A-45
Fu Hua Chen, President Chen and
Associates, Inc. A-47
Town of Dacono A-48
Urban Drainage and Flood Control
District 69 A-50
United States Department of Agriculture
Forest Service A-52
Department Of The Army A-53
W. W. Wheeler and Associates, Inc. A-55
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LETTER RECEIVED FROM PAGE
Colorado Project/T.I.P. A-74
The Farmers Reservoir and Irrigation Co. A-75
U.S. Department of Transportation
Federal Highway Administration A-77
United States Department of the Interior
Office of the Secretary A-78
City of Fort Lupton A-81
Evelyn E. Knaub, Henry Knaub A-83
Weld County Colorado, Office of Board of
County Commissioners A-84
Colorado Department of Local Affairs
Paula Herzmark, Director A-91
State of Colorado, Morgan Smith, Commissioner A-94
Office of Energy Conservation A-100
Division of Water Resources, Department of
Natural Resources; Hal D. Simpson, Chief
Water Management Branch A-101
State of Colorado; Colorado Geological
Survey, Department of Natural Resources,
James M. Soule, Engineering Geologist A-103
Department of Natural Resources; Colorado
Water Conservation Board; Daniel L. Law,
Water Resource Specialist A-104
Department of Natural Resources; Division of
Wildlife, Jack R. Grieb, Director A-107
Tom Ambalam, Professional Engineer
City of Sorthglenn A-108
Denver Regional Council of Governments;
Robert D. Farley, Executive Director A-lll
City of Thornton; Gary R. Palmer, P.E.,
Utilities Director A-112
City of Northglenn; Richard P. Lundahl
Director of the Department of Natural
Resources A-115
Larimer-Weld Regional Council of Governments A-126
Larimer-Weld Regional Council of Governments A-128
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LETTER RECEIVED FROM PAGE
Weld Co., Colorado, Office of Board of
County Commissioners A-146
Larimer-Weld Regional Council of Governments A-149
Francis K. Culkin, Attorney at Law A-161
Albert Watada, Consolidated Ditches A-165
Summary of Draft EIS Public Hearing Record
February 13, 1980 Northglenn Community
Center A-167
City of Thornton
May 1, 1980 A-173
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COLORADO
HISTORICAL
SOCIETY
The Colorado Heritage Center 1300 Broadway Denver. Colorado 80203
January 16, 1980
Sorer L. Williams
Regional Administrator
U.S. Snvironmental Protection Agency
1860 Lincoln Street
Denver, Colorado 80295
Hear Mr. Villians,
This is to acknowledge receipt of the Draft Snvironmental Impact Statement for
the HorthPlenn Water Management Plan, Horthglenn. Colorado.
Date Received: .T«T»I»TV 14. 1980
Date Due: February 25. 1980
Since this proposed project apparently will not affect Cultural Re-
sources, responsibilities under 36 CFR 800 are fulfilled by retaining
documentation of review by this office.
Thank you for the opportunity to comment on the proposed project.
If this office can be of further assistance, please do not hesitate
to call upon ES Reviewer Betty LeFree (Office of the State Archaeolo-
gist) at 839-3391.
Sincerely
Ji
l\
thur C. Townsend
State Historic Preservation Officer
cc: B. Rippeteau State Archaeologist
J. Bartmann Coordinator, Historic Preservation
*•• McGregor, Sheaffer & Roland, Inc.
ACTfBJI.) \^
RESPONSE:
EPA acknowledges that the proposed project will not affect
cultural resources.
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January 17, 1980
T
ro
Mr. Roger L. Williams
Regional Administrator
United States Environmental Protection Agency
1860 Lincoln Street
Denver, Colorado 80295
Dear Mr. Williams
The "Draft Environmental Impact Statement" of the Northglenn Water Manage-
ment Program discusses on page 7 of chapter one, the need for ponds to
control the irrigation tailwaters flowing into the Town of Frederick.
For Northglenn to comply with this requirement, it would be necessary for
Northglenn to purchase land owned by this company.
Please be advised of the following:
1 I 1) Northglenn has made no offer to this company to purchase such land,
2) The sale of a parcel of land of the size required would be contrary to the
subdivision and zoning ordinances of Frederick,
3) The location of the proposed tailwater pond would seriously diminish the
value of the remaining land, and
4) It is unlikely that this company would sell this site to Northglenn because
of the strong public opposition of the Northglenn plan by citizens of
Frederick.
This issue is just one of many which shall be commented on to your agency on or
before February 25th. I am taking this opportunity, however, to advise you of
this discrepancy so that alternatives may be at hand for the meeting of February 13th.
Yours very truly.
3|
«l
RESPONSE:
Gerald R.Armstrong, President
cc: Mr. Wes Wilson
*, MO
1. Negotiations between Rocky Mountain Fuel Company and
Northglenn are the responsibility of Northglenn.
2. The sale of this land would have to abide by existing zoning
ordinances.
3. EPA recognizes that the value of land adjacent to a tailwater
control pond could decrease.
A. No response is necessary.
608 EMPIRE BUILDING. 430 SIXTEENTH STREET • DENVER, COLORADO 80202 • (303) 573-9655
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January 17, 1980
Mr. Wes Wilson
United States Environmental Protection Agency
1860 Lincoln Street
Denver, Colorado 80295
Dear Wes
Holly Hall has advised me that you believe the location of the
Standley Ditch may be moved to the east of this company's
property.
So long as thi-s company owns its FRICO shares, it has rights
to the water from its current location.
Neither Northglenn, Thornton, or FRICO has sought our consent to
this nor has any entity made any offer to purchase or exchange our
shares.
Wes, by this time you should realize that Northglenn's representa-
tions are not, in fact, performance.
Concerning the proposed tailwater pond, please review the enclosed
copy of my letter to Roger Williams.
Yours very truly
rent
RESPONSE:
1 Initial discussions with Northglenn's engineers indicated
that relocation of the Bull Canal is not feasible. This
option of solving the tailwater problem has been dropped
from further consideration.
««&<&*k»V<
Gerald R. Armstrong, Presiden
Enclosure
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IN REPLY REFER TO
L7621 (RMR)PC
United States Department of the Interior
NATIONAL PARK SERVICE
ROCKY .MOUNTAIN REGIONAL OFFICE
655 Parfet Street
P.O. Box 25287
Denver. Colorado 80225
2 5 JSK 19""
Mr. Roger L. Williams
Regional Administrator
United States Environmental Protection Agency
I860 Lincoln Street
Denver, Colorado 80295
Dear Mr. Williams:
The National Park Service has reviewed the draft environmental impact
statement for the Northglenn Water Management Program, City of
Northglenn, Colorado. We support Northglenn's attempt to manage
their water so as to retain much of the land historically
irrigated.
Slqcqrely you
RESPONSE:
1. Acknowledge
Richard A./Strait
Associate Regional Director
Planning and Resource Preservation
'*';
VCONSERVE
A-S
Save Energy and You Serve America!
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3EPARTMENT OF HEALTH EDUCATION ANC
CENTER COt.CRACC BC39.S
January 30, 1980
Ui
Mr. Roger L. Williams
Regional Administrator
United States Environmental
Protection Agency
Region VIII
1860 Lincoln Street
Denver, Colorado 80295
Dear Mr. Williams:
The Draft Environmental Impact Statement, Nortnglenn Water Management
Program, City of Northglenn, Colorado, has been reviewed by the Public
Health Service in Region VIII. No comments will be submitted at this
time.
RESPONSE:
1. Acknowledge
SI
ly jwurs,
& —
iary Hi| Connor, M.O.
Regional Health Administrator
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City Hall
City of
Thornton
8992 N •Vasning'on Si'ee;
Tno'tion CoiO'aco 60229
303: 289 SBC"
January 31, 1980
Mr. Roger L. Williams
Regional Administrator
United States Environmental
Protection Agency
Region VIII
1860 Lincoln Street
Denver, CO S0295
Dear Sir:
REG:0.'! ...I i
Water Division
The City of Thornton Utilities Board and City Council
would like to take this opportunity to formally comment
on the draft environmental impact statement regarding the
proposed Northglenn Water Management System. Although we
do not take exception to the management plan, we are con-
cerned about certain statements about the level of service
provided to Northglenn by Thornton.
There is an overriding concern about the quality of Thornton's
finished water. It can be implied from the report that
Thornton's water is in some way unsafe or unpotable. The
City of Thornton ' s water supply currently meets or exceeds
EPA Safe Drinking Water Standards. Planned improvements to
our treatment process and raw water supply system ensure
that Thornton will continue to meet the EPA standards.
There are also some comments in the plan regarding the abil-
ity of Thornton to adequately serve the City of Northglenn
either now or in the future. The City of Thornton presently
has the ability to serve the City of Northglenn and is capable
of doing so in the future. The reason for the City of Thornton
entering into a severance agreement with the City of Northglenn
was not because of any stated need by the City of Thornton,
this agreement was entered into only to accommodate the desires
of our sister city. Thornton has the necessary plant and
water resources to adequately serve the City of Northglenn.
Enclosed i,s a letter from Mr. Wesley R. Brown, Chairman of
the Thorn,ton Utilities Board, to then Mayor-elect Odell Berry
stating Thornton's continued willingness to serve.
RESPONSE:
1. EPA did not intend to imply that current water quality of
Thornton's vater supply is unsafe. As stated in the draft
EIS (page 15) Thornton has corrected previously identified
water quality problems.
2.
EPA review indicates that Thornton must expand its water
resources system in order to adequately serve the future
growth of both Thornton and Northglenn. Engineering analysis
of the necessary water resources has not been completed by
the City of Thornton. See water supply alternative analysis.
(2A
The C-:> o* Pla-inea P-ocress
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Mr. Roger L. Williams
Page Two
January 31, 1980
We of the Thornton Utilities Department welcome the oppor-
tunity to further detail our views regarding the Northglenn
Hater Management Plan. The Utilities Department staff is
presently conducting an in-depth review of the Environmental
Impact Report and will make their factual correction avail-
able to your staff.
Sincerely,
Wesley/H. Brown, Chairman
Utilities Board
Margarejt W. Carpenter
Mayor
I WRB, MRC/bs
Enclosure
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DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT
REGIONAL/AREA OFFICE
EXECUTIVE TOWER -1405 CURTIS STREET
DENVER. COLORADO 8030}
January 31, 1980
8SOQ
oo
Mr. Roger L. Williams
Regional Administrator
U.S. Environmental Protection Agency
1860 Lincoln Street
Denver, Colorado 80295
Dear Mr. Williams:
FEB07 1980
Dili
i£PA REGION V11IL
Mater Division
Thank you for the opportunity to review the draft Environmental Impact
Statement (EIS), "Northglenn Water Management Program, City of Northglenn,
Colorado."
Your draft EIS has been reviewed with specific consideration for the areas
of responsibility assigned to the Department of Housing and Urban Develop-
ment (HDD) for review of other agencies' EISs. These areas focus upon a
proposal's compatability with local and regional comprehensive planning and
impacts on urbanized areas.
Tour draft EIS failed to discuss the long-term impacts which the proposal
may have upon the health of the affected urban population. Consideration
should be given to the possibility that a change in the existing ground water
table could cause any section of the Bull Canal proposed for sewage water flow
to leak nitrates into the ground water supply. Lining such a section might
act as a mitigation. Also, the odor and safety hazard associated with the
sewage water flow in the Canal should be better described. Possible mitigation
could include fencing along with a suggested minimum distance to any proposed
residential units. The radiological and chemical hazards associated with the
Rocky Flats Nuclear Facility should be discussed in relationship to the present
and possible contamination of the Standley Lake water supply, including what
safety measures will be taken in the event that a sudden contamination of this
water supply occurs.
We appreciate the opportunity to review and comment on this draft EIS. If
you have any questions regarding these comments, please contact Mr. Carroll
F. Goodwin, Area Environmental Clearance Officer, at (303) 837-3102.
Sincerely,
RESPONSE:
1.
3.
Unin. f IT V? Pr°J««, ™ICO has undertaken the
any not M ? ^ ^^^ ™S ^P^ent action will reduce
any potential problems related to groundwater contamination.
miti*atSio0nSlTered fenC1"8 " M alt«n*tlve safety hazard
fectfv < < T C°ncluded that fe"Ci->8 "as not as ef-
fective a mitigation measure as treatment controls. EPA
treatme'Tf
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DEPARTMENT OF THE ARMY
OMAMA DISTRICT COOPS OF ENGINEERS
6014 U.S. POST OFFICE AND COURTHOUSE
MROED-DK
5 February 1980
Mr. William H. Horraberg
Director, Office of Grants
United States Environmental
Protection Agency
Region VIII
1860 Lincoln Street
Denver, Colorado 80295
VO
Dear Mr. Hormberg:
This is in response to your letter dated 18 January 1980 requesting
our opinion of the natural clay liner proposed for the wastewater
storage reservoir at Northglenn, Colorado.
Your concern over the leakage potential of a 6-inch clay layer is
valid but, in our opinion, the intent of the specifications is to
provide an effective liner well in excess of six inches. Granular
material or fractured materials encountered in the reservoir bottom
must be removed and replaced with two feet of compacted select
impervious materials. For other areas, the top six inches is to be
scarified and recompacted to at least 95 percent of maximum density.
We believe this procedure will provide a permeability in the 6-inch
blanket of less than 10~^ cm/sec if the surface soils are clays.
The overall leakage will not present a problem if, immediately below
the 6.-inch recompacted layer, the soils are relatively impervious
as indicated in the soils report.
Our primary concern
(six inches or less)
material which would
of the prepared bott
data. Therefore, it
of the soils which f
soils engineer. The
impervious materials
allowed to dry and c
surface moist after
happening.
is the possibility of a relatively thin
layer of impervious material over pervious
not be apparent from either a visual inspection
om or examination of the existing soil boring
is essential that close inspection and testing
orm the bottom be conducted and approved by a
risks associated with isolated thin layers of
would be compounded if the bottom surface is
rack. We suggest a requirement for keeping the
it has been constructed to preclude this from
RESPONSE:
1. EPA acknowledges the potential risks of not providing an
impervious seal. Northglenn will be required to include
inspection and testing of soils, and assure proper soil
moisture content during construction.
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MROED-DK 5 February 1980
Mr. William H. Hormberg
The soils reports and preliminary environmental report 'furnished with
your 18 January 1980 letter are inclosed.
Sincerely,
2 Incls R. G. BURNETT
1. Soils Reports Chief, Engineering Division
2. Prelim Environ Report
DECEIVED
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western union
Telegram
nFVC£7.t; A.LS ft-.
RESPONSE:
1. Acknowledge
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DAVIS, GRAHAM & STUBBS
ATTOKMCVI AT LAW
«30 COLORADO N*TiOM*l. BUILDING
•SO SlweNTB£NTM STUEft
DCNVCM, COLORADO IO2O2
TetecMONe 303 e*a-»*oo
February 13, 1980
O«"'O J »CO*T
•,C"A H lOHt
joftr* j Vfu.iv
•H<**>LL » »NH
N>
Mr. Roger Williams
Regional Administrator
Environmental Protection Agency
1860 Lincoln Street
Denver, Colorado 80203
Re- Public Hearing of February 13, 1930
at the Northglenn Community Center
Dear Mr. Williams:
we have not yet received a response «!.our
of February 12, 1980, hand delivered to your office on that
same day.
we appear at these Agency proceedings of February
ofthe Councif of Environmental Quality P««.in^to the
preparation of a draft Environmental Impact Statement.
Attached hereto as Appendix 1 is our letter of
The issue of compliance with the scoping process was subject
to litigation in Consolidated Bitches Company, et.al. vs.
EPA. The issue was settled by mutual written agreement
between EPA and these parties on June 2, 1980. It is EPA's
position that during the last two years of review by our
agency; the environmental assessment, public meetings and
numerous phone calls regarding the Northglenn proposal
were sufficient to satisfy the intent and purpose of the
public scoping process required under recent regulations
promulgated by the Council on Environmental Quality.
violated by the Agency.
ai=r, a^^at-hed hereto as Appendix 2 is a letter
f Aucust n 1979 from EpTcontracWr, Engineering-Science,
to tne Nortngienn »A ^Project Officer, Mr. Wes Wilson,
pointing out that a:
-thorough evaluation of alternative water
supplies for Northglenn has not to our
knowledge been accomplished. In order to
address the reasonableness of wastewater
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Mr. Roger Williams -2- February 13, 1980
"alternatives that discharge to other
than Bull Canal, at least the likeli-
hood of developing alternate water
supplies needs to be addressed*.
This letter also points out that very little water rights
information had been provided to the contractor by North-
glenn and that changes were constantly occurring in the
information being supplied by Northglenn.
Attached as Appendix 3 is a letter of October 12,
1979 from the EPA Contractor, Engineering-Science, to EPA
Northglenn Project Manager, Wes Wilson, stating their con-
clusion that an Environmental Impact Statement should be
prepared for the project under the applicable CEO, EPA
and EIS requirements. The letter proposes that an En-
vironmental Impact Statement would be prepared using the
Environmental Analysis prepared by Engineering-Science and
EPA as a basis. This letter clearly points out that a
draft EIS under applicable law must include an
' evaluation of an alternative water supply
and wastewater systems", "a full scale
public participation program", and "further
consideration of land use implications of
the project",
as well as other important issues which had not been studied
in the environmental assessment.
Instead of preparing a draft EIS in accordance
with the Contractor's recommendations, and in violation of
CEW regulations, the Agency merely changed covers on the
Environmental Assessment and issued that document as a
draft EIS. This action is a clear violation of CEQ
regulations which became effective on July 30, 1979
(40 C.F.R. 1506.12) and are binding on all Federal Agencies
for implementing the procedural provisions of the National
Environmental Policy Act (40 C.F.R. 1500.3). The CEQ
regulations clearly provide that
"draft environmental impact statements
shall be prepared in accordance -with the
scope decided upon in the scoping process".
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Mr. Roger Williams -3- February 13, 1980
(40 C.F.R. 1502.9 (a)). The scoping process must be under-
taken after the Agency decides to prepare an Environmental
Impact Statement, unless ic has clearly issued notice to
the public that scoping will be combined with the preparation
of the Environmental Assessment. (40 C.F.R. 1501.4(2)(d)).
Such was not the case here. At no time were our clients.
Rocky Moutanin.Fuel Company and Consolidated Ditches
Company, or any members of the public notified that
scoping would be coterminous with che preparation of an
EIS.
According co the CEQ regulations, the alternatives
consideration of a draft EIS is the "heart" of the statement"
"it should present the environmental impacts
of the proposal and the alternatives in com-
parative form, thus sharply defining the
issues and providing a clear basis for choice
among options by the decisionmaker and the
public".
(40 C.F.R. 1502.14). This same regulation further provides
that the Agency shall"
"rigorously explore and objectively evaluate
all reasonable alternatives", "devote sub-
stantial treatment to each alternative con-
sidered in detail including the proposed
action", "include reasonable alternatives
not within the jurisdiction of the lead
agency", and "include the alternative of
no action".
(40 C.F.R. 1502.14(a)-(d).
The requirements of NEPA and CEQ state that the
purpose of the NEPA process is to study the
"relationship between short-term uses of man's
environment and the maintenance and enhance-
ment of long-term productivity, and any irrever-
sible or irretrievable commitments of resources
which would be involved in the proposal should
it be implemented"
(40 C.F.R. 1502.16).
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Mr. Roger Williams -4- February 13, 1980
The purpose of the scoping proceedings is to
"determine the scope and the significant issues
to be analyzed in depth in the environmental
impact statement".
(40 C.F.R. 1501.7(a)(2).
As clearly demonstrated from the correspondence
of EPA's contractor, the Environmental Assessment
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Mr. Roger Wiiliams -5- February 13, 1980
its project prior|to the completion of the NEPA process.
Attached hereto as Appendices 4 and 5 is the two volume
deposition of Richard P. Lundahl, Director of Natural
Resources of the City of Northglenn. On pages 34, 35,
and 36 of volume 1 (Appendix 4), Mr. Lundahl testified
that EPA representatives authorized Northglenn to pro-
ceed with portions of its project. This.is in direct
violation of the CEQ regulations which provide that no
action shall be undertaken, except for the preparation
of plans and designs, that will
"have an adverse environmental impact"
or "limit the choice of reasonable
alternatives".
(40 C.F.R. 1506.l(a) (1) (2))- This same regulation states
that, when the Agency becomes aware that an applicant
is taking an action which either has an adverse en-
vironmental impact or limits the choice of reasonable
alternatives, the Agency shall promptly
"notify the applicant that the agency
will take appropriate action to insure
that the objectives and procedures of
NEPA are achieved".
(40 C.F.R. 1506.Kb)).
It appears that EPA, in violation of law, has
encouraged Northglenn to commence construction of facilities
which will commit Northglenn co implementing the proposed
Northglenn project at the same time that the Agency is
required by law to study all alternatives, including the
no action alternative.
The CEQ regulations state that "environmental
impact statements" shall serve as the means of assessing
the environmental impact of proposed agency actions,
rather the justifying decisions already made." (40
C.F.R. 1502 (g)). Mr. Lundahl's testimony in volume II of his
deposition clearly shows that the City of Northglenn did
not pursue application to the Denver Water Board to supply
Northglenn with its water needs, nor has it pursued having
Thornton continue to supply its needs, nor has it studied
any other means for supplying water to the City of Northglenn
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Mr. Roger Williams -6- February 13, 1980
other than through the FRICO Exchange.
By its actions in allowing Northglenn to commence
construction on facilities which implement the FRICO Ex-
change, the Agency is limiting the choices of reasonable
alternatives to the Northglenn project and is allowing
needless adverse environment impacts to occur. It is
clear that the proposal to build the wastewater treatment
facility in Weld County, for which EPA funding is sought,
is tied inextricably to the FRJCO Exchange, because this is
the means by which the "borrowed" water will be returned
to FRICO.
We reserve the right to submit further written
comments which more fully elucidate our position. However,
at this time, we are requesting the following actions
from you, in your capacity as Regional Administrator of
the Environmental Protection Agency:
1. That you consider this February 13, 1980
proceeding as a scoping proceeding under the re-
quirements of the CEQ regulations.
2. That you order preparation of a draft
Environmental Impact Statement based upon this
scoping proceeding and all other available in-
formation.
3. That you inform Northglenn immediately
that it cannot construct any feature of the North-
glenn Water Management Program until the NEPA
process has been completed, and agency decision
and record of agency decision has been prepared
in compliance with NEPA, CEQ and EPA requirements.
4. That you issue an order to Northglenn
instructing it to cease construction of any aspect
of the Northglenn Water Management Program which is
now under construction, and-that you petition the
Court to obtain curtailment of any such con-
struction, if Northglenn chooses to proceed with
construction of any aspect of its Water Management
Program during the pendency of the NEPA process.
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T
M
00
Mr. Roger Williams -7- February 13, 1980
Our clients are willing to cooperate with the
Agency study and believe that the above actions are
necessary and will demonstrate the good faith of the
Agency, if undertaken.
Sincerely,
Gregory J. Hobbs, Jr.
for
DAVIS, GRAHAM & STUBBS
GJH Jr/hm
Enclosures
-------
0-CQHHO*
*t«
NICHOLS AWAH U tO* I
*•!(*! j* A *awcc C
vt*>«Ow mu.
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Mr. Roger Williams -2- February 12, 1980
water quality area to advise them, and the Agency, on
matters which should be studied in a draft Environmental
Impact Statement. Our clients have also requested that
Northglenn and the Environmental Protection Agency make
available all information they have which bears on the
project. This information is still being gathered and
analyzed by the consultants our clients have hired.
Our clients are being deprived of the time which
the CEQ regulations contemplate will be allowed for pre-
paration of comments on a draft Environmental Impact
Statement following•the scoping proceeding. In fact,
the draft Environmental Impact Statement for the North-
glenn project is no more than the environmental assess-
ment with a new cover and a proposed decision. We
cannot understand why the Agency is in such a rush to
avoid issuing a draft Environmental Impact Statement
in accordance with the CEQ regulations. We believe
that we should have the opportunity to comment on a draft
Environmental Impact Statement which has been prepared
following proper scoping.
I met with my clients yesterday, and they have
authorized me to state to you that they are willing to
consider the meeting of February 13, 1980 at the North-
glenn Community Center as a "scoping" proceeding, and
are willing to waive their claim that a new°Federal
Register Notice be prepared giving notice of a scoping
proceeding, if you are willing to order the preparation
of a draft Environmental Impact Statement for public
comment responsive to the issues raised at the February
13th meeting.
We formally ask that you make this decision at
this time and that your representative announce at the
opening of the February 13th meeting that the proceeding
will be in the nature of a "scoping" meeting and that a
draft Environmental Impact Statement will be prepared
for public comment which is responsive to the issues
raised at this meeting.
Sincerely,
Gregory J.'"Hobb's, Jr.
for
DAVIS, GRAHAM & STUBBS
GJH Jr/hm
-------
ENGINEERING-SCIENCE
2785 NORTH SPEER BOULEVARD • DENVER. COLORADO 60211 • 303/455-4427
August 21, 1979
Kr. Wes Wilson
Project Officer
U.S. EPA, Region VIII
1860 Lincoln Street
Denver, CO 80211
SUBJECT: NORTHCLENN EA
Dear Wes:
Pursuant to recent discussions this letter is to summarize the status
of the subject project relative to problems encountered in preparation
of the Environmental Assessment.
>
| As we have indicated, since beginning work on the project, we have con-
No tinually encountered unanticipated problems such as lack of data, dis-
I1 crepancies in information, identification of unanticipated issues
and problems to be addressed, and the need to develop data that, at
the start, was assumed would be available.
The cumulative effect of these problems is that it is currently unlikely
that a complete Environmental Assessment adequately addressing the issues
outlined in our DOW can be prepared by 6 September 1979. We further note
that recently a number of related issues have been identified that in our
opinion should be addressed.
Below is a listing of some of the problems we have encountered to date and
the-unanticipated issues that have been identified.
1. Method to be used in preparing cost effective analyses has not been
determined. The problem revolves around innovative - alternative
technology guidelines and multiple purpose vs single purpose projects.
2. We have yet to receive a complete water rights augmentation plan to
review. We have a draft document but changes are continually occurring.
Of particular concern is that the plan docs not include specific infor-
mation relative to how the South Flatte will be protected.
offices IN PRINCIPAL ones
-------
Mr. Wes Uilson
Page 2
August 21, 1979
3. A recent problem with use of Bull Canal water in the City of Dacono
for landscape irrigation was discussed. To date we do not have a
definitive proposed resolution of this problem from Northglenn.
4. We understood that operational studies for Standley Lake have been
conducted that determine the yield. To date we have not received
this information.
5. We implemented a water quality sampling/analysis program with lab
testing conducted by USCS. The data from USGS will not be available
until at least mid-September. We are thus preparing water quality
analyses on a very limited data base (one sample in some cases).
6. A potential problem with water supply in a dry year to FRICO users
upstream of the point of return of the Northglenn wastewater has been
identified.
Based on current information, there will not be enough water to supply
their needs. This effects approximately 25 percent of the FRICO-
Standley Lake farmer shareholders.
7. Thorough evaluation of alternative water supplies for Northglenn has
not to our knowledge been accomplished. In order to address the
reasonableness of wastewater alternatives that discharge to other
than Bull Canal, at least the likelihood of developing alternate water
supplies needs to be addressed.
8. Particularly in the area of water rights and augmentation, there is
no single report or final document that can be considered a complete
and accurate information source. Must information we have to date
has been taken from working documents. Also because of the changing
nature of the information and our current schedule we are unable to
adequately check or verify the numbers.
Because of the above, it is now apparent that a thorough assessment address-
ing all the major issues for the Northglenn project cannot be completed by
6 September 1979. We can by that date have a document that will identify
issues and for many of them -be essentially a status report with unresolved
problems and an indication regarding recommended additional work.
Please contact us if you have any questions or comments.
Very, truly yours,
Allan L. Udin
Denver Office Manager
ALU/bjh
-------
ENGINEERING-SCIENCE
2785 NORTH SPEER BOULEVARD • DENVER. COLORADO 80211 • 303/455-4427
October 12, 1979
U. S. Environmental Protection Agency
Region VIII
1860 Lincoln Street
Denver, CO 80203
Attention: Mr. Wes Wilson
Project Officer
SUBJECT: NORTHGLENN ENVIRONMENTAL ANALYSIS
Gentlemen:
We are pleased to transmit herewith five copies of the Draft Environmental
Assessment (EA) for the Northglenn Facilities Plan. The work has been
conducted pursuant to Directive of Work No. 8 dated 31 May 1979 of our
contract No. 68-01-4611.
|j> The EA analyzes the proposed plan and certain options thereto. The
I direct and indirect impacts of the plan have been analyzed based on the
J^? plan status as provided by the City of Northglenn and their consultants.
W Where data were not available or still in the developing stage, appro-
priate assumptions have been made.
Most of the basic recommendations developed in negotiations between
Northglenn, EPA and ES have been incorporated into the EA. These in-
clude coliform discharge standards, provisions for protection of public
health, programs for protection of agriculture, and consideration of
irrigation of raw edible food crops with effluent. Some significant
project elements were not evaluated either because information was not
available, or the analysis was outside of our scope of work. Examples
of these include monitoring program and plant process analysis.
Based on the work performed on this EA it is our recommendation that
an Environmental Impact Statement (EIS) be prepared for this project.
This recommendation is based on the proposed rules of the EPA for Imple-
mentation of Procedures on the National Environmental Policy Act as they
appeared in the Federal Register on June 18, 1979. Therein an EIS is
required when "The environmental impact of the treatment works is likely
to be highly controversial". In our opinion this project clearly warrants
-------
Mr. Wes Wilson
Page 2
October 12, 1979
an EIS under this criterion. Other criteria presented in the proposed
rules including ". . -adversely affect significant amounts of prime agri-
cultural land. . ." and ". . . adverse effect upon. . -surface or ground-
water quality or quantity. . ." may indicate the need for preparation of
an EIS for this project.
An EIS would use the enclosed EA as a basis. There are several other
elements that must be included to fulfill the CEQ and EPA EIS require-
ments. These include:
1. In-depth analysis of the economic impact of the proposed
project including more detailed cost effectiveness analysis;
2. Evaluation of the proposed treatment process regarding
reliability and flexibility;
3. Evaluation of an alternative water supply and wastewater
systems;
4. Evaluation of long term impacts of use of non-tributary deep
aquifer water;
j' 5. Further consideration of land use implications of the project;
6. Further resolution of inter-agency problems;
7. Full scale public participation program; and
8. Resolution of legal issues associated with water rights and
augmentation.
In conclusion, we are pleased to have the opportunity to work with you on
this interesting and challenging project. We will prepare the final document
when we receive your comment.
Very truly yours.
Allan L. Udin
Denver Office Manager
ALU/bjh
Enclosures
-------
1x5
Ul
February 11, 1980
Mr. Roger L. Williams
Regional Administrator
Environmental Protection Agency
1860 Lincoln Street, Suite 900
Denver, Colorado 80295
Office of the Mayor
RE:
Environmental Impact Statement on
Morthglenn Water Management Plan
Dear Mr. Williams:
On behalf of the City of Westminster, I wish to take
this opportunity to reflect the City of Westminster's
position and thinking on the Environmental Impact Statement
pertaining to the Northglenn Water Management Plan. We
appreciate the opportunity to share our thoughts and
observations on this water plan in the public hearing which
your agency has scheduled for Wednesday night, February 13,
1980.
As your office is fully aware, the City of Westminster
has been in the utility business for many years and became
the lead agency for wastewater treatment in our City in 1970
when the Westminster Sanitation District was dissolved.
Subsequent to this vote of the people, the City embarked
upon the initial 1.0 MGD construction of the Big Dry Creek
Wastewater Treatment Plant located at 132nd Avenue and Huron
Street. We have worked closely with the Denver Regional
Office of EPA in pursuing needed expansions to the treatment
capacity at the Big Dry Plant and have been able to plan
such expansions in advance of the needs occurring in the Big
Dry Creek Basin. We are fully cognizant of the many factors
and influences which must be addressed in a water management
plan such as the one which the City of Ilorthglenn is
presently pursuing. From our experience, we can readily
conclude that establishing water and wastewater utility
services for a growing population is an ongoing challenge
and commitnent for elected city officials, professional
staff members, consulting engineers and water attorneys. We
must be in harmony with the environment and the agricultural
-continued-
RESPONSE:
1. Acknowledge
3031 West Seventy Sixth Avenue • 80030 e 303 429-1546 •
-------
Mr. Roger L. Williams
February 11, 1980
Page Two
S3
community as we pursue design and construction of needed
infra structure, treatment plants as well as assuring
dependable raw water resources.
The City of Westminster joined hands with the Cities of
Northglenn and Thornton and the Farmers Reservoir and
Irrigation Company last May in an historic cooperative
venture which was signed and executed in the presence of
Governor Richard Lamm. This historic document is a bold
indication to the public and to governmental entities such
as the Environmental Protection Agency that cities can work
in harmony on utility matters and at the same time work in a
cooperative spirit with the agricultural community. I am
certain you are fully aware of the many components of the
Four-Way Agreement which we executed in 1979 and I, therefore,
will not go into the details of the agreement. This agreement
has paved the way for the three cities to realize valuable
capacities and capabilities in carrying out their respective
utility plans. City officials representing the three respective
cities worked hard in frank and open negotiations over several
months starting in the late fall of 1978 to hammer out this
cooperative agreement. The terms of it provide the vehicle
for Northglenn to achieve a dependable water supply through
the cooperative venture with the Farmers Reservoir and
Irrigation Company. The three cities stand ready to maximize
the utilization of the Standley Lake Reservoir to assure
reliable water service to our individual constituencies.
All of us are called upon to use our imagination and
implement innovative techniques to achieve water service for
Denver metro area residents. This is especially true in
semi-arid, water short Colorado. It is prudent on the part
of governmental officials to pursue to the fullest extent
possible successive use programs utilizing limited water
resources as many times as possible prior to the water
leaving the State of Colorado. Further, we are called upon
to achieve as much storage capability as possible to store
our water resources when the bulk of the water is available
in the spring time with the seasonal run-off. The Northglenn
Water Management Plan addresses such key factors and should
be looked upon appropriately by the Environmental Protection
Agency. Petty politics and narrow minded thinking must be
set aside in resolving the remaining concerns with their
plan.
We appreciate the opportunity to provide input in this
public hearing which the Environmental Protection Agency is
conducting.
Very truly yours,
Vi June
Mayor
-------
7euJuigji.il ! I,
ro
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1. Based on analysis conducted by EPA's consultant
it has been concluded that odors that may potentially
be generated from Norchglenn's vastevater treatment
plant or storage reservoir are not likely to drift
six miles and create an Impact on the community of
Frederick.
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-------
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2. The operation of Horthglenn's wastewater treatment
facility and storage reservoir vill be such that no
discharges will occur into the irrigation ditch
during the winter months. Discharge is only to
occur during the irrigation season and will be pri-
marily confined to late spring and summer.
3. EPA has considered the option of Northglenn dis-
charging into the South Platte River. This option
which would entail Northglenn continuing to be
provided wastewater services by the Denver Metro
facility is evaluated and presented in detail in
the Environmental Impact Statement.
4. EPA believes that sufficient capacity in Northglenn's
storage reservoir will prevent the introduction of
wastewater into the Bull Canal during flooding events.
-------
February 12, 1980
to
Mr. Roger L. Williams
Regional Administrator
U.S. Environmental
Protection Agency
Region VIII
1860 Lincoln Street
Denver, Colorado 80295
Dear Mr. Williams:
Pursuant to the Notice of Public Hearing concerning the Draft Environ-
mental Impact Statement of the Northglenn Water Management Plan, the
following comments are provided by the Town of Frederick. In summary,
the Town of Frederick is greatly concerned about the adverse impacts
the proposed project will have on the Town of Frederick and the sur-
rounding areas, and as such is firmly opposed to its construction.
In connection with the Draft Environmental Impact Statement, the follow-
ing comments are provided in a numbered sequence for ease of reference.
1. Page 3. It is stated that the integrated approach to resource
management is predicated on the following factors:
"1) Northglenn's stated need to provide an adequate source
of water for its users through the year 2000."
We wish to point out that Northglenn presently has a water source
and according to the City of Thornton, which provides their water
service, the supply is adequate both in quantity and quality. It
does not appear that Northglenn has addressed this very basic
issue in a manner which would substantiate this claim. If the
City of Thornton claims that the supply is adequate and the City
of Northglenn disagrees, it should be a requirement that North-
glenn provide sufficient evidence as to their claim that they do
not have an adequate source of water through the year 2000.
2. Page 6. Items 4) and 5) of the proposed EPA Decision are stated
as follows:
"4) -there are no significant direct adverse environmental
effects of the proposal other than a potential odor
problem at the treatment site;
5) assuming the Bull Canal is currently suitable as a
domestic raw water source, if the proposal is implemented
RESPONSE: 1. EPA acknowledges that the Town of Frederick is
opposed to the construction of Northglenn's waste
water treatment facility.
2. EPA has conducted an alternative water supply analysis
in addition to the proposed FRICO exchange. Presented
in Chapter 3 is a description of the water supply
alternatives considered and presented in Chapter 4
are their associated environmental impacts.
3. Sewage effluent will be prevented from entering the
streets of Frederick under provisions of the tailwater
control plan. Frederick does not currently own water
rights along the Bull Canal nor have they requested a
water supply designation of the canal.
-------
Mr. Roger L. Williams
Region VIII - USEPA
Page Two
U>
O
Bull Canal will no longer be suitable as a source of
domestic raw water, due to nitrate concentrations.
EPA concludes that since the Canal is not presently used
for a domestic water supply, nor has there been any
formal request to designate the canal for domestic water
supply, there is no need to protect the canal for water
supply;"
The Town of Frederick greatly disagrees with the statement numbered
4) . We certainly believe that there are significant direct adverse
environmental effects other than the potential odor problem at the
site, namely, the condition of having sewage effluents from irri-
gation tailwaters run through and adjacent to the high school
grounds, junior high school grounds, and residential streets in the
Town of Frederick; and the fact that the Bull Canal will no longer
be suitable as a source of domestic raw water, which source has
been planned for use by the Town of Frederick and is needed for the
future development thereof.
3. Page 7. Item 2 states "Prevention of agriculture tailwater runoff
into the Towns of Frederick and Firestone."
"Present agricultural practices combined with a lack of •
proper storm water drainage allows runoff to flow through these
communities. Northglenn will be required, at their expense,
to intercept and control these flows in order to further reduce
public contact with tailwater runoff (treated sewage effluent)."
At the present time, Frederick is not aware of any plans to inter-
cept and control the flow of the treated sewage effluent from the
tailwaters of the irrigated lands. It is stipulated in other parts
of the EIS that holding ponds are contemplated which would provide
some control, but would not completely eliminate the situation of
wastewater being conveyed through the school grounds and residential
streets of Frederick. The proposal of constructing holding ponds
would mean that these facilities would have to be constructed in
the prime residential areas which in themselves would pose a con-
dition which would be unacceptable from a health point of view.
Additionally, the construction of holding ponds within the prime
residential areas or areas which are planned as prime residential
areas would have significant adverse impact upon the development
of the future residential sites within the Town of Frederick. In
other words, ponds containing wastewater effluent would now occupy
those vacant lands which are directly across the street from existing
residential areas and would also displace future planned residential
construction in these areas.
4. The purpose of the tailwater control plan is to pro-
vide a degree of control over wastewater used in
irrigation of lands adjacent to the existing communities
of Frederick and Firestone. It is recognized that
these ponds will be temporary in nature as urbanization
of these two communities to the east occurs. It is
expected that as the urbanization occurs, the amount
of land irrigated will gradually decrease therefore
eliminating the need for tailwater control. EPA does
not believe that as prime residential areas develop
that the tailwater control ponds will be restrictive
to this development. It is likely that as develop-
ment occurs and irrigation continues on undeveloped
land that the tailwater control plan collection system
will be modified and protect the public from coming
into contact with the irrigation wastewater.
-------
Mr. Roger L. Williams
Region VIII - USEPA
Page Three
4. Page 10. It is stated that
is not Necessary."
"Protection for Drinking Water Supplies
"The Bull Canal is not currently used for a domestic
water supply and there has not been any petition to the State
to designate this source for domestic use. Based on very
limited data, it does appear the Bull Canal is currently
suitable for a domestic raw water supply. The Town of Fred-
erick indicated to EPA they intended to use water from the
Bull Canal to augment their present surface supplies.. The
Town of Ft. Lupton has informed EPA of its intention to use
San Hill Reservoir which receives some flow from Bull Canal
as their future domestic water supply source."
"The concentration of nitrates in the canal could
adversely affect such plans since the concentration will exceed
the National Drinking Water Standard of 10 mg/1. Water contain-
ing such high concentrations of nitrates is not economically
suited as a domestic source. EPA recognizes that this change
in water quality potentially represents a resource lost. EPA
concludes that: 1) Bull Canal discharges to Sand Hill Reser-
voir are insignificant to the total inflow and, therefore,
this proposal should not adversely affect Ft. Lupton's intended
use of this source and 2) the Town of Frederick should seek
other available sources for a domestic supply."
The Town of Frederick strongly disagrees with this statement. The
Town of Frederick fully intends to use the waters of Bull Canal for
future domestic raw water supply. The water quality presently in
Bull Canal is suitable for this purpose. There are presently 760
acres of prime development land located within the existing Town
limits of Frederick. These lands were annexed with the condition
that they are obligated to provide the Town with 1 1/2 acre feet of
water for every acre of land developed. This would mean that of the
760 acres, there is a 1140 acre feet water commitment to the Town of
Frederick. It has been Northglenn's and EPA's position that in
connection with the future water supply for these undeveloped lands
the Town will simply have to look elsewhere. This is not an accept-
able solution to the Town of Frederick and at a very minimum North-
glenn should be required to protect at least the 1140 acre feet of
water from contamination from wastewater effluent in order to insure
that this water will be available for future use by the Town of
Frederick.
Refer to response to Item 1. m reference to EPA's
anti-degradati0n_policy EPA believes that the current
vegetables.
J>e discharged into the-Bull Canal likewise
irrigation of crops except raw edible
-------
Mr. Roger L. Williams
Region VIII - OSEPA
Page Four
Further, it would appear that allowing the intentional degradation
of the quality of the water in the Bull Canal is contra to the water
quality policy of EPA and the State of Colorado. First, EPA's
"Guidelines for State and Areawide Water Quality Management Program
Development" require that water quality use classifications be
established to protect the highest use attainable. EPA's position
that the Bull Canal may be degraded because it is not presently
used as a water supply appears to contradict EPA policy of protection
of existing quality. EPA also has required that States develop and
adopt an antidegradation policy. See 40 CFR 130.17(e). The position
taken in this EIS concerning the degradation of the quality in the
Bull Canal appears to be inconsistent with this policy.
The position that the Bull Canal may be degraded also appears contra
to the policy of the State Water Quality Control Commission. The
Commission has adopted an antidegradation standard (See 3.1.8).
It has also taken the position that waters should be classified for
the highest water quality attainable (See 3.1.6(1)(3). The inten-
tional degradation of water in the Bull Canal that is now suitable
for water supply appears to be inconsistent with these policies of
the Commission.
If the anticipated degradation of the Bull Canal by Northglenn is
allowed by EPA, the Town of Frederick believes it should be compen-
sated for this degradation similar to the way that Northglenn has
offered to compensate farmers who may grow edible crops with the
Northglenn effluent. This compensation scheme is discussed on
pages 89 and 90 of the EIS. In summary, it recognizes that there
were no raw edible food crops grown in the FRICO Standley Lake
system at this time but because there is a potential for these
crops to be grown in the future Northglenn has agreed to assist
farmers in marketing such crops or to purchase the crops if neces-
sary. The situation concerning use of the Bull Canal as a public
water supply is quite similar. The Bull Canal has not in the past
been used as a water supply by Frederick. However, in view of the
Town's water rights dedication ordinance discussed above, there is
a substantial likelihood that Bull Canal water will be used in
the future as a public water supply. In such event Northglenn
should compensate the Town of Frederick for any cost necessary to
seek the alternate water supplies that EPA suggests that Frederick
use. The Town of Frederick requests that EPA add a grant condition
in this regard similar to the grant condition concerning compensa-
tion to farmers who raise edible crops as set forth on page 90 of
the EIS.
Such a grant condition would be reasonable and justified because
the expectation by the Town of Frederick of future use of the Bull
6. EPA has dropped the condition to ban the sale or dis-
tribution of rav edible food crops within the project
.area. Northglenn is required through its agricultural
reuse ir.anual to provide precautionary measures and
instructions to the fanners relative to the use of
treated effluent on raw edible food crops.
-------
Mr. Roger L. Williams
Region VIII - USEPA
Page Five
Canal for domestic water supply is not mere conjecture. Frederick
is presently served by the Lower Boulder Ditch which has a limited
carrying capacity and is presently involved in a legal controversy
over carrying water to Frederick for domestic use. Further, the
quality of the Lower Boulder Ditch is less desirable than the exist-
ing quality of the Bull Canal because the Lower Boulder Ditch
headgate is just below the sewage treatment outfall of the City of
Boulder.
Groundwater supplies in the Frederick area are of marginal quality
and quantity for municipal use principally because much of the area
overlays abandoned and inactive coal mining areas. Therefore,
Frederick may have no good future public water supply other than
the Bull Canal. Hence, the Northglenn should not be allowed to
solve its problems, by causing additional problems for its neighbors.
EPA should not allow the Bull Canal to be degraded as described in
the EIS. At the very least, EPA should put the financial burden of
any degradation of quality of the Bull Canal on Northglenn where it
rightfully belongs. This should be done by the suggested grant
condition.
Page 15.
states:
The fourth paragraph under the heading "PURPOSE AND NEED"
"Northglenn's stated position is that the City of
Thornton cannot provide an acceptable water supply, either
in terms of quantity or quality. The raw water quality at
Thornton's Columbine Water Treatment Plant has on occasion
had nitrite concentrations that exceed the drinking water
standard of 1.0 mg/1 (1). Thornton indicates this problem
has been corrected (2) . Thornton also indicates that they
are currently developing water resources outside of the
Denver metropolitan area to supplement their existing water
g supplies. The current position of Thornton is that they can
provide an adequate water supply for themselves and Northglenn
(3)."
Thornton says it can meet the commitments of Northglenn and North-
glenn apparently disagrees. Who is right? Surely if Thornton can
meet the needs, the entire project is not necessary for the City of
Northglenn. Certainly before a commitment by EPA is made to fund
the project it should be necessary to fully substantiate the need
therefor. It is, therefore, suggested that the City of Northglenn
be required to satisfactorily demonstrate the actual need and not
just take the position that the quantity and quality of Thornton's
supply is not acceptable without getting proof thereof.
As indicated in response to other comments regarding
this issue, EPA acknowledges the fact that Thornton's
existing water supply is acceptable in terms of quality
to satisfy current drinking water criteria.
However, Thornton has not demonstrated to EPA that
their water resources are adequate to provide the
future water supply needs of both Northglenn and
Thornton without the development of additional
resources. Please refer to the alternative water
supply analysis for further discussion.
-------
Mr. Roger L. Williams
Region VIII - USEPA
Page Six
9
T
u>
10
Further, the discussion of the no action alternative contained on
page 51 of the EIS appears inadequate. EPA reasons that because
Northglenn says it will proceed with the project with or without
federal funds that the environmental effects of funding the project
are the same as not funding the project. This tactic could be used
by every proponent of a federal action in which an EIS is involved
in order to preclude consideration of "no action." Rather than
cavalierly dismissing the "no action" issue as it has in the draft
EIS, EPA should discuss the consequences of maintaining the status
quo such as staying with the City of Thornton for its water supply
and having its wastewater continued to be treated by Metro.
Pages 39 and 40. Paragraphs 1, 2, 3 and 4 under heading "POTENTIAL
FOR DRINKING WATER SUPPLY" state:
"Concern has been expressed regarding the degradation of
the Bull Canal, making its water unsuitable as a raw water
supply. Analysis of the limited data currently available indi-
cates that the water is useable as a raw water supply; i.e.,
suspended solid concentrations are high, no toxic parameters
are present. However, projected concentrations of nitrates in
the canal after discharge from the proposed facility will
inhibit the development of these waters as a water supply,
particularly for the Town of Frederick,"and possibly could
affect a raw water source for the Town of Ft. Lupton."
"The State of Colorado defines raw waters suitable for
potable water supplies as follows: (3)
'These are waters which, after receiving approved
disinfection such as simple chlorination or its equivalent
or which after receiving standard treatment (defined as
coagulation, flocculation, sedimentation, filtration, and
disinfection with chlorine or its equivalent) will meet
Colorado drinking water regulations and any revisions,
amendments, or supplements thereto.'
"Standard water treatment as defined above will not
effectively remove nitrate."
"Annexation requirements of Frederick, Colorado require
that lands brought into the town must also provide additional
water supplies. Landowners surrounding Frederick generally
own shares in FRICO delivered by the Bull Canal. Therefore,
implementation of a plan which discharges effluent to the Bull
Canal would render these waters unacceptable as a water supply
for Frederick. Filings have not been made to change the use
10.
EPA believes that the no federal action alternative
as presented In the EIS presents the realistic no
action alternative. This Is a consequence of
previously negotiated legally binding agreements,
(i.e., the Four Way Agreement), which would require
re-negotiation between all parties prior to returning
to what is indicated as a status quo option. North-
glenn is in fact committed to the construction and
operation of their proposed Water Resource Management
Plan. EPA, therefore, does not believe that the
no action alternative can be defined in terms of
Northglenn receiving its future water supply from
Thornton and future wastewater treatment at Denver
Metro.
EPA concludes that since the Canal is not presently
used for a domestic water supply, nor has there been
any formal request to designate the Canal for domestic
water supply, there is no need to protect the Canal
for water supply.
-------
Mr. Roger L. Williams
Region VIII - USEPA
Page Seven
11
of Bull Canal waters to a water supply and the current
Larimer-Weld 208 Clean Water Plan designates the Canal solely
for agricultural use. Thus it is EPA's conclusion that the
protection of these waters for a potential future water supply
source is unnecessary and EPA recommends that Frederick explore
other options to satisfy future water supply demands."
The position of the Town of Frederick in connection with these
statements is as previously stated. If this project is constructed,
the City of Northglenn will in effect be trading an existing accept-
able supply for a future supply which will negate or substantially
cripple the Town of Frederick's ability to provide an adequate water
supply for its future residents. The justification for such a
trade-off is certainly lacking.
Page 45. Under "SUMMARY OF WATER SUPPLY ALTERNATIVES CONSIDERED".
The City of Northglenn has not examined the alternative of staying
with the City of Thornton. This alternative is likely the most
viable of all and certainly should be a required consideration.
.o
Page 89. Under
AND FIRESTONE".
'PUBLIC HEALTH - TAILWATER CONTROL AT FREDERICK
12
"During irrigation periods. Bull Canal tailwater from
lands adjacent to Frederick and Firestone flows through town
streets. Northglenn has agreed with EPA to provide necessary
facilities to control the tailwater so that it will not enter
the Towns of Frederick or Firestone. The plan, which has
been conceptually developed, will consist of three ponds that
will receive the tailwater from collection ditches along the
lower edges of the fields adjacent to the towns. Low dikes
will reduce stormwater inflow into these ponds. Water from
the ponds will be recirculated back to the irrigated land.
(Should these fields be irrigated during rainfall, some dilutee
tailwater could flow into the streets.) According to the
filings Northglenn has made with the Water Court, their posi-
tion is that this water is from Standley Lake storage and
impounding of this water will not create a water rights
problem. EPA concludes that if the Water Court disagrees, this
amount of water will have to be included in Northglenn's
augmentation plan."
"The proposed grant condition is: 'Northglenn will provide
physical measures to prevent the flow of tailwater from adjacent
agricultural land into the Towns of Frederick and Firestone or
any other residential area. Consultation with Frederick and
Firestone on the design and location of these facilities is
necessary.'"
11. The alternative of Northglenn continuing to receive
a water supply from the City of Thornton is examined
in the alternative water supply section of Chapter 3.
12. Please refer to response to Item 4 above.
-------
Mr. Roger L. Williams
Region VIII - USEPA
Page Eight
The Town of Frederick is greatly concerned about the ability of
Northglenn to control the tailwaters. Even these statements as a
concept indicate that "some diluted tailwater could flow into the
12 streets." It is apparent that even Northglenn cannot assure a
100% resolution of this problem even in a conceptual form. If the
concept is questionable, certainly the result will provide less than
adequate protection.
Throughout the report, there are statements and references to the points
addressed in this letter. In this regard, the Town of Frederick's
position remains the same. We strongly urge that funding of this project
by the EPA not be granted until such time as the concerns of the Town of
Frederick have been properly resolved and not merely addressed.
Sincerely,
Holly Wm. Hall
Mayor
CO
-------
tensg;*3S
»-TSjJ*£5
idEsCS*
T
February 13, 1980
UJ
Environmental Protection Agency
Region VIII
Office of Public Awareness
1860 Lincoln Street
Denver, Colorado 80295
Northglenn Water Management Program, City
of Northglenn, Colorado, Draft Environmental
Impact Statement
Dear Sirs:
The Adolph Coors Company as a substantial water user
with vested water rights on Clear Creek has followed the
Northglenn Water Management Program with a great deal of
interest. More particularly, Coors is participating in
the state water court adjudication process which was commenced
by the City of Northglenn with its filing in the Water Court
of its plan for augmentation. This filing and the judicial
ratification of the plan, of course, are necessary prerequisites
for the completion of any viable Northglenn Water Management
Plan. Therefore, these comments will be primarily addressed
to statements contained in the draft Environmental Impact
Statement which have a direct bearing upon the various water
adjudication proceedings which will ultimately affect all
water users on Clear Creek and in particular the Adolph
Coors Company.
As a preliminary matter, Coors states that the contempor-
aneous decision to prepare a Draft Environmental Impact
Statement (DEIS) and the distribution of that document to
the public afforded no meaningful public participation in
the DEIS scoping process. This oversight should be remedied
to afford proper public participation.
RESPONSE:
The issue of compliance with the scoping process was subject
to litigation in Consolidated Ditches Company, et.al. vs.
EPA. The issue was settled by mutual written agreement
between EPA and these parties on June 2, 1980. It is EPA's
position that during the last two years of review by our
agency; the environmental assessment, public meetings and
numerous phone calls regarding the Northglenn proposal
were sufficient to satisfy the intent and purpose of the
public scoping process required under recent regulations
promulgated by the Council on Environmental Quality.
-------
Environmental Protection Agency
February 13, 1980
Page 2
DETAILED COMMENTS
Chapter 1
00
On page 5 the DEIS describes the fact that there are
only four options identified by Northglenn and EPA within
the framework of the plan. If in fact this scoping of alternatives
to the proposed action was arrived at jointly by Northglenn
and EPA without public participation and input, then this
breach of procedure should be corrected and total participation
should be required prior to the scoping of alternatives.
The evaluation of other alternatives which do not require
the "borrowing" of water from either the South Platte River
or the FRICO system should be carefully evaluated.
Under the section entitled Protection of Vested Rights,
the statement is made that this plan can be administered
by the State Engineer. This statement should be substantiated
far beyond a mere reference to a conclusion based upon "expert
opinion." It is also significant that EPA has made no conclusion
with regard to whether or not some water users may suffer
adverse impacts from the implementation of the plan. If
EPA is to make this conclusion in the final statement, a
substantial amount of documentation would be necessary.
Chapter 2
I On page 16 the statement is made that "By obtaining
water from FRICO, Northglenn has assured itself of water
of adequate quality and a certain water supply source for
the future." This very general statement should be substantiated
by specific references to sources and amounts.
The next paragraph states that "The environmental conse-
quences of [failure to implement the current plan] cannot
be fully determined and may be of lesser or greater magnitude
than those resulting from the full implementation of Northglenn's
current resource plan." This type of general statement
raises many more questions than it answers. EPA's primary
goal must be to specifically identify those options which
would have a lesser environmental impact.
2. EPA has included an analysis of other water supply
alternatives. See Chapter 4. y
3. EPA believes that the Northglenn Water Resource
Management Plan can tn fact be administered but
does have inherent difficulties which must be over-
come prior to full Implementation.
4. EPA believes that the sources and amounts of
Northglenn's future water supply under the FRICO
exchange are discussed in detail in the Environmental
Inpact Statement., Reference should be made to the
chapters on Alternatives and Environmental Issues.
5. The comment made is taken out of context. The
environmental consequences relate specifically to
Northglenn being forced to secure other sources of
irrigation water, nontributary groundwater, tributary
groundwater or any combination thereof and is not a
result of the failure to implement the current plan.
-------
Environmental Protection Agency
February 13, 1980
Page 3
6
7a
CO
VO
7b
8
Chapter 3
In discussing the significant environmental impacts
which affect water resources in the section entitled Tributary
Ground Water, a statement is made that the tributary well
field is not expected to have a "noticeable impact on agri-
culture." It should be emphasized that this of course is
not the criteria in water court. Rather, a junior water
right may only be put into use if the use does not adversely
affect a senior right. Since the impact of the proposed
well field cannot be determined at this time, its existence
can also not be relied upon.
The section which deals with the Standley Lake Yield
is replete with erroneous assumptions about Colorado water
law. Assumption No. 2 that would provide credit for accretions
to the Big Dry Creek system due to increase in urban runoffs
does not take into account the fact that those runoffs belong
to the river and cannot be appropriated by the users of
Big Dry Creek. The third assumption concerning the increased
yield of the FRICO shares assumes that the change in use
of the FRICO shares from agricultural to industrial and
municipal use and the associated increased consumptive efficiency
does not increase the burden on the stream system. In fact,
this type of change in use results in an expanded us* and
an enlarged burden on the system. Finally, the assertion
that better prediction of dry year yields based upon snow
pack estimates which are improved, has no associated quanti-
fiable benefit. Any attempt to quantify this improvement,
can be nothing more than mere speculation.
In the section entitled Bull Canal Water Distribution,
there are certain statements concerning the intentions of
Northglenn with respect to equalizing the distribution of
water among the farmer shares upstream of payback return
and the farmer shares downstream of payback return. Although
these intentions may be admirable, intentions alone do not
meet the burdens required for an augmentation plan to show
lack of injury to any vested water rights.
The statement concerning EPA's conclusions about the
yield of augmenting rights for purposes of the augmentation
plan without the necessary technical backup data is gratuitous
and should be removed from the document.
6. EPA policy to
a*ricultu«l Production lands
7b. Please refer to the agricultural analysis which has
been revised and presented in the Environmental
Impact Statement.
8' bfteen^orthg'lenn^raiCO8116 "*" "**' " "' resoll'ed
f___ ,_• -1 -i . * me courts and there~
lore wij.1 make no response at this time.
9. Engineering data vere provided by Northglenn which
substantiate this conclusion and were utilized in
the development of the assessment of yields.
-------
Environmental Protection Agency
February 13, 1980
Page 4
10
11
12
13
14
15
The statement on page 30 concerning the susceptibility
of this plan should it be implemented to administration
should coincide with those statements referenced earlier
wherein the EPA concluded that the plan was capable of
administration.
In the section entitled Ditch Protection, it should
be emphasized that the particular yield of the shares of
the mutual ditch company may be diminished if there is a
requirement as part of the implementation of the plan to
insure that the water to be used by Northglenn is available
in the ditch as a carrier medium. If this is the case,
then there may be times and conditions when the shares belonging
to Northglenn may not be available for the specific domestic
uses envisioned by the plan.
Coors agrees with EPA's conclusion that the transfer
of South Platte return flows to the Northglenn/FRICO system
represents a depletion to the South Platte and therefore
requires additional sources of augmentation water.
The DEIS summary of legal' issues found on page 32 is,
of course, not an exhaustive listing of the legal issues
involved with such a complex augmentation plan. However,
Coors agrees with the conclusion made by EPA that in all
probability additional augmentation water will be required
prior to approval of the plan since, at the very least,
the plan involves such highly controversial legal issues
as successive use, expanded use, change in use, and the
capture of waters native to the stream out of priority.
In addition to those legal issues highlighted above,
in the succeeding sections of Chapter 3 wherein there are
discussions about the agricultural productivity components
of the plan, it should be noted that even if the net agricultural
productivity is enhanced, this is not the criteria for assessing
damage in a water court proceeding. Rather, if the lands
that are taken out of production supplied a source of recharge
and a component of a conduit system for ground waters tributary
to the 'Platte, then the elimination of irrigated agricultural use
from those lands will have caused an interference in the
historic pattern of water usage in that portion of the Platte
system, and that interference with vested rights must be
compensated for.
10. See response to Item 3, above.
11. EPA acknowledges this feature of the plan. EPA
further recognizes that this will have to be resolved
through implementation of the project and will involve
the resolution of these problem with the participation
of FRICO and Northglenn.
12. EPA acknowledges.
15.
court approval of the plan, this should not be
construed as a legal determination of this need.
Plan 1 *.P°sitlon that the entire augmentation
plan is subject to water court approval and that
process will resolve this issue.
14- See response to Item 6 above.
subVr ," 5 P°Sltion to «»»=« ™ this as this
subject to Water Court determination.
-------
Environmental Protection Agency
February 13, 1980
Page 5
16
17
18
19
Chapter 4
As an overall comment concerning the approach taken
to the selection of alternatives, it becomes evident from
the scope of alternatives discussed within the confines
of the DEIS that no real alternatives to the plan were considered.
Rather, only alternative means of implementing the one plan
for water supply for Northglenn were considered. This type
of analysis does not in reality provide a true examination
of alternative means of supplying Northglenn with the water
it seeks to supply its potential customers.
On page 56 the statement is made that the increased
nitrogen concentrations are not expected to cause problems
in either sugar beet or barley production. This assumption
cannot be substantiated. If in order to be marketable the
sugar beet crops to be irrigated by water from Northglenn's
effluent must have no nitrogen applied after July 15 of
each year , then this means that the Northglenn effluent
cannot be applied after July 15th by those FRICO stockholders
who are irrigating sugar beet crops. This of course means
that either Northglenn must supply them with an alternate
supply of water or there will be a total interruption of
the historic irrigation pattern of acreage planted in sugar
beets.
The potential adverse impacts of the plan set forth
on page 82 with respect to the recharge of the ground water
alluvium are adverse impacts of the plans commented upon
previously herein, and are issues which must be resolved
prior to the approval of the augmentation plan in water
court.
Chapter 5
Although the thrust of EPA's mitigation measures is
to safeguard its investment of public funds, which is admirable,
it should refrain from requiring mitigation measures that
might be contrary to law. In particular, there should be
no requirement to recirculate or prevent the natural return
of irrigation waters from the FRICO system to the South
Platte as set forth by the proposed grant condition quoted
on page 89.. This requirement may have the effect of mandating
16.
Please refer to'the revised alternative section
presented in the final Environmental lapact
Statement. EPA believes that this chapter presents
a lull range of alternatives available to Vorthelenn
for water supply and wastewater treatnent.
17.
19.
: .,.c,,,cy:
their testimony at the February 13, 1980, public
hearing.
18. Acknowledge.
While EPA offers an opinion on this matter it is not
legal in nature, as this issue is
the plan.
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Environmental Protection Agency
February 13, 1980 *
Page 6
19
20
ro
an interference with other vested water rights by requiring
successive use and expanded use of waters which historically
were returned to the South Platte River and which provided
flows for other water users on the Platte. All of the proposed
grant conditions must be evaluated against the requirements
of Colorado law.
Chapter 6
Once again, with reference to our earlier comments,
it appears from the list of public participation meetings
listed in Chapter 6 that there has been no attempt prior
I to issuance of the DEIS to involve the public in the process
of scoping the alternatives to be considered in the DEIS.
Coors will not specifically discuss any of the conclusions
made in Appendix A concerning Colorado water law. Any discussion
of the legal impacts of this plan are rightfully reserved
for the water courts of the State of Colorado.
Thank you for your attention to these matters.
Sir
20. The issue of compliance with the scoping process was subject
to litigation in Consolidated Ditches Company, et.al. vs.
EPA. The issue was settled by mutual written agreement
between EPA and these parties on June 2, 1980. It is EPA's
position that during the last two years of review by our
agency; the environmental assessment, public meetings and
numerous phone calls regarding the Northglenn proposal
were sufficient to satisfy the intent and purpose of the
public scoping process required under recent regulations
promulgated by the Council on Environmental Quality.
LEB:jh
-------
Phon.: (33-12*1
TOWN OF FIRESTONE
WELD COUNTY
FIRESTONE, COLORADO 8052O
February 13, 1980
TO: Enviornmental Protection Agency
RE: Proposed Northglenn Sanitation Facility
Public Hearing
The Town Board of the Town of Firestone wishes to be placed
on the public record as being opposed to the above for the
following reasons :
CO
1. No case, we feel, has been definitely made to rule
out the alternatives to the above facility. As the present
supplier of potable water and the present sewerage processor
have stated that they can adequately meet the needs of the
City of Northglenn into the future, the need for the facility
and the reuse of irrigation water has not been adequately
proven .
2. Our community, together with the Town of Frederick, will
be faced with the prospect of sewerage in the form of irrigation
runoff coursing through the streets of our towns. Certain
"conceptual" solutions, we are told, will offer adeauate pro-
tection form this source of pollution. At no time have any
officials of our community been involved in the determination
of what these "conceptual" solutions are to be nor the adequacy
of the proposals. Data which I requested in mid-December which
I was told by the City of Northglenn was available, pertaining
to studies of hazards of a water re-use system have vet to be
received. In addition, the proposed holding pond solution would
need to be extended to protect all of section 19 to the north
RESPONSE:
1. EPA has revised its alternative analysis on the pro-
posed system. Please refer to Chapter 3 of the final
Environmental Impact Statement for a discussion of
the alternatives considered.
2. EPA believes that the tallwater control plan proposed
by Northglenn will provide adequate controls of the
tailwater within the communities of Frederick and
Firestone. The conceptual solutions are presented
in greater detail in the final Environmental Impact
Statement under mitigation measures. In reference
to section 19 being impacted by tailwater, EPA has
determined that this will not occur as a consequence
of the hydrologic basin drainage characteristics
and that the proposed tailwater control plan will
Intercept any water prior to entering section 19.
-------
Phoo.: »3 3211
TOWN OF FIRESTONE
WELD COUNTY
FIRESTONE. COLORADO 8OS2O
EPA - page 2
of the Town of Firestone. His r>arcel is r
-------
COMMENTS OF THE GREAT WESTERN SUGAR COMPAMY
OH THE
NORTHGLENN WATER MANAGEMEUT PROGRAM
February 13, '330
The company has given careful review of the proposed Draft Environmental
Impact Statement and has met with representatives of the City of Northglenn
and their engineering consultants.
There are two factors to be considered in the proposed program. The first
is the nitrogen present in the discharge wastewater that will find its way ulti-
mately to sugar beet fields as irrigation water. An excess of nitrogen applied
to sugar beets late in the growing season (August through September) could
Seriously affect the growth and sugar yield. The range of seven to nine pounds
nitrogen per acre presents no problem to the beet grower, provided the grower
knows in advance that this will indeed be what he can expect early enough
T»""*A
in the growing season so that he can reduce his -»w*+r nitrogen application to
allow for the nitrogen coming late in the irrigation water. It is our under-
standing that Horthglenn intends to make this information available to the
Irrigation water users on a timely basis. As long as this information does
get out to the water users, Great Western sees no problem with the projected
amounts of nitrogen in the wastewater being used for irrigation.
The second point of concern Is the possibility of algae bloom in the
holding ponds. It is our understanding that the system is designed to preclude
algae blooming and as long as this holds true, we have no problem. Our worry
is In what chemical treatment would be resorted to, should an algae problem
develop. The addition of copper is the usual treatment since it is both
efficient and inexpensive. Copper is quite toxic to sugar beets. Our point
in this comment is not to borrow trouble, but only to be sure that the
operators of the management plan are aware of the potential hazards to beet growers,
should the algae prove to be a problem.
RESPONSE:
1. EPA would like to acknowledge Great Western Sugar
Company's clarification of the nitrogen issue relative
to their operational needs. As part o£ the agricultural
reuse manual, Northglenn will be providing information
on nitrogen content to the farmers using wastewater
effluent in a timely manner so that appropriate
fertilizing requirements can be determined.
2. Northglenn has considered the option of using copper
sulfate as a potential mitigation measure for algal
blooms in the storage reservoir. However, because
of the potential problems of copper related to sugar
beets and other crops, EPA does not find this to be
the most acceptable alternative and has requested
Northglenn to consider other options for algal bloom
mitigation should such an event occur.
-------
Northglenn Water Management Program
Page 2
Great Western wishes to express its appreciation for the opportunity to
comment at this stage in the planning process. We do not wish to create the
impression that we have doubts about the assurances we have already received
relating to nitrogen content of the wastewater discharge or the need for
algae control. We merely want to be on record of making known our potential
problems, should the unforseen become a reality in the future.
3. Acknowledge.
-------
COMMENTS ON HEARING ON
NORTHGLENN HATER MANAGEMEtJr PROGRAM ON
FEBRUARY 13, 1980
By Fu Hua Chen, President
Chen and Associates, Inc.
Geotechnical Engineers
I have listened for four hours on the iinpact of using the
treated sewer for irrigation purpose. The impression of the hearing
so far appears that the design team has not given any consideration
to the various impacts which affect the environmental and ecological
effect of this project. I can assure you that our team, which
consists of highly technical and competent consultants, has
investigated the geological, geotechnical, hydro-logical as well as the
sanitary aspect of the project. There is no phase of the problems
that may exist in this project that has not been studied thoroughly by
our team. The hydrological study alone, including the water right
problem, the water transfer problem, the return flow problem, is in
such a large volume that if I would read the entire contents, it would
keep the audience in this hearing for probably ten hours. I can
assure our opponents that we can natch, acre by acre, foot by foot, iirqpnNSF- 1. Acknowledge
what the brilliant young engineer has claimed, and I challenge all RESPONSE.
opponents to all figures we have presented. The mere fact that our
design has survived the crucial examination from EPA suffices to tell
that we have done our homework.
I am not a chemist nor a biologist, and I do not know the
scientific impact of using the treated sewer for irrigation water, but
I do know that the Chinese have been using raw sewage as fertilizer
for thousands of years. It appears that the sewage has no ill effect
on plant growth. On the contrary, the farm product appears to be much
superior to chemically fertilized vegetation. I do believe this new
process marks a drastic change in thinking on sewage treatment as well
as farming practice. As previously testified, this project not only
has great impact, on the State of Colorado but also the Nation. I do
think it is about time that we totally re-evaluate our past procedure
of sewage treatment and irrigation process and look ahead for a new
way of sanitary engineering in which we can improve both the
environmental and the ecological impact of our system.
-------
Town of Dacono
oo
5J2 Cherry Street
P.O. Box 186
Dacono, CO. 80514
Metro- 825-1256
Local-833-2317
February 18, 1980
U.S. Environmental Protection Agency
Regional Administrator, Region '/III
1860 Lincoln Street
Denver, Colorado 80295
inF^^fn]
1 ; FEB21 1980JJJ
E'- R^'-- ~,;ui]j]
Water L..ision
Dear Kr. Williams:
This letter is in response to the draft Environmental Impact Statement
concerning the proposed Northglenn wastewater treatment facility pre-
pared by your organization.
Ihere are several issues in this study with which the Town takes excep-
tion. Several of these issues have been addressed by Kayor Kail of
Frederick in his letter of February 12, I960. The Town of Dacono has
adopted this letter by resolution.
One of the issues responded to by Mayor Hall concerned the position of
the EPA concerning potential domestic use of the Bull Canal which
presently serves the irrigation needs of southern a'eld County agriculture.
The position of the EPA is that protection of these waters is not nec-
essary due to their current use. One problem with this position is that
the Bull Canal system flows through an area that has exhibited a great
potential for urbanization. Dacono alone has increased its population
eight fold in the last ten years. This growth trend is continuing.
Municipal condemnation suits caused the initial plans for Northglenn's
"alternate technology". What the Northglenn plan will create is a rash
of other municipal condemnation suits as the water needs of southern
Weld County municipalities .grow. In essence, municipal condemnation
actions will be transferred froir. Northglenn to southern Weld County.
Tne disappointing element in the EPA decision concerning the Bull Canal
is in a lack of planning. One could justifiably say that water planning
for local governments is not an EPA function, and we agree. However,
the potential for urbanization in southern Weld County and therefore a
need for the Bull Canal system as a domestic water source, was not even
considered. Your position on the Bull Canal is analogous to stating
that because there are currently Snail Darters alive, these fish do
not require protection.
Another key element of the draft EIS concerning Dacono is the requirement
by Northglenn to either disinfect the future irrigation water in the
Bull Canal or provide an alternate source of such water. It is unclear
Or\V. &uJ
RESPONSE:
There is a recognized administrative procedure for the
classification of state water. Such procedures could result
in the reclassification of the Bull Canal as a water supply
source. Currently, the state has not received any request for
reclassifying the Bull C="?3 as a water supply source.
2. EPA's requirement that Northglenn disinfect or replace
Dacono1s nonpotable water was in the interest of maintaining
water of an acceptable quality for nonpotable use. If EPA's
proposed solution is unacceptable to Dacono, then Northglenn
nust negotiate a mutually acceptable solution to solve the
identified public health problem. EPA is unaware of any
detririental effects of chlorine on lawns and gardens.
-------
Mr. Roger L. Williams
US2PA
2.
whether the- City of Northglenn Is bound to accept the alternative which
is acceptable to Dacono. Disinfection through chlorination is wholly
unacceptable to the Town of Dacono. It is interesting to note that in
the draft BIS a considerable amount of attention was paid to the effects
of various chemicals on farmland. No attention was paid to the potential
effects of chlorination on Qacono's lawns and vegetable gardens. It would
appear that as municipal opposition to the Northglenn project grew, this
option was considered as a convenient way to buy off that opposition with-
out considering its negative environmental impacts.
It is also interesting to note that in Table 3-1 of the draft EIS (page 20)
you list comparisons of various levels of contaminants projected to be in
the Bull Canal after completion of the Horthglenn facility. Unfortunately,
the source of this information is the company which will profit from the
facility's construction! What the Town of Dacono was looking for in the
draft EIS was an objective assessment of the environmental impacts of the
proposed facility. What was presented was a rationale for funding the City
of Northglenn's project by Ignoring or "soft-peddling" opposition arguments.
On page 33 of the draft EIS, you state "...the exchange plan will sufficient-
ly protect FRICO shareholders." I would like to point out that the Town
of Dacono is also a FRICO shareholder, and doesn't feel sufficiently pro-
tected by your Agency.
3. EPA did perform an independent analysis of'the entire project
proposed by Northglenn. This analvsis was done with the
assistance of Engineering-Science, consultants-not otherwise
associated with the project.
Sincerely,
Cllffton T. Elliott, Sr.
Mayor
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Kenneth M Macintosh g
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L. Scott Tupk«r, EMCUI.V* Director
Mr. Roger L. Williams
Regional Administrator
U.S. Environmental Protection Agency
1860 Lincoln Street
Denver, CO S0295
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MO
February 15, 1980
£ FEB20 1980
Subject:
Comments on Draft Environmental Impact Statemen'
Northglenn Water Management Program
Dear Mr. Williams:
I attended a public hearing in Northglenn on February 13, 1980
regarding the recently completed draft Environmental Impact State-
ment for the Northglenn Water Management Program. I was not able
to stay for the entire public hearing, and therefore did not make a
verbal statement. I understand, however, that EPA will receive
written comments regarding the Environmental Impact Statement until
February 25, 1980. Please consider this the comment of the Urban
Drainage and Flood Control District regarding the draft Environmental
Impact Statement.
The interest of the Urban Drainage and Flood Control District
is centered on Northglenn's efforts to address urban runoff con-
trols. It is stated on page 700 of the draft statement that
"...EPA determined that prior to granting funds for construction
or expansion of wastewater facilities, the general purpose govern-
ments within the proposed service area must she*.1 progress in the
form of ordinances adopted or recent efforts taken towards imple-
menting the non-point source controls recommended by the Clean Water
Plan." This determination was made by EPA in response to a DRCOG
recommendation in the recently completed Clean Water Plan for the
Denver Metropolitan Region. '•
From a regional and national point of view, there is a great
deal of confusion as to how to address the stormwater pollution
problem. There is general agreement that stormwater contains pol-
lutants, but the source or extent of the pollutants is not well
understood. Also, there is little understanding as to the effects
of stormwater on receiving waters, as well as what the beneficial
effect would be on receiving waters if urban runoff was in some
way treated. Congress has, in fact, taken the posi-tion that the
urban stormwater pollution problem is not well enough understood
for the Federal Government to commit funds for the abatement of
the problem.,. The Federal approach is to require local governments
to address the problem through the concept of best management prac-
tices.
RESPONSE:
Acknowledge
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Mr. Roger I. Williams
February 15. 1980
Page 2
It seems that irrespective of the lack of understanding-
regarding the urban stomwater pollution problem, the City of
Northglenn 1s going to utilize stormwater in a total water man-
agement program. This is one of the few efforts that I know
of in the nation where urban runoff is being used as a part of
a total water system. All other factors being equal, North-
glenn should be encouraged and supported in the pursuit of the
concept of utilizing urban storm runoff in a total urban water
management context.
The draft Environmental Impact Statement recognizes North-
glenn 's urban runoff controls as a positive environmental fea-
ture, and I would like to reinforce that conclusion.
Sincerely,
LST/lf
L. Scott Tucker
Executive Director
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UNITED Srvnts DIMKTMCNT or AGRICULTURE
FORCST SERVICE
Rocky Mouratn Region
11177 Win Eighth AMHW, Box 25127
Ukewood. Colondo 8022S 1950
February 20, 1980
Roger L. Williams, Regional Administrator
U.S. Environmental Protection Agency
Region VIII
1860 Lincoln Street
Denver, Colorado 80295
Dear Mr. Williams:
Thank you for the opportunity to review the Draft Environmental Impact State-
ment for the Northglenn Water Management Program, City of Northglenn, Colorado.
We share the concern about odor emission discussed in Chapter 4 (page 67), and
air quality described in Chapter 5 (page 101), of the Statement. A significant
positive contribution toward reducing potential odor emissions and improving
air quality can be made in the project area.
5 A program of planting trees, shrubs and other vegetation, can be a step in cre-
ating a natural-like situation that will help compensate for some of the adverse RESPONSE: i. Northglenn will provide => 1=^=^= < •,
odor and air pollution impacts. The plantings can improve the long term aesthe- for the planting of grasses tr^HK v
tic quality of the project area. ' ana shrubs-
The city of Northglenn has a forestry staff that can recommend planting stock
and develop a schedule for a planting plan. This could all dovetail into the
project schedule.
I recommend consideration of my comments in your final Environmental Impact
Statement.
Sincerely,
CRAIG*: RUPP
Regional Forester
<*'
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DEPARTMENT OF THE ARMY
OMAM* DISTRICT COOPS OF ENUIMCIMS
SOU U S POST OFFICE AND COURTHOUSE
MBOPD-A
20 February 1980
Mr. Roger L. Williams, Region*! Administrator
Region VIII - U.S. Environmental Protection
Agency
i860 Lincoln Street
Dearer, CO 80295
r FEB25 1980
Viaiei u.n
Ui
Co
Deer Mr. Williams:
We hare reviewed your Draft Environmental Impact Statement (DEIS) for the
Horthglenn Water Management Program, Sorthglenn, Colorado pursuant to
Section UoU of the Clean Water Act and hare the following comments.
Any fining In waterways, lakes and vetlands In conjunction vlth the project
must be authorized by either a nationwide permit or by an individual permit.
The DEIS states that the final plan has not been adopted. In order to
determine the permit. If any, to be issued It is Important that the final
plan be submitted to this office for review in accordance with Section kok.
In the event an individual permit Is required, the following regulations must
be adhered to.
a. An evaluation report prepared In accordance with the Section boMb)
guidelines promulgated by the Environmental Protection Agency and appearing
in the Federal Register of Id September 1979.
b. Hie Endangered Species Act, as amended.
c. Die Fish and Wildlife Coordination Act.
d. Die national Historic Preservation Act (Section 106).
We would recommend a review, by the Advisory Council on Historic Preservation.
We would advise you that the Final Environmental Statement should contain a
statement that the project will not conflict with the Intent of Executive
Order 11988 (Floodplain Management} as regards to the South Platte River.
RESPONSE:
1. Northglenn has obtained a nationwide permit for the
construction of its urban stormwater runoff retention basin
and interceptor crossing of Grange Hall Creek. Northglenn
r.ust conply with all provisions of the 404(b) guidelines.
No knovn inpacts on endangered species have been identified.
Issues concerning the Fish and Wildlife Coordination Act and
the National Historic Preservation Act are responded to by
the appropriate agency comments (Fish and Wildlife Service
and Colorado Historical Society).
The City of Northglenn operates under the complete floodplain
management ordinances as developed by the Federal Emergency
Management Agency with respect to'Grange Hall Creek. No
impact on the South Platte River floodplain is expected.
Af;.
-
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MROPD-A 20 Jebruary I960
Mr. Roger L. Villiau
We vill anticipate receiving aore fiualiied data tram you, and at tnat tiae
«• can be nore *peciflc in our conaent*.
If you ban any que»tion» pleaae contact this office.
,'JOHH K. VELEHEAB6EC
Chief, Planning Diriaio
2. Final plans and specifications will be forwarded
to your office upon completion.
Oi
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. W. WHEELER AND ASSOCIATES. INC.
• UITK 3O1
CNQLCWOOO, COLORADO aOHQ
February 20, 1980
Mr. Roger Williams
Regional Administrator
United States Environmental Protection Agency
1860 Lincoln Street
Denver, Colorado 80203
Re: #815
Dear Mr. Williams:
>
I On behalf of Consolidated Ditches Company, enclosed are
Ln
Ln our comments concerning the Northglenn Water Management Program
draft environmental impact statement prepared by the Environmental
Protection Agency in January, 1980. It is intended that. our report
be considered a part of the public review and comment process.
Very truly yours,
W. W. WHEELER AND ASSOCIATES, INC.
RAH:sck
Encl.
Raymond A. Hogan, P.E.
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TABU OF CONTENTS
Page
INTRODUCTION I
IDENTIFICATION OF IMPACTS 3
Bull Canal Lining 3
Northglenn Consumptive Use . 4
Reuse of Sewage Effluent 4
Alternative Impact Analysts 5
Impact of Providing More Augmentation Water 5
Impact of Inadequate Replacement 6
Agricultural Productivity 6
EPA Policy 7
Comparative Agricultural Productivity 8
MITIGATION OF IMPACTS 10
Steps to Minimize Adverse Impacts 10
Net Adverse Impacts not Mitigated 10
Adequacy of Water Rights 10
I MISCELLANEOUS COMMENTS 12
Ui
ON ALTERNATIVES I*
Thornton 14
Deep Wells 14
Denver Water Board 14
South Park Water 14
Combination 15
SUMMARY AND CONCLUSIONS 16
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INTRODUCTION
On January 11, 1980, EPA published a "Draft Environmental Impact
Statement" for the Northglenn Water Management Program. In behalf of
the Consolidated Ditches, W. W. Wheeler and Associates, Inc. reviewed
this Draft Environmental Impact Statement. During this review process,
Mr. Weston W. Wilson (EPA Project Officer), Mr. Paul N. Seeiey (Engin-
eering Science), Mr. Allan L. Udin (Engineering Science) and Mr. Harold
F. Bishop (Tipton and Kalmback) were contacted. All of these preparers
of the report were very cooperative and helpful in providing foundation
materials-used in the draft EIS and in answering questions concerning
the draft EIS. Mr. Paul Seeiey advised us that the assumption concern-
ing South Platte current consumptive use on page 39 should be changed
from 2.7 to 1.0 acre-feet per acre.
The scope of our review and the comments contained herein'was
limited to the subjects of agricultural productivity, water quantity
^ and water management plan alternatives. Based on the available infor-
I [nation, we have estimated the impacts of Northglenn1 s water management
*-J plan on vested water rights along the South Platte and its tributaries.
In order to comment on the agricultural productivity analysis, we have
gathered information concerning agricultural productivity from govern-
ment agencies, private agencies, farmers along the South Platte, and
farmers under the FRICO Bull Canal system. Our comments relative to
alternative plans are based upon our general knowledge of available
water supplies and our contacts with Thornton representatives and
Denver Water Board representatives.
The Consolidated Ditches have requested Northglenn to produce
engineering studies among other items relating to the Northglenn water
management plan. On February II, 1980 we were advised that Northglenn
would not provide the requested engineering studies until the studies
had been finalized. Apparently the foundation materials supplied by
Northglenn's engineers are only preliminary and the results and
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conclusions of the draft EIS are based, at least In part, on prelim-
inary engineering studies and a water management plan that has not
been completed or finalized. For example, it was noted (Page 27)
that "...final evaluation of the impacts of the well field cannot be
completed until the field is located and the wells are designed."
Any changes in the preliminary engineering studies or changes in the
water management plan could significantly change the results and
conclusions contained in the draft EIS.
In the draft EIS, several legal issues were identified (Pages 32
and 33). Whether or not these legal issues will be resolved in favor
of Northglenn is a subject to be addressed by attorneys and decided by
the Water Court. In the draft EIS, the authors have expressed their
opinion that changes in Northglenn's water supply plan by the Water
Court are likely and the probable effect of such changes will be to
require more water for augmentation (Page 33). In our opinion, environ-
mental impacts of Northglenn's water management plan can and should be
determined separately from any speculation or assumptions regarding
"l resolution of the legal issues. Resolution of the legal issues in
~? favor of either Northglenn or the opponents will not change the environ-
mental impacts of what Northglenn plans to do. Si
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IPENTIFICATION OF IMPACTS
Northglenn's water management plan will impact the environment in
several different ways. The impacts that are identified below relate
only to the subjects of agricultural productivity, water quantity, and
water management plan alternatives.
f
(Ji
VO
Bull Canal Lining - Lining of the Bull Canal is an integral part
of the Northglenn water management plan. As part of the Four-Way
Agreement, the Bull Canal is to be lined to eliminate or at least
significantly reduce seepage. In turn for lining the Bull Canal,
FRICO has agreed not to charge Northglenn for any transportation loss
downstream from Standley Lake. We concur with the authors of the
draft EIS that lining the Bull Canal could adversely impact downstream
water users who have historically depended on seepage water from the
Bull Canal (Page 33). The draft EIS, however, does not identify the
magnitude of this impact or consider this adverse impact to any further
extent.
The adverse impact on other water users can be estimated for dry
and average years based on Information available (Figure 3-2). In an
average year, 16,611 acre-feet would be released from Standley Lake.
Historically, because of high seepage loss (Page 27), only 60 percent
of this water actually reaches the farm headgate. The remaining 40
percent (6,61*0 acre-feet) seeped from the Bull Canal and returned to
tha South Platte stream system. As used herein, the South Platte
stream system refers to the surface and alluvial groundwater associated
with the main stem of the South Platte and Its tributaries. If this
seepage is reduced to 10 percent by lining the Bull Canal (Page 27),
the reduction In seepage would amount to 4,980 acre-feet. Since this
salvaged water would be used for irrigating lands under the Bull Canal,
we estimate that 65 percent would be consumed and 35 percent would
RESPONSE:
Lining the Bull Canal Is not an integral part of the
Northglenn water management plan. The Bull Canal
lining benefits the farmers served by the canal system
and will increase the water yield to them over what
they would receive from an unllned system. Indirectly,
the cities served by FRICO, including Northglenn, also
benefit as lining is part of the Four Way Agreement.
There may not have been such agreement without this
provision.
At the time of preparation of the draft agreement only
1450 shares of the total 2373 shares in the FRICO
system were in predominantly agricultural ownership.
The balance of 923 shares belongs to Northglenn (214.8
shares) and Thornton and Westminster (703.52 shares).
The average year release to the agricultural users
will be 10,150 a.f. In a dry year the release is 7250 a.f.
The amount of water saved by lining is approximately
3045 a.f. in an average year and 2175 a.f. in a dry year.
The lining of a canal is generally considered a water
conservation measure. With a fixed given release from
Standley Lake the yield to the farmer will be greater
with the lined canal system than with an unlined canal
system. With more water available there will likely
be more consumptive use with the lining than without
It.
-3-
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return to the South Platte stream system. The net adverse impact to
the stream system would be 3,2<*0 acre-feet for an average year.
in a dry year, 11.865 acre-feet would be released from Standley
Uke. Using an analysis similar to that explained above for «.
average year, the net adverse impact would be 2.J10 acre-feet in a
dry year. If the lining of the Bull Canal eliminates all of the seep-
age, the adverse impacts would be f.320 acre-feet for an average year
and 3 080 acre-feet for a dry year. The wet year adverse impact would
be even greater than the quantities expressed above for an average year.
..-.^..^ emotive Us_e.- According to Table 3-*. «M*0 "re-feet
is the amount of water required for household and commercial use.
For Irrigation. 3,200 acre-feet is required in a dry year and 2,700
acre-feet is required in an average year. By assuming that three
percent of the household and commercial water Is consumed and that
75 percent of the irrigation water is consumed, the total consumpt.ve
use of Northglenn, exclusive of any reuse, is 2.520 acre-feet for a
dry year and 2,150 acre-feet for an average year. These consunpt.ve
use quantities represent the water that is totally removed from the
South Platte stream system, constituting an adverse impact.
...... „, .~.age Effluent - By exercising the proposed FR.CO exchange.
Northglenn's sewage effluent would be stored and delivered for ,rr,-
gation of lands under the Bull Canal. The additional consumptive use
or adverse impact resulting from the exchange amounts to 700 acre-feet
in a dry year and 560 acre-feet in an average year. These quantit.es
were determined by adding the reservoir evaporation from Table 3-U
to an estimated 65 percent of the FRICO bonus. This 65 percent
accounts for the percentage of the farm headgate delivery that Is
consumed.
By adding the adverse impacts caused by lining the Bull Canal,
by Northglenn's consumptive use, and by reuse of sewage effluent, the
total adverse impact amounts to 5.950 acre-feet in an average year
and 5 530 ecre-feet in a dry year. These quantities represent the
total adverse impact of Northglenn's water management plan prior to any
attempts to mitigate the adverse impacts.
2. The City of Northglenn currently has a water supply
provided by Thornton which diverts water from the South
Platte River system. Water use by Northglenn will
continue whether or not the Northglenn exchange plan
is implemented.
3. Northglenn proposes to return sewage effluent for
agricultural use in return for the water borrowed from
FRICO. This return includes a 10% or 500 acre-foot
bonus plus evaporation from the Bull Canal Reservoir
which will be used to store the return flow until it
is delivered. The source of supply of water for the
bonus and evaporation will be Northglenn owned-water
either from its share ownership in FRICO, return flow
from pumping nontributary wells, water diverted under
share ownership in South Platte or Clear Creek ditches,
or augmented out of priority diversions.
The combined effect of lining the Bull Canal, continued
agricultural use of 1450 shares of FRICO, consumptive
use by the City of Northglenn and evaporation and bonus
create a net increase in consumptive use. The extent of
injury to other water users, if any, is a matter that
will be decided in the Water Court.
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Alternative Impact Analysis - Although lining of the Bull Canal was
an integral part of the Four-Way Agreement and in itself causes a
very significant adverse impact, the question arises concerning what
decree Northglenn is responsible for adverse impacts in part caused
by other participants in the Four-Way Agreement. For this reason we
performed an alternative impact analysis to determine the impact of
Northglenn's water management plan excluding the Four-Way Agreement.
In an average year Northglenn requires 6,8*0 acre-feet of water. Of
the 4,140 acre-feet used for household and commercial use, we have
estimated that three percent would be consumed directly and 65 percent
of the remainder (sewage effluent) plus five percent for evaporation
would be totally consumed in'the land application process. This
amounts to 2,935 acre-feet. Adding this quantity to 75 percent of
the irrigation water that is consumed gives a total adverse impact
on the South Platte stream system of 4,960 acre-feet for an average
year. For a dry year, using a similar analysis, the adverse impact
amounts to 5,335 acre-feet.
By comparing these quantities with the quantities derived in the
first analysis, Northglenn is responsible for 83 percent of the
adverse impact, in an average year and 96 percent of the adverse
impact in a dry year. By adding the adverse impact caused by the
bonus arrangement that Northglenn made solely with FRICO, Northglenn
for all practical purposes, is responsible for the entire adverse
impact ranging from 5,500 to 6,000 acre-feet per year.
For comparison purposes, the adverse impact without the Four-Way
Agreement but with sewage return at Metro would range from 2,100 to
2,500 acre-feet per year. In other words, in terms of water quantity
the adverse impact would only be about 40 percent of the impact
caused by Northglenn's proposed water management plan.
Impact of Providing More Augmentation Water - In the draft EIS, the
comment is made in several places (Pages 9, 32, and 33} that Northglenn
probably will need more augmentation water. However, the Impacts of
providing more augmentation water to mitigate adverse Impacts on
-5-
The cities along with the fanners, benefit froa the
prevl^lv L inl"8 the BU11 Canal" Llnl"S. as -ntioned
previously, Is a vater conservation measure and will
increase the yield to all shareholders. It is specu-
lative whether or not the entire benefit could be
attributed to Northglenn as the canal would probably
be Uned without the Northglenn exchange plan
Providing additional augmentation water, If required
due to the possibility of inadequate water available
in the plan may affect other water rights. In EPA's
opinion, the quantity of water is less than the quantity
referred to in the W. W. Wheeler report. It is acknow-
leged, however, that requiring additional augmentation
water is likely to affect agriculture.
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other water users were not considered. Mitigation of the identified
adverse impacts ranging from 5,500 to 6,000 acre-feet per year, will
require the dry-up of additional agricultural land unless scms other
alternative is selected. Drying up additional agricultural land, in
turn, will adversely impact agricultural productivity.
Impact of inadequate Replacement - The analyses in the draft EIS are
based on annual quantities. In order to protect vested water rights,
it is necessary to augment the South Platte on a timely basis. For
example, if there is an adverse impact during August, augmenting the
river in June will not mitigate the adverse impact. On page 9 it is
concluded that "...the water rights to be used for augmentation are
sufficiently senior for that purpose..." In order to reach such a
conclusion, it would be necessary to perform an analysis on a daily
basis. We suspect that augmenting water rights such as the Burlington,
with a priority date of 10-20-1885, are not sufficiently senior to
provide replacement water on a daily basis when it is needed by senior
water users on the South Platte.
Agricultural Productivity - The authors of the draft EIS have expressed
the principles governing the change or transfer of water rights.
(Page 129). These principles relate primarily to protection of other
appropriators from injury and maintenance of stream conditions. In
order to prevent injury to other appropriators, it is necessary to
mitigate the adverse impacts identified in the previous section of
this report. One way of mitigating the adverse impacts is to purap
non-tributary deep water. However, using Northglenn's maximum antici-
pated yield, only 2,300 acre-feet would be available, mitigating only
a portion of the identified adverse impact of 5,500 to 6,000 acre-feet.
To provide additional augmentation or replacement water, Northglenn
has purchased agricultural water rights. The process of acquiring
agricultural water rights and drying up agricultural lands adversely
impacts agricultural productivity. After reading Northglenn's water
management reports and the draft EIS, the reader is left with the
impression that Northglenn's plan will actually provide a benefit to
7.
Yield studies of water rights along the South Platte
River which will be incorporated into the Northglenn
plan, have been made on a monthly and annual basis.
Some of the rights in the plan are relatively senior
while others are junior, and subject to being called
out during certain portions of the year and in a dry
year. Northglenn has the storage facilities available
to divert water when it is in priority and store the
consumptive use. This water can later be released to
meet a call to protect out of priority diversions by
the tributary well field or Grange Hall Creek. The
operation of the plan to provide water on a timely
basis to meet a call will be defined in the Water Court.
See the revised section of the Environmental Impact
Statement on Agricultural Productivity. There is a
moderate net benefit to agricultural productivity under
the three options analyzed in comparison with the option
four of condemnation of the FRICO system. Option A
assumes the water required by the City in a dry year
will be condemned or acquired. The balance of water
remaining, approximately 1300 acre feet, is available
for continued delivery to the farmers. This small
quantity of water cannot efficiently be conveyed in a
canal system designed for much larger capacities.
Complete rennovation of the Bull Canal for a reduced
capacity would be expensive and the remaining shares
are likely to be sold thereby completely eliminating
irrigated agriculture under the Bull Canal System.
-6-
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U>
agricultural productivity. For example, in the draft EIS the following
statement is made on page 26: "The Northglenn plan is designed to
provide a net benefit to agricultural productivity." As another
example, in the preface to the "Northglenn Water Management Program"
Volumes 1 and 2, the following statement is made: "By substituting
cooperation for condemnation, Northgtenn has designed a system capable
of satisfying municipal water demands while keeping agricultural land
in production." These statements, in our opinion, are misleading.
The fact is that either condemnation or purchase of an agricultural"
water right and the subsequent dry-up of land will adversely impact
agricultural productivity.
The "net benefit" reasoning used in the draft EIS is based on a
comparison between drying up land under the Bull Canal that would be
irrigated by 7,350 acre-feet in an average year versus drying up 1,260
acres of South Platte land. It was concluded that removing 7,350
acre-feet of farm headgate diversions from the Bull Canal would have
a greater adverse impact on agricultural productivity than drying up
1,260 acres. Since drying up 1,260 acres was the "lesser of two
evils," it was concluded that a net benefit results. In our opinion,
a simple comparison cannot be made between these two alternatives.
Drying up the land under the Bull Canal would produce a consumptive
use of approximately 4,600 acre-feet which is almost four times greater
than the consumptive use associated with the 1,260 acres of South
Platte land. To use this type of reasoning, two valid and comparable
alternatives must be used.
EPA Policy - According to an EPA letter dated September 8, 1978, from
Douglas M. Costle, "It is EPA's policy to protect, through the adminis-
tration and implementation of its programs and regulations, the
Nation's environmentally significant agricultural land from irreversible
conversion to uses which result in its loss as an environmental or
essential food production resource." Either condemnation or purchase
of agricultural water rights and the conversion to municipal use will
result in the loss of irrigated agricultural land.
-7-
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Comparative Agricultural Productivity - Appendix A of the draft EIS
gives a comparison between the agricultural productivity of the Bull
Canal and the South Platte areas. Estimated 1979 crop values were
compared for the two areas as shown in Table A-It and A-5. The yields
per acre as shown in these tables were obtained from the Weld County
Extension Service and from Colorado Agricultural statistician, Lance
Fretwell. The authors of the draft EIS assumed that these yields
were representative of the Bull Canal and South Platte areas. We
contacted Lance Fretwell and the Weld County Extension Service and
were informed that the information that they provide is on a county-
wide basis.
It is a well known fact by farmers in the area, that agricultural
productivity under the Bull Canal is much lower than along the South
Platte because the Bull Canal water supply Is not adequate for the
irrigated land. Even in an average year, FRICO only delivers about
50 percent of the water required to provide a full water supply for
^,3^5 acres. This lack of an adequate water supply Is the primary
reason that lands under the Bull Canal are not as productive as lands
along the South Platte. In our opinion, the yields per acre tabulated
on Table A-k are not applicable to the water short area under the Bull
Canal.
In order to verify this opinion, we obtained crop production
information from several farmers with land under the Bull Canal and
under the South Platte ditches and from other industry and government
agency sources. Since 1979 was a very wet year, use of only 1979
crop production information does not give a realistic indication of
average conditions. From the information that we derived for the
period 1975 through 1979, the average productivity of the farms along
the South Platte amounted to $650 per acre while the average produc-
tivity of lands under the Bull Canal averaged only $260 per acre.
Generally, the crop production information we obtained came from well
managed farms and, therefore, these values may not be representative
of all farms along the South Platte or under the Bull Canal. The
productivity of South Platte farms varies considerably depending on
-8-
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the type of crop grown. The productivity of the truck farms, some of
which are included in the South Platte average productivity value,
generally are very high. By using yields per acre that are more
representative of the Bull Canal and South Platte areas, we determined
the productivity for the land and crops tabulated In Tables A-4 and
A-5. The resultant productivity of the Bull Canal area amounted to
about $220 per acre and the resultant productivity of the South Platte
acreage amounted to about $330 per acre. The South Platte acreage
did not include any truck farms which accounts for the disparity
between the $330 per acre and $650 per acre productivity values.
However, both comparisons indicate that the productivity of South
Platte lands is significantly greater than the productivity of Bull
Canal lands.
In order to compare the alternatives of condemning FRICO land
and water rights versus the purchase of South Platte land and water
rights, it is necessary to present both alternatives using the sane
basis or foundation. Consumptive use is the best measure of a water
[> right's value and change potential in the Water Court. For this
-------
8
ON
MITIGATION OF IMPACTS
Steps to Minimize Adverse Impacts
Chapter 5 of the draft EIS addresses the subject of steps to
minimize adverse Impacts. However, the draft EIS in Chapter 5 does not
consider any steps to minimize either the adverse water quantity
impacts or the adverse impacts to agricultural productivity.
