EIS790976F2
v>EPA
            United States
            Environmental Protection
            Agency
           Region V
           230 S. Dearborn
           Chicago, Illinois 60604
June, 1979
            Water Division
Environmental
Impact Statement
Wastewater
Treatment Facilities
for the
Metropolitan Area
Columbus, Ohio
Final

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           EPA-5-OH-FRANKLIN-COLUMBUS-WWTP&INT-79



            FINAL ENVIRONMENTAL IMPACT STATEMENT

               WASTEWATER TREATMENT FACILITIES

                  FOR THE METROPOLITAN AREA

                       COLUMBUS, OHIO
                        Prepared by the

       UNITED STATES  ENVIRONMENTAL PROTECTION  AGENCY

                           REGION 5

                       CHICAGO, ILLINOIS


                              And


 BOOZ, ALLEN AND HAMILTON,  INC. With HAVENS  &  EMERSON, INC.

       BETHESDA, MARYLAND                CLEVELAND,  OHIO
                                    APPROVED BY:
U.S. Environmental Protection Agency
Region 5, Library (5PL-li)
230 S. Dearborn Street, 8»9» 1670
Chicago, IL   60604
  HN MCGUIRE
  GIONAL ADMINISTRATOR
JUNE 1979

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     VOLUME II



Response to Comments



        And



Final EIS Appendices

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                            PREFACE
      The  Final Environmental  Impact Statement  (EIS)  for the
Columbus,  Ohio Wastewater Treatment Facilities consists of
the three following volumes:

           Volume I:  "Recommended Alternatives,  Technical
           Analysis, and Impacts"

           Volume II:  "Response to Comments and Final EIS
           Appendices"

           Volume III:  "The Draft EIS (Edited)"

      Volume I discusses the essence and substance  of the
final collection, treatment,  and  disposal recommendations,
highlighting any recommendations  that differ from  the
Draft EIS.   The intent of Volume  I is to provide a concise
overview  of the recommended system, emphasizing  areas of
significance (e.g., regionalization, pretreatment, sludge disposal).
Detailed analyses supporting the conclusions can be found in the
Appendices to Volume II and in Volume III.


      Volume II contains the written record of public com-
mentary and appropriate responses to the issues  raised by
this  commentary.  There are over  330 specific comments by
Federal,  state and local governments and private concerns
for which detailed responses  have been developed.   Volume
II also contains additional appendix material which was
developed in response to the  comments on the Draft EIS.

      Volume III is the Draft  EIS  edited only for identified
omissions and errors.  Asterisks  in the margins  indicate
those sections, lines,  or words that have been changed,
added, or deleted.

Reference to  pages in "the  EIS" refer to pages in Volume 3;  the
edited Draft  EIS.

All double-lettered Appendix references-(e.g. AA.BB, etc.) are in Volume
II; all single-lettered Appendix references (e.g. A, B, etc.) are in
the edited  Volume III.

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             TABLE   OF   CONTENTS
                                                        Page
                                                       Number
  I.    INTRODUCTION                                      1-1
 II    COMMENTS FROM FEDERAL AGENCIES                   II-l

       2.1  Department of the Armyd)*                  II~1
       2.2  Department of Health, Education             11-4
              and Welfare (2)
       2.3  Department of the Interior (4)               n-6
       2.4  Department of Transportation (4)            11-13
III.    COMMENTS FROM STATE AGENCIES                    III-l

       3.1  Ohio Environmental Protection Agency  (94)  III-l
       3.2  Ohio Historic Preservation Office  (3)
 IV.   COMMENTS FROM REGIONAL AND LOCAL PUBLIC
       AGENCIES                                         IV-1

       4.1  City of Columbus  (174)                      IV-1
       4.2  City of Columbus Division of Water (4)       IV-169
       4.3  City of Reynoldsburg (3)                     IV-179
       4.4  Delaware County (6)                          IV-183
       4.5  Fairfield County (1)                         IV-187
       4.6  Genoa Township (1)                           IV-194
       4.7  Hamilton Township (1)                        IV-197
       4.8  Mid-Ohio Health Planning Division (11)       IV-199
  V.   COMMENTS FROM PRIVATE CONCERNS AND
       INDIVIDUALS                                       V-l

       5.1  Anheuser-Busch Inc. (16)                      V-l
       5.2  Columbus Industrial Association (4)          V-58
       5.3  Development Committee  for Greater            V-61
              Columbus (5)
  *Number of comments received are in parentheses.

                              -ii-

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                     APPENDICES
AA     EVALUATION OF THE WASTEWATER TREATMENT PROCESSES
       PROPOSED FOR COLUMBUS,  OHIO IN THE DRAFT  EIS  —
       ENERGY AND ENVIRONMENTAL ANALYSIS, INC.
BB    REVIEW OF COLUMBUS,  OHIO DRAFT EIS BY THE MUNICIPAL  ENVIRONMENTAL
      RESEARCH LABORATORY, CINCINNATI, OHIO
CC     REVISED CHAPTER III:   SERVICE AREA AND SEWER SYSTEM
       ALTERNATIVES


DD     REVISED APPENDIX B:   MATHEMATICAL CHARACTERIZATION OF
       THE SCIOTO RIVER BELOW COLUMBUS


EE     COLUMBUS METROPOLITAN AREA GROWTH POTENTIAL 1977-1985


FF     SECONDARY AIR IMPACT  ANALYSIS
GG     EFFECTS OF PARA-DICHLOROBENZINE AND ORTHO-DICHLOROBENZENE
       ON GERMINATION AND EARLY SEEDLING DEVELOPMENT OF CORN
       AND SOYBEANS, U.S. EPA PLANT BIOLOGY LABORATORY,
       BELTSVILLE, MARYLAND
HH     EPA POLICY STATEMENT  CONCERNING THE RELATIONSHIP AMONG
       EPA,  ITS CONTRACTORS,  SUBCONTRACTORS, GRANTEES,  AND
       THE PUBLIC
 II     COLUMBUS EIS PROJECT  PARTICIPANTS
JJ     BIBLIOGRAPHY
                             -ill-

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I.   INTRODUCTION

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                    I.  INTRODUCTION
          Volume II of the Final Environmental Impact
Statement (Final EIS)  prepared for the proposed wastewater
treatment facilities plan for the metropolitan area of
Columbus, Ohio, contains the record of public commentary
and appropriate response to issues raised during the period
of public examination of the Draft Environmental Impact
Statement (Draft EIS).  This record of public commentary
includes all written testimony received at the public
hearing held in Columbus on March 30, 1978, and all addi-
tional written comments submitted to the U.S. EPA from
public agencies, public and private organizations, and
citizens.

          All written comments which were received appear
in this volume.  The letters and written testimony in
many instances raise questions or refer to issues which
required additional analysis and consideration in order
for a response to be formulated.  The responses follow
each written letter with a succinct statement of the issue
or question raised.  A numbering system is used to enable
cross-referencing.  Where analysis has led to a change in
the text of the draft environmental impact statement, the
location and change in Volume III or its appendices are
referenced.  Research data and analysis performed after
the publication of the Draft EIS have been included as new
appendices to Volume II with appropriate references within
the texts of Volumes I and II.
          This volume is organized with the written com-
ments  grouped alphabetically according to Federal agencies;
State  agencies; regional and local agencies; and private
concerns  and individuals.  Where more than one letter was
received  from the same agency, the letters appear in order
of date of receipt.  An issue or question has only been
answered  once; therefore, all subsequent comments relating
to the issue or question will be stated and referenced
back to the original response.

          The official transcript containing the verbal
testimony given at the public hearing held March 30, 1978,
is available for public review at the U.S. EPA office at
230 South Dearborn Street in Chicago, Illinois.
                            1-1

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II.   COMMENTS FROM FEDERAL AGENCIES

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2.1  Department of the Army

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2.1
                           DEPARTMENT OF THE ARMY
                       HUNTINGTON DISTRICT, COnPS OF ENGINEERS
                                   P. O. BOX 2127
                           HUNTINGTON, WEST VIRGINIA 23721
            REPLY TO

            ATTENTION OF:
     ORHPD-R                                                   -"878
     Mr. Valdas V. Adamkus
     Deputy Regional Administrator
     U.S. Environmental Protection  Agency
     Region V
     230 South Dearborn Street
     Chicago, Illinois   60604
                                       Re:  Draft Environmental Impact
                                           Statement Wastewater
                                           Treatment Facilities
                                           EPA, Region V
                                           Columbus, Ohio
     Dear Mr. Adamkus:
     Reference is made ~o your correspondence dated 24 February 1978,  which
     transmitted to the Huntington District copies of the subject DEIS.
     Members of my staff have reviewed  this document with respect to the
     specific interest and jurisdictions  of the Corps of Engineers and have
     the following comments and recommendations.

     On page IV-47.  Possible runoff  problems could result from the use of
     sludge waste and/or incinerator  waste to reclaim strip mines and         (2.1.1)
     landfills.

     A Department of the Army Permit  is required prior to the initiation of
     any construction, i'illing, dredging, or any other work in the Scioto
     River at or below the ordinary high  water elevation.  The placement of
     fill or dredged material in any  waterway may require a Corps Permit.
     Close coordination of the FEIS should be conducted with the Permit
     Section.  If you have questions  concerning the permit process, please
     contact Mr. Michael D. Gheen at  telephone number 304-529-5210.
                                           RECEIVED
original:   OFA


                                         APR 1 7 1978

                                         EPA REGION. 5
                                        OFFICE OF REGIONAL
                                          ADMINISTRATOR
                                II-l

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ORHPD-R                                                        •' n -S'S
Mr. Valdas V. Adamkus

Considering the fact that the facilities involves  the  Scioto River
drainage basin and its adjacent flood plain, sediment  or erosion  control
techniques should be implemented to the fullest extent.  Standard
precautionary measures also should be taken to prevent and/or control
any chemical, fuel, or lubricant spillage which may occur.

The opportunity to review the subject document is  appreciated.

                                       Sincerely yours,
                                 /     vGEORGEU. BIPHER'
                               /   _,/ Colonel, Co/ps x>f Engineers
                               (_--/^^--^District Engineer
                                  II-2

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2.1       Department of the Army
2.1.1     Comment;   Possible runoff problems could result
from the use of sludge waste and/or incinerator waste to
reclaim strip mines and landfills.

          Response:  Current U.S. EPA Guidelines (40 CFR 241)
on land disposal are modeled after sanitary landfill opera-
tional and design characteristics,  with a strong emphasis
on the minimization of environmental impacts during and
after disposal operations.  If these, or equivalent state
guidelines are followed, potential runoff problems should
be mitigated.
                           II-3

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2.2  Department of- Health,  Education
             and Welfare

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       2.2
                  -DEPARTMENT OF HEALTH. EDUCATION, AND WELFARE
                                    April  7, 1978
                 Our Reference:   Draft Environmental Impact Statement  (EIS)
                                 Wastewater Treatment Facilities
                                 Metropolitan Area of
                                 Columbus, Ohio

                 Mr. Valdas V. Adamkus
                 Deputy Regional Administrator
                 U. S. Environmental  Protection Agency
                 230 South Dearborn Street
                 Chicago, Illinois  60604

                 Dear Mr. Adamkus:

                 We are unable to provide a response to the Environmental
                 Impact Statement (EIS)  for the wastewater treatment
                 facilities for the metropolitan area of Columbus, Ohio.

                 The effects of the particulate matter from the incineration
                 of sludge is not fully  known, page VI-6.  Until  such  time
                 as the results  of  the assessment of the impact of the
                 proposed incineration facilities are determined, this office
                 must reserve its comments.

                                              Sincerely yours
                                                           (2.2.1)
                  RECEIVED
                                              Melvin H. Fisher,  P.E.
                                              Regional Engineer
                                              Division of Regional Operations
                                              for Facilities  Engineering
                                              and Construction
c  ^inal:  Water
 APR 1 0 1978

 tPA REGION 5
Ol-FICE OF REGIONAL
  ADMINISTRATOR
                                          II-4

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2.2       Department of Health,  Education,  and Welfare
2.2.1     Comment;   The effects of the particulate matter
from the incineration of sludge is not fully known.

          Response;  The Ohio EPA has conducted a study
which assessed the  impact of sludge incineration facilities
upon air quality in the Columbus metropolitan area.  The
results of this study and U.S. EPA's corresponding policy
on incineration are discussed in Volume I.

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2.3  Department of the Interior

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 2.3
            United Stares  l>n;ir;ment of the Intern.
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 ER 78/194
                                                                         ,.  _„
                                      April 19,  1978              APR 1 9 197 ft
                                                                  EPA REGION 5
                                                                 OFF K-i? Of REGIONAL
 Mr.  George Alexander                                              *DV,!nibTRATnr?
 Regional Administrator
 U.S.  Environmental Protection Agency
 230  South Dearborn Street
 Chicago, Illinois  60604

 Dear  Mr. Alexander:

 This  is in response to the request for the Department of the Interior's
 comments on the draft environmental statement for wastewater treatment-
 facilities for the metropolitan area of Columbus, Ohio.

 Fish  and Wildlife Re sour c es

 Deficient sewage treatment facilities have adversely affected fishery
 resources for years in the Columbus metropolitan area.   At times, under
 certain conditions,  these adverse effects resulted in fish kills dovnstream
 from  sewage effluents.   Generally, such kills were due to organic over-
 loading of the stream resulting in diminished levels of  dissolved oxygen.
 For  the most part, sublethal effects on the stream fishery remain unnoticed
 except that populations of sensitive fish species decreased.  We are
 encouraged to see the implementation of plans to alleviate the poor water-
 quality conditions downstream from sewage treatment plant effluents.

 Since many industries discharge their waste into the city's treatment
 facilities, heavy metal concentrations in receiving waters become a concern
 to us.   Many heavy metals bioaccumulate, resulting in toxic effects to
 consumers of fish.  He recommend that all Loxic materials from treatment
 plant discharges be limited in accordance with recommendations made in
 U.S.  Environmental Protection Agency's latest edition of "Quality Criteria
 for Water".

 Placement of sewer lines could result in water-quality probl.pr.is if erosion
 control measures are not used.  Since siltation problems would be greater
 during the spring, we recommend that the construction of sev,oc lines be
 limited where possible to the dry season (August through November).  Ne also
 recommend against the use of interceptors in stream beds.  Excavation and
 movement of construction equipment in the sti'eam often result in total
 disruption of benthic communities.  Siltation problems are also
            OFA

                                  II-6

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stream-bed construct 'iov:.   In  c-'ses  v'.cre  Intercrpf.cr  lines :n.;;;L  follow
Strega beds, tho af f .-cue ;  '"iMcV1^ of  'he  FLroaTi  s'iculd be/  /I'vulnd  to
determine species ccr-pc^itlur. of tli.;  ...qua^ic  li.,na.   Such  information
could serve as hc.se Lint fl.'jl'a  f. or c'.evr lofjiner.t.  of  a  .x Ltigat K>a plan  to offset
damages to the fishery resource.  The  same  as iesr.i.nnt should be.  made with
stream bank and upland -"e^et^tlon proponed  for removal during construction.

Secondary impacts of the plan presented in  the draft  statement can be
diverse and widespread.  We reconmend  that  institutional arrangements
which would limit sprawl development be e/aLuated  in more detail.   Of special (2.3.
concern to us is the possible conversion  of high-quality wilJjife  habitat
for housing or other developments.  Are specific  arrangements available
and feasible for precluding the possible  extension of sewer facilities into
such areas?  What actions  can and will the  project, sponsor(s)  take to  zone
wetlands and flood plains  to  preserve  the existing resource?  Executive Orders
11988 and 11990 concerning protection  of  wetlands  and flood plain  management
should be cited and proposed  compliance measui'es  discussed.

Development must also be limited within the constraints of available water
supply.  Since the. Coluir.bus area receives most of  its water from  water-supply
impoundments, we are concerned that excessive growth  would result  in
additional impoundments on many of  the remaining  large strains in  the area.
Since these, free-flowing streams provide  excellent fish and wildlife resource
habitat, we are opposed to any impoundments on these  streams.  Conservation
measures for water should  be  implemented  instead  of new water-supply
impoundments.

Cultural Resources

In the parts of the statement  in which cultural resources  are  addressed
(sec.  2.2.10 arid 7.3.4), no clear indication  is given that the presence
or absence of such resources  has influenced the selection  of project
locations or that the State Historic Preservation  Officer  (S11PO) has been
consulted with respect to  the  20 properties on the National Register of
Historic Places located within the  city and the  78 archeologlral sites in
the area.  The document should note whether any of the historic  ar-d/or
archeological sites identified are within the proposed project boundaries (2.3.2)
and what effect, if any, the  proposed projects will have on them.

The final statement should document consultation with the  S!IFO concern:!r.g
the need for a professionally conducted cultural  resources survey  of the
affected areas as contemplated by the National Historic Preservation Ace
of 1966.  The Environmental Protection Agency in  conjunct Lou with  the  SHPO
should apply the Advisory  Council on Historic Preservation Criteria  of
Effect (36 CFR 800.S) to any  known National Register  property  or any
eligible property that may be discovered  within any of the proposed  project
aress.  Following this preliminary  step,  the  procedures set forth  in
36 CFR 800.4 should be followed and documented.
                                II-7

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                                                                              -3-
Hecr a-'' t i_o i uj 1 _Re 3 n •. • r r- P, s

A public park  (r.'oovc r Dan; Park) .lies in Franklin County on the ec'st  side
of Hoover Reservoir.  i"hr: rep-,>r.'. ic: r.^i cltar as to whether Al r.er.ir.tivc A
of the Kig Walnut Creek E twite area waul:* cross these parkland?..  These
lands were acquired in part vith ponies from the Land and Water
Conservation Fund.

Abou.t 100 acres of public parklands lie at the southwest corner of
Havens Corner and Mann Roads.  Land and Water Conservation Fund monies
were used to acquire these parklands.  Figures 111-9 and I.II-10 are  not
complete enough to determine the precise relationship between either the
proposed Alternative B pr Alternative C and these parklands.

On page 111-28, paragraph 4, line 13, mention is made that the proposed
Rocky Fork interceptor would crops a public park.  This park should  be
identified either by name or location.

On page 111-30, paragraph 2, line 4, it is stated that the Blacklick Creek
Interceptor would cross a portion of the Rlacklick Woods Metropolitan Park,(2. 3. 3)
possibly impacting the 55-acre natural area in this park.  Land and  Water
Conservation Fund monies were also used in.the developalent of these  parklands.
We would strongly oppose any sewer right-of-way alignment that would
impact the natural area in any way.   If an alignment can be worked out that
will not adversely impact park development or future plans sigii if icantly,
we would have no serious objection tc the sewer interceptor crossing
these parklands.

However, no portion of the Blacklick Woods Metropolitan Park or of any
other park in which Land and Water Conservation Fund monies have been used
for the acquisition and/or development of recreational facilities should be
used for other purposes.  Such a conversion is in violation of section 6(f)
of the Land and Water Conservation Fund Act which states in part:

       No property acquired or developed with assistance under this
       section shall, without the approval of the Secretary (of the
       Interior), be converted to other than public outdoor recreation
       uses.  The Secretary shall approve such conversion only if he
       finds in to be in accord with the then existing comprehensive
       statewide outdoor recreation plan and only upon such conditions
       as he deems necessary to assure the substitution of other
       recreation properties of at least equ?]  fair market value and
       of reasonably equivalent usefulness and location,

We suggest that you contact the State of Ohio Liaison Officer for the
Land and Water Coiiservation Fund Program, Mr. Robert Tcater, Director,
Department of Natural Resources, Fountain Square, Building D, Columbus,
Ohio 43224, to coordinate and resolve these problems.
                                 TT-fl

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                                                                               -4-
Water F.escurces

The draft statement. TO en t. ions  that  large  yields  of  2, found  watc;i  t-ie
obtained from limestone aquii ers  (p.  il-'ilj;  it  shui.ir"  at least  in a
general manner address the potential  for contaniinafion  of th.?s;  aquifers
and natural or planned mitigation  against  effects  of  alternative  such    , „ _  ..
as land application of effluents and  quarry  disposal  of incinerator ash.
The nature of the quarry considered for  incinerator ash disposal  (p.  IV-30,
V-8) should be discussed (type  of  rock,  fissures,  or  other hydrologicaJly
significant data); and possible impacts  on ground  water should  be  addressed.
The statement should also indicate whether ground  water will  be  monitored
in the vicinity of landfill(s)  used for  sludge disposal (p. VI-1).

                                   Sincerely  yours,
                                                        <:
                                   David L. Jervis
                                   Regional Environmental Officer
cc:   Ohio Department of Natural Resources
                                 II-9

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2.3       Department of the Interior
2.3.1     Comment:  What institutional arrangements are
available to ensure the protection and conservation of
critical natural resource areas from the impacts of sprawl
development trends?

          Response:  Local governmental jurisdictions have
all the authority necessary to plan for and direct overall
development patterns through the process of local public
decision making.  The use and development of land is
.•egulated by the city, county, and township governments.
Lar.d use and zoning regulations can be used to protect
critical resource areas through the establishment of resource
protection districts, ecological preserves, wildlife sanct-
uaries, and the like.  However, these regulatory mechanisms
comprise only part of the complex of decisions made by
local governments which strongly influence development pat-
terns.  The policy decisions made which are related to the
provision of public services and capital improvements gen-
erally have far greater impact upon new development than
zoning or other land use regulations.  The cost of servicing
newly developing areas is increasingly beyond the fiscal
capabilities of municipalities.  While municipalities can
and have availed themselves of Federal funds for major
infrastructure/capital improvements projects (roads, sewage
treatment systems,- mass transit), the costs associated
with maintenance, administration, and service to larger
populations over a greater geographic area are frequently
exceeding the municipal revenues generated by the growth
of the new areas serviced.  The dramatic rise in service
costs can be attributed to a number of factors including
rising fuel costs, increasing wage and salary levels, and
increased government regulation at all levels.

          Thus, more and moife municipalities are recognizing
the need to manage growth in -terms of development patterns
or trends which are consistent with the jurisdiction's
fiscal resources and service capabilities.  The managed
growth concept must be implemented at the local level by
the public officials within the decision making process
and by the voting public at large.  Federal Government
policies which foster the protection and conservation of
either fiscal or natural resources have only recently been
directed to the administration of Federal grant programs
such as construction grants.  These policies are intended
to assist local governments in the difficult effort to
balance growing service needs with sound fiscal policy and
                           TT-I n

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yet achieve pollution abatement goals.  Thus, in the case of
sewage treatment systems, EPA is responsible for ensuring
that the expenditure of construction grants dollars will
not result in the construction of an. overdesigned system
which induces sprawl development and imposes unnecessarily
greater costs to municipalities over the life of the system.
2.3.2     Comment:   The document should identify any likely
effects the proposed project would have on any historic or
archeological sites located within the project boundaries
and indicate appropriate measures to be taken.

          Response;  See the response to comment 3.2.1 made
by the Ohio Historic Preservation Office.
2.3.3     Comment;  The public park which the proposed
Rocky Fork interceptor would cross should be identified by
name or location and whether Federal Land and Water Conser-
vation Fund Act monies were used in acquiring or develop-
ing the park.

          Response;  The park issue has been analyzed in
great deatil and the results are discussed in Volume I
in the section on Interceptors.
2.3.4     Comment;  The possible impacts from land appli-
cation of effluent and quarry disposal of incinerator ash
should be discussed.

          Response;  A discussion of these impacts has been
included in Volume I.
                          11-11

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2.4  Department of Transportation

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2.4
                 U.S. DEPARTMENT OF TRANSPORTATION
                     FEDERAL HIGHWAY ADMINISTRATION
                                 REGION 5
                             182O9 DIXIE HIGHWAY
                         HOMEWOOD. ILUINOIS  6O43O
                              March 28, 1978
                                                       IN REPLY REFER TO
                                                          HED-05

   Mr. Gene Wojcik
   Chief, EIS Preparation Section
   Planning Branch
   U.S. Environmental Protection Agency
   230 South Dearborn Street
   Chicago, Illinois  60604

   •Dear Mr. Wojcik:

   The draft environmental statement for the wastewater treatment facilities
   for the Metropolitan Area, Columbus, Ohio, has been reviewed.  Our review
   discloses that the document is weak or lacking in several areas of impact
   and mitigation discussions.  Specific comments are as follow:

   1.  All alternates for sewer line locations involve highways extensively.
       The associated discussions indicate this is a minor to no impact.
       There is no discussion on how traffic will be maintained or what     (2.4.1)
       provisions will be made to provide safety.  It has been our experience
       that sometimes sewer construction does not provide adequate protection
       for the traveling public.

   2.  Page VII - 24, paragraph 3 discusses the impact on transportation
       facilities.  This statement is not consistent with the information
       developed in the Mid-Ohio Transportation Plan.  Many of the
       existing roads, particularly arterials, .are operating at capacity     (2.4.2)
       loads.  Any growth, whether fill in, increase in density, or new
       area growth, will increase the demand for transportation facilities.
       This discussion should be expanded and corrected.

   3.  Various alternatives require the use of extensive lengths of highway
       rights-of-way.  Some of this right-of-way has access control.  No    (2.4.3)
       mention is made of this fact or the relationship of this important
       feature to the proposed facilities.

       Also the report indicates the only effect on highways will be short
       term..  This is not correct.  The sewer facilities will require
       maintenance and possible replacement in case of failure.  This
       could disrupt traffic at some future date.  Also there may be an
       intent to place manholes within the highway facilities.  These
       would have to be reconstructed to grade at later dates when the
       highway was resurfaced.  These possibilities should be discussed.
                                    11-12

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                                                                            -2-
4.  Construction of the sewer lines  will  leave  large areas of disturbed   (2.4.4)
    soil.  There is no indication in the  report of  effective erosion
    control measures being employed  to  mitigate this problem.

5.  In general, we find a lack of documentation of  early coordination
    with other Federal and State agencies.

                                     Sincerely yours,

                                     Donald E. Trull
                                     Regional  Administrator
                                      By:
                                           W.  G.  Emrich, Director
                                           Office of  Environment and Design
                                 11-13

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2.4       Department of Transportation

2.4.1     Comment:  There is no discussion on how traffic
will be maintained or what provisions will be made to pro-
vide safety.

          Response;  The impacts of facilities construction,
operation, and maintenance upon traffic maintenance and
public safety have been incorporated in Chapter VI-6.1 and
Chapter VIII-8.1.1 in Volume III of the EIS.

2.4.2     Comment:  The discussion regarding existing road
capacities should be expanded and corrected.

          Response:  The discussion is deemed adequate for
an evaluation of  sewage collection alternatives.

2. 4'. 3     Comment:  No mention is made of how rights-of-way
with controlled access will be used for installation of
sewers.

          Response:  Until design of interceptors are com-
pleted, details as to location with respect to the highway
are not known.  It is presumed, however, that the route of
the interceptor will be located off the paved areas and
beyond the ditch lines.  Safety and traffic control are
considered to be paramount, and the designer as well as the
contractor should notify and abide by the decisions of local,
state, and federal agencies involved in construction along
highway rights-of-way.

2.4.4     Comment:  There is no mention of effective erosion
control measures being employed to mitigate erosion during
construction.

          Response:  Appropriate measures should be taken
to reduce adverse impacts during construction.  Dust can be
controlled during construction by water sprays from water
trucks and from wheel wash hoses at the truck entrances and
exits.  Mud and grime on truck wheels can be removed at
wheel washes at all truck exits to prevent the spread of
these materials to the bordering streets.  Construction
vehicles should be discouraged from using residential neigh-
borhood streets.  Erosion from stormwater can be controlled
on major construction sites by straw bales and planting of
grass where necessary.
                           11-14

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          Erosion control plans and practices can be
written into construction contract specifications so that
little or no adverse impact from solids-laden storm run-
off on the surrounding community occurs.  Chemical contami-
nation of storm runoff during construction can be reduced
if:

               No chemical compound such as calcium chloride
               is used in controlling dust or in melting
               ice and snow; instead sand and gravel is used
               for ice and snow melting

               Chemicals and volatile fuels are stored in
               areas protected by vehicle barriers and
               safety devices to minimize chances for
               spillage.
                           11-15

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III.  COMMENTS FROM STATE AGENCIES

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3.1  Ohio Environmental Protection Agency

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3.1
                                Draft IIIS - Wastewater Treatment Facil 1 ties
                                for the Metropo]ftan Area of_ Columbus Ohio - USEPA
 Mr.  Gene Wojcik                                       April 24, 1978
 EIS  Preparation Unit
 Planning Section
 USEPA Region V
 230  South Dearborn Street
 Chicago, Illinois  60604

 Dear Mr. Wojcik:

 The  OEPA, acting as lead agency and review coordinator on Federal  Environmental
 Impact Statements, has solicited comments on the adequacy of the above referenced
 Draft EIS.   Comments were received from Offices in this Agency, the Ohio Department
 of Natural  Resources, and the Ohio Department of Transportation.

 General:
 On the whole,  the Draft EIS was found lacking in that many of the conclusions reached
 appeared to have little background in known fact, relying more on anticipated occur-
 ences.  Because of these suppositions, much of the document created more questions
 than it answered.  This, in connection with data errors, has produced a document
 which would appear to have little use in planning for the Columbus Metro area, except
 to provide a sounding board (as it no doubt will) for further controversy in the
 Columbus facilities planning activities.

 Specific Comments

      4."   C                                                              (3.1.1)
 Executive Summary

 Page 1.  The statement is made that "The subject action of this Environmental
 Impact Statement is the approval of the Facilities Plans for the City of Columbus..."
 The EIS was required to analyze specific areas of concern, not to approve the
 facilities plan.  Neither the facilities plan nor the EIS satisfactorily addresses
 the concerns of an April 20, 1977 letter to Mr.  Robert C. Parkinson expressing what
 the USEPA and the OEPA saw as deficiencies in the facilities plan.

 Page 3-1I-A.  The statement is made that "The proposed improvements will eliminate
 the discharge of untreated or inadequately treated sewage in most of Franklin
 County", However, the proposed improvements do not adequately address the eleven
 (plus)  county operated plants, four (plus) public utility plants, and approximately
 200 privately operated package plants.

 Page 3-1I-A-(1).  The Ohio EPA disagrees with the first paragraph, which can be
 misleading as to the possible reasons for chlorination-dechlorination.

                                                                          (3.1.2)
   State of Ohio Environmental Protection Agency                   James A. Rhodes, Governor
   Box 1049,361 E. Broad St., Columbus, Ohio 43216 • (614) 466-8565          Ned E. Williams, P.E., Director

                                      III-l

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Mr. Gene Wojcik
Page 2


In subsequent chapters, reference is made to  break-point'chlorination  to  reduce
ammonia to zero.  If, in fact, ammonia is that critical,  it  has  been the  USEPA's
position to require chlorination all year thus necessitating chlorination-
dechlorination all year.  Furthermore, even with  the  proposed improvements  there
will be a considerable amount of enrichment of the  river  caused  by  non-point  and
storm sewer discharges.

Page 4-Item II-A-(3).  Refer to the statement, "The atmospheric  modeling  study
performed by the OEPA to determine the impact on  the  ambient concentration  of
particulate matter from existing and proposed incinerators at Jackson  Pike  and
Southerly is inconclusive".

Any problems with the OEPA study were due to  the  fact that USEPA requirements
were not spelled out at the time OEPA was requested to do the report.   The
existing Southerly and Jackson Pike sources had an  effective PTI prior to March  1,
1978 and should not be subject to P.S.D.  requirements.  No PTI application  has been
received for the proposed incinerators at Jackson Pike or. Southerly and these would
be subject to P.S.D. requirements. Regarding  the  Inter Office Memo  of  February 5,  1976
between Mr. Duprey and Mr. Sutfin, we can only state  OEPA does not  have the money  nor
manpower to do the complete work outlined.  Please  refer to  Mr.  Orlemann's  letter  of
March 27, 1978 to Mr. Sutfin for further clarification.        (3.1.4)

PagelO-Item III-A. Service only to New Albany would affect  the planning being
done by New Albany since a local effort is being  initiated  to incorporate Plain
Township into the New Albany planning activities.

Page IP-Item III-A.  Suggested" service to some portions of  Delaware County  contradicts
the Delaware County EIS which stated that the remainder of  the Scioto  Basin in
Delaware County would be determined through additional facilities planning  by Delaware
County, not through the Columbus EIS.                         (3.1.3)

Page 11-Item III-B.  The analysis which supports  the  conclusion  that the ultimate
population concept is not cost effective for the Columbus area,  is  not complete.
The EIS does not consider the environmental or economic impacts  of parallel sewers,
or building the recommended sewers 15, 20, or 25 years from  now.  (3.1.5)

Chapter I

Page 1-2.  The statement was made that the City and County  were  co-applicants is
incorrect.  Being one of the early grants, the City was the sole applicant for  the
facilities planning grant.                            (3.1.6)

Page 1-6.  The average daily flows indicated are not  representative of the actual
daily flows.  Each plant is being flow controlled to  maintain the integrity of  the
treatment process and  to ensure that  the NPDES permits are  not violated.   A more
realistic average daily flow would be 87 MGD at Jackson Pike and 50 MGD at Southerly as
opposed to the EIS flows of 72 MGD and 46 MGD respectively.    (3.1.7)

Page 1-7.  The NPDES permits issued to the City of Columbus  do not reflect the
stringent levels  required to meet Water Quality Standards.   The  OEPA recognizes
that the permit levels will still result  in water quality violations for 13 miles
downstream of the outfalls.  This information is available in the Scioto WLAR,  Volume I
June, 1974.        (3.1.8)

                                    Hi-2

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Mr. Gene Wojcik
Page 3
Chapter II

Page 11-11.  Reference has been made to "several  fish kills".   The only two reported
fish kills in the last four years occurred in the Olentangy River due to a factory
explosion in the City of Delaware and in the Scioto River because Jackson Pike
was by-passing during a union strike.  From time to time there have been shad kills
in the Big Walnut due to temperature changes and non-point runoff after rains.  (3.1.9)

Page II-12-Item 1.  There is a discussion of the condition of Blacklick Creek.   The
statement is made that "A variety of poorly or partially treated domestic wastewater
releases above this sampling point is no doubt the major cause of the degraded con-
ditions evidenced".  This statement is definitely true.   Upstream is the City of
Reynoldsburg plant which is trying to stay in operation until  it can be phased out.
By-passing is occuring daily.  Immediately upstream of the sample point (which has
been discontinued) is the 1.0 mgd Blacklick Estates Sewage Treatment Plant.  This  is
a public utility operation that produces a very poor effluent but the service proposal
in the EIS does not include this pollution source.   (3.1.10)

Page II-14-Item 4.  There is a discussion of the condition of the Olentangy River  at
Goodale Street which needs clarification.  At the time the sampling was done, the
24 inch "old main sewer" was completely blocked (plugged by grease) causing a contin-
uous overflow to the river.  The magnitude of the overflow was between 1 mgd and 5 rrgc.
The condition has since been relieved by the installation of a temporary pump station
which intercepts flow and force mains it to the OSIS.   (3.1.11)

Page 11-42.  There is a discussion of the inadequacy of the Columbus Water Supply.
The City has the ability and the resources to develop adequate water supplies for
Franklin and portions of adjoining counties.  The OEPA, Office of Public Water Supply,
is working closely with the City in developing adequate water supplies.

Page 11-47.  Under "Agricultural Land" there is a tendency to equate all vacant
(non-residential) land as "prime and unique agricultural lands".  The EIS should
address how much land is active farm land and how much land is just vacant land.  Also
an attempt should be made to determine how much land is held by "farmers" as opposed
to being held by holding companies, developers, etc. and only temporarily leased
back to farmers.   (3.1.12)

Page II-50-Item (2) "Scioto West".  The EIS should explain that the Scioto West
Interceptor would also relieve the flow constraints imposed on the Scioto East Inter-
ceptor.              (3.1.13)

Page II-50-Item (2) "Big Walnut".  The EIS should explain that the Big Walnut
Interceptor would also relieve the existing pollution load into Hoover Reservoir.
The EIS should note that the Sunbury-Galena Facilities Plan must address the possiblit/
of interconnection with the City of Columbus via this interceptor as opposed to buildir:
a treatment plant and discharging directly to Hoover Reservoir.    (3.1.14)

Page 11-54, first paragraph.  The statement is made that excess sewer capacity exists
within the City, however, when one considers the basis under which the sewers were
designed, then the sewers have the capacity for the intended purpose.  Until such  tire-
as the design (ultimate) population is realized* the sewers will (technically)  have
excess capacity.

                                    III-3

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Mr. Gene Wojcik
Page 4
Page 11-54.  Reference is made to the Nelson  Road Water  Plant.  The  EIS should
indicate that this plant has been deactivated.   (3.1.15)

Pages 11-55 and 11-56, Tables 11-23.   These do  not  reflect  the current situation.
The federally approved user charge for sewer  rates  was placed in effect January
2, 1978.  Water surcharge rates remain in effect.   The Urbancrest  surcharge rates
do not appear to be correct.  It is our understanding that  the Village of Urbancrest
pays a surcharge to Grove City which in turn  pays a surcharge to the  City of
Columbus 	 in other words, Urbancrest pays a double surcharge.  The EIS should
be corrected.   (3.1.16)

Figure II-6, inserted between Pages 11-56 and 11-57.  This  figure  is  not correct in
the Dublin area and should be revised.  USEPA should contact the City of Columbus
for an updated map.   (3.1.17)

Page 11-57.  Reference is made regarding the  total  availability of water.  Since
OEPA has monitoring jurisdiction over water supplies in  the State, it has factual
data as to the safe yield for the City of Columbus, the  city's ability to construct
additional capacity and the city's long term  water  needs.   The innaccuracies  in the
EIS data should be corrected by contacting OEPAr Office  of  Public  Water Supply for
further information.   (3.1.18)

Page 11-57 Sewer Facilities.  The statement  is  made that the City's  sewers deliver
an average of 155 mgd of sewerage which is not  consistent with statements on  Page
1-6.  In fact, the statement leads the reader to believe that the  City is bypassing
on a daily basis.  A more valid average sewage  delivery  figure would  be 136 mgd with
the combined average capacity of the OSIS of  161 mgd.  At times the  system is' sur-
charged due to insufficient capacity.  (3.1.19)

Chapter III

Page III-1-Section 3.1.2.  Neither the facilities plan nor  the EIS provides adequate
delineation of the individual service areas for the proposed sewer alternatives.  In
order to provide a coordinated planning effort  for  waste treatment improvements for
Central Ohio, it is necessary that the selected plan identify the  areas to be served
by the projects for each area.   (3.1.20)

Page 111-1, Section 3.1.2.  Reference is made to the force  main crossing Griggs
Reservoir at State Route 161.  The force main actually crosses at  Martin Road a
considerable distance south of State Route 161.   (3.1.21)

Page III-2.  The EIS has incorrectly stated the number of combined overflow points.
There are at least three major overflow points  on  the Southerly System and 30 major
overflow points on the Jackson Pike System.   There  are some 80 to  90  additional over-
flow points on both systems.  This information  can  be obtained from  OEPA files. (3.1.22)

Page III-3-Item 3.1.3-(3) Darby Creek.  Neither the EIS  nor the facilities plan
addresses the gross pollution problem that exists  at the Village of  Orient, or the
fact that a large sewage treatment plant exists at  Orient State Institute which
is in the planning area.  Federal funds have  been with'lield from Orient awaiting
determination of Orient's problem via the Columbus  facYlities plan and/or the
Columbus EIS.  (3.1.23)
                                    ui-4

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Mr. Gene Wojcik
Page 5
Page III-6-Section 3.1.3-(9) Blacklick Creek.  The EIS misrepresents the situation
at the City of Reynoldsburg.  The plant is overloaded and is bypassing daily.   This
plant was scheduled to be phased out by 1976.  Consequently maintenance has been
minimized, parts inventory depleted, and personnel phased out.   If the proposed
solution is to be implemented then immediate and extensive upgrading of the plant,
staff and parts inventory must be undertaken to prevent a major health crisis.   The
EIS should address this potential investment and expenditure.  Had the City of
Columbus been allowed to build at least that portion of the Blacklick Interceptor
to the Reynoldsburg Plant then this situation would not exist.

Consideration should be given to the fact that design drawings  for the Blacklick
Interceptor are complete.  With modifications to the original alignment (as recom-
mended in the comment concerning page 111-30 below) the Reynoldsburg Plant could
be phased out in the near future rather than in the 3-5 years that would be required
to design and construct a pump station and force main.

This section should also address the possibilities of regionalization by eliminating
package treatment plants and providing sewer service to subdivisions from the
Fairfield County Area (representing 1.7 mgd).  (3.1.24)

Page III-6-Section 3.1.3-QO) Groveport.  The EIS misrepresents the situation.   The
Franklin County Commissioners bonded, built and operate the plant for the Village
of Groveport.  The plant and sewer system will  be turned over to the Village when
the bonds are retired in the near future.   (3.1.25

Page 111-8.  The EIS does not present an accurate statement relative to the Scioto
East Interceptor.  The force main is not at State Route 161, but at Martin Road.
The Village of Dublin's service contract with the City of Columbus limits flow  to
29 cfs from the Dublin Area.  Once this capacity is reached, development will be
stymied until the Scioto West Interceptor is built,  (see comment concerning
Page III-l)     (3.1.26)

Page III-9.  The EIS does not utilize correct operation and maintenance costs,
particularly as they relate to the treatment plants.  The figures indicate only
those costs necessary to keep the plants minimally operational  and are therefore
excessively low.  This situation is due to civil  service problems, union problems,
and budget constraints.   (3.1.27)

On this same page, why does EIS assume the life of the Columbus Plants at 35 years
when in all other facilities plans the life of sewage treatment plants is 20 years?

On this same page, OEPA does not generally agree with the conclusion in the EIS
that water pollution problems should be allowed to be created (as in the New Albany
Area) before federal  funds can be used to protect water quality.   This does not re-
flect the best environmental concerns, nor does it seem to reflect the spirit of
Public Law 92-500 or 95-217.   (3.1.28)

Page 111-14.   The Columbus EIS information is inconsistent with regard to the Upper
Scioto Basin and the Delaware County EIS.   The  Delaware County  EIS indicates the
remainder of the Scioto  Basin (Excluding Dublin.and Shawnee Hills) would be determined
by additional facilities planning to be performed by Delaware County.   Again, conflict-
ing conclusions between  the Columbus EIS and Delaware County EIS  should be eliminated.
(see comment concerning  Page 10)                  (3  i 29)
                                    III-5

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Mr. Gene Wojcik
Page 6
Also, on this same page, the EIS proposes a pump station  and  force  main  alternate  to
that of extending the Scioto West Interceptor north  from  Manhole  Number  3.   The
EIS does not include a cost effective analysis (only an economic  analysis)  or  an
environmental assessment of a permanent pump station and  force  main across  Griggs
Reservoir.  Since the present pump station and force main is  near Manhole Number
2, even the economic analysis is not valid.    (3.1.30)

Page III-15-Section 3.2.3 Big Run.  The EIS does not address  the  Lake Darby
Estates Subdivision and its current 0.377 MGD plant  which is  proposed to go
to 1.0 MGD in the immediate future.   (3.1.31)

Page III-17-Section 3.2.4 Minerva Park.  The Alum Creek Interceptor is east of
the Minerva Park plant, not west.    (3.1.32)

Page ni-30-(3) Black!ick Creek.  The EIS does not consider all the facts regarding
the Blacklick Creek proposals.  The Metropolitan Park District  is aware  of  the sewer
alignment.  The Board would like to see this reach of Blacklick Creek cleaned  up
immediately. There have been some temporary plants approved pending the  construction
of the Blacklick Creek Interceptor with minimum requirements  imposed since  they
were going to be phased out in the immediate future.  Again the proposal does  not
consider the potential added benefits of regionalization  by elminating seven Fairfield
County Plants, nor the ongoing Canal  Winchester facilities planning effort.

In the other alternatives explored it should be noted in  the EIS  that Blacklick
Woods Metropolitan Park contains a fifty-five acre woodland which has been  desig-
nated as a State Nature Preserve.  Any routing of an interceptor which would
adversely affect this natural area would be unacceptable  to the Ohio Department of
Natural Resources.

Furthermore, it should be noted tnat Blacklick Woods Metropolitan Park has  been
developed under two separate projects with assistance from the  federal Land and
Water Conservation Fund.  Alignment of the interceptor through  the  park  will result
in a Section 6(f) conflict.  According to  that section of the Land  and Water
Conservation Fund Act:  "Property acquired or developed with assistance  from the
Fund shall be retained and used for public outdoor recreation.   Any property so
acquired or  developed shall not be partly  or wholly converted to other than public
outdoor recreation ..."

The short term effects of interceptor construction are certainly outweighed by the
-improved water quality  in Blacklick Creek  which will result from the elimination
of the Reynoldsburg sewage treatment plant and several smaller facilities.   This
stream, currently under stress  from sewage discharges, is expected  to recover
and support  a high quality fishery.  It  is important to know whether or not additional
disruptions  to parklands will result from  the construction of future connecting
sewer lines  and  this  information  should  be included in the EIS.

The expected number of  additional  stream corssings and future easements  across
parklands or wildlife habitat along Blacklick Creek and the other affected streams
to serve  future  service areas should be  addressed in the  EIS.
                                   Hl-6

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Mr. Gene Wojcik
Page 7
Alternative D has not been properly analyized.   No cost effective analysis  or
environmental assessment has been done.   Construction can not be completed  in
21 months (1980).  Surveying needs to be done,  detail drawings prepared,  and
(most likely) easements obtained.  U.S.  40 is the main street of Reynoldsburg and
is totally commercialized.  There is no room in the right of way for a force main,
thus it would have to be laid in the street or the side walk.  Since the  entire
community would be served by this one pump station, complete duplicate facilities
would have to be installed along with standby power.   This proposed solution is
based on poor sanitary engineering practices.