Net Adverse Impacts not Mitigated
Since the FR1CO water will be used for irrigation in the future,
this water is not available to mitigate the adverse impacts previously
identified. By utilizing the remaining water supply sources identified
on Figure 3-2 and Figure A-2, the total amount of water available for
replacement according to the quantities presented in the figures is
2,079 acre-feet in a dry year and 3,083 acre-feet in an average year.
Depending on the option selected, Northglenn may have zero, 650 acre-
feet or up to 2,300 acre-feet of non-tributary deep well water that
could be used for augmentation purposes. Northglenn does not have
enough replacement water available to mitigate the Adverse impacts
previously identified. The net adverse impacts on an annual basis
range from 600 to 3,500 acre-feet depending on the option selected and
whether the year considered is wet or dry.
Adequacy of Water Rights
As explained previously, it probably will be necessary to perform
a daily operation study of the water management plan in order to
determine whether or not the water rights purchased along with additional
water rights will be adequate to mitigate adverse impacts to other
water users. The existing water rights are not adequate even if they
produce the amount of water estimated by Northglenn.
At least some of the water rights may not be available for the
purpose of mitigating adverse impacts. For example, for the Riethman
Ditch in Civil Action No. 45,791 the court decreed as follows:
8.
AH four options identified have an adverse impact on
agriculture with a larger impact by the condemnation
alternative. Whether or not Northglenn has sufficient
water to protect other water right users from injury
will be a matter for the Water Court to decide. The
Water Court will also determine whether or not the
rights claimed by Northglenn to be used In the augmen-
tation plan, such as the Riethman Ditch, can be used
or not.
-10-
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a\
... when such water so diverted is not bene-
ficially used upon the said one hundred and ninety-
five (195) acres of lands described, the plaintiffs,
their heirs, representatives and assigns, shall
conduct or cause to be conducted such water to the
South Piatte River, by means of a ditch carrying the
same directly back to said River, or the same shall
be permitted to remain in said River at the headgate
of said Burlington Ditch; that the water diverted
under said priority shall at no time be permitted
to flow down said Burlington Ditch, beyond or past
the headgate of plaintiff's ditch or lateral,
carrying water to sa.id lands, and this decree is
entered upon the express condition and it is so
ordered and adjudged that the water diverted under
said priority shall never be used, under such
priority upon any lands, other than the one hundred
and ninety-five (195) acres of lands above described;
and, if and when the water diverted under this decree
is no longer applied to said lands or needed there-
g fore, this decree shall become void and of no effect,
and no further water shall be allowed to be diverted
under said priority, either at the headgate of said
Burlington Ditch or through any other ditch, and it
is now adjudged and decreed that the use of water,
under said priority, upon any lands, other than the
one hundred and ninety-five (195) acres of land
above mentioned, would constitute a change in the
conditions of the river and injury to the vested
rights of other appropriators.
Although the Riethmann Ditch was adjudicated in a subsequent
adjudication, the decree apparently mandates that the State Engineer
shall administer the water right as if it were in the first adjudica-
tion, as long as the water is used to irrigate a specific 195 acres.
This acreage is located between the Burlington Ditch and the South
Piatte River at the site which is now the Metro Sewage Treatment Plant.
From an engineering point of view, it appears from this decree that
Northglenn is prevented from changing this water right.
-M-
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MISCELLANEOUS COMMENTS
oo
10
11
12
13
1. Even if the water in storage within the non-tributary aquifer
beneath Northglenn amounts to 230,000 acre-feet, more detailed
engineering work needs to be done to verify whether or not
Northglenn can feasibly pump 2,300 acre-feet each and every year
for 100 years. What happens after 100 years?
2. Before the impacts of Northglenn's proposed tributary wells can
be determined, Northglenn must determine where the wells will
be located.
3. The impact of a shorter winter diversion season for the Croke
Canal should be investigated., We have not reviewed the yield
study prepared by Northglenn's engineers since that information
is not available as of February 12, 1980.
It. Preliminary information indicates that the cropping pattern
shown on Table A-5 may not be correct. Actually some of the
farms purchased by Northglenn along the South Pl.atte have raised
truck crops such as potatoes and other vegetables. This should
be verified since the crop value of vegetables is much higher
than the crops represented in the draft EIS and since this would
increase the adverse impact to agricultural productivity.
5. Northglenn apparently intends at times to continue to irrigate
some of the South Platte lands. This will reduce the quantity of
augmentation water available and could result in an expanded use
of water which could adversely impact other water users on the
South Platte. The resulting impact of this type of joint use
should be investigated.
6. Farms under the Bull Canal rarely, if ever, receive the Great
Western High Ten Growers award while several farms along the
South Platte have received this award. This is another indicator
9. The actual quantity of nontributary water available
to Northglenn, if any, is currently i.i the Water Court
for decision. The amount of water physically available
can only be determined after wells are completed and
the aquifer characteristics have been determined. The
nontributary aquifer beneath the City of Northglenn
has a life of at least 100 years. Because there is
only a fixed volume of water in storage in the aquifer
there is a finite period of water availability. At
such time as the water in the formation has been exhausted
alternative supplies would have to be arranged.
10. See the revised write-up on the tributary wells in the
final Impact Statement. The location of the well field
has been determined and provision has been included to
provide replacement water due to depletion of the
tributary stream system, by well pumping.
11.
A possible shorter winter diversion season for the
Croke Canal is a factor that Northglenn must consider.
12. A revised cropping pattern has been included in the
determination of agricultural productivity in the
final EIS.
13. Northglenn has indicated they will continue to irrigate
some lands subject to water availability. Northglenn
indicates the source of water for this irrigation will
be from water already diverted and stored under the
augmentation plan, Northglenn does not intend to
irrigate only partially in a year and claim consumptive
use credit for the balance of the year.
-12-
-------
that the South PUtte lands are more productive than the Bull
Canal lands. Also, not much Coors barley is grown under the
Bull Canal because an inadequate water supply adversely affects the
quality of the barley.
T
ON
\O
-------
^ Denver Water Board
' — -
ALTERNATIVES
In our opinion, Northglenn should consider other potentially
viable alternatives for their water supply. These alternatives
include the following.
Thornton
As stated in the draft EIS (Page 15), "Thornton also indicates
that they are currently developing water resources outside of the
Denver Metropolitan area to supplement their existing water supplies.
The current position of Thornton is that they can provide an adequate
water supply for themselves and Northglenn."
Deep Wells
Northglenn should consider the development of deep wells to be
used for peaking purposes and to supply water on an interim basis
until other water supplies such as transmountain water can be developed.
Our contacts with the Denver Water Department indicate that Denver has
a large 60-inch water main in or near Northglenn that has additional
capacity and could be used to supply Northglenn if water would be
available. Mr. Bill Miller, manager of the Denver Water Board, indicated
that Northglenn as well as other cities should consider joint develop-
ment of Denver's future transmountain water projects. Development of
these transmountain water supplies would have no impact on agricultural
productivity since this is excess water that Colorado is entitled to
by compact.
South Park Water
Thornton has concentrated its efforts in purchasing water rights
in South Park to provide additional water supplies for Thornton.
Northglenn should consider this alternative since it would probably
-14-
-------
result in a smaller adverse impact on agricultural productivity than
drying up farms along the South Platte downstream from Denver.
Combination - Northglenn should consider combinations of the alter-
natives mentioned above.
-------
SUMMARY AND CONCLUSIONS
1. The scope of our review and the comments contained herein were
limited to the subjects of agricultural productivity, water
quantity and water management plan alternatives.
2. Preparation of the draft EIS as well as our review was hampered
by a lack of information concerning water quantity aspects of
Northglenn's water management plan. Northglenn will not provide
engineering studies concerning their analysis of the yield or
historical depletion resulting from the utilization of their
water rights until the studies are finalized. It becomes very
difficult if not impossible to identify adverse impacts or
determine the adequacy of mitigation efforts when engineering
studies have not been finalized.
3. The direct Impacts of Northglenn's water management plan can and
should be identified and quantified apart from any resolution.
of legal issues. Secondary impacts upon agricultural procuctivity
should be addressed assuming that Northglenn must mitigate all
adverse water quantity Impacts. Other assumptions concerning
resolution of legal issues may also be made, providing the full
range of possibilities is set forth.
J». The water quantity adverse impacts of Northglenn's water manage-
ment plan range from 5,500 to 6,000 acre-feet per year. These
impacts are caused by lining the Bull Canal, by Northglenn's
consumptive use, by reuse of sewage effluent, and by the bonus
arrangement made with FRICO.
5. We concur that more water will be required to mitigate adverse
impacts on other water users. EPA should study the impact on
agricultural productivity of providing this extra water.
-16-
-------
6. Some of Northglenn's augmenting water rights may not be sufficiently
senior to provide replacement water on a daily basis when it is
needed by senior water users on the South Platte.
7. Either condemnation or purchase of agricultural water rights will
adversely affect agricultural productivity by a similar amount.
We disagree with EPA that a net benefit to agriculture will result
from Northglenn's water management plan. A comparable analysis
of the two alternatives must be performed to arrive at this
conclusion.
8. We encourage EPA to review its policy concerning protection of
agricultural lands to see if the adverse impacts identified herein
on agricultural productivity comply with their policy.
9. South Platte lands are much more productive than Bull Canal lands
because the FRICO water supply only provides 50 percent of the
required water in an average year.
I 10. The draft EIS does not adequately consider the mitigation of
(jj adverse Impacts on other water users and on agricultural produc-
tivity.
11. The net adverse impact of Northglenn's water management on other
water users ranges from 600 to 3,500 acre-feet per year depending
on the amount of deep well water developed.
12. It is necessary to perform an operation study of Northglenn's
water management plan to determine the adequacy of their existing
water rights as well as to indicate the additional quantity of
water required.
13. Some of the water rights Northglenn intends to use for augmentation
may not be available because of decree limitations or other
possible limitations.
-17-
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COLORADO PROJECT/T.I.P.
P.O. Box 731
998 SIXTH STREET
BOULDER, CO 80302
303-443-2*71
21 February 1980
Mr. Wes Wilson
EPA, Region VIII
I860 Lincoln St.
Denver, Colorado 80295
Dear Mr. Wilson:
I an writine to encourage a positive declaration by the EPA
regarding the proposed Morthglenn Water Management PIUJ^LCBU. I have
been following tferthglenn's seuage plans for a long time, since being
involved with the formation of the DRCOG Regional Task Force on 208
Planning, and the beginning of the statewide implementation of the 208
effort. 1 an encouraged by the thoroughness in planning and making
recycling/reuse a prine energy conserving feature of the plan.
OQLOKADO PROJECT/TIP is a sister organization of the Technical
Information Project Inc. TIP is a non-profit public interest consulting
firm that specializes in the areas of resource recovery, energy policy
analysis, waste and recycling.
The draft Environmental Inpact Statement for the project,
EPA 908/5-79-002A, thoroughly studies the project and properly
concludes that the project qualifies for EPA funding.. I believe
that it correctly concludes that the innovative and alternate technology
features of the project override any risks involved and that irrigation
waters will be available for agricultural lands during the life of
the project.
RESPONSE:
1 < Acknowledge
i S. Stem
Project Director
ESC. a)
-------
THE FARMERS RESERVOIR AND IRRIGATION COMPANY
DIRECTORS
ADOLPH BOHLENDER.
CONRAD HERBST
ALBERT SACK, a™ »ei
PAUL NORDSTROM. »>
M M KARSH
ALEX MILLER
LAWRENCE GERKIN
SO SOUTH 27TH AVENUE
BRIGHTON. COLORADO 8O6OI
THOMAS G FISHER
fcM*MT«NOC*T
CAROLYNS FULTON
MCftCTAN*
GENEVA D SANDUSKY
February 21, 1980
Ol
awironmental Protection Agency
Region VIII
1860 Lincoln Street
Denver, Colorado 80295
Gentlemen:
RE: Draft Environmental Impact
Statement - Northglenn Hater
Management Program
City of Northglenn, Colorado
This cement to the Draft Environmental Dipact Statement for the
City of Northglenn in the Northglenn Water Management Program is
being submitted for inclusion in the record of written commits
regarding the above-noted Draft Environmental Impact Statement.
The Farmers Reservoir and Irrigation Company supports the City
of Northglenn in its request for grant assistance for the
Northglenn water program. Trie Farmers Company believes that
only through multi-purpose projects, of which the Northglenn
project is a model, will irrigated agriculture continue to be a
viable force on the front range of Colorado.
Ihis comment is limited to one aspect of the Draft Environmental
Impact Statement set forth on pages 89 and 90 with respect to a.
plan to prevent the public sale or distribution of raw edible
food crops irrigated" with the effluent water from the City of
Northglenn.
RESPONSE:
EPA, based on its independent analysis, has determined that
sufficient level of pathogenic die-off occurs with the
proposed system such that waterborne disease transmission
by crop contamination is lov. On a national level EPA has
decided to issue specific guidance for necessary pretreatraent
prior to use of sewage effluent on raw edible crops. This
effort is expected to take 2 to 3 years. At that point
Northglenn, upon permit renewal will be required tc comply
with that guidance or if too costly impose a ban on rav edible
crops as previously proposed. The agricultural reuse ~anual
will contain an advisement against the use of this effluent
on raw edible crops.
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Page 2
February 21, 1980
Environmental Protection Agency
Region VIII
In large part, all of the water available for agricultural users
in the South Platte basin, is reuse water. For many years. The
Farmers Company, in its various divisions, and the other agricultural
users of South Platte water, have utilized reuse water for general
crop irrigation without adverse affect and without limitation upon
the public sale or distribution of any food crops which are irrigated
with predominately effluent waters.
The agreement between the City of Northglenn and The Farmers Company
with respect to the use of water frcm Standley lake provides that
Northglenn shall return effluent of suitable quality to the share-
holders of The Farmers Company. In conjunction with the govennental
standards which will be imposed upon Northglenn, The Farmers Company
believes that the standards for effluent water which will be
established between Northglenn and The Farmers Company will be
adequate to provide for the protection of public health. The Farmers
Company therefore believes that requiring a plan to prevent the
public sale or distribution of any food crops irrigated with the
returned water fron the City of Northglenn neither reflects the present
status of irrigated agriculture on the front range of Colorado, nor
is any such plan required to adequately protect public health.
The Farmers Company further believes that such a limitation upon the
reuse of the waters from the City of Northglenn would not meet the
standards of suitability which are called for in the agreement
between the City of Northglenn and The Farmers Reservoir and
Irrigation Company.
In considering the alternatives in the event that effluent waters
are not directly used for irrigation, such waters will, in any event,
be returned to the South Platte River from the City of Northglenn
and all of the other municipalities in the Denver metro area; and
such waters will continue to be withdrawn for the irrigation of
general food crops without any specific limitation upon the public
sale or distribution of crops grown. In such circumstances. The
Farmers Company believes that it is preferable to provide for the direct
reuse of the effluent waters from the City of Northglenn where both
governmental and contractural standards will be imposed, rather than
providing for the uncontrolled return of the effluent waters to the
lower users in the South Platte River basin.
Very truly yours.
Sdolph Bohlender
President
The Farmers Reservoir « Irrigation Company
-------
U.S. DEPARTMENT OF TRANSPORTATION
FEDERAL HIGHWAY ADMINISTRATION
IEGION EIGHT
J!5 ZANG STIHT. SOX tiW
OENVEI. COIOIADO JOMS
2^/67
February 21, 1980
Mr. Roger L. Williams
Regional Administrator
U.S. Environmental Protection Agency
Region VIII
1860 Lincoln Street
Denver, Colorado 80295
Dear Mr. Williams:
Thank you for the opportunity to review the draft environmental impact
statement for the Northglenn Water Management Program in the City of
Northglenn, Colorado.
We have no substantive comments to make on this document as highway
transportation is not a significant issue in this water works project.
IN WCPIV MFC" 1*0
HED-08
RESPONSE:
1. No response necessary
Sincerely,
Daniel Watt
Regional Federal Highway Administrator
-------
00
United States Department of the Intenor
OFFICE OF THE SECRETAR\
DENVER. COLORADO 80225
'- FEB261980
|\\< . •
JUEPA REG1C.; -.HI.
Division
In Reply Refer To:
ER 80/66
Mr. Roger L. Williams
Regional Administrator
U.S. Environmental Protection Agency
Region VIII
1860 Lincoln Street
Denver, Colorado 80295
Dear Mr. Williams:
In response to your letter of January 11, 1980, requesting review and
comment on the Draft Environmental Impact Statement, Northglenn Water
Management Plan, Northglenn, Colorado, the Department of the Interior
has reviewed the document and provides the following comments.
Fish and Wildlife
The document is not adequate regarding fish and wildlife resources. The
information in the Draft Environmental Impact Statement (DEIS) is not
sufficient to determine whether fish and wildlife resources will be
affected by project construction and operation.
Fish and wildlife resources should have been discussed when addressing
the lining of Bull Canal because reducing the seepage by 30 percent
could be detrimental to fish and wildlife habitat. Mitigative measures
may be warranted. The DEIS also is not clear regarding depletion of
flows from the South Platte River. We have learned from your agency
that the existing South Platte flow regime will be modified below the
tributary well field. The DEIS should define the stream reach affected,
and describe how flow regimes will be changed. It is our understanding
that contact has been made with the Colorado Division of Wildlife to
resolve some fish and wildlife issues. The DEIS should discuss these
issues and any impacts to fish and wildlife that would be associated
with this proposed project.
I The Endangered Species Act requires any Federal agency planning to
construct, fund, or license a construction project to ask the Fish and
Wildlife Service whether listed species or species proposed for listing
occur within the area would be affected by the proposed project. If the
RESPONSE: 1. EPA recognizes that lining the Bull Canal may be somewhat
detrimental to fish and wildlife resources. However, the
lining of the Bull Canal is an independent action of a private
enterprise and is not an integral part of the Northglenn
project. Therefore, EPA will not be able to mitigate any
impacts associated with lining of the Bull Canal.
2. Northglenn's proposal Involves full augmentation of its
South Platte, tributary waters and therefore the overall
historic flow regimes will remain the same. Part of the
stream reach, immediately below the tributary well field
will have an insignificant reduction in flow. This reduction
in flow is considered insignificant because Northglenn's
purchase of water rights are sufficiently senior and will be
utilized to replace well field depletions. Lining of the
Bull Canal by FRICO will increase historical depletions,
but this is a private action unrelated to EPA's or any federal
action and is a question to be resolved in water court.
-------
Service replies that such species may occur in the project area, the
involved Federal agency must conduct a biological assessment. If the
assessment reveals that listed species may be affected, the Federal
agency is to consult with the Service, which in turn issues a written
biological opinion on the project. These procedures should be discussed
in the DEIS.
Ground Water
Because of the potential significance to ground-water resources, the
specifics of the planned effluent disposal by irrigation of alfalfa
should be more thoroughly discussed. We have questions concerning the
discussion of acreage of alfalfa required to ensure continual disposal .
of wastewater-plant effluent (p. 91, 92). The probable volume of effluent
that might be used on the 1,100-acre plot should be mentioned in the
assessment. Typical depths of alfalfa roots in the general area and
normal efficient rates of water application per acre for alfalfa should
be indicated. These details are pertinent to the impact analysis.
California tests of fine sandy loam grading into fine sand at depths of
about 4 feet indicate that 95 percent or more of the alfalfa roots exist
in the upper 5 or 6 feet of soil. Tests were made to determine efficient
rates of water application, with the aim of avoiding loss of water below
plant roots. It was found that application of 3 acre-feet per acre
seemed to accomplish the most efficient use of the water applied and
minimize loss below plant roots. On loam soils, 30 inches or 2.5 feet
of water seemed to be sufficient for plant uptake. For sandy or gravelly
soils, application of 4 or 5 acre-feet per acre was found most efficient
(Young, A. A., 1945. Irrigation Requirements of California Crops.
California Division of Water Resources Bulletin 51, p. 102-104).
Minerals
Known mineral resources of the project area and environs include coal,
petroleum, natural gas, sand, and gravel. The DEIS mentions mineral
resources (p. 49) but does not list the specific resources involved.
The document also states (p. 50) that of the 10 sites evaluated for the
storage reservoir, seven were rejected because they were "underlain by
geologic faults, abandoned coal mines, natural gas lines, and/or
economically recoverable mineral resources (Site 2 and Sites 4
through 9)."
Actually, coal underlies the accepted site as well as the nine rejected
sites, and producing oil wells are within about one-half mile of the
recommended site. Any future recovery of coal from beneath the site
probably would not be affected because of its depth below the surface
(about 2,000 feet) and the impervious clay lining planned for the reservoir
Moreover, any oil or gas occurring beneath the reservoir site likely
could be recovered by directional drilling. Commercial sand and gravel
deposits apparently do not occur within the reservoir site.
3. Consultation with the Fish and Wildlife Service indicates
that the only possible impact on endangered species would be
a consequence of South Platte River depletions affecting
whooping crane habitat downstream in Nebraska. As explained
under comment 2 above, EPA's action to approve the Northglenn
project vill not affect the South Platte flow regime. DOI
may want to consider how the private actions of FRICO of
lining the Bull Canal or any other private action may affect
whooping crane habitat.
It is the intention of Northglenn to dispose of their waste-
water on private farmlands irrigated under the Bull Canal
which currently has 8,000 acres under irrigation. If there
is insufficient private demand for this water Northglenn has
agreed to develop a contingency plan to dispose of the
effluent on City-owned land. A nitrogen balance was performed
to determine the maximum loading in order to minimize this
land requirement. With sufficient nitrogen uptake there is
not expected to be nitrate infiltration into the groundwater.
Execution of the contingency plan would require application
to the State Department of Health.
5. Mineral resources which underlay the proposed site as well
as other sites are discussed in the alternative site analysis
section of the final EIS.
-------
oo
o
(Me suggest that subsequent versions of the document list mineral resources
of the area, discuss their relationship to the storage reservoir, and
state that minerals underlying the reservoir site could be produced, if
necessary.
Historic Preservation
Copies of environmental documents should be sent to the Advisory Council on
Historic Preservation rather than the "National Trust" (see Distribution,
p. v). In addition, the comments of tlhe State Historic Preservation
Officer and/or the State Archeologist on the archeological survey should
be included in the final statement.
Section 404 Permits
From the document we have not been able to determine whether a Section
404 permit will be required for all or portions of this project. This
should be addressed in the DEIS. If a Section 404 permit is required,
comments dealing specifically with the permit will be provided by the
Area Manager, Fish and Wildlife Service, Salt Lake City, Utah.
In conclusion, we believe that the DEIS does not adequately cover the
environmental concerns of the Department of the Interior. The comments
discussed in this letter should be addressed in the final statement.
Sincerely yours,
6. Northglenn has obtained all appropriate 404 perp.its necessary
for construction of their proposed project. See response to
consent 1, Corps of Engineer letter February 20, 1980.
'JOHN E. RAYBOURN
Regional Environmental Officer
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Citp of Jfort lupton
COUNTY Of WELD
February 22, 1980
00
FEB26 1980 .' I
\< ,'j
_ tr." REGION Vlil L—>
Mr. Roger L. Williams
Regional Administrator
U.S. Environmental Protection Agency
Region VIII
1860 .Lincoln Street
Denver, Colorado 80295
Dear Mr. Williams:
Enclosed, the following comments, provided by the City of Ft. Lupton,
concerning the Draft Environmental Impact Statement of the Northglenn Waste-
water Management Plan and the February 13, 1980 public hearing on that plan.
. Project Need. Northglenn contends that this project is necessary
to provide its citizens with an acceptable water supply, i.e.
Thornton cannot provide an acceptable water supply in terms of
quantity or quality. Thornton says it can supply Northglenn with
water sufficient to meet its current and future demands and that
its water quality problem has been corrected. If the latter is
correct, Ft. Lupton sees no need for this project. The applicant
should be required to substantiate their contention and demon-
strate actual need.
2.
3.
Project Funds. "In effect Northglenn ' s wastewater treatment need
is entirely a function of the water supply and exchange program.
In order to implement the exchange, control of wastewater treat-
ment and discharge is essential", (draft E.I.S. p. 16) Ft. Lupton's
position is that the granting of sewer construction funds should be
predicated on a community's legitimate wastewater needs. The City
suggests that the E.P.A. explore whether wastewater treatment
needs - which are artifically generated as a by product of North-
glenn' s water supply and exchange program - constitute a legitimate
need.
Scope expansion. Ft. Lupton is concerned with the operational as-
pects of this plan and their feasibility. It is a pertinent and
appropriate area of inquiry and we request that the environmental
impact study be expanded to include this aspect of the plan.
RESPONSE:
EPA acknowledges the fact tnat Thornton's existing water supply
is acceptable, in terms of quality, to satisfy current drinking
water criteria. Thornton has not demonstrated that their
water resources,without additional expansion, are adequate to
meet the future water supply need for both Northglenn and
Thornton. Please refer to alternative water supply analysis.
Northglenn's wastewater treatment needs are a function of its
future growth and are based on the prorata share of Denver
Metro costs. While the wastewater treatment project is an
integral part of Northglenn's water resource management plan,
EPA has determined that the wastewater treatment need is
sufficiently documented.
Additional analysis of the operational aspects of the plan
has been conducted as part of the final EIS. This analysis
indicates that potential problems may occur in neeting the
suspended solid limit. If suspended solids concentrations
violate penr.it limits, Northglenn is responsible for inplenent-
ing operational controls to achieve permit requirements.
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Mr. Roger L. Williams
Page 2
February 22, 1980
oo
Legal Compliance. It is our understanding that at the February
13, 1980 public hearing, several parties raised the issue of
E.P.A.'s procedural compliance with recently promulgated re-
gulations covering the preparation of draft environmental im-
pact statements. More specifically we are concerned that E.P.A.
has not followed the "scoping requirements" of these regulations
and is in violation of the law.
Water Supply Impact. It is the intent of the City of Ft. Lupton
to evaluate and suggest the classification of the 'Bull Canal and
the Coal Ridge Extension Ditch, including Sand Hill Lake, for the
purposes of raw domestic water supply in the upcoming stream re-
classification hearing of the Colorado Water Quality Control
Commission.
The City of Ft. Lupton is concerned about the adverse impacts this project
will have on the city and the surrounding region and is opposed to its con-
struction. Therefore, until all problems are satisfactorily resolved we urge
the E.P.A. to deny this fund request.
Sincerely,
4. The issue of compliance with the scoping process was subject
to litigation in Consolidated Ditches Company, et.al. vs.
EPA. The issue vas settled by mutual written agreement
between EPA and these parties on June 2, 1980. It is EPA's
position that during the last two years of review by'our
agency; the environmental assessment, public meetings and
numerous phone calls regarding the Northglenn proposal
were sufficient to satisfy the intent and purpose of the
public scoping process required under recent regulations
promulgated by the Council on Environmental Quality.
5. EPA concludes that since the Canal is not presently used
for a dor.estic vater supply, nor has there been any fornal
request to designate the Canal for domestic vater supply,
there is no need to protect the Canal for water supply.
William D. Hoffman, Mayor
City of Ft. Lupton
WDH/af
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! V FEB271980
oo
CO
MO
RESPONSE:
Water quality standards and stream classifications are
established by the Colorado Water Quality Control Commission
and approved by EPA. The proposed South Platte River basin
classifications and standards vill be presented at public
hearings during the summer of 1980. The public hearing process
is the forum for presenting the public's desires.
-------
WilBe
COLORADO
February 24, 1980
OFFICE OF BOARD OF COUNTY COMMISSIONERS
PHONE 1303) 356-4000 EXT. 200
P.O BOX 758
GHEE LEY. COLORADO 80631
oo
•P-
Mr. Roger L. Williams
Regional Administrator
United States Environmental
Protection Agency
Region VIII
1860 Lincoln Street
Denver, Colorado 80295
RE: Approval of a Wastewater Treatment Facility Plan for a New
Sewer Interceptor, Lagoon System, Storage Reservoir, and Agri-
cultural Re-Use System for the City of Sorthglenn, Colorado
Dear Mr. Williams:
After reviewing the draft EIS which addresses the proposed Northglenn
Water Management Program, and after attending the public hearings
concerning this program, Weld County has a number of concerns which
it feels must be addressed before the United States Environmental
Protection Agency can consider awarding a construction grant for
the development of the proposed Northglenn system. These concerns
include the following items :
1. In letters to Mr. Roger Williams, Regional Administrator, EPA,
from Gregory J. Hobbs, Jr., dated February 13, 1980, and
February 12, 1980, it is pointed out that the Environmental
Protection Agency has "intentionally and deliberately" violated
the "scoping requirements" which are set forth in regulations
of the Council on Environmental Quality at 40 C.F.R. , 1500.1
et. seq. , and 40 C.F.R. , 1501.7 et. seq. It is Weld County's
opinion that an important part or~the preparation of a draft
EIS has been ignored. Without such a process, there is no way
of guaranteeing that critical issues will be addressed as the
draft EIS is prepared. In reviewing the statement which has
been issued by EPA, it would appear that several issues have
not been given adequate consideration. Therefore, these
comments should be considered as identifying issues as part of
a "scoping process" as defined by CEQ regulations.
RESPONSE:
1.
position that during the last two years'of'review by our
agency; the environmental assessment, public neetire* and
numerous phone calls regarding the Northglenn proposal
Quality
*;
u.o,
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Mr. Roger L. Williams
Page 2
February 24, 1980
oo
In a review of the draft EIS prepared by W. W. Wheeler and
Associates, Inc., issued on February 13-, 1980, serious questions
have been raised as to whether or not the Northglenn Water
Management Plan is in reality, less detrimental to agriculture
than the condemnation alternative. This report, as well as the
draft EIS, reveal that the full implications of Northglenn's
water supply system are not yet determined. Many of the
implications of this system will be dependant upon decisions
which have not yet been made by the courts. Further, questions
have been raised as to whether or not the productivity figures
used in comparing the impacts on the South Platte and FRICO
land areas relate to the specific farmlands involved. The
conclusions of the productivity analysis are thus at issue.
Each of these questions has significant implications for the
impacts which the project will have on agricultural productivity.
For Weld County, this is a major question which must be more
fully addressed before the project is funded. One of the major
premises of the Weld County Comprehensive Plan supports the
preservation of agricultural land as an important local, state
and national resource. Thus, it is very important that the
true impacts on agricultural productivity in the Weld County
area be assessed.
It is pointed out in the EIS that the need for the treatment
facility is basically a function of the water supply requirements
of Northglenn and not a function of the need for additional
treatment capacity. Given the use of other water supplies, other
alternatives exist for the treatment of Northglenn wastewater.
Therefore, one would assume that it would be appropriate and
necessary to consider other alternatives to the Northglenn supply
proposal within the draft EIS. A logical conclusion, which might
be drawn from such an analysis, would be that alternative
water supplies create a net benefit to agriculture. The existing
alternative does not create a net benefit unless considered in
comparison with the condemnation alternative. Weld County
joins other concerned parties in asserting that a full evaluation
of alternative water supplies has not been accomplished in the
draft EIS. A thorough evaluation of reasonable alternatives
is one of the basic requirements of federal regulations governing
the development of Environmental Impact Statements (see Page 3
of letter to Mr. Roger Williams from Mr. Gregory J. Hobbs, Jr.
dated February 13, 1980.)
Substantial portions of the draft EIS are devoted to the
definition of mitigation measures which must be enforced if the
Northglenn system is to be operated without significant impacts.
Two mechanisms are relied upon by EPA to ensure that these
mitigation measures are implemented by Northglenn. These
include, (a) EPA grant conditions; and (b) the State enforcement
2.
EPA has revised the agricultural productivity analysis to
reflect similar concerns raised by the Colorado Department
of Agriculture. See revised Agricultural Productivity
Analysis, Chapter 4.
3.
Additional water supply alternatives for the City of Northglenn
have been considered. An evaluation of these alternatives is
presented in the revised water supply alternative section of
the EIS.
EPA concurs that grant conditions are difficult to enforce
following wastewater facility construction. In order to
secure additional responsibility and enforceability, EPA
will negotiate with the Colorado Health Department to have
several of these proposed grant conditions included
as NPDES permit requirements. These include the following
requirements: 200/100 ml fecal coliform limit in the effluent,
disinf •-'-ion of Dacono's nonpotable water supply, continuously
contrci tailwater near the communities of Frederick and
Firestone, as well as the requirement to limit new sewer taps
based on DRCOG's population projections, and a ban on taps
along the new interceptor. It is EPA's intention to require
Northglenn to enter into an intergovernmental agreement with
Weld County. EPA has not changed its required inclusions
to the IGA. Northglenn has developed a draft IGA which is
presented in Appendix K.
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Mr. Roger L. Williams
Page 3
February 24, 1980
oo
ON
5a
5.
of NPDES permit requirements. EPA attempts to back up this
enforcement mechanism by having the mitigating measures set
forth in an inter-governmental agreement which is to be
promulgated between Weld County and the City of Northglenn.
In the latter instance, Weld County becomes an enforcement
agency for the grant conditions and mitigation measures. Weld
County seriously questions the effectiveness of the enforcement
mechanisms which are relied upon to ensure that the mitigation
measures are implemented. Once EPA has awarded the grant and
the facility has been built, what authority does EPA retain to
enforce the grant conditions? How many of the p.roposed
mitigation measures can be made a part of the State NPDES permit
under Federal or State law and thus part of a more effective
mechanism for ensuring that the mitigation measures are
implemented? If EPA and the State are unable or unwilling to
provide an effective enforcement mechanism, Weld County might
not choose to enter an inter-governmental agreement which
establishes the County as the enforcement agency, which must
spend substantial amounts of money to enforce grant conditions.
It is Weld County's assertion that the mitigation measures and
the ability of different agencies to enforce the conditions
which are placed on the Northglenn system are factors which
must be carefully reviewed in the Environmental Impact State-
ment process. It is felt that if these agencies cannot
effectively enforce the grant conditions, this fact should be
fully recognized by all parties involved, so that individuals
do not assume that enforcement of conditions is available
where such enforcement is unlikely.
In at least three instances, the mitigation techniques suggested
to solve environmental issues are questionable. These include
the following:
a) The EIS recommends that Northglenn control the distribution
of edible food crops in the FRICO system which are irrigated
by Northglenn effluent. Northglenn has even proposed that
the City will buy those crops to prevent their public
distribution if adequate markets are not available. It
seems that this proposal is very unrealistic in terms of
Northglenn's ability to actually secure adequate markets
or to purchase the crops on their own. There has been no
analysis done of the potential cost to Northglenn of
purchasing such crops if markets are not available.
Farmers under the FRICO system could reasonably choose to
grow raw edible food crops in order to take advantage of
a guaranteed market under the proposed conditions. It
is Weld County's opinion that this particular mitigation
technique is completely unacceptable in solving the
problem of contamination of food crops by effluent from
the Northglenn system.
5a.
food crops. This dec^Ln J1'"""""- °f «w edible
for such use. The Agricult ?" *" endors^nt by EPA
by Northglenn, will advise f Reuse Manual, to be prepared
effluent on raw edible food crcM* againSt the use °f
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Mr. Roger L. Williams
Page A
February 24, 1980
5b
oo
5c
5d
a system have not been discussed in ^e draft El
Further, it seems that there may be legal issV"
with the capture of such tail water and *« u"
distribution. These questions have not been
in the draft EIS. Finally, the draft EIS does not aaoress
now effective such a system would be in actually con-
trolling the discharge of such waters to '^ ""^^d
Frederick and Firestone. For instance, canjf i *4?u^t
that the proposed plan will e«e
. ,
seriously questions whether Horthglenn has the ability to
perform such a management function adequately . It
Northglenn fails to carry out such mitigation measures, wno
is to pay the price in the long range?
6
In two instances, the draft EIS addresses the
nation of domestic water supplies through the
effluent from the Northglenn system. These
domestic water supplies for both F°« ^P"^*!"*!! potential
the case of Fort Lupton, EPA has concluded ^ the poten tial
for contamination of Sand Hill Reservoir is very ^i1"^?-
the case of the Town of Frederick, EPA has "nluded that
Frederick should secure another domestic water ^|P|n^lr^nt
felt that this poses a significant issue which ^.f1™^™*
Protection Agency must address in terms of both this project
5b. Initial plane for the control of tailwater near the towns
of Fredrick and Firestone are presented in the EIS. .
Whether such water may be legally reused in this manner is
subject to water court decision. The effectiveness of this
control is sufficient to prevent public contact with waste-
water effluent. Stormwater will impose an additional
loading on the control ponds, presenting the possibility
that if irrigation preceded or occurred during a storm event
diluted tailwater could enter the streets of Frederick or
Firestone.
5c. Northglenn will be required to meet the NPDES permit con-
ditions to disinfect or replace Dacono's nonpotable water
supply system. Negotiations for this are the responsibility
of Northglenn and will require acceptance by the Town of
Dacono. Northglenn's projected cost of $50,000 la reasonable
and acceptable to EPA.
5d. Northglenn will not be a manager of the agriculture reuse
area. Rather it will develop an agriculture reuse manual.
The purpose of which it to advise irrigators on appropriate
management measures to utilize wastewater.
The State Water Quality stream classification process allows
a community to request classification of waters for potential
use as a water supply. Fort Lupton and Frederick have had this
option to request such a classification of the Bull Canal for
domestic water sources. Since Frederick has not sought formal
reclassification of the Bull Canal for a water supply to this
date nor investigated the use of the Bull Canal for this use,
EPA has determined there is insufficient justification for
delaying the Northglenn Proposal on this basis.
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Mr. Roger L. Williams
Page 5
February 24, 1980
oo
oo
and in terms of future use of waters of the State. The issue,
simply stated, involves determining how significant an invest-
ment has to be made in a given water supply to warrant protecting
it for domestic use. In the case of Frederick EPA has stated
that the water intended for domestic use was not formally
designated as such. How much of a commitment does Frederick have
to make in terms of that water supply before their concerns
can be recognized? It is felt that this issue will not only
arise in the case of the Northglenn project, but in the case of
many 'other projects throughout the State of Colorado. In this
sense, it must be fully addressed if the problem is to be
solved.
7. On Page 15 of the draft EIS, it is indicated that the annual
growth rate for the City of Northglenn is expected to be 3.1
percent per year. It is also indicated that the population of
the City in the year 2000 is projected to be 42,500. Based on
the 1976 population figure of 32,000 and the expected rate of
growth of 3.1 percent per year, Northglenn would reach a popu-
lation of 42,500 by approximately 1987. The significance of
these discrepencies should be analyzed to detercine their effect
on the basic assumptions made in terms of the need and design
of the project.
8. The draft EIS states that a decrease in residential values
adjacent to the site of up to 5 percent is possible if the
facility is located at the proposed site. It is Weld County's
contention, that if the facility is to be located as proposed,
8 appraisals should be made both prior to location of the facility
and after location of the facility to determine effects on
adjacent residential property values. Northglenn should then
be required to pay the property owners the difference in value
between the two appraisals.
19. Weld County disagrees with EPA's conclusion that the site for
the proposed facility is acceptable (see Page 51 of draft EIS) .
In essence, EPA has basically accepted Northglenn's argument
for chosing this site and it does not appear that EPA has fully
evaluated Northglenn's site selection process.
10. The draft EIS addresses water quality effects on livestock on
Page 56. The conclusion reached is that problems will not exist
if effluent quality resrains within recommended limits and proper
management techniques are utilized to prevent nitritis. These
statements raise two issues. First, if the effluent quality does
not remain within recommended limits, who is to enforce those
limits and vhat mitigation measures are to be utilized to reduce
the problem? Second, are technicques such as the reduction of
chemical fertilizers and the maintenance of aerobic conditions_in
stored silage, sound and feasible methods for controlling nitritis?
10
8.
9.
10.
Based on Northglenn's current population growth rate of
3.1 percent Northglenn would expect to reach a total popu-
lation of 42,500 by the year 1990. Northglenn is a land-
locked community. It has no ability to expand its boundaries,
therefore, this population projection la also used for the
year 2000. This population projection is also consistent
with the DRCOG 208 plan.
There is a potential for a decrease in residential property
values adjacent to the site. However, EPA will not require
Northglenn to make any compensation to the landowners for
this potential decrease in property value.
more envronmenay accepae se avaae o e
City of Sorthglenn for the wastewater treatment and storage
Nitrogen concentrations in the effluent and subsequent uptake
and accumulation of nitrogen within silage crops is not
anticipated to reach critical levels that would be detrimental
to livestock. Therefore, it is felt that mitigation mea ures
are not necessary to reduce nitrogen concentrations in c ops.
Nitritis is controlled primarily by maintaining aerobic ondi-
tions in storage silage. These methods are generally ne essary
in normal silage operations to prevent anaerobic conditi ns
which would deteriorate the quality of the silage for livestock
use.
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Mr. Roger L. Williams
Page 6
February 24, 1980
11
12
13
00
14
15
11. The draft EIS addresses a concern relating to the control of
weeds on properties owned by Northglenn within Weld County.
It is Weld County's position that Northglenn must be required
to pay for weed control on these properties.
12. On Pages 93 and 94 of the draft EIS conditions relating to a
proposed monitoring system are set forth. It is stipulated
that the monitoring program would be reviewed by the Larimer-
Weld Regional Council of Governments and by Weld County before
the monitoring program is approved by EPA. Veld County objects
to being placed in the position of reviewing the monitoring
program for any purpose if it has no authority to approve or
deny the proposed program. By participating in such a review
of the program, Weld County presents the appearance that it
has authority where it does not. Finally, it seems that a
mechanism should be established for independent analysis of
the findings of the monitoring program by an agency or firm
other than Northglenn, and that a provision be established which
requires Northglenn to pay for such independent analysis.
13. The draft EIS has shown that Weld County will lose approximately
$8,500 per year in taxes from lands which have been taken out
of production as a result of the facility. It is Weld County's
Position that Northglenn must make payments in lieu of taxes
or all lands taken out of production as a result of Northglenn
land and water purchases in Weld County.
14. At the public hearing on February 13, 1980, a representative of
Great Western Sugar Company identified a concern related to
algae growth in the storage reservoir. It was indicated that one
of the icain techniques for controlling such algae growth was
through the use of copper. It was further indicated that copper
concentrations can cause severe problems with sugar beet
production. This problem must be thoroughly analyzed and proper
precautions taken to insure that sugar beet production is not
harmed as a result of the operational characteristics of the
Northglenn system.
15. The draft EIS identifies several alternatives concerning the
designation of a management agency or agencies, for the Northglenn
facility. Weld County takes the position that it is the
management agency for those portions of the Northglenn Water
Management Program which are physically located within the unin-
corporated portions of Weld County and thus within the County's
jurisdiction as 208 Management Agency. Northglenn could be
designated as an operating agency for the sewage treatment
facilities but it appears inappropriate to designate Northglenn as
a management agency for the facilities located many miles from
the City when the basic criteria for establishing management
11. Northglenn like any other property owner within Weld County
will be required to control weeds on its property at their
own expense.
12. Northglenn has developed based on an EPA requirement
a proposal to monitor vater quality in the canal and
grounduater. This monitoring program is summarized in
Chapter 5 of the final EIS. Under conditions of an inter-
governmental agreement Weld County could obtain authority for
an independent review of these water quality analysis. EPA
does not have the authority to require Weld County to
review or participate in the monitoring program. Rather
EPA's intention is to provide information and to include
Veld County as a participant in the monitoring program.
If Weld County desires an independent check on water
quality, analysis can be accomplished by allowing part of
the monitoring program to be done by the Weld County Health
Department. As recommended in the proposed intergovernmental
agreement such costs would be refundable by the City of
Northglenn.
13. EPA recognizes that approximately $8500 in taxes could be
lost as a result of the Northglenn plan. EPA will not
require any mitigation of this loss.
14. The City of Northglenn has considered controlling algal
growth with applications of copper sulfate. EPA is con-
cerned that improper application of copper sulfate could
result in concentrations of copper that may be toxic to
crops, particularly sugar beets. EPA recommends that
Northglenn select other operational alternatives which will
reduce algal concentrations and do not require the use of
copper sulfate.
15. It is EPA's position that Northglenn and Weld County should
share management responsibilities and these management
responsibilities shall be defined in the Intergovernmental
Agreement, therefore, EPA will require, as a condition to
the grant, that Northglenn execute an Intergovernmental
Agreement with Weld County.
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Mr. Roger L. Williars
Page 7
February 24, 1980
15
16
agency boundaries under the Larimer-Weld 208 Plan is the
service area of a municipality. Furthermore, the City lacks
the powers necessary as a cianagement agency to control land use
and non-point source pollutions sources outside of the service
area of the City. If the facility is constructed, the
relationship between the two governmental entities, as with
entities within Weld County, should be set forth in an inter-
governmental agreement between the City and Weld County.
16. The issue of the need for the project should have been carefully
considered by the State Water Quality Control Ccrmission during
the process by which Northglenn was assigned its funding priority
points. However, as discussed above, a review of the draft EIS
indicates that the determination of need for the project is based
on Northglenn's perception of the need for an independent
municipal water system and not a need for a wastewater treatment
facility. Given that the need for an independent water supply
is doubtful in light of the City of Thronton's testimony at the
February 13, 1980 public hearing, and the lack of any other
evidence of the need for the project, Weld County respectfully
requests that you hold a public hearing to review the priority
points granted the City of Northglenn by the Water Duality
Control Commission pursuant to 40 C.F.R., Section 35.915(g) and
(h) . This current environmental review process is, of course,
dependant upon the request by the State for .funding for the
Northglenn project. A grant for the Northglenn facility based
upon an invalid analysis of the need for the project would not
be in accordance with the intent of the Clean Water Act and
would do injustice to other communities of this State with a
greater need for Federal assistance in building sewage treatment
works.
This environmental impact statement process will be best served if
these comments and the February 13 hearing are considered as a part of
the scoping process so that a complete and detailed analysis of the
environmental impacts of the Northglenn facility can be prepared.
Within this context, the Board of County Commissioners wishes to thank
you for your continuing attention to the concerns of this Board and
the citizens of Weld County.
Respectfully submitted,
Board of W.eld County Commissioners
C. ff. Kirby/ Chairman
/>^"r->-^^_ ' ' ,f t-j% f
Norman Carlson
Lyaia Dunbar
Leonard Roe
16. With respect to the need for the facility and Thornton's
position that they can independently supply water to the
City of Northglenn, see water supply alternatives analysis
in Chapter 3. EPA has determined that no particular benefit
is gained by holding a separate public hearing on their
decision. EPA will hold a formal public hearing on all
aspects of the project as part of the final EIS process.
-------
Colorado
Department of Local Affairs
Richard D. Ljmm. Gov.mor Paula Hiremark. Eneutin Director
February 25; 1980
Mr. Roger L. Williams
Regional Administrator
Environmental Protection Agency
1860 Lincoln Street
Denver, Colorado 80203
Re: Draft Environmental Impact Statement
Northglenn Water Management Program
Dear Roger:
The Northglenn water management program draft environmental impact state-
ment has been reviewed by State agencies as a major-action project. The
following comments on the project are submitted by the Colorado Department
of Local Affairs, as lead agency for the review, and reflect the collective
views and concerns of affected State departments about the project and the
Draft EIS. Individual State agency comments are also attached for your
consideration.
The Water Quality Control Commission in endorsing the Northglenn water
management program recognized it as a pilot project aimed at several
"innovative" water resources management concepts, namely:
1. A direct provision of an available source of water without the
substantial development of new sources;
2. A sharing or reuse of water between municipal and agricultural
water users; and
3. An application of the land treatment alternative for wastewater
on a relatively large scale.
Each of the above concepts is important and needs to be evaluated as Colorado,
and the Front Range in particular, strives to provide water for expanding
municipalities, while protecting the irrigated agricultural economy so
important to the State and the region, and to improve the quality of water
downstream from our major municipalities.
The State's review of the Draft EIS, however, has raised several key issues
and concerns with the project and the EIS as follows:
RA, CXZA, 1*0, RC.
1313 Swrman Street. Room 518. Denver. Colorado 80203 (303) 839-2771
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Page Two
Roger L. Williams, Regional Administrator
Environmental Protection Agency
February 25, 1980
1. In order to fully evaluate the need for such projects, comparative
information must be provided for evaluating the cost and the
feasibility of alternative methods of providing water supply and
wastewater treatment for Northglenn. This evaluation should
include, among other things, the potential for obtaining water
and waste treatment from neighboring municipalities, increased
importation of water to the area and its overall impacts on water
quality and water use, and finally, the utilization of wells tapping
bedrock aquifers.
2. Several state agencies which reviewed the Draft EIS have questioned
the validity of the document's conclusions as to the overall
impacts of the project on irrigated agriculture. Questions were
raised regarding the net acreage lost or converted from irrigated
to dry cropland. The change in value or net agricultural production
as FRICO lands receive greater water application rates while the
application rates along the South Platte decline was also questioned.
We believe that a more thorough analysis in the EIS is required
prior to formulating conclusions on the impacts on irrigated agri-
culture.
3. Concerns have been expressed by several State departments as to
the appropriateness of expending limited Construction Grant funds,
and indeed other public monies (Northglenn's taxpayers'), when
alternative water sources and wastewater treatment facilities are
available and at perhaps a lesser cost. While we recognize that
the federal share of this project is approximately ten percent of
the total cost, we question whether greater water quality benefits
could be achieved by spending the Grant funds on other wastewater
facility projects in the State.
In conclusion, we believe that the Draft Environmental Impact Statement for
the Northglenn Water Management Program is not adequate for the State or EPA
to fully evaluate the expenditure of Grant funds on a project that is aimed
at demonstrating the utility and effectiveness of integrating water supply
and wastewater treatment into a total water management program. We further
believe that substantial supporting data is missing from the Draft EIS and
must be presented in the Final. This is especially important due to the
potential precedent application of the water management concepts fostered by
this project.
The State will offer technical resources as they might be available and any
data we may have as you consider the various alternatives. Please discuss
RESPONSE:
EPA concurs with these comments and refers the Department
of Local Affairs to the revised alternatives analysis in
Chapter 3.
2.
3.
EPA acknowledges these questions and refers the Department
of Local Affairs to the agricultural analysis which has been
revised.
4.
EPA has not evaluated the Northglenn proposal to determine
whether greater water quality benefits may be achieved by
spending grant funds elsewhere in the State of Colorado.
The analysis of grant funding and eligibility depends upon
whether Northglenn's wastewater treatment facility ±s
eligible under the Clean Water Act. The State Water Quality
Control Commission has determined there are sufficient
priority points to place Northglenn high on that list.
Supplemental information is presented in the final EIS to
adequately evaluate the proposed project. EPA will be
pleased to consult with the Department of Local Affairs upon
your review of this additional information.
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Page Three
Roger L. Williams, Regional Administrator
Environmental Protection Agency
February 25, 1980
these possibilities and your requirements with our lead agency representa-
tive, Mr. Charles Jordan, Division of Planning 839-2351, who will coordinate
, other State agency input into the Final EIS. Finally, because of the
e I significant policy issues surrounding the project, we request that EPA
** I prgituiea 60-day review and comment period on the Final EIS.
5. The Northglenn proposal 1>as been the subject of considerable
analysis during the last two years, therefore, EPA is not
inclined at this time to grant the requested 60 day review
period.
Paula Herzroark, Director
Colorado Department of Local Affairs
PH/ae
v£>
CO
Comments attached from:
Department of Agriculture
Colorado Geological Survey
Division of Water Resources
Office of Energy Conservation
Water Conservation Board
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STATE OF COLORADO
DEPARTMENT OF AGRICULTURE
152S Sherman Street
Denver, Colo/ado 00203
(309) 639-2811
L»mm,
Governor
MEMORANDUM Morg» *«*.
CommnMoner
TO: Clearinghouse
Division of Planning
Agricultural Comtmuton
FROM: Morgai/SMltb \ H™, o,™»».,,.
Commissio' -
Department1 of Agriculture «.i.ta,«n»...
t HofChklM
RE: Draft EIS, Northglenn Water Management Program SH^"°"'
DATE: February 22, 1980 STiSS'
_ Don MoKheni,
CffltfT
While we commend EPA for attempting to analyze an extremely *•»•«•" *et*«™.
complicated issue on relatively short notice, we do not c«~im
believe that this Draft EIS adequately answers or analyzes
key issues pertaining to Northglenn's proposal.
EPA has a policy to protect environmentally significant Ke»r»th wii™>.«.
agricultural land and refers to that policy on Page 26, "
stating as follows:
"EPA has established policy designed to
help protect environmentally significant
agricultural lands (10). The policy is to
protect significant agricultural land from
irreversible conversion to uses which
-result in its loss .as an environmental or
'.essential food production resource."
This is a major undertaking. Protecting environmentally
significant agricultural land is a highly complex and emotional
issue. It is also a new issue about which there exists no
major body of knowledge and successful experience. In addition,
the Northglenn concept is a new one. As a result, this EIS
is a test case for EPA as well as for the water sharing concept
proposed by Northglenn. We have therefore tried to hold EPA
to an extremely high standard as we have reviewed this Draft EIS.
EPA has not met that standard in two respects. EPA has not
evaluated, all alternatives to Northglenn's proposal. EPA's
evaluation of agricultural productivity is not, in our judgment,
adequate.
Our detailed comments are as follows:
FHB 2 5 1S90
DIV. OF
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Page 2 - Memorandum - February 22, 1980
TO: Clearinghouse
Division of Planning
FROM: Morgan Smith
Commissioner
Department of Agriculture
RE: Draft EIS, Northglenn Water Management Program
VO
Ln
2a
Evaluation of Alternatives. The EIS states that Northglenn's
position is that Thornton cannot provide an acceptable
water supply in terms of quantity or quality. Thornton has,
however, indicated that the water quality problem has been
corrected and that they can provide an adequate water supply
for themselves and Northglenn by developing water resources
outside the Denver Metro Area (page 15). This conflict ts
not resolved within the Draft EIS. The Thornton alternative
and its subsequent impacts should be discussed within the
final EIS.
A second alternative is the possibility of some arrangement
with Denver.
A third alternative, which is not fully examined, is the
possibility of transbasin diversions. The EIS states
that this alternative was dismissed on the basis of
salinity and minimum flow concerns. While these are
certainly two issues which must be considered, they must
be weighed against other concerns such as the loss of
irrigated cropland along the front range.
Evaluation of Agricultural Productivity. The conclusion
of the EIS that this project should be supported by EPA
appears to rest to a great extent upon the analysis of
the.agricultural benefits which will result from this
proposed project. This analysis was based on the fact
that productivity under the FRICO System is equal to
$250 per acre-foot of water delivered and the productivity
of the South Platte water is $109 per acre-foot of water
delivered. There are several deficiencies in this analysis.
a. This analysis is based upon water diverted
not consumptive use of the water by crops.
EPA must realize (see page 129 of DRAFT EIS)
that much of the water diverted is returned
to the stream and used downstream by other
irrigators when not utilized by crops during
the first application. This is particularly
true when a full supply of irrigation water
is available as appears to be the case under
the South Platte system, 2.75 acre feet of
water per acre, as opposed to the FRICO system
where land appears to be under irrigated, 1.04
acre-feet per acre of cropland. (Note: This
was calculated by dividing water delivered,
page 149, by irrigated crop acreages, Tables
A-4 and A-5.)
RESPONSE:
1.
EPA refers the Department of Agriculture to the water supply
alternative analysis which has been revised and includes
Thornton, Denver and trans-basin diversion alternatives.
2a.
EPA agrees that agricultural productivity should also be
evaluated ln the context of consumptive use. This analvsis
has beer, conducted and is presented in the revised section
cTar!fvCEPA" Productlvlty °f the final EIS. To further
-------
1. Present Production and field
FRICO
Area irrigated in 1979 (Tables A-3 and A-4) 8.345 acres
Gross value' of production (Table A-4) $2,164,000
Average gross value of production per acre
Water released from Standley Lake (page 149) 14,425 acre feet
Beadgate delivery£60Z of release 8,655 acre feet
Headgate delivery per acre
Gross Value of Production per acre foot of headgate delivery
• Report uses $250.00/AF (page 149)
South Platte
Area irrigated in 1979 in sample area (Table A-5)l,158 acres
Gross value of production (Table A-5) $349.540
Average gross value of production per acre
Headgate deliveries (page 149) 3,192 acre feet
Headgate delivery per acre
Gross Value of Production per acre foot of headgate delivery
3*£f*°- $109.51
Report uses $109 (page 149)
2. Value of Production
FRICO
!>
| The value of production in the FRICO System for lands
VO controlled by FRICO farmers and Northglenn was determined
°* for four options. The calculations for Option 1 in an
average year are shown below.
f Water available to land (Figure 3-2)
Releases from Standley Lake 5,953 AF
FRICO exchange return 6.297 AF
12,250 AF
Headgate delivery at 60Z of release - 7,350 AF
(this value shown in Table 3-5)
Gross Value of Production (7,350) (250) - $1,837,500
(this value shown in Table 3-7)
South Platte
The value of production of the lands taken out of
production in the South Platte was determined for four
options. The calculations for Option 1 in an average
year are shovn below.
Total Augmentation Requirements (Table 3-4) 1,332 acre feet
Total acres to be dried up at a depletion rate of 1 acre
foot/acre 1,332 acres
(Note— this computation is not discussed in the
report but the value of 1,332 acres is shown
in Table 3-6)
Water removed from currently productive land (Table 3-6)
1,260 acres
(The water had been removed from the Reithman
Ditch land prior to 1979 so this was subtracted
from the gross requirement. The depletion study
by Wright indicated a depletion of 72 acre feet
for this area in an average year)
Gross Value of Production f
$109/AF of headgate delivery x 2.76 acre " x
1,260 acres - $379,058
(this value shown in Table 3-7)
-------
Page 3 - Memorandum - February 22, 1980
TO: Clearinghouse
Division of Planning
FROM:
RE:
2b
2c
2d
Morgan Smith
Commissioner
Department of Agriculture
Draft EIS, Northglenn Water Management Program
The EIS also assumes (Table 3-7) that this relation-
ship of $250 per acre-foot of water to $109
productivity per acre-foot of water delivered
remains the same regardless of the amount of water
added or removed on a per acre basis. This is an
incorrect assumption. The marginal value of an
acre-foot of water delivered is not a constant
as the EPA assumes but rather there is a decreased
economic benefit for a second acre-foot of water
as opposed to the benefit derived from the first
acre-foot of water. (See attachment Figure 1).
Because of this, Table A-7 is incorrect and any
decisions based upon this analysis will be misleading.
A comparison of the productivity of the irrigated
FRICO lands and the South Platte lands should be
included in this analysis. An example of pro-
ductivity (Tables A-4 and A-5) is the fact that
it takes 140 acres of land under the FRICO System
to grow the same corn from grain (the major crop
under the FRICO System) as can be grown on 100
acres on the South Platte lands.
An attempt by our department to verify thfe yield
per acre figures displayed in tables A-4 and A-5
was unsuccessful. Personal communication with
the sources listed for this information (Director
of -the Weld County Extension Office and
Lance.Fretwel1, Colorado Agricultural Statistician)
revealed that neither has subcounty yield information,
and neither knowingly provided EPA with such informa-
tion. Our department believes that yields under
the FRICO System may in fact be lower than actually
described due to the lack of adequate irrigation
water. If, however, EPA believes these yields
are correct, it should verify the source of this
information and describe how such subcounty data
was derived.
An analysis of the soils and accompanying maps of
the South Platte lands, which will be taken out
of irrigated production as a result of this project,
are needed. The Important Farmlands Map for
Weld County is presently being published by the
Soil Conservation Service and should assist EPA in
this effort.
2b. EPA recognizes that only marginal benefits are realized
in the application of additional water. EPA considered
the value of adding additional water to the South Platte
system and concludes that the marginal benefits that
could be realized are incrementally small relative to
the additional amount of water available so that no
measureable economic change can be added to the analvsis.
2c. EPA considered doing comparative productivity analysis
for the agricultural- lands involved. However, EPA determined
that it is sufficient to analyze the net economic value of
productivity as a result of water delivered or eliminated
from agricultural lands. EPA's consultant contacted the
Colorado Agricultural 'Extension Service as well as the Soil
Conservation Service in order to secure this information.
Subsequent data sources have been contacted and include
farmers along the South Platte River and Dr. Ray Anderson
who has completed studies of the FRICO system. Based on supple-
mental findings, a revised productivity analysis is incorporated
into the final EIS.
2d. EPA would like to acknowledge receipt of the prime
agricultural land maps and has incorporated them into
the EIS evaluation of agricultural productivity.
-------
'age 4 - Memorandum - February 22, 1980
TO: Clearinghouse
Division of Planning
FROM: Morgan Smith
Commissioner
Department of Agriculture
RE: Draft EIS. Northglenn Water Management Program
VO
00
Production of Vegetables and Sugar Beets. The EIS
states that Northglenn has agreed to purchase any
vegetables grown under the FRICO System which are not
suitable for direct human consumption as a result of
this project. Is this agreement legally binding for
the life of this project?
The EIS also states that high levels of nitrogen may
harm sugar beets if applied after July 15th. EPA
recommends that since nitrogen levels in the water
will be high as a result of this project, proper
management of water applications must occur. However,
in order to produce a crop of sugar beets several
water applications must be applied after the 15th of
July. Mould seven or eight water applications of high
nitrogen water after this date affect the yields or
quality of a sugar beet crop? If it does, will
Northglenn take the responsibility for compensating
agricultural producers for their losses?
Water Conservation. The specific actions which Northglenn
will impose in order to conserve water, and thereby
prevent the loss of water for agricultural use, should
be described in detail in the Final EIS.
We do not intend" these comments 'to be a criticism of Northglenn's
efforts or an indication of opposition to the project. We
believe, however, that additional work must be done by EPA on this
Draft EIS. We would be glad to offer our assistance in that
effort.
3. EPA has determined Northglenn will not be required to control
distribution of raw edible food crops grown under the FRICO
system thus this item is no longer applicable. With respect
to high levels of nitrogen that may harm sugar beets see
the comments of the Great Western Sugar Company. Great Western
Sugar Company indicates that proper application of this
effluent should have no adverse effect upon the sugar beet
crop.
Northglenn intends to dispose of its wastewater effluent by
discharging into the Bull Canal and allowing private use by
individual farmers. It is the responsibility of these farmers
to develop appropriate conservation of their water use and not
the responsibility of the City of Northglenn. Northglenn is
developing a procedure as described in Chapter 5 to implement
water conservation within their community.
MS:wlb
-------
ATTACHMENT
VD
VO
value of
production
froa 2nd
acre-foot
value,of
production
frou 1st
acre-foot
EPA ASSUMPTIONS
1AF
•y.^ value of production
from 2nd acre-foot
value of production
from 1st acre-foot
dryland value of
production
BLANK'S RESULTS
2AF
1AF
2AF
amount of irrigation water
applied to one acre of land
amount of irrigation water
applied to one acre of land
Source: Blank, Herbert. "Optimal Irrigation Decisions with Limited Water"
Ph.D. Thesis, Colorado State University (Civil Engineering). October 1975.
-------
MEMORANDUM
OFFICE OF ENERGY CONSERVATION
1600 Downing Street. 2nd Floor
Denver, Colorado 80218
Phone (303) 839-2507, S3»-21Sfr
DATE: February 11, 1980
TO- Colorado Clearinghouse
FROM-. Office of Energy Conservation
SUBJECT: Northglenn Water Management Program
City of Northglenn, Colorado J80-102
FEB111980
CIV. OF PI4NMIM"
O
O
The Office of Energy Conservation has reviewed the City of Northglenn Water
Management Program and offers the following comments.
This program for integrated sewage treatment and waste water recovery
favorably explores many energy conservation considerations. Northglenn has
taken several positive steps including: initiating a tap management system
which will help to control future patterns of development; discouraging non-
contiguous development; proposing land use and zoning regulations which will
help to mitigate detrimental effects of increased water availability; and a
graduated water rate scale which provides higher fees for higher residential
usage rates. By recycling partially treated water to agricultural uses,
nutrients are returned to the land, redjucing dependence on petroleum-based
fertilizers. This also reduces the demand for energy consumptive treatment
processes.
In new building construction at the treatment site, passive solar energy
systems will be utilized and further energy efficiency will be possible "by
earth-sheltering part of the building. In designing the aerator system,
wind power has been evaluated. Although wind was not considered feasible
for the site at this time, this office encourages continued exploration of
such renewable energy options. ^
Recycling plays an integral role in this program. Some of the existing
Thornton system facilities will be rehabilitated for use by the system, thus
reducing the higher energy demands of new construction.
A population projection of 42,500 for the year 2000 is cited, although the
ultimate population figure is given as 48,000. What additional facilities
will be necessary to provide for this eventual demand? Specific electrical
power requirements for the system were not cited, nor was the power source
mentioned. Can existing power facilities accommodate the Northglenn system's
requirements ?
Several lawsuits affecting the project are still pending. Flexibility should
be built into the program to accommodate any changes possibly to be required
by the courts.
RESPONSE:
EPA acknowledges that Northglenn is to take several positive
steps to conserve energy.
Total power requirements for the facility and the comparison
with Northglenn's pro-rated power requirements with Denver
Metro wastewater facility are presented in Chapter 4.
Northglenn's ability to change water rights by utilizing
water tributary to the South Platte or deep nontributary
wells gives them a flexible system. The ultimate water
sources for their project will depend upon determination
made in the water court.
-------
RICHARD D LAMM
Governor
J. A DANTELSON
Slam Engineer
DIVISION OFWATER RESOURCES
Department of Natural Resources
1313 Sherman Street* Room 816
Denver. Colorado 90203
Administration (303) 839-3581
Ground Water (303) 839-3587
February 13, 1980
MEMORANDUM
TO: MARGIE KAMINSEiT, STATE CLEARINGHOUSE
FROM: HAL D. SIMPSON, CHIEF, WATER MANAGEMENT BRANCH
SUBJECT: NORTHGLENN WATER MANAGEMENT PLAN - DRAFT E2S
I This is to acknowledge receipt of the above referenced document which
evaluates the environmental impacts of the Northglenn plan. We have
carefully reviewed the report and believe that It adequately discusses
I the water resource related impacts and issues of the proposed plan.
The issues related to such factors as augmenting South Platte River deple-
tions resulting from transfer of wastewater from the Thornton enclave (835
acre-feet per year) to the Bull Canal, augmenting the South Platte River
for sewer system infiltration (300 acre-feet per year) which will be trans-
ferred to the Bull Canal, and other Issues as set forth on pages 32 and 33
will be decided by the Water Court when the plan for augmentation and
applications for change in water rights are heard by the Court. It is
possible that Northglenn would be required to obtain additional water
resources to provide augmentation water for these depletions.
The use of non-tributary ground water as a source of water which would reduce
the amount borrowed from FRICO is also subject to a decision by the District
Water Court since Northglenn has appealed the denial of the well permits by
this office. If the Court upholds the denial, then Northglenn would ba
required to utilize the South Platte River water rights it has acquired in order
to augment the well field depletions.
The measures required to prevent ground water seepage and contamination
appear adequate if properly Inspected. This office would be willing to aid
FEE
DIV.
RESPONSE:
1. EPA acknowledges that the State Division of Water
Resources finds the draft EIS adequate to discuss
vater resource-related impacts and issues of the
plan.
-------
O
NS
Margie Kaminsky Page 2
February 13, 1980
in the Inspection of the cut-off key for the earth embankment to determine
if fault traces cat across the reservoir.
_. .
Hal D. Simpson
HDS:mvf
cc: Jim Clark, Div. Eng.
BUI McDonald
-------
RICHARD D LAMM
GOVCMNOM
JOHN W. HOLD
Dir
COLORADO GEOLOGICAL SURVEY
DEPARTMENT OF NATURAL RESOURCES
715 STATE CENTENNIAL BUILDING - 1313 SHERMAN STREET
DENVER. COLORADO 80203 PHONE (303) 839-2811
February 1, 1980
Mr. S. 0. Ellis
Colorado Clearinghouse
Colorado Division of Planning
1313 Sherman Street
Denver, CO 80203
Dear Mr. Ellis:
RE: NORTHGLENN WATER MANAGEMENT PLAN EIS
o
u>
We have received and reviewed this I.I.S. In most respects geology
has little direct bearing on this project. The respects that do
(water quality and availability) are regulated by other agencies -or
local jurisdictions. If, in the construction phases of this project,
engineering-geologic data and/or advice are needed, then the C.G.S.
is available to offer limited assistance.
Sincerely,
RESPONSE:
Acknowledge.
4-
Jafnes M.
es M. Soule
engineering Geologist
JMS/gp
cc: Land Use Commission
FEB
i960
GEOLOGY
STOBY OF THE PAST ... KE» TO THE FUTURE
-------
BtNJAr-IN F.STAPLE-TON
Chairman, Danw
FREDERICK V. KROEGER
Vica-Chairman. Durango
JOHN R. FETCHER
Siaamboal Spring*
C. M. FURN6AUX
Waldan
FLOYD L.CETZ
Moma Vina
PATRICK A. GORMLEY
Grand Junction
ROBERT A. JACKSON
Poablo
DAVID LEINSOORF
CrMiad Buna
HERBERT H.VANOEMOER
Stafling
j WILLIAM MCDONALD
Di'actOf
LAREN D. MORRILL
Dapucv Diraetor
RICHARD D. LAMM
Gownof
DEPARTMENT OF NATURAL RESOURCES
COLORADO WATER CONSERVATION BOARD
823 STATE CENTENNIAL BUILDING
1313 SHERMAN STREET
DENVER. COLORADO 80203
February 15, 1980
MEMORANDUM
TELEPHONE
1303) 839 3*41
o
J>
TO: Colorado Clearinghouse
Division of Planning
FROM: Daniel L. Law
Water Resource Specialist
THROUGH: Bill McDonald, Director
RE- Northglenn Water Management Plan
Draft Environmental Impact Statement
S80-102
The Colorado V7ater Conservation Board supports the con-
"
RESPONSE:
so long as surface water is used by Northglenn.
The Board has the following comments on the Draft Environ-
mental Impact Statement :
'
production or changed to ^^"V^^nd in the B^
- . i „ A nn af-r-e*ci nf irriciated f armlana in tne eig
SH
EPA acknowledges the net reduction in irrigated acreage will
occur as a result of withdrawal of surface waters in the
South Platte River. The withdrawal of surface waters is
necessitated by Northglenn's self-imposed requirement to
replace water that, would be exchanged with the Farmers
Reservoir and Irrigation Company (FEUCO). EPA's agricultural
analysis compares the consequences of a successful condem-
nation of FRICO water to the proposed Northglenn-FRICO
exchange to determine which will maintain the highest agri-
culture production. The result of the analysis is that
less irrigated acreage would be taken out of the production
with the exchange than would occur if condemnation were
successful.
EPA acknowledges that up to eighteen hundred acres could be
converted from irrigated farming to dry land farming. It is
possible that no increase in irrigated acreage would result
from this exchange. However, FRICO farmers have the option
to either expand their acreage or to increase the &-nount of
water applied on their existing irrigated land.
-------
Colorado Clearinghouse
February 15, 1980
Page two
o
Ul
6
for the FRICO system.
2. The net benefits for the FRICO system are stated in the
report at $250 per acre-foot of water delivered at the
headgate, while on the South Platte it was stated to be
$109 per acre-foot. These figures are based on 1979
statistics. Such a substantial difference is question-
able. While these results were based on headgate quan-
tities, the consumptive use of water for the various
crops should not differ by more than a few percent. Much
of the water applied on the South Platte lands runs off
to supplement other irrigator's supplies or recharges
the groundwater table. It would be more desirable to
determine the net benefits from a 5 year period using the
consumptive use values and from areas of comparable size
(Net benefits were computed on a basis of FRICO-10,000
acres and South Platte-1000 acres). In addition, the
tailwater recovery and groundwater recharge systems of
the South Platte area should be analyzed to see how
many additional acres are irrigated from the original
diversion.
3. The utilization of 885 acre-feet of water from Thornton's
enclave along with the 300 acre-feet from sewer infiltra-
tion in tBe augmentation figures seems optimistic. If
these sources were denied by the courts, a substantial
amount of irrigated land in addition to the 1800 acres
specified above, would have to be taken out of production
to meet this increased need.
4. The paragraph on page 8 itemizing annual net benefits
($1,180,000 vs. -$460,000) is misleading. For one thing,
the net benefits are stated in terms of a dry year, while
the values were calculated using 1979 statistics, which
was not a dry year.
Further, the comparison is made identifying the augmenta-
tion process versus the condemnation process, but no net
benefit was given to the status quo alternative. It would
appear that the net benefit would be negative when compared
to the status quo since up to 1800 acres of irrigated farm-
land would be taken out of production and no new land
added. Although a more reliable system is established for
3. The agricultural productivity analysis has been revised
include a comparison of productivities using crop consumptive
use values. See response to Department of Agriculture.
4. EPA recognizes that if the court denies the utilization of the
300 acre feet which comes from sewer infiltration Northglenn
will have to obtain makeup water from some other source.
That source could either be Irrigated agriculture or,
alternatively, nontributary deep wells.
5. The intent of the comparison of net annual agriculture benefits is t«
indicate the range of benefits that might result from the North-
glenn plan. It is acknowledged that these statistics were
determined using 1979 values. These values were then applied to
the amount of water delivered through the system during the
dry year.
6. As Northglenn has entered into various agreements and
intends to complete its plan with or without federal
money, the execution of the proposed plan can be
considered the status quo alternative. The results
of the agricultural productivity analysis indicate
the condennation of this water has less agricultural
benefits than the status quo.
-------
Colorado Clearinghouse
February 15, 1980
Page three
FRICO and also a higher yield per share would result,
the net benefits per acre-foot would more than likely
decrease since the crop yields would not necessarily
increase in proportion to the additional water available.
It is imperative that these analytical errors be corrected in
order to provide accurate information prior to a final decision on
the alternatives.
tp. DLL:pm
M
O
-------
STATE Of COLORADO
Richard D. Lamm. Gevemer
DEPARTMENT OF NATURAL RESOURCES
DIVISION OF WILDLIFE
Jack R Grieb, Director
6060 Broadway
Denver. Colorado 80216 (625-1192)
FROM:
February 21, 1980
Stephen 0. Ellis
Colorado Clearinghouse
C. J. Grand ?_
Sr. Wildlife Biologist
SUBJ: Northglenn Water Management Plan
We have reviewed the above-cited proposal and find it to be inadequate.
There are several items that need further consideration.
In conversation with the City of Northglenn we find that the City is
aware that certain losses of wildlife and wildlife habitats will occur
as a result of developing their proposed sewage plant. In addition,
we find that the City has proposed an extensive waterfowl development,
open space and revegetation project as mitigation for those losses.
Wildlife is an extremely important natural resource. We feel it im-
perative that impacts upon wildlife, wildlife habitats, and measures
to mitigate those impacts be reaffirmed and addressed in the environ-
mental impact statement.
RESPONSE:
/d
cc:
EPA
Bept. of Health
OSF & US,SIX
NE Region
File (2)
EPA did not evaluate the possible impacts to wildlife
and wildlife habitat because no significant impact could be
determined. The City of Northglenn is proposing extensive
open space programs which would include its Stonehocker Reservoir
development plan. However, the Stonehocker Reservoir is an
independent recreational development by the City of Northglenn
and is not part of this proposal. The City proposes to re-
vegetate the project site which would include replacement with
trees, shrubs, and grasses. The City had proposed an island
be constructed within the wastewater storage reservoir. This
proposed island, which may be attractive to water fowl, creates
the potential of encouraging additional coliform contribution
to the reservoir. This complicates the monitoring of pathogenic
indicators in the effluent. This Island has been eliminated
from the reservoir. It is likely that wildlife benefits
will be realized through the construction of the proposed
Grange Hall Creek stormwater runoff detention pond which
will provide some level of aquatic and wetlands habitat.
DEPARTMENT OF NATURAL RESOURCES, Harm Sherman, Ejiaculive Director • WILDLIFE COMMISSION, Michael Higbee, Chairman
Wilbur Redden, Vice Chairman • Sam Caudill. Secretary • Jean K. Tool. Member • Vemon C Williemi. Member
Jamet Smith, Member • Donald Fernandez, Member • Richard Diveibru, Member
-------
February 25, 1980
o
oo
Mr. Roger Williams, Administrator
Region VIII
U.S. Environmental Protection Agency
1860 Lincoln Street
Denver, CO 80295
RE: Comments on EIS/Northglenn Water Management Program
Dear Mr. Williams:
The following comments are in response to the Northglenn Draft EIS.
The innovative and alternative provisions of the Clean Water Act
of 1977 emphasize the planning, design and construction of cost
effective municipal treatment works that maximize the recycling
and reclamation of water and nutrients while minimizing energy
use and adverse environmental and public health impacts. So,
elimination of risks is neither expected under PL-95-217, nor is
it practicable because they are inherent in any emerging technology.
The Northglenn project has several features which are specifically
aimed at reducing these risks to an acceptable level and certainly
reduce risk levels below existing sewage treatment plants in the
Denver area.
The question of public health risks are greatly distorted because
of attitudinal differences in terms of certain selected psychologi-
cal dimensions: (1) Fear of contact with impure or dangerous
substances; (2) Progressive versus traditional stance; and,
(3) Revulsion to body waste tendency. Given the complexities
involved in setting tolerance levels for specific contaminants
that might appear in a renovated water, such an approach might
take a long time to develop and even in that case EPA might be
faulted for not covering all possible effects.
A complementary and perhaps more productive approach would be to
conduct a rigorous analysis based on state of the art, which EPA
has amply demonstrated in its assessment. Also, this author is
cognizant of the fact that reclaimed water for second order uses,
when designed properly, will in all probability provide a better
product than that used in a number of public water supply systems,
particularly those with inadvertent reuse in the South Platte Basin.
Re-
FEB27 1980 !. :!
'. T -.1
RESPONSE:
EPA acknowledges these views by the City of Northglenn -
the topics of public health risk, options of reuse within
the semi-arid west, utilization of irrigation canals and
domestic water source and the public attitudes on public
health concerns are addressed in the final EIS.
-------
Mr. Roger Williams, Administrator
February 25, 1980
Page 2 "
There must be a breakthrough in the sacrosanct status of a single
grade water for the wide discrepancy of urban and rural uses.
Utilization of a hierarchy of water supply would, by allocating
reclaimed water to the lower order needs that constitute the bulk
of demand, release the potable water supply for future expansion.
Sections 201 and 208 of PL 92-500 which call for Facility and
Areawide Wastewater Management Planning, provides an unparralled
opportunity which was obviously utilized in the Northglenn project.
But unless federal leadership is forthcoming, it is unlikely that
extensive use of. these provisions for a multifaceted approach to
water supply and water quality planning will receive more than
polite attention.
Environmental demands on water management systems heightened the
perception of utility of wastewater reclamation, which should be
exploited by the agency. I believe that in the semiarid western
states, where water purveyors are mulling over appropriation
doctrines and a myriad of state and federal laws'," EPA has a unique
responsibility to encourage water supply - wastewater treatment
coordination and better management of water resources. When the
sources of supplies are restricted, traditional demarcations
between water supply augmentation and pollution abatement become
invisible. Conjunctive use of surface and ground water supplies
and storage water supplies and storage capacity should be encouraged
to maximize yield and improve water quality.
If the Qnited States, as a nation, is to develop a technology in
anticipation of eventual potable use of renovated wastewater,
indirect or successive use as contemplated in the Northglenn project
must be encouraged and fully developed first. The impetus for
innovation for re-use will come chiefly from the technical-managerial
community, based on accumraulated experience provided by indirect
recycling of water use with new technological systems. Equally
obvious are the potential contributions to the field of re-use in
the areas of costs, management techniques and the level of public
acceptance.
In the light of Safe Drinking Water Act requirements on trihalo-
methanes and synthetic organics, it is highly questionable whether
irrigation canals can be a viable source of drinking water supplies.
Because of non-point source pollution from return flows, it is quite
possible that these sources would require adsorption technologies
in water treatment. Removal costs of nitrates due to sewage
effluent would be relatively minor compared to the extremely high
cost of the adsorption technology.
Accustomed to an orderly administration process of water supply
augmentation, the farmers and other interests suddenly found
themselves squarely in the middle of heated battles which frequently
turned on issues ranging from heavy metals to viruses. For its
-------
Mr. Roger Williams, Administrator
February 25, 1930
Page 3
part, the public often appears content to delegate decision making
power to professionals and specialists. And there is evidence that
conservative attitudes of public health concerns are in conflict
with beneficial effects of alternative technologies. What is
needed is quick, and effectual attention to the relevant issues and
swift decisions to clear up the trivial issues.
The author firmly believes that the Northglenn project deserves
the grant award and prompt action by EPA, to provide an impetus
for innovative and alternative technologies enunciated in the Clean
Water Act, for the following reasons:
a) The project provides a framework for the utilization
of greatest net long-term benefit for agriculture
and other community interests .
b) The project stresses the need for utilizing existing
water resources to the maximum before new sources
are developed.
c) The plan maximizes beneficial uses, the main ingredient
of the appropriation doctrine. Also, it utilizes
optimum allocation techniques and process for water
conservation .
d) The plan enhances in-stream uses in the South Platte
River, by meeting the zero discharge of pollutants
goal of PL 92-500 ahead of the 1985 schedule.
I feel it is high time that the EPA saves time and money by con-
cluding the EIS process as soon as possible and making a grant
offer to the City of Northglenn.
Yours very truly,
Tom Ambalam
Professional Engineer
8150 W. 81st PI.
Arvada, CO 80005
-------
Denver Regional
Council of
Governments
February 25,1980
Roger L. Williams
Regional Administrator
United States Environmental Protection Agency
1860 Lincoln Street
Denver, Colorado 80295
Re: EIS/002-80, Northglenn Water Management Program
Dear Mr. Williams:
The Denver Regional Council of Governments has reviewed the above captioned proposal
for its consistency with adopted regional plans, policies, and review criteria. This proposal
relates to the Regional Growth and Development Plan ( RGDP), which establishes policies
to guide decisions affecting regional development, the Clean Water Plan (CWP), which
provides the basis for the sizing, staging, location, and treatment levels of future waste-
water facilities and the determination of institutional arrangements for wastewater
planning and management, and the Regional Water Study.
The project proposed by Northglenn is intended to provide water and wastewater service
to defined urban service areas which is consistent with the Regional Growth and Develop-
ment Plan. According to regional policy: "Regional systems and the full range of urban
service should be provied only within Urban Service Areas; local or community services
should be provided in Mountain Development areas and Rural Town Centers, and only
limited county and rural services should be provided in non-urban areas."
The project is consistent with the Clean Water Plan. The principal of agricultural reuse
of wastewater embodied by the Northglenn project is encouraged by DRCOG's Clean
Water Plan and the Regional Water Study. The Northglenn project proposal was in the
formative stages at the same time that the 208 plan was being developed, thus it was
not included in the plan as it was originally adopted by DRCOG. The plan has been
amended, however, to designate Northglenn as a Management Agency to carry out this
project.
The project is consistent with these regional plans and should be recognized as an innovative
approach towards solving both the problems of improving water quality and developing
alternative water supply sources within the Denver Metropolitan Region. DRCOG urges
quick and favorable action on the recommendation contained in the BIS.
If you nave any question, please contact our review coordinator, Linda Nuzum.
Sin
RESPONSE:
. Farley
b Executive Director
RDF/bjs
cc: The Hon. Fred Tapia, Councilman, Northglenn COG Representative
EPA recognizes that the project is consistent with
the Denver Regional Council of Governments Clean
Kater Plan. The designation of Northglenn as a
management agency within the DRCOG area, however
does not resolve the question of sharing the
management responsibility with Weld County.
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City of
Thornton
8992 N Wasnmg-on Sires-
'icrr'on Coioraoo 80229
303,289580'
February 25, 1980
r FEB26 1980
L'_EPA sto:
Mr. Roger L. Williams,
Regional Administrator
U. S. Environmental Protection Agency
Region VIII
1860 Lincoln Street
Denver, Colorado 80295
Dear Mr. Williams:
As part of the public comment process, the Thornton Utilities
Board and City Council recently sent you a letter regarding
their impressions of the Northglenn Environmental Impact
Statement for the proposed water management program. The
Utilities Board directed staff to further study the document
and offer comments on the facts presented. Herewith follow
the Utilities Department staff comments:
A.
B.
vi^-
Page 3 refers to Thornton's water supply as having
had concentrations of nitrite that exceed the
National Drinking Water Standard. We would like
to note that the nitrite problem in the distri-
bution system occurred in 1977, after Northglenn
began planning its own utilities system. Addi-
tionally, there is not a National Drinking Water
Standard for nitrite. This non-existent Standard
is also referred to on page 15.
Page 15 refers to 10,000 connections to the water
and sewer system in the City of Northglenn. Our
records show a total of 7,777 connections (7,434
residential; 315 commercial; and 28 multi-family).
Page 30. A paragraph on this page refers to
injury to owners of mutual ditch company shares
that might result with the implementation of the
Northglenn Augmentation Plan. Thornton has filed
its objections to this plan in water court.
RESPONSE:
2.
EPA recognizes Thornton has corrected its problem
regarding nitrite and nitrate contamination. While
there is no nitrite standard within the National
Interim Primary Drinking Water Standards, there is
a recommendation that nitrite concentrations not
exceed 1 milligram per liter.
The reference to 10,000 connections within the City of Northglenn
vas provided by Northglenn's consultants. EPA acknowledges
that your records indicate 7,777 connections as of this date.
^acknowledges that Thornton is an objector in the Water
, 5eA,
e C 7 cf °'arnea Proc'ess
-------
Mr. Roger L. Williams
February 25, 1980
Page 2
i. Page 30 states that Thornton receives all of its
water from the South Platte Tributary well field
Thornton has historically diverted substantial
amounts of water from Upper Clear Creek Ditches
which are the main supply for our Thornton and
Western Hills Water Treatment Plants. We have
recently began developing water rights on Lower
Clear Creek ditches and direct flow rights on the
South Platte River. Presently, the wells make up
approximately one-third of Thornton's total water
supply, although at certain times of the year
almost 100 percent of the water in the treatment
system comes from the wells. This supply is being
evaluated as part of an ongoing study of South
Platte River alternatives by CH2M Hill.
E. Page 30 also refers to the 885 acre-feet per year
of replacement water. Enclosed is a page copied
from Volume II of the Severance Analysis completed
by URS Company. This report indicates that 228 acre-
teet will actually be required for replacement
water. v
F. Page 45. The first paragraph states that one
objective of the Northglenn water management
program is to guarantee an adequate water supply
for Northglenn 's future population. As was previ-
ously stated in the letter sent to you by the
Utilities Board and City Council, Thornton's
service presently is adequate and will be for all
future residents of Northglenn.
G. Page 51. Benefit 1 refers to improved water
supply. Once again, our service is adequate and
meets all State and Federal requirements.
2' The first paragraph states that the City
Thornton is to pay the Farmer's Reservoir and
Irrigation Company the sum of $3,000,000 to line
the Bull Canal system and laterals. Thornton
c?frnS/,tSS;year Period. wil1 Pay FRICO over '
516 000,000 for storage. FRICO has chosen to
utilize some of these funds for the previously-
mentioned lining project. Thornton is not in any
EPA understands that the present source of Thornton's
water supply includes contributions from both upper
Clear Creek ditches and South Platte tributary wells.
5. Northglenn's 885 acre-feet of replacement water was developed
by their consultants. If the 885 acre-feet of replacement
water as stated, is not totally available additional replace-
ment water will be required from the stornwater runoff-Grange
Hall Creek or the tributary well field. If either of the
alternative sources of replacement water are utilized then
the water must be augmented.
6. See previous response to Thornton's letter dated
January 31, 1980, with respect to Thornton's ability
to supply Northglenn with adequate water supply in
the future. Also see Thornton's letter of May 1,
1980, regarding their desire not to analyze the
alternative of providing water to Northglenn at this
time.
EPA recognizes that Thornton is not directly involved
in the lining project nor is the City of Northglenn.
The lining of the Bull Canal by the Farmers Reservoir
and Irrigation Company is an independent, private
action.
-------
Mr. Roger L. Williams
February 25. 1980
Page 3
7l
manner directly involved in any lining project at
this time.
II. The Four -Way Agreement, beginning on page 181, is
not the final version negotiated with FRICO.
There are several minor changes in paragraph 26 . 8- Acknowledge.
Enclosed is a copy of the final revised agreement.
Cary. Palmer, P.E.
Utilities Director
CRP/WEK:ac
Enclosures
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CITY OF NORTHGLENN
10701 Melody Dr., Suite 313
Northglenn. Colorado 80234
Phone (303) 451-8326
February 25, 1980
Mr. Weston Wilson
Environmental Evaluation Branch
U.S. Environmental Protection Agency
Region VIII
1860 Lincoln Street
Denver, CO 80295
Re: City of Northglenn Comments on Draft Environmental
Impact Statement On The Northglenn Wastewater Treatment
Facilities Plan (EPA-908/5-79-002A)
Dear Mr. Wilson:
We have reviewed the Draft Environmental Impact Statement
("DEIS") and provide the following comments and recommenda-
tions which, together with the City's comments on the Pre-
liminary Environmental Report (Attachment C), we request
be made part of the record of public review on the DEIS>.
We agree with the fundamental conclusions of the DEIS,
in which the Northgle-rm Facilities Plan is found to have
environmental benefits that outweigh all possible negative
effects and is found to be eligible for a construction grant
under Title II of the Clean Water Act. We do have, however,
the following specific comments on the DEIS:
1. Scope of EPA's Consideration of Alternatives:
pp. 5, .45-8?
The DEIS contains a detailed discussion of various
alternatives available to the City to provide its citizens
with a source of municipal water supply. At the public hearing
on the DEIS, a number of commenters criticized EPA for not
considering an even broader range of water suoply alternatives.
The City has applied to EPA for a construction grant
to assist in the construction of a sewage-treatment facility
using agricultural reuse of the effluent in lieu or discharge
to waters of the United States. In preparing an EIS on the
Northelenn grant application, EPA's NEPA regulations in
40 C.F.R. Part 6 provide for evaluation of the reasonable
alternatives to the proposal for which the grant assistance
is sought — namely, a sewage treatment facility.
RESPONSE:
1. The National Environmental Policy Act requires that all
federal agencies evaluate alternatives available within
its federal jurisdiction as well as alternatives beyond
its jurisdiction. Since the wastewater treatment
facilities to be constructed by the City of Northglenn
are part of a water supply system, EPA determined
that it was necessary, in order to comply with NEPA
regulations, to fully evaluate those alternatives for
both a vater supply system and a wastewater treatment
system. Further, the mechanism for funding Northglenn's
proposed wastewater treatment system is defined by
the multi-purpose cost-effective analysis which requires
analyzing both wastewater and agricultural r.euse elements.
Northglenn's proposal includes both wastewater treatment
and agricultural reuse, therefore, it is dependent upon
EPA to consider alternatives for both such actions.
KORTH61EIIH I FRICO U»0 «NO WATER RESOURCES M»M6E«EIIT PROJECT
-------
Mr. Weston Wilson
February 25, 1980
Page two
It is beyond the scope of EPA's review under NEPA for
EPA to consider alternatives to the City's plan to supply
water to its citizens, in the context of an application
tor a sewage treatment construction grant. EPA's regulations
in 40 C.F.R. Section 6.507(c) (5)(i)-(vili) list the categories
of alternatives that are to be evaluated in the environmental
review of a facilities plan. Nowhere do the regulations
provide for the consideration of water supply alternatives.
The fact that the City has had the foresight to coordinate
its water supply, water treatment, and wastewater treatment
and disposal functions by means of a comprehensive plan
has absolutely no bearing on the scope of EPA's environmental
review under NEPA. NEPA requires that agencies consider
the environmental effects of their proposed actions and
of alternatives to their proposed actions — it does not
require nor authorize the agency to condition a Section
201(j) construction grant on an analysis of a city's water
supply plan. It does not require the agency to evaluate
projects and their alternatives, which are funded entirely
through local funds. See Friends of the Earth v..Coleman,
518 F. 2d 323, 8 EEC T5T7 (9th Cir. 19/i). To do so is an
unwarranted intrusion into local decision-making and is
unreasonably burdensome to applicants seeking to implement
the agricultural reuse goals of the Clean Water Act.
To require cities seeking construction grant funds
for agricultural reuse to provide a comprehensive analysis
of all water supply alternatives available to them — in
addition to the normal information required for the grant
application — is to sound the death knoll for agricultural
exchange and reuse in the western states. The costs of ob-
taining the grant will simply outweigh the benefits of the
grant. This is a direct contravention of Congress' intent
to promote agricultural reuse of wastewater expressed in
Sections 201(g), 201 M) and 304(d)(3) of the Clean Water
Act.
The City has attempted to provide EPA with all requested
information concerning every aspect of its comprehensive
water management plan. It has done this in order to keep
EPA informed about the entire Northglenn water management
plan. The City will continue to provide to EPA whatever
information is within its control, but Northglenn vigorously
objects to the expansion of EPA's environmental review to
include consideration of the City's water supply alternatives
in the environmental impact statement.
-------
Mr. Western Wilson
February 25, 1980
Page three
2. Need-for.the Wastewater-Treatment.Facility: pp. 15-16
EPA states in the draft that the need for the City's
wastewater treatment facility is "in effect. . . entirely
a function of the water supply and exchange program". This
statement is incorrect and reflects a basic misunderstanding
of the City's water management plan and the City's role
as a home rule city and wastewater management agency.
The type of treatment system chosen by the City is,
to an extent, a function of the method selected to provide
the City with a reliable and economical water supply —
water sharing with the FRICO farmers. To make the water
sharing arrangement functional, the City has designed the
wastewater treatment facility to be complementary to the
exchange. It has been designed to allow the City to perform
its obligations under the exchange agreement with FRICO.
The need for a wastewater treatment facility to treat
wastes generated in the Northglenn 'service area, however,
is not a function of the water supply arrangement. Northglenn
is a home rule city under the Colorado Constitution, and
is a designated wastewater management agency under the Denver
Regional Council of Governments Section 208 water quality
management plan. As such, it is responsible for providing
wastewater treatment to its citizens under both state municipal
law and the federal/state water quality management program
under the Clean Water Act.
Prior to its designation as a wastewater management
agency and its severance from the City of Thornton utilities
system, the responsibility for treatment of the Northglenn
wastewater was left to the City of Thornton. Thornton, in
turn, is a member of the Metro Denver district and thus
entitled to send its wastewater to Metro Denver. Upon desig-
nation as the wastewater management agency for its area,
Northglenn has proceeded to perform its responsibilities
by severing from the Thornton utilities system. Northglenn
is not a member of the Metro Denver district.
The need for wastewater treatment is a function of
the generation of 4.6 MGD of wastewater by the City of North-
glenn inhabitants. The only question is the type of treatment
system to be used — a decision for which Northglenn as
the management agency has been delegated responsibility.
Northglenn has determined that the proposed wastewater treatment
facility in Weld County is the most efficient alternative
- from both an economic and environmental standpoint. This
RESPONSE:
While the impact statement does say that the need for the
facility is entirely the function of the water supply system,
EPA recognizes that the type of treatment system chosen by
the City is a function of the need to exchange water with the
Farmers Reservoir and Irrigation Company. Additionally, the
need for the facility is, as Northglenn indicates, based on
the need to treat wastewaters. Northglenn's grant eligibility
under the EPA-administered Wastewater Construction Grants
Program is a function of the costs associated with treating
the wastewater general ed within the community. The grant
determination for the proposal, as previously mentioned, is
a function of that need.
-------
Mr. WesEon Wilson
February 25, 1980
Page four
oo
determination was made after consideration of a number of
factors and alternatives — including the costs of seeking
membership in the Metro Denver system. Subseauent to approval
by DRCOG and the Governor, Northglenn's decision was approved
by the State Water Quality Control Commission in April 3,
1979 when the Commission found that the facility was needed
and the proposed site appropriate.
In short, the need for the Northglenn wastewater treatment
facility is a function of the wastewater treatment needs
of the Northglenn citizens — not the water supply needs
of the City. As reason would dictate, the wastewater treatment
facility has been designed to be complementary with the
water supply method chosen by the City — but it is not
merely a creature of the water exchange arrangement.
ug
16 of the DEIS be revised to read:
Northglenn's wastewater treatment need
is a function of its responsibilities as
a home rule city and a wastewater management
agency under the DRCOG Section 208 plan to
provide treatment for 4.6 MGD of wastewater
generated within its management area. The
proposed treatment facility is designed to
meet this need while at the same time making
possible the Northglenn water exchange agree-
ment with the FRICO farmers.
3. Description.of the-Northglenn-Plan: p. 3
Although the City of Thornton is currently providing
a water supply and wastewater treatment to Northglenn, its
contractual obligation to continue this service expires
on November 1, 1983 under the terms of the Northglenn/Thomton
Severance Agreement (May, 1979). The "status quo" alternative,
therefore, is not simply continued utilities service from
Thornton — since there is no agreement to provide service
beyond November 1, 1983. The "status quo" alternative is
no wastewater treatment or water supply after November 1,
1983. An alternative to the proposed Northglenn wastewater
treatment tacility is for Northglenn to attempt to negotiate
a long term, service contract with Thornton to provide wastewater
treatment via Metro Denver. An alternative to the Northglenn
water supply agreement with FRICO is to attempt to negotiate
a water supply contract with Thornton for a reliable source
of supply. These are not, however, "status quo" alternatives.
3. EPA recognizes that even without a federal grant
Northglenn would likely construct these facilities at its
expense. Failure to implement the FRICO exchange agreement
would require a change in the severance agreement with the
City of Thornton.
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Mr. WesCon Wilson
February 25, 1980
Page five
4.
Treacmenc of Northglenn WastewaCer ac Meero Denver:
P- *
Paragraph 3 on page 4 of Che DEIS scaces ehae Northglenn
wascewacer presently is conveyed by Thornton to Metro Denver
for treatment. While this statement is correct, it is misleading.
As discussed above, Northglenn is not a member of the Metro
District and has been prevented in the past from participating
in elections for the approval of financing improvements
at Che Metro Denver Central Plant. Northglenn is provided
service at Metro Denver only because it has a short term
service contract with Thornton, which will expire in 1983.
It is also necessary, commencing immediately, for Metro
Denver to expand and upgrade its service if it is to provide
service to Northglenn and other customers in the future.
These facts should be made clear early in the DEIS so that
the public will not be mislead concerning the status quo
of wastewater services for the City of Northglenn. We have
submitted to EPA detailed documentation concerning the Metro
Denver alternative, and are prepared to provide further
information if requested.
We suggest, therefore, that paragraph 3 on page 4 be
revised as follows:
Presently Northglenn's wastewater is
conveyed by the Thornton system and treated
at the Denver MeCropolitan Sewer District
No. 1 (Denver Metro). Northglenn's service
contract with Thornton tor this wastewater
treatment, however, will expire in 1983.
Northglenn is not presently a member oi the
Metro Disrict. Consequently, Northgienn has
submitted a taciiicies plan to EPA to treat
its own wastewater. Norchglenn's revised
tacilicy plan makes the following recommen-
dations for wastewater transport, treatment,
and disposal:
5. Description of the Water Supply Options: p. 5
As discussed above, Northglenn objects to the consideration
of alternative water supply options as part of EPA's NEPA review
of Northglenn's wascewacer creatment facilities plan. For the
sake of accuracy, however, Northglenn would like to comment on
the DEIS list of water supply options on page 5. Since the mid
1970s, Northglenn has studied a wide range of water supply as
4. EPA acknowledges that Northglenn's service contract with
Thornton for its wastewater treatment will expire in 1983.
Northglenn presently receives wastewater treatment by the
Denver Metro District by way of contract with the City of
Thornton. However, Northglenn is not a member of the Denver
Metro District.
The water supply alternative section has been revised to
include a cost and impact analysis of several water supply
options available to the City of Northglenn. See water supply
alternative section in Chapter 3. In addition the alternative
site analysis has been expanded which considers three optional
sites south of Northglenn's proposed site.
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Mr. Western Wilson
February 25, 1980
Page six
S3
O
well as wastewacer treatment options. While the DEIS identifies
four of the water supply options, we would like the record to
show that Northglenn, in fact, considered an even wider range
of options. The water supply options included: •
(1) Long-term Thornton Service Contract
(2) Denver Water Board
(3) New Transmountain Diversions
(4) 176 Well Field
(5) Non-tributary Wells
(6) Boxelder Creek Agricultural Reuse
(7) Colorado Big Thompson Project
(8) Condemnation or Purchase East Slope Agricultural Supplies
(9) FRICO Agricultural Reuse
A number of these water supply options were rejected after
a threshold determination that they would be too costly — from
either or both economic and environmental standpoints. Others
were analyzed in greater detail and rejected on the same grounds.
Northglenn also considered a wide range of alternative waste-
water treatment options. These included:
(1) 13 Options for Treatment at Metro Denver Central Plant
(Lower South Platte Facility Plan)
(2) 8 Optfons for Agricultural Reuse with FRICO (Lower
South Platte Facility Plan and Northglenn Agricultural Reuse
Facility Plan)
(3) 4 Options for Agricultural Reuse in the Boulder Creek
Basin
(4) 10 Alternative Sites for Implementation of FRICO Agri-
cultural Reuse
Northglenn has provided EPA with data on alternative treatment
system options as part of the City's facilities plan.