USEPA would be advised that when investigating  interceptor routes for the Black!ick
Interceptor, adverse impacts on the Blacklick Woods State Nature Preserve should
be avoided.  All alternatives so far noted would significantly impact this  area,
and require extensive mitigation measures.   (3.1.33)

Page 111-32-1tern (5).  The summary is unacceptable to OEPA.   The USEPA proposals
for Big Walnut, Rocky Fork, and Blacklick Creek appear very inadequate.   As stated
earlier, no cost effective analyses or environmental  assessments were done  for the
proposed alternatives.  The previous comments regarding Hoover Reservoir, Reynoldsburg
and Fairfield County were not considered.  Growth in this area has been temporarily
stymied by the lack of sewers and the reluctance of the County Commissioners and
OEPA to approve package plants for developers who hold large tracts of land.  Once  it
becomes obvious that sanitary sewers will not be forthcoming, then the developers
will press for approval of package plants.   (3.1.34)

Page III-36-Item 3.2.6 Groveport;  The EIS is incorrect with regard to the  Groveport
situation.The "Village" of Groveport Plant does have an NPDES permit.   The number
is G916*AD.  It is in the name of the County Commissioners for reasons stated earlier
(see comment concerning Page III-6).  An application for a grant to do SSES is in
the Agency under review.  The Village has requested the proposed interceptors based
upon development pressures they are experiencing.  (3.1.35)

Page 111-39.  As well as elsewhere in the EIS,  the repetitious statement  of "should
be constructed by 1980" is ridiculous.  It will be late 1978 before a portion of
the EIS will be finalized.  Assuming everyone capitulated to the EIS (which is
unlikely) it would be early 1979 before grant application review could commence and
late 1979 before USEPA could approve a grant for detail  engineering to commence.
Construction, at the earliest would be middle to late 1981 or early 1982.  (This
would be eight years from the commencement of facilities planning for City  of Co.lumbus).
                                                              (3.1.36)
Also on this page, the operation and maintenance cost for the Groveport plant cannot
be assigned a value based upon the City of Columbus operation and maintenance data.
The same concern is true for any small entity and is not a valid sanitary engineering
principle.                                                        (3.1.37)
                                   III-7

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Mr. Gene Wojcik
Page 8
Chapter IV

Page IV-3 Brewery Haste Pretreatment  Alternatives.  The  EIS should present additional
information on the potential  environmental  effects of  the four brewery waste pretreat-
ment alternatives.  Besides the short term primary impacts and long term primary
impacts of plant location,  the secondary impacts  of plant location and processes
should be presented.  A site at the brewery should be  selected in order that these
impacts can be given an appropriate technical  relationship.   (3.1.38)

Page IV-7-Item 4.1.4.  The  conclusions appear  to  be based upon erroneous data that
appears in Table IV-2.  The Table indicates under Scenario 1, that the treatment
costs of both 100,000 Ib/day, and 60,000 Ib/day are equal.  Either one is high or
the other is low.  The conclusions should be based upon  Table IV-2 after it is
corrected.  A corrected table should  then also be placed in the  Executive Summary.
                                                             (3.1.39)
Page IV-13-Item 4.2.2.-Q)  Drinking Water Reuse.  The  EIS should compare future
water demand and safe yield data presented against earlier statements on Page 11-57.
                                                         (3.1.40)
Page IV-19-Item 4.2.4 Conclusions.  Here (as well as elsewhere in the EIS) it should
be noted that the bond issue for the power plant  has passed.   (3.1.41)

Page IV-27-Item (2).  The EIS should acknowledge  that  the Nelson Road Plant has been
deactivated.      ("3.1.42)

Page IV-30.  The EIS should acknowledge that future calcination  is a possibility.(3.1.43)

Page IV-30, IV-35, IV-61 and probably elsewhere.  The  idea of disposing sewage sludge
and/or codisposal of incinerator ash into a quarry is  mentioned.  Ohio Solid Waste
Disposal Regulations prohibit the use of quarries and  gravel pits for solid waste
disposal.  Sewage sludge and incinerator ash would definitely be classified solid
waste by OEPA (also by RCRA definition).  Without going  into a lot of detail, the
quarry is considered to be in direct contact with groundwater, and this Agency
would not recommend approval of the use of a quarry for  waste disposal purposes.
                                                             (3.1.44)

Page IV-31.  Mention is made of disposing incinerator  ash at a site adjacent to
the power plant, i.e., Jackson Pike landfill (whic'h is closed).  That site should
not be given high consideration for any further solid  waste disposal.  OEPA has not
approved any such concept and under present conditions,  could not.   (3.1.45)

Page IV-35-(4).  The EIS again ignores the environmental concerns of putting incin-
erator ash in the quarry.  The life of the quarry for  water plant sludge is only  20
years, not 60 years as stated on Page IV-30.  (3.1.46)  (3.1.47)

Page IV-50-Table IV-15.  We assume there is considerable amount  of backup data
available to support Table IV-15.  A considerable number of questions must be asked.
                                    III-8

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Mr. Gene Wojcik
Page 9
     1.  How many trucks is a fleet?
     2.  What is the size and type of the trucks?
     3.  What is the travel time involved?
     4.  What union requirements were considered?
     5.  What wage scale, fringe benefits were considered?
     6.  What secondary roads would they be permitted to use?
     7.  Where would the trucks be kept?
     8.  Where would they be maintained?
     9.  Who would maintain them?
    10.  What energy considerations were made?
    11.  Was an Environmental Assessment done?          (3.1.48)

Page IV-51.  The beginning of the first paragraph is missing, making it impossible
to evaluate the meaning of the first four lines.  (3.1.49)

Page IV-52.  USEPA obviously has not discussed land application with the local  Farm
Bureau.  Had they done so, the statements under 4.3.5(2) would have been quite
different.  Farmers are more inclined to require the City to spread the sludge  so
they do not have to invest in equipment.  They also believe they are doing a  favor
or providing a service to the City, consequently they (the farmer) should be  paid
to accept  the sludge, not the other way around. •   (3.1.50)

Pages  IV-54, IV-55, and IV-56.  Landfill disposal of sludge is discussed.  Land-
filling sludge is not given high potential and OEPA would agree.  Special sites,
plans, and specialized operations are required, and it is a waste of an excellent
resource and landfill space.  The two landfills specifically mentioned, City  of
London, and Richwood, do not have approval to take sludge.  The comment that  they
are "able" to take sludge is false.  Plan approval and PTI processes would need be
undertaken.        (3.1.51)

Page IV-62.  A program for reclamation of barren strip mines is outlined.  No
mention is made as to how or where the funding should be provided to start a  program
immediately.  Can USEPA provide funding for such a demonstration program?  (3.1.52)

Again, hauling sludge to individual farmland to be spread by the owner is full  of
problems.  Who is responsible for the actions or inactions of the farmer?  Who  will
be charged with monitoring the farmer's operation to assure that ground water and
stream pollution do not occur?  Does USEPA have the manpower or available funding
for such a program?

Page IV-63-1 tern 4.4.  This presents a very serious problem to the OEPA.  USEPA
appears to have used the EIS to expound or produce a "value engineering" .document.
Not only that, but it goes on to recommend "brand X".  The statement is made
"This  mention is not to be construed as an endorsement of or a recommendation for a
particular manufacturer's products;" however, when no "or equal" exists in the
market place what else can one do except buy "brand X"?    (3.1.53)

Page IV-65-Item 4.4.3 Oxygen Production and Dissolution.  OEPA does not disagree
with the fact that the present sock system at the Columbus plants severely Affect
plant  operations, as well as being "maintenance-intensive"; however, a more in
depth  analysis must be performed.  Opting for a quick solution that has not been
properly field tested (with annual data) is not the answer.  Unless of course USEPA
is willing to pick up 100% of the costs.      (3.1.54)
                                    III-9

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Mr. Gene Wojcik
Page 10
Page -IV 73.  The EIS discusses using the interconnected  for  storing  excess flow
and using the interconnector to dampen peak  flows  to  Southerly.  On  paper this
sounds feasible, but it introduces  a number  of maintenance problems.  (3.1.55)

Page IV-74.  The EIS discusses the  brewery's discharge to be staged  to  conform
to the reverse image of the normal  domestic  pattern of wastewater  generation.
This being the case, then 6 p.m.  to 6 a.m.  is not  correct.   Travel time from  the
brewery is 22 to 24 hours.    (3.1.56)

Page IV-80.  The EIS design loads to Jackson Pike  and Southerly  do not  include
recycle flows.  There is also no mention of  what happens to  filter backwash.  At
the current time, the OEPA only permits one  manufacturer to  design at a maximum
of 5 gpd/S.F.  Requiring the City of Columbus to design  to this  figure  is specify-
ing a particular equipment manufacturer and  eliminating  competitive  bidding.
                                                             (3.1.57)
Chapter V

Page V-2-1 tern 5.2.3.  The EIS states that "Immediate  standby facilities for sludge
disposal can be provided by landfill ing".  The EIS fails to  take into account the
City's inability to develop and/or  utilize an a-cceptable landfill  site. (3.1.58)

Page V-4, Table V-l.  As an immediate short  term goal, the EIS states,  "Realize
total hydraulic capacity of Jackson Pike and Southerly for wastewater treatment
before expanding either facility or incorporating  flow equalization  concepts".
The EIS fails to consider the internal constraints at Jackson Pike or Southerly
as well as the original peaking factors used for both facilities.  (3.1.59)

Page V-6.  The EIS discusses the reclamation of strip mine  land again, but does
not propose a means for funding the project.  If the  City is to  fund it, then it
must be worked into the Capital Improvement Program/Budget.   This  would take  at
least a year or more.   (3.1.60)

Page V-8.  The EIS again discusses  placing incinerator ash in the  quarry.  As
stated earlier this is prohibited by Ohio Solid Waste Disposal Regulations.

Page V-l3.  The EIS recommends building a bypass around  the  trickling filter  so
that savings can result when complete nitrification is  not a treatment  requirement.
Apparently the EIS author did not review this proposal 'with  permit section staff.
USEPA, Permit Section, has required that OEPA insist  on  year round nitrification
a~t Columbus.  If Appendix B of this EIS is to be followed, then  again the bypass  is
a waste of money.   (3.1.61)

Page V-14-(4)-Final Effluent Filtration.  The EIS  assumes the City will install  the
effluent filtration system of one particular manufacturer.   (3.1.62)

Page V-26.  The EIS "glosses over"  the operation and  maintenance staff  at the two
plants.  This is a very serious and time consuming problem which appears to be
getting worse not better.  The realities of the employee situation should be
considered at this point.    (3.1.63)
                                   Hl-10

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Mr. Gene Wbjcik
Page 11
Also on this page, the EJS .should address what happens next,  should  the  pretreat-
ment of the brewery waste not solve the bulking or operational  problems  at  Southerly.
                                                                    (3.1.64)
Also on this page, the OEPA feels a need for pilot testing the  treatment process
particularly if anything other than normal design standards are going  to be insisted
upon.                                                               (3.1.65)

On Page V-27.  The EIS is again asking the City to consider equipment  available
from only one manufacturer.  (3.1.66)

Chapter VII

Page VII-3.  The EIS draws false conclusions with regard to the area's economy
being, held in check by inadequate water supplies as an independent control  factor.
                                                                      (3.1.67)
Page VI1-11, Table VI1-1.  This table does not represent the proper design  flow
used in Ohio or the current cost for treatment.  The OEPA requires a flow value
of 400 gallons per home.  Day to day experience indicates that  the costs are higher
than the table indicates.  The EIS should acknowledge that Ohio does not operate
under South Carolina policies, guidelines, and'procedures.    (3.1.68)

Page VII-13.  It is the opinion of the OEPA that sufficient development  pressures
exist in the Blacklick Creek and adjoining Fairfield County areas to require ser-
vice either in the form of connection to Columbus or package treatment facilities.
                                                                (3.1.69)
Page V11-15.  The OEPA questions whether USEPA has supplied adequate informa-tion
to support the conclusion that it is unlikely that the influx of business and
and  industry will be sufficient to fill currently vacant commercial  space.   As an
example, 1977 and ,1978 commercial space figures would be more appropriate in es-
tablishing "trend concepts".    (3.1.70)

Page VII-17-Q) Manmade Environment.  OEPA agrees that some demand may be placed
on the City of Columbus where the already serviced, developable areas  are located.
However, a review of OEPA's files and those of Mid-Ohio Regional Planning Commission
will show that an even greater demand exists where services are not located.(3.1.71)

Page VII-21-(4) Rocky Fork.  The EIS neglects the effect of Plain Township  being
incorporated into New Albany,  (see comment concerning Page 10)  (3.1.72)

Page VII-21-(5) Blacklick.  The EIS conclusion is unacceptable  for reasons  stated
earlier.(see comments concerning Pages  III-6, 111-30, and 111-32)

Page VII-22.  The EIS fails to distinguish between farm land, vacant land,  and
prime developer land.  Again an attempt should also be made to  determine whether
land is owned individually or being held by large corporations  or holding companies
for  speculative development purposes,  (see comment conerning Page 11-47)

Page VII-29-(2) Surface Water Quality.  The EIS should indicate that the City of
Reynoldsburg plant is continuously bypassing and has an adverse effect on the
Blacklick Creek.  Chapter III does not offer the City of Reynoldsburg  the immediate
solution proposed in the facilities plan.    (3.1.73)


                                   HI-11

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Mr. Gene Wojcik
Page 12
Page VII-30 7.5 Secondary Impacts of the EIS Plan.   The conclusions  are not totally
acceptable.  Specifically, as part of the Southerly Service Area;  the Blacklick,
Rocky Fork and Big Walnut Creek sub-areas are unacceptable.   In  the  Jackson Pike
Service Area; the Delaware County area is premature.     (3.1.74)

Chapter VIII

Pages VIII-1 and VI11-2.   The discussion of mitigative measures  for  adverse
primary impacts should address sewer construction as  well  as treatment plant
construction.  This becomes of major importance in the Black!ick/Reynoldsburg
area if any of the alternatives are selected.

Included in this discussion should be the identification of the  following issues
raised by the Ohio Department of Transportation (ODOT).

     1.  There should be a discussion of traffic diversion during
         construction of the various interceptors.

     2.  On implementation of the various Wastewater Treatment Plans
         in the Draft by EIS, further coordination should be conducted
         with ODOT's District 6 office regarding the following:

              West Scioto

                   Alternate No. 1
                        a.  FRA-(project) Hayden Run Road
                        b.  FRA-(project) 33-6.14

                   Alternate No. 2
                        a.  FRA-(project) Hayden Run Road
                        b.  FRA-(project) Fishinger Road (County Rd. 52)
                        c.  FRA-(project) 33-6.14

              Big Run

                   Alternate No. 1
                        a.  FRA-(project) Broad Street Bikeway

              Big Walnut Creek, et. al.

                   Alternate A-
                        a.  FRA-(project) County Road 20
                        b.  FRA-(project) 161-16.83
                        c.  FRA-(project) Township Road 195

                   Alternate B-
                        a.  FRA-(project) 161-16.83
                        b.  FRA-(project) Township 195

                   Alternate C-
                        a.  FRA-(project) County Road 20
                        b.  FRA-(project) J61-16.83
                        c.  FRA-(project) Township 195
                                    111-12

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Mr. Gene Wojcik
Page 13
                   Alternate D-
                        a.  FRA-(project) 161-16.83
                        b.  FRA-(project) 161-16.37

                   Alternate Sub B-
                        a.  FRA-(project) TR195
                        b.  FRA-(project) 161-16.37          (3.1.75)
Appendix A
Page A-3-Item A.I.3 Major Interceptors.   The Southerly Plant receives  flow  via
the interconnected  The flows originate from Grove City and Urbancrest and amounts
to some 2.75 to 3.0 mgd.   (3.1.76)

Page'A-16-Itern 16.  The EIS states that "all thermally conditioned and filtered
slude is landfilled".  This is not true.  Ohio EPA is not aware of, nor have they
approved, the landfilling of thermally conditioned and filtered sludge. (3.1.77)

Page A-17-Item 17.  The EIS implies that the Jackson Pike incinerators have
scrubbers.  This is not true. Scrubbers are currently under construction.   (3.1.78)

Page A-18, A.3.2 Southerly.  The EIS states that no further expansion  of the solids
handling and incineration system was thought to be necessary.  This could not be
further from the truth.  Since at least 1974, the City has been attempting  to
expand the solids  handling and incineration facilities.  They have been repeatedly
held up by USEPA.   (3.1.79)

Page A-23-Itern 16.  The EIS should indicate that the Dewatering Complex is  "main-
tenance intensive".  It is rare that more than two units are ever working and
are almost beyond" repair.  (3.1.80)

This same page Item 17.  The EIS should explain that the incinerators  break down
due to the inability of the City to perform maintenance.  The City cannot afford
to take one off line without causing solids problems in-plant.  The sludge which
was lagooned at the plant site was not digested sludge.  It was raw sludge  limed
to a pH of 12 before lagooning.  The lagoons were subsequently flooded with water
to suppress odors.  Other methods were also tried to suppress odors. (3.1.81)

Page A-26, and A-29.  The cost figures do not reflect proper operation and  main-
tenance for the reasons stated earlier,  (see comment concerning page  III-9)
                                                               (3.1.82)
Appendix B

Page B-11.  The report incorrectly assumes the flows as measured by the Columbus
gage on the Scioto River is indicative of flows upstream from the Jackson Pike
Wastewater Treatment facility.  While it is true the gage is located approximately
300 to 500 feet upstream of the discharge point of the Jackson Pike facilities,  it
is incorrect to assume the gage does .not include the discharged flow.   In fact
under the remarks  accompanying the U.S.G.S. gaged records you will find the follow-
ing comments:  (Page 290:  Water Resource Data for Ohio - Water Year 1976 Vol.  1
Ohio River Basin)  - "Records include the return flow of the Frank Road Sewage
Treatment Plant".  Thus the computed 0,7 - \0 flow of 127 cfs is made up of  the

                                   Hl-13

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Mr. Gene Wojcik
Page 14
sewage flow plus the river flow upstream of the plant.   If one estimated the minimum
weekly sewage flow to be 65 mgd or 100 cfs the upstream flow would be approximately
22 cfs or close to the value of 18.2 used in the agency's 303 wasteload allocation
report.

Further evidence of this fact may be seen from the following U.S.G.S. records.

    YEARS IN WHICH THE MINIMUM WEEKLY FLOW AT COLUMBUS  APPROACH
          122 cfs AND RELATED FLOWS IN THE OLENTANGY RIVER
Year
                     Scioto River @ Columbus
Q7 CFS

  126
  125
  133
  129
  131
  124

  127.5
                       Mean
                   Olentangy River
                    @ Worthington
13
12
14
13
12
30

13       Mean
Difference
  113
  113
  119
  116
  119
   94

  114.5 cfs
From the above it will be noted that the differences in flow between the two
gauging stations has a mean of 114.5 cfs and is indicative of the minimum weekly
sewage flow from the Jackson Pike Plant.  In addition, the upstream flow of the
Scioto River is only slightly greater than the mean of 13 cfs measured at the
Worthington gauge on the Olentangy River.

During the drought period of 1953-55, the difference in monthly mean flows between
the Circleville and Columbus gauges varied from 40 to 71 cfs with a mean of 53 cfs.
Even if there was no runoff from the incremental drainage area of nearly 1600 square
miles (which is highly unlikely) the difference in flow hardly accounts for the
discharge from the Jackson Pike Plant.   (3.1.83)

Pjtge B-12.  Comments similar to the above may^be made concerning winter flows of 222
cfs used for modeling winter low stream flow'conditions.  (3.1.84)

-This matter was the subject of an intensive study in 1961 by George Newell (now with
City of Columbus) and Mr. George Garrett of Ohio EPA in cooperation with the U.S.G.S.
It should be recognized that the assumed summer and winter low flows contain a ser-
ious error and thus weaken the presentation of the model's results.

Page B-18.  The model runs illustrated in figures B-3 and B-4 and presented in
tables B-2 and B-3 assume the river is a free flowing stream immediately downstream
of the Jackson Pike facility.  Although this is a common assumption it is inappro-
priate for this stretch of the river particularly with the completion of the
chanelization program in the early 1960s.  Immediately downstream of Jackson Pike
facilities, the river narrows sharply and makes a sharp turn to the east on the
first leg of an oxbow bend in the river.  As a result of these extreme directional
changes and other physical characteristics of the river, stream flows through the
oxbow bend are restricted and the discharge'from the Jackson Pike facilities is

                                •  111-14

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Mr. Gene Wojcik
Page 15
forced across the stream where it in turn, flows  upstream along  the  eastern  bank  to
the vicinity of Frank Road.   This pool-like condition signficantly  alters the  time
of travel calculations and thus the location of  the oxygen sag  point.   This in turn
modifies the impact of the Jackson Pike discharge on discharges from the Southerly
Plant downward.    (3.1.85)

Pages B-19 and B-21.   The allocated loads presented in Table B-4 for the Jackson
Pike facilities and in Table B-5 for the Southerly facilities represent treatment
levels greater than that currently considered as "best available technology currently
available".  Furthermore, there is a serious question as to the reaction rates for
effluents of this high a quality.  In view of the foregoing, it appears that a policy
decision must be made as to the maximum treatment that may be required  of municipal-
ities whose discharge make up a major share of the downstream flow  for  a significant
portion of the summer low flow period.   It should be noted that, as indicated  at the
top of page 20, the loads modeled for wasteload  allocation purposes represent  concen-
trations that closely approach background levels.  In view of the significant  impact
of combined sewer overflows on the river as indicated in Appendix H there should be
a point where the benefits from the control and  treatment of such overflows provide
a greater benefit than additional treatment of dry weather flows.   (3.1.86)

Pages B-22.  The finding that no measureable benefit would be obtained  by shifting a
portion of the load from Jackson Pike to the Southerly Plant is consistent  with
similar studies conducted by this Agency.

Page B-23.  The finding that essentially only secondary treatment is necessary during
wintertime stream flows to maintain water quality standards is  consistent with model
runs conducted by this Agency with the exception of extremely warm  weather  conditions
during November such as that experienced during  the first half  of November  1975.
                                                                     (3.1.87)
Appendix C

Page C 1-4.  The Water Quality Standards reported on these pages are those  adopted
by this agency in 1974, not the current Water Quality Standards adopted in  February
1978.  (3.1.88)

Page C 5-20:  Tables C-2 C-17.  The Water Quality data presented in these tables
gives a fair and accurate portrayal of the water quality of Scioto  River and its
tributaries within the central Ohio area.

Appendix H

Pages H-2 and H-3.   Not all  the regulators are listed.   Also, there is  no mention
that all  the sluice gates are set half closed and what effect this  might have  on
the system.  There is also no discussion of the  other 80 to 90  overflows,   (see
comment concerning Page III-2)   (3.1.89)

Appendix I

Page 1-27.  The EIS states that the interconnector construction would permit tie-in
of the Big Run and Frank Road Jackson Pike Service Area interceptors.   This  is not
true.  The only tie-in will  be the Big  Run Interceptor which recently had an esti-
mated flow of 75 MGD.    (3.1.90)

                                    111-15

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Mr. Gene Wojcik
Page 16
Appendix K

     K-5.  The EIS establishes overflow rates which are not consistent with  Ten
State Standards, Ohio EPA design criteria or good sanitary engineering design.   They
appear to be for the sole purpose of establishing dollar savings,  not obtaining good
treatment efficiencies.  (3.1.91)

Pages K-8, K-9, K-ll, and K- 12.  The EIS establishes design parameters which are not
satisfactory for the reasons just cited.  At the very least, full  scale pilot testing
would be necessary at both plants to establish credibility.  Then  some safety factor
needs to be applied for day to day operation.  (3.1.92)

Appendix L

The OEPA is not familiar with the publications used to develop Appendix L.
It appears to be too general and lacking considerable information  applicable
to the land application of sewage sludge.  We would recommend the  authors of
the EIS review "Ohio Guide for Land Application of Sewage Sludge,  Bulletin 598".
This bulletin was issued in furtherance of Cooperative Extension work, acts of
May 8 and June 30, 1914 in cooperation with the U.S. Department of Agriculture,
Roy M. Kottman, Director of the Cooperative Extension Service, the Ohio State
University.    (3.1.93)

Page L-l .  It is stated that information such as sludge composition, the type of
crops to be grown, and certain soil characteristics including pH,  cation exchange
capacity, and available phosphorus are needed prior to calculating the rate of
sludge application.  This is true although additional information  is also necessary.

For example, before the actual application of sludge can take place, various on-site
landscape features must also be considered to insure that no surface or groundwater
pollution will occur as a result of leaching or runoff.  Such site information as
the amount of xSlope, the proximity to standing and flowing water bodies, the possi-
bility of a flood hazard, the depth o.f the soil, the depth to the  water table, and
the amount of lateral seepage is required.

Equally important are the chemical and physical properties of the  soil.  Chemical
characteristics not only encompass ptt, cation exchange capacity, and phosphorus
retention, they also include the amount of organic material present.  The latter
becomes important if the sludge contains heavy metals, since a high degree of organic
matter increases the cation exchange capacity of the soil and also immobilizes some
heavy metals due to chelation.

Physical soil properties, on the other hand, include texture, structure premeability.
and credibility.  Texture is the most important physical property  since it can
determine the phosphate retention, CEC, permeability, drainage, erodibility, and
buffer capacity of the soil.  The type of soil structure determines the overall water
movement which, in turn, influences the drainage and aeration.
                                   111-16

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Mr. Gene Wojcik
Page 17
Page L-2.  It is stated that the criteria used in preventing injury to plants  from
application of sludge containing heavy metals is based upon the total  amount of Pb,
Cu, Zn, Ni, and Cd present.  While Cu, Zn, Ni, and Cd are toxic to plants  when
they occur in soil in significant amounts, Pb can be toxic in acid soils that  are
low in phosphate.  Pb in sludge seems to be non-toxic since the large  amount of
phosphate generally present ties up the lead prventing injury to plants.

Page L-5, Step 2, Part a.  Reference is made to Table 3.5 when it should be made
to Table 3.3.   (3.1.94)

Summary

In general it appears that USEPA has misused the NEPA process in this  instance.   As
USEPA has indicated in its regulations, the purpose of an EIS is to relate to  the
decisionmaker the environmental impacts of a proposed action in order  that the
decision maker can use that information in concert with economic factors to
make a decision in a more comprehensive manner.  This is a proper function,
and one that the Council on Environmental Quality has reiterated in its draft
revisions to the NEPA regulations.

However, in considering what the EIS is, consideration must also be given as to
what it is not.  It is not a document whereby new alternatives are developed outside
the normal planning process, nor is it a platform for comparative analysis of
various alternatives.  Both of these actions are more appropriately carried out in
the planning process (in this case 201 planning).  Attempts at bringing forth  new
proposals in such a manner are doomed to failure because of the conflicting bases
of project planning and EIS document production — the former must be detailed
and comprehensive while the latter should be general yet concise.  Such conflict
is very evident in this EIS document where (as the previous comments have shown) the
planning bases were not detailed enough, (the repeated lack of cost effective
analyses and environmental assessment) and where the environmental impacts of  the
proposed actions were not considered properly (interceptor route primary and
secondary impacts).

While the above may be rightfully perceived as "lecturing" USEPA on its own proce-
dures, it is being done because of a disturbing tendency, by USEPA to  use the  EIS
as the "fix" for what is perceved to be inadequate planning.  The proper vehicle
for dealing with this situation is during plan review, not as a competition to
existing proposals.  The ludicrous situation that we now find ourselves in is  one
where Columbus now has two facilities plans; neither of which has been (or possibly
can be) approved by OEPA.  We are at a loss as to how to resolve this  issue, and
we fear that this may not be the last occurrences.

We can only state that it is our fervent hope that USEPA will, in the  future,
restrain themselves in calling for an EIS because of facility planning deficiencies,
and will more appropriately attempt to resolve those deficiencies during plan  review.
                                   111-17

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Mr. Gene Wojcik
Page 18
Then, possibly, EIS's will  be produced  only on  proposed actions significantly
affecting the environment,  as they  should  be.
Sincerel
ted
Director

NEW/dmc
12013.0
                                    Ill-IB

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3.1       Ohio Environmental Protection Agency


3.1.1     Comment:  The Executive Summary contains several
errors and statements with which OEPA takes exception.


          Response:  The Executive Summary in Volume III has
been edited for errors.  OEPA's other concerns are responded
to below and in Volume I.
3.1.2     Comment:  The explanation behind the recommenda-
tion of chlorination-dechlorination is misleading.

          Response;  The basic reason dechlorination was
recommended when chlorination is practiced is for the pro-
tection of aquatic life from toxic chlorine concentrations.
Further discussion of this point can be found in subsection
4.2.3 of Volume III.  Statements in the EIS regarding break-
point chlorination capabilities are made to point out the
ease of achieving superior short-term effluent levels from
the treatment facilities.  This point is particularly cri-
tical in light of the commonly-held belief that facilities
designed to NPDES effluent levels will not maintain quality
standards in the Scioto River during a 7-10 flow regime.
3.1.3     Comment:  Service to portions of Delaware County
contradicts statements in the Delaware County EIS.
          Response:  The option of this service provision
is being left open in the EIS so that the option will remain
when the future planning referenced, is undertaken without
delaying necessary construction in the Columbus facilities
planning area.
3.1.4     Comment:  The problems with the OEPA atmospheric
modelling study which are inferred are not sufficiently
explained.

          Response;  U.S. EPA has devised a draft policy
with regard to the use of new and rehabilitated incinerators
at the Columbus, Ohio, Jackson Pike and Southerly sewage
treatment plants, which are located in a nonattainment area
for particulates and SO2-  This draft policy has been incor-
porated into the statement.
                          111-19

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3.1.5     Comment:  The statement does not consider the
construction of parallel sewers or phasing of sewer con-
struction which might be cost-effective for the Columbus
area.

          Response:   The Federal regulations for cost-
effective analysis and 201 facilities planning do not allow
the consideration of parallel sewer construction as an
alternative plan.  Phasing was considered in particular
interceptors.
3.1.6     Comment:  The City and County were not co-applicants
for the 201 planning grant.

          Response;   The correct identification of the City
as the sole applicant has been noted.


3.1.7     Comment:  The average daily flows cited for the
Jackson Pike and Southerly treatment plants are not realis-
tic due to flow control measures.

          Response;   The OEPA's suggested average daily
flow figures have been cited in Chapter I, subsection
1.5.2 of Volume III.
3.1.8     Comment:  The NPDES permits issued to the City
do not reflect the stringent levels required to meet water
quality standards.

          Response:   The statement has been corrected.


3.1.9     Comment:  The reference to several fish-kills
is misleading.

          Response;   The reference in subsection 2.1.3(2)
has been reworded to reflect OEPA's information.
3.1.10    Comment:  The EIS service proposal has not
addressed elimination of the Blacklick Estates Sewage
Treatment Plant  (a public utility).
                          111-20

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          Response:  This comment will be addressed in
later responses regarding the overall Blacklick Creek area
(see Chapter IV, Section 4.3 of Volume II).
3.1.11    Comment:  The discussion of the condition of the
Olentangy River at Goodale Street needs clarification.

          Response:  The clarification has been noted in
subsection 2.1.3(2)4 of Volume III.
3.1.12    Comment;  The EIS should contain greater defini-
tion and discussion of prime and unique farmland as opposed
to vacant land in the area.

          Response:   Reliable estimates of prime and unique
farmland as well as ownership patterns within Franklin
County are not available at this time.  SCS has a survey
underway; however, the data will not be processed nor
available for some time due to limited manpower resources
for the survey program.
3.1.13    Comment:   The EIS should explain that the Scioto
West Interceptor would also relieve the flow constraints
imposed on the Scioto East Interceptor.

          Response;   No flow constraints are known to exist
or to be projected for the Scioto East Interceptor, whose
upper portions are estimated as capable of carrying over
50 mgd.
3.1.14    Comment:  The EIS should note the relationship
between the Columbus and Sunbury-Galena Facilities Plans
for service alternatives around Hoover Reservoir.

          Response:   Analysis of the service needs and the
possible interconnection of the Sunbury-Galena area with
the City of Columbus system will be undertaken in the
Sunbury-Galena 201 facilities planning process.  This is
discussed in subsection 3.1.3(6) of Volume III.
3.1.15    Comment:  The EIS incorrectly identifies the
Nelson Road Water Plant as still in operation.

          Response;  The reference has been deleted.
                          111-21

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3.1.16    Comment;  Table 11-23 no longer reflects the
water and sewer user charge system that U.S. EPA approved
for the City of Columbus.

          Response;  The new user charge system instituted
on January 2, 1978, has been referenced and Table 11-23
deleted.
3.1.17    Comment;  The maps showing water service areas
are not correct for the Dublin area.

          Response:  More current maps are now available
from the City of Columbus and have been noted for future
reference.
3.1.18    Comment;  The figures cited for safe yields of
water for the City of Columbus are incorrect.

          Response;  The discussion regarding water supply
needs, projections, and potential sources of water supply
for the Columbus metropolitan area has been revised to
reflect information provided by the City of Columbus,
Division of Water.
3.1.19    Comment;  The daily average sewer flow is incon-
sistent with figures cited on Page 1-6.

          Response;  The statement has been reworded to
reflect the range of daily sewage flow since average daily
flow figures must be related to a specific time period to
be meaningful.
3.1.20    Comment:  More detailed ^description of the
individual service areas and service alternatives should
be provided in the statement.

          Response;  The descriptions provided are con-
sidered adequate for the purposes of the alternative con-
cept planning and analysis.  More detailed descriptions
of the various service areas can be given at the step 2
level of planning.
                          111-22

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3.1.21    Comment;  Reference to the force main crossing
Griggs Road at State Route 161 is inaccurate.

          Response:  The reference in subsection 3.1.2 has
been corrected.
3.1.22    Comment;  The EIS has incorrectly stated the
number of combined overflow points.

          Response:  The references have been corrected.
3.1.23    Comment;  Pollution problems in the Village of
Orient hav¥ not been addressed in the Facilities Plan or
in the EIS.

          Response;  Orient was considered for potential
service in 1995 by the facilities plan.  However, it was
not cost effective to provide the service; consequently,
the recommendation was not made.  Orient is in Pickaway
County and was not in the planning area designated by U.S,
EPA for analysis in the statement.
3.1.24    Comment;  The EIS misrepresents the situation at
the City of Reynoldsburg.

          Response;  Please see the responses to comments
by the City of Reynoldsburg in Chapter IV, Section 4.3 of
this volume and Volume I.
3.1.25    Comment:  The EIS misrepresents the situation in
Groveport.

          Response;  Two sentences have been added to the
discussion referenced, as follows:  "The Franklin County
Commissioners currently own and operate the treatment plant
for the Village of Groveport.  The plant arid sewer system
will be turned over to the Village when the bonds are retired
in the near future."
3.1.26    Comment;  The EIS does not present an accurate
statement relative to the Scioto East Interceptor.
                         111-23

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          Response;  The reference to location has been
corrected.  The limiting discharge of 29 cfs (18.7 mgd)
from Dublin is over twice the peak flow estimated to come
from both Dublin and the southwest portion of Delaware
County (if this flow is collected by the City of Columbus),
as pointed out in Table III-2 for the modified plan.  Hence,
growth is not likely to be "stymied."


3.1.27    Comment:  The EIS does not use correct operation
and maintenance costs or plant life figures.

          Response:  If treatment plant lives were shortened
and/or related 0 & M costs increased, the cost-effective
analysis involving the consideration of a treatment plant
would not be changed, since all the treatment plant alter-
natives considered in the draft EIS were found not to be
cost-effective.
3.1.28    Comment;  Allowing water pollution problems to
happen (as in New Albany) violates the spirit of PL 92-500
and PL 95-217.

          Response;  The New Albany situation was used in
the EIS as an indication of when to expect pollution to
be evidenced in an area, thus allowing a reasonable esti-
mate to be made of when sewer construction should be phased
so as not to create economic burden by premature facility
construction.
3.1.29    Comment:   The EIS information is inconsistent
with regard to the Upper Scioto Basin and the Delaware
County EIS.

          Response;  The EIS did not size the West Scioto
Interceptor in an effort to instruct Columbus to serve
southwestern Delaware County.  The sizing was put forth
so that the lower section could be constructed without
further delay.  If this section is constructed of the size
mentioned in the EIS, it would not have to be paralleled
in the event a future decision does call for the transport
of sanitary flow from southwestern Delaware County.
3.1.30    Comment:  The EIS does not include a cost-effective
analysis or environmental assessment of the permanent pump
station and force main across Griggs Reservoir, and the
economic analysis is invalid.
                          111-24

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          Response;  The main purpose for the consideration
of the pump station and force main is to delay the construc-
tion of the interceptor between Manholes 2 and 3.  It is not
clear how the "economic analysis" is invalid.

          The first paragraph on Page 111-12 of the EIS
under "Costs" states that a present worth basis was con-
sidered for a pump station versus an interceptor above
Manhole 3.  The detailed analysis was not presented in the
report but is reproduced below:
                        West Scioto

                               Interceptor    Pump Station

     1980 Capital Cost
       (50 year life)          $1,421,000      $ 63,000
       (20 year life)               0           350,000
     1980 Present Worth of
       Salvage                   -248,000       -11,000
     1980-2000 O&M P.W.
       Interceptor and Force
       Mains                       40,0001        2,0001
     1980-2000 O&M P.W.
       Pumping Station         	0	       318,OOP2

                               $1,213,000      $733,000

     1  0.25% of construction cost.
     2  O&M varies from $20,200/yr. in 1980 to $33,600/year
        in 2000.
          The P.W. of the interceptor is some 65 percent
greater than the P.W. of the Pump Station.
3.1.31    Comment:  The EIS does not address the Lake Darby
Estates subdivision and its current 0.377 MGD plant which
is proposed to go to 1.0 MGD in the immediate future.

          Response;  Lake Darby Estates subdivision is
located near Galloway, Ohio, which is not in the Darby
Creek subarea.  This subarea was not reviewed in depth
due to its elimination during preliminary screening through
both its low projected population densities and the diffi-
culty of providing regionalized service to the area.
                          111-25

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3.1.32    Comment:  The Alum Creek Interceptor is east of
the Minerva Park Plant, not west.

          Response:  The reference has been corrected.


3.1.33    Comment:  The EIS does not consider all the facts
regarding the Blacklick Creek proposals.


          Response:  Please see the responses to comments for the
City of Reynoldsburg in Volume I and Chapter IV, Section 4.3 of Volume II,
3.1.34    Comment;  The summary and U.S. EPA proposals  for
Big Walnut, Rocky Fork, and Blacklick Creek appear to be
inadequate.  If sanitary sewers are not provided to these
areas, there will be pressure by developers for the approval
of package plants.

          Response:  U.S. EPA's policy is not to fund sewers
for development, but rather to correct or abate existing and
potential water pollution problems. In some cases, the  use  of
package plants can be the most cost effective solution  for
sewage treatment provided the plants are properly sized,
installed, and operated.  Regulation of package plants  should
be upgraded as necessary to ensure environmental protection.
3.1.35    Comment:  The Groveport treatment plant does  have
an NPDES permit; however, it is in the name of the Franklin
County Commissioners.

          Response:  A telephone request was made of OEPA
for NPDES permits for Reynoldsburg, Minerva Park, Ricken-
backer AFB, and Groveport.  On July 14, 1977, three NPDES
permits were received with a note attached which stated that
Groveport did not as yet have a permit.  Apparently, this
was not the case.  It should be noted that this permit
ultimately requires a tie-in to the collection system of the
City of Columbus.
3.1.36    Comment:  The repetitious statement of  "should
be constructed by 1980" is ridiculous and misleading.
                          111-26

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          Response:  The statement "should be constructed
by 1980" should be interpreted as needed as soon as possible.
The year 1980 was stated since this is the beginning of the
planning period.
 3.1.37    Commen t;  Operation  and maintenance  (O&M) costs
 for Groveport, as well as other  small entities, should not
 be assigned values based on City of Columbus O&M  figures.

          Response;  The O&M for the Groveport  WWTP and
 for other small facilities were  not based upon the City of
 Columbus costs and in fact are approximately twice as high.
 However, if these O&M figures  seem low, it should be
 noted that any increase would  only correspondingly increase
 their associated present worth,  thereby causing treatment
 plant alternatives to become even less desirable  than shown
 in the EIS.
 3.1.38    Comment;  The EIS should present additional infor-
 mation on the potential environmental effects of the four
 brewery waste pretreatment alternatives.

          Response:  It would seem to be apparent that the
 primary impacts of no brewery pretreatment are presently
 being exerted on the Scioto River through the Southerly
 release.  Short-term impacts of construction at the brewery
 site should be far less than those associated with either
 the original brewery construction or any future expansion
 of the brewery.  Long-term primary impacts near the brewery
 of Scenario 2 should not exist, since the only final
 release on site will consist of deodorized air.  Added
 impacts in Scenario 3 will be those associated with sludge
 disposal, a consideration which can either be addressed
 in conjunction with the City or through separate action
 by the brewery.  Scenario 4 combines both the sludge impacts
 of 3 along with a release to a stream.  Regardless of the
 projected actual severity of those impacts, they are ob-
 viously worse in a relative sense than those associated with
 Scenarios 2 and 3.  This fact, coupled with the high
 present worth of Scenario 4, dictated its removal from
 further consideration.  (See the response to comments re-
 garding additional considerations for pretreatment of the
 brewery waste in Chapter IV, Section 4.1.)
                          111-27

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          It is difficult to believe that secondary impacts
will occur as a result of the rather minor inoffensive con-
struction proposed for treatment facilities which did not
occur as a result of the original brewery construction.

          The suggestion as to the need for site selection
by the EIS would appear to be an attempt to open yet another
avenue of criticism of the document.  It was beyond the
scope of services to go to this detail.  The purpose of the
analysis was to illustrate the cost savings that could be
derived if the brewery practiced various levels of pre-
treatment.

          On an overall basis, the primary and secondary
impacts of a 3 mgd wastewater treatment plant at the brewery
can only be effectively addressed in consideration of the
primary and secondary impacts presently and historically
associated with the brewery's operation at its present site.
3.1.39    Comment;  The conclusions in subsection 4.1.4
appear to be based on erroneous data shown in Table IV-2.
The table should be corrected.

          Response:  We do not believe the data presented
in Table IV-2 to be erroneous.  For further discussion,
please see comments and responses contained in chapter V,
Section 5.1 of Volume II.
3.1.40    Comment;  The EIS should compare future water
demand and safe yield data presented against earlier state-
ments in 2.2.7(1).

          Response;  The discussions regarding water sup-
ply demands and sources have been revised to reflect infor-
mation supplied by the City of Columbus, Division of Water.
3.1.41    Comment;  It should be noted that the power
plant bond issue was passed.

          Response;  The notation has been incorporated
within the text.
                          111-28

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3.1.42    Comment;  The EIS should acknowledge that the
Nelson Road' plant has been deactivated.

          Response:  Reference to the Nelson Road plant
has been deleted.
3.1.42    Comment;  The EIS should acknowledge that future
calcination is a possibility.

          Response:  The EIS notes that calcination is a
possibility at the Parsons Avenue plant, and goes on to
list the reasons for its present rejection elsewhere by
the City.
3.1.44    Comment:  Disposal of sewage sludge or codisposal
of sludge with incinerator ash in a quarry is not a viable
alternative under OEPA regulations and policy for solid
waste disposal.

          Response:  The possibility of sewage sludge dis-
posal in a quarry was never raised in the EIS.  A dis-
cussion of incinerator ash and water sludge codisposal can
be found in response to comments of the Columbus Division
of Water in Chapter IV, Section 4.2 of Volume II.  Rejec-
tion of a codisposal opportunity, which should mitigate
against the environmental concerns associated with inciner-
ator ash, is somewhat arbitrary unless the OEPA can show
reasons other than the application of regulation which does
not specifically address the waste residues anticipated in
this situation.
3.1.45    Comment:  OEPA is unlikely to approve any ash
disposal concept utilizing the Jackson Pike Landfill.

          Response;  The EIS only mentioned the concept
which was reported in a plan prepared by A.E. Stilson and
Associates.  A modifying statement has been added.
3.1.46    Comment;  The EIS ignores the environmental con-
cerns of putting incinerator ash in a quarry.

          Response;  See response to Comment 3.1.44.
                          111-29

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3.1.47    Comment;  The life of the quarry for water plant
sludge is only 20 years,  not 60 years.

          Response;   Please see response 4.2.4 contained in
Chapter IV7 Section 4.2 of Volume II.


3.1.48    Comment:  Several questions  arise from Table IV-15
regarding backup data or assumptions as follows:

          1.   How many trucks is a fleet?
          2.   What is the size and type of the trucks?
          3.   What is the travel time  involved?
          4.   What union requirements  were considered?
          5.   What wage scale, fringe  benefits were con-
               sidered?
          6.   What secondary roads would they be permitted
               to use?
          7.   Where would the trucks  be kept?
          8.   Where would they be maintained?
          9.   Who would maintain them?
         10.   What energy considerations were made?
         11.   Was an Environmental Assessment done?

          Response;

          1.   Six
          2.   16 cubic yards
          3.   To Brush Creek and Perry County, about 2 hours
          4, 5.  Assumed same as Facilities Plan's values
                 in the land application scheme.
          6.   Not considered
          7.   Southerly
          8.   Southerly or by contract
          9.   City of Columbus or by  contract
         10.   Only fuel
         11.   No
3.1.49    Comments;   The beginning of the first paragraph
on page IV-51 is missing.

          Response;   The original text has been inserted
and reads as follows:

          Table IV-16 summarizes the results of a prelimi-
nary budgetary estimate for three land recovery schemes
which assume application of 60 tons/day of dry Columbus
secondary solids to the Perry County site.  As can be seen,
project costs are reduced with size, but the project costs
                          111-30

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are never attractive from a cost standpoint.  Indeed, the
cost of operation would have to be subsidized by 85 percent
for Columbus to break even (assuming local capital funding
at 25 percent)  under even the least cost alternative, which
takes full credit for elimination of one new incinerator
at Southerly and the elimination of one operating inciner-
ator from both plants.  Thus, from the standpoint of the
City, any land recovery scheme is uneconomical; but, from
the standpoint of society, a sterile, unattractive tract
of land has been recovered for the beneficial use of sub-
sequent generations.  When viewed in this context, the value
of the land and its relationship to the total environment
is truly infinite, and the cost of reclamation is fully
justified.
3.1.50    Comment;   Discussion with the Farm Bureau would
alter statements made in the EIS regarding land application
of sludge.

          Response;   In the process of preparing the EIS,
discussions were held on several occasions with the Farm
Bureau regarding land disposal of sludges.  The point
of the comment may have some validity, however,
the final EIS should indicate the desire on the part of
the farmers to control application, whether or not they
actually spread the  sludge themselves.  It is interesting
though,  that the Farm Bureau did not bring up this point
during their presentation as a part of the Public Hearing
on the Draft EIS.
3.1.51    Comment:   The cities of London and Richwood do
not have approval to take sludge at their landfill sites
as mentioned in the EIS.

          Response:  Although the EIS does not recommend
disposal in either of the sites mentioned, comments as
to their "ability"  to receive sludges are based on inter-
views with operating personnel.
3.1.52    Comment;  Can U.S.  EPA provide funding for a
demonstration program involving the reclamation of barren
strip mines with sludges?
                          111-31

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          Response:   One possible funding source was indi-
cated in the statement.  Additional sources should be
explored with U.S. EPA under section 105 of PL 95-217 and
with the Department of the Interior under the various mining
reclamation programs.
3.1.53    Comment;  The inclusion of manufactured component
trade names is a serious problem for OEPA.

          Response:  According to U.S. EPA guidelines, trade
names can be mentioned when there are no current competitive
components available in the market.  If an equivalent
component can be found in the future, it can be purchased
as a substitute.
3.1.54    Comment;  A more in-depth analysis should be per-
formed on the sock diffusion system at both Columbus plants,

          Response:  The point of the EIS is merely the
untenability of continuing to supply air needs in the pre-
sent manner.  To avert criticism of specific design param-
eters  (such as transfer efficiencies) and to facilitate
proper cost, estimates, a particular dissolution system was
chosen.  The need for full-scale testing of this system
is repeatedly noted, and it is the intent of the EIS to
merely assure that any system ultimately installed in the
Columbus facilities is at least as cost-effective as the
system discussed.  The EIS is not suggesting a quick solu-
tion but rather a re-examination of alternatives before an
irretrievable expenditure of money is committed.
3.1.55    Comment;  Utilization of the interconnective
sewer for Storing excess flow and to dampen peak flows to
Southerly is conceptually feasible but introduces a number
of maintenance problems.

          Response:  Unless specific maintenance problems
are identified for consideration, the concept remains valid,
                          111-32

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3.1.56    Comment:  The EIS discusses the brewery's dis-
charge to- be staged to conform to the reverse image of
the normal domestic pattern of wastewater generation.
This being the case, then 6 p.m. to 6 a.m. is not correct.
Travel time from the brewery is 22 to 24 hours.