6. Proposed EPA Decision, Granf Amount: p. 6
Northglenn submitted to EPA on December 7, 1979 its comments
on the calculation of the $6,948,000 grant amount. In addition
to technical errors by EPA in its calculation of the grant amount,
Northglenn wishes to be on record in its disagreement with EPA
on the application of the cost effectiveness regulations in regard
to EPA's definition of the "least cost pollution control alternative.
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6a
t-0
6b
6c
Mr. Western Wilson
February 25, 1980
Page seven
The costs of treatment at Metro Denver are substantially under-
estimated for one or more of the following reasons:
(a) Although the present discharge permit may be consistent
with the wasteload allocations of the South Platte River
303(e) Plan, the Plan has expired and was replaced by the
current 208 Plan. This predetermined expiration was actually
included as a part of the original resolution of adoption
of the 303(e) Plan. The 208 Plan sets forth a wasteload
allocation which is substantially more stringent in order
to meet the existing stream classification. Therefore, it
is incorrect to suggest that the current discharge permit
will meet existing stream quality standards and that the
South Platte must first be reclassified to require a more
stringent standard for Metro Denver. In other words, the
existing classification requires a substantially higher
level of treatment than the discharge permit requires.
(b) The capital costs for sludge disposal at the Metro
Denver Central Plant have been excluded. The justification
under the regulations for this exclusion is not in the DEIS.
(c) The costs to meet the current discharge permit require-
ments appear to be much too low. The cost estimates prepared
by Metro Denver and its consultant Gulp, Wesner and Gulp
should be factored into the analysis.
The City believes these facts should be carefully considered
before EPA makes its final decision relative to the grant amount.
We stand ready to further elaborate on these comments and provide
supplemental information to the technical documents previously
submitted on these issues.
7 Prevention of Agricultural Tailwater Runoff Into Towns
of Frederick and Firestone; Prevention of Sale of Raw
Edible Crops Grown Under Standley Lake Division of
FRICO: p. 7
We do not believe that the application of items 2 and A
as grant conditions are supportable under either the Colorado
striam classification system or the technical analyses of the
DEIS. Although we recognize that EPA regulations and guidelines
may be non-conclusive in this area, we do not believe it is a
prudent course of action to apply an arbitrary standard to the
Northglenn plan. Rather, EPA and the Colorado Department of Health
should follow a carefully planned procedure for the development
of a definable standard. The first step in this process should
6a The Denver Regional Council of Governments 208 Clean Water
Plan makes recommendations for the ultimate classification
of the South Platte River. The cost estimates for Northglenn s
pro-rated share of the Denver Metro treatment system costs
are based on the existing water quality standards for the
South Platte. EPA determined that it could not make a cost
allocation based on speculation of a future decision
by the State Water Quality Control Commission relative to water
quality standards.
6b. The justification under the regulations for not including
the costs of sludge disposal of the Metro Denver Central
Plant is that the facilities are not sized differently with
the elimination of Northglenn's proportional input to that
system. As a consequence of the facility size remaining the
same no difference in cost allowance or sludge disposal in
Denver Metro is allowed.
6c. Revisions to the cost estimates for the Denver Metro
facility plan have been prepared by Gulp Wesner and Gulp.
It is EPA's procedure that once a determination is made of
the percentage eligibility under a multipurpose cost
analysis that percentage remains fixed for the remainder
of the project. This procedure is necessary because cost
estimates are continually updated and EPA would be forced
to make continuous revisions to the grant eligible amount
if they did not use the initial cost estimate. As a
consequence, the revised Denver Metro facility plan costs
will not be included in this cost analysis.
The potential exists that waterborne disease could be
transmitted from this facility. EPA maintains it is
prudent and reasonable to require the 200/100 ml fecal
coliform effluent limit to reduce the relative health
risks. Therefore, EPA will require this standard within
the 3SPDES permit. There may be an apparent successful
history of irrigation of raw edible food crops downstream
of the Denver Metro Sewage Treatment Plan, but this is
not a demonstrable fact. It has not been demonstrated
by independent analysis that waterborne diseases are
not transmitted to crops irrigated with Denver Metro
effluent. EPA has determined it will not be necessary
for the City of Northglenn to impose a ban on raw edible
food crops, but will require Northglenn to advise farmers
not to grow raw edible food crops with this effluent.
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M
NJ
N3
Mr. Western Wilson
February 25, 1980
Page eighc
include a well-designed program for the collection and interpretation
of data. There Ls a long and successful history of irrigation
of raw edible food crops in the South Platte Valley downstream
of several Denver area sewage treatment plants. This history
should be examined and, if necessary, supplemented by additional
data prior to the establishment of any new standards. In the
interim, the same standard which applies to the other Denver
area sewage treatment plants should be applied to the Northglenn
facility. If, as a result of new information, a new standard
is established, it can then be uniformly applied to all discharges
to irrigation ditches. We have attached a Feburary 5, 1980 (Attachment
A) technical memorandum by Sheaffer and Roland which further
elaborates on this point of view. Northglenn stands ready to
cooperate with EPA in its efforts to resolve this matter.
8. Potential Odor Problems: pp. 6, 67-72
Paragraph 4 on page 6 appears to conclude that a "potential
odor problem at the treatment site" will be a significant direct
adverse environmental effect of the Northglenn facilities plan.
On pages 67 - 72, the DEIS contains a detailed analysis of the
possible areas which may be affected by an "odor episode" at
the wastewater treatment lagoons. The DEIS, however, does not
discuss the unlikely chain of events necessary to create an odor
8 episode nor does it point out the design features of the plan ^
which mitigate the possibility of occurrence of an "odor episode.
We believe it would be appropriate for EPA to include this discussion
in the Final EIS and it should include a comparison with the
design features of other aerated lagoons in the area so that
the public will be more fully informed. We have attached a Feburary
11, 1980 technical memorandum by Sheaffer and Roland on this
subject for your consideration (Attachment B).
9. Effect On Adjacent Land Values: p. 9
The City agrees with EPA's assessment that the long term
decrease in adjacent land values are insignificant. This conclusion
is supported by experience with other similar systems. We have
attached for your information a technical analysis of the effect
on land values of a much larger set of treatment lagoons and
storage reservoirs in Muskegon County, Michigan as further support
for the conclusions of the DEIS.
10. Eull Canal As Source of Water Supply For The Town Of
Frederick: pp. 10, 39-41
I Northglenn agrees with EPA's conclusion that it is not obliged
to insure that the Bull Canal be a source of future water supply
for the Town of Frederick. It should be emphasized that Frederick
8. An analysis of Northglenn's proposed wastewater treatment plant
and associated storage reservoir has been conducted and included
as part of the final EIS. it is recognized that it is
difficult to find the chain of events necessary to create an
odor episode and to provide mitigation measures for any
individual episode. EPA believes there is a likelihood of
an odor event occurring as a consequence of Northglenn's
facilities inability to consistently meet the proposed sus-
pended solids discharge requirement. The circumstances
surrounding such an event would be associated with a large
algal bloom in the reservoir that could generate odors
during the decay process. Additionally, suspended solids
could carry over into the Bull Canal and decay during
transport downstream generating additional odor. The
actual odor event itself and its frequency cannot be determined
and mitigation measures to control algal production within
the reservoir will in effect be mitigation measures for
odor episodes.
9. EPA acknowledges that in other systems the decrease in
adjacent land values has been different. Those changes in
value are largely a result of public perception and acceptance
of the facility.
10. Refer to response to the City of Frederick, City of Fort
Lupton, Weld County and Larimer-Weld-Cog relative to the
classification of the Bull Canal as a domestic vater supply
source.
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Mr. Weston Wilson
February 25, 1980
Page nine
10
N>
CO
11
12
has merely indicated a desire Co use Che Bull Canal as a water
supply - 1C has not offered any specific plans for doing so.
Frederick currently does not even own any shares in the
Bull Canal, and the shares which ic claims may become available
in the future are under condemnation by Thornton. We understand
that the owner of these shares is currently negotiating the removal
of this condemnation by selling these same shares and its remaining
shares in FRICO to the City of Thornton. Other sources are available
to Frederick and it should continue to pursue those sources.
Frederick should recognize that one of the reasons FRICO
entered into a reuse agreement in the first place was to prevent
future speculation on the use of the Bull Canal as a municipal
water supply conduit. Such a use would be in direct conflict
with Che optimum use of the canal for its intended purposes as
an irrigation canal. Northglenn appreciates EPA's support of
FRICO's efforts as a part of its policy to protect and enhance
agriculture in Che Front Range.
11. Thorncon Water Service: p. 15
Contrary to Thornton's bare assertion that it can provide
adequate water services to Northglenn, the problems with the
quality and quantity of water supplies available to Thornton
are well-documented in published reports by the City of Thornton,
the Colorado Legislature and the Denver Regional Council of Govern-
ments. See Water Discussion and Treatment Reconnaisance Study,
for the~C~ity of Thornton, Colorado CH-M Hill (June, 1978); Metro-
politan Water Requirements and Resources, 1975-2010, prepared
for Colorado State Legislature, Metropolitan Denver Water Study
Committee (January, 1975); Regional Water Study, Denver Regional
Council of Governments (April, 1978). Thornton contends that
these problems have either been solved or did not exist in the
first place, without any documentation for their contention.
Thornton's assertion must be supported by documentation if it
is to be given credence in the Final Environmental Impact Statement.
12. Agricultural Issues — Effect of Nutrients: p. 26
The final EIS should make reference to the technical memoranda,
dated August 14 and August 29, 1979, that Northglenn has submitted
to EPA on the subject of che wastewater nitrogen and its impact
on crops grown under FRICO. These memoranda provide conclusive
evidence that the Northglenn plan for agricultural reuse of its
wastewater reflects good nutrient management practices and conforms.
for example, with the Larimer/Weld Regional Council of Governments
Section 208 Plan for control of agricultural non-point sources
pollution.
11.
EPA has revised its water supply alternative section to
include the option of Thornton continuing to provide North-
glenn fs water supply
12.
See response to comments by the Great Western Sugar Company
and Larimer-Weld Regional Council of Government with respect
to these effects upon agricultural productivity.
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Mr. Western Wilson
February 25, 1980
Page ten
12
13
14
15
Great Western Sugar Company testified at the February 13,
1980 public hearing that Northglenn's plan posed no threat to
efficient sugar beet production. Northglenn intends to work closely
with Great Western in developing the City's Agricultural Reuse
Manual to assure that irrigation practices maximize the effective
use of the reuse irrigation in sugar beet and other crop cultivation.
13. Tributary Ground Water: p. 27
Northglenn concurs with the conclusion that the tributary
well fields will have no adverse effect on agricultural lands.
The statement in the DEIS, however, that "final evaluation of
the impacts of the well field cannot be completed until the field
is located and the wells are designed" is misleading. It suggests
that no analysis of the environmental effects of the well field
has been performed. This is simply incorrect.
It is true that Northglenn has not yet finally located the
well field. Northglenn, however, has selected a group of alternative
sites for the wells and has analyzed the environmental effects
of each. Northglenn has provided EPA with this information, and
is prepared to elaborate on that information if necessary.
14. Lining of Bull Canal: p. 28
The discussion on the Bull Canal lining appears to imply
that the lining is still in the planning stage and may or may
not be completed. FRICO began lining the Bull Canal in the Fall
of 1979 and as of this date the lining is 30 to 40 percent complete.
This project is being undertaken solely under the supervision
and control of the FRICO Board as a part of its responsibility
to the FRICO shareholders. Northglenn supports FRICO in this
effort as an environmentally sound approach to make more efficient
use of available water supplies of the Front Range.
15. Legal Issues: p. 33
The DEIS states that "even though FRICO may legally be able
to line the Bull Canal, this action could adversely impact downstream
users that have historically depended on seepage water from the
canal."
This statement is misleading because it implies that irrigation
return flows will be diminished under the FRICO system as a result
of the Northglenn reuse arrangement. With the possible exception
of the Firestone/Frederick tailwater control plan, this is not
13.
Subsequent to the distribution of the draft EIS Northglenn
has determined the final location of its tributary well
field. Utilization of the tributary groundwater will be
determined by the water Court.
14.
"•
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Mr. Weston Wilson
February 25, 1980
Page eleven
I the case. The return flows should increase slightly due to the
I 10% bonus on the water borrowed by Northglenn.
Sincerely yours,
Richard P. Lundahl
Director of the Department of
Natural Resources
City of Northglenn, Colorado
cc: Robert McGregor
William T. Smith, Jr.
to
(JV
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LARIMER - WELD REGIONAL COUNCIL OF GOVERNTs/lENTS
PHONE (303) 667-3216
ROOM 201
201 EAST 4tn STREET
L.OVELANO, COLORADO »0537
February 25, 1980
Mr. Roger Williams
Environmental Protection Agency
Region VIII
1860 Lincoln Street
Denver, CO 80295
Dear Mr. Williams:
ffi[?£
u.
. FEB28 1980
\L
i v. |?.\ KSJON VW l£J
Re:
Draft Environmental Impact Statement - Northglenn Water Management
Program, City of Northglenn, Colorado
The Larimer-Weld Regional Council of Governments, a designated Water Quality
Management Planning Agency under Section 208 of the Federal Clean Water Act
as amended, has completed a review of the Draft Environmental Impact State-
ment for the proposed Northglenn Water Management Program.
We believe EPA's decision to prepare an Environmental Impact Statement on
this project was a prudent choice, as this is the first time that various
parts of the Northglenn proposal have been identified in sufficient detail to
permit a thorough review of the sizing, location and financing of the project
as well as an evaluation of implications of the operation of its various
components. However, we are concerned that the procedural requirements of the
National Environmental Policy Act and recently promulgated regulations there-
under may have been violated.
In previous communications with the United States Environmental Protection Agency
and the State of Colorado, the LWRCOG has not formally taken a position in
support of or in opposition to the Northglenn Water Management Program. We have
merely requested that sufficient information be provided for all affected parties
to begin a thorough and accurate evaluation of the environmental impacts of the
proposed program.
Based upon the comments which were received by EPA at the Public Hearing held in
the City of Northglenn on 13 February 1980, there are still major unresolved
concerns regarding the proposal. Among these are the actual need for the project;
the advisability of providing federal Construction Grant Program assistance for
wastewater collection and treatment portions of the project; issuance of a NPDES
permit: and management of the proposed treatment facilities in accordance with
applicable 208 Areawide Water Quality Management Plans.
The Larimer-Weld Regional Council of Governments, through its 208 Areawide Water
Quality Planning Committee, which is a policy and technical advisory committee
to the Larimer-Weld Regional Council of Governments' Governing Board, has
examined these issues in detail to determine their effects upon the locally
RESPONSE: 1. EPA wishes to acknowledge the interest that the Larimer-
Weld Regional Council of Governments has taken in the
preparation of the Environmental Impact Statement on the
Northglenn Water Resource Management Program. The issue
of compliance with the scoping process was subject to
litigation in Consolidated Ditches Company, et.al. vs.
EPA. The issue was settled by mutual written agreement
between EPA and these parties on June 2, 1980. It is
EPA's position that during the last two years of review
by our agency; the environmental assessment, public meeting
and numerous phone calls regarding the Korthglenn proposal
were sufficient to satisfy the intent and purpose of the
public scoping process required under recent regulations
promulgated by the Council on Environmental Quality.
2. EPA acknowledges the various items of interest the
Larimer-Weld Regional Council of Governments has indicated
as areas of concern. Each of the nine issues identified
will be responded to below.
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Mr. Roger Williams
February 25, 1980
Page 2
adopted, state-certified and EPA-approved Water Quality Management Plan for
Larimer and Weld Counties, Colorado. In addition, the 208 Areawide Planning
Committee has viewed the project in its broader perspective as a project which
will set precedents in water quality related water resource policy along
Colorado's Front Range. The issues which we have examined and request EPA to
respond to include the following:
1. Need for the Project
2. Applicability of EPA "Multiple Use" Classification of Northglenn Proposal
3. Applicability of "Alternative Technology" Classification of Northglenn
Proposal
4. EPA Adherence to Revised Work Plan for Preparation of Environmental
Assessment
5. EPA Compliance with NEPA Regulations Covering Preparation of Environmental
Impact Statements
6. Recommended Stream Classification for Bull Canal
7. Requirements for Environmental Impact Statement on NPDES Permit
8. Management Agency Designation
9. Conditions for EPA Grant Approval. IGA and NPDES Permit
The attached narrative contains the LWRCOG 208 Areawide Planning Committee's
detailed comments on EPA's Draft Environmental Impact Statement. We request that
all of these comments and attachments be made part of the official hearing record.
We look forward to working with you in finding a cost effective and environmentally
responsible solution to the City of Northglenn's water supply and waste treatment
problems.
Sincerely yours,
/Jonathan M. Rutstein
'Executive Director
JMRisks
Enclosures
cc: The Honorable Gary Hart, U.S. Senator
Harris Sherman, Chairman Colorado Water Quality Control Commission
Paula Herzmark, Director, Department of Local Affairs
Gary Broetzman, Director, Water Quality Control Division
Morgan Smith, Commissioner of Agriculture
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LARIMER - WELD REGIONAL COUNCIL OF GOVERNMENTS
PHONE (3O3I ««7-J2M
ROOM Ml
101 CAST«nSTiieCT
LOveuANC, COUOMAOO M937
Leriiaer-Weld Regional Council o£ Governnents comment* on U.S
Environmental Protection Agency Draft Environmental Impact
Statement For Morthalenn Water Management Program Uorthqfenn,
Colorado. (£PA 908/5-79-002A)
T
M
ro
oo
NEEO FOK THE PHOJEC'f
At page 16 of the Draft Statement, it is stated that,
"Northglenn's wastewater treatment need is entirely a
function of the water supply and exchange program. In order
to implement the exchange, control of wastewater treatment
and discharged is essential.*
we are encouraged to see that EPA has formally recognized
the fact that the City of Northglenn's need of federal
financial assistance under Section 201 of the Federal Clean
Water Act is solely to satisfy its water supply cofnnitments,
and is not directly related to an immediate need for the
collection and treatment of waste waters generated by the
City of Northglenn.
At page 15 of the Draft Statement, EPA states "Northglenn's
stated position is that the City of Thornton cannot provide
an acceptable water supply, either in terms of quantity or
quality. The raw water quality of Thornton's Columbine
Treatment Plant has on occasion had nitrite concentrations
that exceed the drinKing water standard of 1.6 nl. per liter
... the current position of Thornton is that they can pro-
vide an adequate water supply for themselves and Northglenn
(3)."
Information provided by the City of Thornton at the U.S.
Environmental Protection Agency Public Hearing held in
Northglenn on February 13, 1980 refutes statements by the
City of Northglenn regarding the quality of water and tha
ability of Thornton to provide an adequate douestic water
supply now and into the future. A copy of these materials
is provided as Attachment 1. It includes a letter dated
January 31, 1980 from the City of Thornton Utilities Board
to Mr. Roger L. Williams, Regional Administrator, U.S.
Environmental Protection Agency, a resolution dated
February 11, 1S8U from the City of Thornton City Council
EPA references Larimer-Weld COG to the discussion
on water supply alternatives in Chapter 3. The option
of Thornton continuing to supply Northglenn with a water
supply is presented in that Chapter.
*Supplemental comments to verbal testimony presented at
public hearing in Northglenn February 13, 1980.
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1x3
4
supporting the Thornton Utilities Board's position on the
Draft Environmental Impact Statement for the Northglenn
Water Management Program, and a letter from the City of
Thornton Utilities Board to the City of Nortnglenn express-
ing their desire to discuss alternative water supply options
available to Northglenn.
The Larimer-Weld Regional Council of Governments believes
that sufficient documentation has been provided to question
the overall need for the project, and specifically the
request by the City of Northglenn for federal construction
grants funds under Section 201 of the Clean Water Act to
support that endeavor. Further, we question the method by
which the State of Colorado Water Quality Control Commission
allocated priority points to this project which enabled the
City of Northglenn to progress high enough on the
Construction Grants Priority List to be eligible for funds
from the State of Colorado federal allotment of Title II -
Grants For Construction of Treatment Works. Attachment 2 is
a letter dated June 4, 1979 to Mr. Harris Sherman, Chairman,
Colorado Water Quality Control Commission, from the Board of
Commissioners, Weld County, specifically challenging the
allocation of points under the Colorado State Construction
Grants Priority List system.
As stated under Section 201(d) of the Federal Clean Water
Act as amended:
(d)
The Administrator shall encourage waste treatment man-
agement which results in the construction of revenue
-i i '_ties__p_r_oy_icjinq for —
(1) The recycling of potential sewage pollutants
through the production of agriculture,
silviculture, or aquaculture products, or any
combination thereof;
(2) The confined and contained disposal of pollutants
not recycled;
(3) The reclamation of wastewater; and
(4) The ultimate disposal of sludge in a manner that
will not result in environmental hazards.
(e) The Administrator shall encourage waste treatment man-
agement which results in integrating facilities for
sewage treatment and recycling with facilities to
treat, dispose of, or utilize other industrial and
municipal wastes, including but not limited to solid
It. The final EIS describes the need for the Northglenn waste-
water treatment facility in Chapter 2 as being a function of
Its water supply system necessitated by the need to treat
wastewater. Its eligibility under the Clean Water Act is
based on the need for grant award to the cotcnmnity for
treatment of its pro rata share of flows associated with
Denver Metro facility. EPA recognizes the requirement of
the Clean Water Act to encourage wastewater treatment systems
which recycle and reclaim wastewater. In this regard the
Northglenn facility accomplishes this function by providing
a second purpose - agriculture reuse - which is beyond the
necessary requirements to treat and discharge wastewater.
EPA authority under 40 CFR 35.915 is limited to determining
whether State projects listed for construction grants
include only those projects as necessary to meet enforceable
requirements of the act. The eligibility of the Northglenn
proposal is based on its pro rata costs for expansion of
the Denver Metro plant in order to meet present permit
limitations. Grant eligibility for a community according
to EPA cost-effective regulations is established on the
basis of meeting such enforceable permit requirements.
I-f—t-h4s-^r-emains-_an_jiSjiue, it can be discussed during
EPA's EIS public hearing.
- 2 -
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T
waste and waste heat and thermal discharges. Such
integrated facilities shall be designed and operated to
produce revenues in excess of capital and operation and
maintenance costs and such revenues shall be used by
the designated regional management agency to aid in
financing other environmental improvement programs.
Nowhere to our knowledge, does the Act require or encourage
the subsidization of municipal subdivisions to fulfill their
manifest destiny desires for an independently owned munic-
ipal water supply and wastewater collection and treatment
system where adeqaute service for existing and future sewer
needs has been substantiated. We believe that the question
of "need for the project" has been raised in sufficient
detail to warrant a public hearing by the Regional Adminis-
trator of the Environmental Protection Agency for review of
compliance with the Enforceable Requirements of the Federal
Clean Mater Act and Review for Eligibility as set forth
under 40 CFH section 35.915 (g) and (h) - State Priority
System and Project Priority List.
There are over 300 entities on the State of Colorado
Construction Grants priority list, many of whom are in great
need of federal assistance to plan for/ design and construct
legitimate waste treatment projects. Their respective needs
for construction grant funds are directly related to bring-
ing these communities into compliance with the enforceable
requirements of the federal Clean Water Act. We believe
their ability to do so is severely restricted by the State
of Colorado and EPA's intent to award 6.948 million dollars
to the City of Northglenn. We do not specifically challenge
the point priority system of the State of Colorado which EPA
has approved. We merely question the specific allocation of
points to the City of Northglenn through that allocations
procedure. We believe it is the duty of the Environmental
Protection Agency to review such questionable actions and to
ensure that federal tax dollars are expanded for the purpose
they were intended as authorized under the Federal Clean
Water Act.
REQUESTED We ask The Regional Administrator of EPA to hold
RESPONSE: a Public Hearing as set forth in 40 CFR 35.915 (g)
and (h) to determine the eligibility of the pro-
posed project for Title II - Construction Grant
Progran assistance, and to assess the procedure by
which the State of Colorado allocated construction
grants priority points to the City of Northglenn.
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APPLICABILITY OF EPA
NOHTHGLENN PROPOSAL.
•MULTIPLE USE" CLASSIFICATION OF
As defined in EPA's 'Strategies For Funding of Multiple. Use
Projects" prepared by the Office of Water and Waste
Management (U.S. EPA June, 1979),
"A multiple use project addresses water pollution
control and at least one other acceptable purpose.
These latter purposes are in the language of the Clean
Water Act,
control of non-point sources of pollution;
recycling of sewage pollutants;
confined and contained disposal of unrecyclable
pollutants;
reclamation of wastewater;
disposal of sludge;
co-treatment and disposal of other municipal
wastes;
open space and recreation;
reduced total energy requirements" (p. 1)
It is not apparent that the Northglenn proposal accomplishes
any of the listed purposes to any greater extent than has
been historically carried o,ut in Colorado for the last 60
years. In a water short area of the United States such as
Colorardo, recycling and reclamation of water occurs as a
matter of necessity. In Northern Colorado approximately 25
municipal facilities discharge their treated wastes to
ditches or natural waterways which are then used imraediately
for agricultural use, whereby the nutrient - pollutants are
made available for crop production. Water and nutrient
recycling and reclaaation are simply not new in the context
of Colorado water usage. They are a natter of beneficial
coexistence between municipal discharges and agriculture.
If EPA choses to fund Northglenn's proposal as a "multiple
use" project nearly all of Colorado's Wastewater Projects
which discharge to a ditch or heavily used (and appropri-
ated) natural waterway in agricultural areas should qualify.
EPA's Multiple Use Strategy says nothing in support of sub-
sidizing water supply projects. Yet EPA has, as we have men-
tioned previously, adaitted that, tiorthglenn 's waste treat-
ment need is entirely a function of its water supply
commitments.
EPA strategies for funding multiple-use projects contains
a list of multiple-purpose projects which are considered
alternative technology by virtue of controlling nonpoint
sources of pollution and recycling and reclaiming waste-
waters. Korthglenn meets this purpose by guaranteeing
that its effluent disposal will be used in agriculture.
This differs from "de facto" reuse or historical reuse
of sewage effluent by virtue of its guarantee. North-
glenn's ability to store wastewater, to augment borrowed
water, and to discharge only upon irrigators demand clearly
makes it an agricultural reuse system. Further, the City
of Northglenn has agreed to an EPA requirement to maintain
control of sufficient land such that if there is insufficient
demand by private irrigators the wastewater will be reused
for agriculture. EPA does not believe that nearly all of
Colorado's wastewater projects would be eligible for
multi-purpose project funding because they fail to have
this commitment to agriculture. Each new project will be
considered in the future on a case-by-case basis of whether
or not it can meet the seven items for commitment to these
purposes. If new projects can meet these requirements they
will be eligible for multiple purpose funding as is the
Northglenn facility.
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SJ
EPA states at page 61 of the Draft Statement that:
"For EPA to participate in the funding of a Multiple
Use Project, the following should apply:
1. The cost of multiple-purpose project must not
exceed the sum of the costs of the nose cost-
effective single-purpose options which accomplish
the same purposes.
2. The primary and secondary environmental effects
must be assessed in accordance with the NEPA
review procedures, and the project must not have
any significant net adverse environmental effects.
3. At least one of the purposes must be necessary to
cseet an enforceable requirement of the Act.
4. There is no purchase of existing facilities with
federal funds.
5. The project meets the definition of treatment
works, and the works are publicly owned.
6. The project is consistent with the adopted and
approved water quality management plan.
7. For agricultural reuse projects a commitment to
this use for the design life of the project is
necessary.
Northglenn meets all of these requirements (see Chapter 1 -
EPA decision.)•
While EPA may have concluded that the written policies of
the administrative document prepared for funding multiple
use projects has been satisfied, we do not see that there is
sufficient common sense justification to fund the project.
We find that EPA's criteria to fund the proposal under a
multiple use strategy is somewhat confusing in its
priorities to protect or enhance the quality of aquatic life
in tne South Platte River while increasing the public health
risk to water users in the Bull Canal systen. EPA's
apparent concern about public health and water use is mani-
fested in its request for very stringent requirenents to be
included as grant conditions, NPOES permit requirements or
elements of 208 Intergovernmental agreements.
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R£QUESTED We request that EPA justify its decision to fund
RESPONSE: the project in the context of its Multiple Use
Strategy and the Federal Clean Water Act as they
would apply in the State of Colorado.
3. APPLICABILITY OF "ALTERNATIVE TECHNOLOGY!* CLASSIFICATION OF
NORTaGLENN PROJECT
A. The Northglenn proposal is simply a conventional secondary
treatment and storage systen which discharges to a man-aade
canal where water is used primarily Cor irrigation. In addi-
tion, several communities in the Bull Canal systen have made
or are making substantial investments in water supply
systems to use wacer in the canal for domestic water supply
purposes. There is nothing alternative about the Northglenn
wastewater system. It has never been designed to accomplish
a purpose of land treatment or reuse. Therefore it should
not be eligible for 85% funding of construction costs.
B. If by any sense of imagination this proposal could be classi-
fied as "alternative", the present method of waste treatment
for Northglenn's waste will not be abandoned. The capacity
at Denver Metro Sewage Disposal District facilities will
merely be made available to serve other future population
growth in the Denver area. In essence, the discharge
equivalent fron Northglenn will be replaced by sone other
Denver Metro customer.
REQUESTED We request that EPA and the State of Colorado
HESPOMSE; specifically identify the components of the
Northglenn proposal which would classify it as an
'alternative techology" system eligible for
special funding consideration. Please cite all
federal regulations and agency policy guideline
materials used in making this determination.
6. Northglenn's proposal Is not simply a conventional
secondary treatment and discharge to a canal. It
includes the provision that the discharge is only
made during irrigation demand and that the discharge
not occur during canal wasting. (Canal water overflow
into the Little Dry Creek system and hence to the South
Platte system.) As responded to in the previous coinr'ent,
Northglenn complies with the commitment to agricultural
reuse by virtue of a contingency plan designed to reuse
the effluent entirely on land in N'orthglenn's control if
there is insufficient irrigation demand. (See Chapter 5,
Mitigating Measures.) The specific components of the
Northglenn proposal which are eligible for alternative
treatment technology are listed in Chpater 6, EPA Funding
Criteria and Analysis. Those components entirely
associated with agricultural reuse are eligible for
the 85 percent grant. This includes the Bull Canal
wastewater storage reservoir and those mitigation measures
regarding reuse.
EPA ADHERENCE TO REVISED WORK PLAN FOR PREPARATION OF
ENVIRONMENTAL ASSESSMENT
On April 3, 1979, at a regular meeting of the Colorado Water
Quality Control Commission, the U.S. Environmental
Protection Agency announced, through its Regional Counsel,
intent to reopen the environmental assessment of the
Northglenn Reuse project. Shortly thereafter EPA issued a
'Draft Directive of Work" which was to guide the preparation
of the environ- mental assessment. EPA, through its project
officer for the Northglenn Reuse System, requested review
comments from the LWHCOG on the 'Draft Directive of Work".
On 25 May 1979 the LWRCOG submitted its detailed comments
(Attachment 4). The focus of LWRCOG's questions and
comments was to assist EPA
7. The response to your May 25, 1979 letter which recommends
additional studies as part of the Directive of Work for
the consultant is attached as a separate response.
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in defining the need for the project, the availability of
other alternative water supply and waste treatment, and
ensuring that a thorough and accurate examination of signifi-
cant environmental impacts was initiated. LWfiCOG was told
by EPA that the substance of these comments would be
included in their entirety in the "Final Directive* of Work
or the 'Scops of Services - Work Plan" undep whiah the con-
sultant would contractually perform all required tasks.
We have conpared the content of the Draft Environmental
Impact Statement with the 'Directive of Work* for the
environmental assessment and the consultants' Final Work
Plan. We believe that EPA has not identified or sufficient-
ly addressed major issues which were brought to its atten-
tion during the preparation of the Work Plan to guide the
development of the environmental assessment in May of 1979.
Specific issues which LWRCOG asked EPA to address and which
are contained in the LWRCOG comments on the Draft Directive
of Work include, the following:
1. Need for the project including examination of the avail-
ability of alternative sources of waste treatment and
water supply for the City of Northglenn.
2. Overall quantitative impacts to agriculture as a result
of implementing the Northglenn reuse program.
3. Requirements of NPDES Permit to ensure proper operation
of system/ including mitigation measures.
4. Feasibility of other communities in the Denver area pro-
posing similar type reuse systems to gain a source of
water supply.
5. Full disclosure of the sizing and operational charac-
teristics of the proposed treatment system - evaluation
of system design, including reuse as parts of the
proposal.
6. Feasibility of requiring additional treatment processes
if the system does not operate as intended and in com-
pliance with NPDES permit requirements including reme-
dial action plans in case of system failure.
REQUESTED We request EPA to address each issue previously
ftESPOMSE: raised by LtfRCOG; and if appropriate, refine or
expand the scope of such response based upon
actions taken in the LVirtCOG request for compliance
with the 'scoping* requirements of the November 6,
1979 NEPA regulations (see Issue 5 which follows).
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Ln
5. EPA COMPLIANCE HITrl Mt!PA REGULATIONS COVERING PREPARATION Of
ENVIRONMENTAL IMPACT STATEMENTS.
On November 28, 1978, the Council on' Environmental Quality
promulgated rules covering the uniform procedures for imple-
menting the procedural provisions of the National
Environmental Policy Act. These regulations, which became
effective July 30, 1979 require agencies to comply with
•scoping" procedures after the agency determines that an
Environmental Impact Statement will be prepared
(40 CFR 1501.07).
Such 'scoping* procedures are to assist in determining the
scope of the EIS and for identifying the significant issues
related to the proposed actions.
Federal regulations implementing the CEO rules were promul-
gated by EPA on November 6, 1979. These regulations became
effective on December IS, 1979 nearly one month before EPA's
determination to prepare an Environmental Impact Statement
8 on this project.
In a memorandum dated January 4, 1980 EPA gave notice of its
intent to prepare an Environmental Impact Statement on the
Northglenn Project. Notice was subsequently published in
the Federal Register on January 11, 1980. Between the
January 11 and February 19, 1980 LWRCOG was not notified by
EPA of any scoping procedures which are required by federal
regulation. We therefore question the legality of the
public hearing held on February V9, 1980.
"<
In fact LWRCOG has not been provided with the environmental
assessment which EPA is required by federal regulation to
use in the determination of whether an EIS is required.
LWHCOG did however, receive one copy of a report entitled
Preliminary Environmental Report Northglenn Water Management
Program dated November 1979. To our knowledge such a
document has never been released in final form nor does it
have recognition as an environmental assessment in the NEPA
regulations.
REQUESTED We ask EPA to justify its actions and to provide
HESPONSfi; documentation of its compliance with scoping
"~ requirements of the NEPA implementing regulations,
in the determination to prepare an Environmental
Impact Statement on the Northglenn Aeuse Proposal.
8. The Issue of compliance with the scoping process was
subject to litigation in-Consolidated Ditches Company,
et.al. vs. EPA. The issue was settled by mutual written
agreement between EPA and these parties on June 2, 1980.
It is EPA's position that during the last two years of
review by our agency; the environmental assessment, public
meetings and numerous phone calls regarding the Korthglenn
proposal were sufficient to satisfy the intent and purpose
of the public scoping process required under recent
regulations promulgated by the Council on Environmental
Quality.
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6. RECOMMENDED STREAM CLASSIFICATIONS FOR THE BULL CAXhL
EPA states at page 40 of the Draft Statement that,
"Filings have not been aade to change the use of the
Bull Canal waters to a water supply and the current
Larimer-Weld Clean Water Plan designates the Canal
solely for agricultural use. Thus, it is EPA's con-
clusion that the protection of these waters for a
potential source of future water supply source is
unnecessary and EPA recommends that Frederick explore
other options to satisfy future water supply denands."
We wish to remind EPA that the LWRCOG has no final authority
in the determination of stream standards or in the assign-
ment of stream classifications. This authority rests with
the State of Colorado through the Colorado Water Quality
Control Commission. The LWSCOG as a State Management and
Planning Region and as a designated 208 planning agency is,
however, a participant in making recommendations for such
water quality standards and straam classifications. At pre-
sent, the Colorado Water Quality Control Commission has not
assigned a use classification to the Bull Canal or nuneric
standards to be achieved.
While the Larimer-Weld Regional Council of Governments
recognizes the importance of maintaining or improving the
quality of water in the Region consistent with reconnenda-
cions of its adopted 208 Plan, there has been no recoaaenda-
tion (as noted at page 40) to designate the Bull Canal
solely for agricultural use. It is the position of the
LWftCOG 208 APC that ditches and canals not be classified
unless the proposed use designation is to protect an exist-
ing use or a legitimate future anticipated use such as water
supply.
The Colorado Water Quality Control Commission is expected to
hold stream reclassification hearings on the South Platte
River and tributaries sometiae in June or July of 1983.
Petitions to classify the Bull Canal, if appropriate, should
be made at that time through a public participation and
administrative review process as required by both state and
federal law. The future of such a proposal to classify the
Bull Canal should not be superceded by EPA through
administrative action on a proposed waste treatment project.
Compliance with procedural requirements of the law makes
EPA's conclusion regarding no protection of these waters as
a potential future water supply improper. We believe that
the concerns of the Town of Frederick for seeking out a
future water supply are of equal importance to those of the
City of Horthglenn which allegedly lead it to the initiation
of this water reuse program. In addition, we believe tnat
the City of Fort Lupton's concern about protecting its
future source of water supply is also important.
9. The administrative procedure for classification of state
vaters which requires a request for designation to the
State Water Quality Control Commission can be initiated
by the Larimer-Veld Council of Governments. Such a
procedure could have resulted in reclassification of the
Bull Canal as a vater supply source. Currently the state
has not received any requests for the reclassifying of Bull
Canal to a water supply source. As the EIS recognizes,
such a classification would likely prohibit the project.
To achieve water supply quality with 100 percent effluent
would be cost prohibitive. EPA investigated the changes
in water quality in the Bull Canal that would adversely
affect the Town of Frederick and the City of Fort Lupton.
There is no change in the results indicated in the draft
EIS. Fort Lupton's supply will not be significantly
impacted as a result of receiving some small portion
of flow into Sand Creek Reservoir from overflow from the
Bull Canal. Such a small loading will not affect nitrate
concentrations significantly within Sand Creek Reservoir.
The City of Frederick, on the other hand, will find it
uneconomical to take the Bull Canal water and utilize it
for a domestic water supply source, therefore, the city
should look elsewhere for another water supply source.
EPA has no evidence that administrative steps have been
taken to protect this canal for a public water supply.
Therefore, it remains EPA's position that the project
can proceed on the basis that the Bull Canal need not
be protected as a domestic water source.
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9
U>
10
REQUESTED 1. EPA should clarify the stream classification
H£SlfdflS£; process tn the Final Environmental Inpact
Statement, and consider the effects of a
proposed classification for water supply on
the viability of the Northglenn proposal -and
required NPDES permit conditions.
2. EPA should investigate in detail the present
and projected expenditures, of the Town of
Frederick and the City of Fort Lupton to make
the Bull Canal or hydrologically connected
water bodies a future source of domestic water
supply. This investigation should include the
federally financed improvements made to
Firestone Reservoir and the foreclosure on
options (if any) to use those facilities by
making the Bull Canal unsuitable for water
supply purposes. The investigation should
also focus on the feasibility and costs to
Firestone in searching out an alternative
water supply.
3. We ask EPA to defer determination of NPDES
Permit requirements until after the State of
Colorado makes a decision on the use classi-
fication of Bull Canal and hydrologically
connected water bodies below the proposed
Northglenn facility discharge point.
7. REQUIHEMENTS FOR ENVIRONMENTAL IMPACT STATEMENT ON MPDES
PERMIT CONDITIONS " ~~"
If the Northglenn facility is constructed, the EPA through
the State of Colorado will be required to issue an NPDES
Permit to the City of Northglenn to ensure compliance with
appropriate sections of the Federal Clean Watep Act. Based
upon limited information contained in the Draft Environ-
mental Impact Statement about the quality of the discharge
effluent and the potential effects of the discharge on down-
stream water uses, we believe that it is appropriate for EPA
to examine in consultation with the State of Colorado the
specific effluent limits of that anticipated SPQES Permit.
We find it impossible for EPA to determine the effects of
the facility on public health and agriculture without a
thorough examination of the required effluent limits needed
tm protect downstream water uses. Because of these concerns
it would be appropriate to examine the required NPDES efflu-
ent limits and determine the ability of the proposed waste
treatment system to meet those limits, prior to a decision
to award a grant for the construction of the TaVTlity. This
uould be most easily accomplished in the context of the
existing Environmental Impact Statenent.
10. EPA considered various discharge permit requirements to
insure the public health is protected and concluded that
the state's draft permit which included 1000 fecal
coliforns per 100 rilliliters would be insufficient to
adequately protect public health. A more stringent require-
ment of 200 fecal colifonns per 100 milliliters is
appropriate. In addition various grant conditions which
were recor.-iended in the draft E1S will Ijp negotiated with
the Colorado Health Department and may be incorporated
into the NPDES permit to provide enforceability. This
final EIS can be considered the decision document and
evaluation of both the grant action and the state's permit
action. (See Chapter 5, Mitigating Measures.)
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oo
aE'jUESTED We request EPA to consider the feasibility of pre-
KESPOUSE; paring an Environnental Impact Statement ol the
Northglenn (JPDES with the following questions in
mind:
1. Are there provisions for the examination of
the NPDES Permit issuance and compliance under
the NEPA?
2. What are the responsibilities of EPA and the
State of Colorado in that process?
3. Must a decision to prepare an Environmental
Impact Statement for an NPDES Permit be
considered an action independent of a decision
to award a construction grant?
4. Will EPA in consultation with the State expand
the scope of the current Environmental Impact
Statement to include the determination of
specific conditions of the NPDES Permit? If
not, why?
8. MANAGEMNENT AGENCY DESIGNATION FOR THE NORTHGLENN PROJECT
The LWRCOG is a designated water quality management planning
agency with a locally adopted, state certified and EPA
approved 203 Areawide Water Quality Management Plan. As the
guardian of the Plan, LWRCOG is concerned that the integrity
of its Flan, which was developed at great financial cost and
with extensive public participation, is maintained in
accordance with the desires of local governments which have
adopted it. We are also concerned that the Plan meets the
coraplex needs of responsible water pollution control
planning as envisioned by the federal Clean Water Act.
We are in general agreement with EPA's conclusion of joint
11 management agency designation of Weld County and the City of
Northglenn for carrying out certain responsibilities under
their respective controlling 208 plans. However, EPA's pre-
ferred Alternative 3 (at page 96) does not fully disclose
the responsibilities of Northglenn and Weld ,County in the
detail included in Alternative 1, especially as these respon-
sibilities may relate to future reviews, and approvals of '
facility expansions, construction priorities and siting and
operational characteristics of any proposed wastewater
systems. While it is anticipated that these requirements
will of necessity be included in an IGA, we request that EPA
clarify its position with regard to the essential elenents
of management agency authority for both point and non-point
source pollution control. We wish to work closely with EPA
in examining this issue.
11. EPA believes that similar wastevater reuse systems may
be feasible in the Denver Metropolitan area. It is not
within the context of this Environmental Impact Statement
to speculate or identify the development of such plans.
In the future, such plans, if submitted to EPA, will be
evaluated similar to the Northglenn proposal as to their
acceptability for public health, water quality protection,
permit compliance, enforceable requirements of the Act
and environmental effects.
EPA will still require the execution of an inter-
governmental agreement between Weld County and the City
of Northglenn prior to final payment of the Step III
grant. The legal and administrative costs will be analyzed
at that time and if mutually acceptable such administrative
burdens can be placed upon the City of Northglenn. EPA
believes the burden created on Weld County from Northglenn's
facility Is the responsibility of the City of Northglenn.
- 11 -
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11
VD
If EPA awards the City of Mocthglenn a construction grant
for the proposed facility under its "Multiple Use" or
"Alternative Technology" provisions, it will by its actions
define the project as one requiring some non-point,
pollution control management responsibilities for
reclaraation and reuse. The system operation, as proposed by
EPA would place Weld County and/or possibly the State Health
Department in a position of non-point pollution control
management or enforcement requiring great expense and
administrative attention, with no resources to accomplish
those functions. It is our belief that Northglenn should
pay the full amount and all costs to Weld County as a
management agency and the LWftCOG as the planning agency to
participate in this "unique" approach to wastewater
treatment.
EPA's management agency designation will establish a prece-
dent for inter jurisdiction authorities and relationships
between adopted 238 Plans. Other future proposals by grow-
ing municipalities who desire to dispose of wastewaters out-
side their political jurisdictions will be guided by EPA's
precedent.
REQUESTED 1) We ask EPA to expand upon the intent of
RESPONSE: Alternative 3 in the Draft Environmental
Impact Statement and to examine the long-term
implications of its 208 management agency
designation especially as it nay affect future
so called "alternative technology" and
"multiple use* proposals by growing
municipalities on the fringe of the Denver
Metropolitan Area who propose water supply
motivated wastewater pollution control or
sludge application facilities in Southern Weld
County.
2) We ask EPA to look carefully at the legal
issues and administrative costs placed upon
local and state governments which result from
the implementation of new large scale reuse or
reclamation programs that convert point source
to non-point source pollution control
problems.
3) Specifically, we request that EPA examine the
burdens of planning, management and enforce-
ment of water pollution control that evolve
from this approval for waste treatment
management. Out of this examination should
came a recommended course of action for
long-term financing of the Northglenn
wastetreatment program if constructed in Weld
County.
- 12 -
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12
T
8. CONDITIONS FOR EPA GRANT APPROVAL, IGA AND KPDES PERMIT
Three distinct mechanisms are available to ensure thac
adverse environmental effects of the proposed project are
mitigated. If it is determined that the Northglenn waste-
water treatment facility will be constructed, irrespective
of an EPA grant award, the following conditions must be met:
1. An NPDES permit oust be issued by the Colorado State
Health Department and approved by EPA. The permit will
specify the location, magnitude and quality of the
discharge.
2. An intergovernmental agreement (IGA) between the City
of Northglenn (as an operations agency in Weld County)
and Weld County (as a management agency) must be negoti-
ated. The agreement will specify the conditions under
which the parties will allow the facility to be con-
structed, operated, maintained and monitored consistent
with the Larimer-Weld 208 Plan and the State issued
NPDES persiit for the facility.
If an EPA construction grant is awarded, additional require-
ments may be placed upon Northglenn through grant condi-
tions. EPA proposes that a series of public health issues
and operational requirements of the wastewater project be
addressed as grant conditions to ensure compliance by the
City of Northglenn. Several of these conditions require
immediate capital expenditures by the City of Northglenn;
others require a long-term financial commitment, monitoring
responsibilities and possible enforcement measures to ensure
compliance. While Northglenn has given its good faith
intent to meet any and all conditions, we question the
ability of EPA to enforce a violation of the conditions of
grant approval and compliance. Once EPA closes out the
grant or the grantee expends the greater portion of the
grant, EPA has little or no practical recourse to force the
grantee to meet the agreed upon conditions. Failure of
compliance may tnen become a matter for the courts if EPA
elects to use its discretionary administration capabilities
to bring the grantee into compliance with conditions of the
grant award. To our knowledge EPA Region VIII has never
exercised that authority, nor is it a practical approach.
Issues which EPA proposes to be covered as grant conditions
may also be addressed in an IGA or NPDES permit.
REQUESTED 1) In consultation with LWRCOG we request that
RESPONSE; EPA identify in the Final Environmental Impact
Statement the legal authority, administrative
efficiency and practicality of placing various
conditions for the construction, operation,
maintenance and monitoring of the facility of
The Larimer-Weld Council of Government raises an excellent
point with respect to the difficulty of enforcing long term
EPA grant conditions. Following construction the agency
finds it difficult to continually monitor these facilities
and to have a requirement enforced over the design life
period. In response to this request by Larimer-Weld Council
of Governments EPA will negotiate to include several of
the grant conditions previously identified in the draft
impact statement to protect public health as requirements
of the KPDES permit. Therefore the requirements for:
limits on fecal coliform to 200 for 100 milliliters, the
replacement or disinfection of Dacono's potable water
system, the tailwater control plan, as well as limiting
taps along the proposed new interceptor and limiting the
rate of new taps within the city will be considered as
requirements in the NPDES permit. Additional grant
conditions will be required of the City which EPA feels
it has adequate ability to enforce. The other items
which are appropriate for inclusion in the inter govern-
mental agreement will be subject to mutual consent between
Weld County and Northglenn. Failure to execute an inter
governmental agreement will result in withholding of partial
payment for construction of these facilities. EPA, however,
declines withholding of all payment until these conditions
have been met.
- 13 -
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each of the three (3) mechanisms (grant condi-
ons, IGA, NPDES Pernit} to ensure responsible
waste treatment planning, management, facility
construction and enforcement. Inclusion -of
these conditions in any combination of the
three (3) instruments or all of them should be
identified.
2. We request EPA to identify in detail the admin-
istrative requirements and costs necessary to
implement the actual programs, or projects
identified in the Draft Environmental Impact
Statement which EPA feels should be included
as grant conditions or part of an IGA between
Weld County and the City of Northglenn
(conditions as stated on p. 97 and other
places they are referenced). These issues
include the following:
a. Fecal Coliform Limit.
b. Sale and Distribution of Raw Edible
Vegetables.
c. Advisory for Agricultural Reuse.
d. Replacement or Disinfection of Dacono
Hon-pollutable Water System.
e. Tailwater Control.
f. Land Use Authority.
g. Sludge Disposal.
h. Additional Monitoring Requirements.
i. Protection of Groundwater Quality.
j. Limits on New Interceptors.
3. We request that EPA withhold all grant
payments to Northglenn until each grant condi-
tion has been met. In the event that EPA can
not,by law. withhold all grant funds until
complete compliance with conditions, we
request that a graduated payment schedule be
establisned. The schedule should include pay-
ment based upon acceptable completion of
specific grant conditions. Failure to comply,
if within the control of the City of
Northglenn, should be accompanied by
penalties.
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ATTACHMENT 1
8992 H Wssl-nglon Sl'MI
Thornton. Colorado E0229
January 31, 1980
Mr. Roger L. Williams
Regional Administrator
Dnited States Environmental
Protection Agency
Region VIII
1860 Lincoln Street
Denver, CO 80295
Dear Sir:
The City of Thornton Utilities Board and City Council
would like to take this opportunity to formally consent
on the draft environmental iiapact statement regarding the
proposed Korthglenn Water Management System. Although we
t> • do not take exception to the nanagersent plan, we are con-
' cerned about certain statements about the level of service
J, provided to Northglenn by Thornton.
Iss
There is an overriding concern about the quality of Thornton's
finished water. It can be implied from the report that
Thornton's water is in some way unsafe or unpotable. The
City of Thornton's water supply currently meets or exceeds
EPA Safe Drinking Water Standards. Planned improvements to
our treatment process and raw water supply system ensure
that Thornton will continue to meet the EPA standards.
There are also some - comments ihtthe plan regarding the abil-
ity of Thornton, to adequately serve the"City of Northclenn
either now-.'pr-'-in. the future. The City of Thornton preser.tly
has the ability to serve the City of Northglenn and is caoable
.'of doing so in the future. The reason for the City of Thornton
entering into a severance agreement with the City of Northglenn
•was not because of any stated need by the City of Thornton,
this agreement was entered into only to accommodate ths desires
of our sister city. Thornton has the necessary plant end
water resources to adequately serve the City of Northglann.
Knclosod i,s a letter from Mr. Kesley R. Brown, Chair.-aan of
the Thornton Utilities Board, to then Mayor-elect Odell Barry
stating Thornton's continued willingness to serve.
The G:> el n;c:n3 J progress"
-------
Mr. Roger L. Williams
Page Two
January 31, 1980
We of the Thornton Utilities Department welcome the oppor-
tunity to further detail our views regarding the Korthglenn
Water Management Plan. The Utilities Department staff is
presently conducting an in-depth review of the Environmental
Impact Report and will make their factual correction avail-
able to your staff.
Sincerely,
Wesley/a. Brown, Chairman
Utilities Board
Margar^c V7. Carpenter
Mayor
WRB, KRC/bs
Enclosure
-------
Thps-srsfcon
6992 K. V/alMnj'oi Si'!*:
Ihtxmcn. Co'wJCS B0223
303) J23 5501
November 26, 1979
Mayor-Elect Odell Barry
City of Northglenn
10701 Melody Drive
Northglenn, Colorado 80233
RE: Northglenn Utilities Systeir.
Dear Mayor-Elect Barry:
The Utilities Board of the City of Thornton has become concerned
over various statements attributed to various public officials, editor-
ials in the Sentinel Newspaper and letters to the editor of said news-
paper concerning the high cost of the proposed Korthglenn Utilities
System and some inferences that Thornto was responsible for rauch of
the proposed high cost and that there Wiis no alternative at this poi.-.t.
except for Northglenn to proceed.
First, in the most recent negotiations wherein the City of Thorr.zc
agreed to sell those certain utility lines owned by it which are located
vithin the municipal boundaries of Northglenn, Thornton had the lines
valued by what it considers competent engineering consulting fir.T.s. If
the costs to purchase those lines and ppv severence costs to Thornton
were under estimated in the first instance by Korthglenn, that certainly
is not the fault of the City of Thornton.
On behalf of the Utilities Board, we are willing to have our
representatives sit down with you to discuss the alternatives of North-
glenn remaining on the Thornton utility system. This has not been
previously negotiated between the two Cities, however, e recent editori=
in the Sentinel indicated that this alternative was practicallv preclude
This is not necessarily the case, for you must reirenier that ir. the. past
Thornton has always been able to provide Ncrthglenn residents with
adequate water and sewer service and to our knowledge Korthglenn was
one of the few if not the only entity in ths State of Colorado which
received water from its supplier at the sarxi rates and charges that
the supplier charged its own residents.
If you wish to sit down and discuss the alternative referred to
above so that you could refer this to Northglcnn's elected officials
•or to its people for determination, we str.nd ready to do this.
:.v«icd P.'o
-------
Uayor-Elect Odell Barry
P«igc 2
Kovember 26, 1979
No one should be mislead to think that the alternative
referred to above has been precluded when in fact it has not
even been discussed.
Sincerely,
V7es Brown, Chairman
Utilities Board
VTB/jp
Sentinel Xewspaper
Denver Post
Rocky Mountain Kevs
Mayor ?_lvin Thoraas
Mayor Tony Richter
Mayor-Elect Margaret Carpenter
City Manager Gerry Kagnan
Ui
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ATTACHMENT 2
OFFICE OF fc'IARD Of COUNTV COMMISSIONERS
PHONE 1303) 35G-400O EXT. 700
P.O BOX 75S
CMEELEV. COLORADO 83631
COLORADO
June 4, 1979
T
Mr. Harris Sherman, Chairman
Colorado VJater Quality Control Commission
4210 East llth Avenue
Denver, Colorado 80220
Dear Mr. Sherman and Members of the Commission:
RE:
FY-1979 and FY-1930 Construction Grants Priority Lists ~
City of Northglenn
Weld County wishes to comment on the current and proposed allocation of
Construction Grants priority points for a waste treatment facility which
is proposed within the political boundaries of Weld County. The City of
Northglenn, a municipality located in Adams County, is proposing that
facility. We seriously question the need for the facility and the manner
in which the Water Quality Control Commission has allocated Construction
Grants priority points to Uorthglenn for FY-1979; as well, we are concerned
about the way the Commission may allocate points for FY-1980.
It is our understanding that the Commission approved the STEP 1-201 Facilities
Plan for Northglenn over a year ago. However, EPA has not yet approved the
funding to reimburse the City of Northglenn for the initial Plan preparation
or the detailed design required in STEP II. We assume that EPA's actions are
due to the fact that the Facilities Plan has not met a large number of conditions
which are required for final 201 Plan approval.
We question the Commission's assignment of a total of 144 priority points to
Northglenn. This places Horthglenn as sixth out of 360 communities on the
priority list and would dedicate over seven million dollars to its completion.
The Commission has stated that it is not the policy of the Commission to
encourage the proliferation or the construction of new waste treatment plants,
and that it is the policy of the Commission to encourage good local planning
developed under Section 208 of the Clean Water Act (Section 5.3.3 - Grant
Priority System). The Commission has also stated that it "will press
vigorously for publicly owned treatment works to utilize treatment processes
to reclaim and recycle municipal waste water in accordance with established
water law and the appropriation doctrine of the State of Colorado"(Water
Quality Control Commission Policy on Land Treatment of Municipal Waste
Water, July 5, 1978).
-------
Weld County specifically wishes to challenge the priority points allocated to
the City of Northglenn in the context of the Commission's own policies and
point allocation system.
(1) Project Points - 20 project points which have been assigned to Northglenn
do not appear to be justified. We do not see that Northglenn has proposed
"Treatment Beyond Secondary". The material presented thus far by Horthglenn
in its proposals indicate only secondary treatment with discharge to an
irrigation ditch. Northglenn has publicly stated they only expect to
meet simple secondary discharge requirements for an NPDES permit and must
take no further responsibility for treatment after discharge to the ditch.
(2) Special Points - 95 points have been given to Northglenn in the Special
Point category. Weld County does not believe these points were properly
awarded.
50 points have been allocated for the completion of a STEP 1-201 Facility
Plan which allegedly demonstrates that the project is needed. EPA has
reopened the Negative Declaration prepared for the initial 201 Plan
submitted by Northglenn. Among a number of issues which have been raised
in the determination to reopen EPA's decision was the need for the project.
Northglenn's wastes are currently treated at Denver Metro Sewage District.
It is our understanding that there is adequate capacity at this facility
to continue doing so well into the future.
Another 45 points have been allocated to Northglenn for "water reuse".
Reuse of water is already occurring throughout Weld County and has been
performed for many years in the context of Colorado water law. We
believe the Northglenn proposal would only change the location of a reuse
from one hydrologic sub-basin to another and discharge it to an unclassified
irrigation ditch. There are serious water rights issues associated with
this proposal which deserve careful consideration.
We would urge the Commission to again consult its own policies on reuse
and land treatment to determine whether this project really qualifies
as a project "which results in substantial and effective upgrading of
the effluent prior to discharge"and reclaims water in accordance with
established water law. The reuse benefits of whether the discharge is
to a natural water course or an irrigation ditch are ones which should
be addressed in the context of all existing or anticipated beneficial
uses of that water.
Weld County believes that the allocation of Construction Grants priority points
for Northglenn should be revised:
(1) It is clear that the project, as it is proposed, 1s_not providing "treatment
beyond secondary" and is, therefore, not entitled to 20 project points.
(2) The completed facility plan does not conclusively demonstrate need for this
waste treatment project as intended in the Federal Clean Water Act. It
is, therefore, not entitled to 50 points for having a completed 201 Facilities
Plan.
(3) Weld County also believes the Northglenn proposal is not a "reuse"
project in the context of the Commission's written definition of reuse
(Section 5.3.6) nor in the context of historic water use practices that
-------
have been followed in Northern Colorado for many years. Therefore,
Northglenn should not be entitled to 45 points for "reuse".
In sunmary, the City of Northglenn is eligible only to 29 population points
for the FY-1980 funding-list. And, because of the recent opening of the
201 Plan Negative Declaration by EPA, we do not believe the need for the .
project has been sufficiently documented to permit it to be funded on the
FY-1979 priority list at this time. We also believe that sufficient evidence -
may be presented in the forthcoming EPA Environmental Assessment that a
public hearing should be scheduled in accordance with paragraph 3, Section 5.3.5
item (9) of the Commission's Priority System Procedures to determine whether
the project is needed.
We thank you for the opportunity to comment on this important subject.
Very truly yours,
The Board of Weld County Commissioners
Leonard L. Roe, County Commissioner
>
£ LLR: clb
00
ce Jonathan Rutstein, Larimer-Held Regional Council of Governments
Alan Herson, Regional Administrator, Environmental Protection Agency
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ATTACHMENT 3
LARIMER - WELD REGIONAL COUNCIL OF
PHONE (3031 6S7-3ZM
ROOM 201
2O1 EAST *th STREET
LOVE LAND. COLORADO COS37
May 25, 1979
Mr. Weston W. Wilson
Environmental Evaluations Branch
Environmental Protection Agency
Region VI11
1860 Lincoln Street
Denver, CO 50Z95
Dear Mr. Wilson:
RE:
DRAFT DIRECTIVE OF WORK NORTHGLENN ViATER MANAGEMENT PROGRAM -
FACILITY PLANNING/ENVIRONMENTAL ASSESSMENT
The Larimer-Held Regional Council of Governments through its staff and 208
Advisory Committee has reviewed the "Draft Directive of Work" for the North-
glenn Water Reuse Project and has a number of detailed comnents. The review
focused on the need to evaluate the Northglenn project in the context of a
major project which may create widespread impacts to both water supply and
water quality in the Larimer-Weld Region and affected portions of the South
Platte River Basin. The Council of Governments wishes to have a full dis-
closure of the Northglenn project; including justification of need for the
project for both water supply and water treatment and other related activities
to be undertaken by FRICO which are dependent upon the successful implementation
of the Northglenn reuse system. The concern in this regard has been amplified
by recent discussion on the project before the Colorado Water Quality Control
Commission, Weld County Government and tK- COG itself.
It has been extremely hard for the public and technical staffs to evaluate
the project because major features of the plan keep changing and in many
cases have not been sufficiently documented in writing to permit a detailed and
accurate assessment. We are in hopes that the effort currently being under-
taken by EPA will assist interested parties in quantifying and qualifying the
anticipated impacts of the project.
Attached to this Tetter is a detailed comment of the EPA "Directive of Work"
which Was prepared by a subcommittee of the Larimer-Weld 208 Advisory Committee.
RESPONSE:
EPA appreciates Larimer-Weld Regional Council of Governments
continued interest in the development of the Northglenn
Water Management Program Environmental Impact Statement.
Many of the major issues and complications of this
project are presented in the draft Environmental Impact
Statement which has been prepared pursuant to the EPA
Directive Work reviewed by the Larimer Weld Regional
Council of Governments. Specific work elements addressed
in the letter to EPA regarding the workplan are presented
below.
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Mr. Heston W. Wilson
Hay Z5, 1979
Page 2
We hope the information we have provided you will be helpful in structuring
an objective evaluation of the environmental impacts of the Horthglenn plan.
The Larimer-Weld COG looks forward to assisting you in the review of this
far-reaching project.
Very truly yours.
L. Princic
.irperson, LWRCOG
cc: Norman Carlson, Chairman, Board of Wald County Comnissioners
Gary Fortner, Weld County Planning Director
Tom David, Weld County Attorney
W. D. Farr, Sr., Chairman, larimer-Keld 208 APC
^ Rick Claggett, EPA 208 Project Officer
T Jim Brooks, EPA Construction Grants
H
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COMMENTS AND REVISIONS TO EPA "DRAFT DIRECTIVE Of WORK"
FOR NORTHGLENN WATER MANAGEMENT PROGRAM
PAGE
REFERENCE
(pp. 1-4)
(P-D
(p.2)
(p.2)
The comments which follow are recommendations for modification of the
"Directive of Work" submitted to the Larimer-Weld 208 Areawide Planning
Committee on 17 May 1979 by Region VIII EPA. These comments have been
prepared at the request of the EPA and represent a concensus of the
persons listed on the attached sub-committee list. These comments are
presented on behalf of the LWRCOG.
Statement of Work
(Comments on the overview statement.)
Please identify the contractor if known at this time.
Is the term contractor the same as consultant?
1. Existing Situation on Big Dry Creek
Assuming the work effort is "fact finding" in nature and designed to
identify the environmental impacts associated with the project, it is
recommended that the assessment cover Existing and Projected Situation
on the South Platte River System as it might be effected by implementation
of the Northglenn project. The assessment should be quantitative as it
relates to water flows, water uses and water quality within the effected
portions of the Big Dry Creek from Standley Lake, its canals and the
South Platte River from Denver Metro.
The questions of water supply, changes in points of diversion and basin
transfer of water threaten the entire prior appropriation doctrine of
water rights in Colorado and may also affect water quality.
NEED for the project as a water supply and waste water treatment project
should also be documented including a full disclosure of the overall
system and a summary of existing sources of water available to Northglenn,
possible alternative sources other than FRICO water and a justification
for the selected alternative.
2. Impacts to Agricultural Productivity
The quantitative analysis on water quality/quality changes should be com-
pared against three options, not just two. Other alternatives for water
purchase exist besides condemnation. Outright purchase should be clarified
and explored.
3. Public Health Impacts
The language in this overview should be expanded to reflect an assess-
ment of the quality and quality (existing and projected) of source water
for use, make-up and reuse in the proposed system. Effects on public
health should be analyzed including potential for adverse impacts to ex-
isting and anticipated water uses from nutrients (including nitrates),
bacteria, viruses, pathogens, heavy metals and formation of trihalomethanes.
2. EPA has retained the services of Engineering-Science as an
independent contractor to assist in the evaluation of the
Northglenn Water Resource Management Plan and prepare a draft
and final Environmental Impact Statement on the plan. Engineer-
ing-Science is not associated with any other element (con-
struction, operation or implementation) of the Northglenn plan.
3. Presented in the Environmental Impact Statement is a
quantitative assessment of the impacts the project will
have on water flows, water uses and water quality within
the affected portions of Big Dry Creek from Standley Lake
and the South Platte River. The questions raised by
Larimer-Weld Regional Council of Governments regarding
water supply, changes in points of diversion and hasin
transfer of water, and their effect on the prior
appropriation doctrine of water rights in Colorado, is
a subject which will be ultimately resolved in the water
courts. The need for the project as a water supply and
wastewater treatment project is developed and presented
in Chapter 2 purpose and Seed. A summary of the
existing sources of water available to Northglenn are
presented in the alternative section Chapter 3.
The inpacts to agricultural productivity have been
quantitatively analyzed for three options. The three
options include acquiring vater from nontributary wells,
tributary well fields,adjacent to the South Platte River,
and purchase or condemnation of FRICO water. Inpacts to
agricultural productivity are also evaluated for the
following vater supply options: obtaining vater from
the Denver Water Board, obtaining water from the Wind
Gap project, and obtaining water from Thornton. Data
deficiencies for these options results in a seil-ouantitative
assessment of agricultural productivity. These evaluations
are presented in the final Environmental Impact Statement
under the agricultural productivity section.
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-2-
6
PAGE
REFERENCE
(p.3)
(p.3)
(P-3)
Ui
8
(P.3)
(P-4)
Recommendations for mitigation should include changes in NPDES permit
conditions, major and minor design changes, or operational flexibility
required to mitigate adverse impacts.
4. Direct Impact of the Haste Water Treatment Facilities
b. Odor should be evaluated for both ability to meet state
regulations and objectionable levels which may currently be
below regulatory limits.
Other comments and additions to this section are included
in the detailed evaluation of Task E.
5. Public Participation Program
The following change is suggested:
"A full scale public participation program will be carried
out with initial direction from LWRCOG and DRCOG. All
responsibilities for carrying out the program will
rest with a public participation coordinator mutually
acceptable to LWRCOG and DRCOG. He will be pro-
vided assistance from the consultant and will follow
the provisions of 40CFR" Part 35 Sub-Part E, Section
35.917-5."
6. Recommendations
Please clarify the first sentence. Modify the second sentence as follows:
"The recommendations will consider the need for—
(d)
Further analysis of existing data,
Acquisition of new data and further study,
Changes in project operation or design which will
mitigate adverse impacts, and
Mediation between any parties having interests
in conflict and methods by which such mediation
could occur."
(In no way should the consultant or contractor be considered as
the mediator:)
Specifications
Add to Municipalities:
"Town of Frederick, Town of Firestone, Town of Dacono, City of
Fort Lupton"
Add to other Multipurpose Governments:
"Larimer-Weld Council of Governments"
"State of Colorado 208 Executive Committee"
Add to Other Federal Agencies:
U.S. Bureau of Reclamation"
Add to Special Purpose Districts:
Soil Conservation Districts and Rural Domestic Water Supply Organizations
{The contractor will have to check to see which ones are involved.)
8.
EPA has conducted all extensive analysis of the
public health impacts associated with the proposed Northglenn
Water Resource Vanag&rent Program. This analysis has ranged
from literature searches, consultation with noted authorities
in the field, and in-depth analysis of treatment technologies
and operational features of the plan. All of the impacts
and mitigation measures are presented in the final
Environmental Impact Statement under Operational Criteria
of the Proposed Treatment System, Public Health Aspects
of the Project, and Mitigation Measures for identified
public health impacts.
Chapter 4 presents an evaluation of the odor impacts
associated with wastewater treatment facilities. EPA
believes the information presented is suitable for
determining the odor impacts of the treatment facility.
Mitigation measures are addressed in the treatment plan
operation section of the final Environmental Impact
Statement.
, Early in the environmental review process of the Northglenn
project EPA requested public participation of all
vested interest groups including the Larimer-Weld Regional
Council of Governments and the Denver Regional Council
Goverments. During that process an attempt was made to
identify an acceptable public participation coordinator
that was mutually acceptable to both Regional Council of
Governments. Unfortunately, an acceptable coordinator
could not be identified and EPA's Project Officer took
the lead role as public participation coordinator.
Recommendations to EPA were made by the Contractor for
items a, b, and c and analyzed in the final EIS. The
need for mediation supplied at EPA expense has not yet
been determined.
9. All of these modifications suggested by Larimer-Weld
Regional Council of Governments were made to the
Directive of Work and are incorporated into the preparation
of the final Environmental Impact Statement.
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-3-
PAGE
REFERENCE
(p.4)
9
(p.5)
10
Ln
CO
11
12
(p.6 second
paragraph)
(p.7)
The last paragraph should be rewritten to reflect the following changes:
"The public participation program will involve at least the
contractor, Northglenn and its consultants, the cities of
Thornton and Westminster, Fort Lupton. the Towns of Fire-
stone. Frederick. Dacono. Adams County, Weld County, DRCOG,
LWRCOG, the Colorado State Health Department and other public
interest or special interest groups. A technical advisory
group will be established from knowledgeable representatives
identified above and other interested organizations.. The
function of the advisory group will be to advise the con^
sultant on alternatives to be considered and evaluate in-
formation developed in the course of the study."
(Possibly other functions acceptable to LWRCOG and DRCOG.)
2. Data Gathering Program - Studies
Add as a minimum the following studies and reports:
1. "Areawide Water Quality Management Plan for Larimer and
Held Counties, Colorado, and adopted revisions",
September, 1978, Larimer-Weld Regional Council of
Governments. Including supporting documents, spec-
ifically:
a. W.Q.M.P. Interim Report 15, "Institutional Inventories for
208 Functions", April, 1977, Briscoe, Maphis, Murray &
Lamont, Inc.
b. W.Q.M.P. Interim Report #17. "Institutional and
Financial Recommendations for Control of Pollutants trom
Non-Point Sources and Municipal and Industrial Point
Sources", January, 1978, Briscoe, Maphis, Hurray &
Lamont, Inc.
c. Letter of Plan certification by Governor Richard Lamm.
d. Letter of Plan approval by Regional EPA Administrator.
2. "Draft State Framework Plan for Hater Quality Management", April,
1979, State of Colorado 208 Coordinating Unit.
3. Quality of Reports
Please clarify the intent and purpose of the statement:
"The report will include specific actions dealing with
data needs and a land treatment/reuse evaluation of
the Clear Creek plans."
4. Period of Performance
Timing and number of advisory group meetings should be stated here. We
suggest at least four meetings.
Revise activities for end of 1st month to read:
identlfled b? ^riaer-Weld Regional Council
11.
The EPA acknowledges a typographical error in the draft
Directive of Work. The statement should read as follows:
"The report will include specific actions dealing with
data needs and a land treatment/reuse evaluation of the
Northglenn plan."
12. EPA has held and conducted two public participation
meetings in addition to three discussion panel meetings
to review and discuss pertinent issues of the Northglenn
Water Resource Management plan.
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-4-
12
13
14
"Initiate Tasks A and B and where possible complete Sub-Tasks
involving data collection and scoping meetings. Public
participation Sub-Tasks and data evaluation will be con-
tinuous."
(p.8) 7. Draft Reports
ALL participants should be provided copies of the Draft report by the
contractor or EPA. This should be done to insure that there is
reasonable concurrence by the advisory group before the report is
publicly distributed.
(p.8) 9. Miscellaneous Provisions
a. Personnel - Qualifications of the personnel involved should be
presented to assure compliance with the expertise required to do
the work - resumes should be prepared and submitted to the EPA
Project Officer.
(p.9) b. Meetings - Meetings requiring Advisory Committee members should be
scheduled to permit high attendance (evening meetings would be
preferrable and in a central location to the majority of committee
members).
(pp. 10-13) ATTACHMENT 1 (General Comments)
I. BACKGROUND
There must be an explicit description of the project which may become the
(_n subject of an Environmental Impact Statement.
The summary section here contains information which is not all documented
in the 201 Facilities Plan as submitted for public comment, the EPA
Negative Declaration prepared in September of 1978 or in other formal
documents prepared by the City of Northglenn for public review.
In order for the contractor and the public to evaluate the project
accurately, they must know the finite components of the proposed North-
glenn system and any associated activities by FRICO, Northglenn, West-
15 minster, Thornton and others which are dependent upon successful
implementation of the Northglenn project. The identification of these
issues must be considered an integral part of the environmental assess-
ment.
It is therefore recommended that a full disclosure of the proposal and
associated activities which may affect the feasibility of the project
completion be made. At a minimum it should cover the following areas:
(!) Need for the project - can Northglenn adequately be given waste
treatment service from existing service entities?
(2) Is the proposed water supply component of Northglenn's project the
only way to satisfy future water supply needs?
13. During the public participation process EPA provided
information to the public and discussion panel in the
form of the technical handouts as well as oral presen-
tations. The discussion panel group was requested to
provide to EPA their input into the preparation of the
Environmental Impact Statement.
14. EPA assembled qualified personnel, through consultants
and within its own staff, to perform the evaluation and
analysis of the Northglenn Water Resource Management plan.
Personnel included people who were noted experts in their
respective fields of wastewater treatment, agricultural
production, water quality, hydrology, water rights,
cost analysis and water supply. Meetings were scheduled
during the public participation process for maximum
attendance of all vested interests involved in the
Northglenn Water Resource Management plan.
15. EPA recognizes that much of the preliminary information
concerning the Northglenn Water Resource Management plan
was fragmented and it was difficult to comprehend the full
nature of the project. EPA further believes that the
final Environmental Impact Statement provides a full
disclosure of the proposed project and associated
activities. Elements relating to the needs of the project
are discussed in Chapter 2.
As discussed in Chapter 3, Alternatives, the proposed
project is not the only alternative whereby Northglenn
can satisfy its future water supply needs; however, it
has been demonstrated to be the most cost effective option
available to Northglenn.
The operational features and sources of water for the
proposed Northglenn system are discussed and presented
in the final Environmental Impact Statement.
Specific features such as the lining of the Bull Canal
have been previously addressed. EPA does not feel that
the Bull Canal lining is an integral part of the
Northglenn project but rather is an action being under-
taken by a private entity.
-------
EPA does not believe that there is any feasibility in
other entities participating in the proposed Northglenn
system at this time.
PAGE
REFERENCE
15
Ol
16
1i
(p.14}
(P-17)
18
(p.18)
-5-
(3) The sources, quantity, quality and distribution features (intra and
inter basin) should be identified plus any modifications to these
features through canal lining and inter-basin transfers of water by
purchase or exchange.
(4) The feasibility of other entities either participating in the
proposed Northglenn system or proposing similar water reuse systems
themselves.
(5) Sizing of all design components.
Sources of the information used in preparing the summary should be formally
referenced. For example, chlorination, to our knowledge, was only con-
sidered after the Negative Declaration was prepared and the question of
public health raised within the Larimer-Weld region. The specifics of
sludge disposal were not adequately discussed, only vague references
made to sludge usage in Northglenn. The size of the reservoir has varied
from under 5,000 acre feet to over 6,000 acre feet. The ability to
store and treat urban run-off, and Northglenn waste water and release it in
a timely manner has been discussed only generally. As well, tne
responsibilities of Northglenn for monitoring surface and ground water
quality at the treatment site and within the "reuse" portion of the
system have not been discussed and formally documented in the 201 Plan.
The ability of the City of Northglenn to successfully meet all EPA
conditions specified in the Negative Declaration of September, 1978, has
never been publicly disclosed.
II. 201/ENVIRONMENTAL ASSESSMENT STUDY TASK DESCRIPTION
The second paragraph should read as follows:
"The public involvement program is intended to comply
with the final public involvement regulations
published on August 7, 1978 (give citation). In
order to accomplish this..."
The public participation coordination should be under the immediate
control of EPA. This function should be funded entirely from EPA funds.
The selection of the coordinator should rest with DRCOG and LWRCOG to
maintain objectivity. In this scenario Northglenn would not be the
"grantee". EPA would maintain full control of all contracted activities.
Sub-Task A.2 Establish Advisory Group
EPA should explore a means of reimbursing the advisory group members for
expenses (travel, etc.) incurred in the review of the project.
EPA, through the contractor, should be responsible for establishing the
size and composition of the advisory group with the concurrence of
LWRCOG and DRCOG. Committee composition should be acceptable to Weld
County and the City of Northglenn.
Task B - Data Gathering
It is our understanding that this task will identify in detail the adequacy
of existing data and recommend future data gathering if required to sat-
EPA believes that similar wastewater reuse systems may
be feasible but it is not within the scope of this
Environmental Impact Statement to speculatively identify
or address the development of such plans.
The sizing of plan components is presented in the final
design of the proposed wastewater and water supply systems.
The sources of information utilized within the
preparation of the Environmental Impact Statement are
appropriately referenced.
The final Environmental Impact Statement does present a
discussion of the sludge management plan for the Northglenn
project which is presented in Chapter 4.
The size of the reservoir has varied due to variations
in the amount of water that would be stored. The actual
storage volume of the reservoir has been designed based
on the need to store Northglenn's wastewater, the urban
stormwater runoff and capacities required to provide
storage for the FRICO water exchange.
The release of discharges will vary annually and the
determination of timely releases is part of the operational
features of the project. Therefore it is not possible at
this time to specifically comment or develop that program.
Northglenn is committed to developing and implementing a
surface and groundwater monitoring program both adjacent
to the treatment site and within the reuse areas of the
project. This information is presented in the mitigation
section of the EIS.
EPA attempted to coordinate the public participation program
with the Denver Regional Council of. Governments and the
Larimer-Weld Regional Council of Governments. That
effort did not result In the Identification of mutually
acceptable public participation coordinator. Consequently,
EPA designated the Project Officer as the public participation
coordinator.
17. The problem of providing reimbursement for the advisory
panel members was not raised by the panel. EPA
believes that the selected advisory panel represented
most of the various vested interest groups and was
acceptable to Weld County and the City of Korthglenn.
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-6-
PAGE
REFERENCE
(p- 18)
•J8
(P-19)
19
Ul
O1
(P-20)
20
isfactorily answer questions involving "primary impacts".
Sub-Task B.I
1* 's assumed that the responsibility of gathering information is the
burden of the proposers of the project and EPA's consultant for the
environmental assessment. The information gathered must be
objectively presented. Where questions of objectivity are raised,
the consultant, advisory group and EPA should evaluate the information
and recommend future required actions.
Task C - Define Impacts to Agricultural Productivity
The scope of this task should be all portions of the South Platte River Basin
affected by the consumptive use, inter-basin transfer of water (including
effects to groundwater recharge by drying up land) and water quality changes
anticipated by implementation of the project. These impacts should be com-
prehensively discussed for their long and short-term impacts to agricultural
production and agricultural land conversions. The discussion should include
reduced or increased productivity to individual crops, possible limitations
to kinds of crops grown due to conversion from irrigated to dry land farming,
and possible constraints placed on production from degraded water quality.
Sub-Task C.I b. Water Quality
This task should be amplified to include an analytical discussion of
the specific water quality parameters, if any, which may restrict the
types of crops grown or impair crop usage for human or animal consumption.
Sub- Task C.I c. Economic Changes (suggested new task)
It is recommended that this sub- task be made a separate task of equal
standing to other tasks listed. It should appear prior to the existing
Task C. It should contain a discussion and analysis of all economic
changes not just agriculture. The scope of the task shouTd" reflect costs
and benefits to agriculture, municipal water uses (including capital
investments and operations and maintenance), land use changes, etc.
If it is possible to model parts or all of this economic analysis with
an existing input/output model, reference the source model. If a new
mode1 "i11 be constructed for this purpose, it will most likely be costly
and time consuming - please clarify this activity.
Sub-Task C.I d. Land Use Changes
This analysis should be done for several frequency level dry years, to
determine severity of problem.
Sub-Task C.2
These impacts should be compared against each other as
solutions".
18- for ^ "8 C0nsultant ha« collected all pertinent data
Determi P"paratlon of the Environmental Impact Statement.
f±^r^??-"-^«on ZXZXf
20.
19. The agricultural productivity analyst;
and short term impacts to agriculture and agricultural
X=;,'T; ™ SHL'XS :~bi
..
s
3-
water supply sources other 'than the FRICO syste^
'least cost
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-7-
201
21
PAGE
REFERENCE
(p-21)
(p.22)
T
M
Ui
22
23
Sub-Task C.2 b
Modify this task to also reflect the impact to Horthglenn with and.without
a FRICO water supply, (ie. other sources of water.)
Task 0 - Public Health Impacts
The environmental assessment should also reflect the possible distribution
of effluent reuse run-off waters in the Bull Canal system as they might affect
the Towns of Firestone, Frederick and Dacono, including possible mitigation
measures and associated costs. The public health impacts and future use of
Bull Canal waters for public water supply should also include an assessment
of the possibility of effluent in Bull Canal inadvertantly reentering the
Lower Boulder Extension Ditch which is a potential public water supply
currently being considered by the City of Fort Lupton.
An assessment of the existing quality of water in both the Bull Canal-and
Lower Boulder Extension Ditch should be prepared. It should reflect the
suitability of existing waters for public water supply.
The general costs and limitations on improving these waters to meet drinking
water standards for both the existing and projected situation should be
prepared and analyzed.
Task E - Analyze the Direct Impacts of the Wastewater Treatment Facility
Sub-Task E.I - add the following language:
"Determine the potential for shallow and deep ground water
quality changes..."
Sub-Task E.2
Include comment on p.3 #4 previously discussed.
Add the following new sub-tasks following E.5:
" Sub-Task E.6 Evaluate the adequacy of the proposed reuse
system in meeting criteria for "alternate
or innovative waste treatment technology" in
the context of current EPA guidance and
regulations, and State of Colorado Water
Quality Control Comnission policy on water reuse,
including recommendations of the July 20, 1977
"Report of the Task Force on the Land Application
Treatment of Waste Water to the Governor's Science
and Technology Advisory Committee". Make a
determination as to whether the project is con-
sidered eligible for EPA 201 Construction Grants
monies and the level of EPA participation in funding.
Sub-Task E.7 Determine flexibility of proposed system to meet an
anticipated range of treatment requirements for BOD,
SS; also nutrient levels, synthetic compounds, heavy
metals, viruses. Examine feasibility of add-on treat-
ment processes to proposed system for removal of
problem pollutants in the event that NPDES permit con-
ditions are changed for BOD, SS, and fecal coliform
limits.
21 As stated previously, public health impacts have been
evaluated in detail. EPA did not feel it was within the
scope of this project to determine the cost and limitations
of improving the various affected vaters in the project
area as to their ability to meet drinking water standards.
22. EPA has reviewed and evaluated the Northglenn project
in the context of its ability to meet alternative and
innovative waste treatment technology. Additionally
the Colorado Water Quality Control Commission's policy
on water reuse has been taken into consideration in the
determination of grant eligibility. Based on its total
environmental and economic analysis of the system, EPA
has determined that the Northglenn Wastewater treatment
element of its water resource management plan is eligible
for construction grant monies. This analysis is presented
in Chapter 6.
23. A comprehensive analysis of the Wastewater treatment
system has been prepared and is presented in Chapter 4.
This analysis did consider the flexibility of the
proposed system to meet the anticipated range of
treatment requirements and also alternative methods for
ensuring compliance with Northglenn's NPDES permit.
However, additional add-on treatment processes were not
considered as a feasible method of achieving NPDES permit
conditions due to the excessive costs of such processes.
Alternative mitigation measures have been considered
and are presented in the EIS.
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-8-
PAGE
REFERENCE
24
25
(p-23)
26
Ul
oo
(p.23)
27
28
Sub-Task E.8 Assess the need for, and recommend options for
remedial action plans in event of system failure
or inability to meet NPDES permit conditions or"
other limitations placed on effluent discharge.
Sub-Task E.9 Assess the, need for continual short and long-term
water quality monitoring at the lagoon site and through
the Bull Canal system to protect public health
(including potable water supply, agricultural use,
secondary contact)."
Sub-Task E.10 (formerly Sub-Task E.6)
Responsible Party:
It is assumed that the term "the consulting engineer" refers to the
contractor responsible for completion of this Environmental Assessment.
Task f - Assessment of Cost-Effectiveness Analysis Between Alternatives (New Task)
The project should be reassessed for cost-effectiveness. This project should
be evaluated against previously considered alternatives in light of the
potential impacts identified in the environmental assessment. The analysis
should reflect compliance with the most recent EPA guidance including PRM's
and Federal Regulations on cost-effectiveness analysis for land application-
reuse systems.
(EPA may wish to expand the scope of the proposed new task)
Task G - Recommendations (formely Task F)
Sub-Task F.I
Add "6. economic impacts" to the non-inclusive list.
Sub-Task F.2
Change language to read:
"Need for changes in project. If adverse impacts are
documented in Tasks C, D, E, F, then recommendations
for project modifications through location, design,
operation characteristics, monitoring or development
of new project alternatives will be made.
Sub-Task F.4 Recommendations for the substance of inter-
governmental agreements - the duly adopted Larimer-
Weld 208 Water Quality Management Plan requires
that entities constructing, operating and
maintaining waste treatment facilities within its
planning boundaries will negotiate intergovernmental
agreements to define the relationship between these
operations functions and water quality management
functions by designated management agencies approval
by EPA and the State of Colorado. .Recommendations
for the general substance of an intergovernmental
25.
th vPnr* 6Vent °f SySt£m failure or a Violation
the NPDES permit conditions and other limitations
nal V>n1emUent,di8Char8e8' «e discussed in the
nal Environmental Impact Statement. Such
of
of
final >n1eUent,di8Char8e8' «e d
final Environmental Impact Statement. Such plans
der°usprtlonal controis to
As part of the grant conditions Northglenn is required
to implement a water quality monitoring program of
surface waters and goundwaters adjacent to the treatment/
bv th fn6 BUU Canal and °ther wacers i°>P*«ed
in the li ?T'< "°ni«ring program is presented
in the final Environmental Impact Statement in Chapter 5
26. An extensive cost effective analysis of the alternatives
for wastevater treatment has been developed by EPA using
the multi-purpose cost analysis process. This analysis
is presented in the final Environmental Impact Statement
The two vastewater treatment alternative systems include'
the Denver Metro Plant using Northglenn's pro-rata share
of the costs and the proposed Northglenn wastewater
treatment facility.
27. EPA believes it has documented all significant adverse impacts
associated with the Northglenn Water Resource Management
Plan. Chapter 5 presents proposed and accepted mitigation
measures to eliminate the identified adverse impacts.
28. This evaluation and analysis is presented in the draft
Environmental Impact Statement.
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-9-
agreemerit between the City of Northglenn as an
operations agency and Weld County as a management
agency will be made.
Sub-Task F.5 (formerly Sub-Task F.4)
The Larimer-Weld Regional Council of Governments reserves the right to
provide additional comnents to EPA on the "Directive of Work" and to
conment on subsequent Scopes of Work prepared for consultant activities.
Ui
\0
5/25/79 - revision 5/29/79
-------
SUB-COMMITTEE TO REVIEW NORTHGLENN WATER MANAGEMENT PROJECT
Northern Colorado Water Conservancy District Offices
May 21, 1979
7:00 p.m.
W. D. Farr, Sr., Chairman Chairran, Larimer-Weld 208 APC
Darryl Alleroan ' Utilities Director, City of Greeley
Curt Miller Senior Staff Engineer - City of Fort Collins
Henry P. Caulfield Fort Collins Greenbelt Association
Hartelle Nussbaumer Fort Collins - League of Women Voters
Leo Berger Farmer, Weld County and representative of
National Association of Soil Conservation
Districts
Dwight Holter Attorney, Kodak of Colorado
t>
I Richard Beaver Chemist, Colorado State University
I-1
g Irma Princic Chairwoman, LWRCOG
Staff
Larry Pearson Director of Comprehensive Planning LWRCOG
Terrence L. Trembly 208 Project Manager, LWRCOG
Gary Fortner Planning Director, Weld County
-------
rranois K. Vjnlkin
Attorney at Law
720 So Color Jo BWJ.
Denver. Colorado 80222
303-758-1105
February 29, 1980
Mr. Roger Williams
Regional Administrator
H. S. Environmental
Protection Agency
1860 Lincoln Street
Denver, Colorado 80203
Dear Mr. Williams:
\\
J U
MAR04 1980 ! . ,i
EPA REGIC.'I VIIIIHJ
Division
This letter, written on behalf of my clients. The Town of
Frederick, The City of Fort Lupton and the Weisner Sub-Division
Preservation Association, is to provide you with our comments
regarding the Draft Environmental Impact Statement of Northglenn
Water Management Plan. Although the period for public comment
has expired, Mr. Wes Wilson, Project Officer, kindly extended to
me an additional five days within which to submit these comments.
My clients believe that the initial procedures surrounding the
issuance of the draft EIS were inadequate and contrary to the
regulations of the Council of Environmental Quality, which are
binding on every federal agency, including the Environmental
Protection Agency. As you are well aware, these regulations
require that following a Notice of Intent to Prepare and
Environmental Impact Statement, a "scoping" proceeding is to be
held to allow public comment on the areas to be addressed in a
draft EIS. This procedure was not followed in the present matter;
the Notice of Intent to Prepare an EIS was issued simultaneously
with the prepared "draft," this draft being nothing more than
the Environmental Assessment issued in November with a new
cover and a suggested decision.
The CEQ regulations clearly indicate that a draft EIS "shall be
prepared in accordance with the scope decided upon in the
scoping process." (40 C.F.R. 1502.9(a)). This language makes
it clear that a draft EIS is not to be issued until the "scoping
process" has been completed. My clients and other interested
persons were at no time notified of a scoping process and in
particular, that such a process would be undertaken in such an
irregular manner, if it took place at all.
o*X &"> .,.
->A KA0>R£ ^ ,. fcdL
RESPONSE:
The issue of compliance with the scoping process was subject
to litigation in Consolidated Ditches Company, et.al, vs. EPA.
The issue was settled by mutual written agreement between EPA
and these parties on June 2, 1980. It is EPA's position that
during the last two years of review by our agency; the environ-
mental assessment, gublic meetings and numerous phone calls
regarding the Northglenn proposal were sufficient to satisfy
the intent and purpose of the public scoping process required
under recent regulations promulgated by the Council on Environ-
mental Quality.
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N>
Mr. Roger Williams
February 29, 1980
Page Two
My clients have not been afforded the time to prepare comments
on the "draft EIS" as contemplated by the CEQ regulations in
that no adequate or regular scoping process was carried out to
determine the particular areas of concern to be addressed by a
draft statement.
In addition to the irregularities and inadequacies that surround
the present matter with regard to required Agency procedures,
numerous other concerns regarding the "draft EIS" have been
expressed by my clients. In our opinion, these concerns need
to be resolved by the EPA, rather than merely addressed by an
EIS.
The comments received at the 13 February 1980 Public Hearing on
the Northglenn Project indicate that a vast array of concerns
continue to trouble those who will be affected by the project
should it be completed. The Director for Utilities for the City
of Thornton, Mr. Palmer, expressed his opinion that the project
is unnecessary, that Thornton can adequately supply Northglenn
with its water requirements, and that the water from Thornton
is sold at the same price to Northglenn as it is to its own
residents. Mr. Palmer's comments illustrate the point that
little investigation has been made of alternative systems.
The CEQ regulations clearly provide that a draft EIS "should
present the environmental impacts of the proposal and the alterna-
tives in comparative form" in order to provide a clear basis for
choice among options. (40 C.F.R. 1502.14). This regulation also
mandates an Agency to "rigorously explore and objectively evaluate
all reasonable alternatives" and to "devote substantial treatment
to each alternative considered in detail including the proposed
action."
Other alternatives to Northglenn1s proposed exchange program
with FRICO have not been adequately addressed by the "draft EIS"
and consequently no informed recommendations concerning possible
alternatives were made.
My clients have some particular concerns which deserve special
comment. The "draft EIS" states that... "the frequency of any odor
problems for residences near the proposed lagoons will be small."
However, much of the information upon which this statement is based
was gleaned from the Northglenn engineer only. My clients, particularly
the Weisner Sub-Division, believe that an independent study should
be undertaken in this case.
Further, the draft notes that, with regard to drinking water
supply, the EPA "recommends that Frederick explore other options
to satisfy future water supply demands" because present potential
water supplies are now classified solely for agricultural use.
My clients do not believe that this issue has been fully addressed
EPA presents in the final Environmental Impact Statement
a rigorous and objective evaluation of all reasonable
alternatives both for water supply and wastewater treatment
for Northglenn needs. This analysis is presented in the
alternative evaluation section of the final Environmental
Impact Statement. Extensive consideration is given to
water supply alternatives which do not involve the
exchange programs.
3. EPA has conducted an independent analysis of the potential
for odor generation at the lagoons and reservoir. EPA
recognizes that there is considerable difficulty in
identifying the events necessary to create an odor
episode and to further provide mitigation measures for
any individual event. EPA believes that there is a
likelihood of an odor event occurring at the treatment
site as a consequence of the facilitiy's inability to
meet proposed suspended solids requirements. The circum-
stances surrounding such an event would be associated with
large algae blooms in the reservoir which during decom-
position could result in the generation of odors. The
actual odor event itself and its frequency cannot be
determined at this time and mitigation measures to
control algae production as part of the operational
features of the proposed plan will in effect be mitigation
measures for odor episodes.
4. Refer to response to comment Number 1 to the Town of
Dacono letter dated February 18, 1980.
EPA concludes that since the Canal is not presently
used for a domestic water supply, nor has there been
any formal request to designate the Canal for domestic
water supply, there is no need to protect the Canal
for water supply.
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U)
8
Mr. Roger Williams
February 29, 1980
Page Three
by the EPA, and that, although the water supply is presently
classified for agricultural use, Frederick should not be
forever foreclosed from pursuing the most viable water supply
it has until the area is fully explored.
In addition, the draft states that "data to calculate the
increased nitrate concentration in Sand Hill Lake are currently
not available." My clients. Fort Lupton in particular, are
concerned with potential nitrate levels and believe that further
study in this area is warranted.
According to the draft, residential property values in the area
of the proposed plant will decrease by at least five percent.
This may appear to be a minimal amount, but to my clients who
reside in close proximity to the proposed site, five percent
is certainly more than minimal, particularly in a. time of rising
home costs. My clients believe that the issue of devalued
property should be more fully explored.
My clients and I are aware, as the draft confirms, that Northglenn
may build the proposed plant whether or not federal funds are
granted. Such an action is contrary to CEQ regulations which
indicate that no action shall be undertaken, except for plans and
design, that will "have, an adverse impact" or "limit the choice
of reasonable alternatives." (40C.F.R. 1506.l(a) (1) (2)).
If such adverse action is taken before the Agency's NEPA process
is complete, the Agency is obligated to notify the applicant
that the Agency will take "appropriate action to insure that
the objectives and purposes of NEPA are achieved." (40 C.F.R.
1506.l(b)). It is clear that any encouragement by the EPA to
Northglenn regarding commencement of the project is contrary
to the CEQ regulations, particularly when alternatives, remain
to be investigated.
Although my clients expect to make further comments when an adequate
draft, preceeded by the required "scoping process," is completed,
we would request at this time the following action from the EPA:
1. That a scoping process as required by CEQ
regulations be instituted.
2. That a draft EIS by prepared based upon this
scoping proceeding and such other information as is
necessary to prepare such a draft.
3. That Northglenn be informed that any construction
of the project before the NEPA process is completed
is contrary to CEQ regulations.
5.
6.
EPA does not believe that any further analysis of
nitrate concentrations in Sand Hill Lake would prove
meaningful at this time. This is because sources of
nitrate contributions to Sand Hill Lake cannot be
effectively segregated. The primary vater supply
source to Sand Hill Lake is Boulder Creek and irri-
gation return flows with some infrequent discharges
from the Bull Canal terminal reservoir. The inter-
mittent contribution of water into this system from
the Bull Canal has an insignificant effect on
nitrate concentration.
EPA acknowledges that property values in the area adjacent
to Northglenn1s wastewater treatment plant may decrease
in value as indicated in the response to Northglenn's
7.
letter, comment Number 9. EPA further r
decreases in adjacent land values will v
area. These changes in value are in fac
result of public perception and acceptan
EPA does not feel that further analysis
necessary at this time.
cognizes that
ry from area to
largely a
e of the facility.
f this issue is
8.
EPA is aware of all appropriate CEQ regulations as they
apply to the Northglenn project. Further EPA has not
encouraged Northglenn to commence with the project
until the Environmental Impact Statement has been completed.
Additional alternative analyses have been prepared for the
final Environmental Impact Statement.
See response to Item 1.
A draft EIS has been prepared and distributed for comment.
A public hearing has been held on that draft Environmental
Impact Statement. A final Environmental Impact Statement
has been prepared and submitted for review. A final
public hearing will be held on the final Environmental
Impact Statement.
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Mr. Roger Williams
February 29, 1980
Page Four
My clients are anxious to see that, through proper Agency action,
the concerns expressed here are resolved. We are willing to
cooperate with you as fully as possible in bringing this matter
to a satisfactory conclusion.
Sincerely,
FRANCIS K. CULKIN
FKC/bja
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My name is Albert Watada and I represent the Consolidated
Ditches, consisting of 12 ditch's, which irrigates over 60,000
acres along the South PlatttRiver.
This ooiization was incorporated on 12th day of March, 1902.
The five executive board members consist of Delbert Shable,
George Steiber, Antone Heit, Elton Killer and myself.
Of the five men board four of us are in third generation
farming and one in second generation. Therefore each one of us
has deep roots along the South PlattS River. We have pride of our
long heritage in the soil that brings food to your table. At this
time we feel the comments on your impact statement is not all
correct, and we will not accept your comments with creditability.
(1) CHAPTER 4, page 56 of evaluation & alternatives.
Nitrogen on sugar beets; management of water application to
^
sugar beets will be necessary to satisfy Great Westerns contractual
agreement. Also, the comment on high nitrate in silage. I do
hope your not telling u£ farmers how to make money. I would like
to point to you optimum yield in any crop generally means better
chance for profit. This means timely application of balance
fertilizer and not by management of water as stated on page 56.
The remarks that is made on this page has pu£zzled a farmer like
myself, we pay high fee in hiring consultant and have put in many
years of hard and coatly experience in farming, and we open this
book on page 56 Mr. Wilson of EPA suggest management of water
application is key to our fertilizer application. I call this
>»over educated remark".
(2) Acuoi'dijjy—to Agricultural Land Conversion in Colorado;
The conversion of agricultural land to nonagricultural
uses is receiving increased attention throughout the nation and
world, from scientists, farmers, government officials, and other
RESPONSE:
1. EPA acknowledges the views of Mr. Albert Watada
and appreciates his inpuc into the preparation of
the final Environmental Impact Statement.
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T
M
ON
concerned citizens. "Agricultural land conversion is a serious
problem in Colorado", The bulk of our farmland and cropland
losses have occurred along the Front Range where 80 percent of
the state's population is located.
Forty percent of all Colorado agricultural production takes
place alondfJtlt front range. Weld County alone accounts for
30 percent of the state's agricultural sales. Weld County's
total agricultural sales of over 600 million t placed third
amoung all counties in the nation and bulk of that comes from
farm along the South Platt. 1/3 of this is exported to help
the balance of trade. We need this balance of trade in order
to help our energy problem until I this nation can be independent
of the fuel problems. What other commodities can match this? We
will not be able to accomplish this with alternatives that is
suggested to us farmers^ by E P A. In addition to the cost in
loss of food production, the Front Range stands to lose very
important environmental benefits if agricultural water conversion
continues unabated. Agricultural land • provides open space for
maintaining air quality, wild life habitat and uncluttered
visual lines—benefits which will become increasingly important *
as population growth continues. This cannot continue if the
pattern of taking prime agricultural land out of product:on.
After all the benefit of clean air is provided by agricultural
land at no cost to the municipalities.
In the end the issue will not only be of taxpayer and consumer
of Northglenn but a problem of agricultural issue and of the
nation. This is environmental and agricultural impact.
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Summary of Draft EIS Public Hearing Record
•February 13. 1980
Northglerm Community Center
EPA Hearing Officer - Mr. Fred Huff
Multi-Regional Council
Co-Hearing Officer - Mr. Tom Speicher
Regional Council's Office
Project Officer - Mr. Western Wilson
Water Division
Summary of Oral Testimony
The following is a summary provided by EPA of each presentation.
The complete transcript of these proceedings is available for public
review in the EPA Library at 1860 Lincoln St., Denver, Colorado, between
the hours of 8:30 am and 4:00 pm, Monday thru Friday.
i) Adolph Boh lander. President, Farmers Reservoir and Irrigation Co.
(See letter dated February 2i, 1980.)
Mr. Bohlander does not agree that the water will not be suitable
for raw edible vegetables. FRICO has been using water similar and not
as highly treated from the South Platte River and has grown all crops
without restrictions and have had no ill effects. If water quality is
so bad and FRICO can't use it, FRICO may not loan the water to
Northglenn.
2) Dave Pampau, Deputy Executive Director of the Denver Regional
Council Of Governments
(See letter dated February 25, 1980.)
DRCOG generally supports the Northglenn proposal.
3) Charles Sabodos, Town of Dacono
(See letter dated February 18, 1980 from Mayor Elliott.)
The Town of Dacono emphatically rejects disinfection of their water
supply. Raises questions on odors in Dacono 's reservoir.
4) Sherman Lyon, Town Board of Firestone
(See letter dated February 13, 1980 from Mayor Becker.)
The need for the facility has not been definitely proven. The
proposed holding ponds (tailwater control ponds) are inadequate and need
to be extended to protect all of section 19. Nitrate pollution of the
Bull Canal is contrary to mandate set by Congress for EPA. In light of
these questions, Firestone strongly opposes the construction of the
Northglenn facility.
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5) Gary Palmer, Director of Utilities for the City of Thornton
. (See letter dated January 31, 1980 from Mayor Carpenter.)
Read letter of January 31, 1980, then read letter of November 26,
1979 from Wes Brown, Chairman, Thornton Utilities Board to Mayor-elect
Barry provided as attachment to comments by Larimer-Weld COG (see COG
letter of February 25, 1980).
Read resolution passed by City of Thornton on February 11, 1980
(see attachment to Larimer-Weld COG letter of February 25, 1980).
Additional issues: After Thornton discovered there was a problem
with nitrates in their water supply, they corrected it. This problem
was discovered after Northglenn decided they wanted their own utility
system. It is difficult to understand how this could be a major reason
for Northgletm to go off of Thornton's system.
6) Pamela Mulhall, Assistant to the Director of Public Works, City of
Westminster
(See letter of February 11, 1980 from Mayor June.)
Generally supports Northglenn's plan.
>• 7) Greg Hobbs, Attorney, Davis, Graham and Stubbs, representing
I Consolidated Ditches and Rocky Mountain Fuel Company
^ (See letter dated February 13, 1980.)
oo
Indicates that project will adversely affect front range
agriculture. Why not provide further development of Colorado River
water? The proposal is not very innovative as Consolidated Ditch has
been reusing effluent for years. Called upon EPA to objectively study
the alternatives of either obtaining water from Denver, continuing with
Thornton, or developing west slope alternatives. Wants to see "status
quo" retained as much as possible. Condemnation is a strawraan and would
not happen because it is not politically viable. Condemnation was
simply set up to propel project.
Discusses lack of scoping process and failure to include water
supply alternatives.
Requests EPA to come out with a decision that says that no action
alternative is the alternative that is best for Northglenn and for those
that must live with Northglenn.
Submitted two volume deposition of Mr. Richard Lundahl for the City
of Northglenn wherein Mr. Hobbs indicates that Mr. Lundahl indicated the
City had not explored alternatives to a water supply. Distressed to
find out that Northglenn had already starteo construction of Standley
Lake pipeline and water treatment plant.
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O\
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8} Hr, Gerald R. Armstrong, President. Rocky Mountain Fuel Co. (RHFCo)
(See two letters dated January 17, 1980.)
RHFCo owns 1760 acres in Southern Weld County and 72.17 shares of
the Standley Division of FRICO. Indicates how valuable crop production
is on his company's property. They are the largest non-municipal
stockholder in FRICO.
Seeks to protect the quality of water his company is entitled to.
There are shareholders who have never consented to the proposal and
RMFCo has stated their refusal to consent to the exchange proposal. The
Advisory Panel process was a sham. As a panelist, information was
denied him. The use of the Freedom of Information Act was necessary to
get some information. EPA staff was prejudiced in favor of Northglenn's
proposal.
Discusses letter of January 17, 1980 to EPA regarding location of
proposed tailwater ponds on RMFCo property. Current appraisal of his
company's land in Frederick is $4000/acre. Should Northglenn Project be
approved, it could drop to $800/acre. How does EPA justify devaluating
somebody's land?
Issue of project on coal mining was not addressed in EIS. Cutting
county tax base, getting cities in to agriculture business and affecting
the quality of life should not be done.
9) Albert Viatada representing Consolidated Ditches
(See undated written statement located at the end of written
comments
section.)
10)
Raymond Hogan, water resources engineer with W.W. wheeler and
Associates, Inc. representing Consolidated Ditches
(See statement dated February 20, 1980.)
11) Mr. Thomas 6. Sanders, Professor Sanitary Engineering, Colorado
State University
Indicates expertise of person doing the EIS lack, education in areas
of public health and sanitary engineering. Regarding high nitrate
concentration in Bull Canal after project completion, Hr. Sanders says
while that makes its use for drinking water expensive it should not be
considered a viable source for drinking water because the source is
sewage effluent. There is potential to transmit man's viruses. Makes
comparison with problems in Egypt due to sewage in irrigation ditches
and his reconmendation while consulting there was to get sewage out of
irrigation ditches. Suggests western slope and Thornton supplied
options be considered. Does not feel that limit of 200 fecal count per
100 ml is sufficient for this type of system, particularly because this
system will set precedents. Would rather see stricter standards similar
to the State of California (i.e. around 2 total coliform counts per
100 ml). Colorado has a problem and needs to set a standard in this
regard.
RESPONSE: 1. EPA concurs with Dr. Sanders assessment that drinking
water supplies should not be permitted with wastewater
which has received secondary levels of treatment. Currently
the Bull Canal is not designated as a water supply source
by the Water Quality Control Commission. EPA concludes
that since the Canal is not presently used for a domestic
water supply, nor has there been any formal request to
designate the Canal for domestic water supply, there is
no need to protect the Canal for water supply. In ref-
erence to evaluation of West Slope and Thronton water
supply alternatives, an evaluation of these options is
presented in Chapter 3. With regard to the 200 per 100
milliliter fecal coliform requirement, EPA believes that
sufficient protection to public health is provided with
this discharge requirement on Northglenn's wastewater
effluent. This decision is based on expert evaluation
of Northglenn's treatment system and storage reservoir
and the ability of this system to significantly reduce
pathogenic organisms. EPA further believes that data
are insufficient at this time to impose stricter standards
similar to the State of California. EPA will in the future
be establishing criteria for systems similar to the North-
glenn water reuse management plan and be presenting these
criteria to the Colorado Water Quality Control Commission
for consideration of incorporation into the state's water
quality standards.
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Suggests that rather than trying to answer question of whether the
plan will receive water court approval, that all possible court
decisions be reviewed and what effects they may have on plan. Supports
proposed review of treatment process and possible additions to the
treatment process, as he does not believe the effluent quality will meet
the 30/30 BOD and suspended solids requirement. Suggests study of
additional filtration and coagulation.
Suggests intensive investigation of energy needs and comparison to
more conventional treatment systems. Suggests an analysis of the plant
operational plan. Suggests research on impacts of use of effluent on
agricultural soils. Might productivity decrease due to change in clay
soil matrix? Sludge plan and options should be addressed. What would
Colorado's response be if Northglenn funds project without EPA grant?
State does have authority through NPDES requirements to take EPA
proposed conditions and force it on the permit process. There is a
problem with a lack of resources and manpower within the Colorado Health
Department to control and efficiently operate such facilities as this.
Requests that EPA and State develop comprehensive water quality
criteria standards and guidelines associated with the reuse of sewage.
i2) Mr. Bill Schuler, Rocky Mountain Consultants representing the Town
of Frederick
(Read letter of February 12, 1980 from Mayor Hall.)
13) Mr. Ed D'Orazio, resident of Frederick, Colorado
Read statement by Mr. Joseph D'Orazio.
(See undated written comments at end of comments section.)
14) Mr. Gary Miller, Thornton High School student
Is conducting a science project dealing with the ecology of Grange
Hall Creek. EIS contains very little on impacts and costs of the
proposed Stonehocker Reservoir. Wants to know what precautions are
being taken to preserve the stream environment during and after such
construction.
15) Mr. Harold Hodges, resident of the City of Northglenn
Same questions are asked over and over again as in previous
Northglenn hearings. Is Northglenn to become the "snaildarter" of the
West? Same people who cried over the issue of the snaildarter are using
the same tactics to defeat the most progressive water resource program
in the nation. This is a turf issue, your neighborhood versus my
neighborhood, rather than looking at it as beneficial to both Weld
County and Adams County. Agrees with concerns on crops and reuse
issues. EPA never addresses issue that Clear Creek has mine dumps and
sewage in it and is not pure water. Maybe it is time for Northglenn to
go alone. EPA has sufficient information now to make decision. Does
not understand why the exchange agreement between two private parties
can come~under the auspices of the EPA statement.
RESPONSE:
RESPONSE:
2. At this point in time in the development of Northglenn*s
water resource management plan, Northglenn has made the
determination not to proceed with the proposed Stonehocker
Reservoir. If at some point in time this reservoir be-
comes integrated into the overall plan, Northglenn will
be required to acquire a Corps of Engineers 404 permit.
At such time EPA will review the 404 permit for the
Stonehocker Reservoir and make a determination of the
impacts associated with the reservoir. Therefore, it is
not within this EIS to assess the impacts associated
with the proposed reservoir.
The intention of the Environmental Impact Statement on
Northglenn Water Resource Management Plan is not to
create an aura similar to that of the snail darter that
was associated with the proposed Teleco Dam project.
The intent is to provide a full disclosure of the
Northglenn plan and its impacts and measures necessary
to mitigate the identified significant adverse impacts.
Through this process the views and opinions of the
various vested interest groups associated with the project
are evaluated. Both pros and cons for the project are
presented, considered and evaluated in EPA's decision
making process. EPA does not agree that this is a turf
issue, but rather it is an innovative technology which
has come under the scrutiny of various public and private
interest groups. EPA does not believe that it is in the
purview of their Environmental Impact Statement to evaluate
the various water quality problems associated with Clear
Creek. Furthermore, EPA makes its decision as to Northglenn1
grant eligibility after adequate detailed information is
presented to the public and comments are received and
technical evaluations are made. EPA must consider the
FRICO-Northglenn water exchange program as part of its
review of Northglenn's total water resource management
plan because it plays a key integral part in the development,
operation and implementation of Northglenn's plan.
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If Denver Metro permit allows 1000 fecal per 100 ml, why not same
standard for Northglenn? Doesn't think crop restriction is necessary as
there are no heavy metal sources from Northglenn. Requests that
methodology or formula for indicating there may be a five percent
reduction in property values be stated. What does leap frog development
pattern do to the agricultural values?
16) Levi F. Siebert, resident Ueisner Subdivision
Would like answers regarding the five percent property
devaluation. Appraisal on his home was $160,000 in February 1979, down
4 to $134,000 by February 1980. The latter appraisal included the
suggestion that he could never sell it for that because of the proposed
sewage treatment facility.
17) Phillip J. Hatch, Program Manager for Environmental Affairs for the
Great Western Sugar Company
(See written statement dated February 13, 1980.)
18) Thomas D. Faux, resident of Weisner Subdivision
Concerned about change in real estate values. Suggests reference
to Boulder example that reason land value remained high near their
treatment facility is due to green belt policy and land around the
treatment plant may be the only thing available. Indicated he had 116
signatures from people stating that they are unhappy with the odors
produced by the Louisville sewage plant. Signature list turned into
Weld County Planning Commission. Also concerned about possible well
contamination.
19). Frank Culkin, attorney representing the Weisner Subdivision, the
Town of Fort Lupton and the Town of Frederick
(See letter of February 29, 1980.)
Believes that those opposing project have presented their case and
EPA will act to deny funding to Northglenn.
20) Barry Keene, resident of Frederick
The EIS document is not entirely credible. For instance, the
Larimer-Weld 208 Clean Water Plan does not designate any of the uses of
the canals, so the EIS is incorrect to indicate the canal is designated
solely for agriculture. Not realistic to restrict raw edible crops.
May be done initially but what about 40 to 50 years from now? Suggests
that arbitration for intergovernmental agreement should be defined.
21) Jim McNelly, operates the Planet Earthworm Company
Since 1977 has been taking grass clippings and recycling (earthworn
castings) back to city. Stresses need to find economic ways to recycle
nutrients and provide for organic agriculture. Regrets that Denver
Metro sludge is only dumped at Lowry. Hopes people will not be
prejudiced but rather look at long term benefits.
RESPONSE:
RESPONSE:
RESPONSE:
A. EPA has made the determination that no compensation will
be provided to homeowners who might experience decrease
in property value due to the location of Northglenn's
wastewater treatment facility
5. See response to Levi Siebert above for EPA's response
concerning real estate values. EPA acknowledges that odor
generation from Northglenn's wastewater treatment facility
may occur on occasion due to high algal concentrations
in the storage reservoir. Mitigation measures to control
algae will aid in controlling odor problems, however, it must
be recognized that no wastewater treatment facility can be
guaranteed to be 100 percent odor free. EPA would
appreciate receiving the signatures of those individuals
who have been unhappy with the odors produced by the
Louisville Sewage Treatment Plant for inclusion in the
record. EPA believes that Northglenn's proposed construction
techniques provide sufficient protection to prevent well
contamination within the immediate vicinity of the waste-
water treatment plant and storage reservoir.
6. EPA acknowledges that the Bull Canal is not specifically
designated for agricultural use. However, that
the primary use currently of the Bull Canal is for
irrigation of agricultural lands. Concerning the
restriction to raw edible crops, EPA has dropped this
requirement for the Northglenn facility. This is a
consequence of Northglenn agreeing to a 200 per 100
milliliter standard for their wastewater effluent. This
standard has been written into the Northglenn discharge
permit by the Colorado Department of Health. Therefore,
EPA does not believe that excessively high health risks
are associated with the wastewater effluent used for the
irrigation of raw edible food crops. Concerning arbitration
for the inter governmental agreement, EPA is considering
appointing a negotiator between Weld County and Northglenn
to arbitrate the conclusion of an acceptable inter-
governmental agreement between the two parties.
RESPONSE: 7. EPA acknowledges the consents of the Planet Earth Worm
Company and the support it presents for Northglenn's
wastevater treatment and water resource management plan.
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RESPONSE:
-6-
22) Thomas E. Norton, engineer for the City of Fort Lupton
(See letter dated February 22, 1980 by Mayor Hoffman.)
23) Terrence L. Trembly, Director of Water Quality Planning for Larimer-
Weld Council of Governments
(See letter dated February 25, 1980 from Jonathan Rutstein.)
24) Edward Quinlan, President of the Weisner Preservation Association
Suggest that estimate of seepage (at the reservoir) of 55 acre/feet
per year may be significant. Concerned about possible well pollution.
Why can't there be a determination about whether the design considered
possible damage from ice or earthquake generated waves? Will water
8 table rise as a result of this facility? Could the Weisner Subdivision
or other areas all of a sudden find the area has been designated a
floodplain? We were there first. Why should Northglenn dump its
problems in our laps. There are far too many "maybe", "could be" and
"should be" statements in the EIS. EPA should provide definite answers.
25) Dr. Robert McGregor, consulting engineer with the firm of Schaefer
and Roland, consultants to the City of Northglenn
(See letter dated February 25, 1980 from Richard P. Lundahl.)
EPA has done a thorough study and although he disagrees with some
of the finer technical details, he thinks report's conclusions are well
founded.
Suggests EPA analyze frequency of possible odor events. Indicates
that 200 fecal counts per 100 ml standard is unnecessarily too
restrictive as that standard is meant for primary contact recreational
streams. Regarding raw edible crops, it should be pointed out that
there are none (presently) grown under the FRICO systems. Suggests that
local experience is sufficient to indicate there is no problem with use
of secondary effluent on food crops. Cites very high fecal counts in
Burlington Ditch and South Platte River. Requests that a standard for
such reuse be defined. Indicates that cost estimates for Denver Metro
fail to include Denver's new sludge project.
9.
A seepage rate of water from the Bull Canal Reservoir
of 55 acre feet per year does not Indicate
that this is a significant amount. This is primarily
based on soil conditions at the reservoir which indicate
that maximum absorption within the soil matrix below the
reservoir amounts to two feet per year. Such circumstances
along with Northglenn's lining of the Bull Canal Reservoir
indicate to EPA that sufficient mitigation measures have
been taken on the pa*t of Northglenn to prevent possible
groundwater and well contamination from the reservoir.
Furthermore, Northglenn will establish a groundwater
monitoring program which will further indicate if ground-
water within the vicinity of the reservoir is being
contaminated. If groundwater contamination is indicated
from this monitoring, mitigation measures can be taken
to prevent further contamination of wells in the vicinity.
EPA's analysis of the Bull Canal reservoir construction
and lining designs do indicate that the design has con-
sidered damage from ice or earthquake generated waves
and that sufficient latitude is provided within the design
to prevent damage from these events-. Concerning water
table rise as a result of the facility, EPA does not
believe that the groundwater table will experience any
increase due to the minimal amount of seepage and
transmissivity at the site.
The Federal Emergency Management Agency indicates that
such off-stream reservoirs do not create a flood risk
if properly constructed and maintained, therefore, lending
institutions would not be likely to require flood insurance
for residences in the vicinity. Federally subsidized
insurance would be available for homeowners in the area.
Such insurance would be based on low hazard zone rates of
approximately $20 to $25 annually per $100,000 insured
value. In the absence of such insurance or a floodplain
provision in the homeowner's policy, there would not be
any coverage in the unlikely event of failure of the
proposed Bull Canal Reservoir.
EPA believes that the Environmental Impact Statement
provides a full disclosure of the impacts and necessary
measures to mitigate these impacts associated with
Northglenn's waste-water treatment facility.
EPA has determined that 200 fecal counts per 100 milliliter
is an economically achievable standard for wastewater
treatment facilities which involve agricultural reuse in
unrestricted areas and is not as severe as other standards
states have imposed for similar projects. This is
further supported by the Colorado Water Quality Control
Commission and Colorado Department of Health by writing
Northglenn's wastewater treatment discharge permit to
this standard. As stated previously Northglenn is not
required to implement any type of control or restrictions
on raw edible food crops provided that the 200 fecal
coliform per 100 milliliter standard is achieved. EPA
will establish a policy which addresses the public health
risks associated with irrigation of 100 percent effluent
for agricultural reuse in unrestricted areas. Concerning
the inclusion of cost estimates for Denver Metro,EPA will
not include Denver's new sludge project in the Denver
Metro pro rata share for Northglenn as this facility is
not sized differently without Northglenn.
-------
City Hall
8992 N Washington Street 'Rfl jftPP 3 ^ h'"\ Q * 90
Thornton. Colorado 80229 UU Hrfi JJ H|J O«CU
303) 289 5801
May 1, 1980
COHRESPOIiDENCH
Mr. Roger Williams, Administrator
Region VIII
U.S. Environmental Protection Agency
1860 Lincoln Street
Denver CO 80295
Dear Mr. Williams:
To assist in the preparation of the Environmental
Impact Statement for Northglenn 's sewage treatment
plant, Thornton has been asked to present information
on its ability to provide Korthglenn with water and
sewer service as one of the alternatives to the con-
struction of Northglenn1 s project.
There has been a great deal of confusion regarding
this subject. Obviously, we can serve Northglenn,
and do not agree with contrary statements in the EIS.
We are serving Northglenn today. In our planning for
the future , however , both Northglenn and Thornton
have mutually decided to discontinue this service.
Since the Severance Agreement between Thornton and
Northglenn was signed last year, the City of Thornton
has moved forward with its water and sewer develop-
ment plans assuming that Northglenn would have an
independent system. Thornton has spent considerable
sums of money — as has Northglenn — carrying out the in-
tent of the Severance Agreement and the 4 -Way Agreement
among Thornton, Northglenn, Westminster and the Farmers
Reservoir and Irrigation Company, which also refers to
the provision of utility services to Northglenn by
Northglenn. We do not believe it is feasible or
appropriate for Thornton to reassess its water resource
development plan to include Northglenn at this late
date.
Northglenn has not asked us to consider nor have we
been planning for anything other than Northglenn sever-
ing completely from our system. In fact, we have been
planning in anticipation of the severance in making
available certain utility service to other areas pur-
suant to requests to us.
A-173
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Mr. Roger Williams, Administrator
Page 2
We do not want to get drawn into any disputes, if any,
concerning Northglenn's desires to have their own system.
Sincerely yours,
/&<£^
Wes Brown, Chairman
Thornton Utilities Board
Margaret Carpenter, Mayor
/kw
cc file
A-174
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-------
APPENDIX B
DESCRIPTION OF THE EXISTING ENVIRONMENT
THE STUDY AREA
The proposed Northglenn plan affects a large geographical area
north of the Denver metropolitan area. Included are the facilities
for water supply, wastewater conveyance and treatment, urban storm-
water collection, and augmentation elements of the various options.
The key hydrologic features and political jurisdictions of concern
in the Study Area are illustrated in Figure B-l.
COLORADO WATER RIGHTS AND ADMINISTRATION (1)
Colorado has a complex system of water administration and use.
The system evolved from a mining and agriculturally based economy
in which the demand for water often exceeded the supply. Because a
major portion of the state's water is derived from melting snow high
in the mountains, it is not distributed equally in either time or
place.
In Colorado, the use of surface water, including underground
water tributary to the surface system, is administered by the State
under the Appropriation Doctrine. The State Constitution protects
the right of water users to appropriate the waters of natural streams
according to a "first in time, first in right" doctrine, limited only
by the amount of water physically available to those able to put it
to beneficial use without waste. Colorado was admitted to the Union
in 1876, and at that time officially declared the Appropriation
Doctrine to be the sole basis for the allocation of state waters.
Administration
The responsibility for water administration and control in Colorado
is divided between the State Engineer, under the Division of Water
Resources of the State Department of Natural Resources, and the Water
Court. The State Engineer has jurisdiction to administer, distribute,
and regulate the waters of the State. The Water Court has jurisdiction
over matters which are specified by statute to be heard by the water
judges in the state district courts within their respective divisions.
Matters decided by the Water Court include determination of amounts
and priorities on applications for new water rights, and findings of
diligence in the perfection of conditional water rights. Also, the
responsibility of the Water Court is the determination of rights with
respect to proposed changes of water rights and plans for augmentation.
Diversions are regulated on the basis of priorities decreed by
the Courts, generally in the order in which the water was first appro-
priated and put to beneficial use. A water right with an early appro-
priation date takes precedence over rights with later dates. Court
B-l
-------
FIGURE B-l
NORTHGLENN STUDY AREA
-------
decrees also specify the permitted magnitude of diversion in terms
of rate of flow for direct diversions and by volume for storage
rights. A senior appropriator (i.e. one with an early date, whose
right is not satisfied by the flow at his headgate) may call for
water that is being diverted by a junior right upstream. This
system of appropriation and administration thus determines the legal
availability of water at a given location on a stream.
There are two categories of water rights which are defined by
the time lag between diversion and use. Direct flow rights are
for water diverted from the stream to a ditch and put to use more
or less immediately. Storage rights are for water diverted from
the flow of the stream and stored in a reservoir. This water is to
be released for use at some later time, within the same year or in
a subsequent year. Diversion for a storage right may be either for
a reservoir off the stream channel from which it was diverted, or it
may be for an on-channel reservoir.
The consumptive use of a crop is defined as the sum of two things;
1) transpiration, which is water entering crop roots and used to
build tissue or is passed through the leaves of the crop into the
atmosphere, or 2) evaporation, which is water evaporating from ad-
jacent soil, water surfaces or from the surfaces of leaves of the
crop (2.). Because there is not enough rainfall to meet the water
requirements of most crops in the Denver area, irrigation water
from surface or groundwater supplies is needed to promote full crop
growth and development.
Not all the water diverted is actually consumed in use, and
the portion which returns to the stream and is available to downstream
appropriators is known as return flow. The amount of consumptive use
varies with the type of use and method of application. For irrigation,
consumptive use ranges from 40 to 60 percent of diversions. Domestic
and municipal consumptive use ranges from 5 to 40 percent while power
generation and placer mining result in virtually no consumptive use.
Shallow ground water that is hydraulically connected to the surface
system is defined as "tributary" water, and is also administered
under the priority system. To protect the right of tributary wells
to pump, it is necessary to adjudicate their priorities in the same
manner as a surface appropriation.
Changes and Transfers
In Colorado, water rights are treated as real property and may
be purchased or sold separately from the land to which they may be
appurtenant. Water rights may be transferred from one location to
another and the use to which the water is put in some cases may be
changed. The principles governing such transfers and changes have
been stated by the courts in Colorado, subject to certain conditions
which relate primarily to protection of other appropriators from
injury due to the change. Junior appropriators have vested rights
in the continuation of stream conditions as they existed at the time
of their respective appropriation. Mere ownership of a water right,
however, does not mean that it is valuable and can be transferred
or its use changed.
B-3
-------
Augmentation Plans
The Water Right Determination and Administration Act of 1969
provides a means whereby complex water use projects and proposals
can be reviewed by the court and a decree of approval granted.
The technique is called a Plan for Augmentation and provides for
legal recognition of total water supply systems. This proposal
requires the application of the augmentation plan procedures in
order to develop a reliable water supply for Northglenn's municipal
use. In using water rights that have historically been used for
irrigation to provide a municipal or industrial supply, special
problems are sometimes encountered. These problems derive from
the requirement that when a water right is changed there must be
no injury to junior appropriators, and the fact that a municipal
water supply is a year round use and must be highly dependable.
To protect other appropriators on a stream, it is generally neces-
sary to limit a change in use of a direct flow irrigation water
right to the period of time that it was historically used beneficially.
This means that it can provide water only during the irrigation season
and not during the winter months. Water for winter use generally
must be provided from reservoir storage by obtaining a new appro-
priation or by exchange. Storing a portion of the historic irri-
gation consumptive use during the time when it is legally available
for later release to the stream to cover winter depletions is one
method of exchange.
MEASUREMENT OF WATER
There are two types of units commonly used in this report to
define water measurement. These are units of volume and units of
discharge. The unit of volume commonly employed in irrigation
practice is the acre-foot. An acre-foot is defined as the quantity
of water required to cover one acre of land to a depth of one foot,
or 43,560 cubic feet (3). There are 325,900 gallons in one acre-foot.
Discharge, or the rate of flow, is defined as the volume of
water that passes a particular reference section in a unit of time.
The units of discharge commonly used are gallons per minute (gpm)
and cubic feet per second (cfs). One cfs is equivalent to 449 gpm.
The miners inch, or inch, was originally used in hydraulic
mining and irrigation in the Western United States and is still commonly
used in many areas. The use of this unit leads to confusion because
the definition varies between states. In Colorado, one inch is the
quantity of water which will flow through an orifice one inch square
under a head of 5 inches. One Colorado inch is equal to about 12 gpm
and 38.4 inches equals one cubic foot per second. Many ditch companies
use the term "inch" to define the proportionate share of water in the
ditch to which users are entitled. In this case the value of an inch
varies with the amount of water actually in the ditch.
B-4
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WATER RESOURCES IN THE STUDY AREA
Historically, the major use of water in the South Platte River
Basin was by agriculture. While this is still the case, urbanization
of the metro-Denver area and other areas throughout the region have
taken lands out of crop production/agricultural use. As urbaniza-
tion continues, additional lands will be taken out of production
due to development pressures and the economic difficulties facing
farmers in an urbanizing environment.
The South Platte River and its tributaries in the Denver area
are fully appropriated. Water is available to junior appropriators
only during periods of flood runoff. A new direct flow water right
would not be a dependable or reliable source. Because the Denver
metropolitan area continues to grow and water needs increase, it is
necessary to look to various means to meet these new demands.
Storage is one method of increasing water availability through
more efficient use of existing water supplies. Any new storage
appropriation in the South Platte Basin will be junior to the pro-
posed Narrows Project on the South Platte River in eastern Colorado,
and the amount and frequency of water availability to the new
facility would have to be carefully analyzed. In addition, there
are many public and environmental concerns relating to storage which
currently make other alternatives more desirable in terms of economic
feasibility.
Transbasin water is another source of new water. This is an
expensive means of water development, both in terms of facility con-
struction and potential environmental impact on the basin of origin.
Any new transbasin water project can be expected to take many years
to develop.
A third water source is nontributary groundwater. Under current
state administration policy, the amount of such water available for
use depends upon the amount of land owned or controlled by the appli-
cant. This concept is now being tested in court with the argument
that nontributary ground water should be subject to the Appropriation
Doctrine. Complete dependence on a nontributary ground water supply
for a municipality is questionable, given the potential for limited
useful life of the ground water aquifer.
The final source of water for municipal development is through
acquisition of existing water rights and changing them to the new
use. At the present time this is generally the easiest and most
economical way to develop a water supply. Since agriculture uses
about 95 percent of the water available in Colorado, it is a prime
source for water acquisition. When agricultural water is acquired
for a municipal system, the lands historically served are usually
taken permanently out of production.
WATER SUPPLY SOURCES FOR NORTHGLENN
While the Northglenn plan incorporates some water from all of
B-5
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the sources mentioned previously, the biggest potential impact
is on agriculture in the South Platte River Basin as it provides
the most convenient and economical source of water for a municipal
development. The significant feature of Horthglenn's plan, however,
is that a portion of the water used will be borrowed from agriculture,
treated, and returned for agricultural use, thus mitigating at
least some of the adverse impact to agriculture.
Northglenn's Water Sources
Northglenn's proposed raw water supply is based upon the yield
from ownership or share ownership of water rights in the following:
a. The Standley Lake division of FRICO through direct owner-
ship of shares;
b. The Standley Lake division of FRICO through the exchange
proposal;
c. The Berthoud Pass Ditch, a transmountain ditch historically
used as an irrigation supplement by FRICO;
d. Nontributary ground water beneath the City of Northglenn;
e. The Farmers Highline Canal historically used for agricul-
tural irrigation in the area north of Clear Creek through
share ownership in the Farmers Highline Canal and Reservoir
Company; and
f. The Church Ditch also historically used for agricultural
irrigation north of Clear Creek through share ownership
in the Golden City and Ralston Creek Ditch Company.
A key feature of Northglenn's plan is the agreement with FRICO
allowing Northglenn to borrow from Standley Lake the difference
between their municipal water requirement and the amount of water
Northglenn can provide under their own ownership. Any water so
borrowed is returned with a 10 percent bonus to the Bull Canal users
under the Standley Lake system for agricultural use. Northglenn has
expressed their intention to continue irrigating those lands in FRICO
they have purchased for water acquisition purposes subject to the
availability of water. In a dry year, for example, all water would
be needed by the City and there would be no excess water.
A description of the various raw water sources follows:
Standley Lake: The Standley Lake division is one of four main
divisions of FRICO. The system serves a total area of slightly more
than 15,000 acres and there are currently 2,373 outstanding shares
of stock (2). As of August 1979 the cities of Westminster, Thornton
and Northglenn owned or controlled 923 shares or 39 percent of the
stock (4). The total capacity of Standley Lake is 42,000 acre-feet;
however, FRICO has the use of only 20,000 acre-feet and, after the
B-6
-------
cities' share ownership is claimed as stipulated in the four-way
agreement, there are only 12,220 acre-feet available for other
shareholders. Due to the water acquisition policy of these cities,
the shares owned by the cities are constantly increasing. The
water rights associated with Standley Lake are listed below (5):
a. The Standley Reservoir in former Water District No. 2, for
940.36 acre-feet of water for irrigation purposes from
Woman Creek with an appropriation date of September 1, 1869,
decreed on August 2, 1918.
b. The Kinnear Ditch in former Water District No. 2, for 40.47
cubic feet of water per second for irrigation purposes
from Woman Creek with an appropriation date of September 1,
1869, decreed on August 2, 1918.
c. The Kinnear Reservoir 1st Enlargement in former Water District
No. 6, for 49,488 acre-feet of water for irrigation purposes
from Coal Creek with an appropriation date of March 4, 1902,
decreed on June 21, 1926.
d. The Croke Canal in former Water District No. 7, for 1056.00
cubic feet of water per second (conditional) for irriga-
tion and domestic purposes from Clear Creek with an appro-
priation date of March 4, 1902, decreed on May 13, 1936.
e. The Croke Canal in former Water District No. 7, for 944.00
cubic feet of water per second for irrigation and domestic
purposes from Clear Creek with an appropriation date of
March 4, 1902, decreed on May 13, 1936.
f. The Standley Lake Reservoir in former Water District No. 7,
for 32,361 acre-feet of water for irrigation and domestic
purposes from Clear Creek with an appropriation date of
March 4, 1902, decreed on May 13, 1936.
g. The Standley Lake Reservoir in former Water District No. 7,
for 16,699 acre-feet of water (conditional) for irrigation
and domestic purposes from Clear Creek with an appro-
priation date of March 4, 1902, decreed on May 13, 1936.
h. The Standley Reservoir Ditch in former Water District No. 6,
for 26.47 cubic feet of water per second for irrigation
purposes from Coal Creek with an appropriation date of
May 20, 1872, decreed on June 2, 1882.
i. The Standley Reservoir in former Water District No. 6,
for 940.00 acre-feet of water for irrigation purposes from
Coal Creek with an appropriation date of September 1, 1869,
decreed on December 19, 1900.
j. The Standley Lake Enlargement in former Water District No. 6,
for 18,000 acre-feet of water (conditional-abandoned) for
irrigation purposes from Coal Creek with an appropriation
date of December 31, 1929, decreed on September 28, 1953.
B-7
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k. The Berthoud Canal Tunnel in former Water District
No. 51 (Division 5), for 53.40 cubic feet of water per
second for irrigation purposes from the Fraser River with
an appropriation date of June 30, 1902, decreed on August 3,
1911. The ditch generally operates between May and September.
Church Ditch; The Church Ditch (Golden Ralston Creek and Church
Ditch Company) is a carrier ditch company whose physical facilities
and water rights are primarily owned by FRICO (6). There are a
total of 5,710.64 inches in the ditch of which Northglenn owns the
right to purchase 415.205 inches of water. The source of supply is
Clear Creek and the water rights are detailed in a copy of the
Change of Water Rights Application in Appendix D. FRICO owns 29
percent of the total inches in the ditch and has in the past diverted
water to Standley Lake when not required for operational purposes (6).
Farmers Highline Canal: The Farmers Highline Canal diverts from
the north bank of Clear Creek. In addition, the ditch has rights in Big
Dry Creek, Ralston Creek and Leyden Creek. The water rights are
listed in a copy of a Change of Water Rights Application in Appendix
D. Northglenn owns 7.7125 shares out of 1094 shares in the ditch.
Northglenn can take the water into Standley Lake or can take it
directly to the city for park irrigation.
Nontributary Ground Water: Northglenn has filed applications
to construct deep wells for a total of 2300 acre-feet of nontribu-
tary ground water from the Laramie-Fox Hills and Arapahoe aquifers
underlying the City. With the exception of Arapahoe Well No. 7,
the State Engineer denied the permits. Under current water admin-
istration policy, the amount of water available from nontributary
sources is based on surface land ownership, and Northglenn currently
claims ownership or control of sufficient land to yield 650 acre-
feet of water per year. It is Northglenn's position that it is
not practical or economically feasible for any individual or group
of individuals within the City to develop his own deep well supply
and the full 2300 acre-feet per year underlying the City should be
available to the City for development. The matter is currently
pending with the Water Court.
REPLACEMENT WATER
Under terms of the agreement with FRICO, Northglenn must return
the total amount of water borrowed for use of the City plus a 10
percent bonus. In addition, evaporation from the reservoir con-
structed to hold the water until released to the Bull Canal system
must be included in the total replacement water requirement. The
primary replacement water source will be treated wastewater from
Northglenn. Included in the Northglenn replacement program is
wastewater from an enclave of Thornton and all sewer line infil-
tration from the collection system.
A second source of replacement water is urban storm runoff in
Grange Hall Creek which will be captured and diverted for treatment
B-f
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at the sewage plant. Northglenn has junior (1971) water rights
for storm runoff from the city (7). The diversion will occur at a
planned 30 acre-foot detention pond on Grange Hall Creek near the
eastern edge of the City.
The third source of replacement water which may be required
under certain dry year conditions is a planned well field located
near the South Platte River, which will pump tributary water from
the South Platte to a pumping station located near the Grange
Hall Creek detention pond and to the Bull Canal Reservoir site.
Northglenn plans a total of five wells to provide supplementary
water for replacement purposes, but a specific site for the tribu-
tary well field has not yet been specified.
WATER QUALITY
Water Quality Criteria
The proposed Colorado stream water quality criteria (8) were
used to assess the existing water quality. Criteria for water
supply, recreation, and agriculture were used. The pertinent
criteria for these uses are presented in Table B-l.
Surface waters suitable for a water supply are defined as
follows:
"Waters which after receiving approved disinfec-
tion such as simple chlorination or its equivalent
or which after receiving standard treatment (defined
as coagulation, flocculation, sedimentation, fil-
tration and disinfection or its equivalent) will
meet Colorado drinking water regulations and any
revisions amendments, or supplements thereto." (8)
Recreational water is separated into Class I and Class II by
the State of Colorado. These are defined as follows:
Class I - "These surface waters are suitable or
intended to become suitable for prolonged and inti-
mate contact with the body or for recreational
activities when the ingestion of small quantities
of water is likely to occur. Such waters include
but are not limited to those used for swimming." (8)
Class II - "These surface waters are suitable for
recreational uses on or about the water which are
not included in the Class I category."
Agricultural waters are defined as:
"These waters are suitable or intended to become
suitable for irrigation of crops usually grown
in Colorado and which are not hazardous as drinking
water for livestock."
B-9
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TABLF B-l
WATER QUALITY PARAMETERS AND CRITERIA
Use
Category
Physical
Nutrients/
Organics
Parameter
Temperature, °C
pH, units
Dissolved Oxygen,
mg/1
Alkalinity, mg/1-
CaC03
Color
Turbidity, TU
TDS, mg/1
TSS, mg/1
TVS, mg/1
Settleable solids
Hardness
Conductivity, mmhos
Water Supply
5.0 - 9.0
aerobic
free from
mg/1
Biological
Toxics
Metals
Phosphate, mg/1
Phosphorus -
Ortho-phosphate, mg/1
Nitrate-N, mg/1 10
Nitrite-N, mg/1 1.0
COD, mg/1
BOD, mg/1
Organic Nitrogen, mg/1
TKN
Total Coliform, #/100 ml -
Fecal Coliform, #/100 ml
Ammonia-N, mg/1
Fluoride, mg/1*
mg/1
mg/1
mg/1
Inorganic
Minerals
Cyanide,
Aluminum
Arsenic,
Cadmium, mg/1
Chromium, mg/1
Copper, mg/1
Iron, mg/1 (dissolved)
Lead, mg/1
Magnesium, mg/1
Manganese, mg/1
(dissolved)
Molybdenum, mg/1
Selenium, mg/1
Zinc, mg/1
Chloride, mg/1
Sodium, mg/1
Sulfate, mg/1
Calcium, mg/1
Boron, mg/1
2000
0.5
0.2
0.05
0.01
0.05
1.0
0.3
0.05
0.05
0.01
5.0
250
250
Recreation
Class I Class II
6.5 - 9.0
aerobic aerobic
free from free from
200
2000
Agriculture
aerobic
free from
100
10
0.2
0.1
0.01
0.1
0.2
0.1
0.2
0.02
2.0
0.75
*Fluoride levels vary based on annual average of the maximum daily air temperature.
B-10
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Existing Water Quality
Water quality and quantity underlie the major issues of the
Northglenn plan. The quality of water can effect both agricultural
productivity and public health. Within the Northglenn-FRICO area
quality data exist on several bodies of water. To facilitate the
evaluation of these data the various waters have been segregated
into two hydrologic systems. The Clear Creek system includes
Clear Creek, the Church Canal, the Croke Canal, the Farmers
Highline Canal, Allen Ditch, and Standley Lake. The Big Dry
Creek system includes Big Dry Creek and the Bull Canal (see
Figure B-2).
In order to effectively present the existing water quality
data of the two systems, stream profiles are used. A profile is a
graphic representation of a system with river miles as the hori-
zontal axis and parameter concentration as the vertical axis. The
principal rivers and canals are illustrated on each profile map.
The profile maps are used to display mean and maximum/minimum
values of each parameter at each station. The number of events
comprising each sample.set is also presented. Water quality pro-
files for nitrate and fecal coliform concentrations for the Clear
Creek and Big Dry Creek systems are presented in Figures B-3 through
B-6.
The utility of water quality data is dependent, in part, upon
the number and frequency of samples that are collected. The data on
Clear Creek are the most comprehensive, while the Bull Canal data
are of questionable value since only one sample set is available
for analysis.
The existing water quality data base is a compilation of in-situ
parameter concentrations for 40 constituents measured at 22 stations.
The existing water quality data base is summarized in Table B-2.
Physical Parameters
Water quality criteria are proposed for three of the twelve
physical parameters/constituents that have been monitored. Of the
three only pH has numeric criteria, 5.0-9.0 and 6.5-9.0 for water
supply and Class I, recreation, respectively. The mean pH values
reported in the Clear Creek system and the Big Dry Creek system
range from 7.7 to 8.3, well within the criterion range.
Concentrations of color, turbidity, suspended solids, volatile
solids, settleable solids, hardness, and conductivity in Clear
Creek and Big Dry Creek appear to be influenced by wastewater dis-
charges into these waters and possibly by seasonal variations.
Nutrients/Organics
A total of nine parameters in this category have been monitored.
The water supply and agricultural criteria for nitrate are 10 mg/1 and
100 mg/1, respectively. The nitrite criteria for water supply and
B-ll
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TABLE B -2
SUMMARY OF EXISTING WATER QUALITY
W
M
N3
Parameter WS
Temperature, C -
pH, Units 5-9
DO mg/1 -
Alkalinity, mg/1
Color, units
Turbidity, TU
IDS, mg/1
TSS, mg/1
TVS, mg/1
Set Solids, mg/1
Hardness -
Conductivity,
mmhos
Phosphate, mg/1 -
Phosphorus, mg/1
Ortho-Phosphate,
mg/1
Nitrate, mg/1 10
Nitrite, mg/1 1.0
COD, mg/1
BOD, mg/1
TKN, mg/1
Total Coliform,
#/100 ml
Fecal Coliform,
#/100 ml 2000
Ammonia, mg/1 0.5
Fluoride, mg/12
Cyanide, mg/1 0.2
Aluminum, mg/1 -
Arsenic, mg/1 0.05
Cadmium, mg/1 0.01
Chromium, mg/1 0.05
Copper, mg/1 1.0
Iron, mg/1 (diss) 0.3
Lead, mg/1 0.05
Magnesium, mg/1 -
Mangenese, mg/1 0.05
dissolved
Molybdenum, mg/1 -
Selenium, mg/1 0.01
Zinc, mg/1 5.0
Chloride, mg/1 250
Sodium, mg/1 -
Sulfate 250
Calcium, mg/1
Boron, mg/1 -
'Sl.D. - No Data
2
CRITERIA
Rec I Rec II Ag Clear Cr.
- - 8.1-12.9
6.5-9.0 - - 7.8-8.2
_ aerobic 10 7 10 9
- - 36.0-174.5
- - N.D.
- - 12.0-31.4
- 22.2-47.2
- N.D.
- - N.D.
- - 0.12-1.0
- 96-199
- - 0.2-0.7
- - 0.14-2.96
- - 0.09-1.02
- - N.D.
100 0.47-1.78
- 10 0.007-0.14
- - 40.0
2.2-7.8
- 3.5-5.8
- - 1149-63,000
200 2000 - 424-21,000
- - 0.22-2.46
0.69-0.79
0.2 0.0-0.0009
- - 0.0-0.0024
0.1 0.0-0.0007
- 0.01 0.0001-0.0005
0.1 0.0-0.0038
0.2 0.009-0.046
- 0.71-0.91
0.1 0.007-0.019
- - 8.5-12.4
0.2 0.31-0.68
- - 0.032-0.13
0.02 0.0001-0.0013
2.0 0.08-0.55
- - 10.0-49.9
- - 15.2-74.4
- - 68.0-143.0
- - 67.6-147.9
- 0.75 0.03-0.17
RANGE OF MEAN VALUES REPORTED
Croke Cnl
10.6-14.9
7.8
7.2
68.6-114.7
30.5-52.2
11.6-20.1
263-368
N.D.
N.D.
N.D.
128-134
N.D.
0.52-1.32
N.D.
0.29-1.00
0.27-0.41
0.006-0.01
22.0-76.9
N.D.
N.D.
591-13,000
N.D.
0.21-0.35
0.87-0.97
N.D.
N.D.
N.D.
N.D.
N.D.
N.D.
0.87-1.2
N.D.
N.D.
0.55-0.65
0.20
N.D.
N.D.
8.8-29.6
N.D.
N.D.
32.8-42.7
N.D.
Church Dtch
8.1
7.9
7.9
47.6
37.1
8.7
163
N.D.
N.D.
N.D.
83.5
N.D.
0.22
N.D.
0.01
0.24
0.01
16.8
N.D.
N.D.
91
N.D.
0.28
0.69
N.D.
N.D.
N.D.
N.D.
N.D.
N.D.
1.3
N.D.
N.D.
0.9
0.4
N.D.
N.D.
3.8
N.D.
76.0
21.5
N.D.
Farmers Hghln
10.9
8.0
7.4
51.2
43.4
25.3
187
N.D.
N.D.
N.D.
89.4
N.D.
0.49
N.D.
N.D.
0.32
0.002
26.9
N.D.
N.D.
412
N.D.
0.17
0.90
N.D.
N.D.
N.D.
N.D.
N.D.
N.D.
1.8
N.D.
N.D.
1.2
0.39
N.D.
N.D.
3.7
N.D.
N.D.
23.1
N.D.
Allen Dtch
18.4
8.0
6.7
51.5
35
28.9
169
N.D.
N.D.
N.D.
74.8
N.D.
0.03
N.D.
0.08
0.2
0.0
14.0
N.D.
N.D.
1710
N.D.
0.09
0.54
N.D.
N.D.
N.D.
N.D.
N.D.
N.D.
2.6
N.D.
N.D.
0.6
0.02
N.D.
N.D.
5.4
N.D.
N. U
21.'4
N.D.
Standley Lake
10.8-14.3
7.9-8.3
5.3-6.3
79.1-84.3
6.3-38.2
3.9-44.4
203-327
N.D.
N.D.
N.D.
111-119
N.D.
0.08-0.12
N.D.
0.08
0.04
0.005-0.01
17.4-27.0
N.D.
N.D.
14-28
N.D.
0.11-0.22
0.69-0.76
N.D.
N.D.
N.D.
N.D.
N.D.
N.D.
0.18-2.08
N.D.
N.D.
0.12-0.55
N.D.
N.D.
N.D.
8.9-10.2
N.D.
N.D.
37.2-38.6
N.D.
Big Dry Cr
7.4-9.9
7.8-8.1
7.5-8.0
177.0-218.9
17.0-64.0
7.0-41.1
300-843
39-800
11-23
0.1-0.26
253-365
N.D.
0.18-3.64
N.D.
0.05-3.34
0.07-3.35
0.02-0.56
35.5-55.1
2.5-10.1
1.7
441-8644
30-133
0.19-5.41
0.7-1.39
N.D.
N.D.
N.D.
N.D.
N.D.
N.D.
0.05-1.68
0.03-0.02
N.D.
0.05-7.0
N.D.
N.D.
0.04-0.09
11-47.5
33-240
75-435.2
N.D.
N.D.
Bull Canal
N.D.1
7.8-8.0
N.D.I
N.D.
N.D.
3.0-62.0
290-340
64-520
N.D.
N.D.
N.D.
N.D.
N.D.
N.D.
N.D.
0.4-0.9
0.1
N.D.
1.9-4.5
1.7-4.8
N.D.
10-110
0.1
0.77-0.9
N.D.
N.D.
N.D.
N.D.
N.D.
N.D.
0.05-0.11
0.01-0.02
N.D.
0.1-0.31
N.D.
N.D.
0.04-0.09
9.0-13.0
36-44
75-100
N.D.
N.D.
Criteria based on annual average of the maximum daily air temperature.
-------
FIGURE B-2
FrcdericK
Da cono
WATER QUALITY MONITORING
STATIONS
,' Treatment
Site
Station Locations
Sewagt Treatment Plant
Westminster
NORTHGLENN
Denver Metro
u Clear Creefr
N.W. Lakewood
-------
agriculture are 1.0 mg/1 and 10 mg/1, respectively. The agricul-
ture and water supply nitrate criteria have not been violated in
either the Clear Creek system or the Big Dry Creek system. Ni-
trate and nitrite mean concentrations increase below wastewater
treatment plants but do not exceed criteria.
The remaining parameters exhibit similar trends of increasing
concentrations below treatment plants.
Biological Parameters
Coliform bacteria are organisms that indicate the possible
presence of disease causing organisms such as pathogenic bacteria,
virus, worms, and protozoas. The use of total coliform as an
indicator of pathogenic organisms has a long history. However,
there is variable correlation of total coliform content with con-
tamination by excreta. Fecal coliform is a more specific indicator
of warm-blooded animal contamination. This is substantiated through
examination of the excrement from other warm-blooded animals which
indicates that fecal coliformscontribute to 93 percent of the total
coliform populations. Fecal coliform criteria for a raw water
supply and for Class I and Class II recreation are 2000/100 ml,
200/100 ml, and 2000/100 ml, respectively.
Total coliform concentrations in Clear Creek increase down-
stream. Mean total coliform concentrations range from 1149/100 ml,
above Golden, to 62,939/100 ml near its mouth. Increases in the
lower stream segment are believed to be, in part, a result of
wastewater discharges. Canals taking water out of Clear Creek
have mean total coliform densities at their headgates that range
from 91/100 ml to 12,992/100 ml. Standley Lake has mean concen-
trations below 30/100 ml throughout its profile.
Mean concentrations of total coliform in Big Dry Creek range
from 441/100 ml to 8644/100 ml. Th°e Broomfield wastewater treat-
ment plant discharge appears to increase concentrations.
Mean concentrations of fecal coliform in Clear Creek increase
significantly as the stream passes through Denver. Mean con-
centrations increase from above Golden (424/100 ml) to the mouth
(21,000/100 ml). These values exceed all criteria. No fecal
coliform data are currently available for the canals or Standley
Lake. (See Figure B-5.)
Mean fecal coliform concentrations in Big Dry Creek above
and below the Broomfield treatment plant are about 50/100 ml. Con-
centrations below the Westminster treatment plant indicate con-
centrations decrease downstream. Mean concentrations in the Big
Dry Creek and Bull Canal are below the Class I recreation criterion
of 200/100 ml. (See Figure B-6.)
B-14
-------
Toxic Parameters
The water supply criterion for ammonia is 0.5 mg/1. Viola-
tions of this value are noted in the lower segments of Clear Creek.
This is partly the result of wastewater treatment plant discharges.
Ammonia concentrations in Big Dry Creek below the Broomfield
treatment plant violate the criterion but values in the Bull Canal
do not.
The water supply and agricultural criterion for cyanide is
0.2 mg/1. This value is exceeded near the mouth of Clear Creek.
No other toxic contaminants are present in toxic concentrations
in the system.
Metals
Data for arsenic, cadmium, chromium, copper, and selenium
are currently only available in Clear Creek. Data for zinc and
lead are available for both the Clear Creek and Big Dry Creek
systems. Mean concentrations of all of these parameters are below
their respective criterion.
Water supply criterion (0.05 mg/1) for manganese are for
dissolved, while the agriculture criterion (0.2 mg/1) is for total.
Data are for concentrations of total manganese. The agriculture
criterion is violated at all monitoring stations in the Clear
Creek system. Only one station in the Bull Canal exceeded the
agriculture criteria.
Inorganic Minerals
Inorganic minerals for which data are currently available
include: chloride, sodium, sulfate, calcium, and boron. Water
supply criteria have been recommended for chloride (250 mg/1) and
sulfate (250 mg/1) while agriculture criterion are recommended
only for boron (0.75 mg/1).
Chloride concentrations in both the Clear Creek system and
the Big Dry Creek system are well below criterion limits.
Sulfate criterion is exceeded in Big Dry Creek at five
stations. Mean concentrations at these stations range from 273 mg/1
to 435 mg/1.
Boron data are currently only available in Clear Creek. Mean
concentrations are below the agriculture criterion of 0.75 mg/1.
Radionuclides
Radionuclides have been monitored in Standley Lake sediment
to determine if contamination by emissions from Rocky Flats Plu-
tonium Plant has occurred (19). The primary parameter of concern
to the study was plutonium 239.
B-15
-------
The Colorado water quality standards (8) state that, "the
radioactivity of surface waters shall be maintained at the lowest
practicable level and shall, in no case, except when due to
natural causes, exceed the latest federal drinking water standard."
Taken collectively, the plutonium-239 results for sediment
samples collected from Standley Lake did not indicate any discern-
ible contamination.
Standley Lake is within the"Area of Concern" as defined by
the Colorado Department of Health. Areas of concern are downwind
of the Rocky Flats Plant where exposure risks would be the greatest
during a radiation emergency. EPA requires the development of a
notification mechanism for existing and prospective residences who
would be effected by an emergency condition at Rocky Flats, based
on the State Radiological Emergency Response Plan including the
grantees role in carrying out prescribed protective actions. (See
Chapter 5).
Conclusion
The existing water quality data for the Clear Creek and Big
Dry Creek systems has been evaluated in terms of compliance with
water quality criteria for water supply, recreation and agriculture.
The quality of water in irrigation canals seems to remain rela-
tively constant throughout their reaches. Conversely, maintenance
streams such as Clear Creek and Big Dry Creek have fluctuating water
quality. This situation is a result, in part, of wastewater treat-
ment facilities discharging into the main streams, while irrigation
canals receive limited pollutant contributions from urban areas.
Data on the Bull Canal are limited to one sample. Supplemental
monitoring has occurred but these data were not available at the
time of this report. From the limited data, water quality in the
Bull Canal is of a relatively good quality.
Manganese and BOD are parameters of interest in this analysis
because the concentrations in the Bull Canal appear to be related
to the Broomfield wastewater treatment plant. The differences in
concentration in the Bull Canal and Big Dry Creek are probably a
result of different monitoring periods. It is thought that
additional monitoring of the two streams would correlate water
quality in the headwaters of the Bull Canal more closely to the Big
Dry Creek water quality and influence from Broomfield.
Two parameters are of special concern to this assessment, fecal
coliform and nitrates. Fecal coliform is an indicator of possible
health risks. Nitrates can create problems for water supplies
and nitrogen sensitive crops. Existing water quality data in the
Bull Canal indicates these parameters are below their criterion
limits. However, fecal coliform concentrations in Big Dry Creek
and in Clear Creek increase below wastewater treatment plants.
Similarly, nitrate, nitrite, and ammonia-nitrogen concentrations
increase below wastewater discharges.
B-16
-------
WATER QUALITY PROFILE
Nitrate Nitrogen in mg/1
CLEAR CREEK
WATER QUALITY CRITERIA
WATER SUPPLY 10 mg/1 as N
IRRIBATION 100 mg/1 as N
LtESTOCK
={>F
LEGEND
Value* R0pr«»ent Maximum PtrmltsibU
Concentration* Except As Noltd
• MEAN VALUE
MAXIMUM
St. NUMBER OF SAMPLES
MINIMUM
Direction of flow
15.0
FARMERS HIOHUNE
Distance from Clear Creek Headgate in Miles
STANDLEY LAKE
Distance from Clear Creek Headgate in Miles
10.0
CLEAR CREEK
Distance from above confluence with South Platte in miles
0.0
-------
WATER QUALITY PROFILE
BIG DRY CREEK
Nitrate Nitrogen in mg/1
WATER QUALITY CRITEFffA
WATER SUPPLY 10 mg/1 as N
100 mg/1 as N
100 mg/1 as N
IRRIGATION
LIVESTOCK
after discharge from proposed
PROPOSED facility nitrate concentrate
TREATMENTwiH be 12-14 mg/1 ^
Voluat Represent Maximum Permissible
Concentration! Except As Noted
LEGEMD
MEAN .VALUE
MAXIMUM
NUMBER OF SAMPLES
MINIMUM
distance of flow
Distance from Big Dry Creek Headgate in miles
o.o
s.o
10.0
BIG DRY CREEK
15.0
20.0
25.0
Distance from Standley Lake in miles
WESTMINISTER
W.W.T.R
w
-------
WATER QUALITY PROFILE
CLEAR CREEK
Fecal Coliform (#/100 ml)
WATER QUALITY CRITERIA
WATER SUPPLY 2000/100 ml
IRRIQATION
LIVESTOCK _ •
Valuii RtprtMflt Maximum Ptrmiuibl*
Conctntratloni Except A« Nottd
LEGEND
• MEAN VALUE
MAXIMUM
Bt NUMBER OF SAMPLES
MINIMUM
—T direction of flow
No data available
15.0
FARMERS HISHLINE
1.0
CHURCH CANAL
CROKE CANAL
43,000 Distance from Clear Creek Headgate
in miles
is.o
10.0
CLEAR CREEK
Distance from South Platte River in miles.
-------
FIGURE E-6
•VATf.H QuA_iTY PROFILE
3iG DRY CREEK
Fecal Collform (#/100 ml)
V/AT_ER QUALITY CRITERIA
WAT'LR SUPPLY 2000/100 ml
IRRIGATION ~
LIVESTOCK
Values Represent Maximum Permissibls
Concentrations Except Aft Noted
LEGEND
MEAN VALUE
MAXI.WUM
NUMDER OF SAMPLES
MINIMUM
Direction of flow
O
o
ca
a)
o
o
o
a
o
a>
O
O
after discharge from proposed^
TREATMENT fac±lity concentration^
SITE will be 200 fecal
PROPOSED
colonies/100 ml
Distance from Big Dry Headgate in miles
o
o
ta
o
-------
AGRICULTURE IN THE STUDY AREA
Agriculture is an extremely important industry in the State
of Colorado, along the front range, and in the FRICO and lower
South Platte portions of the Study Area. Through urban encroach-
ment, land erosion, land policies, or land development, Colorado
has lost six percent of its productive land in the last two
decades (9). Along the Front Range irrigated crop land has de-
creased from 700,000 acres to 660,000 acres from 1959 to 1978 (9).
In view of the potentially critical impact nationwide of the reduc-
tion in agricultural land, the current EPA policy is ". . . to
protect. . . . the Nation's environmentally significant agricul-
tural land from irreversible conversion to uses which result in its
loss as an environmental or essential food production resource." (10)
To understand the implications of the proposed exchange of
reclaimed water for irrigation water, it is necessary to first define
the soils, irrigation practices, crops, and current productivity
of the agricultural lands in the Study Area.
Soils and Soil Productivity
The USDA Soil Conservation Service (SCS) has conducted
detailed soil surveys for the region. The soils survey for Southern
Weld County is, at present, unpublished (11, 12). The major soils
within the Study Area have a textural range from sandy loams to clay
loams, with minor areas identified as clays and sands. Soils of the
region generally reflect the tertiary and pleistocene sediments
at the eastern edge of the Rocky Mountain system, with minor
sediments derived from the Denver and Arapahoe Arkose formation.
Recent alluvium deposits occur along major stream valleys. Soils
can generally be grouped into the high terrace and alluvial fan
soils, old terrace and plains soils, ridgecrest and slope soils,
upland soils, floodplain soils, and the sandhill area soils.
Soil fertility is naturally low within the survey area.
Nitrogen, and to a lesser degree phosphorus are needed for best
crop production in the irrigated areas. Zinc and Iron are the only
nutrients known to be deficient in many of the soils (H> 12). Most
irrigation water contains enough of the minor elements to meet the
annual requirements of commonly grown crops.
Soil capability classifications used by the SCS are inter-
pretive groupings made primarily for agricultural purposes. In
this classification the arable soils are grouped according to their
potentialities and limitations for sustained production of the common
cultivated crops. Thus, the most productive soils under irrigation,
have Class I capability ratings whereas those with limitations are
rated with higher roman numerals. Class I soils have few, if any,
limitations that restrict their use. Class II soils have some
limitations and Class III soils have moderate limitations which
reduce the choice of crops or require moderate conservation
practices. Class IV, Class V, and Class VI soils have limitations,
B-21
-------
which make them generally unsuited for cultivation and limit their
use largely to pasture or range. Potential flooding, uneven topog-
raphy, excessive rock or tree cover, seasonal high water tables,
drainage problems, inadequate depth to bedrock, excessive slope,
and clay subhorizons are the reasons for poor ratings. The major
irrigated soils within the Study Area are identified as Class II
and Class III soils with minor areas rated as Class I, Class IV
and Class VI.
Irrigation Practices in the Study Area
All methods of irrigation are suited for the soils within
the Study Area, except where slope is a limiting factor. Furrow
irrigation is most common.
Furrow irrigation is accomplished by gravity flow of water in
narrow channels fed by a head ditch. Water seeps into the soils
from the sides and bottom of the furrows. Water is introduced
into each furrow by a siphon tube from the head ditch. Crops
commonly irrigated in the area are alfalfa, corn, sugar beets,
barley, and field beans.
Where slope is a limiting factor, contour ditches, corru-
gations, contour furrows, cross-slope furrows, and sprinklers are
used. Rotating boom-type sprinklers are used in the Study Area
on limited acreages. According to the Weld County Extension
Service (13) there is a trend to replace furrow irrigation with
sprinklers. The two major reasons for this trend are to increase
water application efficiencies and to decrease labor cost.
Cropping Patterns
The irrigated farmland within the Study Area produces a wide
variety of crops. The main crops are corn for grain and silage,
alfalfa, sugar beets, and field beans. A common cropping system
is a 3 to 4 year rotation of alfalfa followed by corn for grain, corn
for silage, sugar beets, small grains or field beans. This type
of rotation allows maximum use of available soil nutrients. Malt
barley is also grown on limited acreage within the Study Area.
Most of the corn grown in the area is used for feed at
commercial feedlots, farm feedlots, and dairies. Significant
numbers of sheep and turkey are raised on the feed crops grown
in the area (11). Sugar beets and malt barley crops are commonly
contracted by Great Western Sugar Corporation and Coors Brewery,
respectively.
A rotation of small grain and summer fallow is the main type
of farming on the non-irrigated acreage. Wheat is the principal
dry-farm crop, but barley and sorghum are also grown.
In the 27 year period from 1950 to 1977, Colorado Agricultural
statistics (14) show an increase in the acreage planted in corn
and wheat. Barley, field beans, sugar beets, and sorghum have
gradually declined since 1950. However, during the same period of
B-22
-------
time yields per acre for all crops have increased. This may be
attributed to more efficient farm management practices and advanced
technology in agricultural practices.
Present Production and Yield
Production and yields for FRICO lands and lands along the
South Platte that might be removed from production due to the project
have been developed. Presented in Table B-3 are the estimated 1979
crop irrigated and nonirrigated acres in the FRICO Standley Lake
Division. Listed in Table B-4 are the estimated crop yields and
crop values for FRICO lands in 1979. The estimated value of crops
produced from irrigated lands within the FRICO Standley Lake Division
in 1979 is $2,164,000. According to recent information from FRICO,
Standley Lake releases for 1979 will be approximately 14,425 acre-
feet. Based on current farm headgate yields of approximately 60
percent of the release, the 1979 farm 'deliveries will be 8655
acre-feet. Therefore, the FRICO farmers gross productivity based on
water deliveries is estimated at $250 per acre-foot of water
delivered at the farm headgate.
Some of the options evaluated may result in the transfer of
some water rights from land near the South Platte River to the
FRICO Standley Lake Division to satisfy part of Northglenn's
requirement to return 110 percent of the water borrowed from FRICO.
Therefore, farm productivity along the South Platte lands that could
be affected has been determined. Presented in Table B—5 is a summary
of the crop values. The farm headgate delivery to these South Platte
lands is 3,192 acre-feet. The estimated value of crops produced
from irrigated lands near the South Platte in 1979 is $349,500. The
gross productivity of those specific lands along the South Platte
is therefore $109/acre-foot of water delivered to the farm headgate.
CLIMATE
The Front Range area around Denver is a transition area from
plains climate to the climate of the foothills. This area is
characterized as a high elevation continental, semi-arid climate.
Temperatures are typically moderate, with a mean monthly .
temperature of 10.1°C (50.2°F). Ranges in extremes have been
recorded from -35.58°C (-30°F) to 40°C (104°F).
Annual average precipitation for the region is 37 centimeters
(14.5 inches) with a large proportion of the rain falling from April
to September. Thunderstorm activity accounts for much of this
precipitation. Heavy thunderstorms in the foothills and plains areas
occasionally cause damaging floods. The area has a low relative
humidity which is a major factor in the areal potential evapo-
transpiration rate of 611 millimeters (24 inches). This amount is
nearly twice the average precipitation and is an indication of the
arid nature of the area. Periods of drought one to two years in
length are common in portions of Adams County (12).
B-23
-------
TABLE B-3
w
I
ESTIMATED DISTRIBUTION OF IRRIGATED
FARMERS
CROP
Corn (Grain/Silage)
Alfalfa
Spring Wheat
Winter Wheat
Barley
Sugar Beets
Field Beans
Fallow
Dairy
Non- Agricultural
RESERVIOR
IRRIGATED
4,850
1,970
0
0
767
606
152
0
0
0
AND NON- IRRIGATED
AND IRRIGATION CO.
AREA (ACRES)*
NON- IRRIGATED
0
0
1,033
834
700
0
0
3,031
62
1,151
AREAS WITHIN
, STANDLEY LAKE
TOTAL
4,850
1,970
1,033
834
1,467
606
152
3,031
62
1,151
DIVISION IN 1979
PERCENTAGE
OF TOTAL AREA
IRRIGATED NON-IRRIGATED
32
13
0
0
5
4
1
0
0
0
0
. 0
7
5
5
0
0
20
1
7
TOTAL
32
13
7
5
10
4
1
20
1
7
TOTAL 8,345 6,811 15,156 55 45 100
^Estimated from planimetering maps of cropping pattern in 1979 within Farmers Reservoir
and Irrigation Co., Standley Lake Division.
-------
TABLE. B-4
ESTIMATED 1979 CROP VALUE
IN FRICO STANDLEY LAKE DIVISION
to
N>
Ui
Crop
Alfalfa
Corn (grain)
Corn (silage)
Sugar Beets
Field Beans
Barley (irrigated)
Barley (non-irrigated)
Wheat (non-irrigated)
Yield Per Acre1
4 ton
100 bu
16 ton
16.6 ton
27.5 bu
42.5 bu
16.5 bu
16.5 bu
1979 Market Value2
$ 49.50/ton
2.74/bu
18.31/ton
29.00/ton
10.00/bu
2.64/bu
2.11/bu
3.76/bu
Crop Acres
1970
33953
14553
606
152
767
700
1867
10,912
Crop
Irrigated
$ 390,000
930,000
426,000
290,000
42,000
86,000
$2,164,000
Value
Non-Irrigated
$
24,000
116,000
$140,000
Weld County County Extension Service.
2
From Northern Feed and Bean, Western Alfalfa Corp, Farmers Marketing Association, Monfort Farms,
Coors Brewery, Great Western Sugar Co.
3
Assume 70 percent of corn to be harvested as grain and 30 percent as silage.
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w
i
TABLE B-5
ESTIMATED CROP VALUE-SOUTH PLATTE RIVER
IN 1979 DOLLARS
„ ~ Crop Value
Crop Yield Per Acre 1979 Market Values Crop Acres Irrigated
Alfalfa 4.2 tons 49.50/ton 456 95,500
Corn (grain) 140 bu 2.74/bu 303 116,200
Corn (silage) 13.8 tons 18.31/ton 129 32,500
Sugar Beets 18.6 tons 29.00/ton 157 84,500
Field Beans 23.6 bu 10.00/bu 65 15,340
Barley (irrigated) 43.6 bu 2.64/bu 48 5,500
349,540
Estimated historic yields based on current market value of crops and information provided by Colorado
Agricultural statistician, Lance Fretwell.
2
Northern Feed and Bean, Western Alfalfa Corp, Farmers Market Association, Monfort Farms, Coors Brewery,
Great Western Sugar Company.
Wright-McLaughlin Engineers, Depletion Studies on the Fulton Ditch, Lupton-Bottom Ditch, and
Burlington Ditch-Wellington Reservoir System.
-------
Snowfall is generally not heavy, with most snow occurring
between November and April. The growing season, or frost-free
period is between April and September.
Wind data are summarized on the Annual Wind Rose (Figure B-7).
Generally, the winds are out of the south. Occasionally upslope
conditions prevail which follow the South Platte River drainage
from the northeast (15). Downslope conditions are more complex
but generally are from the northwest with some winds out of the
southwest. Local wind patterns will vary seasonally and diurnally.
GEOLOGY
Subsurface and geologic conditions are identified at the proposed
wastewater treatment facility and storage reservoir. Investi-
gations have been conducted at the proposed site (16, 17) and re--
viewed. The existing subsurface and geologic conditions are sum-
marized below:
Northern Adams County and southern Weld County are located
at the northwest edge of the Denver Basin. This region of the
basin is separated from the rest of the basin by the South Platte
River. The Denver Basin is a large north-south trending asym-
metrical, structured downwarp (18). The west side of the Basin
has been folded and faulted by the uplifting of the Front Range.
The bedrock geology of the reservoir site area consists of
the Dawson Group (Arapahoe Formation), the Laramie Formation, and
the Fox Hills Sandstone.
The Late Cretaceous, Arapahoe Formation has been eroded away
in this area with about 50 feet of the basal Arapahoe remaining (16).
Some locations in the area are void of the Arapahoe as a result of
faulting and erosion. This formation consists of interbedded sand-
stones and clay shales with occasional lenses of conglomerate.
The non-marine Laramie Formation (Late Cretaceous) underlies
the Arapahoe and is about 600 feet thick. This formation consists
of interbedded shales, siltstone, occasional sandstones and a few
localized coal beds. The top of the Laramie is an erosional sur-
face and is unconformably overlain by the Arapahoe Formation (16).
The Fox Hills Sandstone is the oldest of the three formations.
It is a Late Cretaceous marine deposit of sandstones and shales.
The top of the Fox Hills Formation is at a depth of about 650 feet.
Faults and Earthquakes
The historic seismicity and geologic and tectonic history of
the area has been reviewed to evaluate earthquake susceptibility
(17). Faults in the area were formed with the deposition of the
B-27
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FIGURE B-7
ANNUAL WIND ROSE
STAPLETON INTERNATIONAL AIRPORT
DENVER, COLORADO
N
Over 24-rnph
13-24-mph
8-12 mph
3-7 mph
LEGEND
Percentage frequency of wind direction
based on 10 years of 3-hourly data.
(1963-1972)
B-28
-------
Laramie and Arapahoe Formations in Late Cretaceous time (16).
These faults are classified as not potentially active and are not
believed to present any danger of movement (16, 18).
However, the area is within the Denver Seismic Zone and is
therefore subject to influence by seismic activity in the zone. The
Denver Seismic Zone does not coincide with a major fault zone and
surface fault ruptures have not been associated with historic earth-
quakes (17). This has resulted in the following conclusion (17):
"The Denver Seismic Zone is a potential source of
future earthquakes, however, judging from the lack
of major faults in the area, it is unlikely that
future earthquakes would exceed magnitudes greater
than 5.5 to 6.0 (Richter Scale)."
Because there is a potential for future earthquakes, design
features of any structure must account for earthquake stress. It
has been recommended that facilities related to the Northglenn plan
be designed for a maximum design earthquake that corresponds to a
Modified Mercalli Intensity of VIII (17), which corresponds to a
magnitude of between 6.1 to 6.7 on the Richter scale near the
epicenter. This earthquake is based on what is considered to be
a reasonable credible earthquake in the Denver earthquake zone.
ARCHAEOLOGICAL/HISTORIC RESOURCES
From February 28 to March 1, 1978, Dr. Dean Arnold, Department
of Sociology-Anthropology, Wheaton College, Illinois, conducted an
"Archeological Survey for the Area Affected by the Northglenn Water
Management Program." At the conclusion of this survey, he deter-
mined that there were "no known significant archeological sites nor
cultural resources that would be destroyed or adversely affected
by the proposed project."
The only area of interest identified in this survey was an
"historic dump of recent period probably 1900-1940 A.D.," which
site was referred to as "5AM66." This site was located on the east
side of the right-of-way of York Road, approximately 50 meters
from the crest of the hill, in the general vicinity of the proposed
site for the Northglenn force main. To avoid any interference with
or impact on the 5AM66 site, the City of Northglenn has agreed to
locate the force main on the west side of York Road, well away from
that site.
In addition, Northglenn agrees to include in all construction
contracts a provision requiring the contractor to halt construction
should any archeological artifact be discovered, and to notify the
City immediately. The City, in turn, will notify the State
Archeologist's office prior to authorizing the recommencement of'
construction at the site. Should the State Archeolegist's office
request time to examine the site prior to recommencement of con-
struction, Northglenn will provide this opportunity.
B-29
-------
To summarize, the Archeological Survey has disclosed no
areas of significance in the vicinity of the Northglenn sewage
treatment facility. With respect to site 5AM66, the City will
relocate its force main to avoid any impact on that site. Finally,
the City will include in all construction contracts, a provision
to halt construction to permit evaluation and protection of any
artifacts with archeological or cultural significance.
B-30
-------
REFERENCES APPENDIX B
1. Leonard Rice, Consulting Water Engineers, Water Engineering
in Colorado, January 1975.
2. Israelson and Hanson, Irrigation Principals and Practices,
Third Edition, Wiley International Edition, John Wiley and
Sons, Inc., New York 1962.
3. U. S. Department of the Interior, Water Measurement Manual.
Bureau of Reclamation, Second Edition, 1967.
4. Personal communication, Sheaffer and Roland, August 1979.
5. Musick, Williamson, Schwartz, Leavenworth, and Cope, P.C.,
Draft Application for Approval of Plan for Augmentation, 1979.
6. Hydro-Triad, Ltd. Engineers, Review of Northglenn/FRICO Land
and Water Resources Management Project, April, 1977.
7. Wright-McLaughlin Engineers, Inc., Northglenn Water Management
Plan, Volumes 1 and 2, Water Resources and Faciliites, April,
1977.
8. Colorado Department of Health, Water Quality Control Commission,
Regulations Establishing Basin Standards and an Antidegradation
Standard and Establishing a System for Classifying State Waters,
for Assigning Standards, and for Granting Temporary Modifications.
Adopted May 22, 1979, Effective. July 10, 1979.
9. Denver Business World, September 17, 1979.
10. EPA Agriculture Policy Memorandum from the Administrator to
Assistant Administrators and Regional Administrators, Office
Directors dated September 8, 1978.
11. United States Department of Agriculture, Soil Conservation Ser-
vice. Soil Survey of Southern Weld County, Unpublished.
12. United States Department of Agriculture, Soil Conservation Ser-
vice, Soil Survey of Adams County, 1974.
13. Personal communication. Stan Bayes, Weld County Extension
Service. August 23, 1979.
14. Colorado Agricultural Statistics Bulletin, January 1978.
15. Personal communication, National Weather Service, Stapleton
International Airport, September 25, 1979.
B-31
-------
16. Chen & Associates, Inc., Preliminary Engineering Geology and
Soils Investigation for a Proposed Reservoir Sections 26 and
36, T. IN., R. 68W. Weld County, Denver, Colorado. March, 1968.
17. Chen and Associates, Inc., Subsurface and Geological Investi-
gations for a Proposed Reservoir Site Weld County, Colorado.
Denver, Colorado. September, 1978.
18. Shaeffer and Roland, Inc., Northglenn Water Management Plan,
Volume 3 Wastewater and Return Flow Faciliites Plan. Prepared
for the City of Northglenn, Colorado. April, 1977.
19. U. S. EPA, Plutonium Levels in the Sediment of Area Impoundments
Environ of the Rocky Flats Plutonium Plant Colorado, SA/TIB-29,
February, 1975.
B-32
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-------
APPENDIX C
LITERATURE REVIEW OF PUBLIC HEALTH RISKS
Shuval has recently reviewed general wastewater reuse consi-
derations (1). He reported results of recent unpublished studies
in Israel indicating that poliovirus inocculated in sewage could be
detected in the soil and on cucumbers seven days after irrigation.
These results, as well as others such as the cholera outbreak in
Jerusalem in 1970 (2), were attributed to irrigation with sewage
receiving only primary treatment without any disinfection. Aerosal
dispersion studies of microorganisms (3) also indicate the impor-
tance of treatment process and controls in order to reduce health
risks of water reclamation for irrigation.
The World Health Organization (4) suggests treatment processes
for various reuse options. These options are summarized in Table
C-l. Reuse of reclaimed water for irrigation of food crops, with
the indicated processes and proper disinfection, are felt to be
essentially free of health hazards. The key requirement is proper
disinfection which is defined as: "the art of killing the larger
portion of microorganisms. . .with the probability that all patho-
genic bacteria are killed" (5). Chlorination of ordinary waste-
water usually does not kill all pathogenic organisms, especially
viruses. However, recent work at the University of California at
Berkeley (6) and at Pomona, California (7) indicates that virus
inactivation is possible through in-depth filtration (to remove
micro-particulates) and maintenance of a chlorine residual in the
effluent for at least two hours.
Based on the experience cited, it is clearly important to note
the conditions involved before relating them to the proposed North-
glenn proj ect.
Waterborne Diseases and Outbreaks
Many surveys on waterborne disease causing organisms have been
published (8, 9, 10, 11, 12 and 13). A summary list of diseases that
are potentially transmitted by food contaminated with wastewater and/
or fecal material is presented in Table C-2. Parasites that cause
hookworm, schistosomiasis and leptospirosis, which are transmitted
from human wastes and are capable of penetrating human skin, are a
potential health problem to farm workers (8).
Viruses. A report by Taylor provides an overview of the virus
problems stating the types of viruses found in water and the diseases
they cause (13). Viral diseases that have been linked to sewage
include polio, menengitis and infectious hepatitis (11). The infec-
tious hepatitis virus has not yet been isolated from any source media.
Information concerning infectious hepatitus is inferred from epidem-
iological data and other tests on human subjects (14).
C-l
-------
TABLE C-l
o
NJ
SUGGESTED TREATMENT PROCESSES TO MEET THE GIVEN HEALTH
CRITERIA FOR WASTEWATER REUSE*
Crops Not
for Direct
Human
, Consumption
Health Criteria (A + F)
Irrigation
Crops Eaten
Cooked;
Fish Culture
(B + F
or D + F)
Recreation
Crops .Eaten No
Raw Contact Contact
(D + F) (B) (D + G)
Municipal
Reuse
Industrial Non-
Reuse Potable Potable
(C or D) (C) (E)
Primary Treatment
Secondary Treatment
Sand Filtration or
Equivalent Polish-
ing Methods
Nitrification
Denitrification
Chemical Clarifica-
tion
Carbon Adsorption
Ion Exchange or
Other Means of
Removing Ions
Disinfection
o o o
o o o
o
o o o
o o o
o
o o o
O O 0
o o o
o o o
O 0 O
o o o
o o o
o o o
o o o
o o o
o o o
o o o
o o
o o o
o o
00
Reproduced with the permission of the World Health Organization from Reuse of Effluents: Methods of Waste-
water Treatment and Health Safeguards. WHO Technical Report Series No. 517, Geneva, 1973.
Health criteria: A Freedom from gross solids; significant removal of parasite eggs. B as A, plus sig-
nificant removal of bacteria. C as A, plus more effective removal of bacteria, plus some removal of
viruses. D Not more than 100 coliform organisms per 100 ml in 80% of samples. E No fecal coliform
organisms in 100 ml, plus no virus particles in 1,000 ml, plus no toxic effects on man, and other drink-
ing-water criteria. F No chemicals that lead to undesirable residues in crops or fish. G No chemicals
that lead to irritation of mucous membranes and skin. In order to meet the given health criteria, proc-
esses marked 000 will be essential. In addition, one or more processes marked 00 will also be essential,
and further processes marked „ may sometimes be required.
Free chlorine after 1 hour.
-------
TABLE C-2
DISEASES AND CAUSATIVE AGENTS TRANSMISSIBLE BY FOOD THAT HAS BEEN
CONTAMINATED BY WASTEWATER OR BY SOIL THAT CONTAINS FECAL MATERIAL (8)
Disease
Agent
Bacteria
Arizona infection
Bacillus cereus gastroenteritis
Cholerab
Clostridium perfringens
gastroenteritis
Enteropathogenic Escherichia
coli infection
Paratyphoid fever
Pseudotuberculosis
Salmonellosis"
Shigellosisb
Typhoid fever
Yersinia gastroenteritis
Viruses
Adenovirus infection
Coxsackie infection
ECHO virus infection
Poliomyelitis
Reovirus infection
Viral hepatitisb
Winter vomiting disease
Helminths '
Ascariasis
Trichiniasis
Arizona hinshawii
Bacillus cereus
Vibrio cholerae
Clostridium perfringens
Escherichia coli
(certain serotypes)
Salmonella paratyphi A
Salmonella paratyphi B
Salmonella paratyphi C
Salmonella sendai
Pasteurella pseudotuberculosis
Salmonella (over 1,500 serotypes)
Shigella sonnei
Shigella flexneri
Shigella dysenteriae
Shigella boydii
Salmonella typhi
Yersinia enterocolitica
Adenoviruses
Coxsackie viruses
ECHO viruses
Polioviruses
Reoviruses
Hepatitis virus A
Norwalk agent
Ascaris lumbricoides
Trichuris trichiura
Protozoa
Amebiasis
Balantidiasis
Coccidiosis (Isospora infection)
Dientamoeba infection
Giardiasis
Entamoeba histoyltica
Balantidium coli
Isospora belli, I. hominis
Dientamoeba fragilis
Giardia lamblia
a Other enteric bacteria which could conceivably be transmitted by foods
but proof is inconclusive: Streptococcus faecalis, s^. faecium, Proteus
spp., Prpvidencia spp., Citrobacter freundii, Enterobacter spp.,
Edwardsiella spp., Aeromonas spp., Pseudomonas aeruginosa.
b Reported outbreaks.
C-3
-------
Inactivation of the infectious hepatitis virus depends on the
level of water treatment and disinfection. Work by Young (15) shows
that out of 28 cases reported by Mosely, only four occurred where
complete treatment was available. Of those, one occurred after treat-
ment was by-passed, one lacked the evidence to implicate conclusively
the water supply, another resulted when a concentration of 0.8 mg/1
of chlorine was being applied to the water with no record of a 30-
minute residual, and the last happened where chloramines were used
for disinfection and plant records were inadequate to allow analysis.
McDermott reports virus in 5 out of 32 samples in the finished
water of one community and in 2 out of 32 samples in another community
(12). The infectious dose required to cause disease in humans by
viruses is unknown but is recognized as significantly less than
that dose required for bacterial infectious diseases.
Aerosol Transmission of Pathogens. One concern at sewage treat-
ment plants is the health hazard posed by aerosols from the waste-
water. In a survey by Hickey and Reist (16) the increase in likelihood
of contracting a respiratory disease because of working at a waste-
water treatment plant was reported to be insignificant. The number of
Klebsiella inhaled at a treatment plant are about one-eighth that
needed to produce infectious disease. Although inconclusive, the
incidence of pneumonia in workers at both water and wastewater treat-
ment plants was reported to be the same. Data concerning influenza
and colds were not conclusive.
Sorber (17, 18) has shown in pilot plant studies that aerosols
can disperse pathogens found in domestic sewage. A decrease in the
number of inhaled infectious viral units occurred with a corresponding
decrease in infectious viral units in the sewage. The viricidal
effect of sunlight and higher temperatures was found to be definite,
although the effect of relative humidity varied with different types
of virus. In aerosols, the majority of bacteria die off in the first
three seconds of exposure while some ^persist.
A review by Stanford and others (19) analyzed the morbidity risk
factors associated with spray irrigation of wastewater. The authors
state that a literature search has not revealed any incidence of
disease from irrigation with properly treated sewage (e.g., chlori-
nated secondary effluent). They also state that the formation of
droplets smaller than 500 microns in diameter should be prevented.
Katzenelson (3) presented data on aerosol hazards due to spray
irrigation with contaminated river water and aerated lagoon effluent.
Coliform bacteria and Salmonella were found 350 meters and 60 meters
(1,150 and 200 ft), respectively, from the sprinklers when contami-
nated river water was used. Only coliform bacteria were found in
tests on aerosols from an aerated lagoon, and these were at a
maximum distance of 30 meters (100 ft) from the sprinkler sites.
Irrigation with Wastewater Effluent. A committee organized by
the Sanitary Engineering Division of the American Society of Civil
Engineers stated that no outbreaks of disease due to crop irrigation
C-4
-------
with secondary effluent had been reported with the systems in use
up to 1970 (20). However, a number of outbreaks have been associa-
ted with various types of foods contaminated with wastewater, some
as a result of irrigation. One outbreak resulting from contaminated
vegetables occurred with the use of unchlorinated secondary effluent.
All other outbreaks were connected with water treated to a lesser
extent (8).
Katzenelson (21) demonstrated the hazards of using partially
treated nondisinfected oxidation pond effluent for irrigation. A
survey of the incidence of shingellosis, salmonellosis, typhoid fever
and infectious hepatitis showed that these diseases were two to four
times more prevalent in communities where spray irrigation was
practiced than in others. Unconfirmed cases of influenza also
occurred twice as often where spray irrigation with oxidation pond
effluent was used. However, no sigifnicant difference in disease
incidence was noted during the winter nonirrigation season.
One of the main hazards of irrigating crops with poorly treated
sewage is the possible spread of infectious hepatitis. Neefe and
Stokes demonstrated that the infectious hepatitis virus is trans-
mitted in the feces of humans. In another article by the same
author (14), the effects of the infectious hepatitis virus were shown
to be much less severe after exposure of effluent to high concen-
trations of chlorine, but only partially diminished after treatment
by aluminum sulfate or activated carbon.
Survival of Pathogenic Organisms in the Environment
Bacteria. A review by Sepp (23) includes discussion of the sur-
vival time of many organisms where wastewater is used for irrigation.
Extremely long survival times of such agents as Ascaris eggs and
Salmonella necessitate their elimination during wastewater treatment.
The major factors that influence bacterial survival in soil
are soil type, moisture, pH, sunlight, and temperature (24). pH values
between 2.9 and 4.5 inactivate most bacteria, whereas less inacti-
vation occurs with pH values between 5.8 and 7.8. Sunlight tends
to inhibit bacterial growth, while (within the ranges normally en-
countered) bacterial survival increases with increasing moisture
and temperature. Bacterial die off however can be reduced with
colder temperatures. Monitoring data from lagoon systems in North
Dakota indicate the highest levels of fecal coliform occur during
the winter.
The summary provided by Gerba et al (24), describes several
experiments on the movement of coliform bacteria through soil. In
all cases the die-off of the coliform bacteria from secondary effluent
was substantial after movement of the effluent through 6 meters to
10 meters (20 to 30 ft.) of soil.
Virus. Fujioka and Loh (25) indicate the poliovirus can survive
for 32 days in soil irrigated with secondary effluent. Experiments
C-5
-------
by Leffler and Kott (26) demonstrated longer survival times for
bacteriophage f2 than for poliovirus. In sand saturated with both
tap water and oxidation pond effluent, f2 was detected after 175
days, whereas poliovirus was not detected after 91 days. Bitton
(27) reviewed studies on virus movement through soil.
Duboise et al (28) demonstrated differences in the penetration
rates of viruses through soils resulting from the use of intermittent
instead of continuous flows. Young and Burbank's work with Hawaiian
soils showed that poliovirus passed through columns in which coliphage
T4 was trapped (29). Using coliphage T2 and poliovirus, Bitton (30)
presented evidence that secondary effluent caused desorption of vi-
ruses from soils particles. Interference by the organic matter
present in the secondary effluent was suggested as the reason for
desorption.
Most of the cases of viral and pathogen contamination of food
crops have occurred with irrigated crops (8). Studies by Bag-
dasaryan (31) indicated that survival of enterovirus on vegetables
is dependent on temperature. A 99.6 percent die-off in ten days was
noted with tomatoes at a temperature of 18° to 21°C (64° - 69°F),
compared with a 90 percent loss when kept for ten days at 4° to 10°C
(39° - 50°F).
Larkin et al (32) grew vegetables in plastic-lined wooden
boxes, spraying them with virus-laden sludge and effluent. The
vegetables were allowed to weather extensive periods of direct sun-
light, high temperatures and periodic rainfall. Though 99 percent
of the seeded polio was inactivated during the first five to six
days, virus still could be detected on the lettuce and radishes
after 36 days in one test and after 14 days in another. Other tests
using oxidation pond effluent were conducted by Kott and Fishelson
(33). Under conditions of greater than minimal sunlight, no virus
could be detected on the vegetable surface after 28 hours.
Drewry and Eliassen (34) concluded that virus movement through
soils under saturated conditions should present no real health
hazard to ground water supplies. However, studies by Wellings, et
al (35, 36) show that virus can remain infective after aeration,
sunlight and percolation through 20 feet of sandy soil. Wellings
also demonstrated vertical and lateral movement of virus, as well
as survival in sandy soil for 28 days during a period of heavy
rains. Due primarily to analytical difficulties, data concerning
the mobility and survival rates of infectious hepatitis is limited.
Removal of Pathogens by Treatment Processes
Different levels of pathogen removal by various treatment pro-
cesses should be considered when using reclaimed water. Bryan (8)
discussed the removal of a wide variety of bacteria and virus by
processes in sewage treatment plants. Malina (37) analyzed more
specifically virus removal by processes in both water and wastewater
treatment plants.
C-6
-------
Primary Sedimentation. Primary sedimentation normally removes
less than 50 percent of the pathogenic bacteria from sewage (8). The
wide variation in virus removals documented is probably due to varia-
tions in the concentrations of incoming suspended solids (37).
Viruses are known to adsorb to suspended solids and, hence, be
much less detectable in an analysis of the liquid phase. This does
not necessarily imply that their ability to infect is altered (38).
Biological Treatment. Biological treatment normally removes
about 90 percent of the pathogenic bacteria (8). The different
types of biological treatments vary somewhat in their ability to
remove virus. Activated sludge and aerated lagoon systems are the
two most effective. Both can remove more than 90 percent of the
incoming viruses. Careful operation can achieve removals of greater
than 98 percent (37).
In another study by Malina (39), the sensitivity of virus
removal to changes in different parameters of the activated sludge
process was examined. Virus inactivation was found to be indepen-
dent of 1) organic loading 2) hydraulic detention times and mixed
liquor suspended solids concentrations, and 3) whether oxygen or
air was used in the process. Virus adsorption to sludge was found
to be almost immediate. It was determined also that inactivation
in the process occurs in a time-stable sludge-virus complex. Fur-
ther information concerning virus inactivation in activated sludge
can be found in several other publications (19, 25, 40, 41).
Disinfection. Various disinfecting agents have received atten-
tion (21, 42, 43, 44, 45, 46, 23, 24, 25, 26, 27), but chlorine
remains the most widely used. Several factors influence the effec-
tiveness of chlorine in deactivating pathogens. These are discussed
in an article by Gulp (47) and are: 1) pH and the concentration of
hypochlorous acid present; 2) detention time; 3) turbidity or solids
content (the lower the concentration of particulate matter, the
more effective is disinfection); 4) presence of oxides of iron,
ammonia, manganese and hydrogen sulfide; 5) presence of organic
compounds; 6) temperature; and, 7) mixing.
Effective disinfection of wastewater with chlorine generally
requires a good quality effluent, (e.g. 30/30 BOD and suspended
solids) good mixing, adequate contact time and chlorination to the
breakpoint to obtain a free chlorine residual.
The use of ozone as a disinfectant has recently been given in-
creased consideration. In a comparison of ozone with chlorine (46),
it was noted that ozone oxidizes phenols, cyanides and pesticides
more completely than does chlorine. It also is unaffected by the
presence of ammonium. Disadvantages of its use are lack of residual,
cost and high sensitivity of bactericidal effectiveness to method
of application.
Coagulation. Various studies with coagulation-flocculation
processes have concluded that this is the most effective method of
virus inactivation in water treatment plants besides disinfection (43)
C-7
-------
Removals of greater than 99 percent have been recorded often (30,
31, 32, 48, 49, 50, 51, 52).
Chudhuri (53) concluded that coagulation-flocculation could
not be expected to operate with high virus removal efficiency in
wastewater because of the presence of organic matter. This conclusion
contradicts the findings of Sobsey et al (54), who showed that
99.95 percent of seeded influent virus were removed from raw sewage
by a packaged wastewater treatment system using alum flocculation.
Sobsey et al concluded that alum flocculation and activated carbon
adsorption.with subsequent removal by diatomaceous earth filtration
were functionally more important than chlorine in removing virus
when raw sewage was processed. Later tests on secondary effluents
by Wolf et al (52) showed greater than 99.7 percent removals ob-
tained in a large-scale pilot study.
Sand Filtration. Rapid sand filtration in conjunction with
flocculation is an effective means of removing virus. Sand filtra-
tion is used in wastewater treatment to remove cysts and Ascaris
eggs (8).
Carbon Adsorption. Carbon adsorption has been considered an
effective means of removing virus from water. Tests show that over
90 percent removal is possible. However, one conclusion about this
process may preclude dependence on carbon adsorption for virus re-
duction. Gerba et al (43), found that when the capacity of the
carbon column to adsorb virus is reached, desorption may occur with
the replacement of virus by organic substances. Such an occurrence
could cause a surge of viruses to enter the distribution system,
resulting in a highly virus-laden effluent.
C-8
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REFERENCES APPENDIX C
1. Shuval, H.I., Water Renovation and Reuse, Academic Press, 1977,
2. Cohen, J., et al., Epidemiological Aspects of Cholera El Tor
Outbreak in a Non-Endemic Area, Lancet, II, 1971.
3. Katzenelson, E. and Teltch, B., Dispersion of Enteric Bacteria
in the Air as a Result of Sewage Spray Irrigation and Treatment
Process, Journal Water Pollution Control Federation, 48, 1976.
4. World Health Organization, Reuse of Effluents; Methods of Waste-
water Treatment and Health Safeguards, WHO Technical Report
Series No. 517, Geneva, 1973.
5. Ingram, W. T., Gerber, R. A., et al., Glossary Water and Waste-
water Control Engineering, American Public Health Association,
1969.
6. Pearson, E.A., Personal Communication (Notes on Health Risks/
Virus in the Use of Reclaimed M&I Wastewater in Irrigation),
16 July 1977.
7. Parkhurst, J. D., et al., Pomona Virus Study Final Report, Sani-
tation Districts of Los Angeles County, 230 pp, February 1977.
8. Bryan, F. L., Disease Transmitted by Foods Contaminated by Waste-
water, in: Environmental Protection Agency Document No. 660/Z-74-
041, pp. 16-45, June 1974.
9. Clark, C. Scott, et al., Disease Risks of Occupational Exposure
to Sewage, Journal of the Environmental Engineering Division,
ASCE, Vol. 102, No. EE2, Proceedings Paper 12038, pp. 375-388,
April 1976.
10. Cooper, Robert C., Potler, J.L., and Leong, C., Virus Survival
in Solid Waste Leachates, Water Research, Vol. 9, No. 8, pp. 734-
739.
11. Long, William N., and Bell, Frank A,, Health Factors and Reused
Water, Journal of the American Water Works Association, pp. 220-
225, April 1972.
12. McDermott, James H., Virus Problems in Water Supplies, (Parts I
and II), Water and Sewage Works, May 1975.
13. Taylor, Floyd B., Viruses - What is Their Significance in Water
Supplies^, Journal of the American Water Works Association, pp.
306-311, May 1974.
14. Neefe, John R., Stokes, Joseph, et al., Disinfection of Water
Containing Causative Agents of Infectious (Epidemic) Hepatitis,
Journal of the American Medical Association, August 11, 1944.
C-9
-------
15. Clark, C. Scott, Notice of Research Project: Health Risks of
Human Exposure to Wastewaters, Starting Date, April 7, 1975.
16. Hickey, John L. S., and Reist, Parker C., Health Significance
of Airborne Microorganisms from Wastewater Treatment Processes
Part I and II, Summary of Investigations, Journal of the Water
Pollution Control Federation, Vol, 47, No. 12, December 1975.
17. Sorber, C.A., Schaub, S.A., and Bausum, H.T., An Assessment of
a Potential Virus Hazard Associated with Spray Irrigation of
Domestic Wastewaters, in: Virus Survival in Water and Wastewater
Systems (Malina & Sagik, Editors) Center for Research in Water
Resources, University of Texas at Austin, pp. 241-252, 1974.
18. Sorber, Charles A., and Guter, Kurt J., Health and Hygiene As-
pects of Spray Irrigation, American Journal of Public Health,
Vol. 65, No. 1, pp. 47-52, January 1975.
19. Stanford, G.B., and Turburan, R., Morbidity Risk Factors from
Spray Irrigation with Treated Wastewaters, United States Environ-
mental Protection Agency Document No. 660/2-74-041, June 1974.
20. Committee on Environmental Quality Management of the Sanitary
Engineering Division, Engineering Evaluation of Virus Hazard in
Water, Journal of the Sanitary Engineering Division, ASCE, SA1,
pp. 111-150, Feb. 1970.
21. Katzenelson, E., Buium, I., and Shuval, H.I., Risk of Communi-
cable Disease, Infection Associated with Wastewater Irrigation
in Agricultural Settlements, Science, Vol 194, pp. 944-946,
November, 1976.
22. Neefe, John R., and Stokes, Joseph, An Epidemic of Infectious
Hepatitis Apparently Due to a Water Borne Agent, Journal of the
American Medical Association, pp. 1063-1075, August 11, 1944.
23. Sepp, Endel, The Use of Sewage for Irrigation, A Literature
Review, Bureau of Sanitary Engineering, California State Depart-
ment of Public Health, Revised 1971.
24. Gerba, Charles, P., Wallis, Craig, and Melnick, Joseph L., Fate
of Wastewater Bacteria and Viruses in Soil, Irrigation and
Drainage Division, ASCE, Vol. 101, No. 1R3, pp. 157-175, Septem-
ber 1975.
25. Fujioka, R., and Loh, P.C., Recycling of Sewage for Irrigation;
A Virological Assessment, Abstracts of the Annual Meeting of the
American Society of Microbiology, E25, p. 5, 1974.
26. Lefler, E., and Kott, Y., Virus Retention and Survival in Sand
in: Virus Survival in Water and Wastewater Systems, (Malina and
Sagik, Editors), Center for Research in Water Resources, Uni-
versity of Texas at Austin, pp. 84-91, 1974.
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27. Bitton, Gabriel, Adsorption of Viruses onto Surfaces in Soil and
Water, Water Research, Vol, 9, pp. 473-484, 1975.
28. Duboise, S. F., Sagik, B. P., Moore, B. E. D., and Malina, J. F.,
Virus Migration through Soils, in Virus Survival in Water and
Wastewater Systems, Maline J., and Sagik, B., Editors, Center
for Research in Water Resources, University of Texas at Austin,
pp. 233-240, 1974.
29. Young, R. H. F., and Burbank, N. C., Virus Removal in Hawaiian
Soils, Journal of the Water Works Association, pp. 598-604,
September 1973.
30. Bitton, G., Masterson, M., and Gifford, G.E., Effect of a
Secondary Treated Effluent of the Movement of Viruses through
a Cypress Dome Soil, Journal of Environmental Quality, Vol. 5,
No. 4, pp. 370-375, 1976.
31. Bagdasaryan, G. A., Survival of Viruses of the Enterpvirus Group
(Poliomyelitis, Echocoxsackie) in Soil and on Vegetables, Journal
of Hygiene, Epidemiology, Microbiology and Immunology, VIII,
pp. 497-505, 1964.
32. Larkin, Edward P., Tierney, John T., and Sullivan, Robert,
Persistence of Virus on Sewage Irrigated Vegetables, Journal
of the Environmental Engineering Division, ASCE, Vol. 102,
No. EE1, February 1976.
33, Kott, Hanna, and Fishelson, Lea, Survival of Enteroviruses on
Vegetables Irrigated with Chlorinated Pond Effluents, Israeli
Journal of Technology, Vol, 12, pp. 290-297, 1974.
34. Drewry, W. A., and Eliassen, R., Virus Movement in Ground 'Water,
Journal of the Water Pollution Control Federation, Vol, 40, No. 8.
Part 2, pp. 257-271, August 1968.
35. Wellings, F. M., Lewis, A. L., and Mountain, C. W., Virus Survival
Following Wastewater Spray Irrigation of Sandy Soils, in: Virus
Survival in Water and Wastewater Systems, (Malina & Sagik, Editors),
Center for Research in Water Resources, The University of Texas
at Austin, 1974.
36. Wellings, F. M., Lewis, A. L., Mountain, C. W., and Pierce, L. V.,
Demonstration of Virus in Ground Water after Effluent Discharge
onto Soil, Applied Microbiology, Vol, 29, No. 6, pp. 751-757,
June 1975.