          Response;  The statement referenced is one of
concept, and does not intend to specify the exact period
of time that two-thirds of the brewery load should be re-
leased.  The actual travel time must be identified before
any decisions can be made regarding the proper time of
peak brewery load release.  Our point here was only that
with its small daily volume of high BOD,-, brewery waste
presents an excellent opportunity to smooth out the daily
total oxygen demanding load processed at the treatment
plant.  Conceptually, assuming the cooperation of the
concerned parties, this would entail receipt of the brew-
ery load in a reverse image of the other noncontrollable
municipal sources.  The use of the 6 p.m. to 6 a.m. time
period was only for illustrative purposes, as it represents
the commonly accepted norm for a plant's receipt of a low
influent pollutant mass.  Obviously, this time frame varies
as the size of the plant's collection system and, since
we are talking about smoothing out the air supply peaks,
the detention time in the unit processes prior to the
aeration system.  Whether or not the aeration system oper-
ates in a plug flow, step feed, or complete mix mode is
also of importance.  The importance of the concept also
varies as a function of the pretreatment level provided
at the brewery and the type of unit processes provided at
Southerly.
3.1.57    Comment:  The EIS design loads to Jackson Pike
and Southerly do not include recycle flows.  There is also
no mention of what happens to filter backwash.

          Response:   The design in the EIS does include
recycle flows and provisions for filter backwash.  These
considerations are clearly presented on Pages IV-78, K-12,
and K-13 of the EIS.
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3.1.58    Comment:  The EIS states that "immediate standby
facilities for sludge disposal can be provided by land-
filling"—the EIS fails to take into account the City's
inability to develop and/or utilize an acceptable landfill
site.

          Response:  The proposed project plan was for
either four incinerators at each facility or three incin-
erators at Jackson Pike with as required force main con-
veyance of sludge to the four incinerators at Southerly.
For more discussion on the landfill issue, see responses
to comments made by the City of Columbus contained in
Chapter IV, Section 4.1 of this volume.
3.1.59    Comment;  The EIS fails to consider the internal
constraints at Jackson Pike or Southerly as well as the
original peaking factors of the facilities in regard to
the suggested realization of total hydraulic capacity.

          Response;  The point of this comment or the
specific response required are not clear.  What are the
internal constraints mentioned, and what specific complaints
does the reviewer have with the EIS hydraulic capacities?
The original peaking factors found with the Facilities
Plan were considered less than standard convention (see
Appendix I, Volume III of the EIS).
3.1.60    Comment;  Mention of the use of sludge to reclaim
strip mine land is not supported with adequate funding
proposals.

          Response;  Please see the response to Comment
3.1.52.  City funding should also be explored as there is
generally considerable flexibility in local budgeting pro-
grams .
3.1.61    Comment:  The EIS recommends building a bypass
around the trickling filter so that savings can result
when complete nitrification is not a treatment requirement.
Apparently the EIS author did not review this proposal
with permit section staff.  USEPA, Permit Section, has
required that OEPA insist on year round nitrification at
Columbus.  If Appendix B of this EIS is to be followed,
then again the bypass is a waste of money.
                          111-34

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          Response;  The permit limitations of both plants
are known.  However, it was felt proper to offer alternatives
to those levels when they appeared justified.  The by-pass
option was preserved in case this option has future viability.
In addition, the present permits are substantially before
the end of the useful life of the proposed improvements, and
that future permits may allow the use of the proposed first-
stage bypass.  A design that anticipates the above consider-
ations, would allow the potential savings of significant
operating power expenditures for aeration and pumping.  At
the same time, the design would have to still maintain the
limiting condition of the secondary treatment equivalency
or the water quality standards of the receiving stream as
influenced by the discharges from the wastewater treatment
plants.
3.1.62    Comment:  The EIS assumes the City will install
the effluent filtration system of one particular manufacturer,

          Response;  For the cost effective analysis, the
EIS did assume a particular manufacturer.  This is not
intended to dictate the final choice of the City, but in-
tended to ensure that consideration was given to this
apparent cost-effective system.  For more discussion, see
responses to comments made by the City of Columbus contained
in Chapter IV, Section 4.1 of this volume.
3.1.63    Comment;   The EIS "glosses over" the operation
and maintenance staff problems at the two plants.  This
is a very serious and time-consuming problem which appears
to be getting worse not better.  The realities of the
employee situation should be considered at this point.
                           111-35

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          Response;  Staff problems were apparent at the time
of EIS preparation.  We were told, however, that the diffi-
culties are due to both union and civil service procedures
and regulations, with, at one plant, the suggestion of
intentional sabotage and the desire to avoid assignment in
the thermal conditioning area.  These observations have
led to social questions concerning management difficulties
associated with a labor force which, because of a few, can
collectively respond in an inefficient, unproductive manner.

          It is noted that the EIS has already been accused
of venturing into areas of city policy (even where Federal
funding is concerned), and it would seem that a discussion
of these internal problems would have invited yet another
flood of comments as to the "appropriateness" of this docu-
ment.  In fact, the one suggestion that was made in the
EIS regarding plant staffing  (Page V-26)  was met with a
negative comment by the City of Columbus.
3.1.64    Comment:  The EIS should address what happens
next, should pretreatment of brewery waste not solve the
bulking or operational problems at Southerly.

          Response;  According to the cost analysis pre-
sented in Table IV-2 and its attendant rationale (assuming
that the brewery has been responsible in the operation of
its pretreatment facilities and that the City employees
have performed their operational functions in a responsible
manner), the next logical step is to require a higher
level of pretreatment on the part of the brewery, e.g.,
Scenario 3.
3.1.65    Comment;  If anything other than normal design
standards are used, OEPA feels a need for pilot testing
the treatment process.

          Response;  Several questions regarding pilot
programs are responded to in Chapter IV, Section 4.1
(comments by the City of Columbus).
                          111-36

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3.1.66    Comment:  The EIS repeatedly asks the City to
consider equipment available from only one manufacturer.

          Response;   See previous responses regarding manu-
facturer "specification."  Further, it should be noted that
the OEPA comment is incorrect concerning single source pro-
curement of this system, as the Aerocleve Submerged Aeration
System of the Clevepak Corporation appears to offer direct
competition.

3.1.67    Comment;  The EIS draws false conclusions with
regard to the area's economy being held in check by inade-
quate water supplies as an independent control factor.

          Response:   Growth can occur in areas not served
by sewer through the use of on-site disposal systems.  How-
ever, growth cannot occur in areas where reliable water
supply or service is not available.  Water supply deficien-
cies thus provide potentially greater constraints to the
expansion of the economic base than wastewater treatment
problems.
3.1.68    Comment:  Table VII-1 does not represent proper
design flow used in Ohio or the current cost for treatment.
The EIS should acknowledge that the South Carolina infor-
mation is not relevant to Ohio.

          Response;  Repeated attempts to obtain definitive
capital and O&M cost data for package plants in the Colum-
bus metropolitan area were unsuccessful during the prepara-
tion of the EIS.  Therefore, the decision was made to
modify the South Carolina data as indicative of the "order
of magnitude" difference in costs associated with package
plants.  The references and application of the data pre-
sented have been clarified so as not to be misleading.
3.1.69    Comment:  It is the opinion of the OEPA that
sufficient development pressures exist in the Blacklick
Creek and adjoining Fairfield County areas to require
service either in the form of connection to Columbus or
package treatment facilities.

          Response:  Fairfield County is outside of the
planning area and was not considered in the analysis of
growth patterns and market demand.  The Blacklick Creek
area has been reevaluated using new growth projections.
See the responses to the City of Reynoldsburg.
                          111-37

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3.1.70    Comment;  The conclusion that existing vacant
commercial and industrial space is more than sufficient to
satisfy demand is questionable.  Commercial space figures
for 1977 and 1978 would be more appropriate in establishing
trend concepts.

          Response;  Most of the research regarding market
trends in the commercial office and industrial sectors was
done in early 1977.  Thus, 1977 and 1978 space figures were
not available at the time.
3.1.71    Comment:  A review of OEPA's files and those of
MORPC will show that an ever greater demand exists where
services are not located.

          Response:  The demand for public services can be
characterized broadly as to areas where no services exist
and areas where the services provided are insufficient to
meet demand.  The point made in the EIS is that it may be
cost-effective to upgrade and support existing investments
in public services as opposed to establishing new service prog-
rams and facilities in areas where they have not been pro-
vided heretofore.  The determination of which type of
demand is "greater" requires a value judgement.
3.1.72    Comment:  The EIS neglects the effect of Plain
Township being incorporated into New Albany.


          Response;  The main concern of the EIS was to
abate existing and potential water pollution problems by
the construction of some means for sewage treatment for
transportation to an existing treatment plant, not the
individual collection system of New Albany.  In any case,
this effect may not be of great significance, as indicated
in the following quote from the second annual growth state-
ment for the City of Columbus prepared by the City of
Columbus, Department of Development,  October, 1978 and
included in this Volume as Appendix EE.
"The most interesting and significant development rela-
tive to annexations occurred in the northeastern portion
of the city and county, an area previously defined as an
active growth area.  The annexation activity in the north-
east, which included two relatively large annexations in
the vicinity of 500 acres each,  does not reflect a sudden
development potential in Columbus; rather they are reactions
to an attempt to contain urban expansion in this area.
                           111-38

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Residents of Plain Township initiated a referendum, which
appeared on the June ballot, that would permit the City of
New Albany to pursue the annexation of the remaining unin-
corporated area within Plain Township.  The referendum was
narrowly defeated.  This effort and its near success in-
dicate a desire by many residents in the vicinity of
New Albany not to take on an urban character.  Therefore,
the probability of the entire sewer contract area of New
Albany experiencing urban development through the year 2000,
as previously thought, is somewhat remote.  Figure 6, de-
fining active growth areas, has been revised to reflect
that annexation potential through 1985, and development
potential through the year 2000 will be limited to west of
New Albany Road."

3.1.73    Comment;  The EIS should indicate that the City
of Reynoldsburg plant is continuously by-passing and has an
adverse effect on the Blacklick Creek.  Chapter III does not
offer the City of Reynoldsburg the immediate solution pro-
posed in the Facilities Plan.

          Response:  The condition of the Reynoldsburg plant
is referenced in subsection 7.4.3(2).  The recommended
solutions contained in Chapter III do address the existing
pollution problems.  The "immediacy" of those solutions
is not significantly different than that proposed in the
Facilities Plan.
3.1.74    Comment;  The conclusions regarding the secondary
impacts on the Blacklick, Rocky Fork, and Big Walnut Creek
subareas are unacceptable.

          Response;  Without further specificity, no re-
sponse can be formulated.
3.1.75    Comment;   The discussion of mitigative measures
for adverse primary impacts should address sewer construc-
tion as well as treatment plant construction.  Included in
this discussion should be the identification of the follow-
ing issues raised by Ohio D.O.T.:

          1.   There should be a discussion of traffic
               diversion during construction of the various
               interceptors.
                          111-39

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2.   On implementation of whichever wastewater
     treatment plan selected, further coordination
     should be conducted with ODOT's District
     6 office regarding the following:

     West Scioto

          Alternate No. 1
               a.   FRA-(project)  Hayden Run Road
               b.   FRA-(project)  33-6.14

          Alternate No. 2
               a.   FRA-(project)  Hayden Run Road
               b.   FRA-(project)  Fishinger Road
                    (County Rd.  52)
               c.   FRA-(project)  33-6.14

     Big Run

          Alternate No. 1
               a.   FRA-(project)  Broad Street
                    Bikeway

     Big Walnut Creek, et.  al.

          Alternate A-
               a.   FRA-(project)  County Road 20
               b.   FRA-(project)  161-16.83
               c.   FRA-(project)  Township Road 195

          Alternate B-
               a.   FRA-(project)  161-16.83
               b.   FRA-(project)  Township 195

          Alternate C-
               a.   FRA-(project)  County Road 20
               b.   FRA-(project)  161-16.83
               c.   FRA-(project)  Township 195

          Alternate D-
               a.   FRA-(project)  161-16.83
               b.   FRA-(project)  161-16.37

          Alternate Sub B-
               a.   FRA-(project)  TR195
               b.   FRA-(project)  161-16.37
               111-40

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          Response;  Discussion regarding mitigative
measures to be taken during sewer construction has been
incorporated into subsection 8.1.1.  The need for coordi-
nation with ODOT has also been noted.
3.1.76    Comment;  The Southerly Plant receives flow via
the interconnector.  The flows originate from Grove City
and Urbancrest and amounts to some 2.75 to 3.0 mdg.

          Response:  The information has been included in
Section A.1.3 of Appendix A.
3.1.77    Comment;  The EIS states that "all thermally con-
ditioned and filtered sludge is landfilled."  This is not
true.  Ohio EPA is not aware of, nor have they approved,
the  landfilling of thermally conditioned and filtered sludge.

          Response:  In an unfortunate attempt to
understate the case,  the EIS referred to the City's
practice of dumping the sludges referenced in a field ad-
jacent to the Jackson Pike plant as "landfilling."  Whether
or not OEPA is aware of or has approved this practice,
is beside the point;  the EIS is merely reporting the prac-
tice at the time of interviews with the Jackson Pike per-
sonnel.  This issue has been more clearly delineated in the
EIS.

3.1.78    Comment:   The EIS implies that the Jackson Pike
incinerators have scrubbers.  This is not true.   Scrubbers
are currently under construction.

          Response;  The term "scrubber water" was incorrectly
used and has been deleted.
3.1.79    Comment;   The EIS states that no further expansion
of the solids handling and incineration system was thought
to be necessary.  This could not be further from the truth.
Since at least 1974, the City has been attempting to expand
the solids handling and incineration facilities.  They have
been repeatedly held up by U.S. EPA.

          Response;  The statement referenced is not critical
to any of the analysis contained in the EIS and has been
deleted.  It was not the intent of the EIS to misrepresent
any condition.
                         111-41

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3.1.80    Comment;  The EIS should indicate that the de-
watering complex is "maintenance intensive."  It is rare
that more than two units are ever working and are almost
beyond repair.

          Response:  While the first statement is true, we
would like to point out that all solids handling equipment
is maintenance intensive.  During the plant tour we did not
note nor was it brought to our attention that this system
was "almost beyond repair," and that the Unit Operations
Report (Malcolm Pirnie, 1975) also fails to note that the
vacuum filters are "almost beyond repair."  It is possible
that it is rare to see more than two vacuum filters in
operation due to the fact that it is also rare to have
both incinerators available for operation at one time, and
that there is little reason to operate more than two vacuum
filters when limited incineration capacity is available.

3.1.81    Comment:  The EIS should explain that the in-
cinerators break down due to the inability of the City to
perform maintenance.   The City cannot afford to take one
off line without causing solids problems in-plant.  Various
measures were tried to suppress odor problems.

          Response:  The need for increased incinerator
capacity is recognized as evidenced by earlier responses.

          The EIS reflects an understanding of the nature
of the sludge solids placed in the lagoon based upon
interviews with the plant staff.  Superficially, although
the sludge may have been odorous, we cannot see any reason
why the plant staff would intentionally route raw primary
sludge to a lagoon if other sludge sources were available.
3.1.82    Comment:  The cost figures do not reflect proper
operation and maintenance for the reasons stated earlier
(III-9).

          Response:  The costs stated in the EIS are taken
directly from the "Annual Summary of Operations for Sewage
Treatment" for Jackson Pike and Southerly which are in-
cluded in the 1976 Annual Report of the Division of Sewerage
and Drainage of the City of Columbus.
3.1.83    Comment:  The report incorrectly assumes the flows
as measured by the Columbus gage on the Scioto River is in-
dicative of flows upstream from the Jackson Pike Wastewater
Treatment facility.  While it is true the gage is located
                          111-42

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approximately  300  to 500 feet upstream of the discharge
point of the Jackson Pike facilities, it is incorrect to
assume  the gage  does not include the discharged flow.  In
fact under the remarks  accompanying the U.S.G.S. gaged
records you will find the following comments:   (Page 290:
Water Resource Data for Ohio - Water Year 1976 Vol. 1 Ohio
River Basin) - "Records include the return flow of the
Frank Road Sewage  Treatment Plant."  Thus the computed
Q7 - 10 flow of  127 cfs is made up of the sewage flow plus
the river flow upstream of the plant.  If one estimated
the minimum weekly sewage flow to be 65 mdg or 100 cfs,
the upstream flow  would be approximately 22 cfs or close
to the  value of  18.2 used in the agency's 303 wasteload
allocation report.

          Further evidence  of this fact may be seen from
the following  U.S.G.S.  records.
         YEARS IN WHICH THE MINIMUM  WEEKLY FLOW AT
    COLUMBUS APPROACH 122 cfs AND  RELATED FLOWS IN THE
                      OLENTANGY  RIVER
Year


1970
1968
1967
1962
1959
1956
        Scioto River @ Columbus
  CFS
         Mean
126
125
133
129
131
124

127.5
                Olentangy River
                 @ Worthington
13
12
14
13
12
30
13
Mean
            Difference
113
113
119
116
119
 94

114.5 cfs
          From the above it will be  noted that the differ-
ences in flow between the two  gauging  stations has a mean
of 114.5 cfs and is indicative of  the  minimum weekly sewage
flow from the Jackson Pike plant.  In  addition, the up-
stream flow of the Scioto River is only slightly greater
than the mean of 13 cfs measured at  the Worthington gauge
on the Olentangy River.

          During the drought period  of 1953-55, the differ-
ence in monthly mean flows between the Circleville and
Columbus gauges varied from 40 to  71 cfs with a mean of
                          111-43

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53 cfs.  Even if there was no runoff from the incremental
drainage area of nearly 1600 square miles (which is highly
unlikely) the difference in flow hardly accounts for the
discharge from the Jackson Pike plant.

          Response:   The comments in this submittal and
those made orally at the public hearing imply that the
authors of the EIS were unaware of the remark as to sewage
return flow in the Scioto River at Columbus station de-
scription.  Nothing could be further from the truth.  The
gage was visited by personnel and repeated inquiries were
made to the USGS in regard to the proper 7-10 flow value.
We were assured that the return flow noted for the station
was merely the overflow from the Jackson Pike ash lagoons,
which enters the Scioto River almost exactly at the gage
site.  This situation was also discussed with several OEPA
stream modelers.  The originally submitted Appendix B in-
cluded runs made at the upstream flow of 18.2 cfs preferred
by OEPA.  The shapes of the resultant DO profiles were
identical to those obtained using the 122 cfs upstream flow,
with lower actual DO levels evidenced throughout.  Upon
review, we were requested to drop the runs related to up-
stream flow sensitivity and to replace them with the
temperature-sensitive runs which now appear in the EIS.


          Following the public hearing, USGS was again con-
tacted in regards to this flow problem.  An oral assurance
was again provided that the gage was not impacted by Jackson
Pike, and a summary letter was sent to confirm this.  The
return from USGS indicated that communications had been con-
fused, and stated that the gage control point was indeed
below the Jackson Pike release.  Appendix B has, therefore,
been changed and inserted as a new Appendix in this Volume
to include the modeling runs at an upstream flow of 18.2 cfs.

3.1.84    Comment:  Comments similar to the above may be
made concerning winter flows of 222 cfs used for modeling
winter low stream flow conditions.

          This matter was the subject of an intensive study
in 1961 by George Newell  (now with City of Columbus) and
Mr. George Garrett of Ohio EPA in cooperation with the
U.S.G.S.  It should be recognized that the assumed summer
and winter low flows contain a serious error and thus weaken
the presentation of the model's results.

          Repsonse:  The background flow assumptions used in
the draft EIS are significantly different than those preferred
by OEPA.  However, it is worthy to note that comparable model-
ing predictions remained reasonably close at both flow re-
gimes, showing the relative overall insensitivity of the re-
sults to the background flow assumption.
                          111-44

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          Mr. Garrett supplied us with the State data which
is reproduced in the EIS.  It is unfortunate that the refer-
enced study was not mentioned or made available to us at
that time.
3.1.85    Comment;  The model runs illustrated in Figure B-3
and B-4 and presented in Tables B-2 and B-3 assume the river
is a free flowing stream immediately downstream of the Jack-
son Pike facility.  Although this is a common assumption it
is inappropriate for this stretch of the river particularly
with the completion of the channelization program in the early
1960s.  Immediately downstream of Jackson Pike facilities,
the river narrows sharply and makes a sharp turn to the east
on the first leg of an oxbow bend in the river.  As a result
of these extreme directional changes and other physical
characteristics of the river, stream flows through the ox-
bow bend are restricted and the discharge from the Jackson
Pike facilities is forced across the stream where it in
turn flows upstream along the eastern bank to the vicinity
of Frank Road.  This pool-like condition significantly
alters the time of travel calculations and thus the loca-
tion of the oxygen sag point.  This in turn modifies the
impact of the Jackson Pike discharge on discharges from the
Southerly Plant downward.

          Response;  The OEPA did not inform us of this
situation.  In reviewing their 303e work on the Scioto we
noted that they considered the stream to be free flowing
and that their river miles seemed to be incorrect, we
assumed that this was in error and used values which we
thought may more correctly define stream stations.  With
this review comment, it may have been that they were attempt-
ing to compensate for the sinuous pattern of the river at
their low flows.  Regardless, the predicted sag points, dis-
solved oxygen profiles, and load carryover to Southerly
by OEPA and the EIS appear to be essentially in agreement.
The only output disagreement with the OEPA would appear to
be in the predicted absolute dissolved oxygen values in
the modeled stretch of Scioto; a point which would have
been critical only if the EIS and OEPA modeling efforts
would have disagreed as to standards convention.

          It should be noted that other "experts" have
offered testimony as to the EIS predicting a sag point far
too soon after the Jackson Pike release, while the OEPA
comment implies that the sag should exert itself even
sooner with perhaps more load assimilated than shown in
the EIS.
                          111-45

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3.1.86    Comment:   The allocated loads presented in Table B-4
for the Jackson Pike facilities and in Table B-5 for the
Southerly facilities represent treatment levels greater than
that currently considered as "best available technology
currently available."  Furthermore, there is a serious ques-
tion as to the reaction rates for effluents of this high a
quality.  In view of the foregoing, it appears that a policy
decision must be made as to the maximum treatment that may
be required of municipalities whose discharge make up a major
share of the downstream flow for a significant portion of
the summer low flow period.  It should be noted that, as
indicated at the top of page 20, the loads modeled for waste-
load allocation purposes represent concentrations that closely
approach background levels.  In view of the significant
impact of combined sewer overflows on the river as indicated
in Appendix H there should be a point where the benefits from
the control and treatment of such overflows provide a greater
benefit than additional treatment of dry weather flows.

          Response:  We agree fully with this comment and
have attempted in several places of the EIS to indicate
that treatment further than BATEA should not be required
at the present time.  (See Pages IV-18 through IV-20, V-2,
and V-5 of the EIS.)
3.1.87    Comment:  The finding that essentially only secon-
dary treatment is necessary during wintertime stream flows
to maintain water quality standards is consistent with model
runs conducted by this Agency with the exception of extremely
warm weather conditions during November such as that experi-
enced during the first half of November 1975.

          Response:  If the OEPA agrees with this result
an option would be to establish seasonal, flow-dependent
NPDES effluent restrictions and allow the municipality to
save in its operational power consumption.  This would have
to be agreed to by OEPA and U.S. EPA.

3.1.88    Comment;  The Water Quality Standards reported on
these pages are those adopted by this agency in 1974, not
the current Water Quality Standards adopted in February
1978.

          Response:  The February 1978 standards had not
been adopted at the time of preparation of the EIS.  The
new standards have been footnoted.
                          111-46

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3.1.89    Comment:  Not all the regulators are listed in
Appendix H.  Also, there is no mention that all the sluice
gates are set half closed and what effect this might have
on the system.  There is also no discussion of the other
80 to 90 overflows.

          Response:  The regulators listed in Table H-l
were provided by Malcolm Pirnie, Inc., in response to our
request for such a listing in the combined sewer areas of
Columbus.  The remaining 80 to 90 overflows were not con-
sidered to be in the scope of work set forth by USEPA.
Refer to the Report on Combined Sewer Overflow Monitoring
by Malcolm Pirnie, Inc. (Feb. 1979) for additional informa-
tion on overflow regulation.
3.1.90    Comment:  The EIS states that the interconnector
construction would permit tie-in of the Big Run and Frank
Road Jackson Pike Service Area interceptors.  This is not
true.  The only tie-in will be the Big Run Interceptor
which recently had an estimated flow of 75 MGD.

          Response;  Refer to Page III-2 of the EIS, which
specifically states that City Auditor's Engineer Contract
Reference Number 2032 does call for the connection of both
the Big Run and Frank Road Interceptors with the inter-
connecting sewer.  This statement was confirmed in a
telephone call to the City of Columbus' Department of Sewer-
age and Drainage on May 1, 1978.
3.1.91    Comment;  The EIS establishes overflow rates which
are not consistent with Ten State Standards, Ohio EPA de-
sign criteria or good sanitary engineering design.  They
appear to be for the sole purpose of establishing dollar
savings, not obtaining good treatment efficiencies.

          Response;  A surface overflow rate of 500 gpd/sf
provides no assurance of success if operating MLSS and
return sludge needs are ignored, and deviation from this
parameter in no way violates good (or intelligent) sanitary
engineering design principles.  Arbitrary use of the 10
State Standards or OEPA design criteria appears to us to
be cookbook design with a lack of fundamental understanding
of how these parameters were developed, their applicability,
and their limitations.  See responses to comments made by
                           111-47

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the City of Columbus in Chapter IV, Section 4.1, Volume II
for more discussion.
3.1.92    Comment:  The EIS establishes design parameters
which are not satisfactory for the reasons just cited.  At
the very least, full scale pilot testing would be necessary
at both plants to establish credibility.  Then some safety
factor needs to be applied for day to day operation.
          Response:  Two independent reviews of the draft
EIS have substantiated the design parameters proposed in
the document.
3.1.93    Comment;  The OEPA is not familiar with the publi-
cations used to develop Appendix L.  It appears to be too
general and lacking considerable information applicable to
the land application of sewage sludge.   We would recommend
the authors of the EIS review "Ohio Guide for Land Applica-
tion of Sewage Sludge, Bulletin 598."  This bulletin was
issued in furtherance of Cooperative Extension work, acts
of May 8 and June 30, 1914 in cooperation with the U.S.
Department of Agriculture, Roy M. Kottman, Director of the
Cooperative Extension Service, the Ohio State University.

          Response:  Appendix L was used in part to support
analysis performed on land disposal of sludge alternatives.
Other source materials were relied on as well.
3.1.94    Comment;   Reference is made to Table 3.5 when it
should be made to Table 3.3.

          Response:   The correction has been noted.
                          111-48

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3.2  Ohio Historic Preservation Office

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           3.2
                                                   March 30, 1978
                                                               DECEIVED
                                                                  ApR 0 3 1978
                                                                                REGION 5
                                                                            OFFICE OF REGIONAL
                                                                             ADMINISTRATOR
U. S. Environmental  Protection Agency
Region V
230 South Dearborn Street
Chicago, Illinois  60604
Attn: Planning Branch  - EIS Preparation Section

Re:  Draft Environmental  Impact Statement
     Wastewater Treatment Facilities for the
     Metropolitan Area  Columbus, Ohio

Dear Mr. Adamkus:

As requested,  the staff of the Ohio Historic Preservation Office has re-
viewed the subject statement and offers the following  comments relating to
cultural resources.

In Section 2.2.10 mention is made of the 20 National Register sites and the
78 archaeological sites recorded for the study area.   However there is no
indication that this knowledge was used as a planning  tool  in project site
location.  No  breakdown is given of which resources are  located in which
service areas.           (3.2.1)

The D.E.I.S's  assessment of the facilities effect on historical and archaeo-
logical sites  (Section 7.3.4) is inadequate to meet the  requirements of
Section 106 of the National Historic Preservation Act, Sections 1(3) and of
2(b) Executive Order 11593, and Section 102 of the National  Environmental
Policy Act. There is  no documentation provided to support  the statement
that "there is not likely to be any significant secondary impacts on historical
or archaeological sites.'*  The question of effects on  cultural resources due
to facilities  construction is not addressed in the statement  (Section 6.2.1)
                           (3.2.2)
Plans to conduct cultural resources surveys should be  included in the E.I.S
or documentary evidence indicating that cultural resources  will not be affected.
A determination of effect on properties listed on, nominated  to, or eligible
for the National Register of Historic Places that are  located within the pro-
posed project  areas  will be necessary.  This may be coordinated with the O.H.P.O.
                           (3.2.3)
Thank you for  the opportunity to review and comment on the  subject statement.

                                        Sincerely,
 original:   Water
           THS:FR:cw
                                        Thomas H.  smith
                                        State Historic  Preservation Officer
                                        Director,  Ohio  Historical Society
Ohio Historical Center  1-71 & 17th Avenue  Columbus, Ohio 43211  (614) 466-8727

                                           111-49

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3.2       Ohio Historic Preservation Office
3.2.1     Comment:  The EIS does not indicate specific site
locations of the 20 National Register sites and 78 archaeolo-
gical sites recorded in the study area with respect to con-
struction effects from the planned sewer routes and facili-
ties.

          Response:  The historic inventory for Franklin
County has only recently been completed with over 2,600
listings.  Determinations on which of the buildings are
eligible for designation in the National Register of His-
toric Places have not yet been made.  Discussion with the
Preservation Officer for the Columbus Landmarks Foundation
suggests that a field inspection and inventory would be
appropriate during Step 2 of the 201 planning process.
3.2.2     Comment;  The question of effects on cultural re-
sources due to facilities construction is not addressed in
the statement (Section 6.2.1).

          Response;  The primary effects upon cultural re-
sources from the construction of interceptors and other
treatment facilities are generally those categorized as
public annoyances such as noise, night glare, vibration,
and traffic congestion.  (See discussion in 6.1.1).  These
effects are short-term in their duration whether experienced
during the initial construction phase or later on during
periods of repair and maintenance procedures.  The deter-
mination of potentially serious or damaging effects to parti-
cular buildings or places cannot be resolved and mitigation
measures adopted until Step 2 when final construction plan-
ning and management operations ensue.
3.2.3     Comment:  There is no documentation provided to
support the statement that "there is not likely to be any
significant secondary impacts on historical or archaelogi-
cal sites."

          Response;   Secondary effects are those impacts
created by virtue of population growth induced by the
proposed action over and above the growth projected under
the no action alternative.  The EIS indicates that the
regional population projections will remain ultimately the
same and differ only according to distribution patterns in
particular subareas.  Consequently there are no significant
                          111-50

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secondary effects that can be determined at this time on
cultural resources.   Please see 7.3.4 of Volume III for
revised language.
                          111-51

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IV.   COMMENTS FROM REGIONAL AND LOCAL
           PUBLIC AGENCIES

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4.1  City of Columbus

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REVIEW OF
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION V • DRAFT
ENVIRONMENTAL IMPACT STATEMENT
Wastewater  Treatment  Facilities
for the  Metropolitan Area
Columbus, Ohio
                  by Columbus, Ohio
                  TOM MOODY • Mayor
                  DEPARTMENT OF PUBLIC SERVICE
                 ROBERT C. PARKINSON • Director
                 IVISION OF SEWERAGE & DRAINAGE
               DAYTON D. ROBBINS • Superintendent
             EORGE B. WALKENSHAW • Ass't. Superintendent.
                        IV-1

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                                                                        -2-
                                   REVIEW SUMMARY
                                       ON THE
                      USEPA DRAFT ENVIRONMENTAL IMPACT STATEMENT
                                       FOR THE
                             COLUMBUS METROPOLITAN AREA
     The Federal Water Pollution Control Act Amendments of 1972, commonly referred

to as Public Law 92-500, contained provisions intended to achieve the national

objective to restore and maintain the chemical,  physical, and biological  integrity

of the Nation's waters.  In order to achieve this objective,  PL 92-500 declared

two major national goals:

                    (1)  That the discharge of pollutants into the
                         navigable waters be eliminated by 1985; and


                    (2)  that wherever attainable, an interim goal of
                         water quality which provides for the protection
                         and propagation of fish, shellfish,  and wildlife
                         and provides for recreation in and on the water
                         be achieved by July 1,  1983.

     PL 92-500 also contained several important  national  policy statements,  two of

which were as follows:

                    (1)  Public participation in the development, revision,
                         and enforcement of any  regulation, standard,
                         effluent limitation, plan,  or program established
                         by the Administrator or any State under this Act
                         shall be provided for,  encouraged, and assisted
                         by the Administrator and the States.  The
                         Administrator,  in cooperation with the States,
                         shall develop and publish regulations specifying
                         minimum guidelines for  public participation in
                         such processes.

                    (2)  That to the maximum extent  possible, the procedures
                         utilized for implementing this Act shall encourage
                         the drastic minimization of paperwork and interagency
                         decision procedures, and the best use of available
                         manpower and funds, so  as to prevent needless
                         duplicat ion and unnecessary delays at all levels of
                         government.  Please note the law's concern and
                         commitment regarding minimization of paperwork,
                         prevention of needless  duplication,  and avoidance of
                         unnecessary delays.  (Emphasis Added)

     As the first step in obtaining Federal assistance for construction of  sewers and

wastewater treatment facilities, an applicant for such funds  is required, by law, to
                                     IV-2

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                                                                         -3-
prepare what is known as a Facility Plan.  Facility planning, as provided under




Federal regulations, is a planning process to be used in establishing a cost effective




and environmentally sound wastewater treatment works.  The law stipulates that one




municipality or other local political entity must be designated as the agency respons-




ible for completion of the Facility Plan.




     As such, the City of Columbus formally initiated the required facility planning




process for the Columbus Metropolitan Area on October 3, 197**, and completed same




on October 15, 1976 at an approximate cost of one million dollars.  The citizens




of Columbus have agreed to this program to solve the water pollution problems in the




Columbus Metropolitan area.  They have demonstrated this commitment by voting a




90 million dollar bond issue to pay the local share of the capital costs of this




program.




     On March 15, 1976, during the last stages of the Facility Plan preparation,




the United States Environmental Protection Agency decided to prepare a separate




document called an Environmental  Impact Statement, or EIS, for the Columbus planning




area.  The stated purpose of the EIS was to address several  issues raised by USEPA




In regard to the environmental impacts of construction projects proposed in the City's




Faci1ity Plan.



     The City of Columbus  immediately appealed the EIS decision on the grounds that




the Facility Plan had already  resolved the environmental issues, and on the grounds




that preparation of the EIS would be a needless duplication of effort and cause




unnecessary lengthy delays resulting in increased costs and uncontested degradation




of the area's water resources.  Such duplication, delays, increased costs, and




degradation of waters are  in direct conflict with the aforementioned national goals




and policies of PL 92-500.  The City was promised by USEPA that the final EIS would




be completed by May, 1977> thereby over-optimistically assuring that the EIS imposed




delays would be somewhat minimal.






                                     IV-3

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                                                                            -4-

     Now, after a two year delay and an inflationary expense to the taxpayers of about

30 million dollars in construction costs,  a draft "so-called EIS" has finally been

issued by USEPA.  Several  comments, recommendations  and conclusions in the "draft"

document indicate that the "final" EIS may not,  in fact,  be "final" for quite some

time, thus resulting in additional costs and inflationary spirals at the taxpayers'

expense.  Actual cost to the taxpayers for preparation of the EIS is likely to exceed

one-half million dollars when including governmental  salaries and expenses and the

local effort that must be expended in reviewing  and  assessing the Federal  proposals

and conclusions contained therein.

     In addition to duplicating many of the City's facility planning efforts, the

Federal EIS has not adequately or correctly addressed or resolved the stated issues

originally used by USEPA to justify its preparation.   Therefore,  the EIS document

is believed to be both environmentally incomplete and unacceptable, and technically

inappropriate and inaccurate.

     Specifically, on the environmental issues,  the EIS would appear to be unresponsive

to several major local concerns and problems as  follows:

     1.  The EIS does not include any specific environmental assessment whatsoever
         of its decision to construct a Sewage Treatment Plant on Anheuser-Busch
         property in close proximity to the highly developed residential and
         commercial districts of Worthington, Westerville, Sharon Woods, and other
         North Columbus areas.  USEPA1s neglect  of such concerns as air quality,
         potential odors, property values, implementabi1ity and legality is in
         direct violation of Federal regulations which require that an EIS present
         a detailed assessment of the environmental  impacts for public evaluation and
         information.  This omission alone is grounds for elimination of this EIS
         proposal and all other EIS decisions related to the Southerly Plant.  The
         City's Facility Plan recommended continued treatment of the brewery waste
         at its existing remote Southerly site.

     2.  The EIS interceptor alternatives are based on a 20 year design period, flowing
         half full.  The EIS has not justified this interceptor planning period or
         design basis with any cost effective analysis, nor does it present any
         environmental assessment addressing the impacts of construction of parallel
         sewers in 20 years which will be necessitated by the smaller sewers proposed.

     3.  The EIS proposes delayed construction of the Big Walnut Interceptor Sewer
         in the developing Hoover Reservoir area.  This decision seriously endangers
         the City's present and future drinking  water supply by increasing the
         probability of contamination by untreated sewage.  This proposal  is in direct
         conflict with the City's efforts to protect this valuable and irretrievable
                                      IV-4

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                                                                          -5-

         natural  resource.  Furthermore, the EIS proposes to locate the future  sewer
         in an environmentally critical  area.   The City's Facility Plan made note
         of said  area and recommended an alternate route as well  as immediate
         construction to protect the public health.

     k.   The EIS  proposes construction of sewage pumping stations and force mains
         in lieu  of gravity sewers for the Blacklick Interceptor, the Rocky Fork Inter-
         ceptor,  and a section of the Scioto West Interceptor.   With the present
         and future threats of electrical power interruptions for extended periods
         of time, the City finds these alternatives  to be less  reliable than the
         gravity  sewers recommended in its Facility  Plan.  Unnecessary pumping  of sewage
         when gravity sewer alternatives are readily available  is contrary to today's
         energy conservation needs, and poses a greater threat  of sewage backups, of
         odor nuisances and hazards to the public heal-th.  In summary, these EIS
         decisions neglect to consider the energy intensiveness and reliability of
         pumping  stations and force mains versus gravity sewers.   Furthermore,  no
         environmental assessment was included in the EIS on the impacts of future
         construction of gravity sewers to replace these force  mains.

         Specifically, and in regard to the Blacklick area, the USEPA force main is
         located  along U.S. Route kO and extends through the middle of commercial
         and residential areas in the City of Reynoldsburg.  The EIS has underestimated
         the impacts of construction through such highly developed areas.

     5.   The EIS  also calls for delayed construction of several other proposed  inter-
         ceptor sewers.  The City views this decision as environmentally unsound,
         as it promotes continued use of private treatment units in areas where both
         the City and OEPA have recognized or identified limitations of the soil to
         continually assimilate such poorly treated  sewage.

     6.   The USEPA EIS has proposed expansions to the City's two existing wastewater
         treatment plants on the Scioto River which  are believed inadequate to
         meet community needs, and could result in significant  adverse environmental
         impacts  in Franklin and adjacent counties.   Review of  the EIS indicates
         that many of its proposed facilities utilize unproven  technology, are  based
         on questionable assumptions, and are designed using parameters which deviate
         from normal engineering standards and practice.  New environmental impact
         or consequences are presented, discussed or analyzed in the EIS regarding
         these speculations.
     From a technical standpoint, a large portion of the EIS is devoted to the

presentation and development of design criteria and unit process sizing.  An intensive

review of this document by the City and three consulting engineering firms concludes

it is not an Environmental Impact Statement.  Since two thirds of the document address

redesign of facilities, it should properly be termed a "Re-design Report" or a

"Value Engineering Report".  The City of Columbus recommends that Region V, U.S.E.P.A.

withdraw these sections of this document that deal with design considerations.  Such

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                                                                           -6-
detailed presentation and development is felt to be beyond the authority of an

Environmental Impact Statement.

     However, since the EIS has  inappropriately included these tasks,  we feel

obligated to point out some major inconsistencies,  inaccuracies,  and areas of  total

disagreement.

     1.  Construction of a new,  separate Sewage Treatment Facilities at the
         Anheuser-Busch Brewery  with discharge to the Southerly Plant
         in lieu of total treatment at the Southerly site was deemed
         cost effective in the EIS based on a highly questionable cost
         analysis.  Real savings of such a treatment scenario are believed
         to be significantly overstated.  The EIS states that construction of  the
         brewery Sewage Treatment Plant will cost 2.9 million dollars.  Anheuser-Busch's
         engineers estimate construction cost at about 2£ times this EIS estimate.
         The EIS also states that about 30% of the solids handling and
         disposal facilities and all of the first stage liquid treatment
         facilities proposed in  the Facility Plan for the Southerly Plant
         can be eliminated by prior treatment at the brewery.  The EIS
         fails to account for the fact that the same amount of solids
         must be handled by the  Southerly Plant in either case, and that
         further treatment of the brewery waste and full treatment of all
         other industrial and domestic wastes must still be accomplished
         at Southerly.

         The net effectiveness of separate brewery treatment is also subject to
         serious question since  the solids generated at the.remote location may be
         physically degraded and/or biologically changed during the long 23
         hour residence time in  the sewer system prior to reaching the Southerly
         Plant.  The EIS should  have conducted detailed studies on net treatment
         effectiveness prior to  making such a proposal or decision.

         Legally, there are no existing Federal or Tocal laws
         requiring the pretreatment of compatible brewery wastes.  Therefore,
         the legality and implementabi1Ity of this EIS proposal are highly
         questionable.  The City feels that neither it or USEPA has any legal
         authority to implement  this EIS mandate.  However, the City has
         already imposed a limitation on the brewery discharges under
         authority of its existing ordinances.  In addition, a two year research
         study, conducted by Ohio State University under contract with the City,
         on bulking problems at  the Southerly Plant has not shown brewery
         waste to be the direct  cause.

     2.  Design criteria used in the Federal EIS for expansion of the City's two
         existing treatment plants are consistently inadequate, based on unproven
         technology, not in conformance with recognized engineering practice,  and,
         in many cases, are contrary to USEPA1s own published criteria and not
         approvable by Ohio EPA.  The City's consulting engineers are not willing
         to use these EIS parameters because of the probable damage to their
         professional reputations.  Utilization of such criteria results in the
         EIS development of misleading and unrealistic cost savings in comparison
         to Facility Plan proposals.  Does USEPA really expect anyone to believe
         that a cost savings can be realized by not providing adequate facilities?
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                                                                       -7-
    Here again, optimization of facilities should be a function of the
    Step 2 design and value engineering processes, not of the Environmental
    Impact Statement.  Deviation from normal engineering practice can only be
    recommended after detailed and extensive pilot testing and in-plant
    analysis.  It is highly improbable that a large treatment plant designed
    on such a basis could regularly meet the strict discharge permit limitations
    imposed on the Columbus plants.  Using these inadequate criteria, exces-
    sive violations of U.S.E.P.A.'s own effluent limits will  occur.  Is the
    goal of U.S.E.P.A. to restore water quality in the Scioto River?  If so, it is
    difficult to relate inadequate facilities with this goal.

3.  The City of Columbus presently has inadequate incineration capacity at both
    treatment plants.  For the past four years, the City has repeatedly
    requested USEPA to fund additional units.  Our present situation is indeed
    desperate.  The two incinerators at Southerly Wastewater Treatment Plant
    are worn out and have been for four years.  To completely rebuild these
    units requires some two years.  Without backup units, the City cannot shut
    down any of its existing facilities for rebuilding.  Under the present
    conditions, incinerators cannot be out of service other than for the
    time necessary to make emergency repairs.  The Jackson Pike Wastewater
    Treatment Plant is currently rebuilding both incinerators, and likewise,
    without backup facilities, must divert sludge to an existing lagoon.

    Region V USEPA assured the City in the summer of 1976 that the incineration
    issue would be resolved first in the EIS.  Now after two years and a draft,
    "so called EIS", the incineration question is still not resolved.

4.  The EIS's negative assumptions on  the growth  rate and the short sightedness
    of the planning area is of major concern to the City of Columbus.  Many
    factors affect growth of a community or a metropolitan area    Some of  these are:

       -  area attractiveness

          strategic location

          geographic location

          natural resources

          human resources

          business and Industry

       -  economy

          local government policies

          state government policies

          federal government policies

       -  "in" migration or "out" migration

          birth and death rates


                                    IV-7

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                                                                     -8-
      transportation system and

      utility services provided such as

           electricity
           telephone
           water
           sewer and
           sol id wastes

All of these factors, and more, decide the population and area growth.
While the importance of each factor listed may be debated by planners and
nonplanners, the order listed above is thought to be indicative of the
priority placed upon the many factors by the majority of people and industry.

The area's attractiveness, strategic and geographic location, natural
resources and human resources must be at, or near the top, of any priority
list.  The exact order, or which should be number one or number five,
would be debatable by many.  Government policy at the various levels affects
growth in that it either encourages or discourages the rate of growth.   As
with the other factors in the mid range of the above list they tend to
affect the rate of growth but are not in the upper third in controlling
factors.  The remaining lower third of the list would be debated by many.
In fact, some of these may be in the middle or upper one-third.

The main point of this discussion is that, while the exact position of
utility service may be debated, utility services, especially water and
sewer, are not major controlling factors.  Frequently, the adequacy of
these facilities affect decision, but they are not controlling.

Frequently in a metropolitan area transportation is of primary importance.
If the transportation is available and the area is attractive (which is
used here to cover many intangibles), then people will obtain water and
sewer facilities by whatever means is necessary.  There is a good reason
for this.  Typically the cost of water and sewer services, by even the most
expensive means, represents only about one percent of a family, business
or industry budget, in all but the most unusual cases.  People are
concerned and want these services at the lowest reasonable costs, but
generally these costs do not represent a significant portion or deciding
factor of the family, business or industry location.  A cost range of
one-half of one percent to perhaps a maximum of five percent of a family
or industry budget would cover all cases.  In some instances, the avail-
ability and adequacy of water or sewer service may be a prime considera-
tion.  However, these instances are thought to be very few.

The cost difference between providing properly planned and adequate sewer
service facilities concurrent with or slightly before development is
minor when comparing these same facilities after growth has occurred and
pollution problems develop.

Historically, sewers and wastewater treatment facilities have followed
planned growth and development, not preceeded it.  The very reason that water
pollution control  legislation was passed is that this condition was allowed
to progress to such a point that gross pollution problems resulted.


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                                                                        -9-
     The responsibility for implementing the water pollution abatement program in




the Columbus Metropolitan Area rests with the City of Columbus.  More specifically,




with the Department of Public Service,  Division of Sewerage and Drainage.  It is




for this reason that the Division has been primarily responsible for preparation




of the Columbus Metropolitan Area Facilities Report and for the in depth review and




comments on the Draft Environmental Impact Statement prepared by the U.S.E.P.A.




    The review by the Division and its consultants has been thorough and are




presented in this attached document.  The comments are lengthy and for the most part




are somewhat technical and therefore not necessarily understood by all of those




who read them.  But water pollution abatement, wastewater treatment, and sewer design




are technical subjects and can only be discussed intelligently in these terms.




     Even though this response by the Division is lengthy, we find it necessary because




it has been one of the few forums in which the City has been afforded the opportunity




to participate in the tragedy of the Columbus Environmental Impact Statement planning




process.




     We speak of it as a tragedy because of the valuable time, money, and effort that




has been expended to produce a document that is technically inaccurate, environmentally




incomplete and that makes recommendations for upgrading the City's wastewater treatment




plants based on unproven technology.  The City has an obligation to the taxpayers of




the Columbus area to use sound judgement and competent engineering in developing an




effective water pollution abatement program.  Utilizing unproven technology to build




a 200 million dollar expansion not only violates ones own sense of responsibility but




it would also violate the trust the people of Columbus place in their local government.




Maybe the U.S. government can afford this kind of blundering, but we cannot.
                                       IV-9

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                                                                        -10-
     The two years it has taken to produce the so-called "Draft EIS",  and we repeat
this is only a draft document (and it is unknown when the final version will be
completed)  has increased the cost of the program by about 30 million dollars.   This
money, of course, will have to be made up by increasing both local  and federal  long
term debt.   The real tragedy of this loss is that the repayment burden will  not rest
with those that caused it, but will fall upon our children and grandchildren.   Cannot
we be more responsible?