37. Malina, J. F., Ranganathan, K. R., Moore, B. E. D., and Sagik,
B. P., Poliovirus Inactivation by Activated Sludge, in: Virus
Survival in Water and Wastewater Systems, (Malina and Sagik,
Editors), Center for Research in Water Resources, University of
Texas at Austin, pp. 95-106, 1974.
C-ll
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38. Schaub, S. A., and Sagik, B. P., Association of Enterovlruses with
Natural and Artificially Introduced Colloidal Solids in Water and
Infactivity of Solids-Associated Viruses, Applied Microbiology,
Vol 30, No. 2, p. 212, 1975.
39. Malina, J. F., Viral Pathogens Inactivation During Treatment of
Municipal Wastewater, University of Texas at Austin, 15 pages.
40. Cooper, Robert C., Health Considerations in Use of Tertiary
Effluents, Journal of the Environmental Engineering Division,
ASCE, Vol. 103, No. EE1, Proceedings Paper 12726, pp. 37-47,
February 1977.
41. Lund, Ebba, Report on a Working Group on Bacteriological and
Virological Examination of Water, Water Research, Vo>l, 10,
pp. 177-178, 1976.
42. Cramer, W. N., Kawata, K., and Kruse, C. W., Chlorination and
lodination of Poliovirus and f2, Journal of the Water Pollution
Control Federation, Vol, 48, No. 1, pp. 61-76, 1976.
43. Gerba, Charles, P., Wallis, Craig, and Melnick, Joseph L., Viruses
in Water; The Problem, Some Solutions, Environmental Science
and Technology, Vol. 9, No. 13, pp. 1121-1126, December 1975.
44. Mijumdar, S. B., Ceckler, W. H., and Sproul, 0. J., Inactivation
of Poliovirus in Water by Ozonation, Journal of the Water Pollu-
tion Control Federation, Vol. 46, No. 8, pp. 2048-2053, 1974.
45. Parkhurst, John D., The Market for "Used" Water, The American
City, March 1968, pp. 78-80.
46. Selleck, R. E., and Collins, H. F., Disinfection in Wastewater
Reuse, in: Wastewater Reclamation and Resue Workshop. . .Pro-
ceedings, University of California-Berkeley, p. 286.
47. Gulp, Russell L., Breakpoint Chlorination for Virus Inactivation
8 pages.
48. Subsey, Mark D., Wallis, C., Hobbs, M. F., Green, A. C., and
Melnick, J. L., Virus Removal and Inactivation by Physical-Chemical
Waste Treatment, Journal of the Environmental Engineering Division,
ASCE, Vol, 99, No. EE3, pp. 245-252, June 1973.
49. Chaudhuri, M., and Englebrecht, R. S., Virus Removal in Wastewater
Renovation by Chemical Coagulation and Flocculation, Fifth Inter-
national Water Pollution Research Conference, Vol, II, No. 20,
pp. 1-21, July-August 1970.
50. Manwaring, J. F., Removal of Viruses by Coagulation and Floccu-
lation, Journal of the American Water Works Association, Vol., 63,
p. 298, 1971.
C-12
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51. York, D. W., and Drewry, W. A., Virus Removal by Chemical Coagula-
tion, Journal of the American Water Works Association, pp. 711-716,
December 1974.
52. Wolf, H. W., Safferman, R. S., Mixson, A. R., and Stringer, C. E.,
Virus Inactivation During Tertiary Treatment, Journal of the
American Water Works Association, pp. 526-631, September 1974.
53. Chaudhuri, M., Amirhor, P. E., and Engelbrecht, R. S., Virus
Removal by Diatomaceous Earth Filtration, Journal of the Envi-
ronmental Engineering Division, ASCE, Vol. 100, No. EE4, pp.
937-953, August 1974.
54. Sobsey, Mark D., Wallis, C., Henderson, M., and Melnick, J. L.,
Concentration of Enteroviruses from Large Volumes of Water,
Applied Microbiology, Vol 26, No. 4, pp. 529-534, October 1973.
C-13
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APPENDIX D
ALTERNATIVE WATER SUPPLIES AND ENVIRONMENTAL EFFECTS*
Within the Denver Metropolitan area, municipalities have several
options available for a water supply source. The very basic options
consist of developing a water resource on the West Slope, or East Slope
of the continental divide or a combination of both. This can occur by
developing/acquiring existing or new surface sources and for ground-
water .
WEST SLOPE WATER
Three options are considered for Northglenn's water supply origi-
nating on the West Slope. The options include:
0 Development of new appropriations
0 Acquire existing water rights
0 Participation in existing water development projects
New appropriations would require the creation of new water rights
on the West Slope. However, the availability of new appropriations in
the Colorado River Basin are not expected to provide a dependable water
supply. West Slope water availability is diminishing with the growth of
the West Slope, planned transmountain diversions, and perfecting of ex-
isting rights. Energy development demands, primarily oil shale, are
expected to use most of Colorado's share of the water allocated under
the Colorado River Compact. Lower basin states are expected to exercise
their rights under the Colorado River Compact and thus place a demand
for their adjudicated water below the Colorado state line. This new
demand will inadvertently impact water users in Colorado by transmitting
waters to the lower basin states. There is a high probability that a
lower basin demand will be imposed prior to the year 2000, and will be
concurrent with the completion date of the Central Arizona Project. It
is expected that this new demand will curtail the use of direct flow and
storage water rights junior to 1970 and may even affect rights junior to
1960.
Acquiring existing water rights involves the purchase of water
rights that are now physically in existence. Water rights could be
purchased from agricultural users or from an existing transmountain
diverter. A West Slope agricultural water right is expected to yield
from 0.75 to 1.25 acre feet per acre. Based on these figures the North-
glenn required agricultural land purchases would be from 6,000 to 10,000
acres.
Northglenn could participate in an existing West Slope water proj-
ect with another municipality. Projects which Northglenn may be elig-
ible to participate in include:
*Note: Another water supply alternative has been developed by opponents
to Northglenn's plan, but information on this new alternative was
submitted too late to be considered here. See Appendix M.
D-l
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Aurora's Homestake Project
0 Colorado Big Thompson
0 Windy Gap
Participation in the City of Aurora's Homestake Project is ques-
tionable at this time. The estimated yield from this project ranges
from 10,500 acre feet in an average year to 3,300 acre feet in a dry
year. It is unclear if Aurora has water supplies in excess of its own
requirements, and construction completion is not projected until 1988.
There is a possibility that Northglenn could participate in either
the Colorado Big Thompson Project (CBT) or Windy Gap Project.
Existing stipulations prohibit the use of CBT water outside boun-
daries of the Northern Colorado Water Conservancy District (NCWCD).
Northglenn is presently outside these boundaries and is therefore in-
eligible for CBT water. Northglenn could potentially be annexed into
NCWCD by one of two methods: NCWCD board approval and court petition,
or formation of a new subdistrict of the NCWCD. NCWCD is concerned with
their ability to meet present water demand projections, and past court
petitions for water have been defeated on the basis of impairing the
rights of present CBT water users. Furthermore, NCWCD's present water
supplies have been allocated to existing users within the district. The
extent of Northglenn's privileges as a new subdistrict would only be
that of attempting to buy out an existing user's right.
At present, the water supplies which will be developed by the
municipal subdistrict of the NCWCD through the Windy Gap project have
been allocated. Upon Northglenn's admission to the subdistrict, North-
glenn would have to purchase part of the allotment of an existing par-
ticipant. No excess water is currently available from any of the ex-
isting participants. In the event that Windy Gap water became avail-
able, Northglenn could take delivery at Boulder Reservoir. A pumping
station and pipeline would then convey the water to Northglenn's water
treatment plant. A 5,300 acre foot reservoir would be required to pro-
vide for the five month winter shutdown of Windy Gap.
ENVIRONMENTAL EFFECTS OF DEVELOPING WEST SLOPE WATER
Each of the West Slope water supply alternatives considered for
Northglenn will result in an adverse environmental impact to Colorado's
West Slope.
The most severe physical impact to the Colorado River basin of
transmountain diversions has been associated with reduction in flows and
associated increases of salinity. Salinity pollution in the Colorado
River has been increasing, which results in serious economic impacts to
the existing municipal, industrial, and agricultural users. Any new
appropriation and transmountain diversions of Colorado River water will
compound these impacts. If Northglenn were to acquire existing water
rights, the associated impacts could potentially be less in terms of
water quality, but would result in a reduction of irrigated agriculture
in Colorado.
D-2
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Acquisition of new or existing water rights on the West Slope to
support a water demand on the East Slope is also constrained economic-
ally and politically. The time involved in developing a water supply is
extensive and institutional arrangements difficult in addition to the
need to overcome engineering problems of conveyance. The construction
of the facilities needed to deliver the water to Northglenn would have
minor impacts.
Again the use of Windy Gap water by Northglenn would cause addi-
tional East Slope agricultural water right conversions. The development
of Windy Gap, as a project, would cause an increase in salinity.
EAST SLOPE WATER
East Slope water supply for the Denver Metropolitan area is of an
extremely competitive nature because of projected short falls in water
supply. For the Northglenn Water Resource Management Plan, EPA has
considered the following water supply sources:
0 New appropriation
0 Acquiring existing water rights
° Participation in existing water supply projects
New appropriations would require new water rights from the South
Platte River. Intense competition exists for any further allocation of
the South Platte River and its tributaries. It is thought that the
allocation of rights on the South Platte have been over extended in some
instances. A flow of 5,000 cubic feet per second (cfs) in the South
Platte River is considered necessary to realistically satisfy the per-
fected direct-flow water rights on the mainstream, even though the
decreed water rights far exceed 5,000 cfs. Flows in excess of 5,000 cfs
would represent surplus water available to a new appropriation. Flows
in excess of 5,000 cfs were experienced only ten years during the period
1896 to 1975. If the Narrows Reservoir is constructed and its condi-
tional water right perfected, no surplus water upstream of Narrows would
be available. Because of the unreliability of new appropriations in the
South Platte River basin, municipal water supplies would not be feasible
and new reservoir storage development would largely be supported by
independent water supplies or by existing decrees.
New appropriations of non-tributary water from the deep underlying
aquifer of the Denver Basin are available. Northglenn has applied for
such water rights.
Acquiring existing water rights on the East Slope would involve the
conversion of agriculture water. The market place and price of water
rights on the East Slope have been changing drastically in recent years.
Municipalities, because of their excess demands, are in competition for
agricultural water rights and prices for such water is rapidly increas-
ing. Municipalities have the right to condemn agricultural water as a
last resort to obtaining needed supplies. The conversion of agricul-
tural water rights to meet municipal demands is exerting pressures on
D-3
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agricultural water rights, and threatening the present agricultural
economy.
The existing systems available for Northglenn to pursue as water
supply options are: Denver Water Board, Thornton, and FRICO exchange.
Denver Water Board (DWB) has indicated in the past that it would be
interested in serving Northglenn1s water supply. Although recent re-
ports have indicated current supplies may not meet its present water
demands beyond 1998, long-range future supplies are under study. The
Denver City Charter prohibits water service outside the City limits if
there is not enough water for the intercity water requirements. Pres-
ently the DWB has adopted a policy of exercising caution in entering new
contracts for outside service and is limiting the number of annual taps
for new service. The DWB has stated that it fully intends to scrutinize
any additions to the service areas of its existing raw water customers,
and contracts for the distribution of raw water supplies outside the
service boundaries will be stopped.
If water service was available from Denver, either raw water ser-
vice or treated water service could be considered as an available
alternative.
Northglenn currently is receiving water fom the City of Thornton
and could continue. Future service would be subject to Thornton's
agreement to provide water and Thornton having sufficient water re-
sources. Thornton officials have indicated the City is capable of
providing an adequate quality of water and is agreeable to continue to
provide such service to Northglenn in the future.
Thornton is currently developing additional water resources for the
city and has applications in court for a number of various water rights.
Studies and documentation concerning Thornton's present supply and
future plans were not available for this analysis; however, a general,
overall discussion with City officials concerning this alternative has
provided information for considering Thornton for Northglenn's water
supply.
Thornton currently has a dry year yield of water approaching 20,000
acre feet per year which is adequate to supply Thornton's and North-
glenn' s current demand of about 14,000 acre feet per year. Northglenn
uses about 40 percent of the total or 5,600 acre feet. Utilization of
reservoir storage with Thornton's direct flow rights could increase the
dry year yield from 4,000 to 6,000 acre feet. Also, a proposed exchange
with the Burlington Ditch could add another 7,000 acre feet. Thornton
estimates it will require 20,000 acre feet per year by the year 2000
without providing service to Northglenn. Assuming reservoir storage and
the Burlington exchange is ultimately incorporated into Thornton's water
supply system, Thornton would have a yield slightly over 30,000 acre
feet which would meet the combined requirements of Thornton and North-
glenn for the year 2000. Thornton's ultimate need is estimated to be
45,000 acre feet without Northglenn. These estimates are based on
current projections as estimated by Thornton. Thornton is in the Water
Court on a number of projects and in the process of finalizing other
D-4
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water supply sources; therefore, conditions could change substantially
in the near future. The presenbt water supply sources for the City of
Thornton come from water rights located in Upper Clear Creek, Lower
Clear Creek, South Park, and pumping alluvial groundwater from the South
Platte River basin under G.A.S.P. G.A.S.P. or Groundwater Appropriator
of the South Platte river basin, Inc., is a non-profit organization of
volunteer members formed to provide replacement water for tributary well
pumping in the South Platte River Basin. G.A.S.P. rents approximately
30,000 acre feet of water each year from various sources, including the
Colorado-Big Thonmpson project and Union and McClellan reservoirs. This
water is turned over to the State to be released as necessary to replace
water withdrawn from the South Platte system between Denver and the
Nebraska and Wyoming state lines. Currently a member of G.A.S.P. is
required to replace five percent of the total well diversion.
According to Thornton's officials, planning for Thornton's water
supply in the future consists of the following:
1. The City will continue with an active program of purchasing
additional agricultural rights along Clear Creek.
2. Although Thornton does not currently own any rights on the West
Slope, there is a possibility of a joint venture development of
West Slope water in conjunction with other water users.
3. Thornton will continue to purchase agricultural rights in the
South Park area.
4. The City has filed for new storage rights in South Park and has
a storage exchange agreement with Aurora in Aurora's proposed
Spinney Mountain Reservoir.
5. Thornton has currently an application pending with the Water
Court to allow an exchange with the Burlington Ditch along the
South Platte River.
6. The possible expansion of tributary wells under G.A.S.P. is
also an alternative for future supplies to the City.
The FRICO exchange is considered an existing system because of the
various water sources associated with this alternative. This alterna-
tive can utilize a combination of deep non-tributary well developments,
purchase of existing water rights, and an exchange agreement between
Northglenn and FRICO. This plan is the proposed alternative and is
described in detail in the proposed water supply section of Chapter 3.
ENVIRONMENTAL EFFECTS OF DEVELOPING EAST SLOPE WATER
The most severe environmental impact of developing East Slope water
as a water supply source is a reduction in irrigated agriculture. This
impact is most critical to agriculture along the South Platte River and
areas adjacent to Metropolitan Denver. New appropriations of water
would have the least effect on agricultural production. However, as
D-5
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f he Watlr'cn V " T " ^ nOt ****"* -ai^ble. Furthermore,
tfon it L problbir^ I" determine that new water required augmenta-
turai uses! augmentation water would come from agricul-
cond municlPallties ^Ing water shortages in the
Condemn extensive areas of agricultural land for water
Water USe WiU Serve t0 dama§e an ^Portant part of
*
the cui °f te P™™^ ****>** cndition of
the agricultural land in the vicinity -of Denver, it is not in the best
interest of agriculture to pursue this type o.f water acquisition?
If Northglenn received its water supply service from Denver
•
., Mpply
as previously discussed. One additional option available to ?h"rnton Js
LPSty"r»;ter°f-NHfrthglenn'S "ater rightS a"d Corporate SemiMo
the city s water rights system. The total amount of water available
from such a potential purchase, not including the Northglenn-FRICO
exchange agreement, is 3,400 acre feet in a Iry year. The total
°f th
-.-S-
>9 mllli°n dollars' According to the Colorado
nrM,/nVlTmental lmpaCtS °f the N°«hglen-FRICO exchange are
presented in the agricultural productivity section of Chapter 4.
WATER SUPPLY ALTERNATIVE CONSIDERED FOR COST ANALYSIS
1•dPn^f^^u considered ^ove have been evaluated to
identify those which are considered the most feasible water supply
a
^~u±* LU iMorcngienn. Water supply alternatives considered
are discussed below.
West Slope
Of the alternatives available to Northglenn on the West Slope
Gap appears to be the most advantageous water resource. '
D-6
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This alternative would involve obtaining water from the Windy Gap
subdistrict of the NCWCD. There are 480 units available in the project
at 100 acre feet per unit. To ensure an adequate water supply, North-
glenn would need to purchase 75 units for a total entitlement of 7,500
acre feet per year.
Water transmission would require a pumping plant and pipeline to
convey the supply, most likely from the Boulder Reservoir, to
Northglenn's water treatment plant. The required pipeline would need to
be 42 inches in diameter, and approximately 22 miles long. The pump
station would need to provide a total dynamic lift of 360 feet. For
annual operation and reliability, 5,300 acre feet of reservoir storage
capacity would be needed. The reservoir could be either newly
constructed or an expansion of the Boulder Reservoir.
East Slope
The alternatives for water supply available to Northglenn on the
Ast Slope would be supplied from the Denver Water Board, Thornton, or
FRICO.
Denver Water Board
There are two options available for obtaining water from the Denver
Water Board. The options are either to purchase raw water or treated
water.
Raw Water Supply - Under a raw water contract agreement, Northglenn
could receive raw water supply at the Ralston Reservoir. Transmission
of raw water from Denver would be provided through a 36—inch pipeline
approximately nine miles long. The transmission main would have an
alignment from Ralston Reservoir to northglenn's treatment plant. The
flow of water in this transmission line would be by gravity.
Treated Water Supply - For this option, Northglenn would contract
with the Denver Water Board for full water service. Treated water
supply from Denver would be provided at 50th and Washington Streets.
Transmission of water would be through a 36-inch diameter eight-mile
long pipeline to Northglenn's proposed water storage tanks. A pump
station having 400 foot total dynamic head would be required.
Thornton
The least impact on agriculture would occur if Thornton were to
provide all of Northglenn's future water demand from water resources
developed in the South Park area. Conveyance to Thornton from south
Park is expected to be via the South Platte River.
FRICO
The alternative operational options for exchanging water and source
of the water is described in the Proposed Water Supply section of this
Chapter.
D-7
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APPENDIX E
REVIEW OF PROPOSED SYSTEM PERFORMANCE
-------
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APPENDIX E
REVIEW OF
PROPOSED NORTHGLENN
WASTEWATER TREATMENT SYSTEM
Prepared for
U.S. ENVIRONMENTAL PROTECTION AGENCY
REGION VIII
by
ENGINEERING-SCIENCE, INC.
May 1980
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TABLE OF CONTENTS
Title Page
Table of Contents
List of Figures
List of Tables
Page
i
11
ill
111
III- 1
LIST OF FIGURES
Title
Comparison of Effect of Temperature on Nitrification
in Suspended Growth and Attached Growth Systems
Aeration System Plan
Page
11-35
III- 2
Chapter I - Introduction
Chapter II - Treatment Concepts
Concepts
Aerated Lagoons
Primary Cell
Second Cell
Nitrification
Storage Reservoir
Estimated Effluent Quality
Pilot Studies
Analysis of Concepts and Studies
Raw Waste Load Data
Pilot Plant Treatability Studies
Five-day BOD Removal Analysis
TSS Removal Analysis
Analysis of Nitrification
Relationship of Five-day BOD Removal, TSS Removal,
Nitrification, and Algal Growth In the Proposed
Bull Canal Reservoir
Attainability of Permit Requirements
Fecal Coliform Requirements and Discussion
Comments Concerning Fecal Coliform Limitations
Chapter III - Design Evaluation
Conceptual to Final Design
Aeration System
Energy Requirements
Proposed Mitigation Measures
Chapter IV - Conclusions
I- 1
II- 1
II- 1
II- 1
II- 1
II- 2
II--3
II- 4
II- 7
11-14
11-27
11-27
11-29
11-30
11-32
11-33
11-34
11-37
11-38
11-38
III- 1
HI- 1
HI- 1
HI- S
HI-10
IV- 1
LIST OF TABLES
Number Title Page
II- 1 Reservoir Inflows II- 8
II- 2 Influent Water Quality II- 9
II- 3 Effluent Concentrations Needed to Meet NPDES Requirements 11-10
II- 4 Temperatufe Data 11-16
II- 5 pH Data 11-17
II- 6 Dissolved Oxygen Data 11-18
II- 7 Total Suspended Solids Data 11-19
II- 8 Volatile Suspended Solids Data 11-20
II- 9 5-Day Biochemical Oxygen Demand Data 11-21
11-10 Total Chemical Oxygen Demand Data 11-22
11-11 Soluble Oxygen Demand Data 11-23
11-12 Alkalinity Data 11-24
11-13 Ammonia-nitrogen Data 11-25
11-14 Nitrite and Nitrate Nitrogen Data 11-26
11-15 Wastewater Characteristics 11-28
III- 1 Temperature Loss Calculations for the Proposed Northglenn
Treatment System III- 4
III- 2 Comparison of Annual Energy Requirements for Proposed
Northglenn Treatment System and Selected Alternates III- 9
11
111
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CHAPTER I
INTRODUCTION
The U.S. Environmental Protection Agency, Region VIII, has evalu-
ated and analyzed the proposed lagoon wastewater treatment system and
Bull Canal Reservoir for the Northglenn Mater Management Program in
terms of: (1) the treatment concepts used to develop the system, (Z) the
translation of the treatment concepts to .final design, and (3) the
sufficiency of supporting data and raw waste data for the proposed
system. This report is intended to present the results of these
evaluations.
The second chapter of this report presents the treatment concepts
as developed by Professor Ross E. McKinney of the University of Kansas as
well as an evaluation of the applicability of these concepts, the
sufficiency of raw waste data and supporting treatability studies, and
an.evaluation of the system in terms of complying with proposed effluent
quality criteria'and public health aspects.
I The third chapter discusses the conversion of the conceptual
treatment techniques to the final design by Sheaffer and Roland, Inc.
Particular areas of concern will be the aeration system., the development
of low temperature (winter operation) treatment estimates, energy
requirements, mitigation measures for algae control and other specific
design details.
The final chapter presents a summary of the conclusions concerning
the system.
1-1
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w-
I
CHAPTER II
TREATMENT CONCEPTS
This chapter describes and analyzes the treatment concepts on for
the proposed Northglenn Project. Included is an analysis of the
sufficiency of data on the raw waste characteristics and the sufficiency
of studies providing supportive evidence for the proposed treatment
concepts.
CONCEPTS
The basic concepts used in designing the proposed system were
developed by Professor Ross E. McKinney for Sheaffer and Roland* Inc.
The basic treatment system proposed for Northglenn consists of a
three-stage aerated lagoon system followed by a large storage reservoir.
The effluent from the reservoir may be chlorinated if required. Mixing
and oxygen requirements in the lagoons will be supplied via submerged
static aerators.. The following description of these concepts is
extracted from various letters and memoranda from Professor McKinney to
Sheaffer and Roland, Inc. (References: Letter dated 2/18/78 from R.E.
McKinney to F.J. Roland; Memorandum entitled "Proposed Aerated Lagoon
for Northglenn, Colorado," prepared by R.E. McKinney and dated 4/4/78;
and Letter dated 8/26/78 from R.E. McKinney to P.O. Roland and
accompanying report entitled "Fundamental Concepts of Aerated Lagoons
with Special Emphasis on Nitrification" by R.E. McKinney dated 8/22/?8).
AERATED LAGOONS
Primary Cell
The specific des-ign criteria for the aerated lagoon will
depend on the wastewater characteristics. With normal domes-
tic sewage, a 24-hour, complete mixing aerated lagoon should
be adequate to convert the soluble BOD to microbial cells and
to maintain an adequate microbial population. The 24-hour
aerated lagoon should have a depth of 20 feet to take advantage
of the improved oxygen transfer using static aerators. Maxi-
mum oxygen transfer will be required at this point. Closely
spaced static aerators can provide good oxygen transfer and
good mixing. The sizing of the aerators will depend upon the
chemical characteristics of the wastewaters.
The use of complete mixing in the aerated lagoon cell
provides optimum reaction between the microorganisms and the
wastewater components. The soluble biodegradable organic
materials are quickly metabolized in the aerated lagoon with
only the resistant biodegradable suspended solids not being
metabolized completely in the 24-hour retention period. The
metabolic reaction results in conversion of the biodegradable
organics to microbial cells which are suspended solids. The
effluent from the 24-hour aerated lagoon will contain little
soluble BOD; but will contain some of the suspended BOD and the
microbial cells that will have a definite oxygen demand.
There will also be considerable quantities of ammonia nitrogen
from the degradation of proteins. The problems with the
24-hour aerated lagoon system i-s the need to remove the
suspended solids in order to produce a high quality effluent.
The suspended solids discharged from the 24-hour aerated
lagoon will be quite high, around 236 mg/1 total SS. The BODs
will also be high, approximately 80 percent of the living mass
of microbes. In this case the BODs should be approximately 90
mg/1, giving slightly more then 50 percent BODs reduction.
Normally, 24-hour, completely mixed aerated lagoons give 50
percent BODs reduction. Depending on the degree of metabolism
of the suspended solids in the raw wastewaters, the 600$
reduction should be between 40 and 50 percent.
The objective of the second phase of the aerated lagoon
will be to r.emove the solids and to stimulate nitrification.
Second Cell
The second lagoon will be concerned with endogenous
respiration of the living mass and the start of nitrification
during warm weather. Some suspended solids removal may also
occur since the degree of mixing will be less-than in the first
aerated lagoon cell.
Since the oxygen demand is lower than in the 24-hour
aerated lagoon, the four-day aerated lagoon has less aeration
equipment with greater spacing to produce a mixing action that
carries the solids around the aeration tank and down to the
bottom where the heavy solids settle out.
The changing aerator spacing will permit the heavy solids
to settle between the aerators and will keep the upper liquid
aerobic.
The effluent from the second aerated lagoon will have
less than 30 mg/1 BODs since some of the living mass will
remain in the second aerated lagoon with the settled solids.
If suspended solids are not kept in suspension, some
algae will start to grow in the second aerated lagoon cell.
There will be sufficient nutrients for algal growths if light
penetrates into liquid for sufficient time to allow the algae
to grow. Reasonable mixing should insure that minimum algal
growth will occur in the second aerated lagoon.
II-l
11-2
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The effluent from the four-day aerated lagoon will go to
a nine-day aerated lagoon with decreasing aeration to produce
induced settling in the larger aerated lagoon. The size and
spacing of the aeration equipment should be designed so that
the fine suspended solids have an opportunity to impinge on
the bottom of the lagoon and to be retained there. The mixing
action of-the aeration equipment should provide flocculation
necessary for reasonable solids agglomeration and settling.
It is expected that the suspended solids will drop to 30
mg/1 or less. The remaining suspended solids will be largely
inert materials that would not create any significant 8005.
Nitrification
Nitrification will not become significant until the third
cell. Some nitrification will occur in the second cell but it
will be limited by the ability to retain the nitrifying
bacteria in the second cell.
[In the third cell,] it is anticipated that nitrification
will be close to being complete since adequate oxygen will be
available for the reactions to be complete and time should
allow for the microbes to grow.
The slow growing nitrifying bacteria will be adversely
affected by the low temperatures in the winter months and the
lack of incoming seed.
If nitrification should not develop to the degree anti-
cipated, the system can easily be modified to produce the
desired results. The proposed modification would consist of a
series of redwood media boxes such as used in the ABF tower
filter, anchored to the bottom of the lagoon around each
aerator. The redwood boxes would form a support on which the
nitrifying bacteria would grow and reach sufficient numbers
that they would produce complete nitrification. The redwood
boxes would form surfaces for other microbes and suspended
solids to be retained. It is anticipated that the effluent
suspended solids would be quite low unless a heavy algae
growth resulted. Nitrification destroys alkalinity in pro-
portion to the degree of nitrification. One mg/1 ammonia
nitrogen oxidized to nitrate nitrogen will destroy 7.14 mg/1
alkalinity as 0.30)3. If sufficient alkalinity does not exist
in the wastewaters, nitrification will not be complete. The
data on available alkalinity and nitrification indicates that
nitrification could remove most of the alkalinity and force
carbon to be the limiting factor in the subsequent growth of
algae in the storage reservoir. Thus, nitrification would not
only shift the nitrogen from ammonia to nitrates but would
reduce the potential algal growth, yielding a higher quality
effluent.
It is expected that the effluent discharged from the
aerated lagoon into the reservoir will have a BOD and SS under
II-3
30 mg/1 unless excessive amounts of algae grow up. It is
expected that with complete nitrification, there will be
little carbon available for the alge to grow even though there
will be excess nitrogen and phosphorus.
STORAGE RESERVOIR
The storage reservoir should be designed as deeply as
possible with a minimum of surface area to reduce excess
evaporation of effluent. The excess nitrogen and phosphorus
could stimulate the growth of algae. With complete nitri-
fication most of the alkalinity will be destroyed and little
carbon will be readily available for the algae to grow on. The
use of limited aeration could turn the reservoir over and
minimize the sudden growth of algae. Slow mixing would keep
the nutrients dispersed and would help remove the algae by
flocculation and sedimentation within the storage reservoir.
The following excerpt describes the anticipated potential for algae
growth in the Bull Canal reservoir as described by Dr. McKinney
(Reference: Memorandum by R.E. McKinney dated 9/4/78 entitled "Antici-
pated Microbial Response in Reservoir for Northglenn, Colorado").
ALGAE
The stabilization of organic matter by bacteria produces
a stable effluent as far as bacterial metabolism is concerned.
In the presence of light energy the stable nutrients can be
metabolized by algae to form algal protoplasm. In effect, the
inorganics are converted back into organics which are no
longer stable. The algae undergo endogenous respiration the
same as bacteria. In the presence of light energy, the algae
take the end product of endogenous repiration and convert them
right back to new algae. The net result is that it appears
that the algae remain unchanged when actually they are under-
going continuous change. In the dark, the algae undergo
normal endogenous respiration with the release of nutrients.
When light returns, the released nutrients can be metabolized
again unless lost from solution during the dark period.
In natural water the growth of algae is limited by
phosphorus; but in polluted water the growth of algae is
limited by either nitrogen or carbon. Algal protoplasm has a
chemical composition very similar to bacteria and can be
represented by the empirical formula, CjHgO^.sN. Phosphorus
is normally 1/5 the nitrogen content. Normal domestic
wastewaters contain approximately 200 mg/1 BODs, 200 mg/1
alkalinity as CaC03, 20 mg/1 ammonia nitrogen, 15 mg/1 organic
nitrogen, and 10 mg/1 phosphorus. It is possible to convert
the BOD to its carbon equivalent and to do the same with the
alkalinity. The BOD has approximately 112 mg/1 carbon while
the alkalinity contributes an additional 24 mg/1 for a total
II-4
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of 136 mg/1 carbon. Approximately 2/3 of the BOD carbon is put
into bacterial cells in the synthesis reaction with a slow
release of additional carbon during endogenous respiration.
From a practical point of view, it is possible to estimate that
2/3 of the carbon related to the BOD would eventually be made
available for alg'al metabolism in the aerated lagoon system
where some suspended solids settling will occur. Actually
some of the carbon dioxide would be lost to the atmosphere in
the aeration cell through stripping at the aerator. The
metabolism of protein by bacteria results in the release of
ammonia which reacts with the carbon dioxide to produce
ammonium bicarbonate alkalinity. Metabolism of 10 mg/1 of
organic nitrogen would only tie up 9 mg/1 carbon from the
carbon dioxide. With 200 mg/1 alkalinity at pH 7, approxi-
mately 10 mg/1 carbon would be retained as carbon dioxide in
solution. The release of other minerals tied up by organic
acids which were metabolized by the bacteria helps bind the
carbon dioxide. Careful analyses would have to be made of the
specific system to accurately determine the amount of carbon
made available for algal growth. Alkalinity measurements
after the synthesis phase of bacterial growth in a 24-hour
aerated lagoon would indicate that the available inorganic
carbon is in the range of 48 mg/1 as bicarbonates.
The metabolism of bicarbonates by algae results in a pH
shift upward with the production of carbonates from bicar-
bonates. The carbonates tend to raise the pH to a point where
metabolism ceases. It is estimated that no more than 50
percent of 'the carbon in the bicarbonate alkalinity is
available for metabolism. This means that the 24 mg/1
converted to algal protoplasm would mean approximately 50 mg/1
VSS or 55 mg/1 TSS. If all the carbon could be converted to
cell mass, the algal mass would be around 300 mg/1. The
expected algal growth should be 1/6 the ultimate potential.
Nitrogen is a critical element for both bacteria and
algae growth. The metabolism of 200 mg/1 BOD by the bacteria
would result in 17 mg/1 nitrogen converted to cellular
protein. Approximately 10 mg/1 of the 15 mg/1 organic
nitrogen would be released by metabolism with 5 mg/1 remaining
unmetabolized. The net balance would require 7 mg/1 of the
ammonia nitrogen leaving approximately 13 mg/1 ammonia nitro-
gen untouched. Endogenous respiration would release addi-
tional ammonia in proportion to the rate of endogenous
respiration. If 2/3 of the nitrogen were eventually released
by endogenous respiration, a total of 23 mg/1 nitrogen would
be available for algal growth. At 10 percent nitrogen the
maximum potential growth would be 230 mg/1 VSS or about 250
mg/1 TSS as algal cells.
The 10 mg/1 phosphorus represents a potential algal
growth of 500 mg/1 VSS or 550 mg/1 TSS, making phosphorus the
least limiting of the three elements. In addition to these
elements, iron and magnesium are critical trace metals that
II-5
could also limit the total algal growth potential. Iron is the
more sensitive of the two trace nutrients since iron reacts
with phosphates to form a ferric hydroxy phosphate precipitate
that results in removal of the essential iron. It is hard to
establish iron deficient systems since growth simply levels
off before it should.
It appears from these data that with domestic sewage
carbon could easily become the limiting element in the growth
of algae. The availability of the carbon is the critical
factor in the final analysis. The loss of carbon dioxide
during initial metabolism is the hardest factor to evaluate.
In an aerated lagoon, the aerator-mixers help to drive off the
carbon dioxide since the concentration of carbon dioxide in
the air is quite small. The remaining alkalinity and pH are
the key parameters for determining the available carbon.
Recently, it has been shown that nitrification can play an
important role in the alkalinity reaction. Nitrification
results in the destruction of"7.1 mg/1 alkalinity as CaC03 for
each mg/1 ammonia-nitrogen oxidized. If the 13 mg/1 excess
ammonia-nitrogen were oxidized in the first aeration cell, 92
mg/1 alkalinity would be destroyed, dropping the alkalinity
from 200 mg/1 to around 110 mg/1. With a pH around 7.8, about
13 mg/1 carbon would be available for algal metabolism, the
total algae mass would be around 30 mg/1 until endogenous
respiration released additional carbon dioxide in the second
aerated lagoon. If the algae were able to obtain all of the
carbon released by endogenous respiration, the growth could
reach 80 mg/1 VSS or 90 mg/1 TSS. The total algal mass leaving
the second aeration cell could be as high as 120 mg/1. Further
growth of algae would depend upon additional endogenous
respiration of the bacteria or some other source of carbon.
With sedimentation of solids in the thrid aerated lagoon, the
algae population should show a significant decrease. A very
important reaction occurs with the growth of the algae, the pH
rises. It should reach well over 9 and might even reach 10.
The pH should balance with the relative concentrations of
alkalinity forms. As the pH rises, calcium carbonate will be
precipitated as will iron and calcium hydroxy phosphate. The
removal of iron and phosphate in the third aerated lagoon
should be sufficient in itself to prevent further algae growth
in the reservoir.
The effluent from the third aerated lagoon should have
around 100 mg/1 alkalinity and a pH above 9.0. During the
summer months, the nitrogen should be essentially all nitrates
if adequate oxygen is supplied. The precipitation of iron and
other trace metals should reduce further algae growth to a
minimum. The atmosphere will be the primary source of carbon
but the rate of transfer will be small, depending primarily
upon the degree of mixing at the air-water interface. It has
been estimated that 8 mg carbon could be transferred across
each meter of water surface per day which could yield
II-6
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Bl
I
approximately 20 mg of TSS per day if adequate light were
available and the other nutrients were in excess. Mixing will
be an important key to distributing the algae throughout the
reservoir volume. Not only will mixing distribute the algae
around the reservoir, mixing will assist in separation of the
algae by contact with the bottom surfaces.
Endogenous respiration of the algae results in a con-
tinuous degradation of the algae protoplasm. While the algae
reuse the nutrients released by endogenous respiration, ap-
proximately 20 percent of the algae mass produced will remain
as stable organic suspended solids which will not create an
oxygen demand or release their nutrients. In fact, the 20
percent solid fraction will tie up carbon, nitrogen, and
phosphorus. The net effect will be that nitrogen and/or
phosphorus will become the limiting nutrient in the reservoir.
The long retention time in the reservoir, 9 months should be
adequate to provide a reasonable effluent.
ESTIMATED EFFLUENT QUALITY
The effluent quality expected from the system as estimated by
Sheaffer and Roland based on the design concepts described in the
previous section is presented in the following excerpts from a memoran-
dum from Sheaffer and Roland to Bob McGregor dated November 16, 1979.
Based upon expected annual 600$ and suspended solids
loadings and reservoir release volumes, the anticipated NPDES
effluent requirements will be from 23 to 26 mg/1 BODs and from
22 to 30 mg/1 suspended solids depending on the amounts of
precipitation and evaporation experienced in a given year.
The Bull Canal reservoir is planned to receive 6,722 acre
feet of water during an average year. The wastewater
contribution to this flow is 5,200 acre feet annually, or 78
percent of the flow. Of the remaining 1,522 acre feet, 1,100
acre feet will be intercepted storm water and base flow from
Grange Hall Canal, and 422 acre feet will come from well fields
along the South Platte. During wet and dry years, these flows
will vary as shown in Table 1 (repeated here for convenience as
Table II-l).
The expected BODs and suspended solids concentrations of
each inflow source can be estimated based upon wastewater and
storm water sampling and analysis and existing well quantity
data as presented in Table 2 (repeated here for convenience as
Table II-2).
Based upon NPDES requirements of 30 mg/1 or 85 percent
removal of BODs and suspended solids, and Bull Canal reservoir
releases as dicussed in the basis of design the effluent
concentration needed to meet NPDES requirements are given in
Table 4 (repeated here for convenience as Table II-3).
II-7
TABLE II-l
RESERVOIR INFLOWS
Source
Averagi
Year
(acre feet)
Wet
Year
(acre feet)
Dry
Year
(acre feet)
Domestic Wastewater 5,200
Grange Hall Creek
Storm Water and
Base Flow 1,100
South Platte Well
Water 422
5,200
1,400
62
5,200
1,000
1,172
Total Inflows
6,722
6,662
7,372
SOURCE: Sheaffer and Roland, Inc., Memo of 11/16/79 to Bob McGregor from
Lee Rozaklis, Subject: NPDES permit for Bull Canal Reservoir.
II-8
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TABLE I1-2
INFLUENT WATER QUALITY
TABLE II-3
EFFLUENT CONCENTRATIONS NEEDED TO MEET NPOES REQUIREMENTS
W
Source
5-day Biochemical
Oxygen Demand
(mg/1)
Northglenn Wastewater
(from Northglenn Volume 7} 200
Urban Stormwater and Base
Flow (from Northglenn
Volume 1) 20
South Platte Well Water M)
Suspended
Solids
(mg/1)
190
300
M)
SOURCE: Sheaffer and Roland, Inc., Memo of 11/16/79 to Bob McGregor from
Lee Rozaklis, Subject: NPDES permit for Bull Canal Reservoir.
Average Year
OD5:
1.441 tons BOOn/year x 9.09 x IP8 mg/ton x 0.15
BODg:
24.7 mg/1 + 25 mg/1 BOD5
6,457AF/year x 1.233 x 10" liters/AF
Suspended Solids:
1.788 tons S.S./year x 9.09 x IP8 mg/ton x 0.15 _ 3n 6 ma/1 _> 30 ma/1 s s
6,457AF/year x 1.233 x 10t> liters/AF 30'6 mg/1 * 30 mg/1 S'S'
Wet Year
BOD5:
1.449 tons BODp/year x 9.09 x 108 mg/ton x 0.15
6,432AF/year x 1.233 x 10«> liters/AF
Suspended Solids:
„ _ 25 „ BOD
mg/ ' " mg/ ' BUU5
1,910 tons S.S./year x 9.09 x 1Q mg/ton x 0.15 _ ,, „ ,, ,n ,, <- ,-
- 6>432AF/year x 1.233 x IQb liters/AF -- 32'8 mg/1 * 30 mg/1 S'S'
Dry Year
BOD5:
Q
1.438 tons BODjj/year x 9.09 x 10 mg/ton x 0.15 ,, , „,, ,, „„,-, o
-» 7,049AF/year x 1.233 x IQb liters/AF 22.6 mg/1. ^ 23 mg/1 B
Suspended Solids:
1.747 tons S.S./year x 9.09 x 10 mg/ton x 0.15 . ,, . ., ,7 ,, <.
7t049AF/ye;r x T.233 x 106 nters/AF " " •* mg/' u mg/' :>
SOURCE: Sheaffer and Roland, Inc., Memo of 11/16/79 to Bob McGregor from
Lee Rozaklis, Subject: NPDES permit for Bul1^ Canal Reservoir.
11-9
11-10
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CO
The proposed aerated lagoon system, coupled with the
storage reservoir, should effectively remove virtually all
6005 present in the influent wastewater. Any BODs values in
the reservoir outflows should be exclusively a function of
algae cell concentrations.
Removal of influent BODs w111 be a function of influent
BODs concentration, water temperature, .detention time and
bacterial cell concentrations in the lagoon.
The influent mixture of wastewater and storm water is
expected to have an average suspended solids concentration of
196 mg/1, of which 94 mg/1 is expected to be nonbiodegradable
or very slowly biodegradable. This includes 22 mg/1 of
nonvolatile solids and 36 mg/t nonbiodegradable volatile
solids from the domestic wastewater portion of the influent,
and 36 mg/1 nonvolatile solids from the storm water portion of
the influent. Given the typically high specific gravity (1.25
to 1.40) of these solids, it is expected that these will settle
out of the water, primarily tn the third treatment cells and
the settling basin of the reservoir.
The remaining 102 mg/1 of the influent suspended solids,
along with the dissolved BODs, will be quickly metabolized to
produce an average of 140 mg/1 of bacterial solids in the
treatment cells. It is expected that 20 percent (28 mg/1) of
these solids will be nonbiodegradable and will settle out as
the bacteria are reduced by endogenous respiration. The
remaining bacteria will diminish to low levels (described in
the previous section) in the reservoir effluent. Thus, the
suspended solids present in the influent are expected to
settle out or be metabolized into bacterial solids which in
turn will settle or will undergo respiration.
The algal cells concentration in the reservoir will have
a peak BODs va^ue of 40 to 50 mg/1 and a peak suspended solids
value of 35 to 45 mg/1 during the months of July and August
assuming no settling of algal cells. Probable settling rates
will be on the.order of 60 percent, resulting in BODj levels of
16 to 20 mg/1 and suspended solids levels of 14 to 18 mg/1 in
the effluent.
The presence of algae is expected to be the major source
of both BODs and suspended solids in the reservoir effluent.
Algae production is expected to occur primarily in the storage
reservoir with some production in the third treatment cells.
The lack of an initial population of algae in the influent
wastewater, along with the high turbidity and high degree of
mixing expected in the first two cells, is expected to limit
algae growth in the first two cells.
Growth of algae requires the presence of carbon, nitro-
gen, and phosphorus as major nutrients, along with several
other micronutrients such as iron and calcium. The concen-
tration of nitrogen and phosphorus in the wastewater would
II-ll
support algal concentrations of 550 mg/1 and 750 mg/1,
respectively, if either nutrient were limiting. However, it
is expected that carbon will be the limiting fetor in this
case.
Algae require carbon in the form of dissolved carbon
dioxide, bicarbonate, or undissociated carbonic acid as a
carbon source for growth. The influent mix of wastewater and
storm water is expected to have an alkalinity of 308 mg/1 as
CaC03 (assuming 340 mg/1 is wastewater and 200 mg/1 is storm
water). af
The biodegradable organics in the influent will release
an equivalent of 250 mg/1 CaC03 alkalinity in the form of 003
gas during their initial conversion to bacterial solids. This
will occur entirely in the first two cells where algae growth
will be quite limited. It is, therefore, expected that this
COj will be stripped out of the water by the aeration process
and released to the atmosphere. As the heterotrophic bacteria
undergo endogenous respiration, they will release an equi-
valent of 396 mg/1 CaCOs alkalinity as CO? gas and 95 mg/1
CaC03 as ammonium bicarbonate. Approximately 60 percent of
this respiration will occur in the first two cells where C02
stripping will occur; therefore, only 158 mg/1 CaC03 alka-
linity as released C02 and 95 mg/1 CaC03 alkalinity as
ammonium bicarbonate will be available for algae growth due to
endogenous respiration. In addition, the introduction of 4200
SCFM of aeration into the third treatment cells will introduce
14 mg/1 CaC03 alkalinity as C02 during the nine day detention
period gf the third cell.
Therefore, it would appear that there would be a total of
575 mg/1 CaC03 alkalinity available for algae growth in the
third cell. This would allow the growth of 140 mg/1 of algal
cells. However, the nitrification of the 28 mg/1 of influent
NH3 plus an additional 9 mg/1 ammonia released during meta-
bolism of the influent BODs would reduce the available
alkalinity.
Consequently, the nitrification of 37 mg/1 NH3 will
consume 264 mg/1 of the 575 mg/1 CaC03 alkalinity.
The degree of nitrification occurring depends upon the
ammonia concentration, residence time of the nitrifying bac-
teria, and water temperature and the presence of adequate
oxygen. For ammonia concentrations above 5 mg/1, the mean
cell residence time needed for complete nitrification is
described by the formulas:
6 = 1/u ,
u = 0.5e°-07(T-2°) for temperatures between 10 and 30
degrees C
u - 0.25e°-15(T"10) for temperatures between 3 and 10
degrees C
11-12
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IS
vo
Where:
6 » solids retention, days
u » maximum net specific growth rate of nitrifying organ-
isms, days*'
T = operating water temperature, degrees C
Given the predicted treatment cell operating temperatures ...
it can be determined that sufficient aeration time will be
available for complete nitrification for all but the month of
January when approxmately 75 percent nitrification will occur.
The remaining 311 mg/1 alkalinity will be available for
algae growth. The metabolism of this alkalinity, mostly in
the form of bicarbonates, by algae results in a pH shift upward
with the production of carbonates from bicarbonates. The
carbonates tend to raise the pH to a point where algae growth
is curtailed. In natural water conditions no more than 50
percent of the bicarbonate alkalinity is available for meta-
bolism. This means that only 155 mg/1 alkalinity will be
converted to algae cells producing a cellular concentration of
36 mg/1 at a pH of 9-9.5 in the third treatment cell, assuming
no settling of algae. At this high pH, any remaining ammonia
will quickly volatilize, and any free phosphorus and iron will
precipitate out as ferric hydroxy phosphate and calcium
hydroxy phosphate. This will tend to produce an iron-limited
situation where further algae growth in the storage reservoir
will be eliminated. Even if iron is not limiting, the
additional uptake of carbon dioxide from the atmosphere in the
reservoir will result in an increase of only 4-5 mg/J algae,
bringing the total algae concentration to 39-40 mg/1, again,
assuming no settling.
As these algae are contained in the reservoir, they will
continually undergo an aging process followed by die-off and
reassimilation of nutrients by new algae cells. During
respiration and die-off of cells, CO? is released to the water
and some of it will be lost to the atmosphere. The result
will be a gradual reduction in algae concentrations. In
addition, the limited mixing in the third treatment cell and
the storage reservoir will promote substantial settling of
algae over time. While the effects of die-off and settling are
difficult to predict exactly, an analysis of algae die-off and
regrowth rates along with settling effects suggest an average
reduction of algae cells in the reservoir of approximately 60
percent. This will result in a final algal concentration of 16
mg/1 with a corresponding BODs volume of 18 mg/1.
The EPA and State of Colorado are proposing effluent requirements,
from the final reservoir, of 30 mg/1 BODs, 30 mg/1 TSS, and a fecal
coliform limit of 200 colonies per 100 ml for the 30-day average. The
seven-day maximum values proposed are 45 mg/1 for BODs and TSS and 400
organisms per 100 ml for fecal coliforms.
11-13
PILOT STUDIES
A pilot-scale simulation of the proposed system using two parallel
pilot units was conducted from the end of June 1978 to lovember 10, 1978,
by Dr. McKinney and- Mr. Norouzina (graduate student) to develop
information on the feasibility of the proposed jerated lagoon system and
the validity of the concepts employed in developing the, system approach.
The results of these tests and the test data are summarized from two
memoranda and reports prepared by -Or. McKinney (Reference: "Aerated
Lagoon Pilot Plant Study for Northglenn, Colorado," by R.E. McKinney and
M. Norouzian; and Memorandum entitled "Summary Results from Aerated
Lagoon Pilot Plant for Northglenn, Colorado," by R.E. McKinney dated
3/30/79).
The pilot plants were designed for a flow rate of two gallons
per day. Air was supplied from a small portable air compressor
fitted with a pressure reducer. The air flow rate was adjusted
to 5 1pm to give an oxygen transfer rate comparable to that of
the full scale system. The air diffusion system was a loop of
small plastic tubing around each cell with small holes at
regular intervals. Oxygen transfer tests were conducted on
one of the pilot plants prior to start up.
[Both]'pilot plant[s] [were] fed domestic wastewaters
from Lawrence, Kansas, since it had characteristics similar to
those of Northglenn, Colorado. [Each] pilot plant was fed one
gallon of wastewaters each morning and each afternoon on a
batch basis. The feeding process consisted of drawing off one
gallon of effluent from the third cell and wasting to the
drain. One gallon of effluent was removed from the second cell
and transferred to the third cell. One gallon of effluent was
then removed from the first cell and added to the second cell.
Finally, one gallon of domestic wastewaters was added to the
first cell.
The two pilot plants differed slightly. The first pilot
plant had two wooden racks around the aerator at the beginning
of thi third cell to permit nitrifying bacteria to attach
themselves in an effort to insure proper stability for
nitrification. After 56 days of operation the ammonia
nitrogen feed to the first pilot plant was increased by 30 mg/1
to determine the effect of high nitrogen on this system.
Dur-ing the entire study the pilot plant was operated outdoors
and was subjected to normal diurnal variations in temperature
and sunlight... The study was terminated on the 10th of
November when the weather began to approach winter.
11-14
-------
K
I
The results of the study are shown In Tables 1 through 11 of the
report prepared by McKinney and Norouzian, repeated here for convenience
as Tables II-4 through 11-14.
The two pilot plants were designated A and B with the three cells
designated as 1, 2, and 3 with cell 1 having one-day retention, cell 2
having four-day retention, and cell 3 having nine-day retention.
The temperature of the pilot plants averaged 16 degrees C
although it ranged from a high of 33 degrees C in August to a low
of 5 degrees C in October. Diurnal variations in temperature
were quite significant since the pilot plant was small and was
not insulated.
The pH tended to increase through the first two cells and
then decreased in the third cell. The change in pH is natural
for algal lagoons where the growth of the algae results in an
increased pH.
The suspended solids actually increased initially
through Cells 1 and 2 as a result of microbial growth. In Cell
1 the bacteria metabolized the soluble organics and increased
the SS. In Cell 2 the algae resulted in an increase in SS. Cell
1 was always comletely mixed, forcing the SS to move from Cell
1 to Cell 2 in direct proportion to their growth. Initially,
the SS were allowed to settle in Cell 2; but after about one
month of data collection, a decision was made to complete mix
the SS in Cell ^. SS were allowed to settle in Cell 3. Host of
the suspended solids in the effluent from Cell 3 were algae
cells.
The dissolved oxygen concentration was more than adequate.
There was sufficient DO for good bacterial growth and for
nitrification as well as carbonaceous BOD satisfaction.
The alkalinity decreased as nitrification increased. The
oxidation of ammonia results in the destruction of alkalinity
with a drop of 7.14 mg/1 alkalinity for each mg/1. It should be
recognized that denitrification results in an increase in
alkalinity. The net change in alkalinity represents the
balance between nitrification and denitrification.
The COO data decrease in Cell 1 represented the actual
oxygen uptake by the microbes in stabilizing the organic
matter. The COD rise in Cell 2 was related to the production of
organic solids as a result of algae. The increase in soluble
COD through the three cells is related to the washing of organic
matter off the bacteria. In effect, there is a small conversion
of suspended solids to soluble solids with time. The increased
soluble COD is nonbiodegradable....
The BOD data indicated that the first two cells of both
units gave similar results while the added wood surfaces in
Unit A gave slightly better solids separation. The BOD is
primarily related to the suspended microbes.
TABLE 11-4
TEMPERATURE DATA (°C)
Date
Aug.
-------
TABLE II-5
pH DATA
Date
Aug. 4
7
10
13
16
22
Sept. 3
8
11
16
21
25
29
Oct. 7
13
18
22
27
Nov. 1
5
10
RAW
7.4
7.0
6.9
7-3
7.0
7.5
7.6
7.4
7.7
7.2
6.7
7.6
7.3
7.6
7.0
7.2
7.4
7.1
7.1
7.4
7.1
A-1
8.4
8.3
7.9
8.0
7.8
8.2
8.1
7.8
7.5
7.6
7.9
8.0
7.8
8.1
7.9
8.0
8.0
7.9
7.8
7.8
7.9
A- 2
8.9
9.2
8.8
10.0
9.7
8.8
8.0
7.0
8.7
8.7
8.8
8.9
8.9
8.5
7.7
7.8
7-6
8.2
7.8
7.2
7.8
A-3
8.4
8.6
8.4
9.2
9-3
8.4
8.7
8.3
8.4
8.1
7.4
8.5
8.6
8.J
8.2
7-7
7.6
8.0
7.5
7.0
7.5
8-1
8.3
8.2
7.8
8.0
7.8
7.9
8.0
8.0
7.5
7.7
7.8
8.0
7.9
7.8
7-9
7.9
8.1
8.0
8.2
8.0
8.1
B-2
8.8
9.2
8.7
9.8
10.1
8.7
7.9
8.0
8.1
8.3
8.1
8.8
9.0
8.0
8.3
7.9
7.9
8.1
8.2
8.1
8.2
8-3
8.3
8.5
8.3
9.4
9.3
8.6
8.7
8.3
8.4
8.7
8.4
7.9
8.8
•8.2
8.4
8.2
6.0
8.4
8.5
8.2
8.2
SOURCE: "Aerated Lagoon Pilot Plant Study for Northglenn, Colorado"
R.E. McKinney and M. Novouzian, June 1975.
11-17
TABLE II-6
DISSOLVED OXYGEN, DATA (mg/1)
Gate
Aug. 4
7
10
13
16
22
Sept. 3
8
11
16
21
25
29 '
Oct. 7
13
18
22
27
Nov. 1
5
to
RAW
0.8
1.0
1.4
1.2
1.0
1.0
0.8
0.5
0.7
0.5
0.5
0.4
0.4
0.3
0.0
0.0
0.0
0.0
0.0
0.0
0.0
A-1
9.2
8.3
7.1
6.9
6.1
8.0
7.3
7.4
7.2
8.2
9.1
8.3
8.8
8.9
9-8
9-0
7.0
9.5
10.5
9.8
9.5
A-2
9.5
9.4
8.3
7.5
7.1
8.8
8.2
8.5
8.4
8.1
9.8
9.4
9.5
9.8
9.8
9.5
7.1
9.8
12.5
11.0
10.6
A-3
9.2
9-2
8.3
7.7
7.2
9.1
8.9
8.9
8.3
7.8
9.6
9.4
9.8
10.0
9.4
9-6
6.8
10.4
11.2
11.0
10.4
B-1
9.4
9.4
7.4
6.9
6.3
9.0
4.4
8.2
8.0
8.2
9.5
9.0
9.7
11.4
9.0
9.4
7.4
0.0
11.0
10.0
10.6
B-2
9.8
10.5
8.3
7.8
7.2
9.2
8.2
9.1
8.7
8.7
9.8
10.1
11.5
12.0
10.0
IO.-0
7.5
10.3
12,0
10.9
11.4
B-3
9.5
10.0
8.3
7.8
7.6
9.0
9.8 •
9.1
8.4
8.4
9.6
9.3
1.0
1.4
9.6
9.5.
6.6
10.1
12.1
12.0
11.2
SOUPXE: "Aerated Lagoon Pilot Plant Study for Northglenn, Colorado"
R.E. McKinney and M. Novouzian, June 1975.
11-18
-------
TABLE 11-7
TOTAL SUSPENDED SOLIDS DATA (mg/1)
W
H1
Date
Aug. 4
7
10
13
16
22
Sept. 3
8
11
16
21
25
29
Oct. 7
13
18
22
27
Nov. 1
5
10
RAW
110
160
210
150
340
140
190
270
220
170
ISO
410
360
140
370
170
290
240
170
190
320
A-1
250
290
310
160
290
170
180
250
260
190
290
300
240
260
420
240
210
260
260
200
360
A-2
4
8
16
12
5
5
560
850
760
610
510
500
590
560
360
420
360
370
370
260
330
A- 3
10
15
22
28
19
10
23
23
15
13
31
42
52
33
44
42
120
320
140
140
280
6-1
260
240
280
140
310
170
170
270
210
240
160
270
190
260
360
270
210
280
280
170
380
B-2
22
32
26
22
10
6
1060
73
640
640
480
520
600
510
470
470
370
390
340
280
350
B-3
22
22
23
29
22
22
58
73
120
100
130
230
90
160
11
27
15
280
ISO
340
220
SOURCE: "Aerated Lagoon Pilot Plant Study for Northglenn, Colorado",
R.E. McKinney and M. Novouzian, June 1975.
11-19
TftBLE II-8
VOLATILE SUSPENDED SOLIDS DATA (mg/1)
Date
Aug. 4
7
10
13
16
22
Sept. 3
8
11
16
21
25
29
Oct. 7
13
18
22
27
Kov. 1
5
10
RAW
100
ISO
170
120
270
110
130
190
180
120
120
260
270
110
300
22
190
180
120
120
230
A-1
170
210
230
120
230
140
140
160
200
120
190
210
170
200
310
180
64
200
180
140
260
A-2
2
2
• 6
4
3'
3
370
570
340
420
380
340
450
410
270
310
270
280
270
180
240
A- 3
10
8
- 13
17
17
7
14
14
9
5
21
35
46
26
37
31
92
240
100
120
210
B-!
190
160
200
100
240
140
120
170
46
130
170
190
140
200
270
200
ISO
210
200
130
280
B-2
20
22
16
10
6
5
650
63
416
360
320
370
430
390
350
360
270
280
,250
210
240
B-3
19
15
16
18
20
20
48
63
97
86
120
180
76
130
7
20
10
220
120
230
180
SOURCE: "Aerated Lagoon Pilot Plant Study for Northglenn, Colorado",
R.E. McKinney and M. Novouzian, June 1975.
11-20
-------
TABLE I1-9
5-DAY BIOCHEMICAL OXYGEN DEMAND DATA (mg/1 BODO
TABLE 11-10
TOTAL CHEMICAL OXYGEN DEMAND DATA (mg/1 COD)
H
Date
Aug.
-------
TABLE 11-11
SOLUBLE CHEMICAL OXYGEN DEMAND DATA (mg/1 COD)
TABLE 11-12
ALKALINITY DATA (mg/1 as CaCCh)
M
I
Date
Aug. J)
7
10
13
16
22
Sept. 3
8
11
16
21
25
29
Oct. 7
13
18
22
27
Nov. 1
5
10
RAW
110
260
310
88
210
120
HO
200
4
120
240
65
130
160
140
160
170
160
240
160
260
A-1
120
67
150
45
48
13
67
54
70
88
42
38
55
58
43
49
52
47
47
58
50
A- 2
•45
50
8
58
55
13
94
58
70
53
46
54
55
50
44
53
45
51
51
45
46
A- 3
70
65
63
68
69
25
110
100
7!
66
50
73
70
58
61
53
75
51
59
56
50
B-l
40
40
33
41
27
80
47
48
47
51
56
38
51
54
57
56
63
47
51
50
50
B-2
35
43
47
56
41
47
78
220
60
47
46
54
55
46
46
51
78
47
51
50
46
B-3
60
37
49
74
75
38
59
210
160
160
85
84
91
62
40
60
52
55
55
46
61
Date
Aug. 4
7
10
13
16
22
Sept. 3
8
11
16
21
25
29
Oct. 7
13
18
22
27
Nov. 1
5
10
RAW
210
160
180
200
200
190
170
200
200
190
190
220
210
210
180
200
230
200
200
200
200
A-1
130
160
160
ISO
120
160
110
130
80
85
140
120
120
140
130
140
140
150
130
100
140
A- 2
100
64
150
130
120
150
80
- 62
70
86
90
110
110
120
46
67
75
83
51
23
60
A-3
80
48
100
120
140
130
92
110
110
120
94
120
130
140
92
52
55
48
30
17
23
B-1
140
160
170
160
120
150
120
140
78
100
150
130
120
140
130
130
160
160
140
120
150
8-2
110
67
150
130
120
150
87
110
72
62
94
110
110
120
93
97
110
110
69
69
83
B-3
80
50
110
120
140
140
94
110
120
120
100
110
120
130
130
130
140
140
130
130
120
SOURCE: "Aerated Lagoon Pilot Plant Study for Northglenn, Colorado",
R.E. McKinney and M. Novouzian, June 1975.
SOURCE: "Aerated Lagoon Pilot Plant Study for Northglenn, Colorado"
R.E. McKinney and M. Novouzian, June 1975.
11-23
11-24
-------
TABLE 11-13
AMMONIA-NITROGEN DATA (mg/1 NHyN)
Date
Aug. <>
7
10
13
16
22
Sept. 3
8
11
16
21
25.
29
Oct. 7
13
18
22
27
Nov. 1
5
10
RAW
12
22
20
25
1.7
30
27
30
38
38
32
23
26
A-1
5.8
10.7
15
7.0
10
50
70
60
75
80
74
60
60
A-2
0.6
0.6
O.T
0.8
1.0
5.0
32
40
51
61
48
42
48
A-3
0.1
1.1
0.1
0.6
0.5
0.0
0.7
0.5
14
28
23
27
23
B-1
8.0
10.3
16
8.0
12
10
11
15'
24
25
16
9.0
15
B-2
1.2
0.5
0.1
1.0
0.4
1.8
0.9
2.5
3.5
12
2.0
0.3
1.6
B-3
0.1
1.3
1.0
1.3
0.7
0.0
0.7
5.0
3.0
0.8
0.9
1.5
1.4
SOURCE: "Aerated Lagoon Pilot Plant Study for Northglenn, Colorado"
R.E. McKinney and M. Novouzian, June 1975.
11-25
TABLE 11-14
NITRITE AND NITRATE NITROGEN DATA (rng/1 N07 + N(h-N)
Date
Aug. 4
7
10
13
16
22
Sept. 3
8
11
16
21
25
29
Oct. 7
13
18
22
27
Nov. 1
5
10
RAW
1.1
1.0
1.5
0.8
0.7
0.6
1.0
0.8
0.7
0.5
0.9
0.4
0.6
0.7
1.0
1.5
0.8
0.8
1.1
0.8
1.0
A-1
13
7.0
7-0
11
12
11
10
9-5
26
20
3.7
20
16
10
10
7-5
9.0
7.0
8.5
13
5.1
A-2
0.5
0.5
"0.5
0.5
0.5
0.5
6.0
8.0
7.5
6.0
3.8
3.0
5.1
5.5
10
7.0
4.0
9.0
14
13
12
A-3
21
0.5
0.5
0.5
0.5
0.5
0-5
0.5
0.5
0.5
0.9
0.5
0.3
0.5
1.0
0.5
6.5
8.7
14
11
9.5
B-l
21
6.5
6.0
7.7
12
11
7.5
6.7
24
16
3.0
16
7.0
10
8.0
8.0
6.5
6.5
8.0
10
4.8
B-2
21
0.5
0.5
0-5
0.5
0.5
5.0
9.5
6.0"
7.0
4.3
3-0
4.0
5.0
8.0
7.0
5-0
12
19
13
13
B-3
21
0.5
0.5
0.5
0.5
0.5
O.a
1.0
1.0
1.0
0.6
0.3
0.2
0.3
7-0
9.0
0.6
1.8
2.0
0.9
2.5
SOURCE: "Aerated Lagoon Pilot Plant Study for Northglenn, Colorado",
R.E. McKinney and M. Novouzian, June 1975.
11-26
-------
TABLE 11-15
W
I
The ammonia nitrogen decreased through the three cells as
result of nitrification and synthesis of algal protoplasm. The
B Unit showed almost 90 percent reduction in total nitrogen.
Increasing the nitrogen in Unit A showed a definite reduction
in nitrogen. Unfortunately, the low temperature in October and
November resulted in incomplete nitrification.
ANALYSIS OF CONCEPTS AND STUDIES
This section presents the analysis of the concepts of treatment and
the capabilities of the proposed system. These analyses represent the
results of an independent analysis of the proposed concepts, data base,
treatability studies, and other items supplied by Shaeffer and Rolands,
Inc. These analyses will be further divided into subsections on
sufficiency of raw waste load data, treatability studies, BODs removal
and discharge, TSS removal and discharge, nitrification, algae growth
and the limitation of such growth in the reservoir, and an evaluation of
the capability of the proposed system to fully meet proposed effluent
requirements for BODs and TSS. A separate section will be devoted to an
analysis of- the capability of the system to meet the fecal coliform-
requirements, the applicability of these requirements, and the implica-
tions of the reservoir effluent in terms of potential public health
problems.
Raw Waste Load Data
As several of the documents and memoranda between Dr. McKinney and
Sheaffer and Roland, Inc. indicated, the development of a good data base
describing the raw waste loads expected in the proposed system is
essential to the success of attaining full-scale operation as described
in the proposed concepts. This is particularly true in the case of the
relationships between nitrification, ammonia levels, alkalinity, the
ability to achieve a carbon limiting system in the reservoir, and
ultimately the degree and potential for algae growth sufficient to
exceed effluent permit standards.
The data used in developing the design of the Northglenn system
consist of a series of samples representing one 13-day period in February
and March 1978. These data are presented in Table 11-15. This data base
may not be sufficient for the system proposed for the following reasons:
11-27
WASTEWATER CHARACTERISTICS
Total 600.
Soluble BOD
Total COO
Soluble COO
Suspended Solids
Volatile Solids
Total Solids
Dissolved Solids
pH
Alkalinity
Tota 1 1 ron
Sul fates
Sulfides
Total Sulfur
Sod i urn
Potassium
Calcium
Magnesium
Chlorides
Kjeldahl-N
Ammonia-N
Organ ic-N
Total Phosphorus
Cadml urn
Zinc
Molybdenum
Chromium
Lead
Copper
Boron
Nickel
Selenium
Arsenic
200 mg/1
60 mg/1
220 mg/l
80 rng/1
190 mg/1
220 mg/1
720 mg/1
530 mg/1
7.2
340 mg/1 as CaCOj
0.9 mg/1
160 mg/1
0.2 mg/1
5
-------
w
(1) The data do not represent year round operation in terms of
changes in key parameters such as ammonia-nitrogen concen-
trations, alkafinity levels, etc.
(2) Due to the abnormally high (for municipal wastewaters) ammonia
and total Kjeldahl-nitrogen (TKN), additional sampling should
have been conducted to assure the accuracy and representa-
tiveness of those values.
(3) Sampling of the proposed supplementary water sources, storm
water runoff, irrigation return water, and especially the new
source of potable water should have been carried out to
determine if the ammonia-nitrogen.-alkalinity ratio would be
changed when water from the City of Thornton water is no longer
used. In addition, the quantities of ammonia and the
alkalinity levels in the storm water runoff and irrigation
return flows have not been considered in developing the
overall system concept. The effect of these may be consider-
able, especially during periods of peak flow and so could-
cause considerable changes in the overall ammonia-nitro-
gen: alkalinity ratio.
Pilot Plant Treatability Studies
The pilot plant studies were carried out in a very professional
manner. The data which were collected and the results appear to be
consistent with other similar studies. Several potential concerns
regarding the relationships of these studies to the Northglenn situation
• are:
(1) Lawrence, Kansas, wastewater, not Northglenn wastewater, was
used. Differences in the ammonia and alkalinity relationships
between these two sources were not considered.
(2). There was insufficient run time during cold weather. Cold-
weather operation is critical in aerated lagoons due to the
long detention times and low rates of biological activity.
This is especially true for extreme cold weather such as that
experienced in the Denver area.
(3) No documented attempt to simulate the storage reservoir
conditions was performed. Although one test using effluent
from the pilot plant in a glass carboy placed in the sun did
not produce significant algal growth, according to a verbal
report from Dr. HcKinney, the long-term effects of material
carryover and other nutrient sources to the proposed reservoir
were not adequately considered.
In summary, the pilot plant tests are valuable in terms of
evaluating the level of performance which should be achieved by the
Northglenn system. However, care must be taken to recognize the
limitations of the pilot studies in terms of their direct comparability
to the Northglenn project.
Five-day BOD Removal Analysis
The removal of BOD5 from municipal wastewaters by aerated lagoon
systems such as those proposed for Northglenn may be characterized as
follows:
(1) During the sunnier, essentially complete removal of soluble
BODs should be expected and most of the insoluble BODs in the
influent should be assimilated or removed by sedimentation.
The main contributors to BODs i" tne effluent from the third
cell of the aerated lagoon should be from microbial suspended
solids snd algae which have not settled out. Microbial solids
at this point may be expected to contribute approximately 0.2
to 0.5 pounds of BOD5 per pound of solids. The 600$ which can
be attributed to algal cells can be as low as almost zero (no
die-off) to an excess of one pound of BODs Per pound of algae.
If the TSS from the third aerated lagoon can be controlled
during the summer, then the effluent BODg load to the
reservoir should be quite low. Should the expected high flow
rates of up to 13.1 million gallons per day occur for extended
periods during the summer, the increased mass loading of 8005
.coupled with the decreased treatment efficiency due to much
shorter detention times may lead to relatively high carryover
11-29
11-30
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M
00
of BODg into the reservoir. Should this occur during a dry
year when the reservoir is at minimum storage volume then the
BODs in the reservoir could rapidly approach the level of the
lagoon effluents.
(2) The 6005 in the effluent from the reservoir will be pre-
dominantely affected, in the summer, by the algae population
in the reservoir as this should be the main source of BODs-
However, minor amounts of BODs may be present from other
sources and some minimal background level not associated with
algal cells should be anticipated.
(3) During the winter, the efficiency of the aerated lagoons in
removing BODs will be significantly reduced. As the pilot
studies performed by Dr. McKinney and Mr. Norouzian indicated
(October 7, 1978, through November 10, 1978), as the first-
stage lagoon temperature dropped to about 10 degrees C, the
BODs removal in the first cell was reduced from about 45
percent (at an average first-stage temperature of 20 degrees
C) to 36 percent (at an average first-stage temperature of 10
degrees C) in System A and from 44 percent to 38 percent in
System B. Overall BODs removals for all three cells over the
two periods was from 90 percent removal to 80 percent removal
for System A and from 78.9 percent to 78 percent in system B.
The removals in System B are masked by high TSS (and related
BODs) carryover in the effluent during the warm period of the
study. Even more important may be the last few days of the
pilot plant operation when the cold weather (5 to 7 degrees C)
brought about effluent 600$ concentrations of 50 mg/1 to 70
mg/1 and above in the third-stage lagoon effluents. Com-
pounding these factors is the possibility for peak flows due
to runoff during the critical cold-weather months. The impact
of such high flows and associated additional BODs loads would
be to reduce effluent quality and BODj removals even further
due to higher BODs loading rates and reduced aeration times in
the lagoons.
11-31
(4) The negative effects of qold weather operation on BODs removal
for the Northglenn project may be even more pronounced as the
estimated wastewater temperatures for these lagoons are esti-
mated to go down to about 10 degrees C in the first stage and
6 to 7 degrees C and below in the second and third stages for
up to three to four months of the year. Ths may be expected to
cause a serious reduction in 800s removal from the lagoons
leading to high BODs carryover into the reservoir. If such
carryover continues at high enough BODs concentrations and for
a long enough period of time,"the quality at the effluent from
the reservoir may be adversely affected.
TSS Removal Analaysis
The TSS removals and the effluent TSS from the proposed Northglenn
aerated lagoon system and reservoir can be divided into two major
operational periods representing summer (warm weather) and winter (cold
weather) operation.
(1) Winter operation for aerated lagoon systems with quiescent
settling ponds is typically not critical in terms of effluent
TSS. The TSS results obtained in the pilot studies, high
effluent TSS from the third-stage lagoons following cold
temperatures, are probably due to the f.ollowing factors. The
low temperatures caused reduced BODs removals in the first two
stages of the lagoons which increased the loading on the third
stage. This increase in loading probably resulted in the
growth of additional microbial biomass in the third cells.
This additional biomass would be relatively disperse growth
which, due to the pilot plant mixing, would tend to find its
way into the effluent. This effect would have little impact on
the Northglenn project as the quiescent settling provided by
the reservoir would mitigate the high solids. However, this
could lead to large quantities of organic carbon being
deposited in the reservoir which could seriously affect the
capabilty of maintaining a carbon limiting system in the
11-32
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w
VD
summer months when algal growth levels will be critical in
terms of permit TSS compliance.
(2) Summer operation will be the critical period for the North-
glenn project in terms of compliance with effluent TSS permit
limitations. If the algal growth in the reservoir and the
carryover of algal growth from the aerated lagoons to the
reservoir can be adequately controlled, permit compliance may
be achievable. The ability to maintain a carbon limiting
system in the reservoir is, however, suspect due to BODs and
TSS carryover during cold weather operation, transfer of
carbon dioxide from the atmosphere to the reservoir, high
effluent TSS concentrations from the lagoons in the summer
(characteristic of aerated lagoon systems) due to algal growth
and third-stage mixing, and loss of nitrification during cold
weather operation leading to alkalinity carryover into the
reservoir. In addition to the potential algae growth, the
problem of higher than normal (near peak) inflows during the
summer carrying high sediment loads may impact the reservoir
effluent TSS.
Analysis of Nitrification
The importance of nitrification to the operation of the Northglenn
project is related (in terms of permit compliance) to the removal of
alkalinity and the subsequent ability of the proposed system to maintain
a carbon limiting condition for algal growth in the final reservoir.
Based on the pilot studies performed, literature sources, and experience
with various systems achieving, or attempting to achieve, nitrification,
there is considerable risk that the proposed Northglenn treatment system
will not be able to attain the necessary nitrification performance to
eliminate the available alkalinity in the wastewaters.
Several factors mitigate against achieving noticeable nitrifica-
tion during winter operation of the proposed Northglenn system. The
major problem will be low temperatures in the second and third stages
where most nitrification is expected to occur. The temperatures
projected for these stages in the winter (less than 7 degrees C for three
months in cell number 2 and less than 2 degrees C for three months in cell
number 3) is insufficient.to maintain adequate nitrification, as shown
in Figure II-l excerpted from the "Process Design Manual for Nitrogen
Control" from EPA's Technology Transfer Series. As this figure
indicates, at temperatues of 7 degrees and below, nitrification rates
are generally about 30 percent or less of the rate achieved at 20 degrees
C and only 10 percent of the rate .achieved at 30 degrees C. As the
temperature drops and the rate of growth of the slow-growing nitrifiers
is reduced even further, there is considerable chance of losing all
nitrification. This is especially true for an aerated lagoon system
where the recycling of solids cannot be used to attain high sludge age.
Should the aerated lagoons for whatever reason experience a solids
washout at the beginning of cold weather, this effect will be even more
pronounced.
The second factor which may affect the nitrification during the
cold weather is the additional carbonaceous 8005 which will be applied to
the second ana third cells of the aerated lagoon due to lowered removal
efficiencies. The ability to achieve desirable nitrification results is
much more difficult in systems where the carbonaceous oxygen demand is
still high. If the full-scale aerated lagoons are only able to achieve
effluent BOOs levels of 40 to 50 mg/1 during cold weather, as the pilot
systems did, this could further mitigate against the ability to maintain
the high levels of nitrification projected for the system.
RELATIONSHIP OF FIVE-DAY BOD REMOVAL,
TSS REMOVAL, NITRIFICATION, AND ALGAL GROWTH
IN THE PROPOSED BULL CANAL RESERVOIR
The ability of the proposed Northglenn system, three-stage aerated
lagoons and storage reservoir, to meet effluent TSS requirements will
probably.be dependent on the abilities of the system to inhibit algae
growth in the final reservoir. To do this, it is proposed that a complex
series of reactions and dependencies intended to maintain a carbon
limiting system in the final reservoir be used. No controls of nitrogen
11-33
11-34
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FIGURE II-l
COMPARISON OF EFFECT OF TEMPERATURE ON
NITRIFICATION IN SUSPENDED GROWTH AND
ATTACHED GROWTH SYSTEMS
N3
O
Buswell.et ol. (32)
Haiig $ McCarty,(2)
Salokrishnan.et al. (33)
Huang £ Hop son, (34)
Downing, et 0|.,(I7,18)
20 is
TEMPERATURE, C
or phosphorus are proposed and Northglenn's engineers recognize that
sufficient amounts of these nutrients will be available to sustain large
algal growths.
The ability of the system to be maintained in the carbon limiting
conditions proposed is dependent upon a multitude of factors, the most
Important of which are: (!) complete nitrification in the aerated
lagoons and the attendant removal of essentially all alkalinity from the
wastewaters; (2) that the raw waste will have, on a continuous basis, 30
to 35 mg/1 ammonia-nitrogen, as shown by the two weeks of raw waste load
data obtained; (3) essentially complete removal of carbonaceous BODs by
the aerated lagoons; and (4) exceptionally low, for aerated lagoons,
effluent TSS from the lagoons to the reservoir.
Based on the previous analyses of the data base, attainable
removals, and attainable nitrification, there is considerable risk that
these conditions can be achieved consistently. The high potential for
BODs losses in the 30 to 50 mg/1 range or above in the winter, the high
potential for low nitrification rates and thus high alkalinity during
winter operation, the carryover of TSS (containing carbon) from the
lagoons to the reservoir, and the direct transfer of carbon dioxide from
the atmosphere to the reservoir will all combine to make it very
difficult to maintain the desired conditions in the reservoir. During
the critical summer periods, the high influent flow rates (up to 13.1
million gallons per day) composed of return flows may not have the
correct ammonia-nitrogen:alkalinity ratios and could conceivably lead to
excessive alkalinity levels in the reservoir, especially during dry
years when the reservoir pool is at minimum volume. The long-term
effects of 8005 and TSS carryover into the reservoir will be to build up
a substantial carbon source within the reservoir which could be made
available for algal growth under the right conditions (windy days,
spring turnover, reservoir mixing, release of nutrients to the water
column by endogenous respiration of orgnic solids, etc.). All of the
factors mentioned combine to make the prospect of attaining carbon
limiting conditions in the reservoir appear as a marginally attainable
prospect.
11-36
11-35
ENGINEERING-SCIENCE, INC.
-------
The argument Is also made by Sheaffer and Roland and Or. McKinney
that should algal growth occur, the low alkalinity available would lead
to high pH levels in the reservoir. Such high pH condition could then
lead to ammonia-nitrogen loss due to stripping and precipitation of iron
and phosphorus and a limit to algal growth due to a shortage of thes.e
necessary nutrients. To achieve any reasonable removal of ammonia-
nitrogen, tfe pH would have to well above 9, which is the upper limit for
permit compliance. Thus, pH adjustment would be required before
discharge. In fact, should the pH increase, this would lead to
additional carbon dioxide transfer from the atmosphere which would tend
to lower the pH and increase the available carbon for algal synthesis.
The prospect of removing enough phosphorus or iron to prove limiting to
algal growth seems likewise unlikely at the pH values of 9 to 10 which
might occur.
ATTAINABILITY OF PERMIT REQUIREMENTS
As the foregoing discussions and analyses indicate, several factors
will combine to make 100 percent permit compliance by the Northglenn
system difficult to achieve. The probability that the proposed
Northglenn system will meet all required effluent BOOs limitations is
high. Summer operation should not present a problem in terms of BOD$
unless very high contributions for algal growth are encountered. Cold
weather operation could prove a problem if sufficiently cold weather
attenuates 800$ removal in the aerated lagoons for a long enough period
of time. However, with the long detention in the reservoir, this
possibility is rather remote.
The probability that the proposed system will meet all effluent TSS
requirements is, however, rather low. The maintenance of the carbon
limiting conditions in the reservoir for algae control appears rather
and thus the potential for large summer growths of algae in the reservoir
is quite high. It cannot be unequivocally stated that the proposed
system will not meet the required effluent TSS limitations; however, the
probability of exceeding the effluent TSS limitations appears quite
high.
11-37
FECAL COLIFORH REQUIREMENTS AMD DISCUSSION
The proposed fecal coliform limitations by the State of Colordo for
the Northglenn project are 1,000 colonies per 100 ml for the 30-day
average and 2,000 colonies per ml for the seven-day average. EPA,
however, will require modifying these to 200 colonies per 100 ml for the
30-day average and 400 colonies per 100 ml for the seven-day average.
The 1,000/2,000 limitations wiU be considered first. It has been
demonstrated in many systems that excellent removals of fecal coliforms
can be achieved by long detention time.lagoon systems. It is probable
that most if not all of any fecal coliform contamination found in the
proposed Bull Canal Reservoir effluent will be from sources other than
the influent wastewaters. Only very special circumstances such as
complete loss of biomass in the aerated lagoons or severe short
circuiting in the reservoir could produce excessive effluent fecal
coliform contamination due to the influent wastewaters. The proposed
Northglenn system will have chlorination facilities for the reservoir
effluent. I-t is proposed that these facilities will be used on an as-
required basis. Por the proposed limit of 1,000/2,000 colonies per 100
ml, it should be only under rare circumstances that the use of these
facilities would be required.
The 200/400 colonies per 100 ml limitations required by EPA will be
more difficult requirement. These limits will probably require chlor-
ination of the effluent for considerable periods if not all the time in
order to be met. At these low levels, such things as contamination from
ducks, geese, and other water birds as well as other natural sources may
be enough to cause violation of the proposed limits. Under these
circumstances, the probability of excessive contamination being due to
the influent wastewaters is rather remote.
COMMENTS.CONCERNING FECAL COLIFORM LIMITATIONS
The following text is excerpted from a memorandum by Dr. E.F. Gloyna
concerning the "Mortality Rate Estimates for Disease Causing Agents-in
Domestic Wastewater." This memorandum was prepared by Dr. Gloyna in
response to a request by EPA that Dr. Gloyna address the question of
11-38
-------
disease-causing agents and the potential for the creation of public
health problems due to the use of the effluent from the proposed
Northglenn project for food crop irrigation and direct human contact
with Bull Canal reservoir effluent.
Because of the variety of disease-causing agents and the
multiplicity of environmental factors involved, there is no
simple and universally usable technique for predicting speci-
fic pathogenic agents in a secondary biological wastewater
treatment plant or an individual waste stabilization pond.
Some environmental factors that cause a decrease in bacterial
concentration are; dilution and mixing, aggregation, presence
of toxic substances, predation, sunlight, temperature, and
availability of nutrients.
Some potential waterborne diseases include bacillary and
amoebic dysentery, salmonellosis, leptospirosis, cholera,
vibriosis, and infectious hepatitis. Other less common
diseases are brucellosis, ascariasis, schistosomiasis, an-
cylostomiasis, and tapeworm disease. Epidemiological evi-
dence from other countries indicates that reuse of domestic
wastewaters, particularly for crop irrigation, has resulted in
disease outbreaks. However, the reuse of treated wastewater
in California has not resulted in any confirmed disease
outbreaks [1].
The transmission of pathogens by etiological agents such
as bacteria, protozoa, helminths, and viruses are of concern
but the possible detection of individual pathogenic agents is
usually through some indicator microorganism such as E^. coli.
Effective removal of enteric microorganisms is related to
the retention of settleable material detention of'the liquid,
availablity of nutrients, and a host of environmental factors.
The degree of risk in water reuse always raises ques-
tions. It appears that 100 percent removal efficiency of
pathogens is neither economically practical nor technically
attainable, the concept of "acceptable risk" is the only
realistic approach for grappling with environmental health
questions. In the absence of adequate epidemiological data to
evaluate the potential health hazard from pathogens applied to
soil, monitoring for the occurrence of the pathogens in the
environment must be the primary health measure.
Removal of Organisms
In studies conducted at The University of Texas at
Austin, it was established that a considerable reduction in
coliform organisms is achieved by the passage of wastewater
through waste stabilization ponds as shown by:
(a) Average percent reduction of coliform organisms in
all tests performed was 99.4 plus or minus 0.74,
relative to the initial population in the first
section at a theoretical .detention time of 11.4
days. Percentages based on averages of all tests
and geometric means were similar.
(b) Average percent reduction of total number of bac-
teria was 88.8 plus or minus 21.85 relative to the
initial population in the first section at the
theoretical detention period of 11.4 days. Percen-
tages based on averages of all tests and geometric
means were similar.
There is a general attitude that waterborne disease
outbreaks of epidemic proportions have, to a great extent,
been controlled; however, the potential for disease trans-
mission through the water route has not been eliminated. It is
assumed that disease organisms of epidemic history are still
present in today's sewage, and the status of control is more
one of severance of the transmission chain than a total
eradication of the disease agent. For example, vegetable
decontamination studies have indicated that washing vege-
tables even with detergents is ineffective in removing bac-
teria and helminth eggs. The latter are also extremely
resistant to chemical disinfectants. Thus, in the case of
edible food, emphasis should be placed on either eliminating
the pathogenic agents from the wastewater prior to irrigation
or preventing direct contact between the wastewater and the
edible portion of the crop to minimize the risks of disease
transmission.
However, it must be recognized that pathogens are des-
troyed or removed from untreated wastewaters during treatment
processes. Settleable entities such as cysts and worms will
settle out and become incorporated in the bottom sludges.
Virus particles are largely associated with suspended solids.
Thus, removal of original solids from wastewaters, extensive
biological stabilization, elimination of short-circuiting and
long hydraulic detention will enhance the reduction of certain
disease-causing agents in the treated effluents.
The following paragraphs summarize selected studies.
Emphasis is directed to the importance of polishing or holding
ponds, although it is recognized significant settling and
reduction of pathogens will take place in preceding primary
clarification, aerobic/anaerobic lagoons. A log-log linear
relationship was found between the total plate count (TPC) and
the most probable number (MPN) of colfiorms with a coefficient
of correlation of 0.78. Die away of coliform organisms was at
a higher rate than total bacterial population.
Listed below are summary statements provided in a World
Health Organization Monograph: [3]
(a) In small waste stabilization pond, 0.4 ha in area
and with operating depths ranging from 80 cm to 1.5
m, organic loading rates of 22, 45, 67, 90, and 112
kg BODs per hectare per day, flow rates from 600 to
11-39
11-40
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M
I
to
u>
1050 m3 per day, and temperature ranging from 2 to
33 degrees C, the MPN reached the highest levels in
the ponds receiving the heavier loadings and oper-
ating with the shorter detention times. Coliform
removal rates varied only in the third and fourth
significant figures. No pond failed to remove less
than 99.99 percent of coliform bacteria during any
month in which measurements were taken.
(b) Field studies have shown that large-scale ponds
(tertiary ponds) are particularly effective in
reducing fecal E. coli. The success of maturation
ponds as a buffer against environmental bacterial
pollution has been clearly stated.
"Although a faecal £. coli count of nil per 100 ml
cannot always be obtained in maturation ponds, the
degree of safety (as indicated by faecal E. coli
count) that can be obtained is comparable wfth that
attainble in practice, where sand filtered effluent
is chlorinated."
(c) The 'London Metropolitan Water Board reports that
tertiary pond treatment of effluents from conven-
tional secondary sewage treatment plants reduced £.
coli by 99.5 percent. A detention time of 8 days Ts
recommended.
(d) Similar experiences have been recorded in Australia
where detention times of 30-40 days in multiple
ponds were shown to reduce the number of coliform
organisms to levels approaching those found" in
drinking water. Of course, other factors besides
coliform density must be evaluated before treated
wastewaters and drinking waters can be compared.
(e) Studies in Auckland, New Zealand, showed that over
99 percent of the coliform organisms were removed in
waste stabilization pond.
(f) In Israel, coliform removal rates of about 99
percent have been reported in two ponds connected in
series having a total detention time of 26 days.
The average BODs reduction was 87.4 percent from an
initial BOD of 283 mg/1. Unsatisfactory coliform
reduction was obtained with a detention time of only
3.5 days.
(g) In laboratory studies involving Salmonella abortus
equi the die-away rate was found to be dependent on
temperature, initial organism densi|y, and avail-
ability of nutrients. The reduction was primarily
due to competition for food. In a field experiment
with the same organism, under summer temperature
conditions (25 degrees C), the number of organisms
per ml was below the sensitivity of analyses within
72 hours.
11-41
(h) Field studies in India showed that species of
salmonella were present in the influent, but not in
the effluent, of facultative ponds. However, coli-
fsrm organisms, E. coli, and streptococci were
reduced by only 89~-92 percent, 81-91 percent, and
84-85 percent, respectively. Under the tropical
conditions prevailing, it was possible to achieve 72
percent reduction of 8005 with a loading of 450-560
kg/ha per day. The pond depth was 1.2 m, and the
detention time only 2 days per pond. Aeration was
applied below the pond surface for 1 hour in the
morning and 2 hours in the evening.
(i) Also, in India, studies showed that the die-off rate
of Hycobaterium turberculosis is high. Domestic
wastes mixed with sanatorium wastes were treated in
a septic tank and then in a waste stabilization
pond. Acid-fast bacteria were found in about .50
percent of the samples of untreated waste and in
about 25 percent of the samples of septic tank
effluent, but not in samples taken from the pond and
the pond effluent.
(j) Test conducted in Isreal showed that cysts of
End amoeba histolytica could be found in pond influ-
ents but never in the effluents.
(k) Studies conducted in South-west Africa showed that
18 percent of entero and reovirus were not removed
after secondary settling. However, a 95 percent
additional reduction was achieved by the biological
purification in nine, series-connected polishing
ponds, having a total hydraulic loading.of 14 days.
The TCIOso (50 percent tissue culture infective
dose) in the influent to the wastewater treatment
plant reached levels of 20,000 TCIDso"1.
Increasing attention has been given to the transmission
of viral diseases through water reuse. Waterborne outbreaks
of infectious hepatitis have clearly been associated with the
ingestion of wastewaters. Identification and enumeration of
viruses in water and wastewater has been hampered by the
limitations of sampling techniques, problems of concentra-
tions of samples, the complexity and high cost of laboratory
procedures, and the limited number of facilities having the
personnel and equipment necessary to perform the analytical
service.
Inhibition of Bacteria by Algae
Tests conducted with pathogenic bacteria and algal cul-
tures yielded results similar to those found when enteric
bacteria were used. Escherichia, Pseudomonas, and Serratia
exhibited aftergrowth potential whTle Proteus, A1ca"ligenes7
Enterobacter, Salmonella, Shigella, and Vibrio did not.
Quantitative data have been obtained which demonstrate the
I'-42
-------
I
N5
effect of representative algal species on selected enteric
bacteria. The data show that individual algal species exert
little influence on an increase of the die-off rates. Labora-
tory and pilot-scale field tests provided similar results.
The die-off coefficients for enteric bacteria were similar for
tests conducted in the laboratories using mixtures of axenic
algal cultures and in the field using pilot-scale waste
stabilization ponds.
Others have found similar results [6]. It has been
reported that relatively few contaminant bacteria will develop
in vigorously growing algal cultures. It has been shown that
most solid and air bacteria do not survive when placed into
axenic algal cultures. Such inhibition of bacterial growth by
algae has been attributed primarily to antibiotic substances
that are liberated by algae. It was found that Chlorella
inhibited the growth of bacteria and antibacterial substances
were found in filtrates of Chlorella pyrenpidosa, Chlorella
vulgaris, Scenedesmus quadrfcauda, and Chlamydomonas rein-
hardti. Bacteriostatic substances have also been reported for
Oscillatoria splendida, Stichococcus bacillaris, and Pro-
siphon botryoides. The BOD of clear supernatant after
Chiorella-bacterial growth has been shown to be higher than
with Euglena. Some factor from Chlorella seems to inhibit
bacterial action on municipal wastewater substrates. In
addition to antibacterial substances, algae may indirectly
inhibit bacterial activity by raising the pH of the water
during periods of intense photosynthesis.
References
(1) Crook, J. and Spath, 0., "Wastewater Reclamation in
California," Water Reuse Symposium, Proceedings, Vol. 3 P.
2124, AWWA Research Foundation, Denver, Coloado (1979).
(2) Yousef, Y., "Coliform in Waste Stabilization
Ponds," Thesis, Environmental Engineering, The University of
Texas at Austin, Austin, Texas (1962).
(3) Gloyna, E.F., Waste Stabilization Ponds, World
Health Organization Monograph 60, Geneva, Switzerland (1971).
(4) Nupen, E., "Virus Studies on the Winback Waste-Water
Reclamation Plant (South-West Africa)" Water Research, Vol.
4, 661-672 (1970).
(5) Davis, E., and Gloyna, E. "Bacterial Dieoff in
Ponds," 0. Sanitary Engineering Div., ASCE, 98, SAI 59-69
(Feb. 1972). • ~
(6) Ward, C., and King J., "Fate of Algae in Laboratory
Cultures," Ponds as a Wastewater Treatment Alternative, Waste
Resources Symposium No. 9, The University of Texas, Austin,
Texas (1976).
11-43
Based on these comments and the design of the proposed Northglenn system
(encompassing three aerated lagoons with 14 days detention time and the
very large and long-detention time final reservoir), the potential for
problems concerning transmission of waterborne diseases due to the
influent source should be minimal. Add to this the capability of
chlorinating the effluent from the reservoir if the level of indicator
organisms, fecal coliform, increases and the system appears to be
adequately safeguarded in terms of waterborne disease transmission
potential.
11-44
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10
CHAPTER III
DESIGN EVALUATION
The major areas to be discussed in this chapter are: (1) the
conversion from the conceptual work performed by Dr. McKinney to final
design specifications; (2) the energy requirements of the system; and
(3) mitigation measures to be considered in case of excessive algal
growth in the proposed Bull Canal Reservoir.
CONCEPTUAL TO FINAL DESIGN
The major questions which have arisen in analyzing the final design
for the Northglenn project in comparison to the conceptual design work
prepared by Dr. McKinney are in two areas: (1) sufficiency of the
aeration system; and (2) analysis of potential temperature losses and
thus cold weather treatment capability.
Aeration System
The major points of concern relative to the aerator system are the
aerator layout in the first stage and the potential problem with solids
resuspension in the third-stage lagoons if the aerators near the
effluent point are used extensively.
The design for the first-stage aerated lagoon specifies 64 static
aerators at 20 scfm (standard cubic feet per minute) per aerator using
100 horsepower of blower capacity in each 2.3 million gallon cell. These
aerators are to be installed as shown in Figure III-l. EPA believes that
the number of aerators, their spacing (12 to 13 feet spacing between
aerators), and the proposed air flow andJM"ower horsepower are suf-
ficient to supply the required oxygen demand in the first-stage lagoons
and if spaced properly 64 aerators should be able to keep the first-stage
lagoon completely mixed. There may be a potential problem, however, with
keeping the basin completely mixed due to the geometry of the basin.
Because so much of the first-stage lagoon volume (approximately 40
percent) lies above the 2:1 interior sideslopes which contain no
aerators, the sideslopes may inhibit mixing of solids from the sideslope
area, and "because the distance from the aerators at the bottom to the
III-l
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TABLE III-|
TEMPERATURE LOSS CALCULATIONS FOR THE PROPOSED NORTHGLENN TREATMENT SYSTEM
Influent Average Cell I
Waste- Air Temp.,
water Temp., °c/biol.
temp. °Ca °Cb fc /coeff.d
Jan.
Feb.
Har.
Apr.
Hay
June
July
Aug.
Sept.
Oct.
Nov.
Dec.
a. based
12.8
13.7
14.6
15.6
16.5
17.4
18.3
17.4
16.5
15.6
14.6
13.7
-2.8
-0.9
2.7
8.3
13.5
18.7
22.0
21.2
16.5
10.3
2.8
-0.6
upon an average
10.5/0.51
11.5/0.55
12.8/0.61
14.6/0.68
16.1/0.76
17.4/0.84
18.5/0.90
17.7/0.85
16.4/0.78
14.8/0.69
12.8/0.60
11.5/0.55
Cell II
Temp . ,
oC/biol.
c /coeff.d
5.4/0.15
6.8/0.40
9.0/0.46
12.2/0.58
15.2/0.72
17.5/0.84
19.1/0.94.
18.4/0.90
16.1/0.76
12.9/0.61
8.9/0.46
6.8/0.40
Cell III
Temp . ,
£C/biol.
0.3/0.08
2.0/0.10
5.0/0.14'
9.6/0.48
14.0/0.66
17.6/0.84
19.9/0.99
19.3/0.95
15.8/0.75
11.0/0.53
4.9/0.14
2.1/0.10
influent wastewater temperature
Reservoir
Temp. ,
"C/biol.
, c /coeff.d
0.1/0.07
0.1/0.07
1.9/0.09
7.4/0.41
1?. 6/0. 60
17.7/0.85
20.9/1.07
20.1/1.01
15.5/0.73
9.4/0.48
1.9/0.10
0.1/0.07
d. based uj
Detention Time*
Cell I
hrs.
23.0
22.7
22.2
20.3
13.8
13.6
13.8
17.4
18.7
21.0
22.8
23.2
x>n the t
Cell II
hrs.
92,1
90.9
88.8
81.2
55.0
54.4
£5.0
69.7
75.0
84.1
91.3
92'. 7
Cell III
hrs.
207.3
204. t
199.9
182.7
123.8
122.4
123.8
156.8
168.7
189.2
205.5
208.6
emperature correction
Reservoir
days
185
156
126
96
67
46
32
20
14
240
242
216
equation
Cell I
Influent
BOD5,ng/if
193.0
190.6
186.4
172. Z
123.3
121.9
123.3
150.1
160. S
177.9
191.2
194.1
range of 55«F (12.8"CI In winter and 65*F (18.3'C)
b. based upon local average monthly temperature data
c. baaed upon the thermal energy balance equation
. - . e f
Tw % U06QTi
Where Tw
Ti
AKTe>/(AK + 106O)
water temperature, °C
influent water temperature,
Te * equilibrium water temperature oc
{one degree leas than average air temp.)
K • surface heat exchange coefficient,
cal/d-m2-°C
(a value of 0.7 X IO6 is typical) '
Q - flow rate, mVd
A * laaoon surface area, m^
CT - «w(T-20)
Where CT » temperature correction coefficient
from a standard 20°C condition
6 » 0.07 for temperatures between 6°
and 25°C
0.13 for temperatures between 0°
and 6°C
t " actual water temperature
based upon projected monthly inflows and a design flow of
4.64 MOD
based upon the projected monthly rates of wastewater to
stormwater inflows and predicted wastewater t storm-
water characteristics) assumes worst case treatment con-
ditions, i.e., no well water flows will be used for make-
up water, only wastewater and stormwater
SOURCE: Sheaffer and Roland, Inc., Memo of 11/16/79 to Bob McGregor from Lee Rozaklis, Subject:
for Bull Canal Reservoir.
NPDES permit
-------
I
l-o
levels by maintaining a low differential temperature at the air/water
Interface to impede convective heat transfer (i.e., the upper water
layer acts as an insulator for the lower layers).
Thus, the estimates of 8005 removals and nitrification which have
already been questioned may be even more seriously impacted due to lower
than anticipated water temperatures in the aerated lagoons and reser-
voir. As an example, by assuming that the surface heat exchange
coefficient (k) is double that used by Sheaffer and Roland, Inc. in their
calculatios (this assumption is believed to be a conservative assumption
in terms of comparison to what the actual k values are for statically
aerated lagoons), the January lagoon temperatures calculated would be
8.5 degrees C in cell number 1 (compared to 10.5 degrees C), 1.9-degrees
C in cell number 2 (compared to 5.4 degrees C), and -2.2 degrees C in cell
number 3 (compared to 0.3 degrees C). At these low temperatures,
nitrification and 8005 removal would be almost nonexistent in the second
and third cells.