     An Environmental Impact Statement is supposed to bring together all of  the
various inputs of information, data, skills and opinions on a particular proposed
action.  And after weighing each input carefully, sifting the evidence, and  with
wisdom and experienced judgement, formulate a recommended plan that will accomplish
the goals and objectives of the program.  How can this be done without direct
interaction with the people that are directly responsible for implementing the program,
the City of Columbus?  The answer is that it can't.  Few times during  the preparation
of the "Draft EIS" was anyone in the Department of Public Service contacted  to
discuss findings or recommendations.  The contents of the statement reflect  this
om i s s i on.
     The water pollution abatement program envisioned by the City as its part  of
the national goal to restore the integrity of the Nation's waters is expected  to
be very expensive in terms of dollars and resources.  The City has no other  choice
but to rely on the 75% funding that is available under the U.S.E.P.A.  Construction
Grant Program.  Since that funding is contingent upon the completion of the  Columbus
EIS, the City has no choice but to do its very best to see to it that the EIS
actually reflects the needs of the Columbus community.
     For these reasons, the Division has taken the time to prepare this lengthy
review.  To addressing every calculation, statement and recommendation  in the  "Draft
EIS."  To make sure that every comment  is factual and represent sound judgement and
not just an assumed or unproven guess.  The "Draft EIS" is wrong!  It is hoped the

comments in this  review will  set  it straight.
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                                                                   -11-
                                 DETAILED REVIEW


REVIEW OF
CHAPTER 1.   INTRODUCTION,  BACKGROUND,  AND ISSUES


    Page 1-2   The EIS states  that  the City  of  Columbus and  the  Board of

               County Commissioners  co-applied  for a  Federal grant to

               expand and  upgrade the  City's treatment facilities.  The City

               of Columbus was the  sole applicant.          (4.1.1)



    Page 1-4   Separate brewery wastewater treatment  was  not an  issue in the

               U.S.E.P.A.  "Notice of Intent" to do the EIS.    (4.1.2)



    Page 1-6   EIS states  it will  use  the same  planning area as  delineated  in the

               Facilities  Plan.  However, the alternatives considered for

               interceptors use a different  planning  area.   (4.1.3)



               The EIS did not use  the same  flow  data available  at the time the

               Facility Plan was prepared.  Planning  of alternatives and drawing

               conclusions is  difficult, at  best, if  different data  is utilized

               in the planning process.   (4.1.4)



    Page 1-8   The EIS states  that  realistic schedules extend the construction of

               facilities  5 to 7 years.  The City agrees  that it may even be

               longer with the delays  that have been  incurred by the EIS process.
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                                                                 -12-
REVIEW OF
CHAPTER II.  ENVIRONMENTAL SETTING
     General  Comments
               Detailed  comparisons  between the EIS and the Facility Plan
               resulted  in  no  notable  differences  in  findings or conclusions.
               Even  in the  case where  data available  after the preparation
               of the Environmental  Assessment was reviewed, i.e., air
               and surface  water  quality  data, conclusions were  identical.
               Several discrepancies were noted in this chapter as follows:

               The Man-Made Environment portion of this chapter was developed
               in a  format  completely  different than  that of the Environmental
               Assessment.   A  critical  inconsistency,  that of population
               projections, is discussed  later due to its effect on interceptor
               sizing.   Other  inconsistencies are  the lack of discussion
               on the socio-economic profile and solid waste disposal and
               an extraneous discussion on current and projected economic
               characteristics.

               The City  believes  that  the population  projections as contained
               in the original Facilities Plan have not been shown to be
               significantly different than any other reasonable projections.
               Given the nature of projecting future  populations, a significant
               difference should  be proven to justify any change from the
               Facilities Plan.   Minor variations  in  projections (10-15%)
               have  to be ignored since wastewater collection and treatment
               facilities have to be designed and  constructed to handle peak
               flows and provide  adequate treatment during dry weather low
               stream flows.
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                                                                  -13-
Probably the biggest issue addressed from a planning standpoint




in the EIS is the issue of induced growth.   The paragraph at the




bottom of page 11-25 seems to offer a better cause for induced




growth than found elsewhere in the EIS, and it is only partially




correct.  The interstate highways have convincingly made it easier




for people to move about in the urban area and their basic purpose,




notwithstanding,  had its foundation in a healthy economy and a




growing population.   This is true because the outerbelt serves two




functions -- to provide a bypass for through traffic and to relieve




traffic volume pressure in the center of the urban area.  The latter




fact is of far greater importance to inducing suburban growth than is




interceptor sewers.









Further in this chapter, the point is made that most existing




economic expansion trends are likely to continue, i.e., expansion




of that portion of Franklin County outside the City of Columbus.




However, that is qualified by the statement that "plans to




revitalize the downtown area may reduce the decentralization trend




of the 1960's and J970's."  First, downtown to most people would




be defined as the area within the innerbelt highway.  To say that




growth in this area would be responsible for measurably reducing




the decentralization trend is almost incomprehensible.  Even if




the EIS does not intend such a confined area as this, it will take




several decades to offset a trend that is far more historical than




just the 1960's and 1970's.  One of the principal reasons for




decentralization has been to avoid congestion, and we have not seen
                               IV-13

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                                                                  -14-
any noticeable trends to indicate any change.   It is particularly




evidenced in Columbus by the low density of development compared




with other areas.   We know of nowhere in any U.S. metropolitan




area where density does not decrease as  the distance from the down-




town or center increases.            (4.1.5)








Another major issue concerns the statement on page 11-53 that "the




total of 48,281  acres available for residential  development will




support a growth of 977,204."  Without taking exception to the




assumption that  this land would be developed at  the same density




as the present average density of the city (which is at least arguable),




nothing is offered to describe the location of this "available"




land.  Nothing is mentioned regarding other elements of the




infrastructure which may or may not exist, or such other factors




as zoning, social  setting, accessibility, community facilities such




as schools, parks, health facilities, etc.  Available and suitable




are not always synonomous terms where developable land is concerned.




In addition, there seems to be an inference that some of this land




has been or will be bypassed.  We are forced to ask the question




"Why has this land not been developed?"








Page 11-54 references a Mid Ohio Regional Planning Commission (MORPC)




study  indicating excess sewer capacity  in the city.  This can




probably be said of most cities, and therefore is hardly an unusual




situation.  However, we view this inference as being misleading




because, while this under-capacity is found in "most areas except....,"




we contend that most areas are probably already developedj and it is





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                                                                    -15-






               highly unlikely they  will  be  candidates  for £edevelopment at




               higher densities within  the planning  area.  Also,  the EIS mentions




               ultimate population,  and if these areas  of excess  capacity are not




               completely developed,  the  sewer  capacity is bound  to be excessive




               until  the area  is completely  developed.









               The EIS states  that "the availability, adequacy and accessibility




               of community services will  influence  the community's development




               patterns."  Community services historically follow, not precede,




               development, and they don't seem to have had much  of an influence




               on development  in the northern part of Franklin County or in  the




               southern part of Delaware  County where there are few such services.









               Finally, the EIS does not  generate any new environmental  impacts




               on any of the alternates proposed  in  the Facilities Plan and




               should therefore, come to  the same conclusions.









Specific Comments




   Page 11-8   Rocky Fork has  been deleted as a tributary of  Big  Walnut Creek.




               Also,  no discussions  of  Little Walnut Creek are  included.



                                 (4.1.6)




   Page 11-11  282 mgd is the  total  safe  yield  from  surface water sources  instead




               of the 182 mgd  reported  in the EIS.      (4.1.7)









   Page 11-11  Surface Water Quality information  in  the EIS contain:




               1.  No significant discussion of nonpoint sources.   (4.1.8)




               2.  A report of "several fish kills"  on  the Olentangy River which




                   are unsupported by documentation.    (4.1.9)




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                                                                  -16-
            3.   No discussion  of  fecal  coliforms, and  (4.1.10)

            k.   Hypothetical statements concerning dissolved oxygen
                concentrations in the Olentangy River.  (4.1.11)


Page 11-16  The EIS incorrectly states  that the northwestern quarter of

            Franklin County was not  covered by Climax beech forests.
                                                          (4.1.12)

Page 11-32  Why did the EIS generate new population projections when this

            was already done  in the  Facilities Plan.  Why did the EIS

            generate new projections when five local agencies already had

            generated projections?  Local  agencies would certainly have a

            better concept of  population characteristics in Columbus than
            U.S.E.P.A. in Chicago.  It  is noted that the EIS used a planning

            period population  of  1.11 million as compared to 1.18 million  in

            the original Facilities  Plan.  This shows the EIS effort for

            population projections resulted  in insignificant differences.
                                                       (4.1.13)

Page 11-35  Why did the EIS generate new population projections for the
            Interceptor Service Areas when this data was generated earlier
            for the Facilities Plan.          (4.1.131


Page 11-42  The City of Columbus  does not suffer from an inadequate water

            supply, nor do they anticipate any shortage throughout the planning

            period.         (4.1.14)


Page 11-^7  There is a tendency to equate all vacant  land as active farm
            land.  The EIS should address how much vacant  land  is active farm

            land.  The U.S. Government  is currently planning to pay farmers to
            take a minimum of 10% of all active farm  land out of production.
                               IV-16

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                                                                   -17-
            The conclusion has  to be  that we  have  too much active farm land.
                                                      (4.1.15)

Page 11-50  The EIS should explain that  the Scioto West  Interceptor would also
            relieve the contraints imposed now on  flow to the Scioto East.
                                         (4.1.16)

Page 11-5^  The EIS is misleading the readers by stating that excess sewer
            capacity exists.  When one considers the basis under which the

            sewers were designed, then the  sewers  have capacity  for the  intended
            purpose.  Until  such time as the  ultimate population  is reached,
            the sewers will  always technically have excess capacity.


            Table 11-23 does  not reflect sewer charges currently  in effect.
            A new rate structure was  developed which charges proportionate rates
            to all users of the Columbus Sewerage  System.  The new rate
            structure satisfies the requirements of PL 92-500 and has received
            formal approval  by  U.S.E.P.A.     (4.1.17)


Page 11-57  Safe yield of water appears  to be incorrect according to City of
            Columbus figures.        (4.1.18)
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                                                                         -18-

REVIEW OF
CHAPTER III.  SERVICE AREA AND SEWER SYSTEM ALTERNATIVES

    General Comments

        Service Area Population Estimates

            The EIS projections are, in three service areas,  lower  than  those used

            in the Facilities Plan (FP) and the EIS projections  for two  service

            areas are higher than those used in the Facilities Plan.   The total

            difference is less than 2.7 per cent.



            Who can estimate population any closer than this?



            The City believes the Facilities Plan  is better than the EIS.



        Environmental Impacts

            The EIS has duplicated material from the Facilities  Plan for the

            interceptor alternates.



        Design Criteria

            Planning period - the EIS uses   20 year population  projections with

            interceptors flowing at half full.  The implication  is  that  the sewers

            will convey, at full capacity, the flow from the forty  year  population.

            However, projections for the Facilities Plan show the population in the

            service areas will  increase 3-i* times from the year  2000 to  2025.  On this

            basis,  it is estimated that the EIS proposed interceptors will only convey

            flow for a 25~30 year planning period, at full capacity.  Therefore,

            additional  interceptors will need to be constructed  parallel to the EIS

            proposed sewers.  The EIS does not consider the environmental or economic

            impacts of parallel sewers.  The City will not design or operate sewers

            with capacity  less  than their  own criteria.      (4.1.19)

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                                                                  -19-
Previously Approved Projects

    EPA has approved the following interceptors using the  City  of  Columbus

    ultimate criteria.

        1)  Scioto West and Scioto East
        2)  Brookside Estates
        3)  Alum Creek Interceptor
        k)  Big Walnut Interceptor
        5)  Sewers in Westerville and Dublin
        6)  Blacklick Creek

        For further back-up information,  see Attachment  1.

Cost Estimates

    EIS used 0.25 percent of the construction cost as annual  0  6 M for  the

    interceptors.  A properly designed gravity sewer larger  than 15-inches

    in diameter would not require 0 & M except in rare instances.  This

    distorts cost estimates in the EIS.    (4.1.20)



    Salvage values were not straight lined, but appear to  have  followed a

    decreasing rate trend.  This approach has no justification  for interceptors

    and tends to show a higher present worth cost of interceptor alternatives.
                                   (4.1.21^

    By using a 20 year planning period, the EIS does not consider  construction

    of interceptors for the period from 2000 to 2025.  Therefore,  the present

    worth of EIS alternates is lower when compared to alternates scheduled

    for construction prior to 2000.      (4.1.22)


    EIS states that it used costs for interceptors based on  recent bids in  the

    Columbus area.  Where is the documentation?  Also, these costs are  likely

    to be less accurate to those in the Facilities Plan  since the  Facilities

    Plan costs were site specific.     (4.1.23)


    The increase in costs to construct the ultimate size gravity sewers as

    compared to the EIS proposed sewer works is approximately 1.5% when

    compared to the total costs of all the proposed construction.
                                IV-19

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                                                                   -20-





Pump Stations




    The EIS considers use of pump stations and force mains in the analysis of




    several alternates.   These alternatives have not been evaluated fairly,




    and thus the EIS has arrived at erroneous conclusions.  The City will  not




    assume responsibility for design or operation of force main and pumping




    station facilities as recommended by the EIS.








Sensitivity Analysis




    The EIS performs what is called a sensitivity analysis that compares the




    costs of three methods of sizing interceptors; full  at year 2000, half




    full at year 2000 and full at ultimate population.  The EIS justifies half




    full at year 2000 on the basis  that it costs 15 percent less than ultimate.








    First of all, full at year 2000 is not worthy of being considered as an




    alternate.  Second, this analysis should have been a cost effective analysis




    that  included environmental concerns related to each type of design criteria.




    For example, the full at year 2000 and half full at  year 2000 alternates




    will  require parallel interceptor construction at a  future date.  The




    environmental impacts of such a proposal are much greater as compared to




    the full at ultimate population alternate in which only one interceptor




    would  be constructed at a time prior to full development.  Even




    though EPA does not recognize the effects of  inflation in economic analyses,




    we  feel this factor cannot be  ignored.








    The EIS states  that the full at ultimate population alternate  is not cost




    effective because most of the areas would only be at or less than 25 percent




    of  their ultimate population.  The EIS fails  to recognize that these same




    areas are expected  to triple or quadruple in  population during the years






                                IV-20

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                                                                         -21-

        from 2000 to 2025, which is within the 50 year planning period that

        should have been analyzed for the interceptor alternates.


        Finally, it is noted that the EIS does not do a cost effective analysis

        to justify its basis for design.        (4.1.24)


West Scioto Interceptor

    General

        After the EIS shows that the High Level Alternate is more  cost effective

        than the Low Level Alternate, it  then proceeds to extend and enlarge

        the interceptor to convey flow from South Western Delaware County.

        However, no Cost Effectiveness Analysis (CEA) is performed that compared

        the pump station and force main alternate to that of extending the West

        Scioto Interceptor north from M.H. No. 3.    (4.1.25)


    Alternatives

        EIS arrives at same conclusion as was presented in the Facilities Plan

        with the exception of the pump station and force main.  The EIS does not

        include a Cost Effectiveness Analysis of the pump station, but only  an

        economic analysis.  No environmental issues are discussed  with regards to

        the pump station and force main over Griggs Reservoir.  Factors that

        should have been included are reliability, energy intensivenesss, etc.


        Legality - Columbus cannot serve South Western  Delaware County

        without a sewer contract.


Big Run Interceptor

    General

        The EIS considered the same alternate as was presented in  the Facilities Plan.
                                      IV-21

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                                                                   -22-
    Phasing
        The EIS suggests  that  the  section  between M.H. k and 5 may be needed by
        1995,  but  the rest  of  the  interceptor  should not be built during the
        planning period.  The  EIS  overlooked the fact  that the section between
        M.H.  k and 5 could  not be  constructed  unless the section from M.H.  5 f-O
        6 was constructed.  (4.1.26)
    Alternat ives
        The EIS proposes  construction  of two  interceptors along Fedder Road and
        Renner Road.  However, no  CEA  is performed  to  determine if other altern-
        atives to  serving this area  are attractive.  No calculation was made to
        determine  if the  existing  interceptor  system has the capacity to serve
        the Fedder and Renner  Roads  areas.  Finally, the  interceptors proposed
        by the EIS are incapable of  being  extended  in  the future.  (4.1.27)


Minerva Park
    General
        The EIS duplicated  the alternates  as used  in the FP.  The only difference
        is that the EIS proposes smaller pipe  sizes due to their sewer design
        criteria.   It is  noted that  the EIS states  ".... an  interceptor would be
        constructed from  the  Minerva Park  WWTP in westerly direction  to....the
        existing Alum Creek Interceptor."   The EIS  is  in error, since
        the Alum Creek Interceptor is  located  east  of  Minerva Park.  (4.1.28)


Big Walnut Creek,  Blacklick Creek, and Rocky  Fork
    Big Walnut Creek
        General
            The EIS proposes  delayed  construction  of  alternate A, which  the  FP
            stated was in an  environmentally  critical  area.  Also,  the delayed
                                IV-2 2

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                                                                    -23-
        construction  of this  interceptor will  increase  the  threat of




        contamination to Hoover Reservoir.  (4.1.29)








    Alternatives




        The EIS considers three alternatives  for  the  Big  Walnut  area,  identical




        to those previously analyzed  by the Facilities Plan.








    Phasing




        The EIS recommends that construction  of  the portion south of  Hoover




        Reservoir may be needed by  1985.  However,  the  remaining



        section would not be  constructed during  the planning period.   According




        to the EIS recommendations, Alternate A would eventually be implemented,




        although not  immediately.   This conclusion  was  not  based on a Cost




        Effectiveness Analysis but  rather,  on an  economic analysis  alone.




        The FP discussed the  environmental  assessment of  each alternate for




        Big Walnut Creek, and Alternate A was located in  an environmentally




        critical area.  Implementability was  also noted to  be a  significant



        factor in the FP as well as the environmental impacts to Hoover Reservoir.








Rocky Fork Creek




    General




        The EIS proposes construction of a  pump  station and force main to




        serve New Albany.  The issue  for the  EIS  to address is whether or




        not collection facilities are necessary.
                                  IV-2 3

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                                                                   -24-
    Alternat ives




        Basically,  the  EIS  contains  the  same alternatives as  presented  in  the




        FP with the addition of  a  pumping  station alternative, which  it




        recommends.   No considerations are given to  reliability,  energy  inten-




        siveness, or environmental  impacts related to  delayed construction of




        interceptors.   Unnecessary pumping of  sewage when gravity sewer




        alternatives are readily available is  contrary to today's energy




        conservation needs, and  poses a  greater threat of sewage  backup, odor




        nuisances and public health  hazards.




    Phas ing




        The EIS delays  construction  of all  interceptor alternates until  1995-




        It proposes a pump  station and force main be constructed  immediately




        to serve New Albany.   The  pump station and force main sizes would  be




        affected by annexation plans presently being contemplated by  New Albany.








Black)ick Creek Area




    General




        The EIS  recommends  serving only  the immediate  area  of Reynoldsburg




        with a pump station and  force main.








    Alternatives




        The EIS  considers the  same three alternatives  as previously  analyzed




        in the FP with  the  addition of  the pump  station and force main




        alternate,  which it recommends  be constructed  to serve  Reynoldsburg




        for the  period  from 1980-2000    The EIS  overlooks  the fact that  the




        adjacent  201 Facility  Plan for  Canal Winchester considers, as one




        alternative, conveyance  of its  sewage  to the Blacklick  Interceptor.






                                IV-2 4

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                                                                      -25-

            Also,  as  stated  in  other  alternates,  the  EIS  neglects  to consider

            environmental  impacts  and makes  recommendations on an  economic  basis
            only.   This is quite evident  in  the  Blacklick Creek  force main  alternate

            which  would be constructed through highly developed  areas of  Reynolds-

            burg.   The EIS grossly underestimates the environmental effects by

            stating that the route is along  residential and open grassy areas.

            This is totally  incorrect.


            Finally,  the EIS does  not consider reliability, energy intensiveness

            or environmental impacts  related to  delayed construction of  inter-

            ceptors.   Unnecessary  pumping of sewage when  gravity alternates are

            readily available is contrary to today's  energy conservation  needs,

            and poses a greater threat of sewage backup,  odor nuisances and public

            health hazards.


        Population Estimates

            The EIS is inconsistent throughout  its analysis of the Blacklick

            Creek alternates with  respect to the population to be  served.


    Cost Estimates
        The costs presented  in  Table  111-7 for the Big Walnut Creek,
        Rocky Fork and Blacklick Creek Sub-Areas  are  misleading.   They would
        appear to have been  manipulated  to allow the  pump station  alternate

        to look economically favorable.        (4.1.30)


Groveport

    General
        The EIS recommends Alternate  A which is  identical to  the recommendation

        in the Facilities Plan. This is  another duplication of  effort.
                                   IV-2 5

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                                                                   -26-
Rickenbacker AFB




    General




        The  EIS considered regionalization  of  Rickenbacker AFB.  This area was




        not  considered in the Facility  Plan because  the City of Columbus did not




        have a sewer contract with  RAFB.  Alternatives for serving  the AFB should




        be performed in a Facility  Plan  Update and not in an EIS.
                                IV-2 6

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                                                                     -27-


Specific Comments

    Page I I 1-1   The force main under Section 3-1.2 crosses  the  Scioto  River at

                 Martin Road,  not at S.R.  161.    (4.1.31)



    Page I I 1-2   EIS states a  detailed analysis  of  the  combined  sewered areas

                 is inappropriate at this  time.   This was one  of the  major

                 issues listed in the Notice of  Intent  to do the EIS.



                 EIS states a  model  of the combined sewer areas  was done.  The

                 reliability of such a model is  questionable since  it was  based

                 entirely on theoretical concepts and was not  verified  by  actual

                 field measurements.   (4.1.32)



    Page I I 1-5   Outletting the Sunbury/Galena/Delaware County Facilities  Planning

                 area into the Columbus system is not dealt  with in the Big

                 Walnut or Rocky Fork EIS  alternatives.   (4.1.33)



    Page 11 1-8   The EIS states "Sewers for the  areas to be  regionalized were

                 designed in the Facilities Plan based  on ultimate  population.

                 Guidelines proposed since the preparation of  the Facilities

                 Plan have recommended the use of year  2000  populations for sewer

                 design."

                     (I)  Why  do we have to start over  with  new designs every-
                          time a new guideline comes out.

                     (2)  The  above EIS statement says  that  the year  2000  is
                          recommended for  sewer  design,  but  does not  say that
                          the  year 2000 is required.



                 The EIS states that the quantity of dry weather flow used for

                 sewer design  in the EIS is 90 gallons  per capita per day  without

                                  IV-2 7

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                                                                   -28-
Page 111-8   any backup calculations  or  any  comment  about  the  Facilities
(cont'd.)
             Plan design.    (4.1.34)
             The EIS allowance for infiltration  is  10  gallon  per capita  per

             day.  This is not nearly enough  and  should  be  estimated on  an

             acreage basis and not tied to population.   The fallacy  is

             that, for a given population, the area in which  this  population

             lives will require different lengths of sewer  lines depending

             on development patterns  and the  area in which  the  population

             resides.      (4.1.35)



             Basing the infiltration on a per capita basis  (instead  of

             lineal feet of sewer based on an inch/day/mile standard or

             per acre assumption based on an  average  length/inch/day/mile

             criteria) is irrelevant, as per  capita per  acre  densities are

             too variable to relate to physical  feet of  sewer subject  to

             infi11rat ion.



             The EIS infiltration allowance makes no  consideration for house

             services, illegal connections, abuse or  even deterioration.

             This  is unreal!  In general, the EIS design criteria  for  sewer

             design  is unreasonable and not good engineering  practice.



             The EIS does not truthfully represent the facts  relative  to

             the Scioto East  Interceptor.  Dublin is  currently limited  to

             discharging 29 cfs.  Once this capacity  is  reached development

             will  be stymied until the Scioto West Interceptor is  built.

                                  IV-28                 (4.1.36)

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                                                                   -29-
Page 111-9   EIS used costs for interceptors based on recent bids  in the


             Columbus area.  However, it is inappropriate to use these  costs


             in different areas of the City because each interceptor site


             has its own construction problem.   The Facilities  Plan used


             cost which were developed for each specific site.




             The EIS shows the interceptor alternates to include Operation


             and Maintenance costs (O&M).   O&M  costs are much lower in


             interceptors than stated.




             EIS assumes the life of wastewater treatment plants to be  35


             years.  This assumption is completely unrealistic.  (4.1.37)




Page I 11-9   The use of the 1/2 full criteria provides for capacity beyond


             the planning periodt but no analysis was done to relate the


             20-50 years population flow demands to the sewer which has a


             stated service life of 50 years to determine whether  the sewer


             will serve the area throughout its stated life.  (4.1.38)




             EIS indicates that water pollution problems should be allowed


             to be created (New Albany area) before anything is done about


             them.   This is ridiculous and does not reflect proper environ-


             mental concerns and definitely does not reflect the intent


             of Public Law 92-500.    (4.1.39)




Page 111-12  Pumping stations are not good practice in this day on conserving


             energy, especially when a gravity sewer can be constructed.

                                                        (4.1.40)
                                IV-2 9

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                                                                   -30-
page 111-12  The statement  of  the  West  Scioto pumping to the East Scioto




             does not address  the  temporary nature of this Facility and




             the restriction of  outletting capacity.









             The "permanent" pump  station cannot be permitted to usurp




             East area sewer capacity.     (4.1.41)









Page 111-14  The adding of  additional Delaware area merely compounds the




             above comments and  requires a complete reworking of this area




             analysis.        (4.1.42)









Page 111-17  No substantial information is presented to back up the EIS




             contention that  some  part  of  the Big Run area can be cross




             connected to easterly area sewers by gravity.  Several proposals




             have been made to the City in the past and  it has been the




             City's constant  experience that pumping was required from each




             of the several locations  that were within the eastern part




             of the Big Run area N 6 S  of  l-?0.     (4.1.43)
                                IV-30

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                                                                   -31-
Page 111-17  With regard to running an interceptor from the  Minerva  Park




             plant to the Alum Creek Interceptor,  it would be  quite  a  feat




             to do it going west.   A considerable  amount of  money would be




             saved by going east.








Page 111-20  For Big Walnut, the EIS considered the same three alternatives




             as was previously done in the FP with the addition of another




             alternate.   The EIS recommends eventual implementation  of




             Alternate A which was shown in the FP to be extensively routed




             along environmentally critical areas.    (4.1.44)








Page 111-25  Growth in the Blacklick Creek area is stymied by  the lack of sewers




             and the reluctance by the County Commissioners  and OEPA to




             approve package plants for the developers who hold large  tracts




             of land.  Once it becomes obvious that sanitary sewer will not




             be forthcoming, then the developers will most  likely start



             construction anyway.   Once  the package  plants are  in, there will




              be little  support  if  not outright  opposition to  paying a second




              time for  interceptors.   Conclusions  drawn  by EIS are not valid.



                                                      (4.1.45)




Page 111-28  The EIS should explain that the Big Walnut interceptor  would




             also relieve the pollution load on Hoover Reservoir that  now




             exists.  One of the things the Sunbury-Galena facilities  plan




             must address is the possibility of the interconnection  with the




             City of Columbus via this interceptor as opposed  to building a




             treatment plant and discharging directly to Hoover Reservoir.
                                IV-31

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                                                                   -32-
Page 111-30  The EIS does not consider all  the  facts  regarding  the  Blacklick




             Creek Proposals.  The Metropolitan Park  is  aware of  the  sewer




             alignment and supports its current location.  They are




             desirous of seeing that  reach  of Blacklick  Creek cleaned  up




             immediately.     (4.1.46)









Page 111-31  The EIS recommends implementation  of  a force main  along  U.S. 40




             for the Blacklick area.   The environmental  and aesthetic  impacts




             of this alternate were grossly underestimated  in the EIS.  This




             force main travels along a U.S.  highway  and would  cause  severe




             traffic disruption as well as  significant disruption of  business




             which is located along a large portion of the  proposed route.




             Tunnelling would be extensive  due  to  the number of U.S.  highway




             and Interstate highway crossings.     (4.1.47)









             The EIS proposed pumping station location  set  in  the vicinity




             of S.R.  161 and the force main to Big Walnut  Interceptor totally




             ignors  the  fact that a previous federal  grant  paid for a gravity




             sewer from  the  creek to the vicinity  of  Hamilton  Road just south




             of Morse Road.  This grant and construction was  made to provide




             an outlet compatible with the New Albany plans.   This situation




             will require a  complete reworking of  the cost  effective analysis




             for the  Big Walnut/Rocky  Fork/Blacklick  areas.   (4.1.48)









 Page  111-32  Blacklick Alternative D has the most  primary impacts  (even




             considering the Blacklick Woods Metropolitan Park) and should




             not be  constructed.  The  gravity  interceptor sized to ultimate





                                IV-3 2

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                                                                 -33-
             flow  is  the best way to clean up the  waters and to eliminate




             dual  and triple construction impacts.    (4.1.49)









             No  consideration was given to the existing treatment plants in




             the vicinity of l-?0 and S.R. 256 and S.R. 20k.   (4.1.50)









Page 111-^0  Rickenbacker Air Force Base is not in the approved planning area,




                                                      (4.1.51)
                               IV-3 3

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REVIEW OF                                                               ~34~
CHAPTER IV.   ALTERNATIVES TO THE PROPOSED PLAN

    General  Comments

        Pretreatment of Anheuser-Busch Brewery Wastes

            The City of Columbus considered pretreatment of the brewery; however,

            this option was deemed unappropriate for the following reasons:

                l)  The brewery load is not considered incompatible according

                    to EPA standards.

                2)  No pretreatment standards for brewery wastes have been published

                    to date.

                3)  Economies of scale indicated that treatment at Southerly

                    would be less expensive.

                k)  The environmental impacts of a sewage treatment facility at the

                    brewery would be significantly greater as compared to treating

                    the brewery waste at Southerly.

                5)  The City has no  legal authority to impose pretreatment standards

                    on the brewery.

                6)  Discharge of pretreated brewery wastes might be worthless

                    due to the  long  travel  time  in the sewers to Southerly.

                7)  A  two year  research study, conducted by Ohio State University

                    under contract with the City, has not shown brewery waste  to

                    be the direct cause of  bulking problems at  the Southerly Plant.
                                                             (4.1.52)

            The EIS  recommends  "pretreatment" of  the  brewery waste to the point

            that  the  soluble oxygen  demanding  load  is largely  removed (a  roughing

            filter  at  Anheuser-Busch).  The following questions should  be taken

             into  consideration:

                 (l)   Have  adequate  provisions  been  taken  to prevent odors?

                 (2)   What  is  the  success  and  feasibility of this method?

                 (3)   What  will  be the impact  on  Southerly  solids  handling facilities?

                 (k)  Will  there be problems in the sewers?
                                     IV-3 4

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                                                             -35-
(5)  Is this being done anywhere successfuly?
     If so, what are the problems?
(6)  Who would operate the Brewery  facility?
(7)  Were the basis of cost estimates  the  same?
(8)  Can this proposal be implemented?
(9)  Can any of sludge handling  at  Southerly be eliminated as
     proposed?
(10)  What are EIS proposals for  quantities of  sludge  generated and
     methods and costs of disposal?
(11)  Table IV-2 Page IV-6.  It appears in  the  EIS,  that scenarios
     2, 3 and k, eliminate S2A.5 million  in solids  handling costs
     at Southerly.  While the Brewery  costs reflect  increases as
     level of treatment increases,  the level of cost  at Southerly
     doesn't vary. - This isn't  possible.  	  The  solids
     processing cost at the Southerly  in  "Scenario  2" would have
     to be greater than in "Scenario V!    (4.1.53)
     Based on present worth  equivalent  estimates, which are
     within ten percent of each other,  can  it  be  reasonably
     concluded that Scenario 2 is  the best  overall  brewery waste
     treatment strategy?

     Were projected loads at the Brewery  taken into consideration?

     It appears that the data presented in  Table  IV-2  are
     erroneous and inaccurate.       (4.1.53)

The bond issue for a refuse  and coal  fired  power  plant has been
approved and planning is proceeding.  The discussion of the  use of
the Jackson Pike Plant effluent as cooling  water  at the power
plant is beyond the scope of this  EIS or  the  facilities plan
and should not be addressed.    (4.1.54)
                          IV-3 5

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                                                                   -36-
Land Disposal  of Sludges




    The City of Columbus is interested in developing  a  land  application




    program but has been very reluctant  to implement  a  full  scale program




    because of some of the undefined environmental  pollution problems  that




    could result with attendant liability to the City.   The  City recently




    accepted an invitation by the Ohio Farm Bureau  Federation to participate




    in a land application program which  would investigate  all  aspects  of




    land application of sludges under an~EPA federal  grant.   Under this 3




    year program,  the City will be cooperating with the Ohio Farm Bureau




    and the Ohio State University's Department of Agriculture Engineering




    and College of Medicine,  by applying sludge to  land under completely




    controlled conditions.  This program will generate  valuable data and




    information which can be taken into  consideration in the development of




    future land application programs.









    Landfill disposal of sludge is against Ohio EPA policy and furthermore




    it  is not  implementable due to a considerable amount of  public resistance.




    Reclamation of strip mines must be a total program  which serves the




    need of the strip mine operator.  This program  is therefore not one which




    can be turned on and off by the failure of incinerators.









    The City of Columbus considers the alternative  of using  land disposal




    of  sludges as a backup to  incineration as  inadequate  until  further




    developmental programs have been performed.  Therefore,  the City requests




    immediate  approval of the proposal as presented in  the Facilities Plan




    for disposal of sludge.              (4.1.55)
                                IV-3 6

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                                                                   -37-
Design Parameters




    In developing the design flows,  the Infiltration/Inflow Analysis




    Report has been completely ignored.  Instead,  I/I  flow data has been




    developed using assumptions which are not backed up by any actual  local




    field work.









    The wet stream processes in the Facilities Plan were designed to treat




    loads corresponding to projected average dry weather flows and peak




    hydraulic flows equal  to twice the average dry weather flows.  This




    would constitute the first stage of construction.   During the second




    stage, additional facilities will be designed and  constructed and  as




    warranted by the results of combined sewer monitoring and sewer system




    evaluation survey.  This approach is consistent with the phased




    construction concept of the Facilities Planning Regulations of the EPA.









    In contrast, the EIS has attempted to develop average flows  (including




    wet weather flows) and peak hydraulic flows and yet states (p.lV-2),




    "Pending the results of an ongoing sewer system evaluation survey, it is




    not recommended that any additional hydraulic capacity be provided at




    the two Columbus treatment facilities."        (4.1.56)
                                IV-3 7

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                                                                   -38-
Oxygen Production and Dissolution
    The EIS recommends the use of the jet  aeration  system.   This  recommendation
    does not seem to be based on firsthand knowledge but "reported"  standard
    oxygen transfer efficiencies as high as 5 Ibs per brake horsepower hour
    at 15 feet of water depth.  After conceding that "the acceptance of jet
    aeration system has been limited in the past due to high installation costs,
    cheap energy, and fears concerning maintenance", the EIS describes new
    developments and recommends this system even though it further states,"
    jet aeration would not be the system of choice under the energy  price of
    1.5^/KWH used in preparing the.Columbus Facilities Plans".   Thus, the
    EIS concedes that the jet aeration system would be uneconomical  and
    unreliable in 7^-75 when the Facilities Plan was prepared.

    Even now, the jet aeration system, adopting  what the EIS claims a
    savings of $1.3 million in first cost  at Southerly,  is  not  recommended
    from firsthand experience of the system or with full consideration of the
    maintenance and operation problems that it could present to the
    Columbus plants.   Instead, the recommendation and the "saving"  in cost
                                IV-3 8

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                                                                   -39-
    are based  on  "full  scale  performance  data  supplied  by  Pentech".  Also,




    the EIS  shows a  higher installed  cost for  the  jet aeration  system  (6.k




    million  vs 4  million  dollars  for  fine bubble diffuser)  and  yet claims




    a  "saving" in first cost!








    At the planning  stage, cost estimates to compare  the available alterna-




    tives  are  usually worked  out  using  proven  technologies.   During  the




    final  design  stage  a  detailed evaluation of the available innovative




    technology can be worked  out  and  the  cost-effective technology which ensures




    effective  operation and ease  of maintenance can be  chosen.   Such a




    procedure  ensures orderly development of plans.   The Facilities  Plan




    was developed accordingly.  Thus, not only jet aeration but all  available




    technologies  for oxygen dissolution would  be reviewed  at  the time of



    final  design.      (4.1.57)









Flow Equalization




    The EIS  states (p.  TV-72), "Thus, the wisest flow peak imanagement program




    for Columbus  appears  to be one that awaits the results of the sewer




    system evaluation and sewer  separation project in order to  rationally



    define the future benefits to be  derived with  a flow equalization strategy




    that makes full  use of existing capabilities and  considers  the full




    potential  of  upstream storage within  and external to the  collection system.




    This strategy will  maximize  the City's pollution  abatement  program  in the




    near term, and offers the potential to fully realize the treatment




    capability contained  in the  Columbus  plants over  the forseeable  future".








    The EIS  here  agrees with  the  Facilities Plan which  recommended a phased




    approach in the construction  of  the facilities.   Yet the  EIS develops an




                                IV-3 9

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                                                                   -40-
entirely different set of design flow parameters!   This  waste  of  time,




effort and money could have been avoided.








The EIS states (Appendix Pg. 1-27), "The design hydraulic capacity of a plant




is normally selected at 2 to 2.5 times the average daily flow  for




facilities the size of the Columbus installation".   We agree that this




would normal1y be the case.  However,  the following points  should be noted:








    1.  The plant facilities in the facilities plan are  designed  on




        the basis of average dry weather flow and  not annual average




        daily flow as design annual average daily  flow cannot  be




        determined with certainty without obtaining the  results of the




        sewer system evaluation survey and combined sewer studies.








    2.  With the construction of necessary equalization  facilities in




        Stage 2, there is no reason for the peaking factor  to  be  2 to




        2.5 times average flow as normal1y required for  plants without




        equalization facilities.              (4.1.58)
                                IV-40

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                                                                    -41-
Specific Comments
    Page IV-35   The anaercibic stabilization  of  heat  treated  sludges must be
                 considered an unproven  process.    (4.1.59)


    Page IV-37   Waste heat recovery  boilers  have  been  proposed  but not  installed
                 at either plant.    (4.1.60)


    Page IV-50   In reviewing Table IV-15,  the City assumes there  is considerable
                 amount of detailed data to back it up.   The  following  is a
                 number of questions  which  come  to our  mind:
                     (1)  How many trucks is  a fleet?
                     (2)  What is  the size  and type of  the  trucks?
                     (3)  What is  the travel  time?
                     CO  What union  requirements  were  considered?
                     (5)  What wage scale was considered?
                     (6)  What secondary roads would  they be  permitted  on?
                     (7)  Where would they  be housed?
                     (8)  Where would they  be maintained?
                     (9)  Who would maintain  them?
                    (10)  What energy considerations  were made?
                    00  Were air pollution  problems from  added vehicular
                          travel considered?

                                                (4.1.61)
                                 IV-41

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                                                                    -42-
  Page IV-51   The  beginning of the paragraph at the top of  the  page  is




              missing, and is believed to be highly important.   (4.1.62)








Figure IV-1    Scheme C Thermal Conditioning - Anaerobic stabilization




              indicates that sludge cake is recycled to the main drain,  is this




              true?      (4.1.63)








  Page IV-52   The  EIS  indicates the farmer should pay for the application




              of sludge to farm land-  Normally  it  is just  the opposite.




                                                (4.1.64)
                                  IV-4 2

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                                                                  -43-
   Page  IV-65    The  City agrees that the present oxygen production and

                dissolution  systems at the wastewater treatment plants

                severely affects plant operations as well as being maintenance

                intensive. However, a more in-depth analysis must be performed.

                A  quick solution which has not been field tested for several

                years  is not the answer, unless, U.S.E.P.A. is willing to

                participate  in  100% of the costs.          (4.1.65)



                There  is no  lack of manufactured diffuser socks for th<* Columbus

                aeration system.



   Page  IV-67    Preliminary  Columbus evaluation of belt pressure filter systems

                indicated  low processing capacity for invested capital, with

                large  numbers of moving pieces and intricate systems indicating

                potential  for severe maintenance problems.    (4.1.66)



Page IV-68,  69  Anaerobic  digestion of thermally conditioned sludges or decant

                liquors has  been explored by Columbus and should be further

                evaluated.      (4.1.67)



   Page  IV-76    Comments on  variations possible  in total operating solids are

                valid.  The  need for an adequate air supply to meet demands of

                increased  solids and the effect of contact times to remove

                soluble organic materials have not been discussed. (4.1.68)



   Page  IV-80    At the current  time the Agency only permits one manufacturer

                to design  at a maximum of 5 gpm/SF.  Requiring the City of

                Columbus  to  design to this figure is specifying the equipment

                manufacturer and eliminating competitive bidding   (4.1.69)
                               IV-4 3

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                                                                       -44-
REVIEW OF
CHAPTER V.   FINAL ALTERNATIVE SELECTION  FOR THE  WASTEWATER  TREATMENT  FACILITIES

     General Comments
         First Stage Biological  Treatment

             1.  We do not agree with the recommendation of the EIS  that  first

                 stage biological treatment be eliminated at Southerly.  (4.1.70)



             2.  The pump station for trickling filters at Jackson Pike is sized

                 for 220 mgd to allow for "a 20 mgd credit for recycled flows".

                 This shows the danger inherent in making recommendations based

                 on design approach different from that used in the  Facilities

                 Plan.  For example, the recycle flows do not necessarily have

                 to go to the first stage biological treatment, they can go to

                 the second stage.  Also, they can be programmed for addition to

                 the plant facilities during non-peak hours.   (4.1.71)



             3.  As shown in Table K-l on page K-2, the EIS assumes 58%, 37% and

                 27% removal of  SS, BOD^ and Phosphorus respectively during primary

                 clarification and without the addition of aluminum to raw sewage

                 on a  regular basis.  In comparison, the U.S.E.P.A.  design manual

                 for phosphorous  removal shows the following range of  removals

                 obtainable  in primary treatment without mineral addition:

                            Suspended Solids Removal        40-70%
                            BOD Removal                     25-^0%
                            Phosphorous Removal              5-10%

                 Thus  the EIS, contrary  to prudent design  practice, assumes design

                  removal  rates near  the  higher  limits of generally observed range

                  of removal  rates.   By adopting this practice,  it shows  lower loads on

                  subsequent  treatment facilities which  then would be sized smaller

                  than  would normally be  required.
                                       IV-4 4

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                                                                 -45-
A.  At Jackson Pike, the EIS recommends eight 78-ft. diameter

    trickling filters.  The Facilities Plan recommended eight 10^-ft.

    diameter trickling filters.                (4.1.72)


Within the range of the design criteria available, it is easy to pick

up a convenient design criterion such as a relatively high design

hydraulic load and come up with an "economical" design at this stage.

For example, according to the Process Design Manual for Upgrading Existing

Wastewater Treatment Plants published by the EPA, "Synthetic media filters,

because of their high surface area per unit volume, can perform as well

as high-rate filters at volumetric BOD loadings of about 50 to 100 lb/1,000

cu. ft., and hydraulic loadings of 0.5 to 1.5 gpm/sq. ft."  In comparison,

the EIS design criteria are 1)  BOD load of 170 Ib/1,000 cu ft/day and

2) hydraulic load of 2.0 gpm/sq. ft.  The Facilities Plan design criteria

are 1) BOD5 load of 95 lbs/1,000 cu ft/day and 2) hydraulic load of

1.05 gpm/sq. ft.  The design BOD,- load in the Facilities Plan was based

on achieving a 70% BODq removal during the low winter temperatures

recorded in Columbus.  The EIS claims a 65% substrate removal, while the

design equation used to estimate this removal is not known.  The USEPA

design manual  further states, "The results obtained by any design equation

will be dependent upon the assumptions made in using the equation.

Unfortunately, no equation has yet been developed which reflects the

actual performance of filters,  due to the complex interrelationship of

the many variables involved.  Since it is difficult to accurately predict

trickling filter performance based on these equations, they have limited

utility in trickling filter plant design.  Wherever possible, it is

recommended that treatability or pilot plant studies be used to verify

performance predictions based upon the various design equations".
                                IV-4 5

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                                                                  -46-


    The Facilities Plan concurred with the above recommendation of the EPA

    manual and realizing the importance of the huge investment required

    for these facilities,  recommended pilot studies to determine precise

    design parameters for trickling filters.   The EIS recommends against

    such pilot studies!                          (4.1.73)



Second Stage Biological Treatment

    The EIS recommends that the Busch Brewery treat its waste with

    trickling filters.  The resulting waste reaching Southerly will  be

    treated by single stage activated sludge nitrification process.   The

    system is to operate as a combination of contact stabilization and

    step aeration.  An additional 5.2 million gallons of aeration volume is

    to be used for the sludge stabilization tank.  The remaining tanks

    (existing) are to be used as contact tanks and operated in a step

    feed mode.



    On paper, this set-up looks good and the MLSS values given in the

    EIS are reasonable.  However, there are some problems in operating in

    contact stabilization to step aeration mode when complete nitrification

    is desired.  The EPA Process Design Manual for Nitrogen Control  states

    the following concerning the use of contact stabilization for nitrifi-

    cation:

        "The process  is not well suited for complete nitrification,
        even though relatively high solids retention times can be
        maintained in  the process because of the inventory of solids
        in the sludge  reaeration tank.  Nonetheless, insufficient
        biological mass is present  in the contact tank to completely
        nitrify the ammonia and since ammonia is not absorbed on the
        biological floe, ammonia will bleed through to the effluent.
        Partial nitrification can be obtained at levels which can
        be predicted  by methods presented  in Section k.3-6.  The
        ammonia bleed-through characterizing contact stabilization
        plants  is avoided  in a step aeration plant because of the
        greater contact times employed and backmixing of  influent
                                IV-4 6

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                                                             -47-

    occurs.  Nonetheless, some bleedthrough of ammonia as well
    as organic nitrogen can occur.  This bleedthrough results
    from short circuiting of influent to the effluent and
    insufficient contact time for complete organic nitrogen
    hydrolysis (ammonification) and oxidation of ammonia"
                                                   (4.1.74)


It would be better to incorporate flexibility in design so that the

system may be operated in step aeration mode if desired.  The contact

stabilization-step aeration design would act as a safety factor if

higher than design loads were encountered.  If the nitrifying

activated sludge system were operated in the conventional mode, the

additional volume required for the EIS loading at 2000 Mixed Liquor

Suspended Solids (MLSS) is 35-9 million gallons.  It is very doubtful

the EIS proposed single stage nitrification will meet the NPDES

requi rements.



There are 8 existing secondary clarifiers at Southerly with a total
                           fy
surface area of 135,^00 ft. .  The Facilities Plan designed the final
                                                     o
clarification step for an overflow rate of 500 GPD/ft  at average dry

weather flow.  This would require an additional 37,^00 ft  of tank

surface area.  The EIS proposes no additional clarification tanks,

resulting in an overflow rate of 700 GPD/ft  for average daily  flow
               2
and 1850 GPD/ft  for maximum design hydraulic flow.  This might be

justified for a very low solids loading.



However, the performance of clarification for activated sludge  is

governed by two factors; a) the area required for clarification and b)

the area required for thickening.  The EIS assumes that the area required

for thickening governs.  Thus a high overflow rate is required  before

thickening will be limiting.  However, clarification must also  be

considered in the design.
                           IV-4 7

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                                                                 -48-


    The existing  final  clarifiers  surface  area  at Jackson Pike  is
              ty
    110,160 ft .   The Facilities Plan  proposes  an annual average

    overflow rate of  500  GPD/ft  which requires an additional

    95,500 ft2 of final clarifier  area.  The  EIS proposes that  no

    additional clarifiers be  provided. The resulting overflow  rates

    are: (l) 1,090 GPD/ft2 for average daily  flow and 2,000  GPD/ft2

    for maximum hydraulic flow.  It  is felt that the final clarifiers

    should not be designed for such  a  high overflow rate without

    obtaining justification for  it through pilot testing as  recommended

    by the facilities plan.  If  the  nitrification operation  deteriorates

    due to poor clarification,  it  will adversely affect  the  efficiency,

    operation and maintenance of the effluent filtration system.
                                                  (4.1.74)


Effluent FiItration

    The EIS recommends the use of  Hydroclear  filters.  These filters

    have not been used to date for any major  wastewater  treatment

    plants.  Reliable data regarding the operation and maintenance

    required for  them when installed at a  major wastewater treatment

    plant approaching the magnitude  of those  at Columbus are not

    available. Thereforem it is not possible to compare the total

    annual costs  of the Hydroclear system  with  the filter systems

    proposed  in  the Facilities  Plan.  Furthermore, Hydroclear filters

    are a patented system available  from only one manufacturer. This

    effectively  eliminates any  competition.        (4.1.75)




Oxygen Dissolution System

    Once an air activated sludge system is conceptually  agreed upon

    to achieve nitrification, the  selection  of  a  cost-effective

    method of oxygen dissolution is  a  matter  to be addressed during  the
                                IV-4 8

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                                                                      -49-



                 final  design and could form an  appropriate  part  of  the  applicable




                 value  engineering process.   The EIS  seems  to  have used  this ploy




                 to  somehow come up  with  a  cost "saving".    (4.1.76)








             Di sinfection




                 The EIS  recommends chlorination,  dechlorination  and postaeration.








                 The Facilities  Plan  envisioned  using  the following:




                     1.   Chlorine residual monitoring  and controlling  to limit




                         chlorine residual to less  than  0.5  mg/1.








                     2.   Aeration in  the chlorine contact  tanks.  Work by



                              1                   2
                         Kappe1  and Kothandaraman  et  al has shown that  aeration




                         in chlorine  contact results  in  D.O. from 6  to 9 mg/1,




                         less chlorine use and more efficient  bacterial  kill.








                     3.   In view of the latest Ohio State Water Quality  Criteria




                         published in February 1978,  it  may  be required  to




                         reduce chlorine residual  still  further.   In that case,



                         the cost-effectiveness  of ozonation compared  to




                         chlorination-dechlorination-post aeration system should




                         be examined.  The former precludes  the generation of




                         chlorinated  hydrocarbons while  the  latter does  not.



                                                          (4.1.77)
     ^Kappe, David S., "Improved Effluents by Aeration of Chlorine Contact  Tanks"

A2nd Annual Conference of Water Pollution Control  Association of Pennsylvania,

August 1970.



     2Kothandaraman, V. and Lin, S. D. "Air Agitation of Treatment Plant  Effluents".


Public Works, August 1973.

                                   IV-4 9

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                                                                     -50-
"Savings" in Cost




    For wet stream treatment,  the EIS (p.  19,  20)  shows savings in first




    cost over the recommendations in the Facilities Plan of $10.2 million




    and $16.8 million at Jackson Pike and Southerly,  respectively.  These




    "savings" are not true savings,  as most  of them are arrived at by




    adoption of design criteria even beyond  the higher limit of accepted




    design criteria without acceptable justification  or pilot testing.








    Examples of this include 1) reduction of trickling filter



    area at Jackson Pike by using a  high design loading ("Saving"-$l.1




    million), 2) reduction of  aeration tank  and final  clarification tank




    volumes at Southerly ("Saving-$1.3 million), 3) reduction of final




    clarification tank area and inadequate consideration of rehabilitation




    requirements for aeration  tanks, clarifiers, blowers,  piping and




    other auxiliary equipment  at Jackson Pike  ("Saving"-$9.1 million).




    The total "Saving" produced with these tactics is thus  $11.5 million.








    The remaining "Saving" of  $15-5  million  is achieved by eliminating




    first stage biological treatment at Southerly.  This concept of




    treatment by the brewery is questionable,  as its  environmental



    impacts are not analyzed by the  EIS.  Also, the impacts on the annual




    cost of operation and maintenance of the plant with and without brewery




    are not thoroughly analyzed by the EIS.   This "Saving" is thus doubtful.








    Again,  it must be emphasized that these  apparent "Savings" are shown




    by using value engineering techniques (without  insuring rel iable




    plant operation through reliable design) which are irrelevant at this




                                 IV-50

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                                                                   -51-
    preliminary planning stage.


    In exchange for these questionable "Savings",  the  City  of  Columbus

    is required to bear an increase of $23 million in  the cost of  the

    wet stream treatment facilities due to inflation  in  the last two

    years.                                             (4.1.78)


Pilot Plant

    The Facilities Plan recommended a pilot plant  study  to  test the

    effectiveness of the recommended process and confirm the design

    criteria.  The pilot plant program was required to fulfill the

    following objectives.

            Verify the capabilities of the treatment  processes.

            Optimize the design parameters of the  treatment processes.

            Check the cost-effectiveness of the proposed process system

            alternate.

            Establish the efficiency and stability of  each  process under

            various weather conditions and with the normal  variations  in

            waste load characteristics.

            Establish sludge production rates.

            Establish the mode of operation for the process selected.


    The EIS recommends that pilot plant study be carried out only  to

    evaluate anaerobic digestion of thermally conditioned secondary  sol Ids

    and jet aeration.


    We strongly disagree with the recommendation of the EIS.  As already

    pointed out before,  in absence of any reliable design equation which
                               IV-51

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                                                                   -52-
            is  universally  applicable for the design of trickling filters,


            development of  design criteria by pilot testing  is the only choice


            for large  plants.  Pilot testing will also determine the necessity


            for intermediate  sedimentation.  Operating experience with


            nitrification  in  various modes of activated sludge with varying


            characteristics of wastewater is still negligible.  Pilot testing


            for nitrification and subsequent clarification is therefore


            absolutely essential.  The Facilities Plan designed effluent filters

                                           o
            for a  loading  rate of 3.0 GPM/Ft .   If pilot tests show higher


            loadings are possible, a more cost-effective design can result.


            While  pilot testing  the various treatment processes, several oxygen


            dissolution equipment available on the market  including jet aeration


            can be tested  to  make selection of cost-effective equipment possible.




            It  is  emphasized  that the relatively small expenditure incurred  in


            pilot  testing  will provide an insurance against  any costly redesign,


            modifications,  or additions, that may be necessary if any plant


            additions  made on the basis of traditional assumptions only, are


            found  to be  ineffective  in producing the desired effluent quality.


                                                     (4.1.79)


Summary of General Comments


        The EIS concedes  that their analysis has no conceptual disagreement


        with the design  proposed in  the  Facilities Plan.




        The process of independent development of design and costs constitutes


        application of value  engineering which  is  irrelevant at the facilities


        planning stage.


                                IV-5 2

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                                                         -53-
Underdesigning of facilities amounts to applying value engineering




costing techniques without ensuring reliable design to achieve the




desired effluent quality.








A thorough pilot testing of the process system recommended by the




Facilities Plan is absolutely essential to provide an insurance against




costly redesign, modifications, or additions that may be necessary If




any plant additions, made on the basis of traditional assumptions only,




are found to be ineffective in producing the desired effluent quality.
                       IV-5 3

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                                                                    -54-
Specific Comments
    Page V-2    The  200 mgd assumed hydraulic capacity at Jackson Pike must
                be verified.    (4.1.80)


    Page V-3    I tern 11 The City of Columbus has a sewer use ordinance which
                is being  enforced at the present time.  (4.1.81)

    Page V-8    The  Division  of Water, City of Columbus will not allow the
                use  of its quarry or its useful life to be reduced with
                incinerator ash.   (4.1.82)

    Page V-14   The  City  questions whether contact stabilization proposed at
                Southerly for nitrification is practical.  (4.1.83)

                The  EIS proposes to put 180 mgd through the filter complex at
                Jackson Pike  and 205 mgd at Southerly.  Since the EIS is
                proposing to  treat 200 mgd at Jackson Pike why isn't the remaining
                20 mgd being  filtered.   (4.1.84)

    Page V-15   The  original  facility plan was to meet the first NPDES permit.
                Since then, the NPDES  limits have changed and also particularly
                the  water quality standards have changed so the original
                chlorination  concept is no longer valid and the City really
                should be addressing the possibility of ozonation. (4.1.85)

                In secondary  thickening, the EIS recommends standby polyelec-
                trolyte addition capability.  An air flotation system will  not
                work at aj 1 without some type of polymer addition.
                                 IV-5 4

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                                                                 -55-
Page V-16   Storage of thermally  conditioned  solids  is not a viable concept

            as proved by operation  of  the Southerly  facility.


            The use of digesters  for thickening of thermally conditioned

            solids is questionable  without expensive  remodelling.
                                                     (4.1.86)

Page V-23   We question the savings and  project cost.  No. 1) they have
            undersized the facilities  allowed the City, No. 2) they have

            proposed a treatment  scheme  for Anheuser-Busch that  is totally

            unacceptable, No.  3)  they  have proposed  flows through the plant

            that cannot possibly  achieve NPDES  limits with their inadequate

            faci1i ties.


Page V-26   City Civil Service policy  makes sharing of personnel between

            plants an unlikely event.    (4.1.87)
                              IV-5 5

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                                                                   -56-
REVIEW OF
CHAPTER VI.  PRIMARY ENVIRONMENTAL  IMPACTS  OF THE PROPOSED WASTEWATER
            TREATMENT FACILITIES
    General  Comments



           This chapter reaffirms  the  results of  the  Environmental Assessment

           (EA).  The EA was  reaffirmed  in  the  introductory  paragraph,  but  the

           bulk of the chapter  contains  extraneous  discussions of matters with

           relatively minor importance.   The following  is  a  discussion  of those

           extraneous  items:



             1.  Land - The EIS gives  a  hypothetical  discussion  on abandonment

                 of present sludge lagoons  and  possible  related  impacts.  Also

                 included is  a  lengthy dissertation on the difficulty of

                 predicting negative impacts of the possible backup  sludge

                 disposal system.



                 The EIS has  suggested and  implied  that  land disposal of

                 sludge offers  many advantages  or benefits.   However, the EIS

                 fails to select any specific sites for  any  land disposal.

                 Further, it  fails to  describe  any  potential  impacts associated

                 with disposal  at  any  land  site or  sites.  Thus, one of the

                 major questions listed  in  the  Notice of Intent  to do the EIS

                 has not been addressed  in  any  meaningful  way.   (4.1.88)



             2.  Air - The EIS  contains  extensive discussions concerning:

                 a.  Aerosols carrying pathogenic organisms  ("Although

                     not presently thought  to be  a  serious negative  impact...")

                                 IV-5 6

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                                                         -57-
b.  The "uncertainty related to the health  impacts of  the



    participate matter emissions" even  though  it was



    stated that a wet scrubber would be used to meet  the



    New Source Performance Standard.








c.  "Heavy metals such as those released from  sludge



    incinerators could have adverse effects".








d.  Discussion of cyanides and chlorobenzenes  in sludge.








The EIS offers no documentation to support  the above comments



as related to the Columbus situation.     (4.1.89)
                       IV-5 7

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                                                                     -58-
REVIEW OF
CHAPTER VII.  SECONDARY IMPACTS OF THE PROPOSED  ACTION
     General Comments



                  This chapter exacts heavy tribute from the land  use effects

                  of the proposed project while  relegating  "other  environmental

                  impacts" to be a miscellaneous discussion.  Only two (2)  of  the

                  thirty-one (31) pages deal  with water-related  secondary impacts.

                  Only by adjusting the phasing  of interceptor construction in

                  some areas and proposing the substitution of pressurized  mains

                  in others were minor improvements in  the  secondary impacts

                  described in the Environmental Assessment effected.



                  This chapter begins with the following:



                  The secondary impacts of a proposed action are "(1) indirect

                  or induced changes in population and economic  growth and  land

                  use, and (2) other environmental impacts  resulting from these

                  changes in land use, population, and  economic  growth."



                  Because one of the principal contentions  of the  EIS is that  some

                  interceptor sewers will induce growth, it is important that  the

                  statement above be analyzed carefully.



                  Two points are critical and have already  been  established and

                  presumably sanctioned by the EIS.  These  are that the economy

                  is healthy and will support additional population growth  and

                  that this growth will occur with or without the  proposed  action.
                                   IV-5 8

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                                                       -59-
Thus far, our comments regarding induced growth have contended




that development precedes the need for sewers.  Development




does logically occur where sewers can be provided,  but that does




not mean it will not occur if they cannot or will  not be provided,




It simply means that a delay might be incurred or  other forms of




treatment would be sought.  We believe the lack of availability




of sewer service has not alone materially reduced  growth in




metropolitan areas.








Given the function of interceptor sewers, i.e., to accumulate




flow from smaller sewers for transport to the treatment plant,




their function becomes almost incidental to or unrelated to




being a stimulation to growth.  We believe this to be the case




because we are not aware of locations where interceptors have




been built in advance of development in the speculative sense.




They are built in response to need caused by expansion of or




additions to smaller sewer systems built to serve  growth as




it occurs.








The primary reasons for the interceptor sewers proposed in




the Facilities Plan are to correct existing problems and to




prevent new ones from occur ing.
                    IV-5 9

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                                                                 -60-
Specific Comments

Page VI1-8   The  institutional changes suggested would tend to be

             exclusionary and  the legality is questionable. (4.1.90)


Page VI1-10  The  cost  of private disposal installations are substantially

             understated.   Operation and maintenance has not been mentioned,

             and  historically  has been very poor.  (4.1.91)


Page VI1-11  Table VI 1-1 does  not represent the proper fjow an{j costs

             in Central Ohio.   (4.1.92)



Page VI1-13  The  EIS is evidently not aware of the development pressures

             in the Blacklick  watershed.  If sewers are not provided, this

             will  result  in unsatisfactory installations and pollution

             problems.  (4.1.93)


Page VI1-17  While some demand may be placed on the City of Columbus

             where the already serviced developable areas are located,

             a review of  local  agency files will show that as much or

             more demand  is made where services are not located. (4.1.94)


Page VII-18  Last paragraph.  Where  is the support for this EIS conclusion?

             The absense of interceptors has not stopped the growth.
                                      (4.1.95)

Page VI1-20  Under Scioto West, the  EIS recognizes two of the major factors

             why  people place  sewer  service low in importance in deciding

             on a place to  1ive.

                               IV-60

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                                                                  -61-
Page VI1-21   The EIS  should  be  aware  that New Albany  is attempting to
             annex Plain  Township.  This can completely change the conclusions
             with reference  to  the  Rocky Fork and Blacklick Interceptors.


             The EIS  conclusion for Blacklick  is totally unacceptable
             because  all  the facts  were not taken into consideration.
                                                           (4.1.96)

Page VI1-30   The conclusions under  section 7.5 with respect to Blacklick
             and Rocky Fork  are totally unacceptable.  This is also true of
             Big Walnut and  Big Run areas.
                               IV-61

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                                                                     -62-
REVIEW OF
APPENDIX A. BASELINE EVALUATION  OF THE  COLUMBUS. OHIO FACILITIES FOR
            WASTEWATER TREATMENT

     General Comments
         Appendix A of the EIS  contains  many  incorrect  statements and assumptions

         which significantly effect  the  proposals and decisions made  in  the EIS.



         The most important of  these errors deals with  the  EIS procedure for

         establishing design influent wastewater characteristics for  the City's

         Jackson Pike Wastewater Treatment  Plant, and results  in proposed treatment

         facilities which are obviously  and significantly undersized.  Therefore,

         all portions of the EIS regarding  the  facilities to be constructed at

         Jackson Pike must be considered inaccurate  and should be disregarded.

                                                           (4.1.97)
                                   IV-6 2

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                                                                      -63-
Specific Comments



    Page A-3     The EIS states  that  the  Southerly Plant  receives  flow from a




                 single 108-inch interceptor.   This  statement  is  incorrect.




                 The plant also  receives  flow  from the  156"  Interconnecting



                 Sewer.     (4.1.98)








    Page A-4     The EIS states  that  the  Facility Plan  was prepared  using




                 1973 and 197^ recorded plant  influent  data.   Only by coinci-




                 dence, did the  Solids  Handling Segmental Plan develop design




                 data that equaled 1974 plant  influent  data.   (4.1.99)








    Page A-6     The EIS states  that,  in  1972,  the City considered thermal




                 sludge conditioning  as "the panacea for  the solids  handling




                 and recirculation problems  that still  plague  the  (Jackson




                 Pike)  plant".   This  statement  is incorrect.   Thermal conditioning




                 was originally  installed at Jackson Pike on an experimental




                 basis  with the  expectation  that it  would aid  in  the dewatering




                 process.  The City was willing to try  technology  that was




                 relatively new  in the  U.S.  at  that  time.  The problems  that




                 still  plague  the plant are  probably due  to  the inadequate




                 solids handling and  disposal  capability.   (4.1.100)








    Page A-8     The EIS states  that  the  striking change  in  the Jackson  Pike




                 influent wastewater  quality over the last two years cannot be




                 attributed to the changes  in  the receipt of scavenger wastes




                 from the "night soil1  dump station  provided in 1971, and cites




                 this load as  20,000  to 30,000  gallons  per day.  Since this




                 section of the  EIS is  dealing  with  influent quality, not quantity,



                                   IV-6 3

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                                                                  -64-
             the EIS  should  have  cited  the  load  in  Ibs. per day of

             pollutants,  not in gallons  per day  of  flow.   (4.1.101)



Page A-8     The EIS  states  that  the  observed  1975-1976 change  in  influent

             quality  at Jackson Pike  was caused  by  recycle loads from the

             thermal  conditioning unit,  and that this  recycle  increased

             the measured influent 6005  and SS by 23%  and  k%%,  respectively.

             City sampling data  indicates that this recycle stream  contributed

             less than 10% to the measured  influent load  in 1976.   Actual

             1976 influent strengths  were probably  about  18% higher in BOD,-

             and 38%  higher  in SS than  those ci-ted  and used in  the  EIS as

             a basis  for design of the  required  facilities at Jackson Pike.

             Therefore, since the EIS procedure  for establishing design

             influent wastewater  characteristics for the  Jackson Pike Plant

             is based on false assumptions  and incorrect  data,  the  resultant

             EIS Jackson Pike facilities are obviously and significantly

             undersized, and all  portions of the EIS regarding  the  facilities

             to be constructed at Jackson Pike must be considered  inaccurate

             and therefore must be disregarded.   A  comparison of the  assumed

             EIS and  the actual  1976  data for Jackson  Pike is as follows:

                                  EIS 1976      Actual 1976     % Error
                               Influent  Data  Influent Data     in  EIS
                  BODc            210 mg/1          2*»8 mg/1      ^B%
                   SS             250 mg/1          3*»5 mg/1      38*


             For further back-up  information, see Attachment 2.

                                                      (4.1.102)
                               IV-6 4

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                                                                  -65-
Page A-9     Based on the data presented  in  the  preceeding  comment,  the




             EIS 1976 Estimated Influent  Characteristics  presented here




             are again significantly in error.   This  error  also  significantly




             effects the data and recommendations  in  Appendix  I  and  Appendix K




             of the EIS regarding the proposed facilites  at the  Jackson Pike




             Plant.                                   (4.1.103)
Page A-11    The EIS states that the low flow  reported  in  1971  for  the




             Southerly Plant was due to the  bypassing associated with




             expanding the plant's main treatment  capability.   This




             statement is believed to be inaccurate.  Expansion of  treatment




             facilities had little effect on by-passing  at Southerly during




             1971 through 1973.   The amount  of by-passing due  to the




             construction program would not  be noticed  in annual average




             flows.                                      (4.1.104)








Page A-11    The EIS states that continuous  recirculation of solids about




             the plant is caused primarily by  operational difficulties in the




             present conditioning and dewatering processes.  Inadequate solids




             handling and disposal  facilities  is probably more  responsible.




             Had USEPA approved  the City's grant application in 1975 for




             incineration and dewatering facilities, this situation would




             be essentially solved  at the present  time.   (4.1.105)
                               IV-65

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Page A-H    With  stated  capacities and  largest unit out-of-service,
             firm  pumping capacity at Jackson Pike should be only
             165 mgd.   EIS cited  blower  capacities are believed to be
             inaccurate.     (4.1.106)


Page A-15    Existing  Jackson Pike aeration  tank volume  is cited  incorrectly
             in the EIS.   Plant "A"  total  volume should  be 15 mg  and Plant
             "B" should be 10 mg. Although  this EIS error is only about
             5.2%, it  is  just as  or more significant than the reduced
             population projections used in  the EIS.     (4.1.107)


Page A-15    The areas of the existing final sedimentation tanks  at Jackson
             Pike  are  slightly overstated  in the EIS.  Plant "A"  should be
             72,000 s.f.  and Plant "B" should be 36,000  s.f.   (4.1.108)


Page A-15    The EIS states that, at Jackson Pike, Waste Activated Sludge
             is largely applied to three tanks.  This is false.  The existing
             tanks are make-shift converted tanks originally designed to
             handle only  about 1/3 of the  flow.    (4.1.108)


Page A-16    The existing supernatant aeration tank volume cited  here for
             Jackson Pike is incorrect.  Actual volume should be  5 mg•
                                           (4.1.109)

Page A-16    The three other tanks cited here were never used for aerated
             supernatant  sedimentation as  inferred by the EIS.
                                 IV-6 6

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                                                                  -67-
Page A-1?    The EIS states that,  at Jackson  Pike,  all  incinerator  scrubber




             water goes to the Scioto River.   This  statement  is  false,  as




             there are presently no scrubbers on the incinerators.








Page A-18    The EIS states that at the Southerly Plant,  no further expansion




             of the solids  handling and incineration system was thought  to




             be necessary by the City with the provision  of the  conditioning




             complex in June of 1976.  This statement is  absurd, completely




             false, and shows a lack of knowledge on the  part of the EIS




             authors about local concerns and problems.   The City's 1970




             report on expansion of the Southerly Plant proposed additional




             incineration capacity and possible additions to the dewatering




             complex.  Subsequent reports prepared in 1973 and 197A called




             for immediate construction of two additional incinerators  and




             nine additional dewatering units.  Construction  drawings and




             specifications for additional incinerators,  rehabilitation of




             existing incinerators, and additional  dewatering units were




             essentially complete in 197*»-  A grant application  for same




             was submitted to USEPA early in 1975.   Additions to the




             dewatering complex have already been approved by USEPA and are




             presently under construction.            '








Page A-19    The EIS states that historically the Southerly Plant has long




             been plagued by hydraulic problems.  This  statement is incorrect.




             The plant has experienced severe solids handling problems  since




             EPA refused to fund incinerators and dewatering  facilities in



             1975, as noted in the proceeding comment.     (4.1.111)




                                IV-6 7

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                                                                    -68-
Page A-19    The EIS  states  that  the  Southerly Plant has never fully

             achieved sustained,  stable performance, and cites the cause

             as one of unit  process  limitations with the "as  received1

             wastewater load.   This  statement  is believed to  be  incorrect.

             If the Southerly  Plant  has never  achieved  such performance,

             the cause is  probably attributable to  inadequate solids handling

             facilities,  not the  'as  received- wastewater load.  (4.1.112)


Page A-20    The data presented in the EIS  for the  existing Southerly

             aeration system is incorrect.  The tanks are presently operated

             in the step-aeration mode.   Step  feed  can  be accomplished at

             the 1A, 3/8, 1/2, 5/8  and 3A points  in the tanks, not as cited

             in the EIS.   Center  section  tank volume is 10 mg and west section

             tank volume  is  15 mg.   Two of  the tanks are not  used for aeration.
                                                    (4.1.113)

Page A-23    The EIS  states  that  operational problems have increased for the

             Southerly incinerators  due to  the introduction of thermally

             conditioned  sludge in 1976.  This problem  was probably due to

             the fact that the operators  were originally trying  to feed the

             incinerators  at the  same rate  as had been  done before with the

             wetter cake.   Of  more importance  is the fact that the incinerators

             are over 10 years old and need major rehabilitation and modification,

             As mentioned  previously, this  rehabilitation and modification was

             scheduled to  begin in 1975,  but the project has  been delayed

             pending  completion of the final EIS.       (4.1.114)
                                  IV-6 8

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                                                                  -69-
Page A-2 4
Page A-26    The EIS states  that,  at  Jackson  Pike  and Southerly, failure of

             high recorded effluent BODc  data to correlate with elevated

             recorded effluent  suspended  solids concentrations can be

             attributed to the  crudeness  of  the 6005 test  itself.  Why  is

             the BODr test suspect in this EIS discussion  and not  in other

             sections of the EIS  regarding recorded  influent wastewater

             characteristics?  Influent suspended  solids concentrations are

             even higher, and therefore, measured BODc data should  be less

             reliable suggesting  higher concentrations  than actually

             recorded.   (4.1.115)




Page A-26    The EIS has concluded that the  severe bulking problem at the

             Southerly Plant is caused by the brewery waste discharged from

             Anheuser-Busch. To  the  City's  knowledge,  no proof has ever

             been offered by anyone to substantiate  this statement.
                                                              (4.1.116)


Page A-28    The brewery waste  is  cited here  in the  EIS as *»0 to 60% of the

             nominal BOD^ load  at  the Southerly Plant.  This is not consistent

             with the 37% cited on Page A-2  of Appendix A of the EIS.

                                               (4.1.117)
                               IV-6 9

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                                                                         -70-
REVIEW OF
APPENDIX B.   MATHEMATICAL CHARACTERIZATION  OF  THE  SCIOTO  RIVER BELOW COLUMBUS

     General Comments

         One of the most important statements  in Appendix B  of the  EIS  is  found

         on Page B-1 and reads as  follows:
                      "Obviously,  any attempt at future  prediction
                      (of water quality conditions)  is  fraught with
                      difficulty and plagued with controversy.   In-
                      deed, the capability for mathematical  sophis-
                      tication via the computer far  exceeds  the
                      fundamental  knowledge needed to establish
                      reasonably correct input parameters.   The  reader
                      should remember that a mathematical model  gives
                      only correct relative results  with constant
                      input parameters.  Specific finite results are
                      a desired goal but are rarely  achievable."
         We would agree completely with this statement,  but would  wonder why the

         EIS then went on to present 2k pages of discussion and  calculations in an

         effort to establish required release levels  for the two Columbus Plants.

         In addition, the EIS models were not verified by meaningful  in-stream

         sampling.  The problems with the models are  compounded  by the use of

         assumptions which are themselves arguable.   Therefore,  the models and results

         obtained therefrom do not have credibility.



         The above quoted opening statement coupled with the lack  of sufficient and

         meaningful stream sampling and the use of questionable  assumptions are

         probably justifiable  reasons for deleting all  of Appendix B and disregarding

         any EIS decisions made based thereon.    (4.1.118)
                                      IV-70

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                                                                 -71-
Speci fIc Comments

    Page B-1
      thru
    Page B-2*»    For specific  comments on Appendix B, see Attachment	3_
                              IV-71

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                                                                            -72-
REVIEW OF
APPENDIX I.  REVIEW AND EVALUATION OF THE WASTEWATER TREATMENT PROCESSES  RECOMMENDED
             BY THE COLUMBUS FACILITIES  PLANS
     Specific Comtien t s

         Page 1-1     The EIS cites the population  projections  used  in  the  Facility

                      Plan.  It should be noted  that  the  projections us^d  in  the EIS

                      are only about 6% less  than  those used  in the  Facility  Plan.

                      Considering the accuracy of  such  predictions,  we  question  the

                      validity and necessity  of  the EIS using  projections  different

                      than those presented in the  City's  plans.     (4.1.123)



         Page 1-2     Table 1-2 lists the 1995 Influent Design  Flows and Loads used  in

                      the Solids Handling Facility  Plan Segments.  The  table  contains

                      several errors in the Jackson Pike  data as follows:

                         (1)    BOD5 should be 225  and 190 mg/1

                         (2)    SS should be 302  and 270 mg/1

                         (3)    Annual Secondary  Sludge  should be 175,300 Ibs/day

                                                                  (4.1.124

         Page 1-21    Table 1-10 of the EIS contains  the  following errors:

                         (1)    Facility Plan  decant facilities  for Jackson  Pike  were

                               proposed at 0.56  mg  and  3,825  sq. ft.

                         (2)    Facility Plan  decant facilities  for Southerly  were

                               proposed at 0.75  mg  and  5,100  sq. ft.

                         (3)    Proposed recycle  aeration  tank volumes in the  Facility

                               Plan were 5.0  mg  for Jackson Pike and 5.4 mg for  Southerly.

                               No sludge return  rate  was  specified.

                                                                (4.1.125)
                                         IV-7 2

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                                                                 -73-
Page 1-23    Table 1-11  of the EIS  contains  the  following errors:

                (1)    Southerly Facility  Plan  Contract Administration,

                      Fees and Contingencies Costs were  $5,100,000.

                (2)    Southerly Facility  Plan  Total  Construction Cost was

                      $31,400,000.

                (3)    Annual  0 6 M  costs  cited from  the  Facility Plan are

                      for year 1995 not  for  the  average  year  during  the

                      planning period as  stated.         (4.1.126)


Page \-2k    The EIS states that "two parameters are of  importance  in the

             design  of any wastewater treatment  installation:   influent

             wastewater characteristics,  and final effluent quality  objectives"

             We would insist  that of equal or  more importance  is a  third

             parameter known  as 'unit process  design and sizing1.   Proper

             or required unit process design and sizing  can probably be more

             accurately defined than future  influent wastewater characteristics

             or necessary effluent  quality.  This important third parameter

             can and should be used to effectively compensate  for errors in

             predicting influent conditions  and  final effluent quality

             objectives.  This EIS  statement coupled with the  EIS use of

             optimistic design criteria would  suggest that the authors of

             the EIS have neglected this  third and important  parameter.
                                                  (4.1.127)

Page 1-25    The EIS states that final effluent  quality  objectives are

             "given  (values)  defined by  the  NPDES permits".  This is true

             only if water quality  predictions and NPDES effluent limits

             have been verified by  meaningful  stream sampling  programs and

             computer models.  Without such  verification, imposed NPDES
                                IV-7 3

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                                                                 -74-
             final effluent  limitations are lacking in credibility.

             Evidently, USEPA agrees with this conclusion, as witnessed

             by  its  July  6,  1976 statement pertaining to the scope of work

             to  be performed by the EIS consultant under Contract No.

             68-01-4378 as follows:

                 "As  a part of the liquid treatment alternatives,
                 detailed water quality modeling shall be performed
                 for  the Scioto River to determine: (1) what the
                 appropriate Water Quality Standards for the Scioto
                 River should be and  (2) the design parameters of
                 Southerly  and Jackson Pike STP's necessary to meet
                 those Water Quality Standards."

             At  this particular point  in time, it is questionable  if final

             effluent  quality objectives are, in fact, a given parameter.

                                                  (4.1.128)

Page 1-25    The authors  state that the EIS 85 mgd average design  flow for

             the Southerly Plant could substantially increase if a combined

             overflow  pollution abatement program is undertaken on the

             Southerly collection system and treatment works.  However, the

             EIS neglects this possibility in its actual design of facilities

             for the Southerly Plant.     (4.1.129)



Page 1-25    The EIS presents a formula for developing process peaks at the

             two Columbus wastewater  treatment plants, and then uses the

             relationship for design  of the required facilities.   The validity

             of  this formula is questionable, and, therefore, some rationale

             for its use  should be presented and verified.   (4.1.130)
                                IV-74

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                                                                  -75-
Page 1-26    Assuming that  the  use  of  the  EIS process peak formula  can




             be justified by USEPA, the  EIS  Southerly design process peak




             flow should be 135 mgd, riot 130 mgd.  The  EIS appears to




             consistently round off calculated  figures  in a manner that




             results in smaller unit process sizing,  less required facilities,




             and therefore fewer dollars.  Such consistent practice can




             compound errors and significantly  effect results.  (4.1.131)








Page 1-27    The EIS states that the existing conduit hydraulic capacity




             at Southerly is 230 mgd.  This  statement is highly questionable.




             The City's consultants believe  that extensive modifications may




             be necessary in order  to  hydraulicly  handle 230 mgd.  Also,  the




             EIS uses an  existing  hydraulic capacity of 200 mgd for Jackson




             Pike.  This figure may also be  excessive and needs to be



             verified.   (4.1.132)









Page 1-27    The EIS states that "an approximation of the future influent




             wastewater characteristics  (for Jackson Pike) can be developed



             from the 'knowns1  of today".  The  City requests a definition




             of these so-called 'knowns1,  and,  a justification by the EIS




             authors as to why  these 'knowns1,  whatever they are, can be




             considered as  'knowns1.  (4.1.133)








Page 1-28    Table 1-13 develops the future  Jackson Pike Influent Character-




             istics  used in the EIS for  design  of plant facilities.  As




             pointed out in the comments on  Appendix A, the predictions are
                               IV-7 5

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                                                                   -76-
             based on  erroneous data and assumptions.  Using the same methodology
             as used  in  the  EIS, year  1995 - 2000  influent design character-
             istics for  Jackson Pike should be approximately 250,000  Ibs/day,
             or 270 mg/1,  for  8005 and about 335,000  Ibs/day, or 365 mg/1,
             for SS.   Since  the figures  in Table  1-13 are obviously wrong,
             all EIS  proposals regarding the required Jackson Pike facilities
             must be  considered as  inadequate and  therefore disregarded.
                                                     (4.1.134)

Page 1-30    The EIS  states  that the  lower value  for  SS developed in Table
             1-13 is  believed  to be more nearly correct than the value used
             in the Facility Plan.  Based on the  preceeding comments on
             Appendix  A, we  would disagree.  If the same EIS methodology  is
             used and  Table  1-13 is corrected for  the wrong assumption
             made in regard  to recycle  loads, the  EIS influent design
             parameters  will be significantly higher  than those used  in the
             Facility  Plan.  We wonder whose values will then be assumed  to
             be "more  nearly correct"  by the EIS  authors.  (4.1.135)

Page 1-32    The EIS  cites proposed USEPA Guidelines which allow future
             unforeseen  industrial  load  to be eligible for grant funding
             if it is  cost-effective.  This guideline was used as a basis
             for increasing  future  industrial influent BOD^ and SS by
             15,000 Ibs/day.  We do not  disagree with the appropriateness
             of these  increases, but  the EIS did  not  demonstrate the
             cost-effectiveness of  such  allowances, as required, in the
             cited guidelines.     (4.1.136)
                                IV-7 6

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                                                                  -77-
Page 1-33    The EIS  states  that  the  brewery has made an  Informal




             commitment to the City  to  keep  its untreated waste BOD^ load




             below 60,000 Ibs/day.  This  agreement was not  informal.  The




             limitation was  imposed on  the brewery by the City under the




             authority of its  existing  ordinances.    (4.1.137)









Page 1-33    The EIS  suggests  that  the  influent mass  loadings developed




             for the  Southerly Plant  in the  EIS are more  correct  than those




             presented in the  Facility  Plan, due  to the fact that the Facility




             Plan used higher  influent  flows,  and conditioned on  a brewery




             release  of no more than  60,000  Ibs/day BOD,-.   As pointed out




             earlier  in the EIS,  the  lower design flow is only applicable if




             no combined overflow pollution  abatement program is  developed




             for the  Southerly system.   If such a program is initiated, the




             Facility Plan design characteristics may be more nearly correct.




             The EIS  should  account  for such a possibility.  (4.1.138)









Page \~3^    Table 1-15 for  the Jackson Pike Plant is incorrect because of




             the errors in Appendix A in  the development of the influent




             wastewater characteristics.  See  comments on Appendix A and




             previous comments on Appendix I.  (4.1.139)









Page 1-36    The EIS  estimates the volatile  fraction of the influent suspended




             solids for Jackson Pike  and  Southerly at 70% and 80%, respectively,




             and suggests that these  values are more correct than the Facility




             Plan Segment estimates.  The EIS  should justify use of its




             estimates.   (4.1.140)




                                IV-7 7

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                                                                  -78-
Page 1-36    The EIS states  that  the "upstream attached growth  reactor at

             Southerly can be considered  as mandatory as  long as  the  highly

             soluble carbohydrate wastes  from the  brewery significantly

             impact the plant's  influent  pollutant load".  At this  stage

             in the development  of the  EIS, the  brewery 8005  load is  60,000

             Ibs/day, or 23% of  the EIS average  design BOD^ load.  However,

             later in the EIS, after development of the final recommended

             treatment facilities in Appendix K  which eliminates  upstream

             attached growth reactors,  the brewery BODj load  is still  19%

             of the Southerly average design conditions.   This  load is still

             significant, and therefore,  in conformance with  the  EIS  stated

             philosophy, upstream attached growth  reactors should still be

             considered as 'mandatory1  at the Southerly site.   This would be

             especially true during periods of inefficient operation  or upsets

             at the proposed brewery sewage treatment plant which could

             continue for extended periods of time.  Also, the  EIS  recommends

             two stage treatment  at Jackson Pike because  of its critical

             position on the receiving  stream and  because such  a  system has

             the greatest potential for ease of  nitrification kinetics and

             production of an effluent  free of ammonium.   The City  believes

             that these reasons  are equally applicable to the Southerly

             Plant, and that pretreatment at the brewery  does not,  in fact,

             eliminate the need  for two-stage treatment,  nor will it  result

             in significant  cost  savings  as stated in the EIS.  This  is

             particularly true since, in  addition  to the  brewery  load, the

             final EIS recommended plan still requires full treatment of all

             other industrial, commercial and domestic loads  to be  accomplished

             at the Southerly site.       (4.1.141)
                                 IV-7 8

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                                                                  -79-
Page 1-38    The EIS states that "alternatives for obtaining  an autogenous

             cake other than thermal  conditioning were not evaluated (in

             the Facility Plan)".  This statement is true as  there were no

             other proven alternatives available when the Facility Plan

             Segments were prepared and because it was and is not

             cost-effective to discard the City's recent multi-million

             dollar investment.


Page 1-^0    The EIS suggests that dissolved air flotation thickening  was

             rejected in the Facility Plan at Jackson Pike based on unfavorable

             past experience at both plants.  Other factors such as chemical

             usage, solids capture and product dry solids content were of

             more importance in the Facility Plan selection of centrifugal

             thickening at Jackson Pike.   This concept and selection has

             already been approved by USEPA.  Dissolved air flotation  was

             retained in the Facility Plan at Southerly due to the City's

             recent investment in this process.  The City's proposed solids

             management system for the Southerly Plant has been subsequently

             conceptually revised and approved by USEPA in November of 1976.

             Centrifugal thickening is now to be used for expansion of the

             Southerly facilities.  The EIS authors should be aware of these

             revisions and USEPA approvals, and should have considered same

             in formulating the EIS document.   (4.1.142)


Page 1-^0    The EIS technique used for evaluation of the proposed  project

             plan incorporated the designed wastewater characteristics

             established in Table 1-15.   Since it has already been  shown

             that portions of Table 1-15  are incorrect,  it  follows  that
                                IV-7 9

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                                                                  -80-
             many  portions of  the EIS evaluation of the proposed project

             plan  must  also be considered as incorrect.


Page 1-40    Figure 1-2 shows  the ash decant in the Facility Plan as

             overflowing to the Scioto River.  This is incorrect.  The

             Facility Plan proposed  to return this decant to the liquid

             treatment  section of the plant.   (4.1.143)


Page 1-41    The figure quoted from  the  Facility Plan for Waste Solids

             Management Costs  at Southerly should be $31.4 million.
                                                 (4.1.144)

Page 1-42    Ash lagoon overflow returned to the plant influent in the EIS

             is not a deviation from the Facility Plan proposals.  However,

             this  overflow may be more appropriately returned to other

             downstream processes.   (4.1.145)


Page 1-42    The EIS states that the design equilibrium pollutant quantities

             were  established  in the EIS through mass balance concepts at

             each  unit  process, and  presents the results of these evaluations.

             Where is the presentation of the EIS mass balance concepts for

             each  unit  process?  Calculations and criteria should be presented

             in the EIS, not just the results.  (4.1.146)


Page 1-42    The EIS uses the  phrase "several potential opportunities for

             capital savings were found" during the EIS engineering evaluation

             of the Facility Plan proposals.  The word "potential" seems to

             have been  lost or forgotten between this EIS evaluation

             and the final EIS recommendations.
                                IV-80

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                                                                   -81-
Page I-*»2    The EIS states  that  it  appears  that  savings at Jackson Pike



             can result from the  EIS proposals due  to  the backup provided by




             storage in the  existing anaerobic digesters and the interconnecting




             sludge force main.   However,  little  or no costs have  been




             included in the EIS  proposals  for modifications to these digesters




             or for the pumping  stations  required to make the  sludge force




             main operational.   No wonder  it appears that cost savings can




             be realized. Again  the word  'appears1  seems to have  been lost




             or forgotten by the  time the  EIS makes its final  decisions and



             recommendations.           (4.1.147)








Page 1-^2    The EIS devotes considerable  space and expense throughout the




             document in discussing  anaerobic digestion of recycle solids.




             It is unfortunate  that  the authors of  the EIS were not aware




             or did not recognize the City's present program,  initiated




             prior to preparation of the  EIS, to  investigate anaerobic




             digestion and other  recycle management  alternatives.  Perhaps




             some communication with the  City prior to and during  preparation



             of the EIS would have been appropriate.   (4.1.148)








Page 1-^3    The EIS proposes about  a 50%  reduction in the trickling filter



             installation at Jackson Pike.   This  reduction is  believed to




             be unrealistic, and  will  effect downstream processes  significantly.




             The EIS also uses an oxygen  transfer efficiency of 8%.  It




             should be noted that a  small  change  in  this assumed design




             efficiency will significantly  affect air  requirements. (4.1.149)
                                IV-81

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                                                                  -82-
Page I-Ml    The EIS  uses  a  secondary waste sludge concentration of 1% as
             the basis of  design  for downstream solids processing facilities
             at Jackson Pike.  Although  this concentration  is attainable, it
             may be optimistic for  design purposes.  3A% sludge, which is
             more realistic, would  require at  least 3 more  thickening units.
                                               (4.1.150)

Page 1-45    The EIS  suggests  that, at Jackson Pike, standby equipment
             auxiliaries for the  thermal conditioning process may be a more
             economical option than a new unit.  Operating  experience would
             indicate that heat exchangers and reactors also can be
             out-of-service for extended periods of time and therefore
             require  standby capability.  The  EIS proposes  to store sludge or
             route it directly to dewatering in the event of a heat exchanger
             break-down.  If such an alternative is followed, either huge
             storage  facilities or  several additional dewatering units must
             be provided.   Storage  of thermally conditioned sludge may be
             technically non-feasible due to its expected effect on
             dewaterability.     (4.1.151)


Page \-k$    The EIS  suggests  that  proposed recycle treatment facilities
             for Jackson Pike can be abandoned due to excess main stream
             treatment capacity.  First, where are these excess main stream
             treatment facilities;  and  second, direct return of recycles to
             main treatment units has historically proven to be a problem
             throughout the country.  This suggestion would appear to be a step
             or two backward in modern technology and good  engineering practice,
             and would be another reason to question the overall treatment
             efficiencies of the  EIS proposals.    (4.1.152)
                               IV-8 2

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                                                                   -83-
Page l-i»7
  thru
Page 1-49    Many of the proceeding  comments  for Jackson Pike are

             applicable to the EIS proposals  presented for the Southerly

             Plant.
                                IV-8 3

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                                                                   -84-
REVIEW OF
APPENDIX J.  INTERNAL UNIT PROCESS ALTERNATIVES
     Specific Commen ts
     Page J-]  As stated in the EIS,  the  Facility  Plans  for  the  Columbus
               Plants did recommend the use of centrifuges and dissolved
               air flotation for waste secondary solids  thickening  at  Jackson
               Pike and Southerly,  respectively.   The  reasons for these
               selections were discussed  in previous comments on Appendix  I.
               The proposed Southerly facilities were  revised in 1976  to
               provide centrifuges  for any necessary expansion.  These
               concepts have already  been approved by  U.S.E.P.A. (Also
               see previous comments  on Appendix  I).   It is  not  "equally
               certain that dissolved air flotation offers savings  in  terms
               of 0 & M expenditures" as  stated  in the EIS.  k%  versus 5%
               or 6% solids to downstream processes will  significantly
               increase 0 & M and capital costs of same.  DAF will  have
               major problems matching the solids  capture and content
               of centrifuges even with  large amounts  of chemical additives.
               Centrifuges should require little or no chemicals.   Since
               U.S.E.P.A. has already approved centrifuges for  installation
               at both Jackson Pike and Southerly, we  feel that  this  re-hashing
               of alternatives is inappropriate.   (4.1.153)

     Page J-2  This portion of the EIS suggests  that the City should evaluate
               the following alternatives:
               1.  Belt-presses for sludge dewatering;
               2.  Prototype chemical sludge  conditioning; and,
               3.  Abandonment of thermal conditioning.
               Several comments are in order. First,  belt press trials
               have been conducted at the Southerly Plant.   These trials
               have indicated 0 & M problems. Large doses of chemicals
               are required to achieve the same solids content as centrifuges.
               Second, ferric chloride conditioning, as  suggested in  the
               EIS, is unthinkable with high-pressure  induced draft fans
               on incinerators.  Third, abandonment of the existing thermal
               conditioning process is not cost-effective at the present
               time, but is always a  future option. And, last,  it  is  highly
                                IV-8 4

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                                                                  -85-
          improbable that these EIS  suggestions  would  have  none of  the
          recycle management problems found with thermal  conditioning, as
          stated in the EIS.         (4.1.54)

Page J-*»  The EIS cites the results  of California investigations  on
          anaerobic digestion of thermal  conditioning  products.   We
          do not believe that these  investigations  proved that "the
          dewaterability of the solids remains only marginally  less
          than the undigested thermally conditioned product".  Columbus
          experience indicates that  the cooler sludge  may have significantly
          different dewaterabi1ity properties.   Also the  studies  are  not
          believed to have addressed the effect  of  decreased  volatile
          content on incineration efficiencies and  auxiliary  fuel
          requirements.  These and other effects must  be  fully evaluated
          prior to recommending this anaerobic process.

          The EIS states that Table  J-l  summarizes  the results of a
          hypothetical  examination of each  recycle  management alternative.
          The use of the word "hypothetical"  is  appropriate,  and  the
          entire presentation on recycle management must  be considered
          as such.  A simple statement of concurrence  with  the City's
          present studies on recycle management  would  have  sufficed,  and
          eliminated many pages of discussion on hypothetical alternatives.
          This would have allowed the EIS to  devote more  time on  issues
          which U.S.E.P.A. feels are still  unresolved.  (4.1.55)

          The flow diagrams for alternatives  B2  and Cl are  believed
          to be incorrect.                             (4.1.56)

Page J-9  The EIS discusses the Contra Costa  Sanitary  District project
          on pyrolysis.  Since we believe this project involved a
          combination sludge-garbage waste  application, mostly garbage,
          its direct applicability to pyrolysis  of  sewage sludge  is
          questionable.         (4 1.157)
                               IV-8 5

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                                                                  -86-
Page J-10  The EIS  states  that "starved air combustion cannot be recommended
           for Columbus  except on an experimental basis", and then continues
           on to say  that  "the starved air conbustion furnace also be
           designed with a view  towards conventional incineration".  More
           appropriately,  we would  suggest that  the proposed conventional
           incineration  facilities  be designed with a view toward starved
           air combustion.            (4.1.158)

Page J-ll  The EIS  discussion on phosphorus removal is a duplication
           of Facility Planning  efforts.  (4.1.159)

Page J-12  The EIS  discussion on intermediate sedimentation is a
           duplication of  Facility  Planning efforts.