ENERGY REQUIREMENTS
To ascertain the energy efficiency of the proposed Northglenn
treatment system, the power requirements (kWh per year) for the
installed aeration horsepower for the Northglenn site Irave been compared
to the total estimated power requirements for four other systems
designed to provide equivalent or similar- treatment levels to those
stated for the Northglenn aerated lagoons. The estimated power
requirements for these systems are based on information presented in
"Water Quality Management Planning Methodology for Municipal Waste
Treatment Needs Assessment," prepared by Engineering-Science, Inc in
March of 1977 for the Texas Department of Water Resources for use in
estimating point-source controls, costs, and requirements in non-
designated 208 planning areas. The Northglenn power requirements
including estimated conveyance and other miscellaneous power require-
ments also are compared to the estimated power requirements, including
conveyance requirements, for Denver Metro to treat the Northglenn
wastewater-s.
The first system utilized for comparison Is an extended aeration
(activated sludge) system preceded by primary treatment including
primary clarification and followed by final clarification with recycle.
The effluent quality from the system used would be expected to meet
effluent limitations of 20 mg/1 8005, and 3 mg/1 ammonia-nitrogen on a
monthly average basis. The design of the aeration basin is determined by
nitrification requirements. The annual energy requirements for such a
system are estimated to be 4.8xl06 kWh.
The second system used for comparison is a conventional activated
sludge plant with primary treatment, including primary clarifiers, and
using final clarification and sludge recycle. The effluent from a system
such as this design represents would be expected to meet a' permit
requirement of 20 mg/1 8005 as a monthly average. Little or no
nitrification would be expected from such a system. The annual energy
requirements for such a system are estimated at 2.25x10^ kWh per year.
The third system investigated consists of primary treatment,
including primary clarifiers, rotary biological contactors designed
based on 6005 removal requirements, and final clarification. Such a
system would be expected to meet effluent limitations of 20 mg/1 800$ and
10 mg/1 ammonia-nitrogen as monthly averages. The estimated annual
energy requirements for such a system are 0.72x10^ kWh.
The final system used for comparative purposes is similar to the
third system except that the rotary biological contactor area is
determined based on nitrification requirements. The system would be
expected to meet a 15 mg/1 BODj and 2 mg/1 ammonia-nitrogen permit
limitation on a monthly average basis. The estimated annual energy
requirements are 2.03xl06 kWh.
In each of the above cases, the system design in terms of BODj
removal is determined based on an average flow rate of 4.6 million
gallons per day, an influent BODs concentration of 200 mg/1, an influent
TSS concentration of 190 mg/1, and an influent ammonia concentration of
35 mg/1. The sizes of the primary and secondary clarifiers and thus the
associated energy requirements are based on a peak flow rate of 13.1
III-5
II1-6
-------
I
N3
00
million gallons per day. Stated effluent quality would be expected to be
met even with daily peak rates of 13.1 million gallons per day as
specified by Northglenn. Such hydraulic peaks have very little effect on
energy requirements based on oxygen requirements because these peak
flows normally have low BOD5 concentrations. Thus, the overall effect of
these high flows on energy requirements is quite small. Each system
design includes solids handling energy requirements consisting of
gravity thickening and anaerobic dige-stion. The energy associated with
final disposal is assumed to be equal for all systems.
The estimted energy requirements "for Denver Metro to accept and
treat the City of Northglenn wastewaters was estimated from Denver
Metro's 1980 budget. The budget listed energy use as 59.32x106 kWh per
year for primary and secondary treatment, sludge handling, and effluent
chlorination for a flow of 123 million gallons per day. Based on these
values, the energy requirements by Denver Metro are 482,276 kWh per year
per million gallons treated per day. Thus, the energy requirements which
would accrue to the City of Northglenn's wastewaters for treatment by
Denver Metro may be estimated as 2.23x10^ kWh per year exclusive of
conveyance costs. The estimated energy requirements for conveyance to
Denver Metro are 1.01x10^ kWh per year based on an average flow rate of
4.62 million gallons per day through the Henderson and North Washington
pump stations. Thus, the .total estimated energy requirements for
treatment by Denver Metro is 3.24xl06 kWh per year. In order to estimate
the energy requirements for equivalent treatment (including nitrifica-
tion) at Denver Metro, an additonal energy requirement of 0.9x10^ kWh per
year was estimated based on information contained in "Energy Conserva-
tion in Municipal Wastewater Treatment," an EPA publication. Thus, the
total energy requirements for treatment of City of Northglenn waste-
waters to an effluent quality comparable to that estimated for the
proposed Northglenn system is approximately 4.21x10^ kWh per year.
The required operating aeration blower horsepower for the North-
glenn project with all static aerators operating at 20 scfm is 880
horsepower. This value is specified on page IV-18 of the Basis of Design
memorandum of September 27, 1979, prepared by Sheaffer and Roland, Inc.
This represents installed power levels of 200 horsepower for the first
III-7
aerated lagoon cells (100 horsepower each), 400 horsepower for the
second cells (200 horsepower each), and 280 horsepower for the third
cells (140 horsepower each). Based on these required horsepower levels,
the annual energy requirements for aeration of the aerated lagoons would
be 5.76x10^ kWh. The proposed system calls for the installation of six
2,650 cfm (300 horsepower) blower units with one to be used as a spare.
These would be capable of supplying all of the proposed aerators with 40
cfm or double the design value of 20 cfm. Thus, if the 40 cfm should be
required, the annual energy requirements would be 9.8xl06 kWh for the
aeration system blowers alone. The most energy efficient case which can
be estimated would require the entire 200 horsepower for the first-stage
aerated lagoons (to obtain the maxmum mixing level attainable) -and at
least 70 percent of the required 400 horsepower for the second stage (280
horsepower). Thus, if the third lagoon could be left completely
unaerated, the annual energy requirements would be in excess of 3x10*> kWh
for aeration only. Due to the deep basin design, it is doubtful that the
third cell lagoons could be maintained without odors if left completely
unaerated. Thus, it appears that for aeration the proposed Northglenn
system would require a minimum of approxmately 3x10^ kWh per year to a
maximum of. 9.8x10*> kWh per year.
The estimated energy requirements for conveyance "for the proposed
Northglenn system based on flows and information supplied by Sheaffer an
Roland, Inc. is 0.758xl06 kWh per year. To the previous energy
requirements for Northglenn, a conservatively estimated 0.36x10^ kWh per
year should be added to account for sludge handling and disposal, Bull
Canal Reservoir discharge pumping, chlorination, and other miscellaneous
energy requirements.
The estimated energy requirements for the four alternate systems
shown as well as for Metro Denver treatment and for the proposed
Northglenn system are summarized in Table III-2. The alternate system
designs are not developed to the same degree of accuracy as the proposed
Northglenn system.
III-8
-------
TABLE III-2
COMPARISON OF ANNUAL ENERGY REQUIREMENTS
FOR PROPOSED NORTHGLENN TREATMENT SYSTEM AND SELECTED ALTERNATES
W
N>
VO
Treatment
Annual Energy
Requirements at
Full Horsepower
Usage (KWH/yr)
Design
Ef f 1 uent
BOD5 NH3
Proposed Northglenn System
Lagoon system only 5.76 x ICr
Conveyance & miscellaneous 1.12 x 10°
Total 6.88 x 106
Metro Denver
Without conveyance 3.13 x 10JJ
With conveyance 1.01 x TO?
Total 4.14 x 10b
Primary clarifier - extend-
ed aeration (designed for
nitrification) - final ,
clarifier ' 4.8 x 10 <20
Primary clarifier - acti-
vated sludge - final ,
clarification 2.25 x 10° <20
Primary clarifier - R8C
(designed based on 8005
removal requirement ,
only) - final clarifier 0.72 x 10° <20
Primary clarifier - RBC
(designed for nitrifi- ,
cation) - final clarifier 2.03 x 10° <15
No nitrogen
assumed
<2
PROPOSED MITIGATION MEASURES
The mitigation measures for meeting effluent limitations with
respect to algae control and/or removal, should this become necessary
for the effluent from the Bull Canal Reservoir, were analyzed by Sheaffer
and Roland, Inc. in a letter to Mr. R.P. Lundahl of the City of Northglenn
dated February 25, 1980. The mitigation measures encompassed in that
letter are: (1) use of algicide, (2) use of flocculants, (3). use of
biological controls (algae-consuming fish, primarily tilapia), (4)
selective discharge, and (5) filtration. Of these proposed mitigation
measures, the following comments can be made:
(1) The use of algicide or flocculants to control algae growth in
the reservoir is a stop gap method and does not eliminate the
root cause of such growth, that is excessive supplies of
nutrients and carbon for algal growth. Thus, it may be
effective on a spot basis or for a period of time, but it does
not represent a long-term solution to algae growth except
through repeated applications.
(2) The use. of repeated applications of algicides such as the
CuS04 proposed at Northglenn could lead to unacceptable
buildup of copper concentrations in the reservoir sediments
and impact crops irrigated with the water.
(3) The use of biological controls such as tilapia fish should be
relatively acceptable. It should be noted, however, that no
assurances can be made that such controls would be able to
maintain permit compliance. The use of biological controls
presupposes that the control species will not exhibit selec-
tivity for habitat in the reservoir or for specific types of
algae. Situations could develop where large growths of alge
of a type not desired by the biological control species could
be formed and jeopardize permit compliance even while large
numbers of the control species were working to reduce the more
preferred algal types to very low levels. Additional problems
which may occur due to the use of biological controls include
III-9
111-10
-------
I
U)
o
the necessity to annually restock the control organism (es-
pecially tilapia) due to seasonal losses, the necessity for
modifications to the Bull Canal discharge facilities to
prevent release of the organisms into Bull Canal and as-
sociated waterways, and the necessity of disposing of large
quantities of harvested or winter-killed organisms.
(4) The use of selective discharge at various depths within the
reservoir could be viable in terms of reducing the effect of
algae from surface blooms near the effluent structure affec-
ting effluent quality. As the sole method of mitigating large
quantities of algal growth, however, this control measure does
not appear sufficiently effective.
(5) The use of filtration for algae removal has been documented as
being too expensive, not particularly effective, and prone to
severe operational difficulties for large systems. Thus, this
should be the last method considered for algal-related TSS
removal.
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I
CO
CHAPTER IV
CONCLUSIONS
The conclusions presented in this chapter are based on the results
of the analyses and study of the materials supplied by Sheaffer and
Roland, Inc. describing the treatment concepts and design for tHe
proposed Northglenn wastewater treatment system.
(1) The collection period fcr data describing the raw waste load
to the proposed system spanned a 13-day period in February and
March of 1978. The data collected were for the existing
Northglenn wastewaters only and did not include analyses of
the other sources, such"as irrigation return flow and storm
water runoff, which also will be treated. This data base does
not represent a sufficient sampling and analytical effort for
the proposed Northglenn wastewater treatment system. There is
no assurance that the two-week period represents year round
wastewater characteristics especially the very important
ammonia-nitrogen:alkalinity ratio. The ammonia-nitrogen con-
centrations from the sampling were abnormal for municipal
wastewaters and should have been investigated further, and the
quality of the additional sources of wastewater and the new
potable water source (Standley Lake) should have been char-
acterized and taken into account in determining design waste-
water quality.
(2) The pilot-plant studies of aerated lagoon treatment using the
detention times and three-series-cell concept proposed for
Northglenn were professionally performed and the results were
typical of the treatment expected for long-detention-time
aerated lagoons. Three problems exist, however, in applying
the results of these studies directly to the proposed North-
glenn wastewater treatment system:
(a) Lawrence, Kansas, wastewaters, not a composite repre-
senting the actual wastewater to be treated (City of
Northglenn, irrigation return flow, and storm water
runoff), or City of Northglenn wastewaters, were used for
the tests and differences in ammonia and alkalinity
relationships between the wastewaters as well as other
differences do not appear to have been adequately evalu-
ated.
(b) There was insufficient run time under cold-weather oper-
ating conditions for_ the pilot facility to exhibit the
response of such systems to the low temperatures which
may be expected to occur in the full-scale facility..
(c) The effect of the proposed Bull Canal Reservoir on
effluent quality from the proposed system was not effec-
tively considered in the pilot studies.
(3) The proposed Northglenn wastewater treatment system should
under most conditions have no trouble meeting the proposed
BODg limits for the Bull Canal Reservoir effluent. Two
situations could occur which could cause the permit BODs.
levels _to be exceeded:
(a) During summer or warm-weather operation, there exists a
potential for high algal levels in the effluent from the
reservoir. If the algae levels are high enough, the
attendent BOOs contribution could'cause permit limits to
be exceeded.
(b) During winter operation, the treatment efficiency of the
' three-stage aerated lagoon will be significantly re-
duced. If the effluent BODj from the aerated lagoons
reaches a high enough level for a long enough period of
time, the effluent from the reservoir could be affected
and the effluent BODs could exceed permit requirements.
The possibility for high flow rates due to storm water
runoff 'during winter operation, which would decrease
average treatment time in the aerated lagoons and further
decrease BOD; removal efficiency due to cold weather,
further increases the risk of the effluent BODs exceeding
permit limits during winter operation.
IV-1
IV-2
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to
(4) The probability that the proposed system will continuously
meet effluent TSS requirements {30 mg/1 monthly average and 45
mg/1 7-day average) is believed to be rather low. The
probability of exceeding the permit requirements in the summer
due to levels of algae growth in Bull Canal Reservoir is high.
Another factor which could contribute to high effluent TSS
during the summer is the potential for high influent flow
rates carrying large sediment loads during periods of minimum
reservoir volume. During v,inter operation, the effluent TSS
should, however, pose no problem.
(5) A key operational feature of the proposed three-stage lagoon
system is the achievement of essentially complete nitrifica-
tion and the attendent removal of alkalinity in the second and
third-stage aerated lagoons. This capability is necessary to
achieve the carbon limiting system which is designed to limit
algal growth in the final reservoir. Due to the very low
temperatures expected in the second and third lagoon stages
during cold-weather operation (below 7 and 2 degrees C for
three months in cells 2 and 3, respectively) adequate nitri-
fication to achieve this goal will not be possible. A second
contributing factor to low nitrification levels in the winter
will be increased 8005 loadings on the second and third lagoon
cells due to cold-weathr reductions in BODs removal ef-
ficiencies. This increase in carbonaceous demand will further
inhibit nitrification due to the reduced capability of the
nitrifying organisms to compete.
(6) The capability of the proposed Northglenn system to maintain
carbon limiting conditions to inhibit algal growth in the Bull
Canal Reservoir and thus attain effluent TSS requirements is
dependent on a complex series of reactions and interactions.
No controls of phosphorus or nitrogen are proposed and it is
recognized that sufficient amounts of these nutrients will be
available to support large algal growths. The ability of the
proposed system to achieve the desired carbon limiting con-
ditions is dependent upon many factors. The following are
believed to be the most important of these factors:
(a) essentially complete nitrification in 'the aerated la-
goons with attendent alkalinity removal;
(b) 30 to 35 mg/1 of ammonia-nitrogen in the raw waste on a
continuous basis;
(c) essentially complete removal of carbonaceous BODs in tne
aerated lagoons; and
(d) exceptionally low, for aerated lagoons, effluent TSS from
the lagoons to the reservoir.
The high potential for BODs losses in the 30 to 50 mg/1
concentrations, the high potential for low or no nitrification
rates and thus high alkalinity during winter operation, the
carryover of organics-containing TSS from the lagoons to the
reservoir, and the direct transfer of carbon dioxide from the
atmosphere to the reservoir combined to make it unlikely that
a carbon limiting system can be maintained in the reservoir.
(7) The proposed Northglenn system should exhibit excellent re-
movals of fecal coliforms due to both the long detenton times
through the aerated lagoons and Bull Canal Reservoir and the
capability of chlorinating the reservoir's effluent. The
State of Colorado has proposed effluent fecal coliform re-
quirements of 1,00'0/2,000 colonies per" 100 ml for th 30-day
and 7-day averages for the reservoir effluent. Only extreme
circumstances such as severe short-circuiting in the reservoir
or complete loss of biomass in the aerated lagoons could
produce excessive effluent levels under these requirements.
For the 1,000/2,000 limits, the necessity for chlorination,
proposed for as-required operation, should be minimal. EPA
will require stricter limits of 200/400 colonies per 100 ml.
These limits could very well require chlorination of the
reservoir effluent for considerable periods of time and
possible at all times.
(8) The design of the proposed Northglenn system which utilizes
three aerated lagoons in series with a long detention time in
the final reservoir should result in a very low potential for
IV-3
IV-4
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w
LO
U>
problems concerning the transmission of waterborne diseases
due to the influent wastewaters. Add to this the capability of
chlorinating the effluent from the reservoir if the fecal
coliform level increases and the system appears to be ade-
quately safeguarded in terms of waterborne disease trans-
mission potential.
(9) The design of the aeration system for the first aerated lagoon
cells will not be capable of maintaining complete suspension
of suspended solids. This is due primarily to the geometry of
the cells and the effective zone of complete mixing for static
aerators. Thus, some settling of suspended solids on the
sidewalls of the first-stage lagoons can be expected. • This is
not expected to seriously impair system efficiencies. It
does, however, represent a departure from the system specifi-
cations as set forth by Sheaffer and Roland, Inc. and Dr.
McKinney.
(10) The location of static aerator tubes near the effluent
structures in the third-stage lagoons may cause problems in
terms of effluent TSS concentration from the third lagoons.
These aerators, when in use, may keep suspended solids which
might otherwise have settled out from settling. The inter-
mittent use of these aerators could lead to short-term high
TSS concentrations in the lagoon effluent due to resuspension
of previously settled solids in the areas around these
aerators.
(11) The temperature calculations for cold-weather operation made
by Sheaffer and Roland, Inc. utilize an equation designed for
quiescent lagoons. The temperatures thus calculated for
winter conditions are too high for the statically aerated and
mixed lagoon system proposed for Northglenn. The negative
effects of cold weather on BOOs removal and nitrification
during winter operation cited previously may thus be further
magnified.
IV-5
(12) The aeration energy requirements for the proposed Northglenn
wastewater treatment system were compared to the estimated
total energy requirements for treatment using extended aera-
tion, activated sludge, and rotary biological contactors. The
Northglenn aeration energy requirements are from 20 to 800
percent greater than the estimated energy requiremetns for
these other systems.
(13) The total estimated energy requirements for the proposed
Northglenn wastewater treatment system, including aeration
and conveyance energy and other miscellaneous requirements,
were compared to the estimated energy for conveyance to and
treatment by Denver Metro. The results of this comparison
indicate that the proposed Northglenn wastewater treatment
system will require approximately 60 percent more energy than
treatment by Denver Metro.
(14) Several measures for algae control within the Bull Canal
Reservoir, should this become necessary, have been analyzed.
These measures included: (a) use of algicides, (b) use of
flocculants, (c) use of biological controls (algae-consuming
fish, primarily tilapia), (d) selective discharge, and (e)
filtration. Biological controls and selective discharge are
potential measures for the reduction in algal and suspended
solids in the reservoir effluent. Selective discharge is a
design feature of the proposed effluent facilities and pro-
vides operational flexibility for suspended solids control.
If it is necessary to implement additional suspended solids
controls, and if Northglenn selects biological organisms as
the control strategy (non-native species such as! tilapia), it
will be necessary to ensure total containment of the species.
This containment is desirable to prevent introduction into
State waters and prevent competition with native, game spec-
ies. Containment will require proper-sized screening of
outlet structures and/or continuous chlorination.
IV-6
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\
APPENDIX F
ALTERNATIVE TREATMENT SITE ANALYSIS
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APPENDIX F
ALTERNATIVE SITE ANALYSIS
INTRODUCTION
The Northglenn water resource management plan initially considered
nine alternative sites for wastewater treatment and storage. At that
time, the treatment and reservoir system were perceived as being larger
than currently planned, because the project was being sized to provide
treatment and storage for wastewater from both Northglenn and Thornton.
In addition, the reservoir was to be located on a natural drainage thus
reducing reservoir construction requirements and costs. Thus, larger
land requirements were necessary. However, Thornton has withdrawn from
participating in the project, and other changes have been made which
effectively reduce land and other site requirements.
Seven criteria were used by Northglenn to evaluate the alternative
sites. These criteria included:
° compability with surrounding land use
0 safety of reservoir design
0 control of seepage losses
° underlying mineral resources
0 operational flexibility
0 consistency with approved wastewater management plans
0 severability of system components
The complete analysis of each si°te is presented in Northglenn1 s
Application for Site Approval (Reference 21). However, the site analy-
sis presents a bias toward the selected site, Site 10, because sites one
through nine were evaluated for both a larger and physically different
treatment and storage facility as originally proposed. Site ten was the
only site evaluated for the revised treatment and storage facility.
In view of the above, EPA determined it was necessary to conduct an
alternative site analysis for a wastewater treatment and storage system
identical to the currently proposed Northglenn facility. EPA recognizes
the fact that Northglenn has expended a considerable amount of time and
money investigating and designing for Site 10. However, it has not been
demonstrated that the selected treatment and storage site is environ-
mentally suited for the currently proposed facility. Therefore, this
alternative site analysis evaluates three additional sites for treatment
and storage of Northglenn's wastewater.
The purpose of this analysis is to determine if another site is
more environmentally acceptable, and whether Northglenn's proposed
F-l
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treatment site is environmentally acceptable when compared to other
sites.
This analysis will not develop information to the level of detail
currently available on the proposed site, since that level is specific
for design consideration. This analysis considered all four sites
(including Site 10) from an initial screen perspective, using existing
data. The selection criteria for the three additional sites were:
0 site would require no more than three residences to be relocated
the site is not located in a natural drainage
Based on these criteria the three sites located on Figure F-l and
designated as A, B, and C were selected.
All four sites are evaluated using the following environmental
criteria:
0 geology
0 groundwater
0 soils and construction geology
0 topography and flooding
0 land use
0 proximity to the Bull Canal
0 consistency with land use plans
Additionally, the cost of relocating the proposed facility to one
of the new sites was considered.
A summary of the environmental analysis of alternative sites is
presented in Table F-l.
GEOLOGY
Mineral Resources
Potential mineral resources in the alternative site study area
include sand, gravel and quarry aggregates, coal, oil, and natural gas.
Sand, gravel and quarry aggregates are the raw materials used in
the construction of buildings, roads, and virtually all other man-made
structures. Industrial, commercial or residential development over
recoverable deposits of these resources essentially precludes any future
use. To avoid loss of the use of these resources, surface development
should be sited away from recoverable deposits. No recoverable sand,
gravel or quarry aggregates occur on any of the alternative facility
sites (8).
F-2
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FIGURE F-l
LEGEND
STUDY AREA BOUNDARY
PROPOSED SITE
ALTERNATIVE SITES
RESIDENTIAL DEVELOPMENT
^MAJOR ROADS
...-WATERWAYS
Weld Countv
ALTERNATIVE SITE
STUDY AREA
F-3
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TABLE F—1 ENVIRONMENTAL EVALUATION MATRIX OF ALTERNATIVE TREATMENT AND STORAGE SITES
CRITERION
SITE A
SITE B
SITE C
SITE 10
Mineral Resources
Faults
Subsidence
Soils
Permeability
Suitability for Construction
Prime Agriculture Land
Topography
Slope
Flooding Potential
(>roundwater
Depth
Number of Wells Onsite
Land Use
Current
Zoning
No. of Residences
Proximity to hull Canal
Cost if
No sand or gravel resources,
possible oil, gas or coal
No active or potentially
active faults
Probably not of concern:
South of Boulder -
Weld Coal Field
Low perm., 0.06 - 20 In/hr
Med. to low shear strength
Mod. to high shrlnk-swell pot.
Yea - If Irrigated
West half 0-3% slope to east
Total elevation change 60 ft.
Slight
Perched: 6-12 ft,
D..ep: 70 - 300 ft.
2(1 municipal, 1 other uses)
Agriculture
A-3
None on site;
20-30 within 1/2 mile
200 ft.
$30,247,900
possible oil, gas or coal
No active or potentially
active faults
Probably not of concern
South of Boulder -
Weld Coal Field
Low perm., 0.06- 20 in/hr
Med. to low shear strength
Mod. to high shrlnk-swell pot.
Yes - If Irrigated
0-3% slope toward southeast
Total elevation change 50 ft.
Moderate
Perched: 8-15 ft.
Deep: 25 - 120 ft.
2(1 domestic, 1 irrigation
and stock)
Agriculture
A-3
None on site;
40 - 80 within 1/2 mile
900 ft.
$30,326,600
possible oil gas or coal
No active or potentially
active faults
Probably not of concern:
South of Boulder -
Weld Coal Field
Low perm., 0.06 - 20 In/hr
Med. to low shear strength
Mod. to severe shrlnk-swell
pot.
Tfe« - if Irrigated
3-9% alope around two knolls
total elevation change 55 ft.
Moderate
Perched: B-12 ft.
Deep: 25 - 70 ft.
0
Agriculture
A-3
None on site;
30 - 40 within 1/2 mile
300 ft.
$30,110,400
coal resources, possible o
or gas.
No active or potentially
active faults
Probably not of concern:
South of Boulder -
Weld Coal Field
Low perm., 0.06 - 20 in/hr
Low shear strength,
Mod. shrink-Bwc] 1 pot.
Yes - If Irrigated
able
11
3-531 slope around knoll in
southeast cornpr; 0-3Z Hlope
to northwest corntr, lol.il
elcvntlon chnnRc 60 It.
Slight
Perched: 6-10 ft.
Deep: 28 - 30 ft.
0
Agriculture
Agricultural
None on site;
20 - 30 within 1/2 mile
50 ft.
$30,242,300
Does not include costs of delaying project.
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Coal has been mined in the Denver Basin, which includes the alter-
native site study area, since 1863. In the past century over 100
million tons of coal have been produced from the Boulder-Weld Coal Field
in southeastern Boulder County and southwestern Weld County. The alter-
nate site study area is partially included in this coal field (Figure
F-2), and parts of sites 10 and B are within the approximate boundary of
areas known to be underlain by beds of Laramie Coal that are five feet
thick or greater (Figure F-3). Sites A and C are within a mile of known
Laramie beds (10). Test holes drilled on and around Site 10 encountered
two seams of coal, neither more than 2.5 feet thick. The seams were
from 450 to 600 feet below the land surface (12). The coal seams are
considered both too thin (12) and too far below the surface (7) to be
economically recoverable. Coal workings generally do not go below 500
feet because of economic and engineering considerations (7). Coal seams
probably lie under Sites A, B, and C but test holes would have to be
drilled to determine the thickness and depth of the seams. Coal beds in
the area are thought to be at a depth of 500 to 1,000 feet (10).
The alternative sites are within the Spindle oil and Wattenburg gas
fields (12). None of the sites currently has any producing oil or gas
wells, but active wells exist within a mile of any of the alternative
sites. While oil and gas reserves may exist beneath the alternative
sites, the technology exists to develop such resources after the facil-
ity has been constructed (12).
Faults
Faults are fractures in the underlying rock along which movement of
rock blocks has occurred due to stress and motion in the earth's crust.
An active fault is one which has shown displacement within the last two
million years. A potentially active fault has shown displacement within
the last 25 million years (23). A lagoon or reservoir sited in the im-
mediate vicinity of an active fault could be ruptured if activity along
the fault resulted in surface displacement. An earthquake resulting
from movement along a fault close to the facility could cause damage to
the lagoon or reservoir embankments. No active or potentially active
faults are known to occur directly under any of the alternative sites.
Extensive faulting has occurred west of the alternative facility sites
in the foothill area of the Front Range, and faulting associated with
the Boulder-Weld Coal Field exists to the north. Neither group of
faults appears to extend into the study area (5,6). The Rocky Mountain
Arsenal Fault which showed induced activity but no surface displacement
in the 1960's is from four to seven miles south of the alternative sites
and does not extend under any of the sites (7).
Inactive faults have not shown activity for long periods of time.
However, land use activity and development, or man-induced seismicity,
might affect their stability (23). In addition, inactive faults could
serve as conduits to channel seepage from the lagoon or reservoir into
the bedrock aquifers and pollute groundwater. Such seepage could also
activate a fault by lubricating fault surfaces as happened at the nearby
Rocky Mountain Arsenal Fault. An inactive fault has been found in the
northeast corner of Site 10. On-site studies would have to be conducted
to determine if inactive faults exist beneath the other three sites.
F-5
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Figure F-2
BOULDER-WELD COAL FIELD
Larimer Co.
r
i
i
Boulder Co.
Adams Co.
Jefferson Co.
F-6
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Figure F-3
APPROXIMATE OUTLINE OF
AREAS KNOWN TO BE
UNDERLAIN BY
LARAMIE COAL BEDS
FIVE FEET THICK OR
GREATER
COAL RESOURCES OF THE STUDY AREA
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Subsidence
The Boulder-Weld Coal Field in southeastern Boulder and south-
western Weld Counties (Figure F-2) was extensively mined in the latter
portion of the last century and the first half of this century. Many
areas within the coal field have subsided as a result of mining activ-
ity. However, all four alternative sites lie in areas where the coal is
too deep to have been economically mined (7,10). Virtually no coal min-
ing has occurred in or around the alternative site study area; there-
fore, none of the sites is expected to be affected by subsidence (6).
GROUNDWATER
The depth and fluctuations of the groundwater below each alterna-
tive site is important in order to assess the potential impact of lagoon
seepage upon beneficial uses. Both the upper groundwater, or perched
aquifer, and deeper aquifers are analyzed. Perched aquifers, in agri-
cultural areas, are generally formed by irrigation return water, seepage
from irrigation ditches, and alluvial aquifers (alluvial aquifers are
those areas which contain groundwater that is hydraulically connected to
surface water). Because of poor quality and low yields, perched aqui-
fers are not used extensively as a water supply source. Deeper aquifers
are commonly used extensively for domestic, livestock, and irrigation
purposes, and thus potential impact to them is of greater concern.
Seepage from the lagoons could find its way into these aquifers through
faults or cracks in the bedrock beneath the lagoon and reservoir.
All four potential sites are directly underlain by the Arapahoe
Formation which has been exposed in a broad east-west band that includes
the study sites (11). The Arapahoe Formation is a highly permeable
aquifer which generally contains high quality groundwater (10). The
aquifer becomes deeper below the land surface as it dips south, and it
is an important source of water for Denver's northern suburbs (15). The
entire exposed band of Arapahoe Formation, and especially in the Big Dry
Creek Area, could be considered as a recharge zone for the aquifer (13,
14).
Well logs from the U.S. Water and Power Resource Service (formerly
the Bureau of Reclamation) indicate the groundwater level in the Arapa-
hoe aquifer around the alternative site study area is 10 to 30 feet
below the surface (14). The depth to groundwater in this formation
beneath Site 10 varies from 11 to 38 feet (13). A perched water table
near the Bull Canal was identified to be about seven feet deep and is
believed to be a result of seepage from the canal. The depth to water
beneath the other three sites is estimated from well logs of wells
drilled near or on the sites (3,9). It appears that the deep aquifer
(based on the well logs) beneath Site A is deeper than beneath the other
sites which would be an advantage in siting the proposed facilities.
However, Site A is immediately adjacent to Big Dry Creek, so that seep-
age from the lagoons could enter the Big Dry Creek Alluvial aquifer.
This aquifer is used as a local water source (3).
Without more detailed information from test drillings beneath Sites
A, B and C, it is impossible to determine what differences exist in
F-8
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groundwater beneath the sites. Site A is the most critically located,
because of its proximity to the Dry Creek Alluvium. However, mitigation
measures to ensure that no groundwater degradation occurs will be neces-
sary at all the sites. These measures can parallel those proposed for
Site 10 (i.e., lining the lagoon bottom with clay, the lagoon embank-
ments with asphalt, and drilling monitoring wells around the site per-
iphery to monitor groundwater quality).
SOILS AND CONSTRUCTION GEOLOGY
Soils at each site are evaluated on the basis of their permeabil-
ity, suitability for construction of earthen dikes, and whether or not
they are prime agricultural land. Since the soil excavated at the site
would be used to construct and line the treatment and storage lagoons,
their suitability for lining must be considered. If the native soils
all have a high permeability then the problem of leakage from the la-
goons will be more severe. If the soils are unsuited to construction of
earthen berms then soil will have to be imported for this purpose and
the native soil disposed of elsewhere, thus increasing the cost of con-
struction. Finally, it is desirable to build the proposed facility on
soils which are not prime agricultural land since the land will be
removed for the life of the project from agricultural production. In-
formation for evaluating the above parameters was obtained from Refer-
ences 1 and 2.
All four sites have very similar soil characteristics. The pre-
dominant soils are clay loams, with permeabilities that range from 0.06
to 2.0 inches per hour. However, during tests of soil samples obtained
from Site 10, permeabilities considerably lower than these values were
obtained (4). Bedrock consisting of predominantly claystone with inter-
bedded layers and lenses of sandstone and claystone-siltstone was en-
countered at depths of 3 to 16 feet (4,12). The soil engineering report
for Site 10 indicated that material at the site would be suitable for
construction of the proposed lagoon dikes, and that bedrock could prob-
ably be excavated by a truck-mounted ripper. The report further indi-
cates that most or all of the excavated bedrock could be broken into
small enough pieces to be used as embankment fill (4).
Based on the Adams and Weld County soil surveys (1,2) and on drill-
er's logs of wells drilled in the area (3) it appears that subsurface
conditions at Sites A, B and C are quite similar to those at Site 10.
Well logs indicate that bedrock under Sites A, B and C ranges from 45 to
50 feet deep. The overlying material is mostly clay with up to a two
foot layer of topsoil. Construction of the lagoons would be somewhat
easier if bedrock were not encountered in any excavation such as is
expected at Site 10; in addition, the possibility of lagoon seepage
finding its way into the Arapahoe Formation would be reduced. There is
no way to verify the depth to bedrock at these sites without exploratory
drilling as was done at Site 10.
The construction suitability of the soils appears to be quite simi-
lar at all the sites. Using proper construction techniques and care in
selecting excavated material to be used for embankment fill, the geo-
logical report on Site 10 concluded that the native excavated material
F-9
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could be used. There is no reason to believe that the soil at the other
three sites will be any less suitable.
The construction of the embankment requires coarse aggregate in the
drain blanket. This material could be obtained at Site 10 from the ex-
cavated bedrock material. If bedrock is not encountered at the other
three sites, coarse aggregate material would have to be imported for
construction. Without detailed analysis of the quantities of material
required, it is uncertain whether the cost of importing aggregate at
Sites A, B and C would be less than the cost of excavating the bedrock
at Site 10.
All four sites were classified as prime agricultural land, if irri-
gated. At present, all are used for agricultural purposes, with varying
amounts of irrigation on each. There is no significant difference be-
tween any of the sites with regard to this parameter.
TOPOGRAPHY AND FLOODING
Each site was evaluated on the basis of its general topography and
the potential for flooding. The slope of the land will affect both the
ease of lagoon and reservoir construction and the visual impact of the
lagoons. A site with a large amount of relief would require a greater
construction effort and would have a greater visual impact than one on
flat terrain. Sites with a high possibility of flooding should be
avoided.
All four sites are very similar with regard to slope and flooding
potential. Site B does not have any slopes greater than 3 percent,
Sites A and 10 both have some slopes up to 5 percent, and Site C has
some slopes up to 9 percent. These slopes are not excessive and would
not pose any construction problems. All will require approximately the
same amount of excavation and embankment construction. Because the
topographic features at all four sites are so similar, the visual impact
of the facility will be approximately the same at any of the sites.
None of the sites is subjected to a severe flooding hazard. Sites
B and C both have a moderate flooding hazard. Site B is located dir-
ectly downslope of McKay Lake (see Figure F-l) and could be subject to
flooding due to overflow or levee breaking. Site C is located adjacent
to a drainage ditch which would flow along its north border; high flows
in this ditch would subject Site C to possible flooding. Sites A and 10
have little or no potential for flooding.
CURRENT LAND USE
All four sites are presently used either for pasturage or for
growing crops. Sites A, B and 10 have no residences on them while Site
C has one residence which would have to be relocated. The sites in
Adams County (A, B and C) are all zoned A-3: agricultural with a
minimum ownership of 35 acres. Site 10 in Weld County is zoned
Agricultural.
F-10
-------
Land use practices in the area around the proposed sites are rap-
idly changing. Several nearby parcels of land have recently been sub-
divided and now contain single-family dwellings on one to five acre
lots. At least 20 houses are within a half-mile radius of each of the
sites, and Site B has as many as 80 residences within one-half mile.
Because of recent developments in the area, it is likely that in the
near future residential growth will occur in the vicinity of all sites.
Site C is bounded on the east side by 1-25 which would preclude any
development of homes adjacent to the facility on that side. None of the
other sites has any physical barriers to development around them.
Site C is slightly less desirable than the others because one
household would have to be relocated. Otherwise, the agricultural use
of all four sites makes them equally suitable for the proposed facility.
It would be preferable aesthetically to select a site that has very few
residences around it; unfortunately, rapid growth of residential housing
within the study area has made this impossible. Site C may be preferred
because its proximity to the interstate highway may partially mitigate
aesthetic impacts on nearby residences.
PROXIMITY TO BULL CANAL
Water will, at different times, flow into and out of Bull Canal
from the storage reservoir; therefore, close proximity to the canal will
facilitate these water transfers. However, unless the distance is
great, this factor is not a major constraint. Site 10 is the closest to
the canal, the outlet structure being approximately 50 feet from the
canal. Sites A, B and C are approximately 200, 900, and 300 feet from
the Bull Canal, respectively. Sites A and 10 would operate alike with
regard to water transfer; i.e., water being pumped from the reservoir to
the canal, and flowing by gravity the other way. Sites B and C would
have water pumped from the Bull Canal to the reservoir and flow by
gravity from the reservoir to the canal.
It appears that Bull Canal flows atid effluent management would be
slightly easier at either Site A or Site 10 than at Sites B and C. How-
ever, management at any of the sites would not be particularly difficult
and this factor alone is not sufficient for rejection of Sites B or C.
COSTS
The total cost of the wastewater collection and treatment component
of the proposed Northglenn Water Supply and Wastewater Treatment System
on Site 10 is estimated to be $30,242,300 (16). This includes collec-
tion system modifications, the force main to the treatment site, facili-
ties construction, land costs, and engineering, legal and administrative
costs. All of the costs involved in collection of wastewater, including
the cost of the pump station, would remain approximately the same no
matter which site was selected for the treatment and storage facility.
Because the topography, soils and geology of Sites A, B, and C are
similar to those at Site 10, facility construction costs at each site
would be expected to be similar. Costs for fixed components (collection
and construction) are estimated to be $28,366,900. The cost of the
force main and land costs would change with the selection of a new site.
F-ll
-------
In addition, because a final design has been prepared for the proposed
facility at Site 10, additional engineering costs would be incurred in
changing to a new site. Finally, selection of a new site would result
in delays to the project. A comparison of costs resulting from reloca-
tion of the facility are presented in Table F-2.
Sites A, B, and C are closer to Northglenn than Site 10 and the
shorter distance would result in a shorter and less costly force main.
Cost of the force main to Site 10 is estimated to be $1,729,000. Se-
lection of Sites A, B or C could result in a force main 83 percent, 76
percent, and 78 percent respectively, as long as the force main to Site
10. Construction costs of the force main could be reduced proportion-
ately to $1,433,800 for Site A, $1,307,300 for Site B, and $1,349,500
for Site C. Although Sites B and C are about 50 feet higher than Site
10, it is estimated that the cost of pumping the wastewater a shorter
distance would compensate for the cost of raising it to a higher ele-
vation.
The land at Site 10, 320 acres, was acquired several years ago for
a total cost of $146,400 or $457.50 per acre. Since then, land prices
have increased several fold. Four pieces of land presently for sale and
located close to the proposed facility sites (Figure F-4) range in price
from $2,500 to $5,000 per acre (17,18,19,20). Acquiring the land for
Sites A, B and C at a cost of $3,800 per acre would cost $725,800,
$931,000, and $672,000 respectively. However, if a new site were
selected, Site 10 could be sold. If it sold for only $2,500 per acre,
the credit would be $800,000, more than offsetting the costs for Sites A
or C and $131,000 less than the cost of Site B.
As of 21 January 1980, $235,423 had been allocated for construction
management of the wastewater system, and $37,215 had been spent for
wastewater reimbursables or contingencies (16). These costs not only
are unrecoverable, but an equal amount would probably have to be ex-
pended again if a new site were selected. In addition, $513,000 worth
of engineering has gone into the final design plan for Site 10. How-
ever, it is estimated that with an expenditure of about $100,000 the
Site 10 design plan could be modified to fit any of the other three
alternative sites (22). Unrecoverable costs and additional engineering
costs to move the facility to Sites A, B or C are therefore estimated to
be approximately $375,000.
In March 1979, the City of Northglenn estimated that relocating the
treatment facility would cause a delay of 465 days and would cost at
least $2,500,000, including inflation, lost revenues, aquisition of a
new site, and facility redesign (21). This analysis does not include
inflation or loss of revenue. The cost of building a shorter force main
to any of the alternative sites plus the credit for selling Site 10 to
buy one of the alternative sites would partially compensate for unre-
coverable costs and additional engineering costs involved in changing
sites. If delay costs in changing to a new site are not considered,
little difference exists between costs in keeping the facility at Site
10 and relocating it to any alternative site.
F-12
-------
TABLE t-2 COSTS RESULTING FROM RELOCATION OF NORTHGLENN WATER TREATMENT AND STORAGE FACILITY
SITE FIXED COSTS
FORCE MAIN
($)
Site Cost Coat ChanRe
($) ($)
Site 10
Cost
($)
LAND
UNRECOV. & COST CHANGE
ESTIMATED COST OF
Site 10
Site Cost Selling Credit
Site Size $3800/Ac.
(Acres) ($)
ADDITIONAL OF RELOCATING WASTEWATER PROJECT
ENG. COSTS FACILITY SITE
$2500/Ac. Coat Change
($)
($)
($)
($)
($)
M
U>
10 28,366,900 1,729,000 0
A 28,366,900 1,433,800 - 295,200
B 28,366,900 1,307,300 - 421,700
C 28,366,900 1,349,500 - 379,500
146,400
320
191
245
177
725,800 800,000
913,000 800,000
672,600 800,000
0
- 74,200
+ 131,000
- 127,400
0
+ 375,000
+ 375,000
+ 375,000
0
5,600
84,300
- 131,900
30,242,300
30,247,900
30,326,600
30,110,400
SOURCE: Engineering-Science. Inc.
-------
FIGURE F-4
LEGEND
AG. LAND CURRENTLY FOR SALE
STUDY AREA BOUNDARY
PROPOSED SITE
ALTERNATIVE SITES
RESIDENTIAL DEVELOPMENT
TMAJOR ROADS
WATERWAYS
Weld Countv
AGRICULTURAL LAND USED
IN COST ANALYSIS
F-14
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CONCLUSIONS
All four sites are environmentally suited for construction of
Northglenn's proposed wastewater treatment and storage facility based on
this evaluation. Differences do exist between Sites A, B, C and 10 in
the evaluation criteria, but these differences are believed to be insig-
nificant and can be mitigated by construction techniques and monitoring.
Advantages one site may offer for any given criterion can be balanced by
advantages another site offers for another criterion.
It is recognized that time and money has been committed to the
development of Site 10 and that relocation from this site would result
in some loss of this commitment. However, based on this initial analy-
sis, credits gained due to a shorter force main and land sales could
partially offset the expenditures to date. It is not known whether
these gains could offset the loss of bond revenue and effects of in-
flation. If only direct costs and environmental aspects are considered,
all four sites are equally suited for the proposed project.
F-15
-------
REFERENCES APPENDIX
1. SCS, U.S. Dept of Agr., Soil Survey of Adams Co., Col., Oct. 1974
2. Holden, Dale, SCS, Personal Communication on 28 March and 3 April
1980
3. McConaghy, J. A., Chase, G. H., Boettcher, A. J., and Major, T. J.,
Hydrogeologic Data of the Denver Basin, Colorado, USGS, Colorado
Ground Water Basic Data Report No. 15, 1964
4. Chen and Associates, Inc., Subsurface and Geological Investigation
for a Proposed Reservoir Site, Weld County, Colorado, prepared for
Schaeffer and Roland, Inc., September 12, 1978
5. Kirkham, R. M., and W. P. Rogers. Earthquake Potential in Colo-
rado. Colorado Geological Survey Open File Report 78-3, 1978.
6. Myers, A. R., J. B. Hansen, R. A. Lindvall, J. V. Ivey, and J. L.
Hyres. Coal Mine Subsidence and Land in the Boulder-Weld Coal
Field. Colorado Geologic Survey Env. Geo. Publication No. 9
7. Rogers, W. P., Personal Communication, Colorado Geological Survey
8. Schwochow, S. D., R. R. Shroba, and P. C. Wicklein. Atlas of Sand,
Gravel and Quarry Aggregate Resources, Colorado Front Range Coun-
ties. Colorado Geological Survey, Department of Natural Resources.
Special Publication 5-B, 1974.
9. Colorado Department of Natural Resources, Division of Water Re-
sources, State Engineer. Groundwater Well Records (Microfiche)
10. Kirkham, R. M., and R. L. Ladwig. Coal Resources of the Denver and
Cheyenne Basins, Colorado. Resource Series 5, Colorado Geological
Survey, Colorado Dept. of Natural Resources, 1979
11. Robeson, Stan, USGS, Personal Communcations on March 31, 1980
12. Chen and Associates, Inc. Preliminary Engineering Geology and
Soils Investigation for a Proposed Reservoir Sections 26 and 36,
TIN R68W, Weld County, Colorado. Prepared for Shaeffer and Roland,
Inc., March 1978
13. Jinge, Ray, Colordo Geological Survey, Personal Communication on 4
April 1980
14. Phillips, Mark, Water and Power Resources Service, Personal Com-
munication on 7 April 1980
15. Zawistowski, Stanley. Colorado Department of Natural Resources,
Division of Water Resources, Personal Communication on 28 March
1980
F-16
-------
16. Sheaffer and Roland, Inc. Letter to Richard P. Lundahl, Department
of Natural Resources, Northglenn, Colorado, February 25, 1980
17. Colorado Investor Realty, Denver, Colorado, Personal Communication,
April 1980
18. John Geiger and Co., Denver, Colorado, Personal Communication,
April 1980
19. Van Schaack and Co., Denver, Colorado, Personal Communication,
April 1980
20. Moore and Co., Denver, Colorado, Personal Communication, April 1980
21. City of Northglenn, Application for Site Approval—Northglenn/FRICO
Return Flow Facility, submitted to the Colorado Water Quality Con-
trol Commission, March 19, 1979
22. Alexander, John, Engineering-Science, Personal Communication, April
1980
23. Denver Regional Council of Governments, Regional Growth and Devel-
opment Plan, Specification of Environmentally Significant Areas in
the Denver Region. Comprehensive Planning Office, Denver Regional
Council of Governments, 1977
F-17
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-------
APPENDIX G
ANALYSIS OF CHANGES IN AGRICULTURAL PRODUCTIVITY
-------
-------
AGRICULTURE IN THE STUDY AREA
Agriculture is an extremely important industry in the State of Colorado,
including the FRICO and Lower South Platte portions of the study area. Due
to urban encroachment, land development, changes in land policies and erosion,
Colorado has lost six percent of its productive land in the last two decades.(1)
Along the Front Range, irrigated cropland decreased from 700,000 to 660,000
acres between 1959 and 1978. (1) In view of the potentially critical impact
nationwide of the reduction in agricultural land, the current EPA policy
is "... to protect... the Nation's environmentally significant agricultural
land from irreversible conversion to uses which result in its loss as an
environmental or essential food production resource."(2) Consequently, a
key issue in the evaluation of the proposed Northglenn Water Management
Program is its potential impact on agriculture.
Conceptually, the intent of the Northglenn Plan is to minimize the
impact on agriculture by providing water to the City via a scheme of
water reclamation and exchange in lieu of condemnation. To understand
the implications of the proposed plan as it relates to agriculture, it
is necessary to first examine the soils, irrigation practices, crops,
and current productivity of the agricultural lands in the study area.
Soils and Soil Productivity
The USDA Soil Conservation Service (SCS) has conducted detailed soil
surveys in the region. The soils survey for Southern Weld County is, however,
unpublished at the present time. The major soils within the study area
have a textural range from sandy loams to clay loams, with minor areas
identified as clays and sands. Soils of the region generally reflect the
Tertiary and Pleistocene sediments at the eastern edge of the Rocky Mountain
system, with minor sediments derived from the Denver and Arapahoe Arkose
formation. Recent alluvium deposits occur along major stream valleys.
Soils can generally be grouped into the high terrace and alluvial fan soils,
old terrace and plains soils, ridgecrest and slope soils, upland soils,
floodplain soils, and the sandhill area soils.
Natural soil fertility is low within the survey area. Nitrogen, and
to a lesser degree phosphorus, are needed for best crop production in the
irrigated areas. Zinc and iron are the only nutrients known to be deficient
in many of the soils.(3.4) Most irrigation water contains enough of the
minor elements to meet the annual requirements of commonly grown crops.
Soil capability classifications used by the SCS are interpretative
groupings made primarily for agricultural purposes. In this classification,
the arable soils are grouped according to their potentialities and limitations
for sustained production of the commonly cultivated crops. Thus, the most
productive soils under irrigation have Class I capability ratings, whereas
those with limitations are rated with larger Roman numerals. Class I soils
have few, if any, limitations and Class III soils have moderate limitations
which reduce the choice of crops or require moderate conservation practices.
Class IV, Class V and Class VI soils have limitations which make them
generally unsuited for cultivation, and limit their use largely to pasture
or range. Potential flooding, uneven topography, excessive rock or tree
G-l
-------
cover, seasonal high water tables, drainage problems, inadequate depth to
bedrock, excessive slope, and clay subhorizons are the reasons for poor
ratings. The major irrigated soils within the study area are identified
as Class II and Class III soils, with minor areas rated as Class I, Class IV
and Class VI.
Prime Farmlands
With the assistance of the Colorado State University Experiment
Stations, the USDA Soil Conservation Service has also undertaken the task
of identifying and mapping farmlands of national, statewide and local
importance. The result of these efforts is a series of Important Farmlands
Maps. In general, lands identified on the maps as "Prime Farmlands"
(see Figure G-l) have an adequate and dependable water supply from irrigation,
a favorable temperature and growing season, acceptable acidity or alkalinity,
acceptable salt and sodium content, and few or no rocks. In addition, these
lands are permeable to water and air, are not excessively erodible or
saturated with water for long periods of time, and either do not flood
frequently or are protected from flooding. As illustrated on Figure G-l,
the vast majority of the lands included in this study (both FRICO and South
Platte) have been designated "Prime Farmlands."
Irrigation Practices in the Study Area
All methods of irrigation are suitable for the soils within the study
area except where slope is a limiting factor. Furrow irrigation is most
common.
Furrow irrigation is accomplished by gravity flow of water in narrow
channels fed by a head ditch. Water seeps into the soils from the sides
and bottom of the furrows. Water is introduced into each furrow by a
siphon tube from the head ditch. Crops commonly irrigated in the area
are alfalfa, corn, sugar beets, barley, field beans and small vegetables.
Where slope is a limiting factor, contour ditches, corrugations,
contour furrows, cross-slope furrows, and sprinklers are used. At least
one center pivot sprinkler is used in the study area. According to the
Weld County Extension Service,(5) there is a trend to replace furrow
irrigation with sprinklers. The two major reasons for this trend are
to increase water application efficiencies and to decrease labor cost.
Cropping Patterns
The irrigated farmland within the study area produces a wide variety
of crops. The main crops are corn for grain and silage, alfalfa, sugar
beets, and field beans. A common cropping system is a 3 to 4 year rotation
of alfalfa followed by corn for grain, corn for silage, sugar beets and
small grains of field beans. This type of rotation allows maximum use of
available soil nutrients. Malt barley and certain truck crops are also
grown on limited acreages within the study area.
G-2
-------
Most of the corn grown in the area is used for feed at commercial
feedlots, farm feedlots, and dairies. Significant numbers of sheep and
turkeys are raised on the feed crops grown in the area.(3) Sugar beets
and malt barley crops are commonly contracted for by Great Western Sugar
Corporation and Coors Brewery, respectively.
A rotation of small grain and summer fallow is the main type of farming
on the non-irrigated acreage. Wheat is the principal dry-farm crop, but
barley and sorghum are also grown.,
In the 27 year period from 1950 to 1977, Colorado Agricultural
Statistics(6) show an increase in the acreage plated in corn and wheat.
Barley, field beans, sugar beets, and sorghum have gradually declined
since 1950. During the same period of time, however, yields per acre for
all crops have increased. This may be attributed to more efficient farm
management practices and advanced technology in agricultural practices.
Present Agricultural Productivity
Estimates of the crop yields for lands which may be removed from
agricultural production under the Northglenn Water Management Plan have
been developed. Table G-l indicates the estimated irrigated and non-
irrigated acreages of crops grown in the Standley Lake Division of FRICO
in 1979. Table G-2 lists the estimated crop yields and crop values for
those lands in 1979. The total value of crops produced from irrigated
lands in the Standley Lake Division of FRICO in 1979 was approximately
$1,922,000. According to information obtained from FRICO, Standley Lake
releases in 1979 totalled 14,425 acre feet. Assuming that 60 percent of
the releases were delivered to the farm headgate, the 1979 farm headgate
deliveries amounted to 8655 acre feet. Given an irrigation efficiency
of 65 percent, the consumptive use of irrigation water on the 8345 acres
of FRICO land irrigated in 1979 was approximately 5626 acre-feet. The
average productivity of irrigated land in the Standley Lake Division of
FRICO was therefore $230 per acre in 1979, or $342 per acre-foot of con-
sumptive use of irrigation water.
This average producitivity of $342 per acre-foot of consumptive use
of irrigation water does not represent the actual value of water. Rather,
it represents the value of the crops produced on FRICO land per acre-foot
of water consumed. The value of the crops is the economic return on a
number of resources including water, labor, capital, machinery, fertilizer,
and other inputs. Water delivered via irrigation, of course, is not sufficient
in the absence of these other resources for crop production; therefore,
water is not solely responsible for the value of the crop. In the following
analysis, it is assumed that these other resources are equal for FRICO and
South Platte lands. On the basis of this assumption, the average productivity
per acre-foot of consumptive use provides a relative indicator of the value
of water in the two systems.
The consumptive use of irrigation water in the FRICO system was approx-
imately 0.67 acre-foot per acre in 1979. As this is significantly lower
than the potential consumptive use of most crops, the question arises as
to how FRICO farmers are able to achieve their current level of production
G-4
-------
-------
-------
-------
j
DENVER CITY AND COUNTY
-------
-------
TABLE. G-l
ESTIMATED DISTRIBUTION OF IRRIGATED
AND NON-IRRIGATED AREAS WITHIN
FARMERS
CROP
Corn (Grain/Silage)
Alfalfa
Spring Wheat
Winter Wheat
Barley
Sugar Beets
Field Beans
Fallow
Dairy
Non-Agricultural
RESERVIOR AND
IRRIGATED
4,850
1,970
0
0
767
606
152
0
0
0
IRRIGATION CO.,
AREA (ACRES)*
NON- IRRIGATED
0
0
1,033
834
700
0
0
3,031
62
1,151
STANDLEY
LAKE DIVISION IN
1979
PERCENTAGE OF TOTAL AREA
TOTAL
4,850
1,970
1,033
834
1,467
606
152
3,031
62
1,151
IRRIGATED
32
13
0
0
5
4
1
0
0
0
NON-IRRIGATED
0
0
7
5
5
0
0
20
^
l
7
TOTAL
32
13
7
5
10
4
1
20
1
7
TOTAL
8,345
6,811
15,156
55
45
100
*Estimated from planimetering maps of cropping pattern in 1979 within Farmers Reservoir
and Irrigation Co., Standley Lake Division.
-------
TABLE G-2
ESTIMATED 1979 CROP VALUE
Crop
Alfalfa
Corn (grain)
Corn (silage)
Sugar Beets
Field Beans
Barley (irrigated)
Barley (non-irrigated)
Wheat (non-irrigated)
IN FRICO
Yield Per Acre1
3.06 ton
74 bu
17 ton
19 ton
27.5 bu
52.9 bu
16.5 bu
16.5 bu
Estimates based on information contained
entitled Physical and Economic Effects on
STANDLEY LAKE DIVISION
1979 Market Value2
$ 49.50/ton
2.74/bu
18.31/ton
29.00/ton
10.00/bu
2.64/bu
2.11/bu
3.76/bu
Crop Acres
1,970
3,3953
1,4553
606
152
767
700
1,867
10,912
0
Crop Value
Irrigated Non-Irrigated
$ 298,000 $
688,000
453,000
334,000
42,000
107,000
24,000
116,000
$ 1,922,000 $140,000
in CSU Environmental Resources Center Completion Report No. 75
the Local Agricultural Economy of Water Transfer to Cities, (7)
and personnel interviews with FRICO farmers
From Northern Feed and Bean, Western Alfalfa Corp., Farmers Marketing Association, Monfort Farms,
Coors Brewery and Great Western Sugar Co.
Assume 70 percent of corn to be harvested as grain and 30 percent as silage.
-------
with such a limited water supply. A significant portion of the consumptive
use requirement of the crop is met from soil moisture stored in the soil
profile during the winter and spring months, and from effective precipitation
during the growing season. The soils in the FRICO area are predominantly
fine textured and trend to a clay loam classification. These soils have
a high field capacity, and the readily available soil moisture is on the
order of 2 inches per foot of root depth. The soil moisture is utilized
by the crop during the growing season when the irrigation application and
effective precipitation are not sufficient to meet the consumptive use
requirements. In addition, the crop mix of short-season crops such as
barley and wheat with long-season crops allow the farmer some water manage-
ment flexibility wherein he may apply less water per acre on the short-
season crops and apply more on corn and alfalfa. It therefore appears that
the moisture from the three sources, when judiciously applied to the crops
in the present cropping pattern, is adequate to produce the yields reported
in the FRICO system.
Implementation of the Northglenn Water Management Plan may result
in the removal of certain lands along the South Platte River from irrigated
agricultural production. Table G-3 summarizes the acreages, yields and
values of crops produced on these South Platte lands. The total value
of crops produced on the 1396.5 acres of irrigated land is approximately
$553,000. Based on depletion studies conducted by Wright Water Engineers,
Inc., the consumptive use of water from the South Platte ditches which
would occur as a result of irrigating this land is 2135.6 acre-feet in an
average year. The productivity of the land served by the South Platte
ditches is therefore approximately $396 per acre of land, or $259 per
acre-foot of consumptive use of irrigation water. (Note: In computing
the total crop value for lands in the South Platte system, the production
of 28.4 acres of pasture grass was neglected. This alone would result in
a slight underestimation of the crop value per acre-foot of consumptive
use; it is assumed, however, that this factor is "balanced" by the fact
that well water is occasionally used to supplement the irrigation water
supplied by the South Platte ditches. The total consumptive use of irriga-
tion water, therefore, may be somewhat higher than the consumptive use of
ditch water indicated above.)
For purposes of analyzing the impact of Northglenn"s plan on agri-
cultural productivity, it is assumed that the dry land agricultural
productivity of both FRICO and South Platte lands is $60 per acre annually.
This assumption may be somewhat generous, particularly with regard to the
South Platte lands; it also neglects the fact that a transition period of
about five years is required after removing a parcel from irrigated agri-
culture before it can produce at an acceptable level using dry-farming
techniques.
There is an inconsistency between the productivities of FRICO and the
South Platte for particular crops. It has been noted that the yields of
corn (grain) are 53 percent higher in the South Platte than in FRICO
while corn (silage) yields are 19 percent higher in FRICO than in the
South Platte. The yields for the South Platte irrigated lands are for
Adams County. From reviewing the existing irrigated land maps of Adams
County it is obvious that the major irrigated areas are along the South
Platte River, therefore, it is valid to use the County average yield for
the study area.
G-7
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TABLE G-3
ESTIMATED CROP VALUE-SOUTH PLATTE RIVER
o
00
Crop
Alfalfa
Small Vegetables
Corn (grain)
Corn (silage)
Sugar Beets
Field Beans
Barley (irrigated)
Yield Per Acre1
4.2 tons
-
140.0 bu
13.8 tons
18.6 tons
23.6 bu
43.6 bu
IN 1979 DOLLARS
1979 Market Values2
$ 49.50/ton
1,000.00/acre
2.74/bu
18.31/ton
29.00/ton
10.00/bu
2.64/bu
rt
Crop Acres
602.4
240.6
198.4
123.1
111.8
48.5
71.7
Crop Value
Irrigated
$125,200
240,600
76,100
31,100
60,300
11,400
8,300
1,396.5
$553,000
Estimated historic yields based on current market value of crops and information provided
by Colorado Agricultural statistician, Lance Fretwell and A. Watada, Executive Board Member,
Consolidated Ditches - South Platte River.
2 Northern Feed and Bean, Western Alfalfa Corp., Farmers Market Association, Monfort Farms,
Coors Brewery and Great Western Sugar Company.
Wright Water Engineers, Inc. City of Northglenn South Platte Augmentation Plan,
Engineering Report, March 31, 1980.
-------
The yields of crops produced in FRICO were not available for the
specific study are from County, State, or Federal agencies. The most
definitive data were available from work done by Dr. Ray Anderson(7)
and by personnel interviews with FRICO farmers.
The relative variations in crop yields, particularly the corn (grain)
and corn (silage) anomaly, is consist with the Adams County and Weld County
yields for these crops as reported in the 1979 Agricultural Statistics for
Colorado.
This variation in yields is believed to be a consequence of the
following:
FRICO initially plants corn for grain, but because of water
short conditions crops are often marketed as silage. (Corn
for grain can not be marketed profitable).
South Platte plants corn for grain on areas with better soil and
abundant water and corn for silage on poor soil with less available
water.
IMPACT ON AGRICULTURAL PRODUCTIVITY
The Northglenn Water Management Program is, as its title suggests,
a plan for the allocation of a scarce and valuable natural resource -
water. Because the key element in this plan is water, its impact on the
agricultural productivity of the lands it affects is examined from the
standpoint of consumptive use of irrigation water. In 1979, the productivity
of FRICO lands was approximately $342 per acre-foot of consumptive use of
irrigation water; the comparable value for South Platte lands is estimated
at $259 per acre-foot.
Four options within the basic framework of the Northglenn Water
Management Plan have been examined to determine their impact on total
agricultural production in the study area. The option which contemplates
acquisition of sufficient water to meet Northglenn's needs via purchase
or condemnation of FRICO shares and treatment of wastewater at the Metro
Denver Plant (Option 4) shall be used as the "baseline" to which the
agricultural impacts accompanying all other planning options will be
compared.
Water Availability to FRICO
The amount of water available to the FRICO farmers is dependent on
the option chosen. The estimated farm headgate delivery for each of the
options is summarized in Table G-4. This analysis ignores any benefits
due to lining of the Bull Canal.
G-9
-------
TABLE G-4
ESTIMATED FRICO FARM
HEADGATE WATER DELIVERIES
Option Description
1 Without deep wells
2 650 acre-feet from non-
tributary wells
3 2300 acre-feet from non-
tributary wells
4 Water from Standley Lake
Wastewater to Metro
Water (Acre-Feet)
Average Year Dry Year
63902
63902
63902
3572
4706
4667
46502
788
(1) Equal to 70% of sum of FRICO exchange return and release from Standley
Lake (see Figures 3-1 through 3-4).
(2) Under these conditions there is also excess water over repayment
requirement available to irrigate Northglenn owned lands.
Augmentation Water
Based on data set forth in Northglenn's Water Budget (see Table 4-2,
Main Report), the required augmentation water from surface sources for the
four options evaluated is summarized in Table G-5. Some of the augmentation
water will come from lands currently in production. To determine the impact
of each option on agriculture, only that water to be taken from lands
currently in production is of consequence.
G-10
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Option Description
TABLE G-5
SURFACE WATER AUGMENTATION
Total Required
(acre-feet)
Average Year Dry Year
Water Removed From
Currently Productive
Agricultural Land
(acre-feet of consumptive use
Avg. Year*-1) Dry
1 Without deep wells
2 650 acre-feet from
nontributary wells
3 2300 acre-feet from
nontributary wells
4 Water from Standley Lake
Wastewater to Metro
0
0
0
0
1646
936
0
0
1667
888
0
0
1520
810
0
0
(1) It is Northglenn's intention to remove the same amount of land from
agricultural production in an average year as would be necessary in a
dry year. The average year consumptive use associated with that land
is indicated above (2039.2/1859.3 x dry year consumptive use). This
excess water would be available for irrigation of Northglenn owned land.
Note: 2039.2 and 1859.3 are the respective average and dry year consumptive
use values (in acre-feet) attributable to the South Platte land which
are currently in irrigated agricultural production. Source: Wright
Water Engineers, Inc.
(2) Figures obtained by subtracting dry year consumptive use of currently out-of—
production land (126 acre-feet) from Total Required.
Agricultural Productivity under the Northglenn Plan
The individual and combined gross agricultural productivities for FRICO
and South Platte lands under each of the four options considered are presented
in Table G-6. Anticipated productivities of the irrigated FRICO lands were
computed using the farm headgate deliveries indicated in Table G-4, assumed
irrigation efficiencies of 65 percent in an average year and 70 percent in a
dry year, and an estimated production value of $342 per acre-foot of consumptive
use of irrigation water. Average application rate in the FRICO system is 1.04
acre-feet of farm headgate delivery per acre of land. Under each option, remaining
non-irrigated land in the FRICO service area (total area = 15,000 acres) was
assumed to have a dry-farming productivity of $60 per acre. The FRICO produc-
tivities in Table G-6 represent the sum of the productivities of irrigated and
non-irrigated land in the FRICO system.
South Platte productivities of irrigated land were calculated by subtracting
water required to be removed from currently productive agricultural land (Table
G-5) from total consumptive use attributable to the 1343.4 acres of currently
productive land (2039.2 acre-feet in an average year and 1859.3 acre-feet in a
dry year), and multiplying the differences by $259 per acre-foot of consumptive
use of irrigation water. Land removed from irrigated agriculture was assumed
to have a residual dry-farming productivity of $60 per acre. The South Platte
productivities in Table G-6 represent the sum of the productivities of irrigated
and non-irrigated land.
G-ll
-------
TABLE G-6
GROSS PRODUCTIVITY OF FRICO AND SOUTH PLATTE
IRRIGATED LANDS AFFECTED BY THE NORTHGLENN PROJECT
(IN MILLION DOLLARS)
FRICO1 SOUTH PLATTE2
Option Description
1 Without deep wells
2 650 acre-feet from non-
tributary wells
3 2300 acre-feet from non-
tributary wells
4 Water from Standley Lake
Wastewater to Metro
Average Year Dry Year Average Year Dry Year
1.95
1.95
1.95
1.49
1.76
1.75
1.74
1.04
0.16
0.33
0.53
0.53
0.15
0.31
0.48
0.48
TOTAL GROSS
PRODUCTIVITY
Average Year Dry Year
2.11 1.91
2.28
2.48
2.02
2.06
2.22
1.52
ho
Based on $342/acre-foot of consumptive use of irrigation water. FRICO deliveries given in Table 4;
irrigation efficiency = 65% in average year and 70% in dry year.
2 Based on $259/acre-foot of consumptive use of irrigation water.
Note: All lands which are removed from irrigated agricultural production are
assumed to have a dry-farming productivity of $60/acre.
-------
The total gross productivity for Options 1 through 4 is the sum of
the FRICO and South Platte productivities. It should be noted that additional
water is available under Options 1 through 3 for possible irrigation of
Northglenn owned lands - see footnotes, Tables G-4 and G-5.
The analysis uses an "average benefit" approach to analyzing the impacts
of the Northglenn Water Management Program on agricultural productivity in
the study area. A marginal benefit approach to productivity analysis would,
in theory, be more technically sound. Such an approach recognizes that
additional output (crop value) is not constant, but varies with the addition
of incremental units of input (acre-feet of consumptive use of water). After
careful consideration of the various theoretical and practical aspects of
making this productivity analysis, however, EPA has concluded that use of
average productivity parameters is adequate under these circumstances for
the following reasons:
(1) It would be impractical, if not impossible, to collect the amount
of data necessary to develop reliable estimates of the marginal
productivity characteristics of the FRICO and South Platte systems;
(2) Lands being taken out of production will be completely deprived
of irrigation water - consequently, there is no need to make a
marginal benefit analysis with regard to withdrawal of water from
the South Platte or FRICO lands.
(3) Under the bonus arrangement, the FRICO system is to receive some
additional water under the first three options. It is impossible
to predict whether this water would be spread over the land already
irrigated, or used to bring additional acreage under irrigation.
(4) Land in the FRICO system can be categorized as "water short".
It is reasonable to assume that it produces in a range in which the
incremental output (crop value) attributable to the addition of
successive increments of input (water) is relatively constant.
The South Platte systems, on the other hand, generally has an
adequate supply of water. It is likely that adding increments
of water to the South Platte system would result in a series of
diminishing returns. Consequently, when evaluating the economic
effect of adding water to the "water short" area, the use of an
"average benefit" approach yields a reasonable estimate of agri-
cultural benefits.
Option 4 does not include consideration of any increased productivity
along the South Platte due to the additional water that would be discharged
to the River via the Denver Metro Plant (433 acre-feet per month). This
additional water is less than three percent of the flow in the South Platte
below the Metro Plant. It is unlikely that this flow would result in any
noticeable increase in agricultural productivity in the study area, particularly
in view of the fact that the South Platte ditches under consideration generally
receive an adequate water supply. If the water was available to the South
Platte ditches of concern it could be assumed to be available for the six
months of the growing season. The maximum increased productivity along the
South Platte for this additional water, based on $259 per acre-foot of
G-13
-------
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-------
consumptive use would be $673,000 per year. Any increases in agricultural
productivity beyond the confines of the study area were neglected.
As can be seen in Table G-6, the option that contemplates maximum use
of nontributary groundwater (Option 3) results in the greatest agricultural
productivity (least impact). Option 4 which contemplates Northglenn's
acquiring its entire water supply from FRICO by purchase or condemnation
with wastewater discharged to the South Platte results in the lowest
agricultural productivity (greatest impact). Bar charts presented in
Figure G-2 illustrate the gross productivities under the four options in
both an average and dry year.
The gross productivity of the FRICO system shown in Table G-6 for Option
4 is based on the assumption that the small amount of water retained by the
FRICO farmers would continue to produce a viable irrigation project. The
assumptions regarding the ownership of stock in the FRICO system for the 4
options are shown in Table G-7.
TABLE G-7
OWNERSHIP OF STOCK IN FRICO SYSTEM
Options 1, 2 and 3 Option 4
Owner Shares(1) % of Ownership Shares % of Ownership
Westminister 438.23 18.5 438.23 18.5
Thornton 270.29 11.4 270.29 11.4
Northglenn 214.73 9.0 1,401.88 59.0
FRICO Farmers 1,449.75 61.1 262.60 11.1
2,373.00 100.0 2,373.00 100.0
(1) Projected 1980 ownership
In Option 4 it is seen that Northglenn must control 59 percent of the
shares in order to have an adequate raw water supply to meet the dry year
condition. It is further seen that the FRICO farmers would only control
11.1 percent of the shares. Should the condemnation or purchase of addi-
tional shares by Northglenn be done in such a manner so that the remaining
shares held by FRICO farmers were located in a patchwork pattern throughout
the area, it is questionable that a viable irrigation system would remain.
It is, therefore, very likely that under Option 4 the remaining shares, by
economic necessity, would be sold to cities and irrigated agriculture would
cease in the FRICO system.
CONCLUSION
EPA concludes from this analysis that under the exchange program,
positive agricultural benefits are obtained if all the augmentation water
is derived from deep wells (Option 3). If Northglenn implements an exchange
which requires augmentation water entirely from other irrigators (Option 1),
G-15
-------
there will be some loss to agriculture, but productivity will be sub-
stantially higher than if Northglenn did not execute an exchange agreement
(Option 4). EPA therefore concludes that compared to the situation wherein
ongoing litigation would have been successful, the proposed exchange, re-
gardless of the source from which Northglenn obtains augmentation water,
has significantly less economic impact on agriculture.
The long term exchange agreement with FRICO enhances the likelihood
that significant acreage of irrigated land will remain productive farm-
land during this century. In conclusion, EPA has determined that this
plan meets EPA's policy to protect environmentally significant agricultural
land, and therefore endorses this proposal.
G-16
-------
REFERENCES
1. Denver Business World, September 17, 1979.
2. EPA Agriculture Policy Memorandum from the Administrator to
Assistant Administrators and Regional Administrators,
Office Directors dated September 8, 1978.
3. United States Department of Agriculture, Soil Conservation Service.
Soil Survey of Southern Weld County, unpublished.
4. United States Department of Agriculture, Soil Conservation Service.
Soil Survey of Adams County, 1974.
5. Personal communication. Stan Boyes, Weld County Extension Service.
August 23, 1979.
6. Colorado Agricultural Statistics Bulletin, January 1978.
7. CSU Environmental Resources Center. Physical and Economic Effects
on the Local Agricultural Economy of Water Transfer to Cities
Completion Report No. 75.
G-17
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-------
\
\
APPENDIX H
REVIEW OF SLUDGE MANAGEMENT PLAN
-------
-------
APPENDIX H
REVIEW OF SLUDGE MANAGEMENT PLAN
Northglenn's proposed wastewater treatment and storage facilities
are expected to produce stabilized sludge in the form of a settled six
percent solids mixture in the bottom of the third lagoons. The physical
and chemical quality of the sludge is expected to be suitable for land
application as an agricultural nutrient. Northglenn intends to remove
the collected sludge in the fall of each year from the lagoons and apply
it to agricultural lands by plow injection at an approximate rate of
five dry tons per acre per year. Northglenn intends to apply sludge to
privately owned agricultural lands or to City-owned lands within or near
its city limits or both. The net annual cost to the City for the plan
will be approximately $5,000 per year, not including Federal grant
assistance.
SLUDGE QUANTITY
Northglenn's original estimate of the annual sludge production rate
was 895 dry tons per year in the form of 368,000 cubic feet of sludge
consisting of 5 percent solids and 95 percent water. This estimate was
later revised based upon operational data from a lagoon treatment system
in Muskegon, Michigan. The revised estimate was 600 dry tons per year
in 247,000 cubic feet of sludge with a 6 percent solids content. The
revised estimate would require that sludge be applied to 120 acres of
land each year at a 5 ton per acre application rate, while the original
estimate would require almost 180 acres.
Because of the variation in the estimated quantities of sludge, and
consequently the amount of land required; and doubts about the applic-
ability of the Muskegon operational data, EPA performed the following
independent calculation using conservative assumptions.
Q, wastewater treated = 4.64 million gallons per day
BOD^, five-day biochemical oxygen demand = 200 mg/litre
TSS, total suspended solids = 190 mg/litre
VSS, volatile suspended solids (assumed 70% of TSS) = 130 mg/litre
Y, third lagoon cell yield coefficient =0.5
The value of Y is probably high for the proposed system because Y de-
creases as mean cell residence time increases. A calculation of sludge
production based upon BOD- has the following form:
H-l
-------
Q(days/yr)(BOD5)(C)(Y)K
S = ~2,000 Ibs/ton
where:
S = weight of dry sludge in tons/yr
C = Percent conversion of BOD,, to cell matter and gases
K = metric conversion factor, 8.34
in numerical form;
C4.64)(365)(200)(0.95)(0.5)(8.34)
2,000
= 670 tons/year
An estimate of sludge production based upon suspended solids takes the
following form:
o = (TSS - VSS)(Q)(days/yr.)(K)
2,000
in numerical form;
(190-133)(4.64)(365)(8.34)
2,000
= 403 tons/year
Based on the foregoing, an estimate of 600 dry tons per year appears
reasonable given available information. These estimates should of
course be refined as new information or actual operational data become
available.
SLUDGE QUALITY
An accurate assessment of Northglenn's sludge quality cannot be
made until after the installation and operation of the treatment la-
goons. However, Northglenn wastewater is almost all domestic and
therefore the sludge generated will be similar to typical domestic
sludges. Table H-l lists the range and mean concentration of con-
stituents in municipal treatment plant sludges. The median concen-
tration values would be indicative of domestic sludges. This is further
reinforced by the results of a wastewater sludge assay of 45 Michigan
communities with light to moderate industry and populations between
2,000 and 180,000 as shown in Table H-2.
The concentrations of nutrients and heavy metals will act as con-
straints to sludge use for agriculture. The median cadmium level shown
in Table H-l and the mean level shown in Table H-2 correspond to a rea-
sonably conservative estimate of the expected cadmium levels in North-
glenn' s sludge. Actual levels would be expected to be consideraly lower
given the city's complete lack of industry and limited commercial land
use.
H-2
-------
TABLE H-l
RANGE OF CONCENTRATION OF SLUDGE CHARACTERISTICS FOR
Total N (%)
Total P (%)
Total K (%)
Fe yg/g
Cu yg/g
Pb yg/g
Al yg/g
Cr yg/g
Cd yg/g
Mn yg/g
Ni yg/g
Zn yg/g
NATIONAL
Sample
Number
38
38
37
38
58
57
37
53
57
38
46
SAMPLE
0.5
1.1
0.08
0.1
85
13
0.1
10
5
55
2
108
OF TREATMENT
Range
7.6
5.5
1.10
4.0
- 2,900
- 15,000
2.3
- 13,600
- 2,170
- 1,120
- 1,700
- 14,000
PLANTS
Median
4.8
2.7
0.38
1.0
970
300
0.4
260
16
340
31
1,800
Mean
4.9
2.9
0.46
1.1
940
720
0.7
1,270
135
420
150
2,170
Source: Journal of Environmental Quality, Vol. 6, No. 2, 1977
TABLE H-2
WASTEWATER SLUDGE ASSAY FOR FORTY-FIVE
MICHIGAN COMMUNITIES
Parameter
yg/g of
Dry Sludge
Hg
Cr
Co
Ni
Fe
Zn
Cd
Pb
As
Sample
Number
45
45
45
45
45
45
45
45
45
0.1
22
140
12
1,280
72
2
80
1.6
Range
56
- 30,000
- 10,400
2,400
- 144,000
- 11,000
260
- 26,000
18
Mean
5.1
1,575
1,026
221
23,420
2,538
18
1,468
7.4
Source: Blakeslee, Paul A., Michigan Department of Natural Resources,
1973
H-3
-------
The values presented are all within reasonable ranges for domestic
sludge. EPA believes that levels for Northglenn sludge will be less
than the mean values presented. However, sludge characterization stud-
ies should be conducted on sludge produced at Northglenn1s wastewater
treatment plant so that proposed sludge application rates can be appro-
priately revised.
REGULATORY ASPECTS OF SLUDGE DISPOSAL
The Northglenn facilities plan identified sludge application to
agricultural land as the desirable ultimate disposal option. EPA has
issued regulations concerning the land application of wastewater sludge
(40 CFR, Part 257, September 13, 1979) which have a direct bearing on
the Northglenn project. These regulations cover allowable cadmium lev-
els and polychlorinated biphenyls (PCBs) levels in sludge, and pathogen
control methods prior to land application.
Specifically, the regulations limit the annual loadings after 1987 of
cadmium from sludge to less than 0.5 kilograms per hectare on land which
may be used to grow crops for human consumption. In addition the pH of
the soil-sludge mixture must be 6.5 or greater at the time of each sludge
application. If the cadmium level in the sludge is less than 2 yg/kg (dry
weight) these restrictions do not apply. The cumulative application of
cadmium from sludge must not exceed certain levels based upon the soil's
pH and cation exchange capacity (CEC) as shown in Table H-3.
The expected cadmium content of Northglenn's sludge can be esti-
mated from Tables H-l and H-2. If an average cadmium concentration of
18 yg/g is conservatively assumed, a corresponding maximum annual appli-
cation rate of 12.4 tons/acre results. This application rate would re-
sult in the average annual nitrogen requirements of a typical grain crop
(175 Ibs/acre/year) to be exceeded, and would therefore not limit the
sludge application rate.
TABLE H-3
MAXIMUM CADMIUM APPLICATION
Maximum Cumulative Cadmium Application (kg/ha)
Soil Cation Background Soil pH Background Soil pH
Exchange Capacity Less than 6.5 More than 6.5
Less than 5
5-15
More than 15
5
5
5
5
10
15
Based upon nitrogen requirements, an annual application rate of
five tons/acre/year would be reasonable. At this application rate EPA
calculates that it would take 25 years to reach EPA's cumulative cadmium
H-4
-------
limit assuming worst case soil conditions (low pH and CEC) rather than
28 as calculated by Northglenn. Given typical soil conditions in Adams
and Weld Counties (pH more than 6.5 and CECs between 5 and 15) EPA cal-
culates that the cumulative limits would take 50 years to reach. EPA
concludes that cadmium limitations with respect to agricultural land
application of sludge will not be a problem in Northglenn's case within
the 20-year planning period. Northglenn indicates that it is unlikely
the same agricultural land will be used for sludge application for more
than 15 to 20 years in any case.
EPA's regulations require that any sludge which is land applied
must first be treated by a recognized Process to Significantly Reduce
Pathogens (PSRP). The EPA's Municipal Environmental Research Laboratory
(MERL) in Cincinnati recognizes the value of long-term lagoon retention
of sludge as an acceptable PSRP, and has recommended to the Office of
Solid Waste that lagoon retention of sludge for a period of eight weeks
at temperatures around 20C would be acceptable, providing no new sludge
or fresh wastewater is allowed to come in contact with the lagooned
sludge during that eight-week period. With regard to long-term lagoon-
ing of sludge where contact with fresh wastewater or sludge is not re-
stricted, it is the opinion of MERL that a significant reducton of
pathogens may or may not be achieved depending on individual facilities
circumstances. In the case of Northglenn's lagoon design, with sludge
settling after five to fourteen days of suspension and aeration, the
expressed opinion of MERL was that the system would probably achieve a
significant reduction of pathogens without separate storage. Actual
reductions achieved would be determined by monitoring the facilities.
EPA recognizes that regulations pertaining to a recognized Process
to Significantly Reduce Pathogens are not currently clear as to accept-
able processes for given treatment system. Northglenn has indicated
that when final regulations are implemented compliance will be achieved.
If the eight weeks retention process is acceptable and Northglenn
cannot achieve significant pathogen reduction, Northglenn proposes to
alternately bypass each third cell for periods of up to eight weeks in
order to achieve isolation of the retained sludge from fresh wastewater
and sludge deposition. At the end of each eight-week period, the lagoon
would be dredged and flow through the lagoon would be restored. During
each bypass period, increased aeration would be provided in the remain-
ing third cell to compensate for the lack of retention time. In addi-
tion, potable, submersible fixed film media surfaces, such as redwood
racks, would be lowered into the third cell still in use to provide for
increased nitrification rates through the increased concentration of
nitrifying bacteria on the fixed surfaces.
EPA questions this operations strategy because the increased
aeration of the third cell reduces settling and increases suspended
solids carryover to the reservoir. Northglenn must provide further
explanation of the impacts on treatment, the reservoir and effluent for
this type of operation before EPA approval.
H-5
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SLUDGE MANAGEMENT ALTERNATIVES
Northglenn's facilities plan identified land application of sludge
to agricultural land as the preferred alternative. In the event that
this alternative x-rere to prove infeasible, an available contingency
alternative would be to haul Northglenn's sludge to the proposed Denver
Metro sludge disposal facility^ which is large enough to accommodate
Northglenn's wastewater sludge volumes. Landfilling of sludge will not
be a possibility as there are no landfills in Adams County which will
accept wastewater sludge; all wastewater sludge produced in the County,
including septic tank pumpings, is currently disposed of by the Denver
Metro Lowry facility.
Northglenn's proposed sludge management alternative consists of
sludge collection and stabilization in the treatment lagoons followed by
land application. Sludge will settle in the third cells of the lagoons
where it will be stored until removal. In the bottom of the third cells
the settled solids will undergo continuous aerobic oxidation followed by
anaerobic digestion as each layer of solids is gradually covered by
succeeding layers. Sludge will be removed from the lagoons annually.
Northglenn initially proposed to use a floating hydraulic dredge for
sludge removal. However, recent discussions with Sheaffer and Roland
indicate that this system will not be used in all probability. No
system has been identified to replace the dredge system. Sludge removal
is to occur over a two-month period in the fall of each year followed
immediately with land application. Northglenn states that in case of
adverse weather, spring application is possible.
Removed sludge will be pumped to a storage tank prior to transfer
to tank trucks. The storage tank is necessary to allow continuous
removal, thereby minimizing disturbances to the sludge blanket from
surges due to multiple pump shutdowns and startups. Approximately
30,000 gallons of storage will hold a single day's application volume.
Additional sludge thickening may occur in the storage tank and it is
possible to drain supernatant back to the aerated lagoons. EPA believes
that the amount of settling in the tank will be insignificant and any
design consideration in terms of tank's size or characteristics of the
sludge should not take this into account.
Northglenn proposes to use twin transport-applicator trucks with
5,000 gallon capacities to transport sludge from storage and to the
proposed application sites. A rear-mounted plow, disk, harrow, or
serrated coulter on the truck opens the surface of the field and sludge
is injected immediately behind the opening device to depths between 4
and 14 inches depending on the machine used. The transport-injector
trucks would be able to apply all sludge generated at the facility by
making three hauls per day, 20 or 30 days a month for three months.
This is a relatively new system which is used in several places in
the United States. The system has several potential problems including:
1. Injection is not feasible when the ground is frozen deeply and
adequate soil coverage of the sludge is not achieved. There-
fore, alternative disposal or storage methods may be required
H-6
-------
during the winter if sludge is removed from the third cells in
winter.
2. Depth of injection and timing of applications are critical for
repeated use of the site. Both of these affect the ability of
the liquid sludge to dry out and be incorporated into the soil.
Continuous application may not be feasible or possible.
3. Potential exists for salt build-up in the soil, coliform
accumulation in soil, and sporadically high nitrate leaching
when crops are not planted.
4. Loading rates, speeds, and depth of sludge injection need to be
adjusted for site conditions (e.g., soil type, infiltration
rates) as well as for sludge characteristics (e.g., percent
solids).
5. Application in bands may lead to localized concentrations of
less mobile metals.
These considerations should be addressed in the sludge management
plan.
Northglenn's sludge will be injected on active farmland used to
raise crops, such as corn and hay, for animal consumption. Injection
places sludge in the root zone where it is most beneficial to plants and
accessible to microorganisms. Immediate injection eliminates the need
for a second machine to follow a spreader to turn sludge under. In-
jection also eliminates odors, prevents surface runoff and places sludge
where it will not be in contact with plants or animals, minimizing
health-related concerns. The tilling action of the injection is a bene-
fit to the farmer, reducing his cost and labor. Actual farming opera-
tions will be contracted for by the City.
Proposed Sludge Application Sites
While Northglenn has not provided any letters of intent that
farmers will be willing to farm with Northglenn sludge, this would not
be a difficulty because Northglenn can use City-owned land if farmers
are not willing to participate.
The City of Northglenn currently plans to contract with agricul-
tural landowners in Adams County immediately south of the treatment
lagoon and reservoir site to receive stabilized sludge for land appli-
cation. There exists over 1,000 acres of suitable agricultural lands in
Adams County within two miles of the lagoons.
If contractual arrangements with agricultural landowners prove
difficult, the City has another option available. The City owns four
parcels of vacant or agricultural land within or near the City limits.
These include the lower Clear Creek Ditch agricultural parcel acquired
by the City for water rights, and the Northwest Open Space parcel, the
Stonehocker Park parcel, and the vacant parcel southeast of Stonehocker
Park, all within the City limits. The total acreage of these four
H-7
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parcels is approximately 290 acres. The current land use in the three
parcels within the City is primarily vacant while the Clear Creek Ditch
parcel is currently in agriculture.
The future land uses of the three parcels within City limits in-
clude recreational and open space uses. However, none of these parcels
is scheduled for immediate recreational development. They will there-
fore be available for agricultural use with sludge applications for the
first few years of the project's operation. This will provide the City
with ample lead time to contract for the use of additional agricultural
lands. Northglenn does not specify who will farm the lands owned by
them.
Sludge Utilization Program
Sludge will be used in place of chemical fertilizers to supply
nutrients to corn and grass crops. The nitrogen, phosphorus, and
potassium available in sewage sludge can be estimated from average
values for nutrients found in domestic sludge (Table H-l).
The balance of nitrogen, phosphorus, and potassium is scientific-
ally developoed for commercial fertilizers and to assume the ratios of
the elements in sludge approximates this balance based on national
averages is not valid. It may be necessary to add phosphorus and/or
potassium supplements to achieve the desired ratios.
Application Areas
The beneficial and safe use of sludge depends upon proper selection of
an application site. Land use, slope, soil characteristics, and proximity
to a stream must be considered in site selection. While the specific
sludge application sites to be used by Northglenn are subject to future
negotiations with nearby landowners, the suitability of the City's cur-
rently owned agricultural and vacant lands in Adams County can be evalu-
ated .
Northglenn has considered the basic soil properties of their owned
lands. Criteria considered include slope, surface texture, and depth to
seasonal high water table.
Slopes are in a range to allow conventional runoff and erosion con-
trol, and equipment operation. Soil texture is rated for adequate
nutrient retention and minimal equipment operational problems. The
depth to seasonal high water will be greater than the depth of sludge
application so pollutants are not solubilized. Additionally, Northglenn
should evaluated these soils for the following:
1. infiltration/percolation factors, particularly as related to
down-slope groundwater and surface water
2. pollutant solubility, specifically metals and nutrients, and
pathogens transport and survivability
3. cation exchange capacity of soil
H-8
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Northglenn has assigned rating factors for ranges of soil slope,
texture, and depth to seasonal high water table. These ratings are
presented in Table H-4. This rating of Northglenn-owned land indicates
that approximately 115 acres of suitable, 36 acres of moderately suit-
able, and 44 acres of unsuitable soils are found in the cleared crop
areas. Moderately suitable means extra field investigation of soil
conditions is necessary and management such as runoff, erosion or
groundwater control may be required. Reduced application rates may be
used instead of control measures. EPA must require that anywhere there
is a potential for a seasonal high water table, sludge should never be
applied*
Evaluation of topographic features of Northglenn-owned land (based
on USGS topographic maps) Northglenn concludes that no problems are
expected with erosion of sludge-amended soil into surface waters.
Application Rate
Generally, annual sludge application rates should be limited by the
quantity of nitrogen that can be beneficially utilized by the crops.
Nitrogen, in most cases, is the nutrient in sludge available in the
highest concentration. Thus, limiting the application rates on the
basis of nitrogen will automatically safeguard against salt build-up in
soil and accumulation of other nutrients. EPA's analyses indicate that
Northglenn1s proposed application rate of 5 tons/acre/year is accept-
able .
\
Application Method, Timing, and Crop Management
Sludge will be used to fertilize fields of suitable crops and suit-
able soils. These fields will remain in corn or hay rotation for the
duration of the project or until other agricultural application sites
are provided by the City.
Sludge will be hauled and injected in September, October, and
November. If severe weather prevents fall application, spring appli-
cation in May or early June is possible. Crops grown with sludge will
be used for silage or grain or both.
The State of Colorado Department of Health has issued Giudelines
for Sludge Utilization on Land which addresses issues of sludge sta-
bility, sludge quality nutrients and trace elements application, methods
of sludge application, soils and site considerations, sludge storage,
and monitoring and permit requirements. Northglenn sludge management
plan will require certification by the Colorado Department of Health.
Certification will be predicated on compliance with all guidelines.
Northglenn's sludge management plan review presents costs for the
major capital components including a floating hydraulic dredge, sludge
handling tank, and two 5,000 gallon sludge applicator trucks. Capital
and operation and maintenance costs are also included. These costs
appear to be very low despite the fact that Northglenn plans to rent
some of their equipment to other communities. Other costs should be
included such as for the equipment expected to be used for sludge
i
H-9
-------
TABLE H-4
RATING FACTORS OF SOIL PHASE PROPERTIES
FOR SLUDGE APPLICATION
Soil
Property
Rating^
Factor2
Basis of Rating
0-3% S
3-8% S
8-15% M
15-25% U
Texture
Sandy M(S)|
Sandy Loam M(S)
Loamy Sand M(S)
Fine Sandy Loam S
Very Stony Fine
Sandy Loam
Extremely Stony U
Fine Sandy
Loam
Silt Loam S
Muck U
Depth to Water Tablec
Very Shallow U
Shallow M
Moderately S
Shallow
Deep S
Runoff
Runoff, Erosion
Runoff, Erosion
High Runoff, Erosion, Equipment Operation
Pollutant Retention
Pollutant Retention
Pollutant Retention
Pollutant Retention
Damage to Injector
Damage to Injector, Pollutant Retention
Pollutant Retention
Application not Possible
Pollutant Retention, Solubilization
Pollutant Retention, Solubilization
Pollutant Retention
a. S - Suitable, M - Moderately Suitable, U - Unsuitable
b. Increased rating if spodic horizon
c. Water table depth can be altered
H-10
-------
removal and the sludge holding tank as well as elements discussed in the
report such as soil scientists, engineers, and agricultural staff.
MITIGATION MEASURES
The current Northglenn sludge management plan is in substantial
compliance with most recent state and Federal guidelines. However, it
does not address mitigation measures in the detail deemed necessary by
EPA. Therefore, Northglenn will limit sludge application rates as spe-
cified until and unless data from the Northglenn treatment facility
indicates adjustments may safely be made. In addition, Northglenn will
provide a Sludge Management Plan, with annual updates, to the State of
Colorado Department of Health minimally specifying:
1. Sludge characteristics
2. Groundwater protection
3. Crop types and farming practices for lands receiving sludge
4. Soils monitoring
H-ll
-------
-------
APPENDIX I
EVALUATION OF EFFICIENT USE AND CONTROL PLANS
-------
-------
APPENDIX I
EVALUATION OF EFFLUENT USE AND CONTROL PLANS
-------
-------
APPENDIX I
EVALUATION OF EFFLUENT USE AND CONTROL PLANS
The draft EIS presented several mitigating measures for minimizing
the potential public health impacts of Northglenn's proposal. These
mitigating measures required Northglenn to formulate certain plans and
procedures to insure that tailwater would not drain into areas of urban
development of the towns of Frederick and Firestone; that an environ-
mental monitoring plan be developed whereby data will be collected to
provide a basis for evaluating the possible contaminations of ground-
water soils and crops; and that the non-potable municipal irrigation
water system of the town of Dacono be replaced or provision made to
properly disinfect water withdrawn from the Bull Canal.
TAILWATER CONTROL PLAN
Tailwater is excess irrigation water that has been applied to a
field and has not infiltrated into the soil. This water flows down
grade until it reaches a natural storage depression or is collected for
reuse or erosion control. Tailwater from lands irrigated by Bull Canal
waters may drain into the developed portions of the towns of Dacono,
Frederick, and Firestone. A field survey and review of 1977 aerial
photography indicate that drainage from approximately 880 acres may
affect these communities. For the Northglenn project, the irrigation
tailwater is to be collected and reused as irrigation water to mitigate
potential health problems which might arise from human contact with
treated wastewater. Approximately 810 of the 880 acres of potential
irrigation area are within the town limits of Frederick or Firestone and
may undergo urbanization. If so, the tailwater flow from these areas
would cease.
The proposed tailwater control plan consists of collecting excess
irrigation water by ditches at the lower end of fields and delivery to a
tailwater storage pond. The water is to be pumped from the storage pond
back to the fields for reapplication. The proposed collection ditches
and storage ponds are shown in Figure 1-1.
The amount of tailwater generated and collected depends on the
irrigation method used on the field. It should not be more than 20
percent of the irrigation water applied to the field. A higher amount
of tailwater may indicate erosive streams in the field, lost fertilizer,
and usually results in higher pumping costs for the return system (1).
With the exception of the southeast quarter of Section 30 and the west
half of Section 32, the water and soil conservation practices of the
landowners appear to be excellent and the tailwater flows from these
lands appear to be minimal (2). The proposed plan is for improved man-
agement in the area through cooperation with the local office of the
Soil Conservation Service (SCS).
The tailwater storage ponds are designed in accordance with stand-
ard practices used in Colorado by the SCS. Approximately three acre
feet of tailwater pond capacity is provided for every 160 acres of
1-1
-------
Figure 1-1
TAILWATER CONTROL PLAN
0 1,000 2,000 3,000 4,000 9,000 Ft.
J
Drainage Basin Boundary
Bull Canal
Potential Irrigation Areas
— Town Limits •+
O Tai(water Detention Pond
Tailwater Collection Ditch
Aluminum Irrigation Pipe
1-2
-------
irrigated area. Automatic pump controls are to be installed and, with
the associated design pump capacity, the pond volume is conservative for
tailwater flows. The system was not, however, designed for storm water
runoff events and the potential exists for the system to be surcharged
beyond the design capacity. Proper management can minimize such occur-
rences by discontinuing irrigation well before a predicted storm occurs.
Such management will require close coordination with the landowner,
FRICO, and Northglenn.
The effect of urbanization on the tailwater management plan has not
been addressed by Northglenn. As the agricultural land is developed,
changes in irrigation practices may be necessary as well as other modi-
fications in the tailwater management plan. The tailwater plan raises
legal questions of successive reuse of irrigation water. These ques-
tions will be resolved in the Water Court and were not considered in
this mitigation plan.
REVIEW OF PRELIMINARY FIELD MONITORING PROGRAM
The City of Northglenn has submitted a preliminary field monitoring
program for the wastewater irrigation aspects of the Northglenn Water
Resources Management Plan. The field monitoring program will involve
monitoring groundwater, irrigation tailwater, Bull Canal flows, and
plant tissue from irrigated crops. Presented in Table 1-1 are the
parameters to be measured and frequency of monitoring from each source.
Groundwater Monitoring
Approximately fifty wells will be monitored on a quarterly basis
for the constituents presented in Table 1-1. The fifty wells will be
distributed throughout the irrigated area at a density of approximately
one well per quarter section of land. Additional wells located along
the fringes of irrigated areas will monitor groundwater flows leaving
the irrigated areas. The location of existing wells available to be
monitored are illustrated in Figure 1-2. The wells will be monitored
prior to irrigation with treated effluent to determine baseline condi-
tions.
The proposed monitoring program appears adequate to detect any
significant changes in groundwater quality caused by irrigation with
treated effluent. The frequency will allow early detection and miti-
gation of any observed groundwater quality degradation. It would be
beneficial to monitor deep wells (tapping lower aquifers) to ensure that
wastewater is not seeping to the lower aquifers. The likelihood of this
occurring is small.
Bull Canal Overflows and Irrigation Tailwater
The irrigation tailwater will be monitored monthly during the
irrigation season for the parameters shown in Table 1-1. In addition,
the excess irrigation water collected at the terminal reservoir will be
monitored periodically. (See Figure 1-2) The frequency of monitoring
this reservoir is currently not established. It is recommended that the
terminal reservoir be monitored monthly during the irrigation season.
1-3
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TABLE 1-1
SUMMARY OF THE FIELD MONITORING PROGRAM
Constituent Measured
Biochemical Oxygen Demand
Chemical Oxygen Demand
Suspended Solids
Nitrogen (Total)
Nitrogen
Phosphorus (Total)
Coliform (Total)
Coliform (Fecal)
PH
Total Dissolved Solids
Alkalinity
Barium
Cadmium
Cobalt
Copper
Iron
Manganese
Mercury
Nickel
Lead
Zinc
Boron
Molybdenum
Groundwater
Q
Q
Q
Q
Q
Q
Q
Q
Q
Q
Q
Frequency of Sampling
Irrigation Tailwater
M
M
M
M
M
M
M
M
M
M
M
Crops
A
A
A
A
A
A
A
A
A
A
A
A
A
A
Q = quarterly
M = monthly
A = annually
1-4
-------
R.68W.
Figure 1-2
R.66W.
WELD COUNTY A
R.66W.
Irrigation Area
A Existing Permitted Wells In The
Vicinity Of The Irrigation Area
-------
Crop Monitoring
The proposed crop monitoring program will monitor crop tissues
annually for the metals listed in Table 1-1. Baseline data will be
collected during the summer of 1980 on crops presently grown by FRICO
shareholders.
It is the opinion of EPA that soils as well as crop tissues should
be monitored for long-term metals accumulation. The reasons for this
are:
1. Different parts of a plant accumulate metals at different
rates; in addition, other physiological factors within the
plant may affect the amount of uptake of a particular metal by
a particular plant.
2. Different plant species react differently to various metals. A
level that may be toxic to one plant may not affect a different
species. Therefore data on the metals composition of one type
of plant may not be indicative of the value in another plant
grown in the same soil.
3. Other physical or chemical factors within the soil, such as pH
or organic matter content, will affect the degree of metal up-
take by a particular plant species. Changes over time in one
of these factors would cause a greater or lesser metal concen-
traton in the plant for the same soil metal concentration.
4. For these reasons, soils in the area should also be monitored
for the metals listed in Table 1-1. Crops should be monitored
to see if there is a correlation between the crop metal content
and the soil metal content. In addition, some similar soils
outside but near the wastewater irrigated soils should be moni-
tored to determine if any change in soil characteristics is
caused by factors other than irrigation with wastewater. A
baseline study should be conducted to determine the existing
soil characteristics and the number of samples needed to
adequately monitor the soils.