Page J-16  The EIS  mentions one  particular manufacturer of one air
           system.  The  EIS should  not have used one manufacturer's
           name unless it  also mentioned  names for the other systems
           discussed.    (4.1.160)

Page J-17  The EIS  recommends evaluation  of  just one aeration system.   Several
           systems  need  to be evaluated,  not just one.  The document
           also states that the  final EIS will consider the results of
           such an  evaluation in the selection of a proposed dissolution
           system,  and that jet  aeration  be given a detailed evaluation
           by the design consultant that  prepares the plant improvements.
           We agree that this evaluation  is a Step 2 process, either as
           an engineering  report task or  as a part of the value engineering
           process, not  as a Step  I  EIS function.  However, if the
           final EIS  is  to consider the results  of these evaluations,
           it would appear  that  the EIS  will  not  be  final  for quite some time.

           The City does not agree  with several  of these EIS conclusions:
           First, re-review of the  cost effectiveness of dissolved air
           flotation  in  detail is not considered necessary, especially
           since U.S.E.P.A. has  already approved centrifuges; second,
           recent investigative  efforts have not suggested that anaerobic
                                IV-8 6

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                                                           -87-
digestion of thermally conditioned  products  is  the most
effective means of recycle management,  but  rather suggest  that
It might be an effective alternative.   It  is  premature to
recommend this system for the Columbus  Plants,  as it must  still
be considered as unproven technology.   Third, the inference
is that the EIS has eliminated intermediate  settling at
Southerly at this stage of development  of  the recommended
project plan without brewery pretreatment.   This  is not
consistent with Pages J-12 and J-lA.  Fourth, the EIS should
recommend testing of several aeration systems,  not just  one.
Fifth, since the jet aeration system  is presently energy
intensive, the EIS recommendations  would seem to  imply that
the City should install such a system with  the  hopes that
electrical costs will increase.   And  last,  the  EIS conclusions
and statements regarding air system evaluation  would seem  to
infer that the final EIS will be completed  during the Step
2 design phase and that the final EIS will  select the air
system.  This is not an EIS task!
                                     (4.1.161)
                        IV-8 7

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                                                                      -88-
REVIEW OF
APPENDIX K.  DESIGN QUANTITIES  AND UNIT PROCESS  SIZING  FOR  THE  RECOMMENDED
             TREATMENT FACILITIES

    Specific Comments

        Page K-1     The EIS proposes  to process  only  waste  activated  sludge in

                    the Jackson Pike  thermal  conditioning facility.   Dewaterability

                    of this sludge after anaerobic  digestion  must  be  determined

                    prior to making this recommendation.  The dewaterabi1ity of

                    straight thermally conditioned  waste secondary sludge is known

                    to be considerably less  than the  dewaterabi1ity of  a  mixed

                    thermally conditioned sludge.     (4.1.162)



        Page K-2    The EIS Recommended Project  Plan  Design Conditions  in Table

                    K-1 are incorrect for Jackson Pike  and  have not been  justified

                    for the Southerly Plant.   The Jackson Pike  conditions are

                    incorrect because of the  errors made  in Appendix  A  (See

                    previous comments on Appendix A). The Southerly conditions

                    have not been  justified  since the EIS did not  address the

                    environmental  impacts of  constructing and operating a Sewage

                    Treatment Plant at the Brewery  site, and  therefore, pretreatment

                    at the brewery cannot be  considered as  the  most cost  effective

                    alternative.  Since Appendix K  deals only with expansion of

                    the two treatment plants, this  entire EIS appendix  must be

                    considered  as  inaccurate, inconclusive, incomplete  and  in-

                    appropriate, and  must be  disregarded.   It follows that  all

                    EIS proposals  regarding  expansions  of the Jackson Pike  and

                    Southerly Plants  must also be discounted  and disregarded.

                                                              (4.1.163)

                                   IV-8 8

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                                                                  -89-
            THE FOLLOWING COMMENTS  IN  REGARD  TO  APPENDIX  K ARE OFFERED

            FOR INFORMATIVE PURPOSES ONLY.  THEY ARE NOT  TO BE CONSTRUED

            AS CITY ENDORSEMENT OF  THE EIS  RECOMMENDED  TREATMENT FACILITIES

            OR PROJECT PLAN.



Page K-2    Table K-2 in the EIS is based on  removal efficiencies,  many of

            which are believed to be over optimistic, especially in view

            of the unit process design parameters used  elsewhere in the

            EIS.  For instance, Primary BODr  removals,  particularly at

            Southerly, may be overstated in view of the high soluble content

            from the brewery discharge and  from  the returned recycle

            stream without separate treatment.   Primary solids removals

            are also believed to be excessive.   All stated removal

            efficiencies may significantly  decrease during EIS maximum

            peak loads of 1.9 times annual  averages and during EIS  peak

            flows of 1.8 to 2.7 times  average flows at  Jackson Pike and

            Southerly, respectively.  These peaking factors coupled with

            the EIS required removal efficiencies and the EIS unit  process

            design parameters are likely to cause excessive overloading of

            downstream treatment facilities and  subsequent severe deterioi—

            ation of effluent and river water quality.   For additional

            back-up information, see Attachment  4.   (4.1.164)



Page K-3 &  The EIS sludge process  stream characteristics shown here and
Page K-4
            used for design of the  solids handling facilities at the Columbus

            Plants leads to some serious questions regarding the EIS

            recommended project plan.   In general, the  information  is sketchy

                                IV-8 9

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                                                            -90-

and therefore one must speculate somewhat as to the design
parameters used for the various unit processes proposed.
The authors of the EIS should submit and furnish all calculations,
design parameters, influent solids, solids captures and other
data used to prepare this table.  However, the following comments
can be made at this time.  First, there is an obvious
100,000 Ibs/day dry solids error in the Jackson Pike Minimum
Maximum Day data for secondary solids.  Second, 8% digested
sludge dry solids content is probably speculative and may not
be attainable on a continuous basis.  Third, 1% dry solids
concentration for secondary sludge,  although attainable, is
optimistic for design purposes.   Fourth,  35% to 36% solids capture
for design of secondary sludge dewatering units and 32% solids
capture for design of Primary Solids dewatering units  are probably
attainable some of the time, with significant chemical
expenditures, but are highly speculative for design purposes.
Fifth,  it  is probable that the dry  solids content of the
dewatered  sludge coupled with the volatile destruction  in the
anaerobic  digesters will not achieve autogenous combustion  in
the  incinerators.  In addition,  incineration capacities will
be reduced by the wetter cake.  And last, the EIS proposals
require storage of sludges prior to dewatering during periods
of above average conditions.  Storage times can be as much  as
15 to  16 days for primary sludge and 10 to  15 days for  secondary
sludges after thermal conditioning  and anaerobic digestion.
City experience would  indicate that this EIS proposal may result
in odor and dewaterabi1ity problems, and until such problems are
solved or  proven to be non-existent by the  EIS authors, this
recommendation cannot be seriously  considered.  If this EIS
                          IV-90

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                                                                  -91-
            process  scheme is  shown  to be  inappropriate,  then  additional




            dewatering and incineration units  must  be  provided at  both




            plants.   Historically, across  the  country,  inadequate  and




            improperly designed  solids handling  and disposal facilities,




            lacking  the capability of disposal on a day-to-day basis,




            have caused severe problems and  decreases  in  the overall  treat-




            ment efficiencies  of many plants.  Solids  handling and disposal




            has been neglected too  long and  it is believed  that the EIS




            proposals will likely promote  continuance  of  these historic




            trends.   The EIS proposed solids handling  and disposal  facilities




            at both  plants are believed to be  undersized,  inadequate  and




            lacking  in the day-to-day and  standby capacity  necessary  for



            continuous, dependable operation.     (4.1.165)








Page K-5    The EIS  again suggests  that the  existing Jackson Pike  facilities




            are rated at 200 mgd.  The City  questions  the accuracy of this



            statement.   (4.1.166)








            The EIS  states that  rehabilitation of the  four  existing primary




            sedimentation tanks  at Jackson Pike  "is not a strong requirement




            for successful wastewater treatment".  With the EIS removal




            efficiencies listed  on Page K.-2  and  the unit  process design




            parameters used, rehabilitation  of the  tanks  may be absolutely




            necessary.  The Facility Plan  recommended  complete replacement




            of these tanks as  they are over  40 years old  and probably




            beyond rehabilitation and modernization.
                               IV-91

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                                                                  -92-

Page K-8    The EIS recommends  a  45% reduction  In  the  size  of the Jackson

            Pike first-stage trickling  filter  installation  on the basis  of

            the Facility Plan organic loading  rates for the Southerly Plant.

            Such rationale is believed  to be tenuous grounds for such a

            decrease.   Hydraulic  loading rates  are nearly doubled over that

            proposed in the Facility Plan.   At  EIS peak flow, the hydraulic

            loading rate is 3.64  gpm/sf.  At EIS peak  mass  loadings,  BODjj

            load will  be 325 lbs/1000 cf.-day.   Both rates  would appear

            high, and  could be anticipated to  cause overloading of downstream

            facilities.  In any event,  EIS trickling filter removal efficiencies

            will be less than the Facility Plan proposals causing significant

            increases  in power costs for the subsequent treatment processes.

            It is probably more cost-effective  to provide larger trickling

            filters.



            The EIS proposes a 5% increase in  the size of the Jackson Pike

            Intermediate Settling Tank area.  Did the  EIS include additional

            costs for  this increase?    (4.1.167)



Page K-ll   The EIS proposes surface overflow  rates for secondary settling

            tanks considerably in excess of normal practice, acceptable

            Ohio EPA standards, and USEPA design manuals.  EIS average

            overflow rates at Jackson Pike are 36% to 445% higher than Agency

            standards.  EIS peak overflow rates at Jackson Pike are 44% to

            116% higher than Agency standards.   Similar statements can be

            made about EIS Southerly overflow  rates.   EIS peak overflow

            rates are  also two times the acceptable or allowable proposed

            Ohio EPA standards.  These EIS design parameters will likely

            result in  severe degradation of plant  effluent  and Scioto River
                                IV-9 2

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                                                                  -93-

            water quality standards.   For  sure,  this  E1S  design  will  save
            initial  capital  costs,  but,  equally  sure,  such  dollar  savings
            will  be  at the expense  of the  objectives  of Public Law 92-500.
            For additional  back-up  data, see Attachment 5.
                                        (4.1.168)
Page K-12   The EIS  states that  "it is believed  (by the authors)  that Jackson
            Pike can maintain a  suitable performance  with the  	
            higher surface overflow rate,  and deviation from the conventional
            standards is strongly recommended".   The  City would  suggest  that
            the EIS  authors had  better be  "sure" instead  of just "believing"
            that such suitable performance levels can,  in fact,  be
            maintained with these high overflow  rates.    (4.1.169)

Page K-13   The EIS  again discusses secondary solids  thickening,  and  states
            that the Facility Plan  provides approximately three  times the
            average  day requirement at Jackson Pike.   First, since USEPA
            has already approved the City's concept,  this discussion  is
            probably inappropriate.  And second, the  Jackson Pike  Facility
            Plan does not provide three times the required  number  of
            centrifuges, especially in light of  the errors  in  the  EIS
            regarding influent wastewater  characteristics.

Page K-14   The EIS  project plan calls for anaerobic  solids destruction
            of recycles at both  plants.  As stated previously,  it  is  premature
            to make  this decision,  since the process  must still  be considered
            as unproven technology.  Full  scale  pilot testing must be
            conducted and the results analysed to determine the  full  effect
            and net  efficiencies of such a system prior to  inclusion  in  any
            Columbus treatment scenario.
                                IV-9 3

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                                                                 -94-
Page K-15   The EIS  uses  assumed  peaking  factors  for waste solids production
            in the design of  solids  handling and  disposal facilities.  The
            authors  should present some justification for the use of these
            assumed  values.   (4.1.170)


Page K-16   The EIS  states that,  under the  Facility Plan proposal,  neither
            plant would ever  realize its  maximum  incineration potential due
            to the fact that  the  plant's  dewatering capability  did  not match
            the rated maximum sol ids loading capacity of the  incinerators.
            This statement is false. All unit  processes in the Facility
            Plan were designed  on the basis of  solids productions.  There-
            fore, maximum incineration potential  was not limited by dewatering
            capability but rather, and more  appropriately, by actual plant
            solids productions.       (4.1.171)


Page K-17   In Table K-5, the average dry solids  content of the sludges to
            incineration  is 32% to 34%.   It is  doubtful that the EIS process
            schemes  will  yield  these contents,  Centrifuging  of 3% to 5%
            primary solids and  8% to 3%  secondary solids will probably yield
            a maximum of  25% dry  solids  to  the  incinerators.  Average dry
            solids may be less.   This will  require considerable auxilliary
            fuel in the  incinerators and significantly  derate the
            incineration  capacity.    (4.1.172)


            Table K~5 shows diversion of 50,000 Ibs/day of solids  from Jackson
            Pike to Southerly via the interconnecting sludge  fprce  main,
            In order to transport these  solids,  flows in the force  main
            must be about kJQ gpm at approximately 0.9% dry solids, not
            105 gpm at k%> as proposed in  the. EIS.  The  EIS allows
                                IV-9 4

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                                                                  -95-
            kO gpm in additional  dewatering capacity to. handle
            this  load.   The EIS  is  either concentrating these  diverted  solids

            from  0.9% to over 10% somewhere at  the Southerly Plant  prior to

            dewatering,  or  is suggesting  that the  force ma,in can  be operated

            at velocities in the  range of 1A ft./sec.  if  these solids  are

            put into the primary  tanks aiad come out as  primary solids,  either

            2 to  3 more dewatering  units  must be added  or  1 more  heat

            treatment unit  will  be  required.   If they come  to  the system at

            0.9%  solids, 3  more  concentration centrifuges  and  1 more heat

            treatment unit  will  be  required.


            The EIS authors should  furnish a detailed diagram  with  calculations

            showing the entire sludge processing system at  both plants  and

            the design parameters used.


Page K-18   The City does not agree with  the EIS concepts  and  proposals for

            solids handling and  disposal.  First,  construction of pumping

            stations for the sludge force main  is  less  cost-effective and

            has higher O&M  problems than  additional incineration.  Second,

            the long term potential of applying dewatered  thermally conditioned

            solids to strip mined land is not believed  to  be as great as

            suggested in the EIS.  The City has been studying  this  alterna-

            tive  for about  a year.   Third, using the dry solids figures in

            the EIS and correcting  for the attainable dry  solids  content of

            the dewatered cake,  4 incinerators  will be  required at  both

            Southerly and Jackson Pike.  Fourth, it is  inappropriate for

            the EIS to consider  installation of the new dewatering  centri-

            fuges in the existing vacuum  filter building.   Construction of
                                IV-9 5

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                                                            -96-
a new building housing  six centrifuges  has already  been




funded by USEPA and is  presently  under  construction.   Fifth,




it is doubtful that the water  plant  solids disposal quarry will




be available for use for incinerator ash  disposal.   Its



entire capacity is needed  for  water  plant solids, and  OEPA




will  not approve its use for codisposal of  incinerator ash.




And last, it is unlikely that  the EIS proposal with their signif-




icantly reduced facilities will  permit  reprocessing of the




solids from the existing Jackson  Pike lagoon.



                                  (4.1.73)
                          IV-9 6

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                                                                    -97-
                            SUMMAT10N




In summary,  several  important  points must be reiterated:




1.  The EIS  has been prepared  without input from the City of Columbus.   The




    City has had no input to the EIS decision making process.   USEPA has been




    reluctant to communicate.









2.  USEPA has not cooperated with the City of Columbus in its requests for the




    original Booz, Allen and. Hamilton and the Havens and  Emerson EIS reports.









3.  USEPA has no reason or authority to design facilities as a part of the




    EIS process.









k.  USEPA's  inappropriately included design criteria is inconsistent with its




    own published standards, is unapprovable by QEPA, and is unacceptable to both




    the City and the City's consultants.   If such  design  criteria remain in the




    EIS and  are thereby imposed on the City of Columbus,  two important questions




    must be  answered.  First,  who will be responsible for design of the




    facilities, and second, who will have final responsibility for the resultant




    treatment facilities meeting NPDES permit requirements.   Hopefully, these




    issues will not require resolution in the courts.









5.  The EIS  document does not address the environmental impacts of many of its




    own controversial and questionable proposals.








6.  The EIS  seems to be an attempt to stymie area  growth  by providing inadequate




    sewers,  inadequate facilities, and delayed construction schedules.   In




    addition it appears to attempt to justify its  preparation by presenting
                                 IV-9 7

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                                                                  -98-
fictitious cost savings at the expense of planning area water quality.








In the guise of an "Environmental  Impact  Statement" this  document attempts




to dictate every aspect of Columbus'  pollution  abatement  program for the




next 20 years.   The Federal  Government  is dictating what  sewers  can be




constructed, when, and what  size.   They have decided what wastewater




treatment processes can be constructed, their size and what  flows and




loads they must treat.  They further  dictate what effluent limits these




facilities must meet and provide criminal penalties with  fines of $25,000




per day for any violation.  These fines will  have to be paid by  the users




of the system.   The City has not been permitted to participate in the




development of  any of these decisions.   The only role left for the City




of Columbus in  this whole process is  the operation of the facilities, and




since the Federally designed facilities when constructed  will  not meet




their own limits, we suggest that USEPA also assume the operation of




these facilities.  The City of Columbus wi11  not accept responsibility



for operating inadequate facilities and incurring severe  fines as a result.








In conclusion,  the City intends to challenge these USEPA  decisions and




will strongly urge adoption of  itsoriginal  Facility Plan.  The  project




delays caused to date by the Federal  EIS have already cost the taxpayers




an additional 30 million dollars.  The taxpayers of this  community do not




need to be further burdened with additional  unnecessary delays and the




associated increased cost and adverse environmental impacts.
                                IV-9 8

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                                                                        -99-
                                  ATTACHMENT 1


Hearing before the subcommittee on investigations and review of the committee on

Public Works and Transportation:
                                    Congress
                               2nd Session
                               September 21, 1976

The above subcommittee investigation related that the New York Region of EPA in

April, 1975, prepared a general report on the cost of sewer construction versus

the size of pipe.  With the results of their analysis, they said "it is cost

effective to build interceptors that are sized to handle ultimate flows."



Recommended standards for Sewage Works-Great Lakes-Upper Mississippi River Board

of State Sanitary Engineers - 1971 Revised Edition:  Design Period "In general,

sewer systems should be designed for the estimated ultimate tributary population,

except in considering parts of the systems that can be readily increased in capacity."



The statement by USEPA that the EIS solutions will save the City money is completely

erroneous and misleading.  The sewers proposed do not meet the tributary area total

service needs as do those sewers proposed by the City in the Facilities Plan.  It

will be necessary to at least duplicate the EIS proposed sewers in the year 2000 or

later and the EIS purposely fails to point this problem out to the readers.  The

doubling or tripling of the cost of these sewers by making future sewer construction

an assured problem will result in a much heavier economic load on the City for not

solving this problem correctly now.  The future construction cost associated with

R/W acquisition, which could prevent the eventual construction of the future sewers,

or a tremendous  increase in construction cost (beyond the inflation impact) due to

restrictive construction room impacts due to adjacent development is not addressed

either.


                                     IV- 9 9

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                                                                   -100-
                                    ATTACHMENT _J	









Calculation of 1976 Actual Jackson Pike Influent Load Concentrations




1976 T.C. Operating Time = 7,300 Hrs. (83.33$)




1976 Recorded Influent BOD5 = 260 mg/1  (160,000 Ibs/d)




1976 Recorded Influent SS = 370 mg/1 (220,000 Ibs/d)




1976 Recorded Flow = 72 MGD




EIS T.C. Average Recycle BOD5 = 30,000  Ibs/d




EIS T.C. Average Recycle SS = 71,000 Ibs/d




Maximum T.C. Inlet Capacity = 200 gpm




Maximum T. C. Solids Capacity @ 4£$ D.S.  and 83.33$ Operation = 90,000 Ibs/d




EIS T.C. Solids Capture = 21$ (Unrealistic)




Maximum T.C. Recycle Flow = < 180 gpm




EIS T.C. Avg. Recycle BOD5 = 16,600 mg/1  (83-33$ Operation)




EIS T.C. Avg. Recycle SS = 39,400 mg/1  (83.33$ Operation)




     (Note:  EIS T.C. Recycle SS = "4$ D.S.) (Unreal istic)




Actual  1975 T.C. Recycle BOD5 = 8,400 mg/1 (Plant Records)




Actual  1976 T. C. Recycle SS = 3,400 mg/1  (Plant Records)




Actual  1977 T.C. Recycle BOD5 = 6,000 mg/1 (Plant Records)




Actual  1977 T.C. Recycle SS = 2,000 mg/1  (Plant Records)









Contributions to influent quality by T.C.  recycle have been  grossly overstated in




the EIS.









Actual  Estimated 1976 Avg. Influent BODr  = 245 - 250 mg/1




Actual  Estimated 1976 Avg. Influent SS  =  340 - 350 mg/1




(T.C. = 8,000 mg/1 BOD5 & SS, 83.33$ Operation, 180 gpm)
                                 IV-100

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                                                                       -101-
                                   ATTACHMENT  3


                                                          March 17,  1978
Mr. Wi 1 1 iam Baker, P.  E.
Grant, Brundage, Baker & Stauffer,  Ltd.
Consulting Engineers
960 Checkrein Avenue
Columbus, Ohio   *»3229

Dear Mr.  Baker:

     As you requested, I have reviewed "Appendix B - Mathematical  Characterization
of the Scioto River Below Columbus" which is incorporated into the draft EIS entitled
"Wastewater Treatment Facilities for the Metropolitan Area Columbus,  Ohio".   This
Appendix is deficient in several particulars, the most important of which are the
fol lowing:

     1.      The  authors  have made no attempt to verify the dissolved oxygen (DO)
             model they employed to evaluate the impacts of future Jackson Pike
             and Southerly discharges.  This deficiency alone vitiates their analysis
             and reduces Appendix B to merest speculation.  It is  compounded by
             assumptions which are  themselves arguable.   (4.1.119)

     2.      On Page B-2, the authors present an equation they assert to be that
             employed in their analysis.  However, the given equation is the
             integrated form of a modified Streeter-Phelps model which assumes
             constant values (in both space and time) for the parameters KI , K£
             and Ko.  Since the authors  state that these parameters are variable,
             the equation on Page B-2 is inapplicable to the problem  at hand, and
             cannot be used as an analytical tool.   (4  n
             The carbonaceous biochemical  oxygen demand (CBOD)  decay rates  they
             employed are extraordinarily  large, ranging from 0.6 day "'  (base e,
             20° C) to 6.0 day"1 (base e,  20° C) , although the  lower value  was
             apparently used in most reaches.  As a result, a summertime DO minimum
             \3 predicted to occur between Jackson Pike and Southerly only  2 miles
             (6 hr time-of-f low) below the Jackson Pike outfall;  a substantially
             complete DO recovery between  the DO minimum and the  Southerly  outfall
             is also entailed by these K-j's.  These predictions should be compared
             with the results obtained by  the U.S. Public Health  Service survey of
             the Scioto River conducted from February 1937 through July 1939
             (R. W. Kehr, et al., "A Study of the Pollution and Natural  Purification
             of the Scioto River", Bull. No. 276, US Pub. Health  Serv.,  Washington,
             19^1).  Under summertime low  flow conditions (125  to 3^*5 cfs at Jackson
             Pike), the DO minimum was observed to occur near Commercial  Point (30
             to kO hr. time-of-f low below  Jackson Pike), corresponding to a CBOD
             decay rate of about O.lA day"1  (base e, >_ 20° C) .  The Public  Health
             Service data represent a variety of Columbus effluents ranging from
             plain sedimentations to activated sludge and include Lo's expressed as
                                     IV-101

-------
                                                                        -102-
To:  Mr.  Wi11iam Baker
             BODj- from 5-  to 18.  mg/1 .  Therefore,  it seems  likely  that the Kj values
             employed  in  the EIS  are  excessively  large and predict  a DO sag more
             severe than  can be  reasonably expected.         (4.1.121^

     k.       The authors  assume  that  the  CBOD and the nitrogenous biochemical oxygen
             demand (NBOD)  are exerted  simultaneously.  However,  long  term BOD tests
             conducted on  Scioto  River  samples collected near South Bloomfield indicate
             that the  NBOD exertion commences only  after a lag of about 8.7 days at
             20° C (S. Strand, "The Statistics of the BOD Parameters", M.S. Thesis,
             The Ohio  State Univ.  1975).  The average NBOD of these samples was 16 mg/1,
             Thus, the assumption of  simultaneous exertion of CBOD  and NBOD appears to
             be unwarranted and  predicts  a DO sag more severe than  can be reasonably
             expected.     (4.1.122)


     In  summary, the stream quality modeling described in Appendix  B is inadequate
and cannot be relied upon  to accurately simulate  the water quality  conditions resulting
from the proposed Jackson  Pike and Southerly discharges.  There  is  reason to believe
that stream conditions resulting  from those discharges will  be better  than those
suggested by the Draft EIS, but  lacking good water  quality simulations, no accurate
predictions can be made.

                                          Respectfully yours,
                                           Robert M.  Sykes, Ph.D.
                                       IV-102

-------
                                                          -103-
               ATTACHMENT
  EIS  DESIGN  REMOVAL  EFFICIENCIES  FROM TABLE  K-1

(a)   Influent vs.  Primary  Effluent loads  (no  recycles)  indicate
     58% SS  removal at  JPWTP  and 71%  SS  removal at  SSTP .
     »
(b)   Influent vs.  Primary  Effluent loads  (with  recycles)  indicate
     A5% net  SS  removal  at JPWTP and  6]%  net  SS removal at  SSTP.

(c)   Influent vs.  Primary  Effluent loads  (no  recycles)  indicate
     37% BOD5 removal at JPWTP  and kk% BOD5  removal  at  SSTP.

(d)   Influent vs.  Primary  Effluent loads  (with  recycles)  indicate
     26% net  BOQr  removal  at  JPWTP and 33% net 6005  removal at SSTP,

(e)  First stage  removal  efficiencies  at  JPWTP are 73% for SS ,
     67% for  BOD5, 2k%  for TKN  and 63% for P.
(f)   Second stage removal  efficiencies  at  JPWTP  are  kb%  for  SS,
     32% for BOD5,  30% for TKN and  k}%  for P.

(g)   Second stage removal  efficiencies  at  SSTP are 3^% for SS,
     36% for BOD5,  91% for TKN and  1\%  for P.

(h)   Efficiencies of polishing filters, etc. at  JPWTP are 74%
     for SS, 27% for BOD5, 30% for  TKN  and 50% for P.

(i)   Efficiencies of polishing filters, etc. at  SSTP are ]3%
     for SS, 23% for BOD^, 35% for  TKN  and 45% for P.

(j)   Overall removal efficiencies for JPWTP are  38%  for  SS ,  99%
     for BOD5,  9A%  for TKN and 90%  for  P.

(k)   Overall removal efficiencies for SSTP are 98% for SS, 98%
     for BOD5,  94%  for TKN and 90%  for  P.
                         IV-103

-------
                                                     -104-
Many of the above  E1S  removal efficiencies are believed to
be over optimistic especially in view of the unit process
design parameters  used  in EIS.
                    IV-104

-------
                                                                    -105-
                         ATTACHMENT
       COMPARISON OF SUGGESTED  SECONDARY  CLARIFIER OVERFLOW RATES

                                gpd/sf

                                                                        Approvable
                           EIS                Proposed                   by
               	Recommendations         Facility Plan	  USEPA   OEPA
               Jackson Pike  Southerly" Jackson Pike  southerly  Stds.   	
Average Day        1090         700         500          500     200-800   500


Maximum Rate       2000         1850         975          985     800-1200 1000
                                  IV-105

-------
                         £"• TT f, ; ~T   PI '•'"'    " 'O V
                         fej
CO!.'.". D J
 UCf ••J11 f,|
                                         unit]
                             DEPARTMENT OFr PUBLIC SL'.rc
                                            3E- 43215
                                             AprM 24,  1973

                                                                          APR?. 61978    .

      Mr. George Alexander, Regional Administrator                      .  E.PA  REGION 5
      U.S. Environmental Protection Agency                               OFFICE Oi: RfGtONAt
      Region V                                                             *IW!N'STRAT'V»
      230 S. Dearborne                            //  n  -^s
      Chicago,  Illinois 60604

      Attention:  Gene Wojcfk, Chief
                  EIS Preparation Section
                  Planning Branch

      Dear Mr. Wojcik:

           The City of Columbus have reviewed  the report entitled "Draft Environmental
      Statement-Wastewater Collection and Treatment  Facilities - Columbus, Ohio"
      dated November  14, 1977, prepared by Booz Allen-Havens and Emerson,  Inc.  The
      City's review indicates  that several important passages  in this  report were
      altered or eliminated in the draft EIS published  by USEPA which  changed  the  original
      intent of Booz Allen-Havens and Emersons proposals.  Furthermore, several
      significant environmental impacts are omitted which seems to confirm that USEPA
      had preconceived ideas regarding several key  issues in the EIS.

           More specifically,  the City notes the  following major alterations
      referenced to the original Booz Allen-Havens and  Emerson report:

                1.  Page 14 of  Executive Summary - The end of the third  paragraph
                   was changed to delete the phrase "and a flexible waste  solids
                   handling disposal system... while assuring dependable solids
                   processing  within the confines of the plant on a day to day
                   basis."  Why does USEPA not want  to  provide a flexible,
                   dependable  solids handling  system-for processing solids at  the
                   plant on a  day to day basis?

               2>  Page 1-6 -  The last sentence of  the  first paragraph  originally
                   started the  "USEPA has directed... that the EIS utilize  this
                   larger planning area".  The draft EIS was changed to delete
                   the words "USEPA has directed".  What is the reason  for this
                   change?

                3-  Page I I 1-22 - The last.line of the first paragraph  was  omitted
                   TYo.ri the Draft CIS.  This statement  read "Due to possible


ORIGINAL:  WATER


                                     IV-105 - A

-------
F'u". George Alexander
U.S..FnvifonnonLai Protection Agency
April  2it,  1978
Page 2
             contamination of the Hoover Reservoir resulting from poorly
             performing individual home treatment systems, a No Action
             Alternative will not be considered."  What- is the reason for
             the USI:FA EIS to omit an important environmental issue
             such as the contamination of a public drinking water supply
             for a city of 800,000 people?

         ^'  Page I I.I ~^6 - In the last sentence of the las.t paragraph,
             the word "uneconomical" was changed to read "not cost
             effective".  USEPA is improperly using the term "cost effective",
             as such term by definition, must also include environmental
             assessments.   Since this sensitivity analysis considers only
             economics, the original report correctly used the word
             "uneconomical", thereby implying that environmental  issues
             were not considered.

         5'  Page IV-2^4 -  The Draft EIS omitted several statements on this
             page related  to sludges, chlorinated pesticides, and PCB's.
             One of these sentences stated "Ten mg/1  of effluent
             suspended solids will result in an effluent chlorinated benzene
             concentration of about 0.0001 mg/1 at Columbus; a value 100
             .times more than the maximum allowable PCB concentration."
             We believe that this statement refers to application of waste
             solids in agricultural applications.  Regardless of the
             alternative,  we question why USEPA chose to remove a passage
             related to such a significant environmental  issue as PCB's.
             Does USEPA feel that such high'levels of PCB's are not an
             environmental-consideration and justify omission from the
             Draft EIS?

         6.  Page IV-33 -  In the third paragraph, USEPA has deleted the
             statement that a parallel  force main may be necessary for fail-
             safe reliability.  Does USEPA believe it proper to disregard
             such a distinct probability?

         7.  Page IV-38 -  The USEPA Draft EIS omitted the statement referring
             to sludge cake application to the land,  as follows:   "The
             ultimate analysis revealed that this alternative was harder to
             implement and less cost effective than an incineration alternative.
             Further, only the incineration alternative provided continuous
             availability  and reliability."  Why was  this passage omitted?
             Since the City and USEPA consultants all agree that  incineration
             is most cost  effective, and considering  the PCB's,  chlorinated
             pesticides, etc in the sludge,  why does  USEPA continue to pursue
             land application of sludges?  Does USEPA feel  that  the chlorinated
             benzenes and  PCB's will disappear from the Columbus  sludge in
             the course of further modelling studies?  What criteria were used
                                 IV-105 - B

-------
Mr. lo6O!"nG Alex3nner
U.S.- Environmental  Protection Agency
April  24, 1978
Page 3
             .by USEPA in omitting the recommendations of its  consultants?
             In this particular case,  what are the reasons  of the USEPA
             which led them to a decision which is different  from that o1
             their consultants?

         8.   Page IV - 39 ~ The draft EIS omits the following passage in
             relation to land application of sludge:   "The  resistance of the
             service area population to the subsidizing of  operations which
             are not cost effective..."  Why does the USEPA want to omit
             the reference to the costs of land application of sludges?
             Why does USEPA omit the sentence in the following paragraph of
             the EIS that relates to the State and Federal  agencies that
             will have to make a firm commitment to the municipality to
             accept any liabilities which may arise from applying these solids
             to the land?  We are particularly interested in  knowing why
             the USEPA chose to omit the fact that there would be long term
             liabilities from the effects of land application of sludges
             that contain PCB's and chlorinated pesticides.

         9*   Page IV-45 - USEPA has deleted three significant paragraphs
             and one table showing that nutrient recovery alternatives do
             not appear attractive for implementation by Columbus.  Here
             again, the draft EIS attempts to reduce and omit the negative
             impacts of its preconceived ideas.  Counting USEPA1s own
             engineers, five consulting firms have now shown  the fallacy of
             land application for Columbus,

        10.   Page IV-49 " The Booz Allen-Havens and Emerson report made this
             statement in regards to strip mine reclamation,  "However,
             these grants fail to relate to the significant operation and
             maintenance expenditures associated with a land  application scheme."
             The Draft EIS modified this statement to read, "These grants do
             not provide for operation and maintenance expenditures."  This
             is a prime example of how USEPA has altered the  work of the
             consultants to minimize the negative impacts of  some of USEPA's
             recommendat ions.

        11.   Page IV-52 - In the first paragraph, the draft EIS has deleted
             the statement "Thus, from the standpoint of the  City, any land
             recovery scheme is uneconomical."  We would like to know why
             this was omitted.,

        l2-   Page 1V-63 - In the first paragraph, the draft EIS has omitted
             references to the  large land areas of 95,000 and 44,000 acres
             required for nutrient recovery schemes and to the poor
             implomentabi1ity of these schemes.  Why?  Where   in Ohio  is this
             amount of land available for  land application?
                                    IV-105 - C

-------
Mr. George Alexander
U.S. LnvironmentuS  t-r ULL;CL ion
April  2'{,  1978
Page A
        13.  Page VI-8 - The Booz Allen-Havens and Emerson report made the
             statement, "Although the air qua]ity "standards for particulate
             matter will be met-at both incinerator sites...".  The USEPA
             EIS changed this sentence to read,  "Irrespective of whether
             the air quality standards for particulate matter is met or not —".
             This changes the meaning of the sentence as originally written
             by the consultants.

        lA.  Page VI-9 ~ The Booz Allen-Havens and Emerson report states,
             "The sludge from the Columbus area  contains trace amounts of
             hazardous organic substances such as cyanides.  A relatively
             greater amount of potentially toxic chlorobenzenes has been
             detected  in this sludge."  The USEPA EIS modified these sentences
             to read, "The sludge from the Columbus area contains trace amounts
             of potentially hazardous organic substances such as cyanides and
             chlorobenzenes."  Further in the paragraph the USEPA modifies a
             sentence that said,  "However, test  data shows that virtually all
             of the PCB's and chlorobenzenes are destroyed during the sludge
             incineration."  Why?

     The content of the original  Booz Allen-Havens and Emerson report clearly
shows that they felt they had enough reliable data regarding Columbus sludge to
make strong recommendations for incineration and against land application.  This
is evidenced on pages  IV-38, IV-39, IV-40, IV-45, IV-46, IV-47, IV-49, IV-50,
IV-5], and many other pages in the Booz Allen-Havens and Emerson Report.

     The USEPA Draft EIS has extensively modified the original document submitted
by the EIS consultants and changed the original  meaning of many statements.
Furthermore, the USEPA has omitted references to important environmental  issues:
to name a few,  contamination of Hoover Reservoir, PCB concentration of 100 times
the maximum allowable  limits and  chlorinated pesticides in the sludge.  The
omission of these environmental issues is in conflict with USEPA's regulations.
We ask that USEPA explain the reasons why environmental issues of such magnitude
were not addressed  in an Environmental Impact Statement?

     The City requests that this  statement be entered  in the public record of the
public hearing on the Draft Environmental Impact Statement for the Metropolitan
Area of Co-lumbus, Ohio held in City Council  .Chambers, Columbus, Ohio on March 30, 1973.

                                       Sincerely,      s~\
                                       ROBERT C. PARKINSON, P.E.
                                       Director of Public Service
RCPrDDR:jms

cc:  O.E.P.A.
     Grant, Brundage, Baker & Stauffer, Ltd. (Consulting Engineers)
     Malcolm Pirnie, Inc. (Consulting Engineers)
     Burgess & Niple (Consulting Engineers)
     D. D. Robbins
     G. B. Walkenshaw                    Iv_105
     R. Smith
     E. Ary

-------
4.1       City of Columbus

          The following sections refer to the general and
specific comments raised by the City of Columbus, Ohio, in
its review of the Draft EIS.  Comments are responded to in
the same order as they are presented in the City's review
document.  The responses are limited to those points raised
in the City's detailed review since the concerns expressed
by the City in pages one through ten of their document
merely summarize those found in the detailed review.  Where
general comments are further detailed by subsequent  specific
comments, response is made only to the specific comment.
4.1.1     Comment;  The EIS incorrectly states that the
Franklin County Board of County Commissioners co-applied
with the City of Columbus for the Federal Construction
Grant.

          Response;  The correct identification of the City
as the sole applicant has been noted in Chapter I.
4.1.2     Comment;  Separate brewery wastewater treatment
was not an issue in the U.S. EPA "Notice of Intent" to do
the EIS.

          Response;  The following issues raised in the
Notice of Intent implicitly define brewery wastewater
treatment or pretreatment as an issue in and of itself:

               The level of sewage treatment necessary to
               meet water quality standards in the Scioto
               River

               The liquid sewage treatment alternatives that
               would enable the attainment of water quality
               standards in the Scioto River

               Alternative methods of sludge treatment and
               disposal.

     Moreover, the "Notice of Intent" does not preclude
from examiniation any issues raised during or as a result
of preparing an EIS.  In fact, raising of issues early in
the process is encouraged by the  new CEQ EIS regulations.
                          IV-106

-------
4.1.3     Comment:  The EIS states that it will use the
same planning area as delineated in the Facilities Plan;
yet, the alternatives considered for interceptors use a
different planning area.

          Response;  Section 1.5.1 has been changed to
indicate that the planning areas are roughly equivalent,
with the EIS planning area somewhat larger.
4.1.4     Comment:  The EIS did not use the same flow
data available at the time the Facility Plan was prepared.

          Response;  See response 3.1.7 to Ohio EPA comments,


4.1.5     Comment:  The EIS claims that plans to revitalize
the downtown area may reduce the decentralization trend
of the 1960's and 1970's.  To say that growth in the down-
town area would be responsible for measurably reducing the
decentralization trend is almost incomprehensible.

          Response;  This statement has been taken out of
context.  If the entire paragraph 2.2.4(1) on projected
trends is read carefully, it is clear that the EIS assumes
"both the growth and spatial redistribution trends of the
1970's are likely to continue in the foreseeable future."
4.1.6     Comment;  No hydrologic discussion of Little
Walnut Creek is included in Section 2.1.3.

          Response;  Information on the hydrology of Little
Walmut Creek was unavailable to the authors.  Lack of this
information is not a serious deficiency in evaluating al-
ternatives .
4.1.7     Comment;  282 mgd is the total safe yield from
surface water sources instead of 182 mgd reported in the EIS

          Response;  This typographical error has been cor-
rected in Section 2.1.3(1).
                          IV-107

-------
4.1.8     Comment;  Surface water quality information con-
tains no significant discussion of nonpoint sources.

          Response:  Problems with septic tanks and urban
stormwater discharges are discussed in the EIS.  Other non-
point source problems (e.g., agriculture, mining) are not
discussed since they would have negligible, if any, impact
on the selection of alternative actions.
4.1.9     Comment;  Reports of several fish kills on the
Olentangy River are unsupported by documentation.

          Response;  This has been corrected with addi-
tional information from Ohio EPA.
4.1.10    Comment;  There is no discussion of fecal coli-
forms within the section on surface water quality.

          Response;  Fecal coliform levels are mentioned
in general for the Scioto River, Olentangy River, and
Blacklick Creek; with specific discussion of values for
the Scioto River both in Chapter II and Chapter VI (Pages
IV-16-18).  Appendix C provides a summary of the avail-
able information.


4.1.11    Comment;  Statements concerning dissolved oxygen
concentrations in the Olentangy River are too hypothetical.

          Response:  Dissolved oxygen is reported as "high"
at Worthington and in standards contravention during low
flows at Goodale Street.  This is substantiated in Appendix C.
4.1.12    Comment;  The EIS incorrectly states that the
northwestern quarter of Franklin County was not covered
by Climax beech forests.

          Response;  This has been corrected.
4.1.13    Comment:  Why were new population projections
developed in the EIS?
                          IV-108

-------
          Response:  The rationale for developing new
population projections is given in Section 2.2.2(1).
Further discussion of the original Draft EIS projections
is presented in Volumel.
4.1.14    Comment;  The City of Columbus does not suffer
from an inadequate water supply and does not anticipate any
shortage throughout the planning period.

          Response;  This section has been modified in the
EIS and responded to in comment 3.1.18 under Ohio EPA.
4.1.15    Comment;   The EIS should address how much vacant
land is active farmland.

          Response;  See response to Ohio EPA comment 3.1.12,


4.1.16    Comment:   The EIS should explain that the Scioto
West Interceptor would also relieve the constraints imposed
now on flow to the Scioto East.

          Response;  See response to Ohio EPA comment 3.1.13,


4.1.17    Comment;   Table 11-23 does not reflect sewer
charges currently in effect.

          Response;  See response to Ohio EPA comment
3.1.16.


4.1.18    Comment;   Safe water yields appear to be incorrect
according to City of Columbus figures.

          Response:  See response to Ohio EPA comment
3.1.18.
4.1.19    Comment:  The EIS designs interceptors to flow
half-full in the year 2000 rather than on ultimate popu-
lation.
                          IV-109

-------
          Response:  EPA Guidelines (40 CFR 35E)  state that:
"Interceptor pipe sizes (diameters for circular pipes)
allowable for construction grant funding shall be based upon
a staging period range of from 20 to 40 years, since direct
monetary costs vary little within this range.  Since the
projection of population flows beyond 20 years is highly
conjectural, the pipe size may be based upon a staging
period of 20 years and an assumption that the pipe, at peak
flow, will be flowing at half depth at that time."
4.1.20    Comment;  The 0.25 percent of the construction
cost as annual O&M for interceptors is an estimate that is
unreasonably high.

          Response:  The 0,25 percent of construction cost
was used as an estimate for the annual O&M of interceptors.
This is an estimate of the cost required to staff and equip
a maintenance crew and to allow some contingencies for
repair or replacement of interceptor sections.
4.1.21    Comment;  Salvage values were not straight lined,
but appear to have followed a decreasing rate trend.  This
approach has no justification for interceptors.

          Response:  Salvage values were depreciated using
the straight line method.
4.1.22    Comment;   By using a 20 year planning period, the
EIS does not consider construction of interceptors for the
period 2000 to 2025.

          Response:  See previous comment 4.1.19.


4.1.23    Comment:   EIS states that it used costs for
interceptors based on recent bids in the Columbus area.
Where is the documentation?

          Response:  The bids used as a check on the
validity of the EIS cost estimates are as follows:
                          IV-110

-------
Date Bid Submitted       C.I.P.  No.    Contract Dwg. No.

March 22, 1977             710031            CC-2553
December 7, 1976           710046            CC-2382
March 2, 1976               N.F.             CC-2382
December 14, 1976          710021            CC-2196
March 8, 1977               N.F.             CC-2416
March 2, 1976              710106              N.F.
June 29, 1976              710030              N.F.
October 12, 1976           7100538             N.F.
December 28, 1976          710158            CC-2243
March 9, 1976               N.F.               N.F.
August 24, 1976             N.F.             CC-2493
February 24, 1976          710124            CC-2192
February 15, 1977          710123              N.F.
4.1.24    Comment;  The environmental impacts as well as
cost of building parallel interceptors at some future date
are significantly greater than designing to full at ulti-
mate population and have not been analyzed.

          Response:  The impacts of constructing sewers of
the cost-effective size (20 year - half full)  have been ana-
lyzed.  In addition it is not EPA policy to design sewers
based on ultimate population as this can greatly overstate
needs for adequate protection of the water.  See Comment
4.1.19.

4.1.25    Comment:  The EIS recommends extending and en-
larging the interceptor to convey flow from Southwestern
Delaware County and does not provide a cost-effective
analysis.

          Response;  The first paragraph on Page 111-12
of the Draft EIS under "Costs" states that a present worth
basis was considered for a pump station versus an inter-
ceptor above Manhole 3.  The detailed analysis was not
presented in the report but is reproduced below:
                         IV-111

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                        West Scioto

                            Interceptor     Pump Station

1980 Capital Cost
  (50 year life)            $1,421,000      $ 63,000
  (20 year life)                 0           350,000
1980 Present Worth  of
  Salvage                     -248,000       -11,000
1980-2000 O&M P.W.
  Interceptor and Force              ,,>
  Mains                         40,000Uj       2,000
1980-2000 O&M P.W.
  Pumping Station           	0           318,000
                            $1,213,000      $733,000

(1)  0.25% of construction  cost.
(2)  O&M varies from $20,200/year in 1980 to
    $33,600/year in 2000.
          The P.W. of  the  interceptor is some 65 percent
greater than the P.W.  of the Pump Station.

          The EIS did  not  size the West Scioto Interceptor
in an effort to instruct Columbus to serve southwestern
Delaware County.  The  sizing was put forth so that the
lower section could  be constructed without further delay.
If this section is constructed of the size mentioned in
the EIS, it would not  have to be paralleled in the event
a future decision does call for the transport of sanitary
flow from southwestern Delaware County.
4.1.26     Comment:  For the Big Run Interceptor, the EIS considered
the same alternative presented in the Facilities Plan.  The EIS overlooked
the fact that the section between MH 4 and 5 could not be constructed
unless the section from MH 5 to 6 was constructed.

          Response:   The  EIS reviewed the same alternative
as the Facilities Plan since it appeared to be the only
feasible solution for regionalization of this subarea.
The interceptor  section between MH 4 and 5 was the only
section projected to  require service during the planning
period.  The EIS did  take into account the fact that to
provide service to  the first section, the interceptor
section between MH  5  to 6 would also have to be constructed,
as shown in Table III-3.
                           IV-112

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4.1.27     Comment;  The  interceptors proposed by the EIS
are incapable of being extended in the  future.

           Response;  With population projections pointing
toward  a  fairly heavy growth in an area surrounding Inter-
state 70  close to the City of Columbus,  modification to
the Facilities Plan alternative was described in the EIS.
The modification was suggested only as  an  option to collect
flow from this area without requiring additional construc-
tion of the Big Run Interceptor above Manhole 4.