Although initial monitoring should be on an annual basis, the fre-
quency could be decreased to once very three or four years if no appre-
ciable increase is noticed in the first three to five years of irriga-
tion.
DACONO IRRIGATION SYSTEM
The Town of Dacono has a nonpotable water system which draws water
from the Bull Canal and is provided without treatment, for irrigation in
certain parts of the town. The degraded quality of the water in the Bull
Canal will create an unnecessary health risk within Dacono. Northglenn
1-6
-------
will resolve this problem either by substituting an alternative water
source for Dacono's use in place of the Bull Canal water currently used,
or installing and operating a disinfection system on the water Dacono
receives from the Bull Canal. If disinfection is chosen, the system
will be designed to achieve a level of; disinfection acceptable to EPA
which shall include a residual chlorine level of not less than 0.3 mg/1.
Northglenn's review of the needs and conditions of the Dacono
irrigation system has resulted in the development of plans for a chlorine
disinfection system. The cost of this system is approximately $32,500.
Alternatively at Northglenn's expense, a replacement for this system
could be provided. Northglenn shall consult with the Town of Dacono to
obtain their concurrence with these plans.
1-7
-------
-------
-\
APPENDIX J
COST ANALYSIS AND GRANT FUNDING
-------
-------
APPENDIX J
COST ANALYSIS AND GRANT FUNDING
-------
-------
APPENDIX J
ANALYSIS OF COSTS AND GRANT FUNDING
INTRODUCTION
This appendix presents the costs for the various water supply and
wastewater treatment alternatives and options, compares their costs and,
lastly, determines the EPA grant eligibility and funding amount for the
Northglenn proposal.
WATER SUPPLY ALTERNATIVES
The water resource development alternatives which are evaluated in
the Northglenn EIS include three water supply source alternatives and
two wastewater treatment alternatives. Depending upon which water sup-
ply and wastewater treatment alternatives are combined, there are two to
five subalternatives which have been evaluated. The alternative water
supply alternatives which are evaluated, and associated wastewater
treatment options are:
FRICO Water Supply
Three options of exchange agreements available. Northglenn
treats wastewater and returns effluent to FRICO.
Purchase of Water Rights. Metro Denver treats wastewater,
South Platte discharge.
Windy Gap Water Supply
Northglenn Wastewater Treatment
Metro Denver Wastewater Treatment
Denver Water Board Water Supply
Denver Water Board Raw Water Contract
Northglenn Wastewater Treatment
Metro Denver Wastewater Treatment
Denver Water Board Full Service Contract
Northglenn Wastewater Treatment
Metro Denver Wastewater Treatment
FRICO Water Supply
This alternative involves obtaining the projected water require-
ments from the Farmer Reservoir and Irrigation Company (FRICO). There
are two possibilities for obtaining FRICO water: enter into an exchange
agreement with FRICO, or to purchase water rights from FRICO through
condemnation suits.
J-l
-------
Exchange Agreement
This option is the proposed Northglenn Land and Water Resources
Program. This option requires water supply treatment facilities, re-
placement water facilities and wastewater treatment facilities. Under
this option three possible water supply exchange configurations are
identified. Presented in Table J-l is the water budget for each of the
exchange options. These options were described in detail in the draft
environmental impact statement.
Water Right Purchases
Northglenn would acquire all water rights needed for its present
and future demands by purchase or condemnations from the FRICO Standley
Lake Division. For this option the water supply facilities and distri-
bution system requirements would be the same as the facilities used
under any of the exchange agreements. Water exchange and associated
replacement water are not involved in this option. Under this option
wastewater treatment would be handled by Denver Metro. This option is
presented as Option 4 in Table J-l.
Windy Gap Water Supply
This alternative involves obtaining transmountian diversion water
from the Windy Gap Subdistrict of the Northern Colorado Water Conser-
vancy District. The required unit of water to serve Northglenn's ulti-
mate water needs would have to be purchased from participants in the
Windy Gap Project. Delivery of the Windy Gap water would most likely be
delivered and stored at Boulder Reservoir and pumped through a new pipe-
line to Northglenn.
Water treatment and distribution would be the same as the proposed
system, and no replacement water would be required.
Wastewater could be treated at either Metro Denver or a Northglenn
Wastewater Treatment Plant.
Denver Water Board Water Supply
The Denver Water Board would provide water to Northglenn under a
long term contract agreement. Northglenn could contract for either raw
water or treated water service.
Raw Water Supply Contract
For this option, raw water would be delivered by the Denver Water
Board to Northglenn. Water treatment and distribution would be the same
as under the proposed project. No replacement water facilities are
required. Treatment of wastewater could be by either Metro Denver or
Northglenn, under their proposed wastewater treatment project.
J-2
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TABLE J-l
NORTHGLENN'S
WATER BUDGET
1988 Conditions
(All values in Acre-feet)
CONDITION
Option 1
Without
Deeo Wells
Treated Water Requirements
Household and Commercial
Irrigation (lawns and parks)
Total Water Required
Raw Water Sources
Farmers Highline
Standley Lake Shares
Church Ditch
Berthoud Pass Ditch
Arapahoe Well No. 7
Proposed Deep Wells
FRICO Owned Water
Total Water Supplies
FRICO Exchange
Net Amount Rec'd from FRICO
10% Bonus (500 AF min)
Reservoir Evaporation
Total Payback Requirement
Replacement/Wastewater Return
Sewage - Northglenn
Sewage - Thornton Enclave^
Sewer Line Infiltration
Storm Runoff-Grange Hall Crk
Tributary well Field
Total Water Available
Excess Physical Supply
(Total Available - Payback
Requirement)
Diversions to be Augmented
Grange Hall Creek
Tributary Well Field
Total Augmentation Require-
ments
Augmentation Rights Available
Excess Water Rights to Meet
Flow Requirements
Dry
4140
3200
7340
69
1074
135
120
5
0
5937
7340
5937
594
316
6847
4016
885
300
1200
446
6847
0
1200
446
1646
1985
339
Avg
4140
2700
6840
137
1504
389
608
5
0
4197
6840
4197
500
236
4933
4016
885
300
0
0
5201
268
0
0
0
2136
2136
Option 2
650 af
Deep Wells
Dry
4140
3200
7340
69
1074
135
120
5
645
5292
7340
5292
529
316
6137
4016
885
300
936
0
6137
0
936
0
936
1985
1049
Avg
4140
2700
6840
137
1504
389
608
5
645
3552
6840
3552
500
236
4288
4016
885
300
0
0
5201
913
0
0
0
2136
2136
Option 3
2300 af
Deep Wells
Dry
4140
3200
7340
69
1074
135
120
5
2295
3642
7340
3642
500
316
4458
4016
885
300
0
0
5201
743
0
0
0
1985
1985
Avg
4140
2700
6840
137
1504
389
608
5
2295
1902
6840
1902
500
236
2638
4016
885
300
0
0
5201
2563
0
0
0
2136
2136
Option 4
Return to
Metro
Dry Avg
4140 4140
3200 2700
7340 6840
69 137
1074 1504
135 389
120 608
5 5
0 0
5937(3) 4197(3)
7340 6840
0 0
0 0
0 0
0 0
4016 4016
885 885
300 300
0 0
0 0
5201 5201
To Metro Sewer
for Treatment and
release to South
Platte River
To Metro Sewer
for treatment and
release to South
Platte River
(1) An enclave of Thornton will be connected to the Northglenn system.
(2) Excess water available In the system without augmenting which can be used for
irrigation of Northglenn owned FRICO land.
(3) Water obtained from FRICO by purchase or condemnation of additional shares.
J-3
-------
Full Contract Services
Under this option, total water service, including maintenance and
billing, would be provided by the Denver Water Board. The only capital
improvement required for water service would be to Northglenn's distri-
bution system. Replacement water would not be required; therefore,
wastewater treatment could be by either Metro Denver or Northglenn.
Major components for the various water supply alternatives are
presented in Table J-2.
Development of Costs
This evaluation and comparison of water resource/wastewater treat-
ment options considers capital costs, operations and maintenance costs,
and salvage value. Utilizing these costs, present worth and annual
household costs were calculated.
Costs for each of the alternatives were prepared following EPA
guidelines. The basic assumptions followed for cost forumulation are:
0 Construction costs are based on July 1979 prices.
Operation and maintenance costs are based on January 1, 1980
prices.
Operation and maintenance costs are based on projected mid period
flow rates (1990)
0 Present worth calculations are based on a 20-year period and a 6
7/8 percentage rate of interest.
0 All systems are sized to serve the ultimate population of the
service area (42,500 people).
0 All operation and maintenance costs are based on projected 1990
flow rates.
0 The present worth and equivalent annual costs are reduced by the
salvage value of various system components in the year 2000.
0 Calculations of salvage values follow EPA cost effectiveness
guidelines.
An average household cost is based on average year water demands.
Capital Costs
Capital costs are for all major components of each alternative.
Major component costs were determined using recent bid prices for
related jobs, Dodge and Means construction cost manuals, and consul-
tation with the appropriate engineers and vendors.
J-4
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TABLE J-2
FEATURES OF WATER SUPPLY/WASTEWATER TREATMENT OPTIONS
DENVER WATER BOARD WATER SUPPLY
FRICO WATER SUPPLY
FRICO
Agricultural
Reuse
Metro
Denver
Single Purpose
WINDY GAP WATER SUPPLY
Northgjenn
Wastewater
Treatment
Metro Denver
Wastewater
Treatment
Raw Water Contract
Northglenn
Wastewater
Treatment
Metro Denver
Wastewater
Treatment
Full Service Contract
Northglenn
Wastewater
Treatment
Metro Denver
Wastewater
Treatment
C-,
Yes Yes
Yes Yes
Northglenn Northglenn
Water Supply
Raw Water Source Clear Creek Clear Creek
Raw Water Storage Standley Standley
Raw Water Delivery Gravity Gravity
Treatment Plant Northglenn Northglenn
Distribution System
Mew Improvements
Thornton Pipes Purchase
Billing & Maintenance
Replacement Water
System Required Yes No
Wastewater Collection
Thornton Pipes Purchase Yes Yes
In-City Improvements Yes Yes
Interceptor System Northglenn Regional
Wastewater Treatment
Site Bull Canal
Method Lagoons
Storage 4000 AF
Stormwater Management
System Included Yes No
Transmountain
Boulder Res.
Pumped
Northglenn
Yes
Yes
Northglenn
No
Yes
Yes
Northglenn
Central Plant Bull CanaJ
Conventional Lagoons
0 3300 AF
No
Transmountain
Boulder Res.
Pumped
Northglenn
Yes
Yes
Northglenn
No
Yes
Yes
Regional
Centra] Plant
Conventional
0
No
Transmountain
DUB
Gravity
Northglenn
Yes
Yes
Northglenn
No
Yes
Yes
Norttiglenn
Bull Canal
Lagoons
3300 AF
No
Transmountain
DWB
Gravity
Northglenn
Yes
Yes
Northglenn
No
Yes
Yes
Regional
Transmountain
DWB
Pumped
DWB
Yes
Yes
DWB
No
Yes
Yes
Northglenn
Central Plant Bull Canal
Conventional Lagoons
0 3300 AF
No
No
Transmountain
DWB
Pumped
DWB
Yes
Yes
DWB
No
Yes
Yes
Regional
Central Plant
Conventional
0
No
-------
The major components of water treatment, operational storage, and
distribution services were sized for a dry year water requirement of
7,340 AF per year. These component costs are assumed to remain constant
and independent of any alternative. Cost variation will occur from
different raw water source developments.
Operations and Maintenance Costs
Operations and maintenance (O&M) requirements result in an annual
cost for the personnel, equipment, supplies and utilities needed to
maintain the annual O&M of both water supply and wastewater treatment
facilities. Costs have been calculated for the mid-period of operation,
1990. These annual O&M costs are considered to be the average O&M costs
throughout the analysis period. From these costs present worth values
are calculated by taking this expense as an annual expense for the
entire analysis period.
Operations and maintenance costs are formulated by using past bill-
ing records when available, O&M cost curves, or by using a percentage of
the overall capital costs for the facility.
Salvage Values
To compute localized costs for a comparison of the alternatives,
EPA guidelines require salvage values to be calculated for all system
components. Salvage values are calculated at the end of the 20-year
planning period using 6 7/8 percentage interest rate and straightline
depreciation during the service life of the facility. Service lives for
facilities are as follows: Land is permanent and is inflated 3 percent
per year; structures, 30 to 50 years; process equipment, 15 to 30 years;
and auxiliary equipment, 10 to 15 years.
Present Worth Values
Present worth values are calculated by using capital costs, opera-
tions and maintenance, and salvage values. Capital cost present worth
is the calculated capital cost figure. Operations and maintenance pres-
ent worth is the present value of the annual O&M costs, taken as if the
calculated O&M costs for 1990 flows were the average annual expenditure
for the planning period. Salvage value present worth is the present
worth of the salvage values that are calculated for the end of the plan-
ning period. Project present worth values are capital costs plus opera-
tions and maintenance present worths minus salvage value present worths.
Annual Average Household Cost
Annual average household costs are calculated from the annual costs
and the projected average household water/wastewater consumption and
discharge. Annual cost for each alternative project is the present
worth values extended over the planning period, expressed as an annual
expenditure. Water consumption costs are calculated based on the annual
expenditures and an average year water demand of 6,840 acre feet.
Wastewater discharge costs are developed using Northglenn's projected
wastewater flow of 4,016 acre feet per year and the expected annual
J-6
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expenditures. The replacement water cost which was calculated for the
FRICO Exchange Alternative was based on the amount of replacement water
required and the annual expenditure attributed to replacement water
development.
To arrive at a cost comparison for the alternatives that will
directly be attributable to the consumer, annual average household costs
are calculated. Annual average household cost is the consumptive use
rate times the annual average household consumptive use or discharge.
Average household consumptive use is 131,400 gallons per year for water
supply. This figure is based on projections made by Wright-McLaughlin
Engineers. The annual average household wastewater discharge is pro-
jected to be 81,030 gallons per year or 74 gallons per day per person by
Sheafer and Roland. The annual average household quantity of replace-
ment water is the quantity of replacement water required per household
to account for the total replacement water quantity for each option
under the FRICO exchange.
WATER SUPPLY/WASTEWATER TREATMENT COSTS
This section presents the cost of all system components for each
water resource alternative. Water supply costs are presented first then
the wastewater options are presented.
FRICO Water Supply
Water supply under this alternative would come from Clear Creek and
would be stored in Standley Reservoir.
FRICO Exchange Agreement
Under the FRICO Exchange Agreement there are three possible options
available to Northglenn. Each option varies with the amount of water
borrowed and returned to FRICO. The supplemental water supply needed
for augmentation could be developed from either deep wells in the
Arapahoe formation, or a tributary well field along the South Platte
River. For each exchange agreement, borrowed water plus a 10 percent
bonus will be required for repayment. This repayment will incur a
replacement water cost that will require initial capital outlay and a
continued operation and maintenance program. To meet the replacement
water obligation, Northglenn proposes to treat its own wastewater flow
to a sufficient quality for a successive use program. Because of the
replacement water obligation, only the wastewater treatment option
available is to have Northglenn treat the wastewater. Costs for each
system component, water supply and distribution and replacement water
are discussed below.
Water Supply - Capital costs for each option vary by the amount of
water required and its source. It is realized that any option imple-
mented will affect the quantity of water borrowed from FRICO, but be-
cause of operational procedure and diurnal flow variations in water
distribution demands, the size of this transmission main is assumed to
remain the same. Capital costs for each option are presented in Table
J-3.
J-7
-------
TABLE J-3
WATER SUPPLY
ITEM
Standley Lake Pipe
Treatment Systeu
Distribution
New & Thornton Pipes
Deep Hell and
Well No. 7
Maintenance Eq.
Const. Ma Int.
t, Resident Eng.
Land & Easements
Contingencies
Eng. Legal & Admin.
Overhead & Admin.
Water Right Purchases
Total
OPTION
CAPITAL COSTS
1,494,100
4,979,200
20.338,700
In
140,774
200,000
1,857,300
180,000
375,000
1,696,800
0
4,110,120
35,371,994
I (Avg. Year)
COM
67,437
418,668
280,986
Standley Lake
Pipe O&M
0
0
0
0
0
299,250
1,066,341
SALVAGE
VALUE
50 yr.
248,527
30Z-20 yr.
70Z-50 yr.
579,765
30X-20 yr.
70Z-30 yr
1,302.502
30 yr.
12.879
0
0
3X/yr.
90,123
50 yr
62,377
0
0
1,087,126
3,383,299
OPTION II (Avi>. Year)
CAPITAL COSTS
1,494,100
4,979,200
20,338.700
629,984
200,000
1,857,300
180,000
375,000
1,696,800
0
4,110,120
35", 861, 004
O&M
67,437
418,668
280,986 1
Combined u/
Standley Lake
0
0
0
0
0
299,250
1
1,066,341 3
SALVAGE
VALUE
248,527
579.765
.302,502
57,616
0
0
3%/yr.
90,123
50 yr.
62,377
0
0
,087,126
,428,036
OPTION
CAPITAL COSTS
1,494,100
4,979,200
20,338,700
2,240,860
200,000
1,857,300
180,000
375,000
1,696,800
0
4,110,120
37,472,080
III (Avg. Year)
O&M
67,437
418,668
280,986 1
Combined w/
Standley Lake
0
0
0
0
0
299,250
1
1,066,341 3
SALVAGE
VALUE
248,527
579,765
,302,502
205,009
0
0
90,123
62,377
0
0
,087,126
,575,389
C-i
I
oo
Present Worth
Capital Costs
Less Thornton Pipes $ 18,258,694
Thornton pipes 14,518,700
O&M 1,066,341 (10.694644) 11,404.137
Salvage 3.383,299
Total P.W. $ 40,798,232
Annual P.W. ($/yr) $ 3,814,828
Unit Cost (6840 AF/yr)1.71 $/1000 gal
Annual avg. household cost 225 $/yr
(131.400 gal/yr)
Present Worth
Capital Costs
Less Thornton pipes
Thornton pipes
O&M
Salvage
Total P.W.
Annual H.U. (?/yr)
Unit Cost (6840 AF/yr) 1
Annual avg. household co:
(131,400 gal/yr)
Present Worth
Capital Costs
18,747,704 Less Thornton pipes
14,518,700 Thornton pipes
O&M
Salvage
Total P.W.
11,404,137
3.42B.036
$ 41,242,505
$ 3,B56,J70
73 $/1000 gal
it 227 $/yr
Annual P.W. ($/yr)
$ 20,358,780
14,518,700
11,404,137
3.575.389
$ 42,706,228
S 3,993,235
Unit Cost (6840 AF/yr) 1.83 $/1000 gal
Annual avg. household cost
(131,400 gal/yr)
240 $/yr
Cost up-dated from Northglenn Water Management Program Vol. 2 4/20/77 12%/yr.
Assumptions: Capital costs for the Standley Lake-transmission main will not change.
Operational procedures dictate that a certain size pipe will be re-
quired to accommodate the diurnal flow variation when coupled with
reservoir facilities; therefore, it is assumed that the transmission
main has been designed on these operating constraints. Annual flow
decreases through the Standley transmission line for various options
will reduce the O&M, but the increased deep well yield will increase
O&M; therefore, total over all O&M costs will not change.
Water right purchase is for the presently-owned water in
Standley Lake:
Total Water Rights Costs 9,261,000
Total Water Rights =
9,261,000
3150
2940 $/AF
Standley Lake - 1398 (2940) - 4,110,120
Replacement water 1755 (2940 = 5,159,700
-------
Operations and maintenance costs are calculated by updating the
costs which appear in the Northglenn Water Management Program, Volumes 1
and 2, prepared by Wright-McLaughlin Engineers. Annual O&M costs for
the three options are presented in Table J-3. These O&M costs are for
projected 1990 flow rates.
Salvage values were calculated from the capital costs required for
each system. Salvage values for the water supply system are presented
in Table J-3 for all three exchange agreements. Present worth and
annual household costs are also presented in Table J-3.
Replacement Water - Replacement water costs are associated with the
wastewater transmission from Northglenn to the treatment facility,
treatment at the proposed treatment plant, and storage in the proposed
Bull Canal Reservoir. Table J-4 shows borrowed water quantities and
replacement water obligations for average years under each option.
Capital cost for the replacement water systems of Options I and II has
remained about the same because of the unknown flow variations. Cost
variations of these two options are a result of the amount of water
rights required for augmentation of delivered water. Option III has no
replacement water costs because of the large volume of water to be
developed from the deep wells and the excess wastewater flow that is
originally owned by Northglenn. Table J-5 shows the replacement water
capital costs.
Operations and maintenance, salvage value, present worth, and
annual average household costs for the replacement water system are
presented in Table J-5. These costs have been updated from the North-
glenn Water Management Program by Wright-Mclaughlin Engineers.
Water Right Purchases
For this option additional water entitlements would be required
from the Standley Reservoir Division of FRICO. There would be no
replacement water obligation; therefore, wastewater treatment could be
treated at Metro Denver.
Water treatment and distribution capital costs for this option
would remain the same. Additional capital outlay would be required for
raw water right purchases. Informaton supplied by Sheaffer & Roland
indicates that Standley Reservoir shares yield 5 acre feet per share in
a dry year and shares are assumed to be priced at $17,500 per share.
It was assumed that enough shares would be purchased to ensure water
during a dry year. Table J-6 shows the water supply capital costs for
this option.
Operations and maintenance costs for this option are developed by
the same method as for the exchange agreements. Operational procedure
would be similar for all these options. Table J-6 shows O&M for this
option for the projected 1990 flow. Salvage values, present worth, and
annual average household costs are presented in Table J-6.
J-9
-------
TABLE J-4
C-l
REPLACEMENT WATER ATTRIBUTED TO NORTHGLENN PROPOSAL
1. Total Supply
2. Borrow Supply
3. Owned Supply
4. Percent borrowed
Line 2 Line 1
5. Percent Owned
Line 3 Line 1
6. Borrowed Water to Each House:
(Avg.Year; Line 4 x 131, 400 gal/yr)
7. Owned Water to Each House:
(Avg.Year; Line S x 131, 400 gal/yr)
8. Consumptive Use Borrowed Water (Line &X.38)
9. Consumptive Use Owned Water (Line 7x.38)
10. Wastewater Collection Borrowed Water
(Line 6 - Line 8)
11. Wastewater Collection Owned Water
(Line 7 - Line 9)
12. Line Losses Borrowed Water
(Line 10 x .03)
13. Line Losses Owned Water (Line 11 x .03)
14.. Treated Water to Bull Canal from Borrowed Water
(Line 10 - Line 12)
IS. Treated Water to Bull Canal from Owned Water
(Line 11 - Line 13)
16. Change in Borrowed Water
(Line 6 - Line 14
Based on 3 person per bouse and
2000 population 42,500
Opt. I
6,840 AF
4,197 AF
2,643 AF
61
39
80,154 gal/yr-house
51,246 gal/yr-house
30,458 gal/yr-house
19,473 gal/yr-house
49,696 gal/yr-house
31,773 gal/yr-house
1,491 gal/yr-house
953 gal/yr-house
48,205 gal/yr-house
2,096 AF/yr
30,820 gal/yr-house
1,389 AF/yr
Average Year
Opt. 11
6,840 A.F.
3,552 AF
3,286 AF
52
48
68,329 gal/yr-house
63,072 gal/yr-house
25,965 gal/yr-house
23,967 gal/yr-house
42,363 gal/yr-house
39,105 gal/yr-house
1,271 gal/yr-house
1,173 gal/yr-house
41,092 gal/yr-house
1,787 AF/yr
37,932 gal/yr-house
1,184 AF/yr
Opt. Ill Opt. I
6,840 AF 7,340
1,902 AF 5,934
4,938 AF 1,406
28 81
72 19
36,792 gal/yr-house
94,608 gal/yr-house
13,981 gal/yr-house
35,951 gal/yr-house
22,811 gal/yr-house
58,657 gal/yr-house
684 gal/yr-house
1,759 gal/yr-house
22,127 gal/yr-house
962 AF/yr
56,898 gal/yr-house
638 AF/yr
Dry Year
Opt. II Opt. Ill
7,340 7,340
5,292 3,642
2,048 3.698
72 50
28 50
Required Replacement Water
1. Change in Borrowed Water (Line 16 from above)
Residential
Commercial
2. Bonus Based on 10% of Total Water Borrow
of 500 AF
3. Evaporation
Total Replacement Required
1.389 AF/yr
300
500
236
2,425 AF/yr
1,184 AF/yr
256
500
236
2,176 AF/yr
638 AF/yr
138
500
236
1,512 AF/yr
Available for Replacement
1. Northglenn Owned Wastewater
(Line 15 from above)
2. Thornton Enclavement
3. Line Infiltration
4. Grange Hall Runoff (Required)
5. Tributary Well Field (Required)
Total
1,340 AF/yi
885
300
2,718 AF/yr
1,649 AF/yr
885
300
3,071 AF/yr
2,474 AF/yr
885
300
4,014 AF/yr
Requirements from Grange Hall and Tributary
Well Field to irrigate Northglenn lands
Waste flow compensates
for replacement re-
quired
1,332 AF/Yr
Waste flow compensates Waste flow compensates
for replacement re- for replacement re-
quired quired
687 AF/yr 0
-------
TABLE J-5
REPLACEMENT WATER COSTS
OPTION I
C-4
ITEM
Treatment tagoons
Bull Canal Reservoir
Pump Station A
Force Main
Hater Right;1
South Platte System
Grange Hall Creek
Stonehocker Ren.
land i Easement*
Contlnglncies
For Hsstevater
Contlnglncies For
Other Structures
Step 3 Engineering
Engineering • Legal
TOTAL
1 Water right* are adjusted for whatever augmentation in required
Total water purchase by tlorthglenn - $ 5,159,700
OFT OH II
Average Year
Capital O&M Salvage
$ 255.000 42,416
988,400 13,900 164,410
50.000 5,660 '°Z«55l[g'
216,000 2,530 35,929
4,032,431 2,018,961
729,000 33,500 121,251
313,600 52,164
138,000 22.955
75,000 37,551
151,400 25,184
322,000 53,561
73,500 ' 0
1.096,700 0
$8,441.031 $55,590 $2.578.540
Capital $ 8,441.031
OIH • S94.515
Salvage (2,578,540)
Total P.W. $ 6.457,006
Annual Cost 603,761
S/Yr.
Unit Cost 1.39
(1332 AF/yr) J/1000 gal.
Cost per house 42.58 $/Yr.
Dry Year
Capital OJH Salvage
$ 255,000 $ 42,416
988,400 13,000 164,410
50,000 5,660 4,158
216,000 2,530 35,929
4.983,019 2,494,903
729,000 33,500 121,251
313,600 52,164
138,000 22,955
75,000 37,551
151,400 25,184
322.000 53.561
73,500 0
1,096,700 ' 0
$9,391,619 $55,590 $3.054,482
Capital $ 9,391,619
OW 594 ,515
Salvage (3,054.482)
Total F.W. $ 6,931,552
Annual Cost 648,142
$/Yr.
unit Cost 1.84
(1079 AF/yr) S/1000 gal.
Cost per house 45.66 $/Yr.
Average Year
Capital OUt Salvage
$ 255,000 $ $ 42,416
988,000 13,900 164,410
50,000 5,660 4,158
216,000 2,530 35,929
1.872.771 937.661
729,000 33,500 121.251
313.600 52.164
138,000 22,955
75,000 37.551
151.400 25.184
3
322.000 53,561
73,500 0
1,096,700 O
J6.280.971 $55.590 $1,497.240
Capital $ 6.280,971
OM 594,515
Salvage (1,497.240)
Total P.W. $ 5,378.246
Annual Cost 502,891
$/Yr.
Unit Cost 2.25
(687 AF/yr) J/1000 gal.
Cost per house 35.55 $/Yr
Dry Tear
Capital OHM Salvage
$ 255,000 $ $ 42.416
988,000 13,900 164,410
50,000 5,660 4,158
216,100 2.530 35.929
2,833,160 1,418,609
33,500 0
313,600 52,164 '
138,000 138,000
75,000 75,000
151,430 25.184
322.010 53.561
73.500 0
1.096.700 0
I 6,512. 5*0 » 55.590 $ 2.009.431
Capital $ 6,512.160
OW 594,515
Salvage (2.009,431)
Total P.W. $ 5.097.644
Annual Cost 476.654
$/»r.
(hilt Cost 1.92
(760 AF/yr) $/1000 gsl
Cost per house 33.56 5/Yr.
Average Year
Capital OJM Salvage
$ 0 $ 5
0
0
0
0
0
0
0
0
0
0
0
O
Dry Year
CSDital 0*M Salvage
$ 0 « $
0
0
0
0
0
0
0
0
0
0
0
0
Ho replacement water necessary,
which results in zero costs to consumer.
-------
TABLE J-6
FRICO WATER RIGHT PURCHASES
Item
Raw Water Purchase
Standley Lake Pipeline
Treatment System
Distribution
Maintenance Equipment
Construction Maintenance
and Resident Engineering
Land and Easements
Contingencies
Engineering, Legal and
Administrative
Former Water Right Purchases
Overhead and Administration
Total
Capital
$
20,779,500
1,494,100
4,979,200
20,338,700
200,000
1,857,300
180,000
375,000
1,696,800
4,110,920
56,190,720
O&M
$/yr
67,437
418,668
280,986
0
0
0
0
0
0
299,250
1,066,341
Salvage Values
$
5,496,177
248,527
579,765
1,302,502
0
0
90,123
62,377
0
1,087,126
8,866,598
Present Worth Capital
O&M
Salvage
Total Present Worth
Annual Work
Unit Cost (6,840 AF)
Annual Average Household Cost
$ 52,798,020
11,404,137
8.866,592
$ 55,335,558
5,174,137 $/Yr
2.32 $/1000 gal.
305 $/Yr.
1. Adjustments for Northglenn's purchases of the Thornton watermains
have been made for capital cost present work values.
J-12
-------
Operations and maintenance costs for this option are developed by
the same method as for the exchange agreements. Operational procedure
would be similar for all these options. Table J-6 shows O&M for this
option for the projected 1990 flow. Salvage values, present worth, and
annual average household costs are presented in Table J-6.
Windy Gap Water Supply
Water supply under this alternative would be obtained from the
Windy Gap Transmountain Diversion Project. Capital costs for this
alternative differ from the previous alternatives by the proposed method
of obtaining raw water supplies. Additional capital costs for the raw
water supply would involve the purchase in the Windy Gap System, trans-
mission main, pump station, and storage facilities. Water treatment and
distribution would be the same as for Northglenn's proposed plan. Waste-
water treatment could be at either Metro Denver or Northglenn's proposed
plant.
The total water units available in the Windy Gap project are 480
units at 100 acre feet per unit. To ensure adequate water supplies,
Northglenn would be required to purchase 75 units for a total water
entitlement of 7,500 acre feet. Units in the Windy Gap project are
assumed to be purchased at a price, after inflation, comparable to the
original selling price. Operating procedures and seasonal flow patterns
indicate that Northglenn would most likely want to purchase storage
capacity in the Boulder Reservoir. A total storage capacity of 5,295
acre feet would be required. For raw water delivery from the Boulder
Reservoir to Northglenn1s proposed water treatment plant, a new 15
million gallon per day transmission line and pumping station would be
required. Presented in Table J-7 are the total capital costs for the
water supply under this alternative.
Operations and maintenance for the water supply system were formu-
lated based on the amount of capital outlay. Northglenn's share for the
operation of the Windy Gap project was taken as a pro rata share of the
total costs projected by Windy Gap. Raw water pipeline and pumping
operation and maintenance costs were taken as 1 percent of the capital
costs and a power cost of $0.034 per kilowatt hour. Operations and
maintenance costs for Northglenn1s seasonal storage are assumed to be
0.5 percent of the capital costs.^ Presented in Table J-7 are the esti-
mated annual operations and maintenance costs for the Windy Gap water
supply alternative. Also presented in Table J-7 are the salvage values,
present worth, and average annual household costs.
Denver Water Board Water Supply
For this water supply alternative, Northglenn would contract with
the Denver Water Board for water services. Contract services could be
for either raw water services or for full water services. For either
water service contract wastewater collection and treatment could be
handled by Metro Denver or Northglenn's proposed plant.
J-13
-------
TABLE J-7
WINDY
Item
Raw Water Pipeline and
Pump Station
Seasonal Storage Reservoir
Windy Gap Water
Treatment System
Distribution System
Maintenance Equipment
Construction Manager and
Resident Engineer
Land and Easement
Contingencies
Engineering, Legal and
Administrative
Total
GAP WATER
Capital
$
11,500,000
7,275,300
6,231,500
4,979,200
20,339,400
200,000
1,857,300
230,000
4,130,100
4,393,300
61,136,100
SUPPLY
O&M
$/yr
276,000
199,000
199,000
342,600
285,200
0
0
0
0
245,000
1,391,500
Salvage Values
$
1,569,400
1,648,200
501,700
1,389,000
0
0
110,100
1,239,000
0
6,457,400
Present Worth Capital
O&M. 1,391,500
Salvage
Total Present Worth
Annual Worth
Unit Cost (6,840 AF)
Annual Average Household Cost
$ 58,541,700
14,881,597
(6,457,400)
$ 66,965,897
6,261,629 $/Yr
2.81 $/1000 gal.
369 $/Yr.
1. Adjustments for Northglenn's purchases of the Thornton watermains
have been made for capital cost present worth values.
J-14
-------
Raw Water Supply
Under a raw water contract agreement, Northglenn would receive raw
water supply at the Ralston Reservoir. Northglenn could then pump this
water to the proposed water treatment plant.
Water treatment and distribution system costs would be the same as
for Northglenn's proposed plan. Total capital costs are presented in
Table J-8. The additional capital costs that are shown in Table J-8
would be incurred by the construction of the raw water transmission main
from Ralston Reservoir to the water treatment site and system develop-
ment fees. The new raw water transmission main would have a 15 million
gallons-per-day capacity and flow by gravity. Seasonal storage and an
adequate raw water development program would be assured by system de-
velopment fees. These fees are based on the number of service connec-
tions (Tap Pees). The projected ultimate number of taps and the Denver
Water Board charge per tap by size are presented in Table J-9.
Operations and maintenance costs, in addition to the treatment and
distribution of the water, would be required for the raw water pipeline,
Denver Water Boards service availability charge, and for the consumptive
use charge. An O&M of 0.5 percent of the pipeline capital cost is used
because pumping is not required. Service availability charges are simi-
lar to lifeline charges and are based on the size and quantity of taps.
Presented in Table J-10 are the projected annual service availability
charges. Consumptive use charges are based on annual water consumption
of 6,840 acre feet at a price of $0.3937 per 1,000 gallons.
Full Service Contract
For this option Northglenn would contract with the Denver Water
Board for full water service. For this type of service the storage and
distribution system would be the only component retained from North-
glenn' s proposed project. Treated water would be taken at 56th and
Washington Street and pumped through a new pipeline to Northglenn's
proposed water storage tanks.
Water distribution system capital costs would remain the same as in
the proposed project. Additional capital costs would be required for
the construction of a new 15 million gallon-per-day transmission main
and pump station. The required system development fees are again based
on the number of projected taps. Price schedules for the treated water
system development.fees are higher due to the added expense of treating
the raw water supply. Total estimated project costs for water supply
under this option are presented in Table J-ll. Presented in Table J-12
are the number of taps, by size, and the price schedule for each tap
size.
Operations and maintenance cost for service is based largely on the
consumptive use of each dwelling. Operations and maintenance cost for
the new transmission main and pump station is assumed to be 2 percent of
the capital costs for these facilities. This assumption was based on
pipeline location being in urbanized area of development, and because
portions of the pipeline will be high pressure type pipe. The pump
J-15
-------
TABLE J-8
DENVER WATER BOARD RAW WATER CONTRACT
Item
Raw Water Pipeline
System Development Fees
Service Availability
Treating System
Water Consumption
Distribution
Maintenance Equipment
Construction Manager and
Resident Engineer
Land and Easements
Contingencies
Overhead and Administration
Engineering, Legal and
Administration
Total
Capital
$
7,644,700
11,836,400
0
4,979,200
0
20,339,400
200,000
1,857,300
230,000
1,903,900
0
2,843,500
51,834,400
O&M
$/yr
51,600
0
310,200
342,600
877,600
285,200
0
0
0
0
245,000
0
2,112,200
Salvage Values
$
1,213,200
3,130,700
0
501,700
0
1,389,000
0
0
110,100
151,100
0
0
6,495,000
Present Worth Capital
O&M
Salvage
Total Present Worth
Annual Worth
Unit Cost (6,840 AF)
Annual Average Household Cost
$ 49,239,700
22,589,227
(6,495,800)
$ 65,333,127
6,108,957 $/Yr
2.74 $/1000 gal.
360 $/Yr.
1. Adjustments for Northglenn's purchases of the Thornton watermains
have been made for capital cost present worth values.
J-16
-------
TABLE J-9
SYSTEM DEVELOPMENT FEES1
Tap Size
5/8
3/4
1
1 1/4
1 1/2
2
3
4
6
Fee
$
1,000
1,925
4,150
5,400
10,700
27,000
53,000
135,000
Taps
69
8091
119
0
58
63
34
24
2
Total
$
69,000
8,091,000
229,075
0
313,200
674,100
918,000
1,272,000
270,000
Total 11,836,400
1. Water tap projection done by Sheaffer & Roland,
J-17
-------
TABLE J-10
SERVICE AVAILABILITY
Tap Size
5/8
3/4
1
1 1/4
1 1/2
2
3
4
6
Annual Fee
$/yr
26
35
42
48
60
84
150
228
420
Taps
69
8091
119
0
58
63
34
24
2
Total
$
1,794
283,185
4,998
0
3,480
5,292
5,100
5,472
840
Total
310,200
Source: Sheaffer & Roland, Inc.
J-18
-------
TABLE J-ll
DENVER WATER BOARD TREATED WATER SUPPLY COSTS
Item
Capital
$
O&M Salvage Values
$/yr $
Pipeline and Pump Station
System Development
Distribution System
Contingencies
Engineering, Legal and
Administration
Land and Easements
Service Availability
Consumption Charge
Total
6,140,700 299,800 867,300
25,308,000 0 6,694,000
20,339,400 Combined with 1,389,000
Consumption Charge
1,550,700 0 123,000
1,404,900
99,000
0
0
418,100
1,908,400
54,842,700 2,626,300
0
47,400
0
0
9,120,700
1.
Present Worth Capital
O&M
Salvage
Total Present Worth
Annual Worth
Unit Cost (6,840 AF)
Annual Average Household Cost
$ 52,248,400
28,087,343
(9,120,700)
$ 71,215,043
6,658,924 $/Yr.
2.99 $/1000 gal.
392 $/Yr.
Adjustments for Northglenn's purchases of the Thornton watermains
have been made for capital cost present worth values.
J-19
-------
TABLE J-12
Tap Size
5/8
3/4
1
1 1/4
1 1/2
2
3
4
6
Total
TREATED WATER SYSTEM
Annual Fee
$/yr
2,350
2,350
4,250
8,100
9,900
18,000
43 , 000
84,000
220,000
DEVELOPMENT FEES1
Taps
69
8091
119
0
58
63
34
24
2
Total
$
162,150
19,013,850
505,750
0
574,200
1,134,000
1,462,000
2,016,000
440,000
25,308,000
1. Source Sheaffer & Roland, Inc.
J-20
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station and pipeline was designed for 15 mgd, power costs were assumed
to be $0.034/kwh. Annual costs for service availability are based on
the number of taps and size. Presented in Table J-13 are the projected
taps and annual tap fees for the treated water service. Consumption
charge for water use is set up as a block rate as shown in Table J-14.
Annual costs are dependent on per capita consumption and persons per
dwelling. Based on reports by Wright-Mclaughlin, population projections
for the City of Northglenn will be 42,500 persons in approximately
14,200 dwellings. This would be about three persons per dwelling for an
average water consumption calculation. Wright-Mclaughlin's projected
per capita consumptions are: 74 gallons per capita per day (gpcd)
Residential, 46 gpcd Residential irrigation, 11 gpcd Commercial irriga-
tion, and 13 gpcd Commercial. Based on these figures, average annual
consumptions would be 131,400 gallons per dwelling, or approximately
5,522 AF/yr for residential use. Total commercial use would be approxi-
mately 1,300 AF/yr. Presented in Table J-15 are the tap distribution,
consumption, and average annual consumptive costs. Operations and
maintenance costs, salvage values, present worth, and average annual
household cost for the treated water supply options are presented in
Table J-ll.
WASTEWATER TREATMENT OPTIONS
Northglenn's Proposed Wastewater Treatment Plan
Costs for wastewater collection and treatment under Northglenn's
proposed plan has been developed and presented in the Draft Environ-
mental Impact Statement. Table J-16 shows the estimated required costs
for Northglenn1s proposed project.
Wastewater Treatment of Metro Denver
Costs for wastewater treatment at Metro Denver were also presented
in the Draft EIS. These costs are presented in Table J-16.
SUMMARY AND COST COMPARISONS
Evaluation of alternatives is on a comparative basis and compari-
sons are strictly on costs associated with each alternative. A summary
of calculated cost estimates has been formulated in order to assess the
alternatives and is presented in Table J-17.
Annual average household prices have been calculated for the pro-
posed project.
The estimated costs of each alternative are summarized in Table
J-17. The range of equivalent annual cost per household is from $384/yr
to $507/yr.
The analysis provides a basis for cost comparisons under a variety
of alternatives. The least costly alternative for water supply and
treatment are the options under the proposed exchange project. High
operations and maintenance cost for the other alternatives tend to
elevate costs more than the proposed plan.
J-21
-------
TABLE J-13
SERVICE AVAILABILITY CHARGE
Tap Size
5/8
3/4
1
1 1/2
2
3
4
6
Hydrants3
a. (1970
Annual Fee
$/yr
42
42
50
72
102
180
276
504
90
Taps
69
8091
119
58
63
34
24
2
500
Total
$
2,898
339,822
5,998
4,176
6,426
6,120
6,624
1,008
45,000
418,000
WME Report = 411, use 500)
Source Sheaf fer & Roland, Inc.
TABLE J-14
First
Next
Next
Over
DENVER WATER
FOR TREATED
Monthly Usage
Gallons
15,000
35,000
650,000
700,000
BOARD BLOCK RATES
WATER CONSUMPTION
Consumption Charge
Bimonthly Usage
Gallons
30,000
70,000
1,300,000
1,400,000
Rate Per
1,000 Gallons
$
1.25
1.11
0.83
0.74
J-22
-------
TABLE J-15
TAP CHARGES FOR TREATED WATER CONSUMPTION
Size
Ultimate No.
Taps
Annual Charge
per Tap
$
Total Annual
Charge
$
Single Family
5/8 x 3/4
Apartments
Commercial
Commercial
Total
5/8x3/4
1
1 1/2
2
3
4
6
5/8
3/4
1
1 1/2
2
3
4
1
1 1/2
2
3
8033
7
13
7
11
17
2
57
69
58
106
38
37
13
7
328
6
7
19
10
42
8640
192,34
443.67
929.41
1,283.82
1,675.58
4,371.42
12,740.36
21,444.26
133.75
42.50
261.76
960.39
1,373.46
1,434.88
1,488.00
5,698.74
747.10
1,511.58
1,511.58
2,134.08
5,904.34
1,545,100
3,100
12,100
9,000
18,400
74,300
25,500
142,400
9,200
2,500
27,700
36,500
50,800
18,700
10,400
155,800
4,500
10,600
28,700
21,300
65,100
1,908, 400 /Yr
J-23
-------
TABLE J-16
WASTEWATER TREATMENT
NORTHGLENN TREATMENT AND RETURN TO FRICO
ITEM
Treatment Lagoons
Bull Canal Reservoir
Pump Sta. "A"
Force Main
Collection System
Field Monitoring
Dacono Disinfection
Tallwater Control
Maintenance Equipment
, Construction Manager
1
^ Land & Easements
Contingencies
Engineering
Step 3 Engineering
Sub-Total
EPA Funding
TOTAL
Capital Costs O&M
$ 2,643,100
4,354,700
597,800
1,729,000
10,151,100
57,400
20,000
110,200
150,000
429,700
161,400
1,082,570
2,212,600
513,000
24,212,600
6,948,000
$ 17,264,600
$ 260,800
86,000
32,190
14,430
98,160
35,100
1,600
1,500
0
0
0
0
0
0
529,780
0
$ 529,780
Salvage
$ 439,651
724,357
49,719
287,600
510,254
0
0
Land
72,000
0
0
0
180,074
0
0
2,198,855
0
$2,198,855
METRO DENVER TREATMENT
Item
Denver Expansion
So. Platte 15" Interceptor
Henderson Pump Station
Henderson Force Main
Washington Pump Station
Collection (Northglenn)
(Thornton)
Contingencies
Engineering
Debt Service Existing
TOTAL
Capital Less
O&M (661,099
Capital
$ 662,679
670,312
866,700
1,847,376
49,819
546,800
8,991,900
900,777
501,400
$ 15,037,263
PRESENT WORTH
Thornton Pipes
Thornton Pipes
Sub-total
x 10.694644)
Salvage Value
Total P.W.
Annual Worth
Ilr»-l *- fVles^
O&M
$ 383,389
21,400
- 18,100
300
97,900
0
0
88,800
$ 661,099
$ 6,045,
7,991,
14,037,
7,070,
(1,437,
19,690,
$ 1,839,
1 A1
19,731,553
1,844,944 $/yr.
1.41 $/1000 gal.
114 $/yr.
-------
TABLE J-17
COSTS OF ALTERNATIVE NORTHGLENN WATER SUPPLY/WASTEWATER TREATMENT SYSTEMS
DENVER WATER BOARD WATER SUPPLY
C-i
N3
Capital ($)
Water Supply
Replacement Water
Wastewater
Total
FRICO WATER SUPPLY
FRICO Denver
Agricultural Metro
Reuse (proposed Wastewater
prolect) Treatment
$ 36,268,000 $ 56,190,000
7,400,000 0
17,272.000 15.037.000
$ 60,940,000 $ 71,227,000
Operation & Maintenance ($/Yr.)
Water Supply
Replacement Water
Wastewater
Total
Present Worth ($)
Water Supply
Replacement Water
Vastewater
Total
$ 1,066,000 $ 1,066,000
55,000 0
529.800 661.000
WINDY GAP WATER SUPPLY
North- Denver
glenn Metro
Wastewater Wastewater
Treatment Treatment
$ 61,136,000 $ 61,136,000
0 0
17,272,000 15.037,000
$ 78,408,000 $ 76,173,000
$ 1,351,500 $ 1,351,500
0 0
529.800 661.000
$ 1,650,800 $ 1,727,000 $ 1,881,300 $ 2,012,500
$ 40,798,000 $ 52,798,000
5,900,000 0
19,739,000 19.671.000
$ 66,437,000 $ 72,469,000
Annual Average Household Cost ($/Yr.)
Water Supply 230 305
Replacement Water 40 0
Wastewater 114 114
Total 384 419
$ 66,969,400 $ 66,969,400
0 0
19.739.000 19.671.000
$ 86,708,400 $ 86,640,400
369
0
114
483
369
0
114
483
Raw Water
North-
glenn
Wastewater
Treatment
$ 51,834,000
0
17,272,000
$ 69,106,000
$ 2,112,200
0
529,800
$ 2,642,000
$ 65,333,200
0
19,739,000
$ 85,072,200
360
0
114
474
Contract
Denver
Metro
Wastewater
Treatment
$ 51,834,400
0
15,037,000
$ 66,871.400
$ 2,112,200
0
661,000
$ 2,773,200
$ 65,333,000
0
19,671,000
$ 85,004,000
360
0
114
474
Full Service Contract
North-
glenn
Wastewater
Treatment
$ 54,843,000
0
17,272,000
$ 72,115,000
$ 2,626,000
0
529,800
$ 3,155,800
$ 71,222,000
0
19,739,000
$ 90,961,000
393
0
114
507
Denver
Metro
Wastewater
Treatment
$ 54,843,000
0
15,037,000
$ 69,880,000
$ 2,626,000
0
661,000
$ 3,287,000
$ 71,222,000
0
19,671,000
$ 90,893,000
393
0
114
507
-------
The cost estimates are for comparison purposes only, following EPA
guidelines. The annual charges levied against each household would be
different from the costs present in Table J-17 for the water supply
options. Reasons for these differences include:
Other revenues such as tap fees and water leasing can actually
reduce the system costs prior to ultimate development.
0 Financing of future bond expenditures is likely to be around 9
percent for 30 years if current market conditions prevail.
0 No provision has been made for the future inflation of construc-
tion, and operation and maintenance costs.
0 Some of the options considered are institutionally infeasible at
this time. For instance, agricultural reuse under the Denver
Water Board raw water and treated water options would be diffi-
cult under the Board's policy to retain dominion over the waste-
water generated from its water supply contracts.
EPA construction grant money will effectively reduce the total
project costs which are incurred by Northglenn, or Metro Denver,
and therefore reduce the price to consumers.
Presented in Table J-18 are what the annual charges per average
household and for a single family residence are estimated to be for
providing water supply and wastewater treatment under the proposed
project. The differences result from consumptive use variation. These
estimates include provisions for tap fee revenues, inflation through
1990 and short-term water leases.
J-26
-------
TABLE J-18
AVERAGE ANNUAL USER CHARGE
Year All Households Single Family Household
$/yr $/yr
1980 228 272
1981 315 375
1982 340 405
1983 367 437
1984 396 472
1985 428 510
1986 463 551
1987 463 551
1988 463 551
1989 463 551
1990 463 551
a. Average includes both single family and multi-family dwelling units.
J-27
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EPA FUNDING ANALYSIS
The remaining material in this appendix presents the details of EPA's
cost analysis, applications of EPA's "sum of the costs" rule to determine
grant eligiblity. For purposes of this analysis, the most cost effective
wastewater treatment option to Northglenn's proposal is treatment at the
Denver Metro plant. Hence, this option is used to determine eligibility.
Metro Effluent Limitations
The level of treatment for Denver Metro which will be used in the
analysis is based upon the effluent limitations that are given in the
National Pollutant Discharge Elimination System (NPDES) permit for
Denver Metro as "Future Effluent Limitations." These limits are:
30 Consecutive 7 Consecutive
Parameter Day Period Day Period Instantaneous
BOD - mg/1 20 30
Total Suspended Solids-mg/1 20 30
Fecal Coliforms-Organisms/100 ml 1,000 2,000
Ammonia Nitrogen-mg/1 1.5 1.5
Total Residual Chlorine-mg/1 - - 0.05
Oil and Grease-mg/1 - - 10
Dissolved Oxygen - - 6.4(min)
pH units between 6.0 and 9.0
The NPDES permit effluent limitations were based upon the wasteload
allocation which was part of the South Platte River 303(e) Water Quality
Management Plan. The wasteload allocation set the effluent requirements
at a level necessary to protect water quality in order to maintain the
South Platte River's B2, warm water fishery classification.
At present, the Colorado Water Quality Control Commission is in
the process of reclassifying all water bodies in Colorado. The South
Platte River will be assigned use classifications. Potential use clas-
sifications which could be applied to the South Platte River at the
Denver Metro Plant include secondary contact recreation, agriculture,
warm water aquatic life class 1, warm water aquatic life class 2 and
domestic water supply class 2. Effluent limitations for dischargers will
be set at a level to protect the uses for which the River will be classi-
fied.
Since at this time there is uncertainty as to the use classifica-
tions that will be placed upon the South Platte River and therefore the
effluent requirements, it was decided by EPA that the effluent limits in
the NPDES permit for the Denver Metro facility shall be used in the
determination of the necessary level of treatment at Denver Metro.
These limitations are taken from the most recent approved wasteload
allocation based upon existing classifications.
Operation and Maintenance (O'&M) Costs, Denver Metro
EPA Region VIII was instructed by EPA Headquarters to use the
prorated costs of Northglenn's share of the O&M costs at Denver Metro.
J-28
-------
The present worth of the O&M costs for the 20-year project will be
determined using the mid-period year (1990) operation and maintenance
expenses as the annual cost. Therefore, the share of the cost that
will be attributed to Northglenn shall be 4.45/165 times the present
worth of the O&M costs. 4.45 mgd is the 1990 projected flow for the
Northglenn facility and 165 mgd is the 1990 projected flow for the
Denver Metro facility.
The annual O&M cost was determined using information from the
1980 Denver Metro Budget (1), the "Phase 1 Report, Central Plant
Facility Plan" (Denver Metro Facility Plan) (2), and the plan for the
proposed Metro Denver Central Plant, Adams Co. Sludge Recycling
Facilities. The annual O&M cost for secondary treatment was taken
from the 1980 Denver Metro Budget and was prorated and projected to
show the cost for treating Denver Metro's flows in 1990. The costs
for bond retirement and the costs of the existing solids disposal
system were subtracted out.
Expansion and Upgrade at Denver Metro, Capital Cost Breakdown
The Denver Metro Facility Plan concluded that there is sufficient
primary treatment capacity to treat flows at Denver Metro until the
year 2004. This conclusion had been qualified; additional studies were
recommended on the peaking flow conditions for the primary facilities.
For the Northglenn cost analysis, it has been assumed that additional
primary treatment capacity will not be required, therefore no capital
expense will be used for this item.
The facility plan rated the capacity of the existing "secondary
facilities" to be at 132 mgd. At this capacity, the facility plan
states that the plant could meet the effluent limits of 20 mg/1 BOD,.
and TSS.
The facility plan specified a number of recommendations to bring
the flow capacity up to 185 mgd for the design year 2004.
Several of the recommendations represented changes in the Denver Me-
tro plant that related to improvements in the operability of existing
facilities and were not related to increasing the flow capacity of the
plant. These costs were therefore not included as costs of treating
Northglenn's flows at Denver Metro. These items and costs were:
Immediate pilot work and investigations
Cost $350,000
Additional automation of North Complex activated sludge
Cost $150,000
Provide an improved aeration basin dewatering system
Cost $20,000
Install South Complex standby waste sludge pumps
Cost $50,000
J-29
-------
Modification of South Complex secondary clarifiers and flov
distribution system
Cost $500,000
Addition of rapid mixing chambers for chlorination system
Cost $100,000
Modification of existing North Complex chlorine contact basin to
reduce short circuiting
Cost $100,000
A group of items in the list of recommended improvements for the
Denver Metro plant were determined to be related to an increase of the
flow capacity but their costs could not be broken down in order to
show the incremental costs for the additional capacity which would
be necessary to accomodate the Northglenn flows. These capital costs
were therefore split out using a pro rata basis. The Northglenn share
was determined to be the ratio of Northglenn's design flow divided
by the total flow increase of the upgrade, 4.64 mgd/53 mgd. The items
and their total capital costs are given:
Upgrade or replace the aeration system in the North Complex
Cost $2,500,000
Upgrading of the North Complex secondary clarifiers
Cost $2,000,000
Upgrading of the anaerobic digester mixing system to a mechanical
mixing system
Cost $1,500,000
Conversion of the existing anaerobic digestion system to a dual
digestion system
Cost $4,000,000
An item that was listed was the modification of the anaerobic
digester gas collection system and increasing the capacity of the
waste gas flare system. One half of this cost was attributed to the
increase of capacity of the digesters. Therefore, one half of the cost
was multiplied by the pro rata ratio 4.64/53. The total cost of this
item is $200,000.
The addition of a final effluent reaeration and foam control basin
was recommended. This item would be used to handle the total plant flow.
The Northglenn cost of this item was therefore taken out as the incre-
mental cost of the Northglenn flow to the total wastewater treatment
flow. The total cost of this item is $1,100,000.
The Denver Metro Facility Plan included a cost estimate for
upgrading the plant to meet advanced secondary treatment requirements
through nitrification, breakpoint chlorination, and dechlorination.
The nitrification process would be performed using two different
types of units. In the North Complex of the plant, combined stage
J-30
-------
nitrification would be done using a modification of the existing aera-
tion basins. Separate nitrification units would be added to the secon-
dary facilities in the South Complex. The capital cost of modifying
the North Complex aeration basin to perform both secondary treatment
and nitrification is considerably less than the capital cost of the
separate stage nitrification that will be added to the South Complex.
The incremental cost of the addition of the capacity for Northglenn's
flows will be the cost of the addition of 4.64 mgd to the 65 mgd
separate stage nitrification units.
The level of treatment that the Denver Metro Facility Plan pro-
vided, for was less stringent than the level required by the NPDES permit
for Denver Metro. Since it can be expected that operation of the pro-
posed breakpoint chlorination system can be performed to attain this
higher level of treatment, the Facility Plan costs were considered
adequate. ,
EXPANSION AND UPGRADE AT DENVER METRO
Costs Determined on Pro rata Basis
Upgrade North Complex aeration system $ 2,500,000
Upgrade North Complex secondary clarifiers 2,000,000
Upgrade anaerobic digester mixing system 1,500,000
Modification of anaerobic digester gas collection
system and increase' capacity of waste gas flare
system . 100,000
Conversion of existing anaerobic digestion system
to dual digestion system 4,000,000
Total Cost $10,100,000
Pro Rata Cost
(10,100,000) = 884,226
t>j mgd
*884,226 x 1.07 = 946,122
946,000
*The factor 1.07 is included to correct the cost estimate for inflation to July
1979.
All costs equipment 20 year life no salvage value.
Costs Determined on Incremental Cost Basis
Reaeration
Cost equation taken from Figure 6-17, "Construction Costs for
Municipal Wastewater Treatment Plants 1973-1977" (3).
J-31
-------
C = 2.27 x 105 Q0<87
„ . . GI 2.27 x 105 165°>87 „,,,
Ratl° ^ 2.27 x 10^ 169. 64"-87 = '9762
C2
Capital Cost = 1,100,000
.0238 (1,100,000) = 26,224
Salvage Value - Assume 50 year life for basin
Assume basin cost 1/2 capital cost 13,112
Present Worth (PW) salvage ;(. 6) (13,112) (. 2645) = 2,081
26,224 - 2,081 = $24,143
24,143 x 1.07 = 25,883 OR $26,000
Nitrification Facility
Cost equation from EPA 1973 Report "Cost Effective Wastewater
Treatment Systems" (4)
Equation C = 210,055 + 59204. 6Q
Ratio G! = 210,055 + 59.204.6 (65) = 0.9366
TT- 210,055 + 59,204.6 (69.64)
C2
(1 - .9366)=0.0634
Capital Cost = 12,000,000
.0634 (12,000,000) = 760,800
Salvage Value - Assume 50 year life of basins
Assume basins 50% of costs
PW = .6 (760, 800)(.5)(. 2645) = 60,369
760,800 - 60,369 = 700,431
700,431 x 1.07 = 749,461
or 749,000
Breakpoint Chlorination
' Cost equation from EPA 1973 Report "Cost Effective Wastewater
Treatment Systems"
Equation C = 136,587 Q°'52
! =.9872
1 - .9872 = .01280 8,959 x 1.07 =
280 (700,000) =
No .Salvage Value
.01280 (700,000) = 8959 or
-------
Dechlorination
Use same cost equation as for Breakpoint Chlorination
C2 169.64>52
1 - .9857 - .01432
.01432 (500,000) = 7,160
7,160 x 1.07 = 7.661
or $8,000
Total Capital Costs Present Worth 1984 Construction Date
Construction Costs
(calculation pro-rata basis) $ 946,000
Reaeration Facility 26,000
Nitrification Facility 749,000
Breakpoint Chlorination . 10,000
Dechlorination 8,000
Total $1,739,000
Adjust to 1980 present worth
1,739,000 (.76647) 1,332,891
Total Costs
Annual O&M STP $ 307,689
Annual O&M Sludge 75.700
Total $ 383,389
PW = 10.6976 x 383,389 $4,101,342
PW O&M $4,101,342
PW Capital 1.332.891
Total Treatment Cost $5,434,233
Rounded $5,434,000
Costs of Conveyance of Wastewater to Denver Metro
Discussion
The existing interceptor system that conveys wastewater from
Northglenn and surrounding areas is shown in Figure J-l. Using DRCOG
population estimates, the projected wastewater flows for the "Agricul-
tural Reuse Service Area", shown in Figure J-l are given.
J-33
-------
WESTMINSTER
BIG DRY
TREATMENT
PLANT—-,
L'i wifltinnn
MORTHOLENN
THORWTON
LEGEND
Agricultural Reuse Service Area
-— Northglenn City Limit
— Thornton City Limit
A Pump Station
• ••• Force Main
lUlinilllllHl Gravity Interceptor
B Wastewater Treatment Plant
THORNTON
NORTH ^
WASHINGTON! ~
DENVER METRO CENTRAL
TREATMENT PLANT--"
J-34
-------
1980 1990 2000
Total flow (million gallons
per day) 4.74 6.24 7.00
Flows proposed for treatment
with Northglenn System 3.59 4.45 4.65
Flows remaining for treatment
at Denver Metro 1.15 1.79 2.35
Using flow estimates for the existing service areas, it has been
projected that the Thornton-North Washington pump station would have
its capacity exceeded by 1985 (5). It also has been projected that
the capacity of the Thornton-North Washington interceptor which ex-
tends from 100th Avenue to the Thornton-North Washington pump station
will be exceeded by 19-85. The Thornton-North Washington force main,
which conveys flow from the Thornton-North Washington pump station,
is expected to have sufficient capacity until the year 2000. The
flows are conveyed from the Thornton-North Washington force main to
the Denver Metro sewage treatment through the Clear Creek Inverted
Siphon. The Clear Creek Siphon will have to be enlarged during the
planning period due to increased flows from the Clear Creek basin
regardless of Northglenn's plan.
If Northglenn's flows are to be treated at Denver Metro for the
planning period, changes would be required in the existing system
to handle the projected flow increases. The interceptor system shown
in Figure J-2 is the system used in the cost comparison as the facili-
ties which would be necessary for the conveyance of the flows from
Northglenn and the surrounding area. Using the system, .90 mgd of
Northglenn's flow would be conveyed through the existing Thornton-North
Washington Pump Station and Force Main. The remainder of 3.74 mgd of
Northglenn's flow would be conveyed using the South Platte Interceptor
and the Henderson Pump Station and Force Main. Along with Northglenn's
flow, wastewater from parts of Thornton would also be conveyed in the
system. These flow quantities are 1.31 mgd in the South Platte
Interceptor and 2.36 mgd in the Henderson Pump Station and Force Main.
The cost of the construction of the conveyance system which was
assigned to Northglenn in the cost analysis is the ratio of the
Northglenn flow over the total flow multiplied by the total construc-
tion cost. The operation and maintenance costs were also determined
on a pro-rata basis using flow quantities.
Wastewater Conveyance Costs Treatment at Denver Metro
South Platte Interceptor 15" gravity sewer
3'^ ^ 31 905,100 (Total Cost) $ 670,312
Construction Cost 670,312
Contingencies (25%) 167,578
Salvage Value (6) (.2645) 837,890 (132,973)
O&M 17,800 x 10.6976 190,400
Engineering Design & Construction Inspection 83,800
Administration & Overhead 3,600 x 10.6976 38,500
1,017,617
or 1,018,000
J-35
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FIGURE J-2
-N-
Scale
10,000 Feel
I Mile
•Thornton Wastewater
Service Area To Be
Served By Northglenn
Henderson
Pump Station
Thornton
Outfall
NORTHGLENN
Northglenn Area
To Be Served
By Thornton /
Thornton Wastewater —
Service Area To Be
Served By Northglenn
Central Plant
Thornton -North Washington
Pump Station S Force Main
METRO DENVER ALTERNATIVE
a New Pump Station
• Existing Pump Station
Now Gravity Sewer
Existing Gravity Sewer
New Force Main
••••Existing Force Main
SOURCE :
sl*AffER & (id ANd, WC.
J-36
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Henderson Pump Station
Construction 1,413,600 (3.74
6.10) 866,700
Contingencies (25%) 216,675
Salvage Value (Assume 50% of item 50-year life
50% of item 20-year life)
(.6)(.5) 1,083,375 (.2645) -(85,966)
O&M 4,600 x 10.6976 498,500.
Engineering & Construction Inspection 108,300
Administration & Overhead 4,600 (10.6926) 49.200
1,653,409
or 1,653,000
Henderson 27" Force Main 5,800 LF
Construction 3,013,100 3. 74
6.10 1,847,376
Contingencies (25%) 461,844
Salvage Value (.6) 2,309,220 (.2645) -(366,473)
O&M 8,200 (10.6976) 87,700
Engineering 230,900 230,900
Administration & Overhead 9,900 (10,6976) 105,800
2,367,147
or 2,367,000
Existing System Costs
North Washington Pump Station 53,500
O&M
North Washington Force Main
1981-2000 O&M 300 x 10.6976 3.200
56,700
or 57,000
TOTAL 5,095,000
Costs for Northglenn Multiple-Purpose Project
Discussion
The costs for the Northglenn wastewater treatment, agricultural
reuse project are given (6). Two items in the cost estimate need
to be explained. They are the collection system costs and the land
for the contingency plan costs.
Collection System Costs
Northglenn has purchased its wastewater collection system from
the City of Thornton. Work is required on sewer system lines in order
to sever the Northglenn collection system from the Thornton system.
Additional construction is necessary for Northglenn to implement the
multi-purpose project; all flows within Northglenn must be conveyed
J-37
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to Pump Station A so they can be pumped to the treatment facility in
Weld County.
Two alternative costs were determined for the severance of the
Northglenn collection, the cost of severing the system and having flows
leave Northglenn at two different drainages to be conveyed to the
Denver Metro wastewater treatment plant, and the cost of severing
the system with all Northglenn flows being conveyed to Pump Station A.
The present worth of each alternative cost consists of the cost of
operation and maintenance of the entire collection system as well as
the capital cost of the construction necessary to sever the systems.
The cost of the multi-purpose project collection system improve-
ments is then determined as the cost of severance under the alternative
where the flows will be conveyed to Denver Metro subtracted from the
cost of severance if the flows will be conveyed to Pump Station A.
The work necessary to sever the Northglenn and Thornton collection
systems shall not be eligible for EPA funding since presently a waste-
water collection system exists and the construction is required due to
a transfer of existing facilities between municipalities.
Costs of the Contingency Plan
EPA has required that in order for Northglenn to be given funding
as an alternative technology project, the City would have to provide
assurance that effluent would be put to agricultural use for the entire
project life of 20 years. Northglenn has informed EPA that it has
developed a contingency plan. At present, Northglenn owns 1,065 acres
which could be irrigated using the Bull Canal system. This land was
purchased by Northglenn when the City was obtaining water rights. The
acquisition of the land was incidental to the purchase of water. It
was determined by Northglenn and EPA concurs, that 1,065 acres would
be sufficient to allow all of the treated wastewater from Northglenn
to be applied to land. Northglenn has also obtained the right of first
refusal from FRICO shareholders so that it can obtain the water rights
necessary to implement the contingency plan. Northglenn has agreed to
accept a grant condition which would require that they retain a commit-
ment so that if farmers under the exchange agreement would no longer
accept FRICO water, Northglenn, through land ownership, lease, or
irrigation easement would be able to apply its treated wastewater to
land. Under this plan, Northglenn will be able to sell existing land
as long as it is replaced by a commitment to an equivalent amount of
land.
For the cost effective analysis, it was decided to use the price
of the land as a cost of the project. The land purchase will not be
eligible for Federal construction grant funding since it is not an
integral part of the treatment process and since the purchase was
made before a grant was given.
J-38
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NORTHGLENN MULTI-PURPOSE COSTS
Lagoons & Storage
Earthwork, structures, piping $ 3,402,200
Asphalt liners & Roads 2,591,800
Landscaping 124,700
Site Buildings 418,500
6,537,200
Contingencies 10% 653,720
$ 7,190,920
30
Salvage Value (50-year life) -ppr = .6
P.W. (salvage value) = 7,190,920 (.6)(.2645) -1,141,199
6,049,721
Mechanical Equipment 1,161,300
Electrical Instrumentation, telemetry 488,000
Fencing 54,700
1,704,000
Contingencies 10% 170,400
1,874,400
Step 3 Engineering 403,600
Construction Management 342,900
O&M Cost 321,900 (10.6976) 3,443,600
Administration & General Overhead 38,800 (10.6976) 415,000
12,529,221
Total (Lagoons & Storage) 12,529,000
Land (Northglenn Treatment Plant Site)
Land Cost 179,600
Salvage Value -(86,000)
27" Force Main
93,600
94,000
1980 Construction & Contingencies 2,139,500
1980 - 2000 O&M 7,800 (10.6976) 83,400
Salvage Value (59-year life) (.6) (2,139,500) (.2645) -(339,539)
Administration & General Overhead 9,160 (10.6976) 98,000
Step 3 Engineering 90,900
Construction Management 77,300
2,646,839
2,647,000
J-39
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Pump Station A
1980 Construction & Contingencies 712,600
1981 - 2000 O&M 34,800 (10.6976) 372,300
Salvage Value 50-year life for 50% of item
20-year life for other 50%
712,600 (.5) (.6) (.2645) -(56,545)
Administration & Overhead 3,050 (10.6976) 32,600
Step 3 Engineering 30,300
Construction Management 25,700
1,116,955
1,117,000
Field Monitoring Program
1980 Construction & Contingencies 77,500
1981 O&M 35,100 (10.6976) 375.500
453,000
Dacono Disinfection
1980 Construction & Contingencies 32,500
1981 - 2000 O&M 17.100
49,600
50,000
Firestone & Frederick Tailwater Control
Construction & Contingencies 163,700
Salvage Value of Land -(7,200)
O&M (1,500) (10.6976) 16.046
172,546
173,000
Land for Contingency Plan
Cost of Land 221,900
Salvage Value -(106.300)
Present Worth 115,600
116,000
Collection System Costs
*
Multi-Purpose Project
Construction 1,159,700
10% Contingencies 115,970
Salvage
Assume 75% 50-year life
25% 20-year life
.75 (1,275,670) (.6) (.2645) -(151,836)
O&M 92,700 (10.6976) 991,700
Step 3 Engineering 54,200
Construction Management 46,100
Administration & General Overhead 5,460 (10.6976) 58,400
2,274,234
J-40
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Single Purpose Project
Construction 546,800
10% Contingencies 54,680
1981 - 2000 O&M 70,100 (10.6976) 749,900
Salvage
Assume 75% 50-year life
25% 20-year life
Salvage Value .75 (601,500) .2645 (.6) -(71,594)
Step 3 Engineering 26,400
Construction Management 22,400
Administration & Overhead 27,800
Engineering Design 29,600
1,385,986
Difference - Multi-purpose/Single Purpose
Collection System Costs
2,274,234
-1.385,986
888,248
888,000
Northglenn - Total Cost 18,067,000
*In accordance with EPA regulations the value of land was appreciated
at the compound rate of 3% annually.
SUM OF THE COSTS RULE
In order for EPA to participate in the funding of a multiple-
purpose project, it must be shown that the cost of the multiple-purpose
project must not exceed the suotr of the costs of the most cost-effective
single purpose options which accomplish the same purposes.
Sheaffer and Roland has developed costs for a single purpose
agricultural water supply project which would deliver water from the
South Platte River to a storage reservoir located at the proposed
Northglenn wastewater treatment plant site. The project would require
the construction of a Platte River diversion structure, a pump station
and force main to the reservoir site and a 4,000 acre-foot storage
reservoir.
The following present worth cost developed for this alternative:
Capital Costs 11,532,900
Pipeline and storage reservoir
salvage value
Assume 50 year life -(1,401,900)
Land salvage value -(47,900)
Operation and Maintenance 1,246,300
11,329,400
hS-i/Jtv
J-41
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This cost is then added to the costs of the single-purpose waste-
water treatment project.
Agricultural water supply 11,327,400
Treatment at Denver Metro 5,095,000
Conveyance to Denver Metro 5,343,000
21,765,400
This cost is greater than the present-worth cost of the proposed
Northglenn multi-purpose project, $18,067,000. Therefore, the
Northglenn project complies with the sum of the cost rule.
J-42
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APPENDIX K
DRAFT INTERGOVERNMENTAL AGREEMENT
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INTERGOVERNMENTAL AGREEMENT
THIS INTERGOVERNMENTAL AGREEMENT, made and entered into
this day of , 19^_, by and between the CITY
OF NORTHGL5.VN, a home rule city of the State of Colorado (hereinafter
"Northglenn"). and the COUNTY OF WELD, a home rule county of
the State of Colorado acting by and through its Board o£ County
Commissioners (hereinafter "Weld .County").
WIT.VESSETH
WHEREAS, Northglenn has been designated the wastewater aanagement
agency for the Northglenn Service Area under the Denver Regional
Council of Governments ("DRCOG") Areawide Water Quality Manageaent
Plan (208 Plan); and
'AfHESEAS, Nortaglenn plans to construct and operate a wastewater
treatment facility described as the Bull Canal Reuse Reservoir
to serve the Northglenn Service Area, within the unincorporated
area of Meld County, and has applied for a grant from the United
States Environmental Protection Agency C3PA) to assist it in
financing the 3ull Canal Reuse Reservoir; and
WHEREAS, Northglenn will deliver treated effluent from the
3ull Canal Reuse Reservoir to farmers within ifeld County via
the Bull Canal for use as irrigation water as part of the North-
glenn/FRICO Agriculture Reuse Project; and
WHEREAS, the Larimer-Weld Regional Council of Governments
(L-WRCOG) in its Areawide Water Quality Management Plan (208
Plan) has found the Northglenn/FRICO Agricultural Reuse Project
"...to be in accordance with the regional goals and objectives
and recommends that the project be funded..." subject to specific
requirements for the institutional approval of the plan and certain
health and environmental concerns addressed herein; and
WHEREAS, Weld County is the designated wastewater management
agency for its unincorporated area under the Larimer-Weld Regional
Council of Governments Areawide Water Quality Management ?lan;
and
WHEREAS, Weld Councy, as che designated wasteuater management
agency for ics unincorporated area, sec forth in said Areawide
Water Quality Management Plan, has Che responsibility for protecting
wacer qualicy within ics management area; and
WHEREAS, both Norchglenn and Weld Councy desire Co integrate
the Norchglenn/FRICO Agricultural Reuse Project into conformity
with che Areawide Wastewacer Management Plan Co minimize che
environmencal effects from the operation of che treatment facility
by insuring chat the facility is operated according to che highest
standards and In conformance wich all applicable operational
conditions, and Co establish che necessary institutional arrangements
sec torch in said plan; and
WHEREAS, boch Northglenn and Weld Councy see1* co ascablish
an operating ralacionshlp based on mutual cooperacion; and
WHEREAS, Norchglenn and Weld Councy seek Co accomplish chese
objectives by means of an intergovernmental agreement setting
forth che conditions under which Morthglenn may operacs its wascewacar
creacmenc facility in addicion co ics role as a management agsncy
under che DRCOC Seccion 208 Wacar Qualicy Management Plan.
NOW, THEREFORE, in consideration of che amcual promises,
covenants and conditions set torch aerein, che parcias hereco
agree as follows:
!• Responsibilities of Northglenn as a Management and
Operating Agency in Weld Councv. Norchglenn and Weld CounCy shall
share management agency responsibility for che wascewacer creacmenc
facilicy, hereafter Sull Canal Reuse Reservoir, described in
Exhibit A attached hereco and incorporated herein by this reference.
Norchglenn is hereby designated as an operacing agency within
Weld CounCy for said facility. The rights and responsibilities
of Norths!«nn as an operating agency are sec fe«rcJi in full balow:
<«' FacUtcies Boundary. The area wiehln Weid County
chat is included wlchln the Norchglenn Facilities Plan boundary
for the wascewater creatment system is described in Exhibic 8,
attached hereco ami incorporated herein by this reference.
-2-
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(b) Facilities Pl.in. I'ha final ijoilicies plan for
Che Norchglenn treatment c'jciliCy is described In Exhibit C and
attached heroco and incorporated horain by Chis reference.
(c) Reusj Ara-i. Tho NorChglenn/FRICO Reuse Area is
described in Exhibit D accaclied hereto and incorporaced herein
by Chis reference.
(d) Building Permits for che Treatment Facility. Norch-
glenn shall apply for and Weld County shall issue a building
permit for che construction of Che treatment building at the
Norchglenn wascewacer treatment facility to be located within
Weld County. The building permit shall contain che following
conditions:
(1) compliance with applicable provisions of che
councy building code existing at che time of Chis Agreement.
(2) landscaping treatment of che building and
all areas of che site not used as sewage treatment
lagoons, reservoir, driveways, parking areas, or cultivated
agricultural land.
(3) approval of all accesses onto cne treatment
facility and to the treatment building by che Weld
County Engineering Department, which approval shall
noc unreasonably be withheld.
(4) compliance wich maximum setback requirements
defined in Section 3.14 of che Weld County Zoning Reso-
lution, as in effect at the time of this Agreement.
(5) prevention of soil erosion and fugitive dust
in excess of emissions permitted under Norchglenn's
state fugitive dust emission permit.
(6) prevention of the growth of noxious weeds.
(e) Sgecial Use Permit. A permit for the special us«
of the land and facilicies sec forth in Exhibit A is hereby granted
upon the following terms and conditions:
(1) No open storage, stockpiling or air drying
of sludge within cha facility boundaries sat forth
-3-
in Exhibit A wichouc first applying tor and securing
a permit therefore from Weld County, which permit shall
not be unreasonably withneld.
(2) Norchglenn shall disinfect the effluent prior
Co discharge to achieve a criteria of 200 fecal coliform
per 100 ml unless che SCace of Colorado or EPA shall
establish a higher limit.
(3) Norchglenn agrees to issue and reissue on
an annual basis for the design life of Che plant, to
all shareholders of record in che Standley Lake Division
of FRICO, and to all shareholders of record of any
ocher division of FRICO Co which uacars from the NorEhglenn
reservoir are diverted, an advisory concerning the
constituents of the wascewacer in the reservoir and
a notice that such water should not be used for the
irrigation of raw edible vegetable crops. In the event
chat raw edible vegetable crops irrigated with Nortnglenn
wastewacer are offered cor sale or public distribution,
Northglenn agrees co find alternative process markets
for the crops or to acquire at its own expense the
crop itself. In lieu of tne foregoing, Northglann,
at its option may treat Che fecal coliform component
of its effluent Co a level found by EPA Co adequacely
protect Che public health for use in irrigation of
raw vegetables, or otherwise so handle or treac the
effluent or raw edible vegetables so as to prevent
a public health hazard; such as by treatment, posting
Che use of the vegetables only after boiling, or such
ocher manner acceptable co EPA.
(4) Norchglenn shall provide Weld Councy with
an agricultural reuse manual governing the reuse arrangement
between Norchglenn and che FRICO farmers. Norchglenn
will develop che Agricultural Reuse Manual (as ouclined
below) to provide advice co farmers of the Standley
-4-
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u>
Lake Division of fr'RCCO on che use of creaced sewage
effluent foe crop irrigation. Periodic public reporting
in Che advisory notices will be provided Co Che FRICO'
Board and Co anyone requesting this information.
A. Water Yield Projections
1. Snow survey
2. Scandlsy Lake YieLd
a. Bull Canal Shares
b. Reuse Wacer
8. Wacer Delivery Projections
1. Crop Projections
a. Type
b. Acres
2. Scandley Lake
a. Cities
b. FRtCO delivery
3. SuLl Canal Reservoir
a. Wascewacer
b. Makeup Water
C. Nutrient Delivery Projections
I. 3ull Canal Reservoir Qualities by Month
2. Recommended Commercial fertiliser Application
Rates
3. Croo Advisories
Q. Adjustments to Delivery Projections
1. Standley Lake Quantity and Quality
2. Bull Reservoir Quantity and Quality
3. Crop Advisories
4. Field Monitoring Results
£. Distribution of Reports
i. Agricultural Advisory Reports
2. Wacer Quality Monitoring Raporcs
(5) Norchglann will undertake che cose of modifi-
cations, operation and maintenance for che Dacono nonpocatM-
water supply Co insure chat Che nonpotable water supply
for Che Town of Dacono is properly disinfected to procacc
* ^
public hsalch for the design lira of Che Norchglenn
projecc. Norchglenn shall cause the disinfection of
che existing Town of Dacono nonpotable wacer supply
coming from Che Bull Canal at times when Che Sull Canal
Reuse Reservoir is in operation to maintain a fecal
colifortn level no greater than che level existing imrau-
diately upstream of the Norchgiann treatment facility,
or, at Northglenn1s opcion, it may instead replace
Dacono's existing nonpocable wacer supply with an equivalent
source of supply In exchange for Oacono's FRICO/Scanu!uy
Lake Division wacer shares. Norchglenn shall consult
with the Town of Dacono and secure its approval as
-5-
a condition prerequisite to the implementation of any
one or more of these plans.
(61 Norchglenn will provide physical measures
co prevent che flow of wascewater from adjacent agricultural
land inco the Towns of Frederick and Firestone or any
other rasidencial area. Consultation with Frederick
and Firascone on the design and location of these facilities
Is necessary. Operacion of chese facilities shall be
at che request of Frederick or Firestone and Northglenn
shall assume no liability thereby co any person claiming
a right co che use of said wacer.
(7) A monitoring program will be developed by
Northglenn to include locations and depths of grounawatar
monitoring wells, locacions of surface water Tionitoring,
and procedures for monitoring crops. Pollucanc parameters
and monitoring frequencies muse be developed. Domestic
groundwacar supplies in che area that could be affectsd
by che project i\usc be identified and periodically
monitored. The monitoring program shall be Ticdifiad
as information is developed on items sucti as the potential
for crop contamination by toxic substances.
Test procedures for che analysis of pollutancs
shall conform Co regulations published pursuanc Co
Section 304(h) of the Clean Wacar Act. Norchglsnn will
be required to retain all records and information resulting
from the monitoring activities including all records
of analysis performed and calibration and maintenance
of instrumentation for che design life of the proj'ecc.
Northglenn muse provide annual public reporting
on che findings of tile .-nonicoring program. Northglenn
muse also identify any nonconformance wich regulations
concerning the level of contaminants in crops sec by
Che Federal Drug Administration iFDA) or United SCaces
Department of Agriculture (USDAI, State agriculture
and health dupartmancs and ocher government agencies.
-6-
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EPA will provide L-WRCOC and Weld County copies
of Che draLC program cor their review. A minimum of
a 90-day review period will be given. EPA will review
Che L-WRCOG and Weld Councy commencs before che monLCoring
program is approved.
(8) Norchglenn agrees co pay Co Weld Councy a
sum equal co ewency percent (207.) of Che annual salary
of a Weld Councy Healch Deparcmenc employee for independent
processing of monitoring samples. Such payment shall
continue proraca from monch Co month so long as an
employee is assigned by Weld County Co monicor Che
reports.
(9) Upon che conveyance co the City of Che water
rights and diversion facilities, Norchglenn agrees
Co replace, at its own expense with an aqua! quanCiey
of water in rate and duration of flow, any existing
residential groundwacer supply chac becomes concarainacea
in excess of applicable scace standards as a result
of che operation of the Norchglenn creacmenc facility.
(10) Norcnglenn agrees Co cake immediate action
co respond Co any reasonable request raade by Weld County
Co remedy any 'adverse environmental efface resulting
from the operation of che Norchglenn facility. In che
event of any emergency chac poses an imminent chreat
to public health or safety, Norchglenn will immediately
concacc the Weld Councy Health Deparcmenc. Northglenn
agrees not Co allow the release of any affluent from
the treatment faciltles boundaries chac would threaten
che public health or safety.
(11) Northglenn shall assure chac sufficient land,
approximately 1,100 acres, in che FRICO system is under
Cheir control — through ownership, lease, or contract
— for the purposes of effluent disposal. This condicion
Is binding for che 20-year design life of Che project.
-7-
Weld Councy shall nuc prevent the use of such land
for chac purpose by purchase, agreement or any ocher
governmental accion.
(12) In order Co insure proper construction of
the Bull Canal Reuse Reservoir, Norchglenn agrees chac
during conscruccion of che cuc-off key for che reservoir
dike, a Crench will be made along che norchwesc boundary
chac will penetrate down Co a compecenc zone in che
Arapahoe formation. An examination of che exposed unics
will be made to determine if any faulc traces cac across
this porcion of che reservoir. If a faulc trace is
locaced wichin Che proposed reservoir area, either
che dam will be relocaCed co exclude che trace, or
che crace will be sealed with an impermeable liner
before implacemenc of che clay liner. The resulcs of
these investigacions and any micigacive measures must
be insoecced and approved by che Corps of Engineers,
who will reporc che results Co EPA.
All shallow test holes within the reservoir sice
chac have a depch greater Chan 30 feet below che pond
base muse be plugged wich concrece. Any cast holes
chat have a depch of less Chan 30 feet must be back
filled and compacted. The cased USGS cesc wells (BW-77-15B
and SW-77-17B) muse be pressure plugged with concrete
from the bottom up to insure proper abandonment. EPA
will be notified when the plugging is to cake place
so Chac a staff member can observe the plugging operation.
The thickness of the clay liner will be increased
^
over che proposed 6" compacted seal for areas where
the seal will be in direct contact with sand or sandstone.
Clean clayscone material must be used. In all cases
the inplace ciaystone that will be used for a seal
muse be ripped up to che required depch before compacciiu,
che six inch chick seal, [n areas where clayscone is
-------
not present, a supply of claystone (from stockpile)
must be spread in che area and a compacced seal of
ac Lease one fooc chick provided.
(13) Norchglann will develop a detailed operations
manual for the Bull Canal Reuse Reservoir facility.
Weld County Health Department will be provided an oppor-
tunity to assist in the development of the manual.
(14) The Bull Canal Reuse Reservoir facility will
be monitored by fully trained personnel on a 24-hour
per day basis.
(£) Norchglann shall enforce and comply with the carms
and conditions of Che L-WRCOG 208 plan.
2. Rights of Morthglann as Kanagamenc and Ooeracions Aganey.
(a! Northglenn shall be Che sole encity co receive
and manage federal or scace grant funds for che sonscrucicon
of the treatment facility.
(b) Northglann shall have the exclusive right, subjecc
only to Che express provisions of this Agraemenc, Co construct,
operate, and rcanags the craacmenc facility.
(c) Weld Councy hereby delegates Co Norchglann, as
operating agency, any righc or claim ic might have as management
agency under the L-WRCOG Section 208 Water Quality Management
Plan to perform any of che above funccions relacive Co che Norchgleru,
creacmenc facllicy and Weld County hereby agrees co share wich
Norchglenn che rights and responsibilities as a wascewacer managemen'
agency pursuant co che L-WRCOC 208 Plan for che Bull Canal Reuse
Reservoir facility sec forch on Exhibtc A.
(d) Weld Councy agrees Co cooperate wich Norchglenn
now and in che future co secure all necessary permits, approvals,
granc awards and cooperace in any ocher manner Co ensure che
successful and healchful operacion of che Norchglenn/FSICO Agri-
culcural Reuse Projecc.
(e) All pennies, approvals or similar condicions of
local, scace, or federal government agencies shall be applied
for by Norchglenn and secured by Northglenn in its own name and
on its own behalf.
(f) Weld County shall retain all land use and zoning
authority in che area surrounding the Bull Canal Reuse Reservoir
facility sat forth on Exhibit A.
(g) Northglenn shall retain all authority for Che
expansion of Che Bull Canal Reuse Reservoir and Co approve or
disapprove all Cap connections into the project interceptors
located outside of Weld County. Northglenn shall retain all control
necessary for expansion, alteration, or modification of the Bull
Canal Reuse Reservoir.
(h) The City of (Jorchgiann and Weld Councy shall share
responsibilities as Management Agencies under their respective
208 Water QualiCy Plans as to the construction of additional
interceptors to the facility from within Weld County to ensure
adequate planning, grant award and operacion thereof.
3. Dismissal of Pending Litigation. Weld Councy agrees
Co dismiss with prejudice its participation in che following
lawsuits: (a) Board of Counev Commissioners of Weld Councy v.
Citv of Northglann (79CV431) and (b) Consolidated 3it;hes Co.
v. Wacar Qualiey Concrol Commission (79CV530). In addition Weld
CounCy agrees noc to prosecute any further action arising out
of Che construction or operacion of che Northglenn/FRICO Agricultural
Reuse Projecc except as may be necessary for the enforcement
of this Agreement.
4. Taxes. Norchglenn agrees to pay Co Weld Councy each
year, a sum of money equal co and in lieu of che real propercy
taxes which would have otherwise been lawfully assessed by Weld
Councy against che real propercy owned by Norchglenn in Weld
Councy, as such propercy presencly exists in both excanc and
condicion of improvemenc.
5. Tides. The tides co each paragraph herein are illustraciv.
only and shall not be interpreted 'in such a manner as to alcer
Che meaning o£ an individual paragraph or che agreement.
-10-
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6. SeverabiIiCv. Each provision oc chis agreemenc is inca-
graced wtch all ocher provisions oc chis Agreemenc and shall
remain in force and effecc unless an individual paragraph nay
be decermined Co be invalid. If any provision of chis agreemenc
shall be deemed Co be invalid Che encire agreemenc is null and
void.
7. Venua and Incerorecacion. This agreemenc shall be binding
upon che parcies hereco and cheir successors and assigns. Enforcemenc
of Che cerms hereof shall be an imparcial venue in Che Denver
Dlscricc Courc. This Agraemenc is ancered inco and shall be incer-
preced pufsuanc Co Che provisions oE ^rcicla XIV Seccian 13 at
Che Conscicucion oc Colorado and C.R.3. 1973, Seccion 29-1-203.
IN WITNESS WHEREOF che undersigned sec torch cheir hand
and seals on che day and dace above firsc wriccen.
APPROVED AS TO FORM:
Councy Manager, Councy oc Weld
Councy Accorney, Councy of Weld
Chairman, Larmer-WeTa
Regional Council of Covernmencs
ATTEST:
CITY OF NORTHCLENN
Mayor, Licy oc Norcngiann
APPROVED A3 TO FORM:
Cicy Manager, Cicy oc Norchglenn
Cicy Accorney, CiCy or Norchglenn
Special Counsel
ATTEST:
COUNTY OF WELD
Chairman, Board oc Councy Commissioners
-11-
-12-
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Colorado
Department of
Health
4210 East 11th Avenue
Denver, Colorado 30220
Phone(303) 320-8333
June 4, 1980
RICHARD P. LUNDAHL
10701 MELODY DRIVE, SUITE 313
NORTHGLENN, CO 80234
CITY OF NORTHGLENN
Frank A Tray lor, r,
Executive Director
CERTIFIED: P06 6984983
RE: Final Permit, NPDES Permit Number: CO-0036757, WELD COUNTY
Gen 11emen:
Enclosed please find a copy of the permit issued under the Federal Clean
Water Act and Colorado Water Quality Control Act.
Issuance of this permit constitutes a final determination by the Division
of Administration of the Colorado Department of Health, in conjunction with
the U.S. Environmental Protection Agency and may be subject to administrative
review proceedings pursuant to the State Administrative Procedure Act, in-
cluding an adjudicatory hearing. You are advised to consult this act and
particularly to consult Sections 24-4-104, 24-4-105, 24-4-102(7), and 25-8-401,
C.R.S. 1973 for more information. In addition, the Regulations for the State
Discharge Permit System contains material tKat is pertinent to any admini-
strative review of the issuance of this permit.
Your NPDES Waste Discharge Permit required that specific action be performed
at designated times. Failure to meet these requirements constitutes a vio-
lation of this permit and can result in civil and/or criminal action(s).
Please read the permit very thoroughly.
1. All municipal and industrial facilities are required to submit self-
monitoring information. (PART 1.8. Monitoring and Reporting).
Frequencies and types of self-monitoring are summarized in PART I.A.
Effluent Limitations and Monitoring Requirements.
2. Monitoring and reporting requirements for feedlots are described in
PART I.A. Effluent Limitations and Monitoring Requirements (see 2.c.)
and in PART I.B. Monitoring and Reporting.
3. In some instances a schedule of compliance is to be submitted if required
by your permit. Please note the required date as specified in PART I of
the permit.
L-l
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Page 2
Final Permit (.Continued)
k. PART II A. Management Requirements and B. Responsib?1i ties, contains
information that explains further requirements which are enforceable
as are all other provisions of the permit.
5 PART III Other Requirements specify certain reports that are required
and/or notifications that are necessary.
If you have any questions, please contact the Permits Section, Water
Quality Control Division at (303)^320-8333, Ext. 3361.
Very truly yours,
Arden Wa11 urn
Acting Chief
Permits Section
Water Quality Control Division
AW/ as
cc: EPA
District Engineer - Sam Cooper.
Health Department
208 Planning Area
Enclosure
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COLORADO DEPARTMENT OF HEALTH
Water Quality Control Division
4210 East 11th Avenue
Denver, Colorado 80220
TYPE OF FACILITY:
S.I.C. NO.:
LOCATION:
CONTACT:
RECEIVING WATER:
CLASS:
FACILITY DESCRIPTION:
STATEMENT OF BASIS
CITY OF NORTHGLENN
, PERMIT NUMBER: CO-0036757
WELD COUNTY
Major Municipal
4952
West i of Section 36, Township 1 North, Range 68 West of
the 6th Principal Merdian, just north of the Adams/Weld
County Line.
Richard P. Lundahl>
10701 Melody Drive, Suite
Northglenn, CO 80234
(303)+451-8326
313
Bull Canal
Unclass ified
Effluent Limited
Segment
The proposed Northglenn facility will treat sewage and
stormwater runoff in an aerated lagoon system with dis-
charge to the Bull Canal. The facility will consist of:
two parallel sets of three-cell aerated lagoons; a storage
reservoir with a capacity of 4362 acre-feet; chlorination
in the effluent channel; a pump station and wetwell; a
service building for aeration equipment, laboratory,
maintenance garage; public seminar room, and offices; and
a power substation.
Wastewater from Northglenn will be collected at a pumping
station in southeastern Northglenn and transported by
force main to the treatment facility. The incoming flow
will be measured before entering the first cell, which
will be a complete-mix basin. The second and third cells
in each set of lagoons will be facultative aerated treat-
ment lagoons. Total lagoon acreage will be 13-5 acres
with a 6.55 mgd capacity per each set of lagoons.
From the final lagoons, water will flow by gravity into
the storage reservoir. The purpose of this reservoir is
to regulate the flow discharged to the canal for irrigation.
Mixing equipment will be installed in the reservoir to
prevent stratification which could lead to ordor problems
during turnover periods. Hydraulics will allow the flex-
ibility to also store Bull Canal water in the reservoir.
A pumping station located in the northwestern portion of
reservoir will pump water to a discharge conduit to the
Bull Canal. This conduit will have chlorination equip-
ment for disinfection of the water as it flows to the
canal.
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COLORADO DEPARTMENT OF HEALTH
Water Quality Control Division
Statement of Basis - Page 2
Permit No.: CO-0036757
Steps will be taken during construction of the facility to
minimize seepage. The bottom of the lagoons will be lined
with clay and the inner side slopes will be protected with
an asphalt face. The outer slopes of the lagoons will be
planted with native grasses. Seepage from the reservoir
will be minimized by the impermeable bedrock that underlies
the reservoir. The bottom of the reservoir will have a clay
liner. The inner side slopes 'will be protected with asphaltic
concrete while the outer side slopes will be planted with
native grasses. The asphaltic liner will be backed by a
drainage system which will return leakage to the reservoir.
An embankment cutoff trench will also be constructed to
intercept seepage for return back to the reservoir.
A system of groundwater monitoring wells will also be
installed. These wells will be used to monitor any seepage
from the faci1ity.
RATIONALE FOR PERMIT LIMITATIONS AND CONDITIONS:
This project has become very controversial during its
development with many of its overall aspects complicating
the drafting of this permit. Northglenn is seeking an
Environmental Protection Agency construction grant for the
partial funding of the project and because of this federal
participation and the complexity of the situation, an
Environmental Impact Statement (EIS) process is being
prepared. Opponents have argued the project should not
be grant fundable because of doubt as to whether the
project is needed from a pollution abatement standpoint
(Northglenn1s sewage is presently treated by the Denver
Metropolitan Sewage Disposal District). Proponents have
argued the project is unique because it formally sets out
a multiple water use.
Another complicating factor is that the Northglenn treat-
ment facility is to be sited in Weld County and the Larimer/
Weld Regional Council of Governments (the City of Northglenn
is in Adams County and the Denver Regional Council of
Governments) and therefore, conflicts of jurisdiction
have developed. Additionally, a water rights issue has
been raised because wastewater for Northglenn, which is
presently treated and discharged to the South Platte River
would be, as the project is proposed, discharged for
irrigational purposes in the Bull Canal system. Irrigators
of the South Platte system have argued their rights
will be damaged by the project.
The Water 0_uality Control Division has been aware of all
these complex issues; however, it has had to proceed under
the assumption that the project will become a reality and
has strived to act. responsible in processing the permit
in a timely manner (as required by Colorado Law). All of
the complicating factors of this project have contributed
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COLORADO DEPARTMENT OF HEALTH
Water Quality Control Division
Statement of Basis - Page 3
Permit No.: CO-0036757
to this Division spending more time and effort in drafting
this permit than normally would be expended for a permit
for a discharge to an irrigation ditch. This permit
also has incorporated some requirements which are normally
not written into the permit.
An application for a NPDES permit was submitted on May 7, 1979.
On September 10, 1979, a draft permit was sent to public
notice for comments. The permit was drafted for a discharge
to the Bull Canal, a presently unclassified irrigation canal.
Because of the interest expressed about the draft permit
and the controversial nature of the project, the Division
held a meeting in Denver on October 10, 1979 to receive
additional public input. Most of the comments during the
meeting dealt with the public health aspects of the pro-
ject.
During the subsequent months EPA reopened the environ-
mental assessment for the project and, in fact, issued
on January k, 1980 a notice of intent to prepare an EIS.
The Division has been in close contact with EPA during
the preparation of the EIS so that issues associated with
the issuance of the NPDES permit could be defined.
Public health issues defined in the draft EIS are:
1. potential health risk from direct human contact with
treated wastewater which has received little or no
dilution;
2. potential health risk from human consumption of raw
edible crops irrigated with the treated wastewaters;
3. unsuitability of the Bull Canal as a water supply as
a result of treated wastewater discharge.
Each of these issues raise valid concerns. With the first
issue, there is concern of children using the Bull Canal
for recreational purposes or coming in contact with tail
water from land irrigated with Bull Canal water. The
tailwater presently flows unimpeded through the Town
of Fredrick. Regarding the second issue, there is the
potential for unrestricted use of the Bull Canal for
agricultural use. The Town of Dacono has a nonpotable
water system which uses water from the canal for irrigation
of private gardens. Also, the possibility exists that
members of Farmers Reservoir and Irrigation Company
(FRICO) may use the canal water to irrigate raw edible
crops. The third issue concerns the degradation of the
Bull Canal for use as a raw water supply for the Town
of Frederick and Ft. Lupton because of the anticipated
elevated nitrate levels from the discharge. A more
detailed discussion of these issues can be found in
the EIS.
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COLORADO DEPARTMENT OF HEALTH
Water Quality Control Division
Statement of Basis - Page 3
Permit No.: CO-0036757
In order to mitigate these concerns, EPA has proposed as
grant conditions that Northglenn:
1. disinfect their discharge to 200 fecal coliform
organisms per 100 milliliters;
2. either provide adequate disinfection of the Dacono
nonpotable water system or provide an alternate water
supply;
3. provide control facilities to prevent tailwater from
flowing into populated areas.
The fecal coliform disinfection proposal has generated
much concern in that the Division's draft permit required
disinfection to a level of 1,000 organisms per 100 milli-
liters. The rationale for this limit is based on the
recognized standard recommended in the "Water Quality
Criteria 1972" by the National Academy of Sciences, and
is even more restrictive than the recommended standard for
secondary contact recreation classification.
The NAS standard is for unrestricted irrigation use and
though not a recently established standard, there has
not been any conclusive evidence since to suggest this
widely accepted standard is no longer valid. Nevertheless,
in response to public concern, this Division requested
the Disease Control And Epidemiology Division of the
Colorado'Department of Health to review this standard
and all related research on this topic as it pertained
to the Northglenn project. It was the conclusion by the
professional staff that the proposed limit would protect
the existing use of the, Bull Canal.
Subsequent to a public meeting held in Frederick by the
Division on April 23, 1980, the City of Northglenn has
requested that the Division substitute a permit limitation
of 200 organisms per 100 milliliters for the originally
proposed 1,000 organisms/100 ml limitation. The
Division remains confident that the 1,000 limitations is
adequate to protect public health as related to the existing
use of the Bull Canal. However, in being responsive to
the requests of the permittee and because of the concern
of local residents, this Division has included the 200
limitation in the permit. This in no way is to be construed
as setting precedent or acknowledging the technical and
public health need for such a limit.
Regarding the proposed conditions that Northglenn provide
adequate disinfection to the Dacono water system and
provide tailwater control facilities, it is the Division's
position that conditions such as these are not within the
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COLORADO DEPARTMENT OF HEALTH
Water Quality Control Division
Statement of Basis - Page 4
Permit No.: CO-0036757
purview of the permit program which is directed to effluent
quality. These conditions, therefore will not be placed
in the permit. The 200 fecal coliform limitation should
satisfy any concern.
Other issues have been identified. These are:
1. the potential of groundwater pollution from lagoons
and reservoir seepage;
2. the potential of safety hazard from reservoir embankment
failure;
3- potential odor problem;
k. effect on relative land values adjacent to the treat-
ment site;
5. visual or aesthetic effect of the facilities;
The facility has been designed to minimize seepage from
the lagoons and reservoir. However, there is always the
potential of seepage finding its way to groundwater.
Because groundwater in the area is used for domestic needs
by nearby residence, contamination of this supply is of
obvious concern. Therefore, the Division has included
in the permit a requirement that Northglenn develop a
groundwater monitoring program acceptable to this Division.
The frequency of this groundwater monitoring has been
changed from quarterly to monthly sampling which will provide
a broader data base in which to evaluate the facility and
which will provide more responsiveness should contaimination
of the groundwater be detected. A contigency plan, a
permit requirement, is also to address steps Northglenn
will take should contamination of groundwater be shown
to be attriburable to Northglenn's operation. Northglenn
will also monitor the Bull Canal for evaluation of the
impact of its operation.
Concern has been expressed over the structural saftey of
the reservoir embankment. The design has been reviewed
by the State Engineer's office and found to be acceptable.
Concern for potential odor problems from the facility has
also been expressed. Though there is always a potential
odor problem from a sewage treatment facility, proper
operation of the facility - a necessity in order to meet
the NPDES permit effluent limitations - will minimize any
odor potential. Specifically, odor cannot be regulated
in a NPDES permit.
The aesthetic effect of the facility and the facility's
impact on adjacent land values are issues which cannot be
addressed in the NPDES permit process. These have been
considered during the site approval process.
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COLORADO DEPARTMENT OF HEALTH
Water Quality Control Division
Statement of Basis - Page 5
Permit No.: CO-0036757
A concern has been raised that should a permit violation
occur, what mechanism would be available to notify
regulatory authorities. Standard language in all permits
requires the permittee to notify in writing the WQCD
and EPA within 5 days the permittee is aware of a violation.
Because of the nature of the discharge (i.e. intermittent
releases of large volumes of water) and the concern over
public health, language has been added to the permit
requiring Northglenn to orally notify the WQCD and EPA
within 24 hours of becoming aware of a violation.
There have been considerable comments expressed over the
potential effects of nitrates from the discharge on
agricultural and water supply uses of Bull Canal water.
Public comments received indicate that the anticipated
relatively high levels of nitrates in the Bull Canal
water can adversely affect some nitrogen sensitive corps,
i.e. crops such as sugar beets which do not require nitrogen
beyond a certain growth stage. Statements have been
made that contracts between farmers and a sugar beet processor
do not allow application of fertilizer beyond July 15
of the year.
The Division responds to this in two ways. First, a
nitrogen balance using historic irrigating practices
shows that the amount of nitrates attributable to the
effluent is small compared to the amount from applied
commercial fertilizer. Besides, even commercial fertilizer
applied before July 15th remains available in the soil.
Secondly, the Bull Canal is unclassified and without a
numeric standard for nitrates. Until a numeric standard
is applied, the Division does not feel it is appropriate
to include a nitrate limitation in the permit.
For the reason given above, a nitrate limitation has not
been included to protect a potential drinking water supply
use. If the Bull Canal is designated a drinking water
supply usage in the reclassification process, then the
permit can be appropriately amended. The permit does
contain the standard reopener clause which allows the permit
to be revised should water quality standards and/or the
classification of the receiving stream be changed. It
should also be pointed out that runoff from agricultural
land back to Bull Canal will contribute a signigicant
amount of nitrates.
State Effluent Standards for BODj;, Total Suspended Solids,
Total Residual Chlorine, pH and Oil and Grease will be
applicable to the discharge. The designated discharge
point will remain the end of the outfall conduit to Bull
Canal. A compliance schedule for the development of an
industrial pretreatment program is also a requirement of
the permit. The permit is set to expire on June 30, 1983-
Jim Chubrilo
MaY 15, 1980
L-8
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Permit No.: CO-0036757
County: Weld
AUTHORIZATION TO DISCHARGE UNDER THE
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
In compliance with the provisions of the Federal Water Pollution Control
Act, as amended (33 U.S.C. 1251 et. seq.; the "Act"), and the Colorado Water
Quality Control Act (25-8-101 et. seq., CRS, 1973 as amended)
the City of Northglenn
is authorized to discharge from their Northglenn/FRICO Return Flow Facility,
located in the West i of Section 36, Township 1 North, Range 68 West of the
6th Principal Meridian, just north of the Adams/Weld County line,
to Bui 1 Canal ,
in accordance with effluent limitations, monitoring requirements and other
conditions set forth in Part I, II, and III hereof.
This permit shall become effective thirty (30) days after the date of
receipt of this permit by the Applicant. Should the Applicant choose to
contest any of the effluent limitations, monitoring requirements or other
conditions contained herein, he must comply with Section 2^-^-104 CRS 1973
and the Regulations for the State Discharge Permit System. Failure to
contest any such effluent limitations, monitoring requirement, or other
condition is consent to the condition by the Applicant.
This permit and the authorization to discharge shall expire at midnight,
June 30, 1983-
Signed this -^^day of. .-
COLORADO DEPARTMENT OF HEALTH
77
Brdetzman,
itor
Water Quality Control Division
12/79 L-9
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PART I
Page 2 of 22
Permit No.: CO-003&757
A. EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS - SEE ANY ADDITIONAL REQUIREMENTS
UNDER PART III.
1. Effluent Limitations
During the period beginning no later than immediately and lasting
through June 30, 1983 » the permittee is authorized to discharge
from outfall(s) serial number(s):Discharge Point 001, the end of the outfall con-
duit from the storage reservoir to the Bull Canal as referenced in Figure 1 S 2,
Effluent Parameter Discharge Limitations Pa9es 21 and 22:
Maximum Concentrations
mg/1 mg/1 mg/1
30-day avg. 7-day avg. Daily Max.
BOD5 30 a/
Total Suspended Solids 30 a/
Fecal Coliforms-Number/lOOml 200 c/
Total Residual Chlorine N/A
45
45
400
N/A
c/
N/A
N/A
N/A
0. 5
d/h/
pH - units shall remain between 6.0
and 9.0
d/.
Oil and Grease shall not exceed 10 mg/1 d_/ in any grab sample nor shall there
be a visible sheen.
This permit may be modified, or revoked and reissued to comply with any
applicable water quality standards and/or the classification of the
receiving stream if the standards are changed and/or the stream is
reclassified.
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PART I
Page 3 of 22
Permit No.: CO-0036757
A. EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS (Continued)
2. Monitoring Requirements
In order to obtain an indication of the probable compliance or
non-compliance with the effluent limitations specified in Part 1,
the permittee shall monitor and report all effluent parameters at
the following required frequencies.
Effluent Parameter
Flow - MGD (AF)
BOD5 - mg/1
Total Suspended Solids - mg/1 £/ **
Fecal Coliforms - Number/100 ml Daily
pH Daily
Oil and Grease **
Total Residual Chlorine - mg/1 Daily
Measurements Frequency
Daily
£/ **
\J Sample Type f/
Daily Totalized
Grab
Grab
Grab
Grab
Visual
Grab
** Samples shall be taken according to the following schedule:
Effluent Discharged
Mill ion Gallons/Week
0-58
53 - 116
117 - 17*
> 175
Required No. of Samples
one per week
two per week
three per week
four per week
This permit may be modified to require more or less frequent monitoring
if operating data so justifies.
See pages 7 and 17 of 22 for additional monitoring requirements.
Self-monitoring samples taken in compliance with the monitoring requirements
specified above shall be taken at the following location(s): 001, end
of the outfall conduit form the storage reservoir to Bull Canal as referenced
in Figures 1 and 2, pages 21 & 22.
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PART I
Pagek of 22
Permit No. CO-0036757
A. EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS (Continued)
3. Footnotes
a/ This limitation shall be determined by the arithmetic mean of a minimum
of three (3) consecutive samples taken on separate weeks in a 30-day
period (minimum total of three (3) samples); not applicable to fecal
conforms - see footnote c/.
Jb/ This limitation shall be determined by the arithmetic mean of a minimum
of three (3) consecutive samples taken on separate days in a 7-day period
(minimum total of three (3) samples); not applicable to fecal conforms -
see footnote c/.
c_/ Averages for fecal coliforms shall be determined by the geometric mean
of a minimum of three (3) consecutive grab samples taken during separate
weeks in a 30-day period for the 30-day average, and during separate days
in a 7-day period for the 7-day average, (minimum total of three (3)
samples).
d_/ Any discharge beyond this limitation as indicated by any single analysis
and/or measurement shall be considered a violation of the condition of
this permit.
e/ Quarterly samples shall be collected during the months of March, June,
September, December, if a continual discharge occurs, if the discharge
occurs on an intermittent basis, all the samples shall be collected
during the period when that intermittent discharge occurs.
JY See definitions, Part B.
£/ In addition to monitoring the final discharge, influent samples shall be
taken and analyzed for this parameter at the same frequency as required
as for this parameter in the discharge.
JV Monitoring is required only when chlorine is used for disinfection.
_[/ Monitoring is required only during periods of discharge. If "no discharge"
occurs, this shall be reported at the specified frequency. (See Part B).
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2/2/77
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PART I
Page 5 of 22
Permit No.: CO-0036757
B. MONITORING AND REPORTING
1. Representative Sampling
Samples and measurements taken as required herein shall be representative
of the volume and nature of the monitored discharge.
2. Reporting
Monitoring results obtained during the previous month shall be
summarized for each month and reported on applicable
discharge monitoring report forms, postmarked no later than the 28th
day of the month following the completed reporting period. The first
report is due no later than the 28th day of the month following the
month in which discharge commences. If no discharge occurs, "No
Discharge" shall b« reported. Duplicate signed copies of these, and all
other reports required herein, shall be submitted to the Regional
Administrator and the State at the following addresses:
Colorado Department of Health U.S. Environmental Protection Agency
Water Q_uality Control Division i860 Lincoln Street - Suite 103
4210 East llth Avenue Denver, Colorado 80295
Denver, Colorado 80220 Attention: Enforcement - Permit Program
3. Definitions
a. A "composite" sample, for monitoring requirements, is defined as a
minimum of four (4) grab samples collected at equally spaced two (2)
hour intervals and proportioned according to flow.
b. A "grab" sample, for monitoring requirements, is defined as a single
"dip and take" sample collected at a representative point in the
discharge stream.
c. An "instantaneous" measurement, for monitoring requirements, is defined
as a single reading, observation, or measurement using existing
monitoring facilities.
k. Test Procedures
Test procedures for the analysis of pollutants shall conform to regulations
published pursuant to Section 30A(h) of the Act, and Colorado State
Effluent Limitations (10.1.4), under which such procedures may be required.
5. Recording of Results
For each measurement or sample taken pursuant to the requirements of this
permit, the permittee shall record the following information:
a. The exact place, date, and time of sampling;
b. The dates the analyses were performed;
c. The person(s) who performed the analyses;
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PART I
Page 6 of 22
Permit No. 00-0036757
d. The analytical techniques or methods used; and
e. The results of all required analyses.
6. Additional Monitoring by Permittee
If the permittee monitors any pollutant at the location(s) designated
herein more frequently than required by this permit, using approved
analytical methods as specified above, the results of such monitoring
shall be included in the calculation and reporting of the values
required in the Discharge Monitoring Report Form (EPA No. 3320-1),
or other forms as required by the Division. Such increased frequency
shall also be indicated.
7. Records Retention
All records and information resulting from the monitoring activities
required by this permit including all records of analyses performed
and calibration and maintenance of instrumentation and recordings
from continuous monitoring instrumentation shall be retained for a
minimum of three (3) years, or longer if requested by the Regional
Administrator or the State Water Quality Control Division.
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PART I
Page 7 of 22
Permit No.: CO-003&757
C. SCHEDULE OF COMPLIANCE/BEST MANAGEMENT PRACTICES
The permittee shall manage the facilities to protect the existing
beneficial uses of the Bull Canal and ensure protection of public
health. Because of the unique situation of intergrated treatment,
Storage and canal facilities, the management and operation of the
system will likely determine how effective the permittee is in pro-
tecting public health. Therefore, the permittee shall design a
management and mitigation program and submit it to the Water Quality
Control Division at least 365 days prior to the initial discharge.
The program shall be subject to the approval of the Division and
the EPA. This program shall at a minimum address the following:
1. Bull Canal Monitoring Program. The City of Northglenn has
submitted to the WQCD a plan for monitoring the parameters
BOD, Fecal Coliform, Total Nitrogen, Nitrate Nitrogen, Chloride,
Total Dissolved Solids, Iron, and Cadmium at the following
locations:
a. Bull Canal upstream of Discharge Point 001 designated in
this permit; (sampled weekly)
b. Bull Canal at Dacono; (sampled weekly)
c. Discharge from terminal reservoir to Coal Ridge Ditch. (Sampled daily)
The City of Northglenn and the WQCD will mutually establish the exact
monitoring station locations.
2. Contingency Plan. The permittee should address what steps will be
taken should an upset condition occur whereby the effluent from the
storage reservoir is of a quality which does not or will not meet
effluent limitations and which might be deterimental to public health.
Also, the permittee should address what measures the City of Northglenn
will undertake !f groundwater under the facility site are shown to
be contaminated by the permittee's operations.
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PART I
Page 8 of 22
Permit No.: CO-0036757
D. SCHEDULE OF COMPLIANCE FOR PRETREATMENT PROGRAM DEVELOPMENT
Under the authority of Section 307(b) and 402(b)(8) of the Clean Water Act,
and implementing regulations (^OCFR 403), the permittee is required to develop
a pretreatment program. This program shall enable the permittee to detect
and enforce against violations of categorical pretreatment standards promulgated
under Section 307(b) and (c) of the Clean Water Act and prohibitive discharge
standards as set forth in kQ CFR 403.5.
On or before the dates specified below, the permittee shall accomplish I terns 1
through 15 , in order to implement an approvable pretreatment program.
The permittee shall:
1. Submit Evaluation of Present Legal Authorities by June 30, 1980.
*2. Submit Listing of Industrial (Non-Domestic) Users by June 30, 1980.
3. Submit Draft Industrial Waste Ordinance, Agreement,
or Contract (si by October 30, 1980.
*»• Submit Results of Sampling and Analysis of Industrial
Inputs to POTW System by December 31, 1980.
5- Submit Implementation Verification of Necessary Additional
Legal Authorities by June 30, 1981.
6. Submit Evaluation of Funding Mechanisms (User Charges, etc.)
to Sustain Approved Program by June 30, 1981.
7- Submit Draft Program for Industrial Input Monitoring by POTW
and/or Industries by October 30, 1981.
8. Submit Determination of Necessary Additional Monitoring/
Analysis Equipment and Structures by October 30, 1981.
9- Submit Specific Limits for industrial Inputs Identified as
Prohibited Discharges by December 31, 1981.
10. Submit Finalized Industrial Waste Ordianance, Agreement, or
Contract (s) by March 31, 1982.
11- Submit Finalized Program for Industrial Input Monitoring by
POTW and/or Industries by June 30, 1982.
12. Submit Completed Analysis for Categorical Standards Removal
Allowances, if Appropriate by June 30, 1982.
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PART I
Page 9 of 22
Permit No. : CO-0036757
SCHEDULE OF COMPLIANCE FOR PRETREATMENT PROGRAM DEVELOPMENT - (Continued)
14. Submit Request for Pretreatment Program Approval by October 30, 1982.
15. Attain Approval of Pretreatment Program by March 31, 1983-
16. Attain Total Program Implementation by Ju'Y '» 1983.
* Upon review of this submittal, the Water Quality Control Division
may determine that the subsequent items will not be required for submittal.
The terms and conditions of the POTW pretreatment program, when approved,
shall be enforceable automatically through the permittee's NPDES permit.
No later than 14 calendar days following a date identified in the above
pretreatment schedule, the permittee shall submit either a report of progress
or, in the case of specific actions being required by identified dates, a
written notice of compliance or noncompliance, any remedial actions taken,
and the probability of meeting the next scheduled requirement.
Any application for authority to revise categorical pretreatment standards
to reflect POTW removal of pollutants in accordance with the requirements of
40 CFR 403-7 must be submitted to the permit-issuance authority at the
time of application for POTW pretreatment program approval or at the time
of permit expiration and reissuance thereafter.
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PART II
Page 10 of 22
Permit No. CO-0036757
A. MANAGEMENT REQUIREMENTS
1. Change in Discharge
All discharges authorized herein shall be consistent with the terms and
conditions of this permit. The discharge of any pollutant identified
in this permit more frequently than or at a level in excess of that
authorized shall constitute a violation of the permit. Any anticipated
change in discharge location and/or facility expansions, production
increases, or process modifications which will result in new, different,
or increased discharges or pollutants must be reported by submission of a
new NPOES application or, if such changes will not violate the effluent
limitations specified in this permit, by notice to the State Water
Quality Control Division of such changes. Process modifications include,
but are not limited to, the introduction of any new pollutant not pre-
viously identified in the permit, or any other modifications which may
result in a discharge of a quantity or quality different from that which
was applied for. Following such notice, the permit may be modified to
specify and limit any pollutants not previously limited.
2. NoncompHance Notification
a. If, for any reason, the permittee does not comply with any maximum
effluent limitation specified in this permit the permittee shall
provide the Regional Administrator and the State Water Quality Control
Division with the following information, in writing, within five (5)
days of becoming aware of such condition:
(1) A description of the discharge and cause of noncompliance; and
(2) The period of noncompliance, including exact dates and time; or, if
not corrected, the anticipated time the noncompliance is expected
to continue, and steps being taken to reduce, eliminate and prevent
recurrence of the noncomplying discharge.
b. The permittee shall orally notify the Water Quality Control Division
and EPA within 2k hours of becoming aware of a permit violation.
c. The permittee, as soon as it has knowledge thereof, shall notify the
State Water Quality Control Division of any spill or discharge of any
pollutant, not otherwise authorized in this permit, which may cause
pollution of waters of the State.
3. Facilities Operation
The permittee shall at all times maintain in good working order and
operate as efficiently as possible all treatment or control facilities
or systems installed or used by the permittee to achieve compliance
with the terms and conditions of this permit.
k. Adverse Impact
The permittee shall take all reasonable steps to minimize any adverse
impact to waters of the State resulting from noncompliance with any
effluent limitations specified in this permit, including such accelerated
or additional monitoring as necessary to determine the nature and impact
of the noncomplying discharge.
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PART I I
Page H Of22
Permit No.CO-0036757
5. Bypassing (see additional requirements under Part III)
Any diversion from or bypass of facilities necessary to maintain compliance
with the terms and conditions of this permit, or any activity that results in
the avoidance of any required treatment for any process or run-off water, is
prohibited, except (i) where unavoidable to prevent loss of life or severe
property damage, or (ii) where excessive storm drainage or runoff would damage
any facilities necessary for compliance with the effluent limitations and
prohibitions of this permit. The permittee shall promptly notify the Regional
Administrator and the State Water Quality Control Division in writing of each
such diversion or bypass.
6. Removed Substances
Solids, sludges, filter backwash, or other pollutants removed in the course
of treatment or control of wastewaters shall be disposed of in a manner such
as to prevent any pollutant from such materials from entering waters of the
State.
7. Power Failures
In order to maintain compliance with the effluent limitations and prohibitions
of this permit, the permittee shall either:
a. Provide an alternative power source sufficient to operate the wastewater
control faci 1 ities;
or, if such alternative power source is not in existence, and no date for
its implementation appears in Part I,
b. Halt, reduce or otherwise control production and/or all discharges upon
the reduction, loss, or failure of the primary source of power to the
wastewater control facilities.
8. Any discharge to the waters of the State from a point source other than
specifically authorized is prohibited.
B. RESPONSIBILITIES
1. Right of Entry
The permittee shall allow the Director of the State Water Quality Control
Division, the EPA Regional Administrator, and/or their authorized representative,
upon the presentation of credentials:
a. To enter upon the permittee's premises where an effluent source is
located or in which any records are required to be kept under the
terms and conditions of this permit; and
b. At reasonable times to have access to and copy any records required to
be kept under the terms and conditions of this permit and to inspect any
monitoring equipment or monitoring method required in the permit.
c. To enter upon the permittee's premises to reasonably investigate any actual,
suspected, or potential source of water pollution, or any violation of the
Colorado Water Quality Control Act. The investigation may include, but is
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PART I I
Page 12 of 22
Permit No.CO-0036757
not limited to, the following: sampling of any discharge and/or process
waters, the taking of photographs, interviewing of any persons having any
knowledge related to the discharge, permit, or alleged violation, and access
to any and all facilities or areas within the permittee's premises that may
have any affect on the discharge, permit, or alleged violation.
2. Transfer of Ownership or Control
In the event of any change in control or ownership of facilites from which
the authorized discharges emanate, the permittee shall notify the succeeding
owner or controller of the existence of this permit by letter, a copy of which
shall be forwarded to the Regional Administrator and the State Water Quality
Control Division.
3. Availability of Reports
Except for data determined to be confidential under Section 308 of the Act,
Section 25-8-405 of C.R.S. 1973 and Regulations for the State discharge permit
system 6.1.8, all reports prepared in accordance with the terms of this permit
shall be available for public inspection at the offices of the State Water Quality
Control Division and the Regional Administrator.
As required by the Act, effluent data shall not be considered confidential.
Knowingly making any false statement on any such report may result in the
imposition of criminal penalties as provided for in Section 309 of the Act,
and CRS (1973) 25-8-610.
4. Permit Modification
After notice and opportunity for a hearing, the permit may be modified,
suspended, or revoked in whole or in part during its term for cause including,
but not limited to, the following:
a. Violation jaf any terms or conditions of this permit;
b. Obtaining this permit by misrepresentation or failure to disclose fully
all relevant facts; or
c. A change in any condition that required either a temporary or
permanent reduction or elimination of the authorised discharge.
Changes in water quality standards, control regulation or duly
promulgated plans would qualify as "a change in any condition."
5. Toxic Pollutants
Notwithstanding Part II, B-4 above, if a toxic effluent standard or
prohibition (including any schedule of compliance specified in such
effluent standard or prohibition) is established under Section 307 (a)
of the Act for a toxic pollutant which is present in the discharge and
such standard or prohibition is more stringent than any limitation for
such pollutant in this permit, this permit shall be revised or modified
in accordance with the toxic effluent standard or prohibition and the
permittee so notified.
2/2/77 L'2°
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PART I I
Page 13 of 22
Permit No. CO-00367.57
6. Civil and Criminal Liability
Except as provided in permit conditions on "Bypassing" (Part II, A-5)
and "Power Failures" (Part II, A-7), nothing in this permit shall be
construed to relieve the permittee from civil or criminal penalties for
noncompliance.
7- Oil and Hazardous Substance Liability
Nothing in this permit shall be construed to preclude the institution of
any legal action or relieve the permittee from any responsibilities,
liabilities, or penalties to which the permittee is or may be subject
under Section 311 of the Act.
8. State Laws
Nothing in this permit shall be construed to preclude the institution
of any legal action or relieve the permittee from any responsibilities,
liabilities, or penalties established pursuant to any applicable State
law or regulation under authority preserved by Section 510 of the Act.
9. Permit Violations
Failure to comply with any terms and/or conditions of this permit shall be
a violation of this permit.
10. Property Rights
The issuance of this permit does not convey any property rights in
either real or personal property, or any exclusive privileges, nor
does it authorize any injury to private property or any invasion of
personal rights, nor any infringement of Federal, State or local
laws or regulations.
11. Severability
The provisions of this -permit are severable, and if any provisions of
this permit, or the application of any provision of this permit to
any circumstance, is held invalid, the application of such provision
to other circumstances, and the remainder of this permit shall not be
affected thereby.
12. At the request of a permittee, the Division may modify or terminate a
permit and issue a new permit if the following conditions are met:
(a) The Regional Administrator has been notified of the
proposed modification or termination and does not object
in writing within thirty (30) days of receipt of notifi-
cation, and
(b) The Division finds that the permittee has shown reasonable
grounds consistent with the Federal and State statutes,
and regulations for such modification or termination and
(c) Requirements of public notice have been met.
2/2/77 L-21
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PART I I I
Page11* of 22
Permit No. CO-0036757
OTHER REQUIREMENTS
Additional Bypassing Requirements
If, for other reasons, a partial or complete bypass is considered necessary,
a request for such bypass shall be submitted to the State Water Quality
Control Division and to the Environmental Protection Agency at least sixty
(60) days prior to the proposed bypass. If the proposed bypass is judged
acceptable to the State Water Quality Control Division and by the Environmental
Protection Agency, the Bypass will be allowed subject to limitations imposed
by the State Water Quality Control Division and the Environmental Protection
Agency.
If, after review and consideration, the proposed bypass is determined to be
unacceptable by the State Water Quality Control Division and the Environmental
Protection Agency, or if limitations imposed on an approved bypass are
violated, such bypass shall be considered a violation of this permit; and
the fact that application was made, or that a partial bypass was approved,
shall not be defense to any action brought thereunder.
Testing
Test procedures shall conform with those procedures specified in the Federal
Register, Volume 38, Number 199, October 16, 1973. These procedures involve
the use of the latest edition of one of the following references:
1. "Standard Methods for the Examination of Water and Waste Water",
2. "ASTM", Annual Book of Standards, Part 23, Water, Atmosphere Analysis,
3. "Methods for Chemical Analysis of Waters and Wastes", Environmental
Protection Agency.
Discharge Point(s)
Discharge points shall be so designed or modified that a sample of the
effluent can be obtained at a point after the final treatment process and
prior to discharge to State waters.
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PART I I I
Page '50f 22
Permit No. CO-0036757
OTHER REQUIREMENTS (Continued)
Within three (3) months after the effective date of this permit, a flow-measuring
device shall be installed to give representative values of effluent volume
at some point in the plant circuit, if not already a part of the wastewater
plant.
The following locations of flow-measuring devices are required:
1. Facilities with detention times within the treatment system of 2k
hours or less: on the influent or effluent line, or within the system.
2. Facilities with detention times within the treatment system of 2k
hours or more: on the effluent line.
If permittee desires to locate a flow-measuring device in a location other than
in 1 or 2 above, then permittee shall submit a request to the Division giving
the specific location (by map). The request shall include a justification that
the location will give accurate measurements within ten (10) percent of the
actual flow being discharged. Installation shall be subject to approval by the
Division prior to installation.
At the request of the Regional Administrator of the Environmental Protection
Agency or the Director of the State Water Quality Control Division, the permittee
must be able to show proof of the accuracy of any flow-measuring device used in
obtaining data submitted in the monitoring report. The flow-measuring device
must indicate values within ten (.10) percent of the actual flow being discharged
from the faci1ity.
The limitations stated in PART I, Section A, are calculated on the basis of
gross measurements of each parameter in the designated discharge regardless
of the quantity and quality of these parameters in the plant flow unless
otherwise specified.
If the permittee desires to continue to discharge, he shall re-apply at least
one hundred-eighty (180) days before this permit expires.
Within sixty (60) days of the effective date of this permit, the permittee shall file.
a statement with the Environmental Protection Agency and the State Water Quality
Control Division which shall contain the names of the person or persons who are
designated to report conditions as noted in PART II, Section A, Paragraph 2a
(Noncompliance Notification), and as noted in PART II, Section B, Paragraph 7
(Oil and Hazardous Substance Liability). The permittee shall continually update
this list as changes occur at the facility.
The permittee is required to submit an annual fee as set forth in Section 25-8-502
C.R.S. 1973 as amended. Failure to submit the required fee is a violation of this
permit and «;il' result in the suspension of said permit and enforcement action
pursuant to Section 25-8-601 et. seq., 1973 as amended.
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PART I I I
Page 16 of 22
Permit No.: CO-0036757
OTHER REQUIREMENTS (Continued)
Expansion Requirements
Pursuant to Colorado Law, C.R.S. 1973 25-8-501(6), the permittee is
required to initiate engineering and financial planning for expan-
sion of the treatment works whenever throughput and treatment
reaches eighty (80) percent of design capacity. Whenever ninety--
five (95) percent of either the hydraulic or organic capacity of the
treatment works is met, the permittee shall commence construction
of the necessary treatment expansion.
In the case of a municipality, construction may be commenced, or
building permit issuance may be terminated, until such construction
is initiated, except that building permits may continue to be issued
for any construction which would not have the effect to increasing
th'e input of sewage to the municipal treatment works.
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PART III
Page 17 of 22
Permit No.: CO-0036757
OTHER REQUIREMENTS (Continued)
GROUNDWATER MONITORING PROGRAM
The permittee shall submit a re
later than 180 days prior to th
treatment facility.
This report on a proposed g
to monitor any movement of
area of the treatment site.
so as to monitor groundwate
dominant direction of groun
and background water qualit
The report shall also conta
minimum:
1. A large scale topog
3-
k.
This map sha
of the prop
ort to the Water Quality Control Division no
commencement of operational status of the
oundwater monitoring program designed
oilutants into the groundwater in the
Monitoring wells shall be situated
quality inside the site, in each
water movement away from the site,
for groundwater entering the site.
n the following information as a
aphic map of the site and surrounding
1 show the location and estimate water
sed groundwater monitoring points, in-
area.
levels
eluding an estimate of the rate of groundwater movement
and the direction
A description of t
casing size and th
method of installa
A description of ti
the analyses to be
removed from backg
qua 1i ty mon i tor i ng
be performed at le
monitoring point:
f the groundwater gradient.
e proposed monitoring wells including
perforated zone of the casing and the
ion.
e method of sampling and a listing of
performed on the wastewater plus water
ound and down-gradient groundwater
points. The following analyses shall
st on a monthly basis for each
Chlorides, mg/1
I ron
Cadmium
a) Nitrate and Ammonia Nitrogen, mg/1 e)
b) Total Dissolved Solids, mg/I f)
c) COD, mg/1 J g)
d) Fecal Coliform, #/100 mg
Before sampling, all monitoring wells must be pumped for a
minimum of ten min
when not sampling.
ates. Wells should be capped and locked
in
Groundwater uses
(domestic, irrigati
of site.
the area. Show location of all wells
on, etc.) in and within one-half mile
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PART I I I
OTHER REQUIREMENTS (Continued) Page l8 °f 22
Permit No. CO-0036757
Upon approval of the program by the Division, the monitoring points shall
be installed and the first monitoring report submitted no later than
sixty (60) days prior to the commencement of operational status of the
treatment facility. Monitoring reports shall be submitted on a monthly
basis thereafter and shall contain, at a minimum, the following information:
1. Monitoring point locations and numerical identification;
2. Monitoring well depth, surface elevation of well, and
depth to static water level of well;
3- The required analyses and the date the sample was taken
for each monitoring point.
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PART I I I
Page 19 of 22
Permit No. : CO-0036757
OTHER REQUIREMENTS (continued)
Industrial Wastes
A. As part of the pretreatment program development compliance schedule contained
in Part | of this permit, the permittee is required to submit a list of
industrial contributors to the treatment facility by October 30, 1980.
The permittee is also required to submit the results of a sampling and
analysis program of the individual industries by June 30, 1981.
This program shall include the identification of quantitative and
qualitative characteristics of the individual industrial imputs as well as
production data, where applicable, for at least the industrial contributors
for which categorical pretreatment standards have been or will be developed
(refer to Paragraph D of this section). Subsequent to the above initial
submission, the permittee shall continue to monitor and analyze these
industrial inputs on a routine basis, and shall submit the results to the
Division of this ongoing monitoring effort at six (6) month intervals on
June 30th or December 31st of each calendar year.
8. The permittee must notify the Division of any new introductions by new
or existing sources or any substantial change in pollutants from any
industrial source. Such notice must contain the information described in
"A" above and be forwarded no later than sixty (60) days following the
introduction or change.
C. Pollutants introduced into the treatment facility by any source of a
nondomestic discharge shall not inhibit or Interferewi th the operation
or performance of the facility. The following pollutants may not be
introduced into the facility:
1. Pollutants which create a fire or explosion hazard in the facility;
2. Pollutants which will cause corrosive structural damage to the
facility, but in no case discharges with pH lower than 5-0, unless
the facility is specifically designed to accommodate such discharges;
3- Solid or viscous pollutants in amounts which will cause obstruction
to the flow in sewers, or other interference with the operation of
the facility;
k. Any pollutant, including oxygen demanding pollutants (BOD, etc.)
released in a discharge of such volume or strength as to cause
interference in the facility;
5. Heat in amounts which will inhibit biological activity in the facility
resulting in interference, but in no case heat in such quantities
that the temoerature at the treatment facility influent exceeds 40°C
(lO^op) unless the facility is designed to accommodate such heat.
D. In addition to the general 1 imitations expressed above, more specific
pretreatment 1 imitations have been and will be promulgated for specific
industrial categories under Section 307 of the Act, including but not
limited to, those listed below. Compliance with these regulations is
required no later than three (3) years following the date of promulgation:
(See 40 CFR, Subchapter D, Parts kQQ through 500, for specific information).
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PART III STP
Page 20 of 22
OTHER REQUIREMENTS (Continued) Permit No, :CO-0036757
Automatic and Other Laundries
Coal Mining
Electroplating
Inorganic Chemicals Manufacturing
Iron and Steel Manufacturing
Leather Tanning and Finishing
Machinery and Mechanical Products Manufacturing
Miscellaneous Chemicals Manufacturing
Nonferrous Metals Manufacturing
Ore Mining
Organic Chemicals Manufacturing
Paint and Ink Formulation and Printing
Paving and Roofing Materials
Petroleum Refining
Plastic and Synthetic Materials Manufacturing
Pulp and Paperboard Mills and Converted Paper Products
Rubber Processing
Soap and Detergent Manufacturing
Steam Electric Power Plants
Text!le Mi 1 Is
Timber Products Processing
£. At such time as a specific pretreatment limitations become applicable to
an industrial contributor, the permit issuing authority may, as appropriate,
do the following:
(1) Amend the NPDES discharge permit to specify the additional
pollutant(s) and corresponding effluent 1imitat ions(s) consistent
with the applicable national pretreatment standards;
(2) Require the permittee to specify, by ordinance, contract, or
other enforceable means, the type of pollutant(s) and the maximum
amount which may be discharged to the permittee's facility for
treatment;
(3) Require the permittee to monitor its discharge for any pollutant
which may likely be discharged from the permittee's facility,
should the industrial contributor fail to properly pretreat its waste.
The permit issuing authority retains, at all times, the right to take legal
action against the industrial contributor or the treatment works, in those
cases where a permit violation has occurred because of the failure of an
industrial contributor to discharge at an acceptable level. If the permittee
has failed to properly delineate maximum acceptable industrial contributor
levels, the permitting authority will look primarily to the permittee as the
responsible party unless the contributor's discharge is obviously unaccceptable
under kO CFR, Subchapter 0 - Water Programs.
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Flow
Measuring
Device
Sanitary
4.645 MOD
Stormwater( Intermit tent)
0-6.605 MGD
Complete Mix
Aerated Lagoon
Aerated Lagoon
Aerated Lagoon
Fertilizer
Wastewater Flow
-**• — Sludge Flow
N5
VO
Long Term Storage
Bull Canal Discharge Point 001
Agricultural Reuse FRICO -*
Intermittent
0-29.09 MGD
Disinfection
Intermittent
0-29.09 MGD
«
TJ
01
(O
n>
o
-h
FIGURE 1
CITY OF NORTHGLENN
SCHEMATIC FLOW DIAGRAM MULTI-CELL AERATED LAGOON
NORTHGL.ENN/FRICO RETURN FLOW FACILITY
O
O
I
O
O
VjO
ON
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PART I I I
Page 22 of 22
Permit No. CO-0036757
APPRCKIMATE MEAN
DECLINATION. 1978
Discharg
. Point
i- I* . I • X-
-J U--J-.'1. JL;
S U R R Y**= Oil I L
,—""* •-
J-3
i 2 160 000 FEET
FIGURE 2
CITY OF NORTHGLENN TREATMENT FACILITY
LOCATION MAP
L-30
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APPENDIX M
SOUTH PLATTE - DEEP WELL ALTERNATIVE
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App end ix M
South Platte-Deep Well Alternative
As explained in Chapter 4, another alternative water supply for
Northglenn was presented to EPA just prior to completing the final
EIS. The following alternative analysis was developed too late to be
included within Chapter 4; however, EPA believes this alternative
warrants discussion. This analysis therefore, is presented here for
review by interested public and governmental officials.
As explained in the EIS, Northglenn decided to purchase South
Platte surface water (from Consolidated Ditches among others) to
secure sufficient make-up water following denial by the State Engineer
of their requested deep well permits. Based on recent opinions of the
Water Court, it now appears that Northglenn will be permitted some if
not all of the deep well water applied for. If so, Northglenn could
drill and produce this water, thereby having excess supply for its
design year needs. Northglenn indicates it would likely sell the
South Platte Consolidated Ditch water if deep well water is developed.
South Platte-Deep Well Alternative Presented by Opponents to the
Proposed Plan
On May 21, 1980, representatives of the Consolidated Ditches
Company presented the South Platte-Deep Well alternative to EPA. This
was followed by a meeting on May 29, 1980, with representatives of
Northglenn, Consolidated Ditches, and EPA to discuss this option. A
letter explaining this option from Mr. Raymond Hogan copied to EPA is
included in this appendix.
The suggested alternative by Consolidated Ditches Company is to
combine the deep well source and the South Platte surface for raw
water delivery. In a dry year, Northglenn's demand is projected to be
7340 acre-feet per year. To supply this amount, Northglenn could use
Clear Creek water rights (Farmers Highline, Church Ditch, and Berthoud
Pass Ditch) totaling 324 acre-feet, already purchased by FRICO shares
totaling 1070 acre-feet, and 2300 acre-feet from deep wells.
Actually, Northglenn's deep well yield would likely be less than 2300
acre-feet since some land owners may not grant permission to
Northglenn to pump their share of this water. Consolidated Ditches
suggests the remaining requirement for 3600 to 4000 acre-feet could be
pumped directly from the South Platte by means of the proposed
tributary well field or in combination with diverting additional water
from Grange Hall Creek. Under these circumstances, an exchange with
FRICO is no longer essential and presumably a wastewater system of
transporting sewage to Denver-Metro could be implemented. The South
Platte raw water could be treated at the Nortrhglenn water supply
M-l
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treatment facility now under construction. The South Platte water
would be diverted an accordance with the priority system and
Northglenn would return the historic depletion through Denver Metro
supplemented as necessary by release from storage.
As presented by Consolidated Ditches Company, this alternative
may require Northglenn to deliver to FRICO, 500 acre-feet per year in
order to break the FRICO exchange agreement. Under the Consolidated
Ditches plan, the total consumptive use to the South Platte would be
3010 acre-feet. Northglenn's replacement sources appear to be
adequate to replace this consumptive use. These sources include the
historic depletion credit for both the Clear Creek and South Platte
ditch rights, credit for the historic agricultural depletion of the
FRICO shares owned by Northglenn, and the total ammount of water
pumped from the nontributary wells. The replacement water will be
returned to the stream system at Denver Metro supplemented by returns
at other points or storage releases which may be necessary to protect
specific rights from injury.
Although EPA has not performed a cost analysis, the costs may be
expected to be somewhat higher than the proposed plan. Increased cost
of pipeline, pumping, treatment, storage and delivery to Denver Metro
plus the costs of upgrading and expanding the Metro facility must be
factored in. In addition, the cost of the negotiation of some
agreement under which Northglenn could connect to the Denver Metro
plant would be required. Water quality of this source may pose a
problem similar to that experienced by Thornton regarding their South
Platte wells. If this South Platte supply was obtained above the
Denver Metro outfall, then costs would further increase.
If the proposed exchange plan is implemented, initially, Thornton
will divert less water due to Northglenn's withdrawal from the
system. As Thornton extends it service and water demand increases,
Thornton will again divert water now delivered to Northglenn. If such
deliveries are made under the GASP program for five percent
augmentation as currently the case, no change would occur in river
flow over present conditions. If such deliveries are made under a
full augmenttion requirement, then the additional replacement
requirements placed on Thornton would mean Thornton must provide
replacement water equal to its total consumption use resulting in a
greater river flow. Under the South Platte-Deep Well Alternative,
additional return flow to the South Platte may result from Northglenn
developing the new deep well source.
As previously stated, the proposed plan to delivery water to
Northglenn from South Platte ditches will not affect stream flow since
full augmenttion of surface diversions is required under Colorado
water rights law. As explained above, Northglenn's withdrawal from
the Denver Metro facility will not affect river flow either. However,
M-2
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implementation of the South Platte-Deep Well Alternative could
slightly increase river flow due to development of a non-tributary
source.
EPA concludes that the South Platte-Deep Well Alternatives, along
with the Denver Metro wastewater system, has certain advantages
including additional water available to South Platte irrigators and
negates the need to mitigate certain public health risks associated
with the proposed exchange. Conversely, this proposal would not
include those benefits to agriculture as explained in Chapter 4 and
would again expose FRICO agriculture water to condemnation action. As
previously explained, implementation of EPA required mitigation
measures for the proposed exchange plan does not create a public
health hazard. Therefore, EPA concludes that since the South
Platte-Deep Well Alternative does not provide the agricultural
benefits of the proposed plan, it is not as favorable as the proposed
exchange plan.
M-3
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W. W. WHEELER AND ASSDCIATES. INC.
CONSULTING ENGINEERS
SUITE 2O1
77O WEST HAMPDEN AVENUE PHDNE
ENGLEWDOD. COLORADO BD11D 761-4131
May 22, 1980
Mr. Gregory J. Hobbs, Jr.
Davis, Graham & Stubbs
2600 Colorado National Building
950 Seventeenth Street
Denver, Colorado 80202
Re: #814 Consolidated Ditch-EPA
Dear Greg:
Attached is a Northglenn Water Use Schematic which depicts a
basic alternative to Northglenn's water management plan. The purpose
of this letter is to explain the basic alternative plan and to
suggest that EPA study the feasibility of this alternative in the
final EIS.
The basic assumption is made that Northglenn would not partici-
pate in the FRICO exchange or FRICO's reuse of Northglenn's sewage
effluent. From an engineering point of view, it appears to us that
Northglenn would still be obligated to provide FRICO with 500 acre-
feet of bonus water.
In a dry year Northglenn's demand is projected to be 7,3^0 acre-
feet. To supply this amount, Northglenn could obtain 320 acre-feet
of water from its Clear Creek water rights, 1,070 acre-feet from its
FRICO shares, and 2,000 acre-feet from deep weTTs. Northglenn's deep
well yield was reduced from 2,300 acre-feet per year to 2,000 acre-
feet per year to account for some land owners who may not grant per-
mission to Northglenn to pump their share of deep well water. The
remaining demand of 3,950 acre-feet would have to be supplied by
other sources. There are at least three alternatives for supplying
M-4
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Mr. Hobbs
May 22, 1980
Page 2
this water. First, Thornton could provide this supply. Second,
Denver should be contacted to see if they would be willing to supply
this water. Third, Northglenn could pump this water from the South
Platte either directly or indirectly by means of a Grange Hall Creek
diversion or through alluvial wells. This water could be treated at
a treatment plant as proposed for Northglenn near Stanley Lake.
The total consumptive use or impact to the South Platte for this
alternative would be 3,010 acre-feet. As shown in the table below,
Northglenn1s replacement sources appear to be more than adequate to
balance this consumptive use.
Historical Consumptive Use
or Replacement Credit
(Acre-Feet)
Replacement Source
Clear Creek Water Rights
FRICO Shares
Deep Wei Is
South Platte Ditches
Total
If Northglenn had not made the agreement with FRICO concerning
the bonus, the consumptive use Northglenn would have had to compensate
the river would be 2,480 acre-feet. It appears then, that without
the FRICO agreement Northglenn could have provided 2,7^0 acre-feet of
replacement water without purchasing the water rights in the South
Platte ditches.
Although we have not performed an economic feasibility study,
we suspect that this alternative would result in a smaller future
charge to Northglenn1s residents for water and sewer services than
the projected charge for Northglenn's water management plan. This
M-5
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NORTHGLENN WATER USE SCHEMATIC
f
CLEAR CREEK
FRICO SHARES 1,070
CONSUMPTIVE
USE
2,650
WATER
SOURCES
320 .
SOUTH PLATTE 3,950
'DEEP WELLS 2,000
7,340
i
FUTURE CONDITIONS - DRY YEAR
METRO SEWAGE-MINIMUM FRICO REPLACEMENT
SOUTH PLATTE-RAW WATER SUPPLY
NORTH-GLENN
4,020
SEWAGE
RETURN
870
EVAPORATION
30
STORAGE
530
500
CONSUMPTIVE
USE
A
330
RRIGATION
170
METRO SEWAGE
RETURN FLOW
LAWN IRRIGATION
RETURN FLOW
V
GRANGE HALL CREEK
SOUTH PLATTE WELLS
IRRIGATION
RETURN FLOW
SOUTH PLATTE
NOTE: All quantities in acre-feet per year
TOTAL CONSUMPTIVE USE 3,010
-------
\
~\
APPENDIX N
ANALYSIS BY NORTHGLENN'S ENGINEER OF APPENDIX E
-------
-------
APPENDIX N
Analysis by Northglenn's Engineer
of Appendix E
shevf FER & RolANd, INC.
Chicago Washington, D.C. Denver
Environmental Planning & Engineering • Solar Energy • Resources Management
May 23, 1980
Mr. Wes Wilson
EPA Region VIII
Environmental Evaluations Branch
1860 Lincoln Street
Denver, Colorado 80295
Re: Engineering-Science's Review of Northglenn
Proposed Wastewater Treatment System
Dear Mr. Wilson:
We received on May 9, 1980 a preliminary copy of a report
prepared by Engineering Science entitled "A Review of Proposed
Northglenn Wastewater Treatment System." Although Engineering
Science's cover letter states that the preliminary report was
sent only to the participants in the Northglenn treatment
workshop conducted by EPA, unfortunately this was not the case.
Consequently, a report containing discrepancies and errors is
publicly distributed. Obviously, it will be difficult for you
to correct this problem, but it is your responsibility to do so.
These comments are a part of the public discussion of the
issues prior to the publication of a Final Environmental Impact
Statement. In the spirit of scientific accuracy, these comments
should be included as an integral part of the Final
Environmental Impact Statement.
We have divided our comments into three areas of concern.
The first is in regard to the data collection, pilot plant
130 North Franklin Street • Chicago, Illinois 60606 • (312)236-9106
1660 S. Albion St. • Denver, Colorado 80222 • (303) 758-7653
N-l
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Mr. Wes Wilson
May 23, 1980
Page 2
studies and the basis of design for the mechanical portions of
the lagoon treatment. We can understand the hesitation on the
part of Engineering Science to give a full endorsement to a
design for which they are not responsible and the future
professional liability which might be implied from such an
endorsement. Nonetheless, most of the conclusions in the draft
report are based on a misunderstanding of the data used in the
design of the system and a superficial analysis of what "might,"
"could," or "maybe" happen in any mechanical design.
Our design is sensitive to these possibilities and several
redundancies have been included in the design to prevent these
possiblities from becoming actual problems. This design feature
was overlooked in the review. Of course, no one can say with
absolute certainty that this design or any other conventional
treatment plant design will work without some operational
problems until it is actually built and operated. This,
however, does not lead a reasonable design engineer to conclude
that such a system should not be built; if this were the case,
no sewage treatment plants would ever be built.
The State of Colorado is eventually responsible for the
approval of the sewage treatment plant design. This approval
was secured by Northglenn in the summer of 1979 and there have
not been any changes to the design since that approval. We
believe this approval speaks for itself.
The only item of significant discussion is whether or not
the treated wastewater, after long term storage in Bull
Reservoir, will experience algae growth at a level in excess of
30 parts per million. Since the 30 parts per million algae
(suspended solids) standard is not a public health issue, the
EPA and the State of Colorado have consistently relaxed this
standard for discharges from storage lagoons with a flow less
than 2 mgd. This is particularly true of lagoons which
discharge into streams used for irrigation purposes, since the
algae growth is beneficial to irrigators as a highly stable form
of organic nitrogen, and since it is not a signficant problem
for downstream drinking water supplies.
Northglenn1s flows will exceed 2 mgd and the system is not
eligible for this exemption. Northglenn, therefore, has taken
the 30 parts per million suspended solids standard as a given
and has instructed our firm to provide them with a design which
will meet the standard. Because the total system does not
solely rely on the mechanical design, most of the discussion on
the pros and cons of the mechanical system is not the key
issue. The key issue is whether or not the entire system is
capable of meeting the standards. Throughout the planning and
N-2
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Mr. Wes Wilson
May 23, 1980
Page 3
design of the Northglenn system, we have consistently
recommended to Northglenn that redundancies and contingency
plans must be readily available for all of the mechanical
elements of the plan. The control of algae is no exception in
this regard. There are several candidate non-mechanical
mitigation measures which are successfully practiced on a
continuing basis throughout the country to limit the growth of
algae in storage reservoirs. These mitigation measures are
included as a part of the overall plan. Although it is not a
common practice of the sanitary engineering profession to build
such a high level of redundancy in conventional sewage treatment
plant designs, we have done so in this case to provide the best
practical assurances that the water quality standards on the
Bull Canal will be met as a part of Northglenn's contractual
obligations with FRICO.
The second area of concern is in regard to the comparison
of the energy requirements for the Northglenn system and
treatment at Metro Denver. The comparison presented by
Engineering Science is misleading and unrealistic and does not
follow EPA guidelines. EPA performed a proper analysis of the
energy impacts as a part of the Negative Declaration on the
project in the Fall of 1978. That analysis concluded that the
Northglenn plan consumed less energy than treatment at Metro
Denver. Since 1978, Metro Denver has published a draft Facility
Plan describing in more detail the new facilities necessary to
meet its discharge permit requirements, Thornton has decided to
substantially reduce its participation in the Northglenn plan,
and Northglenn has finalized its design. These changes have
further enhanced the energy conservation aspects of the
Northglenn plan. If the Northglenn wastes were to be treated at
the Denver Metro Plant, 280 percent to 450 percent more energy
per unit quantity of water treated would be required. The
analyses to support this conclusion are included in this report.
The third area of concern is in regard to the mitigation
measures for algae control. Although we understand that
Engineering Science's report was not intended to provide
conclusions on the workability of these control measures, the
overall negative tone of the discussion is quite misleading to
the general public. It implies that it is impractical to
control algae in storage reservoirs. We both know this is not
the case, and we are providing additional detailed supporting
information.
We have organized our comments to respond to each of the
fourteen preliminary conclusions of Engineering Science's
report. For convenience, we have reproduced each of Engineering
Science's preliminary conclusions as an introduction to our
N-3
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Mr. Wes Wilson
May 23, 1980
Page 4
comments. This will facilitate the incorporation of our
reponses into the final EIS. We trust this review has been
provided in a timely manner. Please contact us if you have any
further questions.
Sincerely,
SHEAFFER 5 ROLAND, INC.
FRMrbs F. Robert McGregor, P.E.
Encl.
cc: Sheaffer
Lundahl
Musick
Seeley
Schuyler
McKinney
N-4
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SHEAFFER AND ROLAND, INC.
REVIEW COMMENTS
The following review comments are made on the May, 1980
draft Engineering-Science report on the proposed Northglenn
system. Each of the fourteen conclusions in the Engineering-
Science report are reproduced in numerical order and are
immediately followed by comments prepared by the professional
staff of Sheaffer and Roland, Inc.
(1) The collection period for data describing the raw
waste load to the proposed system spanned a 13-day
period in February and March of 1978. The data
collected were for the existing Northglenn waste-
waters only and did not include analyses of the
other sources, such as irrigation return flow and
storm water runoff, which also will be treated.
This data base does not represent a sufficient
sampling and analytical effort for the proposed
Northglenn wastewater treatment system. There is
no assurance that the two-week period represents
year round wastewater characteristics especially
the very important ammonia-nitrogen:alkalinity
ratio. The ammonia-nitrogen concentrations from
the sampling were abnormal for municipal waste-
waters and should have been investigated further,
and the quality of the additional sources of
wastewater and the new potable water source
(Standley Lake) should have been characterized and
taken into account in determining design waste-
water quality.
The statement that the Sheaffer and Roland analysis
"did not include analyses of other sources, such as irriga-
tion return flow and storm water runoff" is simply false.
The City of Northglenn, in a two year cooperative
program with the U.S. Geological Survey has extensively
sampled stormwater runoff and irrigation return flow in five
separate locations within the City. One of these locations
is the actual point from which the stormwater and irrigation
return flow will be intercepted for treatment. This data
base represents an unusually extensive source of information
far more detailed than is normally available for the design
of a wastewater treatment system.
The 1978 wastewater sampling program also included
tests of the Westminster sewage. Since Westminster uses
N-5
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-2-
Standley Lake as its water supply, this data provided a
basis for estimating the changes in sewage quality which
could be expected from the new water source.
The South Platte River has been analyzed extensively
over the past several years and this data is available
through the EPA STORET system.^ij
All of the above data was considered in the design of
the Northglenn system. This level of effort far exceeds the
normal practice for the design of sewage treatment systems
and represents a sound basis for proceeding with confidence
on a final design.
The reference to "abnormal" ammonia level in the waste-
water is unsubstantiated and incorrect. Commonly accepted
ammonia levels in domestic wastewaters normally fall in the
range of 12 to 50 mg/l.t2' The Northglenn wastewater falls
well within this range and can not be considered abnormal
for a collection system like Northglenn"s with very little
inflow/infiltration.
We agree with the observation made by Engineering-
Science concerning the critical nature of the ammonia nitro-
gen/alkalinity ratio. The wastewater sampling program
suggested that an ammonia nitrogen/alkalinity ratio of 0.1
should be expected for the Northglenn wastwater. Normal
domestic wastewater can be expected to have a ratio of 0.2 to
0.3. The lower the ratio, the more difficult it will be to
limit the growth of algae by limiting the amount of available
carbon (alkalinity). As a recognition of the importance of
this ratio, the Northglenn system is conservatively designed
using the 0.1 ratio. If for some reason, the actual ratio is
closer to the normal range, the system will operate even
better than predicted.
(2) The pilot-plant studies of aerated lagoon treatment
using the ^detention times and three-series-cell
concept proposed for Northglenn were professionally
performed and the results were typical of the treat-
ment expected for long detention-time aerated la-
goons. Three problems exist, however, in applying
the results of these studies directly to the
proposed Northglenn wastewater treatment system:
(a) Lawrence, Kansas, wastewaters, not a composite
representing the actual wastewater to be
treated (City of Northglenn, irrigation return
N-6
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-3-
flow, and storm water runoff), or City of
Northglenn wastewaters, were used for the
tests and differences in ammonia and
alkalinity relationships between the
wastewaters as well as other differences do
not appear to have been adequately evaluated.
(b) There was insufficient run time under cold-
weather operating conditions for the pilot
facility to exhibit the response of such
systems to the low temperatures which may be
expected to occur in the full-scale facility.
(c) The effect of the proposed Bull Canal Reser-
voir on effluent quality from the proposed
system was not effectively considered in the
pilot studies.
The possible differences between the Lawrence, Kansas
and Northglenn wastewater were carefully considered as a part
of the pilot studies "professionally performed" by Dr. Ross
McKinney. The pilot studies referenced on page 11-14 of your
report purposely selected wastewater from "Lawrence, Kansas,
since it had characteristics similar to those of Northglenn,
Colorado."
These pilot studies, however, did not simply stop at
testing the Lawrence wastewater in its normal form. As
referenced on page 11-14 in report, both a low ammonia level
(Pilot Study B) and a high ammonia level (Pilot Study A)
wastewater were tested.
As previously mentioned, the actual design considered
the differences between the quality of the wastewater used in
the pilot plant and the quality of the sewage, stormwater,
and irrigation return flow water expected in the Northglenn
system. Engineering-Science's reference to "other differ-
ences" is not specific in terms of its effects on the
proposed design. Thus, it is not clear what is meant by this
comment. We are prepared to respond concerning these "differ-
ences" as soon as some specific items are identified by
Engineering-Science.
In regard to cold weather effects, the pilot plant was
operated during the months of October and November in the
range of 5 to 17°C with 50% of the temperatures 7°C or less.
These temperatures are referenced on page 11-16 of your
report. Since the pilot plant was more shallow and was not
insulated, it tended to operate at colder temperatures than
N-7
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would be expected in the full scale system. This fact is
also referenced on page 11-15 of the Engineering-Science
report. These October and November temperatures simulated
the effects of a full scale operation during the critical
winter months of January and February. Further comments on
lagoon temperatures are provided under item 11.
Engineering-Science's opinion concerning the effect of
the Bull Canal Reservoir vis-a-vis the pilot studies is
vague. Perhaps Engineering Science could suggest a specific
pilot plant design which would provide a more appropriate
model of the reservoir's effects. We can provide further
comment on this matter if Engineering-Science were to provide
a specific opinion or alternative pilot plant design.
(3) The proposed Northglenn wastewater treatment system
should under most conditions have no trouble meet-
ing the proposed BOD5 limits for the Bull Canal
Reservoir effluent. Two situations could occur
which could cause the permit BODg levels to be
exceeded:
(a) During summer or warm-weather operation, there
exists a potential for high algal levels in
the effluent from the reservoir. If the algae
levels are high enough, the attendent BOD5
contribution could cause permit limits to be
exceeded.
(b) During winter operation, the treatment effic-
iency of the three-stage aerated lagoon will
be significantly reduced. If the effluent
BOD_ from the aerated lagoons reaches a high
enough level for a long enough period of time,
the effluent from the reservoir could be
affected and the effluent BOD- could exceed
permit requirements. The possibility for high
flow rates due to storm water runoff during
winter operation, which would decrease average
treatment time in the aerated lagoons and
further decrease BOD5 removal efficiency due
to cold weather, further increases the risk of
the effluent BODc exceeding permit limits
during winter operation.
We agree with Engineering-Science's comment that the
proposed system should have "no trouble meeting the proposed
BOD5 limits for the Bull Canal Reservoir effluent." Their
N-8
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-5-
reference to two possible situations which might cause the
permit BODc levels to be exceeded are highly speculative and
are without specific foundation.
The inference that algae levels could become so high as
to cause a large BOD demand in excess of the permit levels
ignores the proven methods of algae control commonly used in
storage reservoirs.
In regard to the comment concerning a high loss of BOD-
treatment efficiency during cold weather operations, we can
only agree with the Engineering-Science comment on page 11-37
that "this possibility is rather remote."
The statement concerning the major loss of treatment
efficiency during high flows is difficult to believe and is
directly contradictory to a statement made on page III-7
concerning a conventional treatment plant. It is extremely
difficult, if not impossible, to understand how stormwater
could have such an adverse effect on an aerated lagoon with a
detention time of fourteen days when it will not adversely
effect a conventional treatment plant with only a few hours
detention time.
(4) The probability that the proposed system will con-
tinuously meet effluent TSS requirements (30 mg/1
monthly average and 45 mg/1 7-day average) is
believed to be rather low. The probability of
exceeding the permit requirements in the summer due
to levels of algae growth in Bull Canal Reservoir
is high. Another factor which could contribute to
high effluent TSS during the summer is the poten-
tial for high influent flow rates carrying large
sediment loads during periods of minimum reservoir
volume. During winter operation, the effluent TSS
should, however, pose no problem.
The statement of "belief" that the proposed system will
probably not meet effluent TSS requirements due to algae is
apparently based on a misunderstanding of several technical
items as described above.
The statement by Engineering-Science concerning sediment
loading during high flow periods is unclear. Perhaps it was
thought the stormwater itself would carry a heavy sediment
load to the lagoons. This is a highly unlikely event, however,
due to the fact that the heavy flows will be from the South
Platte River wells which will carry virtually no sediment, or
N-9
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from Grangehall Creek after sediment deposition in the
Grangehall Creek detention pond.
Perhaps this statement was speculating on the possi-
bilities for a carryover of sediments from the lagoons to the
reservoir. This is also highly unlikely because the lagoons
have detention time of 5 days even if the makeup system is
operated continuously at full capacity, because the third
aeration system is designed to preclude the resuspension of
solids and because a dead storage area has been designed at
the south end of the reservoir to capture any sediment carry-
over.
(5) A key operational feature of the proposed three-
stage lagoon system is the achievement of essen-
tially complete nitrification and the attendent
removal of alkalinity in the second and third-stage
aerated lagoons. This capability is necessary to
achieve the carbon limiting system which is design-
ed to limit algal growth in the final reservoir.
Due to the very low temperatures expected in the
second and third lagoon stages during cold-weather
operation (below 7 and 2 degrees C for three months
in cells 2 and 3, respectively) adequate nitrifica-
tion to achieve this goal will not be possible. A
second contributing factor to low nitrification
levels in the winter will be increased BOD_ load-
ings on the second and third lagoon cells due to
cold weather reductions in BOD5 removal effic-
iencies. This increase in caroonaceous demand will
further inhibit nitrification due to the reduced
capability of the nitrifying organisms to compete.
The nitrification process does not stop, but only slows
down, under cold water conditions. The figure on page 11-35
of the Engineering-Service report confirms this fact. This
phenomenon was recognized.and its effects were incorporated
into the lagoon design.1 } This is actually one of the ad-
vantages of a lagoon over a conventional treatment system
designed to achieve nitrification. When the process slows
down in a conventional treatment system, there is inadequate
detention time for nitrification. The Northglenn system,
however, provides adequate detention times and 75% nitrifi-
cation can be achieved in the critically cold month of
January. Although this is not complete nitrification, it is
adequate to achieve the desired effluent quality.
In the event additional nitrification is desired, fixed
redwood media racks could be installed easily and inexpensiv-
ely at a later date.
N-10
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-7-
Comments regarding the temperature effects on the lagoons
during cold weather periods are included under item 11. The
comment regarding the possible carryover of carbonaceous BOD
to the third cell may occur in a system with a low level of
mixing in the first cell but it will not occur with a high
level of mixing as included in the Northglenn design.
(6) The capability of the proposed Northglenn system to
maintain carbon limiting conditions to inhibit
algal growth in the Bull Canal Reservoir and thus
attain effluent TSS requirements is dependent on a
complex series of reactions and interactions. No
controls of phosphorus or nitrogen are proposed,
and it is recognized that sufficient amounts of
these nutrients will be available to support large
algal growths. The ability of the proposed system
to achieve the desired carbon limiting conditions
is dependent upon many factors. The following are
believed to be the most important of these factors:
(a) essentially complete nitrification in the
aerated lagoons with attendent alkalinity
removal;
(b) 30 to 35 mg/1 of ammonia-nitrogen in the raw
waste on a continuous basis;
(c) essentially complete removal of carbonaceous
BOD_ in the aerated lagoons; and
(d) exceptionally low, for aerated lagoons,
effluent TSS from the lagoons to the reser-
voir.
The high potential for BOD5 losses in the 30 to 50
mg/1 concentrations, the high potential for low or
no nitrification rates and thus high alkalinity
during winter operation, the carryover of organics-
containing TSS from the lagoons to the reservoir,
and the direct transfer of carbon dioxide from the
atmosphere to the reservoir combined to make it
unlikely that a carbon limiting system can be main-
tained in the reservoir.
Responses to items a, b and c are included in other
sections of this report. Item d is vague in its definition
of "exceptionally low." The effluent TSS from the lagoons to
the reservoir in the final design are within the limits
typically found for a lagoon with low levels of mixing
N-ll
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-8-
smilar to the cell 3 design. Perhaps the concern expressed
by Engineering Science is predicated on the full continuous
usage of the entire blower capacity available for cell 3.
This capacity will not be used continuously/ but will be
available on a stand-by basis to accomodate any unusual short-
term loadings. If any unusual unforseen problems develop,
the aerators nearest to the outlet could be turned off to
encourage further settling and the blower capacity could be
reallocated to other portions of the system.
In its statements concerning the possible carbon dioxide
transfer from the atmosphere, Engineering-Science did not
even attempt to quantify the potential for algae growth. The
maximum contribution of carbon dioxide from the atmosphere
would result in a potential maximum algae growth of 4-5
mg/1.^ ' This potential was considered in the design of the
systems and will not cause effluent limitations to be
violated.*31)
(7) The proposed Northglenn system should exhibit
excellent removals of fecal coliforms due to both
the long detenton times through the aerated lagoons
and Bull Canal Reservoir and the capability of
chlorinating the reservoir's effluent. The State
of Colorado has proposed effluent fecal coliform
requirements of 1,000/2,000 colonies per 100 ml for
the 30-day and 7-day averages for the reservoir
effluent. Only extreme circumstances such as
severe short-circuiting in the reservoir or com-
plete loss of biomass in the aerated lagoons could
produce excessive effluent levels under these
requirements. For the 1,000/2,000 limits, the
necessity for chlorination, proposed for as-requir-
ed operation, should be minimal. EPA will require
stricter limits of 200/400 colonies per 100 ml.
These limits could very well require chlorination
of the reservoir effluent for considerable periods
of time and possible at all times.
(8) The design of the proposed Northglenn system, which
utilizes three aerated lagoons in series with a
long detention time in the final reservoir should
result in a very low potential for problems con-
cerning the transmission of waterborne diseases due
to the influent wastewaters. Add to this the capa-
bility of chlorinating the effluent from the
reservoir if the fecal coliform level increases and
the system appears to be adequately safeguarded in
terms of waterborne disease transmission potential.
N-12
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-9-
We agree with the conclusions in statements 7 and 8.
(9) The design of the aeration system for the first
aerated lagoon cells will not be capable of main-
taining complete suspension of suspended solids.
This is due primarily to the geometry of the cells
and the effective zone of complete mixing for
static aerators. Thus, some settling of suspended
solids on the sidewalls of the first-stage lagoons
can be expected. This is not expected to seriously
impair system efficiencies. It does, however/
represent a departure from the system specifica-
tions as set forth by Sheaffer and Roland, Inc. and
Dr. McKinney.
We agree there may be some minor deposition of solids
along the outer slopes of Cell I. This deposition, however,
will not be a significant source of odors and we agree with
your statement that it will not seriously impair system effic-
iencies. We are in the process of clarifying our specifica-
tions on this matter to avoid any confusion during the award
of the construction contracts for the lagoons.
(10) The location of static aerator tubes near the
effluent structures in the third-stage lagoons may
cause problems in terms of effluent TSS concen-
tration from the third lagoons. These aerators,
when in use, may keep suspended solids which might
otherwise have settled out from settling. The
intermittent use of these aerators could lead to
short-term high TSS concentrations in the lagoon
effluent due to resuspension of previously settled
solids in the areas around these aerators.
Our response to this statement is included under item 6.
(11) The temperature calculations for cold-weather
operation made by Sheaffer and Roland, Inc. utilize
an equation designed for quiescent lagoons. The
temperatures thus calculated for winter conditions
are too high for the statically aerated and mixed
lagoon system proposed for Northglenn. The nega-
tive effects of cold weather on BOD5 removal and
nitrification during winter operation cited prev-
iously may thus be further magnified.
This conclusion is both unsubstantiated and inaccurate,
and appears to be based only upon the personal opinion of
Engineering-Science reviewers. The temperature calculations
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-lO-
used by Sheaffer and Roland, Inc. are specifically applicable
to aerated lagoons and have been verified by extensive
comparisons to existing aerated lagoon systems.
Engineering-Science maintains on page III-5 that
the temperature calculation underestimates the heat losses
from mixed lagoons and as a result, the design treatment
efficiencies will not be achieved:
The temperature loso calculations prepared for the
aerated lagoon system by Sheaffer and Roland, Inc. are
shown in Table III-l. These calculations underestimate
the heat loss from mixed aerated lagoons. The calcu-
lation procedure shown on the table is for quiescent
lagoon systems. This causes major errors in estimating
heat loss for aerated-mixed lagoons for two reasons:
(1) the mixing action continuously brings warmer
subsurface waters to the surface thus allowing addi-
tional heat transfer to the atmosphere, and (2) the
mixing action prevents the formation of a relatively
stable thermal zone at the surface which normally
inhibits heat transfer, in quiescent lagoons, to the
lower levels by maintaining a low differential tem-
perature at the air/water interface to impede convective
heat transfer (i.e., the upper water layer acts as an
insulator for the lower layers).
Thus, the estimates of BOD5 removals and nitrification
which have already been questioned may be even more
seriously impacted due to lower than anticipated water
temperatures in the aerated lagoons and reservoir. As
an example, by assuming that the surface heat exchange
coefficient (k) is double "that used by Sheaffer &
Roland, Inc. in their calculations (this assumption is
believed to be a conservative assumption in terms of
comparison to what the actual k values are for stati-
cally aerated lagoons), the January lagoon temperatures
calculated would be 8.5 degrees C in cell number 1
(compared to 10.5 degrees C), 1.9 degrees C in cell
number 2 (compared to 5.4 degrees C), and -2.2 degrees C
in cell number 3 (compared to 0.3 degrees C). At these
low temperatures, nitrification and BODc removal would
be almost nonexistent in the second and third cells.
Theabove statements by Engineering-Science are based on
their belief that the calculation procedures used in the
design are not applicable to aerated lagoons. Engineering-
Science's beliefs, however, are not supported by any pub-
lished reference or empirical data. The simple fact is the
N-14
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-11-
equation is intended to be used for aerated lagoons:
Aerated lagoon temperatures can be estimated with a
relationship derived from a thermal energy balance
across a complete mix system...to determine the lagoon
water temperature during the coldest week of the year,
the value of the surface heat exchange.coefficient k can
be assumed to be equal to 0.7 x 10
o
The accuracy of this calculation was confirmed by the
author using actual operating data collected form numerous
full scale systems in Oregon, Ohio, Indiana and Texas. Addi-
tional research by others has confirmed that mixing is not a
major factor in determining an appropriate k value even for
lagoons with a much higher level of mixing.* '
The use of the equation is further substantiated by the
Niwot, Colorado and Windber, Pennsylvania aerated lagoons.c'
Although these systems are subject to higher thermal losses
than the Northglenn design, their water temperatures have not
equalled the extreme cold postulated by Engineering-Science.
The Niwot system contains a 15-day detention time
surface aerated lagoon which receives raw influent wastewater
and discharges to a quiescent second .cell. The water temper-
ature of the first cell was monitored over the winter of 1973
1974. The lowest temperature reported was 2°C. This is
significantly higher than the water temperatures predicted by
Engineering-Science for the third cells of the Northglenn
system in spite of the fact that the Niwot first cell has
more detention time, a higher surface to volume ratio and a
more turbulent form of aeration than the Northglenn lagoons.
In the case of the Windber, Pennsylvania, aerated lagoon
system, the influent and effluent wastewater temperatures
from the 47-day three-cell aerated system were monitored over
a three-year period. At no time did the effluent wastewater
temperature drop below 2°C in spite of longer detention
times, higher surface to volume ratios an a climate more
severe than that of Northglenn. It can therefore be con-
cluded that the temperature calculations used by Sheaffer &
Roland are adequately documented, appropriately conservative,
and applicable to the Northglenn design.
The arbitrary doubling of the surface heat exchange
coefficient k is arbitrary and without substantiation.
Exactly who believes that doubling k is an appropriate
assumption is not discussed. One must, therefore, assume
that this is only the personal opinion of the Engineering-
N-15
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-12-
Service staff. It is difficult to accept this opinion in
light of the actual operating data which does not support
such an opinion. The weakness of their opinion is also
betrayed by the results which would follow if it were true
(i.e. a water temperature of -2.2°C in cell 3 is an
impossibility for liquid water). This statement, therefore,
incredibly seems to imply that the water in cell 3 will be a
solid block of ice. This type of an unsupported analysis
does not do justice to the EIS process.
(12) The aeration energy requirements for the proposed
Northglenn wastewater treatment system were
compared to the estimated total energy require-
ments for treatment using extended aeration/
activated sludge, and rotary biological contac-
tors. The Northglenn aeration energy requirements
are from 20 to 800 percent greater than the
estimated energy requirements for these other
systems.
(13) The total estimated energy requirements for the
proposed Northglenn wastewater treatment system,
including aeration and conveyance energy and other
miscellaneous requirements, were compared to the
estimated energy for conveyance to and treatment
by Denver Metro. The results of this comparison
indicate that the proposed Northglenn wastewater
treatment system will require approximately 60
percent more energy than treatment by Denver
Metro.
These conclusions are based on a comparison of extremely
unrealistic conditions and are inconsistent with the EPA
regulations on energy impact analyses. As a result, they
are misleading to the public and are not worthy of inclusion
in the final EIS. The conclusion of a proper analysis is
that treatment at Metro Denver will require the consumption
of 280% to 450% of the energy required for the Northglenn
proposal.
EPA guidelines for energy impact analyses are found in
the regulations.^ ' The intent of these regulations are
further explained in an EPA handbook for the Preparation of
Environmental Assessment of Construction Grant Projects:
N-16
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-13-
Because of the recently increased concern about the
limited resources available to meet our energy needs,
the environmental assessment should include an analysis
of energy impacts. Impacts include the energy required
to operate the treatment plant, to manufacture chemi-
cals used in wastewater treatment and to meet the deg
mand of future population and industrial complexes.1 '
The regulations also require that the use and recovery
of energy and scarce resources such as nutrients be included
in the analysis.™' Nitrogen fertilizers are an energy
intensive product which will be conserved under the North-
glenn plan through the Agricultural Reuse Manual. The appro-
priate credits for the recovery of these energy-intensive
nutrients should therefore also be included in the analysis.
The proper type of an analysis was submitted to EPA in
the Fall of 1978 and was included in the Negative Declara-
tion, f10'11' That analysis concluded that the Northglenn
plan will consume 6 to 23% less energy than treatment at
Metro Denver to meet current discharge permit requirements.
Although that analysis was based on a system intended to
treat a larger portion of Thornton sewage than the current
plan, it is unclear why Engineering Science chose to abandon
that type of analysis and substituted an analysis which
ignores several energy consuming items at Metro Denver, used
several treatment alternatives which are either incompatible
with the Metro Denver system or are incapable of meeting the
discharge permite requirements, overestimated the energy
requirements of the Northglenn plan, and ignored the energy
recovery aspects of the Northglenn plan.
An updated energy budget for the Northglenn plan is
included in Table 1. It includes the energy requirements at
the full design flow rate of 4.64 MGD and includes suffic-
ient energy to meet the design effluent requirements with
the expected flow variations due to the various makeup water
sources.
The collection and interceptor system energy require-
ments are based on the already completed final system design.
They are 36% less than the estimates prepared by Engineering-
Science. The largest part of the discrepancy is believed to
be the result of the fact that Engineering-Science improperly
included the energy requirements of the makeup water system
in its calculations. It is not consistent to include the
makeup water for the Northglenn alternative since it is not
included for the Metro Denver alternative.
N-17
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-14-
Th e aerated lagoon energy consumption is also based on
the final design and the expected level of performance of
the system. The energy requirements of Cells IA and IB are
governed by mixing which in turn is governed by the volume
of water in these cells. The mixing requirements, there-
fore, do not vary with flow rate and the actual requirements
will average 134 horsepower. The achievement of less than a
complete mix along the outer edges of cells IA and IB is not
expected to hinder system performance.^12' The installed
horsepower of 200 is included for safety purposes only for
those short periods of time when oxygen transfer require-
ments might exceed mixing requirements. It is not appro-
priate to include this redundancy in estimates of energy
requirements any more than it is appropriate to include the
total installed horsepower capacity at a conventional treat-
ment plant.
The energy requirements for Cells IIA and IIB are
governed by oxygen transfer requirements. Based on an oxy-
gen 'transfer efficiency of 1.0 Ib. of oxygen transfer per
horsepower hours, 266 year around average horsepower is
adequate to provide the desired level of treatment. The
aeration system as it is designed has been shown to transfer
3.0 Ibs. of oxygen per horsepower hour and it is possible to
justify the use of only 90 horsepower in.cells IIA and IIB
based on aeration requirements alone.^ ' Such a low level
of horsepower, however, may not achieve the desired level of
mixing in Cells IIA and IIB. Thus, the estimates of energy
requirements are based on a mid range horsepower requirement
of 178. Additional redundancy is also available since 400
horsepower will be installed and reserved for Cells IIA and
IIB. This additional horsepower, plus the conservatively
low assumptions concerning oxygen transfer efficiencies will
more than adequately accomodate variations in rate and
quality of wastewater flow. It is intended, however, only
for occasional use and most certainly will not be used on a
continuous basis. This design approach provides a high
degree of safety in the expected performance of the system.
Engineering Science's presumption that 280 horsepower will
be used continuously is simply not supported by the facts.
The energy requirement for Cells IIIA and IIIB are
controlled by the oxygen requirements to achieve nitrifi-
cation. The rate of nitrification will vary from month to
month with the peak rate (and therefore peak oxygen require-
ments) during the summer months. Based on a conservatively
low oxygen transfer rate of 2.1 Ibs. oxygen per horsepower
hour and an average nitrification biological efficiency
N-18
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-15-
TABLE 1
Northglenn System Energy Requirements
ANNUAL REQUIREMENT
ITEM ______ (OOP's KWH/YR)
Collection System Pump Stations
B (65' TDH, 0.90 MGD)
D (132* TDH, 0.03 MGD)
E (120' TDH, 0.02 MOD)
F (55' TDH, 0.05 MGD)
G (25' TDH, 0.02 MGD)
Subtotal Collection System
Interceptor System Pump Stations
A (77' TDH, 4.64 MGD) 604.0
Subtotal Interceptor System 604.0
Aerated Lagoons
Cells IA & IB (134 HP) 972.6
Cells IIA & IIB (178 HP) 1292.0
Cells IIIA S IIIB (58 HP) 421.0
Cells IIIA & IIIB Safety Factor (30 HP) 217.7
Subtotal Aerated Lagoons 2903.3
Storage and Discharge
Reservoir Mixing (8 HP) 52.2
Discharge Pumping (19* TDH, 4.64 MGD) 144.5
Chlorination
Operation (70.6 tons/yr.) 38.0
Manufacture (70.6 tons/yr.) 282.5
Transportation (Gulf Coast by Rail) 13.9
N Fertilizer Value
Manufacture (154-218 tons/yr.) (2,035.5 - 2,874.3)
Delivery (truck, 30 miles round trip) (2.3 - 3.3)
Subtotal Storage & Discharge (2,346.5 - 1,506.7)
Sludge Management
Land Application (247,000 ft /yr.) 88.0
M Fertilizer Value (7 tons/yr.) (94.9)
Subtotal Sludge Management ( 6.9)
N-19
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-16-
TABLE 1
(Continued)
ANNUAL REQUIREMENT
ITEM (OOP's KWH/YR)
Miscellaneous
Dacono Disinfection
Operation (1 ton/yr.)
Chlorine Manufacture (1 ton/yr.)
Chlorine Transportation (Gulf Coast by Rail)
Tailwater Control
Field Monitoring (600 miles/yr.)
Metering and Miscellaneous Power (10 HP)
Subtotal Miscellaneous
TOTAL System Requirement 1,390-.0 - 2,229.8
N-20
-------
-17-
coeffient of 0.48, an average total horsepower of 58 for
Cells IIIA and IIIB will be adequate to provide the design
levels of nitrification.
Sheaffer and Roland agrees with Engineering Science's
comment that if the third cells are left unaerated, some
odor problems may develop.^ ' But we do not agree that the
entire 280 horsepower installed for Cells IIIA and IIIB will
be used on a continuous basis. If it were to be used in
this manner, some of the problems mentioned by Engineering
Science such as solids carryover into the reservoir might
occur. Such a continuous operation would not be prudent and
it is misleading to base energy requirements on such an
operation.
For the purposes of this estimate/ we have used an
additional continuous 30 horsepower beyond the computed
value of 58 horsepower as a 50% safety factor. This safety
factor will provide additional nitrification and BOD reduc-
tion during extended periods of high flow or high strength
wastewater. The 280 installed horsepower provides addi-
tional system redundancy (250%) for short-term variations in
flow. As is the case with Cells I and II, it is unreason-
able to presume that this entire capacity will be used on a
continuous basis in estimated energy requirements.
The storage reservoir mixing requirements are based on
a demand of 0.004 horsepower.per acre foot with an average
storage of 2000 acre feet^ibj
The discharge pumping is for the sewage portion of the
total return flow at an average pumping head of nineteen
feet. Only the sewage portion was included since the deliv-
ery of return flows are not included in the Metro Denver
alternatives.
The electrical energy requirements for chlorination are
based on an average chlorine dosage of 10 parts per million
to the treated sewage portion of the flow. This is a reason-
able estimate for a chlorine dosage and is significantly
higher than the 1.5-2.0 parts per million dosage applied at
Metro Denver. The energy requirements for the manufacturing
and delivery of chlorine to the site are based upon an EPA
publication with transportation by rail from the Gulf Coast.' 6
The energy value of the nitrogen contained in the waste-
water is based on a manufacturing of anhydrous ammonia from
natural gas and delivery by truck to the farm from a local
N-21
-------
-18-
plant. A range of 154 to 218 tons per year of elemental N
will be delivered to the Bull Canal farms depending upon the
amount of nitrogen lost during storage.^ ' This is the
equivalent of 187 to 265 tons per year of anhydrous ammonia
which requires 35,000-38,000 ftj of natural gas per ton to
manufacture which has an annual equivalent energy value of
13,200 KWH per ton.^18' These savings are expected as a
result of Northglenn's program to inform the farmers of the
available nitrogen in the wastewater through the Agricultural
Reuse Manual. The storage reservoir will allow sufficient
flexibility in operation to assure that the nitrogen applica-
tion will provide the maximum benefits to the farmers.
The energy requirements for sludge management are for
the dredging and land application of 247,000 ft /yr. of
sludge.containing 7 tons/yr. of useful elemental nitrogen
The miscellaneous energy requirements include disin-
fection of the Bull Canal water for Dacono, the tailwater
control P5995fm25ear Frederick and tne field monitoring
program.'^ir22'23' A miscellaneous power requirement of 10
horsepower is also included for items such as metering, yard
lighting, heating, etc.
A corrected energy requirement for the Metro Denver
alternative is included in Table 2. This requirement in-
cludes the necessary energy to meet the discharge permit
requirements at Metro Denver using a system compatible with
the present facility as defined in Metro Denver's Facility
Plan.' ' In contrast to the estimate prepared by Engineer-
ing Science, this analysis does not include any systems
incompatible with the Metro facility and it does not make
comparisons with systems that are incapable of meeting the
discharge permit requirements.
The energy requirements for the collection and inter-
ceptor system include all the pump stations necessary to
deliver the full 4.64 MGD to the Metro Denver Central Plant.
These estimates are approximately 15% higher than estimated
by Engineering Science. The discrepancy appears to be
primarily due to the fact that Engineering Science did not
include the collection system energy in the Metro Denver
alternative even though the collection system energy was
included in the analysis of the Northglenn alternative.
The energy requirements for primary treatment, second-
ary treatment and sludge handling are based upon a unit
N-22
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-19-
TABLE 2
Metro Denver System Energy Requirements
ANNUAL REQUIREMENT
ITEM (OOP's KWH/YR)
Collection System Pump Stations
D (132' TDK, 0.03 MGD)
E (120* TDK, 0.02 MGD)
F (551 TDK, 0.05 MGD)
G (25' TDH, 0.02 MGD)
Subtotal Collection System
Interceptor System Pump Stations
Henderson (173' TDH, 3.74 MGD) 1,060.7
North Washington (60' TDH, 0.90 MGD) 88.5
Subtotal Interceptor System 1,149.2
Metro Denver Secondary Treatment
South Primary Electrical (4.64 MGD) 92.1
South Secondary Electrical (4.64 MGD) 1,526.7
Subtotal Secondary Treatment 1,618.8
Sludge Management
WAS Concentration
Electricity (654 dry tons/yr.) 45.5
Polymer Manufacturing (37,300 Ibs/yr.) 3.7
Polymer Transportation (37,300 Ibs/yr.) ***0
Anaerobic Digestion Electricity (1191 tons/yr.) 131.8
Solids Dewatering
Electricity (1351 dry tons/yr.) 55.4
Ferric Chloride Manufacturing (101 tons/yr.) 101.2
Ferric Chloride Transportation (Pueblo, CO.
by rail) 1.6
Holding Tanks
Electricity (3690 dry tons/yr.)
Lime Manufacturing (247 tons/yr.)
Lime Transportation (Lyons, CO. by rail)
Digested Solids Dewatering
Polymer Manufacturing (2 tons/yr.)
Polymer Transportation (2 tons/yr.)
Solids Disposal
Liquid (8050 wet tons/yr.)
Cake (9007 wet tons/yr.)
Subtotal Sludge Management
N-23
-------
-20-
TABLE 2
(Continued)
ANNUAL REQUIREMENT
ITEM (OOP's KWH/YR)
Biological Nitrification
Electricity (1117 MG/yr.) 730.0
Subtotal Biological Nitrification 730.0
Breakpoint Chlorination Nitrification
Electricity (372 MG/yr.) 85.0
Chlorine Manufacturing (416 tons/yr.) 1,664.4
Chlorine Transportation (Gulf Coast by
rail) 81.7
Sulfur Dioxide Manufacturing 20.0
Sulfur Dioxide Transportation ** 0
Subtotal Breakpoint Chlorination 1,851.1
Disinfection
Biological Nitrification Effluent
(1117 MG/yr.) 40.3
Breakpoint Chlorination Effluent
(372 MG/yr.)
Chlorine Manufacturing (10.2 tons/yr.)
Chlorine Transportation (Gulf Coast by
rail)
Subtotal Disinfection
Miscellaneous
Supporting Maintenance 113.2
Subtotal Miscellaneous 113.2
TOTAL System Requirement S«SS=S==B
6,338.2
N-24
-------
-21-
process by.unit process analysis of the 1980 Metro Denver
Budget.^ ' This is necessary since Metro Denver does not
provide primary treatment and all of the sludge handling for
its entire 1980 flow of 123 MGD. Thus a simple pro rata
share of these energy costs based on 4.64/123 would result
in a misleading low estimate. The energy requirements in-
clude the manufacturing and transportation of those chemi-
cals in a manner consistent with the EPA guidelines. These
guidelines require a full accounting of the primary and
secondary impacts of a proposed plan and its alternatives.
The energy requirements for the South Primary Complex
and the South Secondary Complex are mainly electrical energy.
The sludge handling processes include electrical energy as
well as the manufacturing and transportation of various
chemicals used for sludge conditioning. The energy costs
associated with hauling liquid sludge and sludge cake to the
Lowry Bombinhg range and its vicinity are also included.
The chemical requirements are based upon the 1980 Metro
Denver budget. The basis for the various other estimates
are summarized as follows using EPA publications and known
sources for the chemicals:
a) Polymer production requirement of 0.1 KWH/lb. with
polymer transportation energy negligibly small;
b) Ferric chloride production of 0.5 KWH/lb. with
transportation by rail from Pueblo, Colorado at a
rate of 670 BTU/ton-mile;
c) Lime production of 0.3 KWH/lb. with transportation
by rail from Lyons/ Colorado;
d) Disposal of 6% solids liquid sludge by truck 10
miles from the plant at a rate of 1425 BTU/ton-
mile;
e) Disposal of 15% solids cake sludge 25 miles from
the plant at a rate of 1425 BTU/ton-mile
The energy requirements for nitrification are based on
a suspended growth biological nitrification system with
breakpoint chlorination as a backup system to assure permit
compliance during cold weather and peak flow periods. This
type of system has been favored by Metro Denver in its Facil-
ity Plan since it is compatible with the existing facilities,
will provide reasonable assurances that discharge permit
requirements can be met consistently and it is compatible
with possible future plant expansion.
N-25
-------
-22-
Por the purpose of this analysis, we have also assumed
that it will not be necessary to nitrify the portion of the
effluent (12%) which is discharged to the Burlington Canal.
It is also assumed that the breakpoint chlorination system
will be used to treat 25% of the effluent requiring nitri-
fication. The EPA design manual on nitrification control
recommends that a backup system should be sized to provide a
minimum safety factor of 50%.* ' It is further assumed
that this backup system will be used only 50% of the time.
Thus, approximately 25% of the nitrification flow will use
breakpoint chlorination. This represents a reasonable esti-
mate of the energy requirements for the backup system even
though it does not provide the same high level of redundancy
as proposed in the Northglenn system.
The energy requirements for the suspended growth bio-
logical nitrification and breakpoint chlorination are based
on Figures 111-33 and 111-73 of the EPA publication on
Energy Conservation in Municipal Wastewater Treatment using
a permit effluent requirement of 1.5 parts per million with
an influent concentration fo 35 parts per million. The
influent concentration is the same one used in analyzing the
Northglenn alternative and provides a consistent basis
comparing the two systems. The sulfur dioxide is required
to dechlorinate the flows passing through the breakpoint
chlorination system to meet the 0.05 parts per million re-
sidual chlorine requirement in Metro Denver's discharge
permit.
The energy requirements for disinfection include only
those flows which do not require breakpoint chlorination.
It is assumed that additional disinfection will not be
required after breakpoint chlorination and sulfur dioxide
dechlorination.
The miscellaneous energy requirements are calculated
based on a pro rate share of the 1980 Metro Denver budget
for support maintenance. This item inlcudes energy for yard
lighting/ repair garages and other miscellaneous items.
There is no credit for nitrogen fertilizer values in
the Metro Denver alternative since it does not include a
storage reservoir to manage the nutrients to make them
available to the downstream crops when they are needed and
Metro Denver does not have any mechanism for identifying the
amount of nitrogen available from the effluent to the
various canals diverting water from the South Platte.
N-26
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-23-
(14) Several measures for algae control within the Bull
Canal Reservoir/ should this become necessary,
have been analyzed. These measures included: (a)
use of algicides, (b) use of flocculants, (c) use
of biological controls (algae-consuming fishf
primarily tilapia), (d) selective discharge, and
(e) filtration. Biological controls and selective
discharge are potential measures for the reduction
in algal and suspended solids in the reservoir
effluent. Selective discharge is a design feature
of the proposed effluent facilities and provides
operational flexibility for suspended solids con-
trol. If it is necessary to implement additional
suspended solids controls, and if Northglenn
selects biological organisms as the control
strategy (non-native species such as tilapia) , it
will be necessary to ensure total containment of
the species. This containment is desirable to
prevent introduction into State waters and prevent
competition with native, game species. Contain-
ment will require proper-sized screening of outlet
structures and/or continuous chlorination.
These conclusions seem to imply that biological controls
and selective discharge are the only viable algae control
measures available to Northglenn. The use of algicides for
algae control is not discussed in the conclusions, but the
following statements appear on page 111-10 of the Engineering-
Science report.
The use of algicide or flocculants to control
algae growth in the reservoir is a stop gap method
and does not eliminate the root cause of such
growth, that is excessive supplies of nutrients
and carbon for algal growth. Thus, it may be
effective on a spot basis or for a period of time,
but it does not represent a long-term solution to
algae growth except through repeated applications.
The use of repeated applications of algicides such
as the CuS04 proposed at Northglenn could lead to
unacceptable buildup of copper concentrations in
the reservoir sediments and impact crops irrigated
with the water.
This discussion dismisses the use of algicides as a
"stop gap" measure and a hazard to irrigated crops in spite
of the fact that this measure has been widely used with
N-27
-------
-24-
consistent success in drinking water supply reservoirs across
the country for years. This was previously discussed in the
Sheaffer & Roland, Inc. memorandum on algae control measures
dated February 25, 1980. The low alkalinity waters of the
Northglenn Reservoir will require low dosages (less than 0.1
mg/1) of copper sulfate algicide to effectively control
algae in a given year.
It is anticipated that the use of copper sulfate as a
measure will be able to be used on a repeated application
basis if needed without any adverse economic or environmen-
tal impacts. Assuming a worst case economic condition (that
each year's application of algicide would completely wash
out of the reservoir) the annual cost would be less than
$1,000 at current prices. With respect to potential environ-
mental impacts/ the amounts of copper sulfite needed would
pose no difficulties. Assuming that all of the copper
sulfate applied to control algae would leave the reservoir
and be applied to crops, the concentration in the irrigation
water would be less than 0.02 mg/1 which is well within the
acceptable.limits for sugar beets, which are sensitive to
copper.^ ' At this level, and assuming an annual applica-
tion rate of 18" per year of irrigation water, cooper would
accumulate in the soil at an annual rate of 0.01 kg/ha. It
would take over 400 years of such accumulation before cumu-
lative levels would reach current EPA limits for cadmium
which is a much more worrisome metal than copper.* '
With respect to copper build-up in reservoir sediments,
if all the copper applied annually were to settle out in the
reservoir this would contribute only 60-65 kg of copper to
the 130 acre reservoir bottom each year.
This rate of accumulation of a copper residual is slow
and could be routinely monitored as a part of the system's
operation. Contrary to the opinion expressed by Engineering-
Science, a build-up of copper in the sediments would be the
ideal situation. The copper would then be slowly released
into water solution and the algae would be prevented from
growing without additional applications of copper sulfate.
Since the accumulation in the sediments is slow, any build-
up in the amount of copper in solution is also slow. This
provides a natural protective device since the concentration
of copper needed to control algae is one-half the amount
which is harmful to any crops. Thus, algae control on a
continuous basis would be achieved without harming the crops
and might reduce the need for future copper sulfate addi-
tions to the reservoir.
N-28
-------
FOOTNOTES
HJ.S. Environmental Protection Agency, STORET,
South Platte at 88th Avenue,
STORET DATE 79/05/30.
2
Metcalf and Eddy, Wastewater Engineering: Collection,
Treatment, Disposal, McGraw-Hill, 1972, p. 231.
Sheaffer and Roland, Memorandum to Bob McGregor from
Lee Rozaklis, RE: NPDES Permit for the Bull Canal
Reservoir, November 16, 1979, p.7.
4
White, Stan C. and Linvil G. Rich, How to Design
Aerated Lagoon Systems to Meet 1977 Effluent Standards,
Water and Sewage Works, March-June, 1976, (Four Parts),
p. 82, April Issue.
Balkum, Earl T., Aerated Wastewater Pond Process and
the Mass Transfer of Oxygen from Air Bubbles,
Doctoral Dissertation, University of Denver, May, 1975.
Personal Communication, Windber Area Sewage Authority,
Windber, Pennsylvania, March, 1979.
Federal Register, Vol. 43, No. 188, Wednesday, September 27,
1978, p. 44060.
a
EPA, Environmental Assessment of Construction Grants
Projects, EPA-430/9-79-007, FRD-5, January, 1979, p. 52.
Federal Register, Volume 43, No. 188, Wednesday, September 27
1978, Appendix A, 6.a., p. 44087.
U.S. Environmental Protection Agency, Region 8, Negative
Declaration, Project Number C 080416-01 (Step 2), Northglenn
Wastewater Treatment Facility, September 29, 1978, p. 47-48.
Sheaffer & Roland, Letter report RE: Metro Denver Alternatives
July 31, 1978.
12
Engineering Science, A Review of Proposed Northglenn Waste-
water Treatment System, May 1980, p. III-3.
N-29
-------
FOOTNOTES
(Continued)
Gilbert R. Gary and S. J. Chen, Testing for Oxygen Transfer
Efficiency in a Full Scale Deep Tank, 31st Purdue industrial
Waste Conference, May 4, 1976, Figure 14.
14
Engineering Science, A review of Proposed Northglenn Waste-
water Treatment System, May, 1980, P. III-3.
Artificial Destratification in Reservoirs - A Committee
Report, Journal AWWA 63:9:597, September, 1971.
U.S. Environmental Protection Agency, Energy Conservation
in Municipal Wastewater Treatment, EPA 430/9-77-011, MCD-32,
March, 1978, pp. 4-3 and 4-4.
Memorandum from McGregor to Lundahl, Musick, Wilson, Odin,
and Sheaffer, RE: Nitrogen Applications in Northglenn/FRICO Reuse
Area, Sheaffer and Roland, August 29, 1979.
18
Personal Communication, Dick Rortvordt, U.S. Department of
Agriculture, Washington, D.C. (202) 447-7340, May 16, 1980.
19
Sheaffer and Roland, Letter Report, RE: Impacts of Northglenn1s
Proposed Sludge Management Plan and Compliance with EPA, State
and Local Requirements, February 25, 1980.
U.S. Environmental Protection Agency, MCD-32, Figure 3-103.
Tlemorandum from McGregor to Lundahl, Musick, Sheaffer, Wilson
and Udin, Sheaffer and Roland, September 13, 1979.
22
Sheaffer and Roland, Letter Report, RE: Preliminary Field
Monitoring Program, February 25, 1980.
23
Sheaffer and Roland, Letter Report, RE: Preliminary Design
of Tailwater Control Plan, February 25, 1980.
24
Black and Veatch, Central Plant Facility Plan, Phase I Report,
Metropolitan Denver Sewage Disposal District No. 1,
June, 1979.
25
Metropolitan Denver Sewage Disposal District No. 1, 1980
Budget, June 30, 1979.
N-30
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-27-
FOOTNOTES
(Continued)
26
U.S. Environmental Protection Agency, Technology Transfer,
Process Design Manual for Nitrogen Control, October, 1975,
p. 4-15 to 4-20.
Personal Communication, Ron Brenton, Director of Environ-
mental Programs, Great Western Sugar Company, February, 1980,
28
Federal Register, Volume 44, No. 179, Part 257, Criteria for
Classification of Solid Waste Disposal Facilities and
Practices, September 13, 1979, p. 54362.
29
Bishop, N.E., Studies on Mixing and Heat Exchange in
Aerated Lagoons, Technical Report CRWR 78, Center for
Research in Water Resources, University of Texas at Austin,
January, 1975.
Stumm, W. and J. J. Morgan, Aquatic Chemistry, Wiley
Interscience, 1970, p. 154-55.
Sheaffer and Roland, Memorandum from Lee Rozaklis to Bob
McGregor, Re: NPDES Permit for the Bull Canal Reservoir,
November 16, 1979, p. 11.
N-31
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TECHNICAL REPORT DATA
(Please read Instructions on the reverse before completing)
1. REPORT NO.
EPA-908/5-5-79-002C
2.
3. RECIPIENT'S ACCESSION NO.
4. TITLE AND SUBTITLE
Final Environmental Impact Statement
Northglenn Water Management Program
City of Northglenn, Colorado
Appendix
5. REPORT DATE
June 27, 1980
6. PERFORMING ORGANIZATION CODE
7. AUTHOR(S)
Weston W. Wilson and William Rothenmeyer, EPA
Al Udin and Paul Seeley, Engineering Science, Inc.
8. PERFORMING ORGANIZATION REPORT NO.
9. PERFORMING ORGANIZATION NAME AND ADDRESS
Engineering Science, Inc.
2785 North Speer Blvd., Suite 140
Denver, Colorado 80211
10. PROGRAM ELEMENT NO.
11. CONTRACT/GRANT NO.
12. SPONSORING AGENCY NAME AND ADDRESS
U.S. Environmental Protection Agency
Region VIII
1860 Lincoln Street
Denver, Colorado
13. TYPE OF REPORT AND PERIOD COVERED
14. SPONSORING AGENCY CODE
15. SUPPLEMENTARY NOTES
Environmental Appraisal and Negative Declaration dated September 29, 1978, issued by
EPA. Draft Environmental Impact Statement dated January 11, 1980 also issued by EPA.
16. ABSTRACT
This is a final Environmental Impact Statement (EIS) for proposed construction of
facilities to provide water supply, wastewater treatment and agriculture reuse of
sewage effluent for the City of Northglenn, Colorado. Under an exchange agreement
with the Farmers Reservoir and Irrigation Company, approximately 5,000 acre-feet
annually will be diverted for Northglenn's municipal use, treated, augmented from
other sources, stored, and then returned for irrigation purposes.
The U.S. Environmental Protection Agency (EPA), Region VIII, Denver, under the
authority of Section 201 of the Federal Water Pollution Control Act Amendments of
1972, is authorized to grant 75 and up to 85 percent matching funds for construction
costs of designated wastewater treatment facilities.
The recommended action is to construct an 8 mile interceptor, aerated lagoon and
a storage reservoir. Implementation of the exchange program negates the pending
water condemnation actions that are in progress.
The appendix includes responses by EPA to comments recieved on the draft EIS,
analysis of the alternative systems and cost estimates.
17.
KEY WORDS AND DOCUMENT ANALYSIS
a.
DESCRIPTORS
b.lDENTIFIERS/OPEN ENDED TERMS
Denver Regional EIS for
Wastewater Facilities
and the Clean Water
Program
Denver Metro Sewage
farmers Reservoir and
Irrigation Company
c. COSATI Field/Group
Wastewater Reclamation
Sewage Irrigation
Agricultural Reuse
Water Pollution
Flow Augmentation Plan
Alternative Wastewater Treatment Technology
Environmental Impact Statement
18. DISTRIBUTION STATEMENT
Release Unlimited
19. SECURITY CLASS (ThisReport)
21. NO. OF PAGES
_ • 44 R
20. SECURITY CLASS (Thispage)
22. PRiCE
EPA Form 2220—1 (Rev. 4-77) PREVIOUS EDITION is OBSOLETE
* U. S. GOVERNMENT PRINTING OFFICE ,980 - 678-895/^6 Reg. 8
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