4.1.28     Comment:  The  EIS duplicated  the alternates used
in the  Facilities Plan,  except to change the sewer pipe
size and  incorrectly states the location of the Alum Creek
Interceptor.

           Response;  EPA policy and design criteria dic-
tated smaller sewer sizes.  The City is correct, however,
in suggesting the change from "westerly" to "easterly".
The change has been made in the EIS.


4.1.29     Comment;  The  delayed construction of the inter-
ceptor  will increase the threat of contamination to Hoover
Reservoir.  The pump station and force  main sizes would
be affected by annexation plans contemplated by New Albany.

           Response;  For the Big Walnut Creek area, the
suggested section of the interceptor to be constructed
during  the planning period is below the reservoir.  When
and if  the area north of this point is  constructed, the
route suggested by Alternative A or Alternative B may.be
selected.  One of the major concerns within  the  Big  Walnut  subarea is the
protection  of Hoover Reservoir, a potable water supply. The Facilities
Plan recommended construction of an intercepting sewer  for the
elimination of  potential surface water contamination from the sparcely
developed area  east of Hoover Reservoir. At present, there is no
pollution source impacting Hoover Reservoir that requires a regional
sewer system in the Big Walnut Sewer Service Subarea. Provision
of public utilies and highways have been show to induce rapid development
of desirable lands. If rapid  development occurs east of the reservoir,
surface water degradation may occur from overland non-point sources
even with the interception of all sanitary wastewater.  Therefore,
the EIS recommends protecting the reservoir through strict zoning
and development regulations.
                           IV-113

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4.1.30    Comment:  The EIS is inconsistent  and  incorrect
throughout its analysis of the Blacklick Creek alternatives,

          Response:  Comments pertaining to  the  Blacklick
Creek Subarea will be addressed in the response  to  ques-
tions raised by the City of Reynoldsburg.
4.1.31    Comment;  The force main referenced  in  section
3.1.2 crosses the Scioto River at Martin Road,  not  at S.R.
161.

          Response:  Description of the crossing  has  been
corrected.
4.1.32    Comment;  The model on combined  sewered  areas is
questionable since it was based on theoretical  concepts
and was not verified by actual field measurements.

          Response;  The lack of verification is explicitly
mentioned in the combined sewer modeling discussion.   It
was never intended to draw definite, detailed conclusions
from this analysis, and it is so stated in Appendix H.
The broad conclusions which are drawn will be either sub-
stantiated or revised at the completion of the  City's com-
bined sewer overflow analysis.


4.1.33    Comment:  Outletting the Sunbury/Galena  area
into the Columbus  system is not dealt with in the  Big
Walnut or Rocky Fork alternatives.


          Response:  In Sunbury/Galena  localized facilities planning
 will be evaluated to determine the need  for sewer service for  that service
 area.
4.1.34    Comment;  The EIS uses a  90 gallons  per  capita
per day dry weather flow without documenting the figure.

          Response;  The 90 gallons per  capita per day
came from the I/I report prepared by Malcolm Pirnie.   The
EIS examined 19 of the 22 areas evaluated  in the I/I,
and then used the average wastewater flow  (45.8 mgd)
divided by the population served  (45.8 mgd/528,553).
                          IV-114

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4.1.35    Comment;  The EIS allowance for infiltration
is not nearly enough and should be calculated on an
acreage basis and not tied to population.

          Response;  The point made in the comment as to
the fallacy of a per person allowance could just as easily
be made concerning a per acre allowance.  Until a collec-
tion system for the year 2000 population is designed, any
estimate for I/I to an interceptor has similar weaknesses.
4.1.36    Comment;  The EIS does not truthfully represent
the facts about the Scioto East Interceptor and Dublin's
limited discharge.

          Response;  The limiting discharge of 29 cfs
(18.7 mgd) from Dublin is over twice the peak flow esti-
mated to come from both Dublin and the southwest portion
of Delaware County (if this flow is collected by the City
of Columbus), as pointed out in Table III-2 for the modi-
fied plan.
4.1.37    Comment;   The EIS cost estimates for construction
and O&M are inappropriate and use an unrealistic
plant life figure.

          Response;  The 0.25 percent of construction cost
was used only as an estimate of annual O&M costs for the
interceptors, and if removed would not change any decision
made by comparative cost analyses.  If treatment plant
lives were shortened, the cost-effective analysis involving
the consideration of a treatment plant would not be changed,
4.1.38    Comment:  Use of half full criteria provides for
capacity beyond the planning period, but no analysis was
done to relate the 20 to 50 years population flow demands
to the sewer which has a stated sewer life of 50 years, to
determine whether the sewer will serve the area throughout
its stated life.

          Response:  Please see response to comment
4.1.19.
                         IV-115

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4.1.39    Comment:  Allowing population problems to develop
in New Albany violates the spirit of P.L. 92-500 and 95-217,

          Response;  Please see response to comment
3.1.28.
4.1.40    Comment;  Pumping stations are not good practice
in this day on conserving energy, especially when a gravity
sewer can be constructed.

          Response;  The cost of energy has been included
in the comparison between pumping station and gravity
sewer options.
4.1.41    Comment;  The "permanent" pump station cannot
be permitted to usurp East Area sewer capacity.

          Response;  The costs reported in the Draft EIS
were for a permanent pump station and force main with the
knowledge that at a time after the planning period this
station would be abandoned.  The 29 cfs previously
cited by the City as the limiting flow from the Dublin
area was found to be twice the capacity needed through
the planning period, as pointed out in Table III-2 of the
EIS.
4.1.42    Comment:  The adding of additional Delaware
County area merely compounds the above comments and re-
quires a complete reworking of this area analysis.

          Response:   The addition of Delaware County causes
a suggested increase in size for the sections of the inter-
ceptor which must be constructed by 1980.  This merely
allows for future flexibililty in decision making by south-
western Delaware County without holding up needed con-
struction.
4.1.43    Comment;  No substantial information is presented
by the EIS to support contention that some part of the Big
Run area can be cross connected to easterly area sewers by
gravity.
                          IV-116

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          Response;  A review of City construction drawings
showed the invert of manhole 19 north of 1-70 and the
intersection of Billiard and Renner Roads to be 919.58.
The sewer at this location is shown as 27" at a slope of
0.4% and is over 10 feet deep.  The manhole at the inter-
section of Feder and Milliard Roads which would serve the
area south of 1-70 is shown to have an invert elevation of
901.43 feet.  The 27" sewer at this point is over 25 feet
deep.  With this data, it was assumed that the areas to
the west of these manholes could be served by gravity
utilizing a limited extension of these sewers.
4.1.44    Comment;  The EIS recommends implementation of
Alternate A for Big Walnut which was shown in the Facili-
ties Plan as being extensively routed through environ-
mentally critical areas.

          Response;  The proposed construction during the
planning period for the Big Walnut Creek subarea could
accommodate the future choice of either Alternative A or B
for service to the area further north.  This decision can
be made at the time the extension is needed.
4.1.45    Comment:  The lack of sewers in Blacklick Creek
will not halt development.  Developers will build regard-
less.

          Response;  Please see response to comment 3.1.34.


4.1.46    Comment;  The EIS does not consider all the facts
regarding the Blacklick Creek proposals.

          Response:  All comments regarding Blacklick Creek
are dealt with in responses to comments made by the City
of Reynoldsburg in Chapter IV, Section 4.3 of this volume.


4.1.47    Comment;  The environmental and aesthetic impacts
of installing a force main along U.S. 40 for Blacklick
Creek were grossly underestimated.

          Response;  Please see response to Comment 4.1.46.
                         IV-117

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4.1.48    Comment:  The EIS proposed pumping station loca-
tion set in' the vicinity of S.R. 161 and the force main
to Big Walnut Interceptor totally ignores the fact that a
previous Federal grant paid for a gravity sewer from the
creek to the vicinity of Hamilton Road just south of
Morse Road.  This grant and construction was made to pro-
vide an outlet compatible with the New Albany plans.  This
situation will require a complete reworking of the cost-
effective analysis for the Big Walnut/Rocky Fork/Blacklick
areas.

          Response;  See the revised analysis in Chapter
III of Volume  I  and  the revised  regionalization chapter
appended to this volume.
4.1.49    Comment;  Blacklick Alternative D has the most
primary impacts and should not be constructed.  The gravity
interceptor sized to ultimate flow is the best way to clean
up the waters and to eliminate dual and triple construction
impacts.

          Response:  Please see responses to comments
made by the City of Reynoldsburg in Section 4.3 of this
Volume.
4.1.50    Comment;  No consideration was given to the
existing treatment plants in the vicinity of 1-70 and
S.R. 256 and S.R. 204.

          Response:  Please see responses to comments
made by the City of Reynoldsburg in Section 4.3 of this
volume.
4.1.51    Comment;  Rickenbacker Air Force Base is not in
the approved planning area.

          Response:   The analysis for the base has been
deleted since the base has been phased out.
                          IV-118

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4.1.52    Comment:   The pretreatment of brewery waste was
considered by  the  City to be inappropriate  for seven reasons:


          1.    The brewery load is not considered incom-
                patible according to EPA standards.

          2.    No  pretreatment standards  for  brewery wastes
                have been published to date.

          3.    Economies of scale indicated that treatment
                at  Southerly would be less expensive.

          4.    The environmental impacts  of a sewage treat-
                ment facility at the brewery would be signi-
                ficantly greater as compared to treating
                the brewery waste at Southerly.

          5.    The City has no legal authority to impose
                pretreatment standards on  the  brewery.

          6.    Discharge of pretreated brewery wastes might
                be  worthless due to the long travel time
                in  the sewers to Southerly.

          7.    A  two year research study, conducted by Ohio
                State University under contract with the
                City, has not shown brewery  waste to be the
                direct cause of bulking problems at the
                Southerly Plant.

           Response;   The City cites seven reasons why brewery pre-
 treatment was deemed inappropriate.   These points were not generally
 raised in any of  the documents made available during the
 preparation of the  EIS.   Responses to each point are as
 follows:

           1.   This is not related to questions  of where and to
               what level it is cost-effective to  treat the
               brewery waste.

           2.   See above response. Further, no  hard  pretreatment
               standards should be established for an industrial
               waste that is compatible with conventional wastewater
               treatment technology since the cost-effectiveness
               of pretreatment is obviously situation specific.
                           iv-119

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 3.    The City or brewery should provide support-
      ing documentation of this conclusion.   Our
      costing analysis, which we believe is  con-
      servative, suggests an opposite  conclusion.
      Conceptually, it is difficult  to imagine
      how 3 mgd of non-pretreated  brewery waste,
      which contributes nearly 30  percent of the
      entire anticipated 85 mgd Southerly BOD^
      load (and over fifty percent of  the soluble
      3005 load) can be more cost-effectively
      treated once diluted with normal municipal
      wastewater.  Economies generally result
      when handling wastes in their  most concen-
      trated form.

 4.    The City or brewery should cite  what they
      believe to be the significantly  greater
      environmental impacts with the brewery
      pretreatment.  Proper safeguards have  been
      incorporated into the EIS pretreatment
      scenarios to minimize local  impacts, par-
      ticularly in terms of odor control.


5.     Pretreatment can be thought of as load limitation.
      The City and brewery have agreed that  the average
      day brewery load should be no more than 60,000
      Ibs of BODg/day.  If the brewery uses  public
      sewers or public treatment facilities, it would
      appear that the City can develop any statutes
      that it needs to deal with the situation.
 6.   In reference to Scenario  2,  it should
      be noted that the average day primary sedi-
      mentation overflow rate at Southerly is
      only about 700 gpd/SF  and that the proposed
      means of phosphorus removal  will incorporate
      metal salt (alum) addition to the influent
      wastewater.  Alum is an effective coagulant,
      especially when backed up by organic poly-
      electrolyte addition.  It is likely that
      the sloughed solids from  the brewery's
      roughing trickling filter can be effectively
      controlled at Southerly even with changing
      settling characteristics  due to the long
      conveyance time in the interceptors.
                 IV-120

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          7.    Ihis document was not available to us during
               the EIS preparation,  and,  we therefore could not
               comment on the validity of its conclusions.
               The key word in the City's comment may be
               "direct";  obviously the bulking problem will
               be directly caused, by some organism whose
               growth is  selected for by  the means of opera-
               ting or the operating limits of the existing
               facilities.  The key question is,  "Would
               this bulking problem exist without the brew-
               ery with the present installation and loads?"
               We find that it would not, as addressed in
               the supplemental analyses.

4.1.53    Comment;  The EIS recommends "pretreatment" of
the brewery waste to the  point that the soluble oxygen
demanding load is largely removed.  The following ques-
tions should be taken into consideration  regarding this
Scenario 2:

          1.    Have adequate provisions been taken to prevent
               odors?

          2.    What is the success and feasibility of this
               method?

          3.    What will  be the impact on Southerly solids
               handling facilities?

          4.    Will there be problems in  the sewers?

          5.    Is this being done anywhere successfully?  If
               so, what are the problems?

          6.    Who would  operate the Brewery facility?

          7.    Were the basis of cost estimates the same?

          8.    Can this proposal be implemented?

          9.    Can any of sludge handling at Southerly be
               eliminated as proposed?

         10.    What are EIS proposals for quantities of sludge
               generated  and methods and  costs of disposal?

         11.    Table IV-2 Page IV-6.  It  appears in the EIS,
               that scenarios 2, 3,  and 4, eliminate $24.5
               million in solids handling costs at Southerly.
               While the  Brewery costs reflect increases as
               level of treatment increases, the level of cost
               at Southerly doesn't vary. - This isn't possible,
               The solids processing cost at the Southerly  in
               "Scenario  2" would have to be greater than in
               "Scenario  4"!

                          IV-121

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          Response;   In reference to Scenario 2,  the City
raises 11 questions.   Our responses are as follows:

          1.    Yes,  to the level of detail incorporated
               with  the development of the scenarios.   It
               is so stated in the Draft EIS and  has been
               further stated in our response of  March 29,
               1978,  to the brewery's requests for addi-
               tional information.
          2.    We do not limit the brewery to a specific
               treatment method,  but believe the one de-
               fined for the purposes of cost estimating
               is a reasonable alternative.

          3.    The overall effect will be to slightly in-
               crease the magnitude of waste solids from
               Southerly's primary sedimentation system
               and significantly decrease the magnitude
               of waste solids from the secondary treat-
               ment system.

               Although it is unclear what problems are con-
               templated,  three common problems are:  Solids •
               no more than presently experienced and perhaps
               less, since we are dealing with a biological
               suspension, which is unlikely to settle under
               the velocity conditions found in a sewer;  H2S
               and methane formation - no more than presently
               experienced since the deposits should not
               increase; Odors - possibly less in the sewer
               reaches near the brewery due to biological
               stabilization of brewery load, in the sewer
               reaches away from the brewery we doubt if
               there will be a significant change over pre-
               sent conditions.

          5.    The use of synthetic media trickling filters
               for stabilization of soluble, simple car-
               bohydrate, and readily biodegradable indus-
               trial wastes is not a unique treatment
               technology, and has been successfully
               applied throughout the United States.  Use
               of this treatment technology to reduce the
               soluble oxygen demanding load prior to re-
               lease to a sewer has not been tried any-
               where to our knowledge, but we believe the
               concept to be technically valid.
                         IV-122

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          6.    It  is  recommended that the brewery
               will operate its own facility.

          7.    Southerly costs and operating costs  were
               determined from the values cited  in  the
               Facilities Plans and elimination  of  parallel
               or  complete unit processes when they were
               no  longer required.  Capital cost estimates
               for brewery treatment facilities  were inde-
               pendently determined.

          8.    This question is more dependent upon the
               willingness of the participants rather than
               on  technical concerns.

          9.    Yes, Table IV-2 clearly shows what sludge
               handling facilities can be eliminated.
         10.  Appendix K clearly states the quantities
              and methods for sludge disposal.   Capital
              and operating costs were largely  developed
              from the informational basis contained in
              the Facilities Plans.  The  validity
              of  any final cost estimate  is dependent
              upon the original validity  of the costs
              found in the Facilities Plans.

         11.  The $24.5 million difference is associated
              with the elimination of both main stream
               ($15.5 million)  and waste solids  handling
               ($9.0 million) unit processes.  It is  our
              view that with the 60,000 Ibs/day of BODc
              brewery load scenario, no further significant
              capital or operating savings can  be realized
              at  Southerly once the soluble oxygen demand
              of  the brewery's waste is controlled.

4.1.54    Comment:  The discussion of the use of the Jackson Pike
plant effluent as cooling water is beyond the scope of the EIS or
the Facilities Plan and should not be addressed.

         Response:  The potential  use of the Jackson Pike effluent
for cooling water at the proposed refuse/coal fired power plant is
entirely appropriate within the scope
                           IV-123

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of an EIS.  It represents a clear beneficial use of waste-
water and avoids the use of the river water/effluent mixture
for cooling.
4.1.55    Comment:  While the City of Columbus is interested
in developing a land application program for sludge, the
potential liabilities and environmental risks are still not
resolved to a point where the City is willing to implement
the proposal recommended in the EIS,

          Response: See Volume I Section 3.3


4.1.56    Comment;  The I/I Analysis Report was ignored in
developing design flows, and the approach used in the EIS
is inconsistent with the phased construction concept of
the facilities planning regulations of the EPA.

          Response;  The Infiltration/Inflow Analysis re-
port made available to use did not monitor combined sewer
areas.  Further, the Facilities Plans concluded that the
results of the I/I study could not be used in developing
peak flows.  The EIS developed infiltration/inflow estimates
based upon the information available.

         The Facilities Plan specifically states that the
average annual design flows for Jackson Pike and Southerly are
120 mgd.  How these flows were derived, particularly at
Southerly, was not stated.  The firm hydraulic capacity to
average annual flow ratio of less than two is indicated
for both plants.  The use of such flow ratios violates
conventional design practice.

         The EIS checked the validity of the average day
design flow values.  An insignificant difference was found at
Jackson Pike  (110 mgd for the EIS versus 120 mgd for the
F.P.) while a significant difference was found at Southerly
(85 mgd for the EIS versus 120 mgd for the F.P.).  Thus, it
was believed that Southerly had an adequate hydraulic
capacity but Jackson Pike's hydraulic capacity was still
below accepted norms.  It seemed pointless to expand the
Jackson Pike hydraulic capacity to 240 mgd or more when
the 150 to 156 inch diameter connecting sewer was availa-
ble for flow diversion to Southerly, which, save for its
firm pumping capacity, had sufficient reserve hydraulic
capacity to handle a diverted 50 mgd.  Thus, the EIS
offers an easy-to-implement program which provides 430
mgd of hydraulic capacity against the 380 mgd proposed in
                         IV-124

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the Facilities Plan.  Most fundamentally, this yields
(using the EIS average day flows) a hydraulic capacity
peaking factor of 2.2 times the average day flow of both
plants against the 2.8 and 2.1 factors  (at Jackson Pike
and Southerly, respectively) derived with the proposed
project plan of the Facilities Plan.  (Refer to pp. 1-24
through 1-27).
4.1.57    Comment;  The EIS recommends use of the jet-
aeration system.  This recommendation is not adequately
supported.  All available technologies for oxygen dissolu-
tion should be reviewed at the time of final design.

          Response;  The EIS recommends a detailed evalua-
tion of jet aeration in plant-scale studies as a possible
replacement for the antiquated, maintenance intensive,
sock diffuser systems.  Other alternatives are also
suggested.  We readily admit that we have no first-hand
knowledge of the system's oxygen transfer efficiency; we
do have test data from reputable independent consultants.

          Nowhere does the EIS state a first cost savings
for the Pentech system, with all analyses pointing to its
cost-effectiveness when operating costs are considered.
The $1.3 million savings mentioned in the comment is for
the overall biological treatment system at Southerly, a
point noted in the "Processing Concept" line in the cost
summary table.  The end result of this entire comment is
exactly what the EIS recommends.
4.1.58    Comment:  The EIS states (Appendix I Pg. 1-27),
"The design hydraulic capacity of a plant is normally
selected at 2 to 2.5 times the average daily flow for
facilities the size.of the Columbus installation."  We
agree that this would normally be the case.  However, the
following points should be noted.

          1.    The plant facilities in the facilities plan
               are designed on the basis of average dry
               weather flow and not annual average daily
               flow as design annual average daily flow
               cannot be determined with certainty without
               obtaining the results of the sewer studies.

          2.    With the construction of necessary equaliza-
               tion facilities, there is no reason for the
               peaking factor to be 2 to 2.5 times average
               flow as normally required for plants without
               equalization facilities.
                          IV-125

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          Response;  The point of the flow equalization
comment is unclear, although it would seem that the
comment addresses oversizing of the hydraulic capacity of
the treatment facilities.  The EIS proposal for a 2 to
2.5 average day to peak flow ratio is realized through
minimal expansion of existing facilities and a matching
sizing of proposed hydraulically-dependent processes.
This would be accomplished through the use of the intercon-
necting sewer; an existing facility which the Facilities
Plan did not incorporate.  If the SSES and separation pro-
jects show the need for equalization facilities,  the EIS
does not preclude their construction.

          If the 120 mgd flows cited in the Facilities Plans
do indeed represent average dry weather flows as  claimed,
we find no justification whatsoever in the Facilities Plans.
Further, if they were, a design with no equalization facili-
ties such as proposed in the Facilities Plans would cer-
tainly use a higher peaking factor than that found in the
Plans.  The second point of the comment assumes a conclusion
before the data is in to perform the required analysis.

          Finally, since the EIS has revealed a significant
difference in the design average annual flow at Southerly
and provided an economical means of achieving a normal
hydraulic capacity for the wastewater flows at Columbus,
an independent quantification of design flows has not been
a waste of time, effort, and money.  The need for such
effort can be attributed to the lack of justification in
the Facilities Plan in deriving these flow values and the
apparent neglect in addressing normal hydraulic capacity
considerations.
4.1.59    Comment;  The anaerobic stabilization of heat
treated sludges must be considered an unproven process.

          Response:   Agreement with this point was clearly
expressed in the EIS (see Appendix J).   It must be pointed
out, however, that the cost for trying this process is
minimal, and provisions for its abandonment if unsuccess-
ful have been incorporated into the EIS proposal.
4.1.60    Comment:  Waste heat recovery boilers have been
proposed, but not installed at either plant.

          Response:  The EIS statement has been changed to
recommend that the proposed waste heat recovery boilers
be installed.
                          IV-126

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4.1.61    Comment;   The information in Table IV-15 has not
been adequately documented.

          Response;  Please see the response to Comment
3.1.48 of OEPA in Chapter 3 of this volume.
4.1.62    Comment;   The beginning of the paragraph at the
top of page IV-51 is missing.

          Response;   The missing text has been incorporated.


4.1.63    Comment;   Scheme C Thermal Conditioning-Anaerobic
stabilization indicates that sludge cake is recycled to
the main drain, is this true?

          Response;   The bottom II pointing to the left
should have been III in Scheme C-l and has been corrected.
We cannot believe that this caused any question in a re-
viewer's mind since the remaining four schemes show a correct
identification.

4.1.64    Comment;  The EIS  indicates the  farmer  should
pay  for the application of sludge to farmland.  Normally
it is just the opposite.

          Response;  While this is generally  the  case, no
operation should be conducted  for a loss.  As a first step,
the  City should still  attempt  to cover operating  expenses
for  their vehicles and drivers.  Also see  response to
comment  3.1.50.

4.1.65    Comment:  The City believes a  more  indepth analy-
sis  of the present oxygen production and dissolution sys-
tems must be performed.  A quick solution  which has not
been field tested for  several  years is-not the answer.
There is no lack of manufactured diffuser  socks  for  the
Columbus aeration system.

          Response;  The EIS does not suggest a quick solu-
tion (See Appendix J).  The  Facilities Plan did not sug-
gest that an in-depth  analysis was going to be performed.
The  EIS suggests this.  Our  interviews with plant personnel
and  Mr. Walkenshaw led us to believe that  there was a lack
of manufactured replacement  socks and fittings.   The com-
ment has been  deleted.
                          IV-127

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4.1.66    Comment:  Preliminary evaluation of belt pres-
sure filter systems indicated low processing capacity for
invested capital, with large numbers of moving pieces and
intricate systems indicating potential for severe main-
tenance problems.

          Response:  The EIS suggests the testing of such
a system:  testing which was not underway during the plant
tours conducted for the EIS.  The City's experiences with
belt pressing should be evaluated against their experiences
with thermal conditioning.  The intent here is to remind
the City that continued investment in thermal conditioning
may not be the wisest course of action.
4.1.67    Comment:   Anaerobic digestion of thermally con-
ditioned sludges or decant liquors has been explored by
Columbus and should be further evaluated.

          Response:  Further evaluation of any data avail-
able to Columbus is an excellent approach.
4.1.68    Comment:  The need for an adequate air supply
to meet demands of increased solids and the effect of
contact times to remove soluble organic materials have not
been discussed.

          Response:   Appendix K defines the design condi-
tions and recommended oxygen transfer needs.  Air supply
cannot be defined until a dissolution system is selected.
The design provides adequate solids contacting for removal
of soluble oxygen demanding pollutants.  If the reviewer
believes this not to be the case, he should so state with
a supporting rationale.
4.1.69    Comment:  Requiring the City of Columbus to de-
sign to 5 gpm/SF is specifying the equipment manufacturer
and eliminating competitive bidding.

          Response;  The designer could obtain an indexed
prebid guarantee from the manufacturer of the proposed
system and alternatives which are allowable under lower
hydraulic loads and perform a cost-effective analysis.
Alternately, he could prepare drawings and specifications
for each filtration alternative to assure competition.  The
lack of competition should not be used to penalize the manu-
facturer of a potentially superior system if significant
savings can be derived.
                             IV-128

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4.1.70    Comment:   We do not agree with the EIS  recommen-
dation that first  stage biological treatment be eliminated
at Southerly.

          Response:  The elimination of first stage biological treatment
 at Southerly is contingent upon the provision of load reduction and flow
 equalization at the brewery at a level at least the equivalent of that
 defined by Scenario 2.  If a Scenario 2 treatment scheme proves to be
 inadequate for Southerly in the future, then implementation of Scenario
 3 at the brewery will become the cost-effective solution.
4.1.71     Comment:   The pump station for  trickling filters
at Jackson Pike is  sized for 220 mgd to allow for "a 20 mgd
credit  for recycled flows".  This shows the  danger inherent
in making  recommendations based on design approach different
from that  used in the Facilities Plan.

           Response:  The Facilities Plans made no such
allowance  for any recycle flow volume, nor did it consider
buffering  the effluent filter backwash or a  programmed
return  of  any recycle.  A  recycle credit  of  20 mgd at the
trickling  filter pumping station was chosen  to assure flex-
ibility and to highlight the fact that recycles must be
considered.   Where  recycle flows are applied obviously
depends upon the anticipated quantity and quality char-
acteristics.   Provision of an extra 20 mgd at the trick-
ling filter pumping station would have no economic impact
while assuring future flexibility.
4.1.72     Comment:   The EIS, contrary  to  prudent design
practice,  assumes design removal rates near  the higher
limits  of  generally observed range of  removal  rates.   By
adopting this practice, it shows lower loads on subse-
quent treatment facilities which then would  be sized
smaller than would normally be required.

           Response:   These comments  show  the danger of
blind use  of manuals, and ignore key questions such as
the  soluble  and particulate influent and  effluent char-
acteristics  for each pollutant and the hydraulic loadings
applied to the sedimentation tank.   The design influent
wastewater quality characteristics for Jackson Pike are
                              IV-129

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clearly  developed in Appendix I.  In Table  1-15,  it is
clearly referenced that some phosphorus  insolubilization
can be expected  due to the heavy metal load  contained in
the Jackson Pike influent.  This situation was  revealed
in the course  of preparing this EIS by brief sampling
and analysis of  the influent and by the  iron content in
the Jackson Pike sludges.  The value used is believed
to be conservatively stated.

          The  assumed particulate BODj value and volatile
suspended solids concentrations are both reasonably de-
fined, in our  opinion.  Therefore, the key question is
what removal efficiency would be expected for an applied
suspended solids concentration of 240 mg/1 with a  volatile
content of 70  percent and a surface overflow rate  of 880
gpd/SF.  58 percent was used.  Acceptance of this suspended solids removal
efficiency and the  particulate phase characteristics  for BODc and phosphorus
automatically yields the efficiencies defined in the  EIS.  This procedure
is more valid than  that found in the Facilities  Plan  which uses constant
removal efficiencies for suspended solids (50%), BOD5 (30%), and phosphorus
(30%) with uniquely different wastewatersuunder  simitar  hydraulic loading
rates.
4.1.73    Comment;   On trickling filter  design recommenda-
tions, the  EIS  claims a 65 percent  substrate removal, while
the design  equations are not shown.   Further, the EIS rec-
ommends against the use of pilot studies to determine
precise design  parameters for trickling  filters.

          Response:  The EIS could  find  no  valid reason
why the trickling filters at Jackson  Pike and Southerly
were designed in the Facilities Plan  for exactly the same
hydraulic loading rate, since the organic load at both
plants would be so  different in form  and mass.  The sizing
recommended at  Jackson Pike in the  EIS represents cost-
effective utilization of synthetic  media treatment in a
first stage application.
                             IV-130

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          We  agree with the  reviewers comments  concerning
the magnitude of unknowns  in the design of  synthetic media
installations.   We did not use  formulas but preferred to
use curves  provided by a representative manufacturer.
These data  suggest that a  70 to 75 percent  soluble organic
removal  is  an envelope of  poor  return for investment and
that a 60 to  65 percent soluble organic removal represents
a more cost-effective expenditure.  It is difficult
to assume any overall removal from a trickling  filter com-
plex and believe that it should be designed in  view of
the anticipated oxidation  and synthesis with  a  separate
design of the sedimentation  system. The EIS assumed an effluent
suspended solids of 30 to  35 mg/1 on an average day basis
with a surface overflow rate of about 1400  gpd/SF.  If
the Facilities Plan is designed on an overall basis for
suspended  solids and BODc , we are  curious  as  to how adjust-
ments  in design for different hydraulic loading rates are made.


 4.1.74    Comment:  There are problems  in  operating  in con-
 tact stabilization  to  step  aeration mode when  complete
 nitrification  is  desired...   it  is  very  doubtful the  EIS
 proposed single stage  nitrification will  meet  the NPDES
 requirements... the EIS  proposes  no additional clarifi-
 cation tanks.

          Response:  The  comments on the recommended activated sludge
 system result  from the complicated nature of nitrification kinetics
 and their practical  application as well as the intent of the  recommended
 system of the  EIS.   The recommended  system, although  it does  make use
 of a return  sludge reaeration  capability, does not  in any way reproduce
 the short aeration or substrate to solids contacting  times found in
 conventional contact stabilization which the manual refers to.  The
 EIS Southerly  system has  been  designed to handle a  nitrogen peak
 1.8 times the  average day  value,  under a liquid temperature of 10°C,
 and in recognition of the  nitrifier  dilute-out found  in single state
 systems.   We are confident that the  proposed system will meet the
 NPDES requirements.
           The use  of  arbitrary criteria in the sizing  of
 any sedimentation  system is not recommended.  It is noted that
 the surface overflow  rate of 500 gpd/SF is the same design
                                IV-131

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value used in the Facilities Plan's Alternate I analysis,
whether or not the applied sludge was produced in an
oxygenated environment (MLVSS = 3700 mg/1)  or air environ-
ment (MLVSS = 2,250 mg/1)  or at different plants where a
different volatility of the activated sludge could be
expected.  The comment incorrectly assumes that the EIS design
is based upon governing thickening considerations and suggests
that the final sedimentation system is not designed conserva-
tively enough.

          There is no problem deviating from arbitrary
criteria if they can be shown to be invalid.  Arbitrary use
of a 500 gpd/SF final surface overflow rate is one such
criterion.  The table on the following page was prepared to
illustrate this point, for it shows that although the recom-
mended sedimentation area of the EIS is less than that found
in the Facilities Plan, the EIS system is sized more conserva-
tively when a solids loading parameter is used.  Although it
is recognized that solids load parameters should be used
with caution, they are certainly more valid than a simplistic
use of surface overflow rates independent of the nature
(sludge volume index) and concentration of the applied mass.


4.1.75    Comment;  The recommendation of Hydroclear filters
is not substantiated with reliable operating data, nor are
they available from more than one manufacturer.

          Response;  The EIS recommends Hydroclear as the
apparent cost-effective filtering process.   If evidence is
made available during detail design that such is not the
case, the EIS does not preclude the installation of another
filter system.  See our previous response to Comment 4.1.68
regarding competition.  It should be noted that the Facili-
ties Plan's effluent filter recommendations violated the
standards for both Hydroclear and lower rated competition.

4.1.76    Comment:  Once an air activated sludge system is
conceptually agreed upon to achieve nitrification, the
selection of a cost-effective method of oxygen dissolution
is a matter to be addressed during the final design and
could form an  appropriate part of the applicable value
engineering process.  The EIS has used this ploy to come
up with a cost "saving".

          Response:  The intent of the EIS is to
assure the consideration of an apparent cost-effective
system when final design is undertaken. Capital cost savings
are not claimed in the EIS for the dissolution system costed.
                           IV-132

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                                   Jackson Pike       Southerly

                              P.P.        E.I.S.    F.P.      E.I.S.
Proposed Sedimentation
  Area, sf                  205,000     110,000   172,400    135,000

Applied MLSS -                      ....                    ....
  mg/1                        4,100U;     1,500     3,200U'    2,000

Required R/Q to satisfy
  mass balance if return
  sludge = 10,000 mg/1         0.69       0.18       0.47      0.25

Average day waste-water
  flows - mgd                   120        110        120   85

Hydraulic  Capacity -
  mgd                           200        200        180       230

Maximum Return Sludge           103         55       87.5        90

Ave. day solids loading
  rate - Ibs/SF.day              34         15         27        13

Return Sludge Required
  under Hydraulic
  Capacity Flows - mgd          138         36         85        58

Solids load at hydraulic
  Capacity flows and
  above return sludge
  lbs.SF.day                     50         29         41        36
 (1)  Obtained from our evaluation of the Facilities Plan (Appendix I)
     since this document reported only MLVSS.  We used 55 and 70 per-
     cent volatility for Jackson Pile and Southerly, respectively.
     Although this solids loading rate is only slightly less than
     that found for the F.P., it should be noted it is handling
     some 28% more influent wastewater.
                                 IV-133

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4.1.77    Comment;  The cost-effectiveness of ozonation
compared to chlorination - dechlorination - post aeration
system should be examined.  The former precludes the gen-
eration of chlorinated hydrocarbons while the latter does
not.

          Response;  The Facilities Plan did not mention
that an aerated chlorine contact tank was envisioned, nor
did it mention the air requirement or the planned means
of supply for such a tank.  Whether or not this is pro-
vided, we know of no conclusive data that suggest that the
NPDES permit requirements for chlorine residual and fecal
coliform can be consistently met without dechlorination.
Post aeration after dechlorination was provided in the EIS
since overdoses of S0~ may deplete dissolved oxygen.  The
references to Kappe and Koth-andaraman in the comments are
meaningless unless actual fecal coliform and chlorine  resi-
duals are known, as well as the temperature and quality of
the test wastewater and the experimental conditions of the
investigation.

          Although reduced chlorine residual is certainly
a present and future concern (and is addressed in the EIS),
an equally pertinent point can be made regarding the need
for year around disinfection (see pages IV-16 through 18 of
the EIS).  If the installation of ozone equipment can be
justified in light of future disinfection requirements,
the EIS does not preclude its implementation.
4.1.78    Comment:   For wet stream treatment, the EIS
(p. 19, 20)  shows savings in first cost over the recommen-
dations in the Facilities Plan of $10.2 million and $16.8
million at Jackson Pike and Southerly,  respectively.  These
"savings" are not true savings, as most of them are arrived
at by adoption of design criteria even beyond the higher
limit of accepted design criteria without acceptable justi-
fication or pilot testing.  Also, the impacts on the annual
cost of operation and maintenance of the plant with and
without brewery are not throughly analyzed by the EIS.
This "Saving" is thus doubtful.

          Again, it must be emphasized that these apparent
"Savings" are shown by using value engineering techniques
(without insuring reliable plant operation through reliable
design) which are irrelevant at this preliminary planning
stage.
                             IV-134

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          Response;  This is truly a critical point.   Two
important points must be made regarding costs:

               All costs are approximate and are based on
               Facilities Plan estimates.

               The bulk of the savings at Southerly are
               due to Brewery pretreatment, the alternative
               shown to be cost-effective in the EIS.  In
               fact, if the Brewery did not pretreat, total
               net possible savings at both facilities
               would be reduced to only $22 'million with a
               minimum  (~$3 million) savings at Southerly.
4.1.79    Comment:   We strongly disagree with the recommenda-
tion of the EIS that pilot plant study be carried out only
to evaluate anaerobic digestion of thermally conditioned
secondary solids and jet aeration.  As already pointed out
before, in absence  of any reliable design equation which is
universally applicable for the design of trickling filters,
development of design criteria by pilot testing is the only
choice for large plants.

          Response:  As mentioned previously, we fail to
see how an extensive pilot plant program would serve a
tangible benefit under the recycle problems which plagued
the plants at the time of the preparation of the Facilities
Plans and the EIS.   The comment is still framed in gen-
eralities.  It should specifically explain how to achieve
the listed goals at what plant, under what time frame, for
                             iv-135

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what expenditure,-with what control, with what simulated
stress, and with what size equipment under the present
operation at both plants.  The EIS recommendations were
for full-scale testing of considerations not influenced
by the spin-around of solids or liquids.
4.1.80    Comment:   The 200 mgd assumed hydraulic capacity
at Jackson Pike must be verified.

          Response:  The 200 mgd hydraulic capacity at
Jackson Pike was obtained through a review of the avail-
able unit sizing as published by consultants to the City.
4.1.81    Comment:   The City of Columbus has a sewer use
ordinance which is  being enforced at the present time.
          Response:  The influent heavy metal levels re-
corded at both treatment facilities indicate the need for
the EIS goal statement.  In any case, the City should ini-
tiate an industrial pretreatment program to control heavy
metal discharges.
4.1.82    Comment:  The Division of Water, City of Columbus
will not allow the use of its quarry or its useful life to
be reduced with incinerator ash.

          Response;  This goal is probably worded too
strongly in the EIS.  Ultimate ash disposal is left to the
City's discretion, and if the codisposal scheme is not
internally desirable, the EIS does not wish to force its
use.  Our intent was to point out that this was a possible
outlet for the incinerator ash and, since both the water and
sewerage and drainage divisions answer to one Director, it
might be easily implemented.
4.1.83    Comment;  The City questions whether contact
stabilization proposed at Southerly for nitrification is
practical.

          Response;  Please see the response to comment
4.1.74.
                             IV-136

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4.1.84    Comment:  The EIS proposes to put  180 mgd through
the filter complex at Jackson Pike and 205 mgd at  Southerly.
Since the EIS is proposing to treat 200 mgd  at Jackson Pike,
why isn't the remaining 20 mgd being filtered?

         Response:  This point is addressed on page IV-78  of the
EIS.  There is  no reason to overtreat during a condition which must
coincide  with swollen stream flows.
4.1.85    Comment;  The NPDES limits and  the  water  quality
standards have both changed so the original chlorination
concept is no longer valid.  The EIS recommends  standby
polyelectrolyte addition capability.  An  air  flotation sys-
tem will not work at all without some type of polymer  ad-
dition.

          Response;  We agree that the  disinfection system
proposed in the facilities plan does not  address the
disinfection-detoxification needs of the  Columbus treatment
plants.

          At high solids loading rates, polymer  addition is
necessary to assure reliable performance  of an air  flotation
system; or, at lower solids loading rates, float solids
concentrations can be increased with polymer  addition.   The
EIS's recommended system uses the existing Southerly flota-
tion units with anticipated dry solids  loadings  of  10  and
14 pounds per SF/day under average and  maximum day  condi-
tions; values which do not suggest the  use of polymers
unless one or more units are out of service.
4.1.86    Comment;  Storage of thermally  conditioned solids
is not a viable concept as proved by operation  of  the
Southerly facility.  The use of digesters for thickening
of thermally conditioned solids is questionable without
expensive remodelling.

          Response;  We are not aware  of  any operational
data from Southerly which prove that storage of thermally
conditioned solids is not viable.  This data must  be
proved before we can analyze the statement, since  it may
be out of context or the operational problem may be  in-
correctly identified in terms of causative agent.
                          IV-137

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          Thickening on thermally conditioned sludge occurs
automatically in any laminar flow condition such as found
in an anaerobic digester or the sludge storage tanks.  What
are the expensive remodelling needs that the comment refers
to?  If the reference is to sludge collectors, this expense
should be weighed against the Facilities Plan's proposal of
an isolated aerobic treatment system.  We have included ap-
proximately $0.7 million at both plants for rehabilitation
of the digestion complexes to meet the recommendations of
the EIS.
4.1.87    Comment;  City Civil Service policy makes sharing
of personnel between plants an unlikely event.

          Response;  The EIS is merely attempting to point
out a potential way to save operating expenditures.  Perhaps
this plan could be implemented by new position descriptions
with elimination of the old through natural attrition of
personnel.  This EIS took no cost credit for this contingency.

4.1.88    Comment;  The EIS has suggested or implied that
land disposal of sludge offers many advantages or benefits.
However, the EIS fails to select any specific sites for any
land disposal and does not discuss potential impacts associ-
ated with any sites.

          Response;  Land disposal sites for strip mine
reclamation have been generally specified as being both
the quick-start areas identified by ODNR (page IV-48)
and the publicly-owned strip-mined land in Perry County.
In addition, the potential sites and impacts will be
thoroughly addressed in the additional sludge handling
facilities planning.


4.1.89    Comment;  The EIS offers no documentation to sup-
port the discussion of air quality impacts as related to
the Columbus situation.

          Response;  See Volume I for a revised analysis of
air quality impacts due to sludge incineration.


4.1.90    Comment;  The institutional changes suggested
would tend to be exclusionary and the legality is question-
able.
                            IV-138

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          Response:  The EIS does not recommend  institu-
tional changes to prohibit development.  Rather  the EIS
indicates that growth can and will occur in nonsewered
areas and that the regulatory agencies responsible for con-
trolling onsite discharges from package plants and private
disposal systems might consider various options  to improve
overall performance of waste disposal systems in the non-
sewered areas undergoing or targeted for development.


4.1.91    Comment:  The cost of private disposal installations
are substantially understated.  Operation and maintenance
has not been mentioned and historically has been very poor.

          Response:  Installation costs for a conventional
septic system were obtained from Columbus, Ohio, sources
and appear to be reasonable with cost estimates  obtained in
other similar urban areas.  However, depending on the site
and the type of system installed, costs may, indeed, run up
to $5,000 per house.  Operation and maintenance  costs simi-
larly will vary anywhere from $35-70 for a conventional tank
pump-out to several hundred dollars if repairs or replace-
ment to existing equipment is needed.  A conventional sys-
tem adequately designed and properly installed should re-
quire cleaning or pumping only every 2 or 3 years.  However,
if the system has been poorly designed, sited, or installed,
it may require cleaning every 6 months.  Poor operation and
maintenance histories are common throughout the  country and
cannot be considered unique to the Columbus area.  Localized
facilities planning must identify the O&M problems, and
recommend and implement the cost-effective alternative.  This
will minimize or eliminate inadequate on-site systems in the
planning area for the planning period.

4.1.92    Comment:  Table VII-1 does not represent the proper
flow and costs in Central Ohio.

          Response:   The use and relevance of the cost data
presented in Table VII-1 have been referenced in the text.
4.1.93    Comment;  The EIS is evidently not aware of the
development pressures in the Blacklick watershed.  If sewers
are not provided, this will result in unsatisfactory instal-
lations and pollution problems.

          Response:  Pressures for development in Blacklick
or any other outlying area need not be curtailed because
of public decisions not to sewer.  Rather, development can
                           iv-139

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be encouraged to occur within environmentally compatible
guidelines and with the improved regulation of onsite sewage
disposal systems.  Over the long term the improved manage-
ment and regulation of onsite systems can be much less ex-
pensive than sewering.  Unsatisfactory installation prac-
tices resulting in pollution problems can and should be
prevented in any case.
4.1.94    Comment:  While some demand may be placed on the
City of Columbus where the already serviced developable
areas are located, a review of local agency files will show
that as much or more demand is made where services are not
located.

          Response;  Please see response to comment 3.1.71.
4.1.95    Comment:  Where is the support for this EIS con-
clusion?  The absence of interceptors has not stopped the
growth.

          Response;  The point the EIS has repeatedly made
is that the Columbus sewer system and the various proposed
expansions will not significantly increase or decrease the
total population growth anticipated for Franklin County.
Rather, the impact that the sewer expansions will have is
on the distribution of that population growth among com-
munities and areas within the county.


4.1.96    Comment;  The EIS conclusion for Blacklick is
totally unacceptable, because all the facts were not taken
into consideration.

          Response;  Please see responses to comments made
by the City of Reynoldsburg in Section 4.1.3 of this volume,
4.1.97    Comment:  Appendix A contains many incorrect
statements and assumptions which significantly effect the
proposals and decisions made in the EIS.  The most impor-
tant of these errors deals with the EIS procedure for es-
tablishing design influent wastewater characteristics for
the City's Jackson Pike treatment plant, and results in
proposed treatment facilities which are obviously and signi-
ficantly undersized.  Therefore, all portions of the EIS
regarding the facilities to be constructed at Jackson Pike
must be considered inaccurate and should be disregarded.
                            iv-140

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          Response;  The identification of so-called
in Appendix A is very disturbing, since the  City was  given
the opportunity to comment on, and provided  with draft  ver-
sions of, not only this Appendix but also Appendix  B  and
Chapter IV  (which originally included Appendix  I) .  It  was
the intention to resolve all conflicts in baseline  data
early in report preparation  (the City was supplied  these
documents in July, 1977) .  No objection was  expressed by
the City to the conclusions drawn either in  a July  6, 1977,
meeting or in the intervening time frame.
          It is recommended that the City provide an  itemiza-
tion of so-called "errors" prior to initiation of design
work.
4.1.98
4.1.99
Comment;   The Southerly Plant receives flow  from
the 156" interconnecting sewer as well as the  108"  inter-
ceptor.

          Response;  The statement has been revised.
Comment:  The EIS states that the Facilities  Plan
was prepared using 1973 and 1974 recorded plant  influent
data.  Only by coincidence, did the  Solids  Handling  Segmen-
tal Plan develop design data that equaled 1974 plant influ-
ent data.

          Response:  Footnote (1)  on Table A-2 will be deleted.
                              IV-141

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4.1.100   Comment;  The EIS states that, in 1972, the  City
considered thermal sludge conditioning as  "the panacea for
the solids handling and recirculation problems that  still
plague the Jackson Pike plant".  This statement is incor-
rect.

          Response:  The use  of the word "panacea" has been
deleted from the text.
4.1.101   Comment:  Regarding the receipt and impacts  of
the  'night soil1 dump station on influent wastewater quality
at Jackson Pike, the EIS should have cited the load in
pounds per day of pollutants, not in gallons per day of
flow.

          Response;  The impact of this source can be  quickly
identified by the flow volume cited, about 0.025 mgd.  If
the  scavenger waste solides concentration is taken as
15,000 mg/1  (reflecting the collected mixed vault contents
of a septic tank), then in 1971 this source contributed
about 5 mg/1 of influent SS; a value too insignificant to
be the source of the change in influent suspended solids
concentrations noted in 1975 and 1976.

4.1.102   Comment:   The City disagrees with the data used to
establish influent quality parameters at Jackson Pike.

          Response:  The EIS states that the dramatic  change
in influent quality is due to recycle loads and upstream
bypassing.  It did not state the percentage increase.  The
Facilities Plan did not consider this recycle load in  any of
their published documents.  In fact, the Unit Operations
Process Schematic for Jackson Pike published as a portion of
the cost-effective analysis of the Plan specifically shows
this recycle to be to the filtrate tank, with the flow from
this tank sent aeration.  Interviews with the plant staff
suggested that no recycle to the influent sample point
did occur;  it was only after repeated questioning that
this situation was discovered.  However, it is not certain
that this recycle sewer contains only decantate consider-
ing  the manner in which sludge streams and their separate
liquors are moved around the plant.  The data presented
in Attachment 2 is in no way conclusive proof that the
EIS  is wrong, as we do not know the duration of the 1976
sampling program, the sampling point, the compositing
technique and time.  More conclusive proof could be
                            IV-142

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provided by sampling the influent before and after the
point of recycle introduction for any extended period of time
(daily samples over several months).

          There are two key points in this discussion.  First,
what is the difference in the EIS and P.P. influent quality
characteristics?  Values are repeated below:

                             EIS

         BOD5 = 210 mg/1 @ 110 mgd = 190,000 Ibs/day
         SS   = 240 mg/1 @110 mgd = 220,000 Ibs/day


                    Solids Handling P.P.

         BOD5 = 190 mg/1 @ 120 mgd = 190,000 Ibs/day
         SS   = 270 mg/1 @ 120 mgd = 270,000 Ibs/day

From the above, if the EIS influent quality and mass for
BODS is wrong, then so must be the Facilities Plan.  The
significant difference rests with the 50,000 Ibs/day of
suspended solids.
4.1.103   Comment;   Based on the data presented in the pre-
ceding comment, the EIS 1976 Estimated Influent Character-
istics presented here are again significantly in error.

          Response:  We disagree (see preceding response)
until an alternate explanation which justifies the plant's
records is provided.
4.1.104   Comment:  The EIS states that the low flow reported
in 1971 for the Southerly Plant was due to the bypassing
associated with expanding the plant's main treatment capa-
bility.  This statement is believed to be inaccurate.

          Response;  The flows in question really do not
affect the conclusions of Appendix A from 1973 on, and the
discussion as to bypassing during construction could be
                            iv-143

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dropped.  However, no data  are  provided to justify the com-
ment and are probably not available,  since by-passed flows
were not monitored historically.
4.1.105   Comment:  The  continuous recirculation of solids
about the plant is probably caused by inadequate solids
handling and disposal  facilities.

          Response;  The statement has been revised.
4.1.106   Comment;  The  EIS  stated blower capacities are
believed to be inaccurate.

          Response:   The firm influent pumping capacity of
Jackson Pike will be  changed in the EIS from 170 mgd to
165 mgd.  The EIS will read  that there are two 21,000 cfm
blowers and four  15,000  cfm  blowers in the influent pump
building.


4.1.107   Comment:  Existing Jackson Pike aeration tank
volume is cited incorrectly  in the EIS.  Although this
EIS Error is only about  5.2  percent, it is just as or more
significant than  the  reduced population projections used
in the EIS.

         Response:   The sizes reported in the EIS are those of the
Facilities Plan.  The revised population figures of 1.025 million have
been acknowledged by the City to be consistent with other projections.

4.1.108   Comment;  The  areas of the existing final sedimen-
tation tanks at Jackson  Pike are slightly overstated in the
EIS.

          Response;   The tankage called out in the EIS is
one-quarter of the plant volume of the Facilities Plan.

          The EIS does not mean to imply the historic use
of the three abandoned tanks.   Their mention in conjunc-
tion with the sedimentation  tank is merely because all four
are the same size.
4.1.109   Comment:  The existing  supernatant aeration tank
volume is actually 5.0 mg.

          Response:  The figure has  been corrected.
                            IV-144

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4.1.110   Comment;   The EIS states that no further expansion
of the solids handling and incineration system at Southerly
was thought necessary by the City.  This statement is com-
pletely false.

          Response;  The statement has been deleted.
4.1.111   Comment;   The EIS states that historically the
Southerly Plant has long been plagued by hydraulic problems.
This statement is incorrect.

          Response;  As described on Page A-28, it is the
return sludge pumping limitations which cause the breakdown
in liquid stream processing at Southerly in conjunction with
the many solids handling inadequacies.
4.1.112   Comment;   The EIS statement that the Southerly
Plant has never fully achieved sustained, stable performance
because of unit process limitations with the 'as received1
wastewater load is believed to be incorrect.

          Response:  This comment seems to indicate that
the admitted bulking problem at Southerly is due to solids
handling limitations rather than the nature of the "as re-
ceived" wastes.  This is hard to believe, and we contend
that effluent deterioration due to carryover of bulking
sludge could occur regardless of the adequacy of solids
handling equipment.  Page 67 of Volume One of the Cost
Effective Analysis of the Facilities Plan, would seem to
support the EIS statement.
4.1.113   Comment;  The data presented in the EIS for the
existing Southerly aeration system are incorrect.

          Response;  The tanks may presently be operated in
a step-aeration mode, but they were not being operated in
this manner at the time of the plant tour by the writers of
this EIS.  In fact, it may very well have been the review
of the draft submittals mentioned earlier that promoted the
changeover to a step-aeration mode at Southerly.  Such an
operation should give a better load distribution, poten-
tially higher dissolved oxygen levels throughout the
aeration system, and allow a lower MLSS to be applied to
the final settlers.
                             IV-145

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          The EIS stated capability of quarter-point addi-
tion has been changed to correspond to the points listed  in
the comments.  Dimensions of the aeration tanks stated in
the Facilities Plan were used to derive the volumes listed
in the EIS.
4.1.114   Comment:   The problem with the Southerly incinera-
tors was probably due to the fact that the operators were
originally trying to feed the incinerators at the same rate
as had been done before with the wetter cake.

          Response;  The EIS is merely quoting the opera-
tors.  Thermally conditioned cake is known to result in
upper hearth burning without modifications of the incinera-
tor and operational practices.
4.1.115   Comment:  Why is the BOD5 test suspect in this
EIS discussion and not in other sections of the EIS regard-
ing recorded influent wastewater characteristics?

          Response:  BOD5 values, when considered alone,
are regarded as suspect by the EIS throughout.  However,
better correlation between BODc and SS is evidenced in
reported influent concentrations than effluent, which is
the point of the discussion commented upon.  This should
be expected, as raw wastewater typically contains a colloi-
dal suspension which, in comparison to a biologically sta-
bilized, flocculated, and clarified effluent, will show
poorer suspended solids settleability at equivalent concen-
trations and settling conditions.
4.1.116   Comment;  To the City's knowledge, no proof  has
ever been offered by anyone to substantiate the statement
that the severe bulking problem at the Southerly Plant
is caused by the brewery waste discharged by Anheuser-Busch.

          Response:  The City specifically noted this  state-
ment when discussing the draft submittals and did not  object
to its inclusion.  We must retain this contention until
proven otherwise, for the circumstantial evidence is over-
whelmina.  Further work in this area since publication of
the draft EIS substantiates this finding.  See Appendices AA and BB
for further discussion.
                              IV-146

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4.1.117   Comment.;   The brewery waste is cited here in the
EIS as 40 to  60  percent of the nominal BOD5 Load at the
Southerly Plant.   This  is not consistent with the 37 per-
cent cited  on Page A-2  of Appendix A of the EIS.

          Response;   The 37 percent value cited on Page A-2
is specific for  the breweries records (which the City cau-
tioned us in  using)  in  January, 1976.  The 40 to 60 percent
range on Page A-28 is for the entire year.  Figure 1-1 shows
the chronological  variation of the plant's influent BOD,-.
We see no inconsistency.
4.1.118   Comment:   The EIS models were not verified by
meaningful  in-stream sampling.   The models and results ob-
tained therefrom do not have credibility and probably jus-
tify the deletion of Appendix B entirely and any EIS de-
cisions made  thereon.


          Response;   The general comments made could apply
as well to  the modeling activities of both the OEPA and
the Facilities Plan,  since  hypothetical flowing loads are
analyzed in all  instances.   Criticism of specific model
inputs used in the  Facilities Plan beyond effluent flows
and loads is  difficult  since none were published.  There is
essential agreement in  all  modeling results, however, and
we are. not  sure  if  the  comments imply the EIS is too severe,
too lenient,  or  simply  too  detailed.
          We believe that the caveat on Page B-l is necessary as a
cautionary statement.  We find that too often modeling efforts and
descriptions do not adequately describe the  assumptions,  uncertainties,
and input values.


4.1.119   Comment;   There was no  attempt made to verify the
DO Model.   (From Attachment  3, City of Columbus)

          Response;  Given the practical constraints in
terms of  time and resources,  committing substantial resources
and time  to verify  a situation when the modeling results
of three  independent entities (OEPA,  the Facilities Plan,
and the EIS) all show essentially the same result is a waste
of time and resources.   True  verification can only be achieved
with installation of the proposed facilities and achieving
the anticipated effluent quality  under the seasonal flow
regimes of interest.  Verifying the input parameters at
                            iv-147

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other conditions is misleading because of sensitivity con-
siderations in terms of these same inputs, the model's out-
put, and often, the analytical tolerance of the measured
constituent.  If the comment could identify the questionable
assumptions used in this modeling effort, the alternatives,
and the results thereby desired, we would gladly discuss
the arguability of each effort.
4.1.120   Comment;   The equation used in the EIS is a modi-
fied Streeter-Phelps model which assumes constant values
for the parameters K]_, K2, and K3 and therefore is inappli-
cable and cannot be used as an analytical tool.

          Response;  The equation stated on Page B-3 is the
cornerstone of all commonly conducted stream modeling acti-
vities.  The parameters mentioned are adjusted at specified
reaches and subreach points, a fact which is certainly known
to the City.  Or is the City arguing for:

          constant values for K]_, K2, and K3 - (a seemingly
          naive desire), or

          a new equation -what is the alternative?
4.1.121   Comment;   It seems likely that the K-^ values em-
ployed in the EIS are excessively large and predict a DO sag
more severe than can be reasonably expected.

          Response:   We have not seen the 1937 study men-
tioned, but question whether the Jackson Pike effluent made
up nearly the same percentage of the downstream flow as it
does under the proposed plan.  The comment also seems to
indicate that the CBOD coefficient derived in this study
does not vary with temperatures greater than or equal to
20°C.  To understand and interpret the comments, we would
like to see the report.  Key questions include:  How was
K2 calculated?  What were the dissolved oxygen profiles?
What were the sampling stations?  Was ammonium present?
What was the time of travel in various stream stretches?
How many samples were taken and at what frequency?  Did
the study include day and night samples?  Was an attempt
made to define long term BOD values?  We don't, question
the data in this report, only the interpretation.
4.1.122   Comment:   The assumption of simultaneous exertion
of CBOD and NBOD appears to be unwarranted and predicts a
DO sag more severe than can be reasonably expected.
                             IV-148

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          Response:   Again,  to respond to this point we
need to  see  the  report.   Key questions include:  What  is
the similarity of  the rates  observed in a quiescent 300 ml
BOD bottle to those  found in the stream?  Were any samples
taken closer to  the  Columbus plants?  How was the N30D
measured?  What  were the river flow conditions at the  time
of sampling? What was the entire data base instead of the
average?  Does the City really mean to imply  that it
expects  no nitrogen  oxidation in the river until a time of
travel of about  8.7  days has elapsed?


4.1.123   Comment;   As the EIS population projections  differ
only 6 percent from  the  Facilities Plan,  we question the
validity and necessity of using the EIS projections.

          Response:  The EIS  projections are as  valid as any others
 particularly given information published prior to the Draft EIS.
 Further analysis has  led us to identify 1.025 million as the most
'appropriate number to use in Step 2 design work  for the wastewater
 treatment plants.

4.1.124   Comment;   Table 1-2 contains several errors.


          Response:   This transposition of the BODc and SS
data in  the  table  was not caught in internal review.   The
text on  Page 1-30  shows  that correct values were used  in
comparing the P.P. and EIS influent quality and pollutant
mass.  All values  have been  changed to agree with this
comment.
4.1.125   Comment;   Table  1-10 of the EIS contains several
errors.

          Response;  According to page 84 of Volume 1 of
the Cost Effective Analysis  of the Facilities Plan, the
existing decant tank at  the  time of Plan preparation is 35
feet in diameter.  The values quoted in the EIS assumed the
construction of a duplicate  tank (which was underway) along
with the addition of the single extra tank proposed in the
Plan.

          We understand  these four tanks to be 35 feet in
diameter with a 13.5 SWD.  The Jackson Pike value has been
changed to 5.1 mg from 5.4 mg.
                              IV-149

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4.1.126   Comment;  Table 1-11 of the EIS contains several
errors.

          Response;  The values have been changed to $5.1
million from $5.2 million and $31.4 million from $31.6
million.

          The footnote has been changed to state O&M costs
are for 1995.


4.1.127   Comment;  We would insist that of equal or more
importance than influent wastewater characteristics and
final effluent quality objectives, is a third parameter
known as 'unit process design and sizing1.  The authors of
the EIS have neglected this third and important parameter.

          Response;  We would agree that unit process sizing
is important, and feel confident in the parameters selected
for use in the EIS.  Indeed, in several instances we are
more conservative than the Facilities Plans in system re-
quirements, as summarized in Table K-3 which shows:

         19 recommended expansions (c) and additions
           (e), and

        16 recommended contractions  (d) and elimina-
          tions (g)

Further, although it may superficially appear that we are
not conservative enough, in many instances (as shown pre-
viously with the final sedimentation systems), we are ac-
tually more conservative than the Facilities Plan with al-
ternate design parameters.


4.1.128   Comment;  Without verification of water quality
predictions and NPDES effluent limits, imposed NPDES final
effluent limitations are lacking in credibility.

          Response;  The criticism of this comment could
have been made as easily of the Facilities Plan.  All pre-
dicted modeling done for critical low flows on the Scioto
River has  shown contravention at NPDES levels and all
(OEPA, Facilities Plan, and EIS) have recommended construc-
tion of facilities required for the NPDES specified efflu-
ent.  The door is left open for future additions, and we
doubt that any evidence can be presented for treatment
capabilities less than those of the NPDES permits.
                             IV-150

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4.1.129   Comment;  The EIS states that the 85 mgd average
design flow for the Southerly Plant could substantially
increase if a combined sewer overflow pollution abatement
program is undertaken on the Southerly collection system.
However, the EIS neglects this possibility in its actual
design of the Southerly Plant Facilities.

          Response;  This cannot be done without a defini-
tion of flows as a function of time and quality character-
istics.  Treatment facilities should be provided once the
needs of a CSO pollution abatement program are properly
defined.
4.1.130   Comment;  The validity of the formula for develop-
ing process peaks is questionable, and, therefore, some
rationale for its use should be presented and verified.

          Response;  This formula is merely used to define
process peak flows for design.  We feel that it states a
flow which will occur with a frequency corresponding to a
four hour peak in a one week period.  We used this internally
at Columbus.  Process design for a reliability  (e.g., 97.6
percent) beyond this point is generally not cost-effective.
4.1.131   Comment;  Assuming that the use of the EIS process
peak formula can be justified by USEPA, the EIS Southerly
design process peak flow should be 135 mgd, not 130 mgd.
The EIS habit of rounding off figures compounds errors and
significantly affects results.
          Response:
                             0 95
                    1.95 (85)     = 132.7
          The EIS is rounding off to "the nearest 10 mgd for
flow peaks.  We feel a round off to 135 mgd is insignifi-
cant.
4.1.132   Comment:   The EIS states that the existing conduit
hydraulic capacity at Southerly is 230 mgd.  This statement
is highly questionable.
                            IV-151

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          Response;  Information supplied during preparation
of the EIS led us to believe that both plants contained con-
duit capacity for the cited flows.  If not, they should be
reduced for the true values and one or both plants should be
expanded to assure that at least twice the design average
flow of each plant or 390 mgd (and maximum recycles) can be
treated by the collective Columbus treatment works.
4.1.133   Comment;   What are the "knowns" regarding future
influent wastewater characteristics for Jackson Pike?

          Response;  The knowns are represented by present
wastewater characteristics and flows, and results of the
analysis presented in Appendix A.
4.1.134   Comment;  The figures in Table 1-13 are obviously
wrong, therefore the EIS proposals regarding the Jackson
Pike facilities must be considered inadequate.

          Response;  The EIS methodology produces the loads
shown for 1995-2000, while the basis for calculation of
the loads in the comment is unknown.  See the response to
Comment 4.1.102 for more discussion.
4.1.135   Comment;   If the same EIS methodology is used
and Table 1-13 is corrected for the wrong assumption made
in regard to recycle loads, the EIS influent design para-
meters will be significantly higher than those used in the
Facility Plan.

          Response;  No other reasons (bypassing and recy-
cles) for the dramatic rise in the Jackson Pike influent
suspended solids and, to a lesser extent, BOD^ are known.
The Facilities Plan and associated document did not adequately
discuss the situation.  In terms of the bypassing, if it
did not occur and the EIS did not attempt to quantify it,
the average day flow at Jackson Pike would have been lower.
4.1.136   Comment;  The EIS did not demonstrate the cost
effectiveness of such allowances (unforeseen industrial
load), as required, in the cited guidelines.
                            iv-152

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          Response:  The cost-effectiveness of providing
this additional loading at the time of original construc-
tion rather than as a separate future add-on to the pro-
posed facilities should be evident.  However, if the re-
viewers of the EIS can present data showing the value of
such a future addition and a reduction in initial sizing,
such a system is not precluded.
4.1.137   Comment:   The City - Brewery agreement was not
informal as referenced in the EIS.

          Response;  The word informal will be changed to
formal.
4.1.138   Comment:  The EIS should account for the possi-
bility of a combined overflow pollution abatement program.

          Response ;  See the response to Comment 4.1.129.


4.1.139   Comment:  Table 1-15 for the Jackson Pike Plant
is incorrect because of errors in Appendix A re:  influent
wastewater characteristics.

          Response;  See earlier responses . (4 . 1. 102 and 4.1.133)


4.1.140   Comment:  The EIS should justify use of its es-
timates for the volatile fraction of the influent suspended
solids for the plants.

          Response ;  The influent volatile suspended solids
measurements for Southerly were provided by the plant op-
erators.  The values given for the first four months of
1977 averaged 79 percent with a monthly average range of
71 to 85 percent.  It seemed reasonable to conclude that
the Jackson Pike volatile solids were lower due to normal
   c and SS considerations and recognition of the heavy
metal load received at the plant.  We  are  unaware of
data that would invalidate these assumptions.
                            iv-153

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4.1.141   Comment;   The City believes that pretreatment at
the brewery does not, in fact, eliminate the need for
two-stage treatment, nor will it result in significant cost
savings as stated in the EIS.

          Response;  The percentages stated do not reflect
the parameter of concern, soluble BOD5 associated with the
brewery waste, which, due to its simple carbohydrate nature,
is more rapidly biodegradable than complex domestic contri-
butions.  As shown in Table 1-15, the brewery is anticipated
to contribute more than 50 percent of the soluble BOD  com-
ponent at Southerly without pretreatment.  With pretreat-
ment,  (Scenarios 2 and 3 in Table IV-1), a 35,000 Ib/day
soluble BODj. reduction is anticipated at Southerly.  Thus,
on a soluble basis, the remaining brewery BOD load is only
25 percent of the total received at Southerly.
4.1.142   Comrent;  The EIS authors should be aware of these
revisions (solids management system) and USEPA approvals,
and should have considered same in formulating the EIS docu-
ment.

          Response;  We were not made aware of approval by
the U.S. EPA or the pending application during our inter-
views .
4.1.143   Comment;  Figure 1-2 shows the ash decant in the
Facility Plan as overflowing to the Scioto River.  This
is incorrect.

          Response;  Statements in the EIS as to ash lagoon
overflow to the Scioto under the Facilities Plan have been
deleted.
4.1.144   Comment;  The figure quoted from the Facility
Plan for Waste Solids Management costs at Southerly should
be $31.4 million.

          Response;  The correction has been made.
                              iv-154

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4.1.145   Comment:  Ash lagoon overflow returned to the
plant influent in the EIS is not a deviation from the
Facility Plan proposals.  The overflow may be more appro-
priately returned to other downstream processes.

          Response;   The EIS does not preclude lagoon over-
flow to alternate main stream points.
4.1.146   Comment:  Where is the presentation of the EIS
mass balance concepts for each unit process?  Calculations
and criteria should be included in the EIS as well as the
results.

          Response:  It is unclear as to whether this com-
ment questions that mass balances were ever done or com-
plains as to their not being included in a document that
has already been severely criticized for being overly
technical.  Tables K-l and K-2 provide sufficient process
information for review purposes along with the individual
process discussions in the remainder of Appendix K.
4.1.147   Comment;   Little or no costs have been included
in the EIS proposals for modifications to the digesters or
for the pumping stations required to make the sludge force
main operational.

          Response;  Again, operation of the force main as
originally proposed during EIS preparation has not been
retained by U.S. EPA as a part of the initial project plan,
therefore no costs are included.
4.1.148   Comment;   The EIS does not reflect the City's
present program to  investigate anaerobic digestion and other
recycle management  alternatives.

          Response;  If the City knew of this process prior
to the July 6,1977 meeting with Havens and Emerson, they
disguised it well both in their questions and interest ex-
pressed.  Perhaps the City's program could be attached to
the EIS, describing the methodology and results obtained to
date.
                            IV-155

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4.1.149   Comment:   The EIS proposed  50  percent reduction
in the trickling filter installation  at  Jackson Pike is
unrealistic,  and will affect downstream  processes signifi-
cantly.

          Response:   See previous responses to Jackson Pike
trickling filter questions.  In regards  to oxygen transfer,
the Facilities  Plan  merely lists the  air requirements, and
does not include oxygen needs nor assumed oxygen transfer
efficiencies.
4.1.150   Comment:   The City recommends  the use of 3/4
percent  sludge  as the basis for design of the downstream
solids processing facilities at Jackson  Pike.  This would
result in a  requirement for three more thickening units.

          Response:   The majority of  the waste secondary
solids from  Jackson  Pike will be sloughed trickling filter
humus.   A solids concentration of one percent or more is
normally achieved easily with this  source of solids.
The activated sludge from the secondary  system should
easily concentrate to one percent based  upon historic SVI's,
an old CRT, and dosages  of metal  salt.  With proper pump selection
and polymer usage, it is possible to derive a greater production from
a centrifuge to satisfy  emergency conditions. Note that differences
in the number of thickening units selected is more due to differences
in the design influent suspended  solids.  Since  the EIS believes a lower
value is more correct and ends with the same number of dewatering units,
it is more conservative  than the  P.P.  in this controlling unit  process
step.
4.1.151   Comment:   The EIS suggests  that,  at Jackson Pike,
standby equipment auxiliaries for the thermal conditioning
process may  be  a  more economical option  than a new unit.
Operating experience in this regard is questionable.

          Response:   The City should  present informa-
tion to support the  contention that the  thermal conditioning
system experiences  significant downtime  due to problems
                               IV-156

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with the heat exchanger and reactor rather than the system's
auxiliaries.  In answer to storage questions, Jackson Pike's
digesters do have a huge storage capability.  We do not
understand the City's contention that storage of thermally
conditioned sludge may be technically nonfeasible due to
changes in dewaterability and believe data should be sup-
plied to justify this contention.
4.1.152   Comment;   Where are the "Excess main stream treat-
ment facilities" the EIS suggests could be abandoned, and
direct return of recycles to main treatment units has his-
torically proven to be a problem.

          Response;  We do not believe that direct recycle
of decantate and filtrate or centrate derived from concen-
trating thermally conditioned solids has been shown to be
a problem if their impact has been anticipated in design.
Indeed, today this practice is recommended by the manufac-
turers of the thermal conditioning equipment as the one
where success is most likely.  Further, odor control is most
easily achieved by this concept as operating experience at
Columbus and elsewhere suggests.
4.1.153   Comment;   It is not "equally certain that dis-
solved air flotation offers savings in terms of O&M ex-
penditures" as stated in the EIS.

          Response;  The EIS only questions the abandonment
of existing facilities which may have failed due to over-
loading.  At this time, we don't believe that centrifugal
thickening has been conclusively shown to be superior to
dissolved air flotation for waste secondary sludge.  We
note that if disc centrifugation is chosen  (it was not clear
in the Facilities Plan) its pretreatment needs can be quite
significant (screening, degritting, etc.).  We agree that
since the installation of thickening centrifuges for Southerly,
the argument for retaining DAF at Southerly is now academic.
4.1.154   Comment;  Belt press trials have been conducted
at Southerly and indicate O&M problems.  Ferric chloride
conditioning, as suggested in the EIS, is unthinkable, and
abandonment of the existing thermal conditioning process
                             IV-157

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is not cost-effective at the present time.  All of these
suggestions probably would have recycle management problems,

          Response:  We assume that the argument against
ferric chloride is due to iron "clinker" formation.  The
City should note that Jackson Pike has an iron content
in its sludge of about 2 percent already.  The EIS never
said only inorganic conditioning chemicals could be used
and would suggest using conditioning chemicals which per-
form best for the service needs.

          The EIS in no way suggests the present abandon-
ment of thermal conditioning, and the comment is in agree-
ment with statements made in the EIS regarding future aban-
donment if the operation of these units becomes untenable.

          The closing comment as to recycle impact is
merely a semantic argument by the City.  Thermal condi-
tioning systems have unique recycle impacts, especially in
terms of the energy required to stabilize solubilized pol-
lutants.  It is these unique impacts which are the point
of the EIS statement.  We are merely trying to point out
that if a maximum day standby thermal conditioning system
and isolated aerobic liquor treatment system are necessary,
as suggested in the Facilities Plan, perhaps a re-evalua-
tion of conditioning and dewatering alternatives is in
order in light of the plant's operating experience with
thermal conditioning.
4.1.155   Comment:   We do not believe that the California
investigations proved that "the dewaterability of the solids
remains only marginally less than the undigested thermally
conditioned product."

          Response:  We would agree that these effects
must be investigated.  We did not know that alternative re-
cycle investigations were underway at the time of the July
6th meeting with the City, and if the need for such investi-
gation was considered in the preparation of the Facilities
Plan no mention of it was included in the published documents,
The stated and costed means of recycle stabilization in the
plan was by isolated aerobic treatment, a process which has
proven to be unsuccessful in actual operation at the
Columbus facilities.
                            IV-158

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4.1.156   Comment;  The flow diagrams for alternatives
B2 and Cl are believed to be incorrect.

          Response;  In alternate B.2, an arrowhead has
been placed on the waste sludge from the return sludge
line to ahead of the thickening unit.  In alternate C.I,
II to the left has been changed to III.
4.1.157   Comment:  Since the Contra Costa project involved
a sludge-garbage waste application system, its direct ap-
plicability to pyrolysis of sewage sludge is questionable.

          Response;  Test data from Contra Costa were with a
refuse/sludge mixture.  However, both Envirotech and
Nichols offer present information for pure sludge systems,
which we describe.  The EIS deliberately leaves all options
regarding pyrolysis or starved air combustion open for de-
tail design.
4.1.158   Comment;  We would suggest that the proposed con-
ventional incineration facilities be designed with a view
toward starved air combustion.

          Response;  The suggestion is appropriate and has
been incorporated within the text.


4.1.159   Comment;  The EIS discussion on phosphorus re-
moval and intermediate sedimentation are duplications of
Facility Planning efforts.

          Response;  The EIS considers  several  items
regarding phosphorus removal not mentioned in the Facilities
Plan, including the possibility of reduced future influent
levels.  It is this possibility that pointed toward the
choice of metal salt addition, for the economic analysis
under present conditions (which was not included in the
published Facilities Plan)  was extremely close  (See
Table J-3 of the EIS).   Finally, the Facilities Plan was
not clear as to point (or points) or metal salt addition
nor the anticipated production of metal hydroxy phosphates.
                              iv-159

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4.1.160   Comment;   The EIS should not have used one manu-
facturer's name unless it also mentioned names for the other
systems discussed.

          Response;  The maintenance-intensive dissolution
system presently utilized at both Columbus wastewater treat-
ment facilities prompted the EIS to include a discussion
of an alternative system, and in no way precludes considera-
tion of other air dissolution systems which can be shown
to be cost-effective.
4.1.161   Comment:   The EIS recommends evaluation of just
one aeration system.  Several systems need to be evaluated
with a detailed evaluation study done at Step 2.  Hence,
the final EIS cannot include the results of this detailed
evaluation.

          Response:  The City is correct in that such a
consideration can not be finalized in any version of an
EIS.

          Most of these comments have been addressed pre-
viously.  The analysis of intermediate settling is pertin-
ent to Jackson Pike only, and brewery pretreatment is as-
sumed throughout Appendix J.  To say that the EIS conclu-
sions put the City in a position of hoping for electrical
rate increases in regards to aeration systems is unsupported
either by the analysis of the EIS or the realities of elec-
trical rate trends.  The conclusion on page J-20 clearly
states the likelihood of the present worth of the jet
aeration system being within ten percent of the apparent
least cost alternative.  If rates stay the same, the cost
to the City to operate the jet aeration system will be less
than the other methods evaluated, a savings which would be
accentuated by any future rate increases.  This comment
carried a substantial verbal impact at the public hearing
on the EIS,
4.1.162   Comment:  The dewaterability of straight thermally
conditioned waste secondary sludge is known to be considerably
less than the dewaterability of a mixed thermally condi-
tioned sludge.
                            IV-160

-------
          Response:   The EIS makes provisions for the de-
watering of a decanted thermally conditioned sludge either
directly following conditioning or after anearobic diges-
tion.  The constant comment on the anaerobic process is
remarkable, for the EIS is only proposing an evaluation of a
system using facilities which would be abandoned under the
published Facilities Plan proposal.
4.1.163   Comment;  The EIS Recommended Project Plan Design
Conditions in Table K-l are incorrect for Jackson Pike and
have not been justified for Southerly.

          Response:  See pertinent previous responses.


4.1.164   Comment:  Table K-2 in the EIS is based on removal
efficiencies, many of which are believed to be over opti-
mistic.

          Response:  These comments have been addressed
elsewhere and we believe they provide a reasonable quanti-
fication of system performance for average day conditions.
The reviewer should remember that the Southerly influent
already reflects the pretreatment benefits by the brewery.
We note that the Facilities Plan ignored the soluble compo-
nent of the Southerly influent BOD5.  In regards to Attach-
ment 4, we would remind the reviewer that systems generally
perform to residuals which in turn dictate efficiencies -
not the reverse.  The peaking factors were used to establish
processing needs under maximum conditions.
4.1.165   Comment;   The EIS sludge process stream charac-
teristics shown here and used for design of the solids
handling facilities at the Columbus plants, lead to some
serious questions regarding the EIS recommended project
plan.

          Response;  We believe that the assumptions made
are clear in these tables and that they are overwhelmingly
clear in comparison to those found in the Facilities Plan.

          1.   The minimum maximum day Jackson Pike diges-
               ted solids to dewater should be 98,000
                             IV-161

-------
     Ibs/day - not 198,000 Ibs/day.   Supporting
     data show 98,000 Ibs/day value  was used.

2.    An eight percent solids content for a therm-
     ally conditioned, anaerobically digested
     sludge is not unrealistic to us when it is
     remembered that without anaerobic digestion
     a good design number is 10 percent or more.

3.    A one percent secondary solids  concentration
     is not optimistic when it is remembered
     that Jackson Pike's sludge will be dominated
     by sloughed humus.  At Southerly, the bulk-
     ing component has been eliminated by pretreat-
     ment at the brewery while the activated
     sludge system has received the  beneficial
     densification characteristics derived from
     a old cell residence time and the accumula-
     tion of metal hydroxy phosphate precipitates.

4.    The solids capture efficiencies are believed
     reasonable.  If values substantially less
     than these are encountered, chemical aids
     should be added to avoid needless suspended
     solids recycles and handling.

5.    Cake solids concentrations used in the EIS
     do not significantly differ from those used
     in the Facilities Plans.  Since the Facili-
     ties Plan assumed a lower influent suspended
     solids volatility, it is likely that their
     cake volatility is essentially  the same.
     We note that the sludge cake volatility in
     the Facilities Plans suspiciously stays at
     60 percent for both Southerly and Jackson
     Pike with their two uniquely different
     wastewaters and different assumptions for
     influent suspended solids.  Finally, note
     that the EIS's anaerobic digesters offer
     the potential use of digester gas as a sup-
     plementary fuel source for the  incinerators
     if autogenous sludge cake conditions are not
     achieved.
                  IV-162

-------
          6.   Section K.2.9 o'f the EIS shows that the
               Facilities Plans' dewatering system was
               undersized for realization of the maximum
               incineration capability.
4.1.166   Comment;  The EIS again suggests that the exist-
ing Jackson Pike facilities are rated at 200 mgd.  The
City questions the accuracy of this statement.

          Response:  The EIS includes rehabilitation or
replacement of the sedimentation tanks. See previous comments
on hydraulic capacity.

4.1.167   Comment:  It is probably more cost-effective to
provide larger trickling filters.  Also the EIS proposes
a 5 percent increase in the size of the Jackson Pike
Intermediate Settling Tank area.  Were costs for this in-
crease included?

          Response;  See previous trickling filter responses.
The cost difference, although minimal, is included in the
EIS.
4.1.168   Comment;  The EIS proposes surface overflow rates
for secondary settling tanks considerably in excess of
normal practice, acceptable Ohio EPA standards, and USEPA
design manuals.

          Response:  Please see appropriate responses to
earlier comments on surface overflow rates.
4.1.169   Comment:   The EIS authors had better be sure
that suitable performance levels can, in fact, be main-
tained with the high overflow rates.-

          Response:  It is believed that testing, if it could
be done, would show that the design offered in the EIS
would perform equivalently or superior to the design de-
fined in the Facilities Plan at equivalent plant flows.
4.1.170   Comment:  The EIS should present some justifica-
tion for the assumed values used in determining peaking
factors for waste solids production.
                            IV-163

-------
          Response;  We believe they are reasonable.  Present
operation anddata available at both plants largely pre-
clude the establishment of plant specific values.
4.1.171   Comment;   The EIS states that, under the Facility
Plan proposal, neither plant would ever realize its maxi-
mum incineration potential due to the fact that the plant's
dewatering capability did not match the rated maximum
solids loading capacity of the incinerators.  This state-
ment is false.

          Response:   After reconsideration we still think
the statement in the EIS is true.
4.1.172   Comment:  In Table K-5, the average dry solids
content of the sludges to incineration is 32 percent to
34 percent.  It is doubtful that the EIS process schemes
will yield these contents.  The EIS should furnish a de-
tailed diagram with calculations showing the entire sludge
processing system at both plants and the design parameters
used.

          Response;  Excluding the presence of the anaerobic
digesters, the EIS used a similar waste solids handling se-
quence as the Facilities Plan and similar cake solids.  We
would expect similar performance.

          The EIS did not mean to suggest that the force
main should be run at 105 gpm, but rather that this re-
flects the transport needs.  It does suggest the transport
of thermally conditioned and anaerobically digested solids.
The visualized system would dilute these solids down with
settled wastewater to the required transport concentration.
The pipeline's pumping system should be designed to assure
turbulent flow.  At 4 percent solids, we would suggest a
velocity on the order of 5 fps or, for the 8-inch diameter
pipeline, a flow rate of 790 gpm.  For a 1 percent solids
concentration, we would suggest a velocity of 1 fps or a
flow rate of 160 gpm.  In both cases, we would recommend
that the incoming sludge be diverted to Southerly's pri-
mary sedimentation system, where it should reconcentrate
to some 8 percent solids  (since it remains as a conditioned
                             IV-164

-------
 sludge),  causing the minimal recommended increase  in  dewater-
 ing capability.  Whether  or not it is more cost effective
 to pump a short time with high head losses or a long  time
 with low head losses is beyond the scope of the EIS;  super-
 ficially, the 1 percent case is most attractive.
 4.1.173   Comment:  The  City does not agree with the  EIS
 concepts and proposals for  solids handling and disposal.
 First, construction of pumping stations for the sludge
 force main is less cost-effective and has higher O&M
 problems than additional incineration.  Second, the long
 term potential of applying  dewatered thermally conditioned
 solids to strip mined land  is not believed to be as great
 as suggested in the EIS.  The City has been studying  this
 alternative for about a  year.  Third, using the dry solids
 figures in the EIS and correcting for the attainable  dry
 solids content of the dewatered cake, 4 incinerators  will
 be required at both Southerly and Jackson Pike.  Fourth,
 it is inappropriate for  the EIS to consider installation
 of the new dewatering centrifuges in the existing vacuum
 filter building.  Construction of a new building housing
 six centrifuges has already been funded by USEPA and  is
 presently under construction.  Fifth, it is doubtful  that
 the water plant solids disposal quarry will be available
 for use for incinerator  ash disposal.  Its entire capacity
 is needed for water plant solids, and OEPA will not approve
 its use for codisposal of incinerator ash.  And last, it
 is unlikely that the EIS proposal with their significantly
 reduced facilities will  permit reprocessing of the solids
 from the existing Jackson Pike lagoon.


          Response:  See Volume  1 for a discussion of findings regarding
incineration.  The proposal to apply sludge to strip mined  lands  will be
free of the daily pressures of being the sole ultimate sludge outlet, and
we believe it can be properly  evaluated  under these conditions.

          If the quarry is not available for ash, the EIS  in no way
requires its use.  The EIS does not propose reprocessing of soilds
from the Jackson Pike lagoon.
                              IV-165

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4.1.174   Comment;  On April 24, 1978, a letter from Robert
C. Parkinson concerning the report entitled "Draft Environ-
mental Statement-Wastewater Collection and Treatment Faci-
lities-Columbus, Ohio" November 14, 1977, prepared by
Booz, Allen—Havens and Emerson, Inc. was received.

          The essence of this April 24, 1978, letter ques-
tions revisions that the U.S. Environmental Protection
Agency (EPA) made to the Draft Environmental Statement  (DBS)
report from Booz, Allen—Havens Emerson prior to issuing
the Draft Environmental Impact Statement (DEIS).

          Response;  The working relationship between
USEPA and its contractors is defined in the document:
"RELATIONSHIP OF EPA WITH CONTRACTORS & SUBCONTRACTORS  IN
THE EIS PREPARATION PROCESS..." which is included in Volume
II Appendix HH.        The responsibility for content of the
Draft EIS is that of USEPA and as such USEPA has sole
discretion as to the appropriateness of the subject material.
The 14 points identified in the April 24, 1978, letter  repre-
sent changes that were made by USEPA to produce the most
objective analysis possible consistent with the knowledge
concerning cost-effectiveness and environmental effects
(impacts) as determined by USEPA.  Response to these 14
points are as follows.

     1.   As of February 1978, the air modeling of primary
impacts associated with the incineration alternative was
inconclusive and therefore no one could state that incinera-
tion would provide the reliability desired without adverse
environmental impacts, nor could it be demonstrated to  be
the lowest cost alternative.

     2.   It is not necessary to state that USEPA directed
itself since the EIS is our document.

     3.   By law the No Action Alternative must be considered
and evaluated.  See response to City of Columbus, March 30,
1978, comments for discussion of Hoover Reservoir.

     4.   We agree that the cost sensitivity analysis itself
does not establish cost-effectivenes.  Analyses of Chapters
3 and 7 lead  us to conclude that preparing designs based on  an ultimate
population concept are generally not cost-effective for the
Columbus area.  This section of the final EIS has been
appropriately revised.

     5.   The passage omitted was determined to be misleading
by USEPA.
                             IV-166

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     6.   There is no evidence that a parallel sludge
force main is the most cost-effective way to provide for
the flexibility and reliability required.

     7.   See response to comment #1.

     8.   Since the City has the authority and responsi-
bility to restrict toxic substances from their sewer system,
they are the ones who control the ultimate composition of
their sludges and its disposition.

     9.   The sections omitted by USEPA were determined to
be misleading.

    10.   We believe the DEIS wording to be more objective
and accurate.

    11.   One point of view is that any operation and main-
tenance expenditure by the City should be minimized irre-
spective of the capital costs involved.  This approach does
not satisfy the requirements of a cost-effective analysis
which states that all alternatives shall be evaluated and
compared on a present worth basis.  When this is done both
capital and Operation and Maintenance costs are included
in the analysis, and the conclusion that can be drawn then
reflects more completely the economic costs to society.
In addition, the primary impacts of the incineration alter-
native were inconclusive at the time the  DEIS was issued.
See response to comment #1.

    12.   We believe the revised discussion to be more
accurate and objective than the paragraph omitted.

    13.   The air modeling analysis by The Ohio Environ-
mental Protection Agency (OEPA) did not support that sen-
tence in the DES.

    14.   We believe the revised discu'ssion to be more
accurate and objective than the draft version.
                           IV-167

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4.2  City of Columbus Division  of Water

-------
4.2
          TOM MOODY

            MAYOR


     KOUCRT C  PARKINSON. P f.

      DIRECTOR OF PUBLIC SERVICE
                                                                    JACK A HOLT. P F
          CITY   OF   COLUMBUS

                       OHIO
                  DIVISION OF WATER
                    9O W. BROAD STREET
                  COLUME.US. OHIO 43215
                           March 14, 1978
         TO:     D.  D.  Robbins, P.E., Supt.
                Division of Sewerage and Drainage

         FROM:   Jack A.  Holt, P.E., Supt.
                Division of Water
         RE:
Review of Columbus Fap'iJ/ities Plan E.I.S.
         Dear Mr.  Robbins:

         First we  wish to thank you for the opportunity to review and
         comment on the referenced E.I.S.  insofar as it pertains to the
         operation of our Division.  We are sure you can appreciate that
         time does not give us the opportunity to study all related docu-
         ments in  great detail.  We have found the E.I.S.  concerns us
         directly  in the following ways:

              1.  Adequacy  of Water Supply
              2.  Protection of Hoover Reservoir
              3.  Protection of Ground Water in vicinity of our proposed
                  Southern  Well Field
              4.  Solids Disposal
              5.  Water Rates
              6.  Water Reuse

         We will comment on each of these  items.

         1.  ADEQUACY OF WATER SUPPLY

         On page 11 the following  statement is made, "The  ability of the
         area's  economy to  support additional  population and the adequacy
         of water  supplies  may be  more significant determinants of popu-
         lation  growth and  development patterns than availability of
         public  sewer services."
                        QUALITY WATEI7
                                                 REASONABLE
                                        IV-168

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                                                                 -2-
D.  D.  Robbins,  P.E.                       March 14, 1978
Page 2


On page 11-42 the  following statement is made, "The region faces
the following constraint:

        Inadequacy of water supply",

"Sufficient water  is available at least through the year 2000.
This estimate,  however, takes into consideration the development
of deep water wells  and the possible  damming of Big Darby Creek.
Therefore, the siting of manufacturing units requiring large
quantities of water  is constrained.   Provided the economic growth
continues to be focused on the trade  and service sectors, water
supply problems may  not develop."

On page 11-57 existing safe yields are reported as lOOmgd.  This
figure is based upon the worse drought of record.  Some of the
central Ohio streams have rather short records and as a result
all yields are currently being reported on the basis of a 50 year
drought (98% dependable supply).  This basis is consistent with
State and Federal  Water Supply practices.  Using the 50 year
Brought criteria.   Safe yield of existing sources (Griggs, 0'
^.:aughnessy and Hoover) is Slmgd MOT  lOOmgd.  The Alum Creek
Raw Water Supply will be available in 1978 and will add 35mgd
making the current 98% yield 116mgd.   This will be adequate un-
til the early 1980's.  Our South Well Field project is currently
under design and well construction is scheduled this year.  It
is estimated that  this project will  add 50mgd to bring our total
supply safe yield  to 166mgd.  Our estimates indicate this will
meet average daily demand through the year 1990 at which time
additional sources will need to be brought on line.

Work we have done  with the Ohio Department of Natural Resources
on the Central  Ohio  Water Plan (COWP) has identified a year 2020
supply deficiency  of lOOmgd.  The following sources are being
investigated to meet this need.
                                               Potential Yield  MGD
     A.  Scioto River Upground Reservoir            50-80
     B.  Olentangy Diversion                        20+
     "C.  South Well  Field Expansion                 20-50
     D.  Upper Darby                                30
                                                   120-180

Alternates to the  Scioto River Upground Reservoir include Mill
Creek Reservoir (38mgd) and/or Bellepoint Reservoir (GSmgd/ or
(106mgd total).

The abundance of water to meet future (year 2020) needs is indi-
cated by a statement made on page IV-13 of the E.I.S.
                             IV-169

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                                                                     — 3 —
D.  D.  Robbins,  P.E.
Page 3
     March 14,  197S
"a future water demand on the Columbus system of ebout 250mgd,
with a developable upstream reservoir safe yield of about 350rogd.
The ultimate supply from Delaware County sources was estimated to
be 530mgd."

This statement apparently is referring to data contained in Table
9a, page 45 of the Environmental Assessment Report of the Facilities
Plan.   This data was in turn taken from a 1972 report by Mid Ohio
Regional Planning Committee.  This information has been up-dated
by work on the previously mentioned Central
is scheduled for printing later this year.
        Ohio Water Plan  which
Comments made on page 11-11 require clarification as reference is
made to a total  safe yield of 352mgd with 182mgd being from sur-
face supplies and 105mgd being developed from ground supplies.
This leaves 65mgd unaccounted for.  Since reuse has been discounted
how is this to be interpreted.
                                    (4.2.1/4.2.2)
Conclus ion

We are well aware of the need for future water supplies and are
taking the necessary steps to procure same for the City of Columbus,
There are ample  available resources which can be developed to meet
Columbus' needs  through the year 2020 and beyond.

2.  HOOVER RESERVOIR

In addition to our concern for future supplies we are deeply con-
cerned for protecting existing ones.  We note a major change rec-
ommended by the  E.I.S. for the Big Walnut Sanitary Sub Area.  The
Facilities Plan  proposed an interception along the east side of
Hoover Reservoir.  The E.I.S.. recommends this be postponed until
such time as population densities  in the area approach or exceed
2 persons/acre.   The analysis indicates this should not happen
before 1985.

We call attention to the following statement on page 5 of the E.I.S,
"Many locations within the Columbus
periencing water pollution problems
tank and package plant performance.'

Also on page 10 "In Big Walnut, the
Reservoir area may stimulate growth
action."
planning area are now ex-
because of inadequate septic
attractiveness of the Hoover
with or without the proposed
We are very concerned that this situation be monitored very closely
and facilities' made available to dispose of sanitary water in this
area.  As we all know, it is a lot easier (and less costly) to
protect a source than to try to clean one up.
                               IV-170

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                                                                  -4-
D. D. Robbins, P.E.                      March 14, 1978
Page 4


The E.I.S. assumes in its density calculations that the year 2000
population will be spread out uniformly over the 24,300 acre
drainage area.  Is this likely to happen or will ir.fact there be
pressure for group (sub-divisions) concentrations.  In short, can
we depend on the Ohio EPA to disapprove any package plant requests
within the Hoover Dam Area?        ,
                                   ( 4 • <£. 3 /
3.  GROUND WATER QUALITY

On page 11-15 the following statement is made, "Wells located
close to streams and having hydraulic connections to the streams
are vulnerable to pollutants."  On page IV-13-14 discussion is
made concerning recharging the aquifers adjacent to Scioto River
in the vicinity of Walnut Creek.  The E.I.S. conclusion is that
because of nitrogen content of discharge and problems with low
flow augmentation this should not be done.

We agree.  As already mentioned we are well underway in developing
of 50mgd water supply utilizing ground waters from this very area.
Direct ground water recharge usina plant effluents should not be
considered.

4.  SOLIDS DISPOSAL

There is a considerable amount.in the E.I.S. concerning solids
handling with a recommendation that solids be disposed of at the
Water Division's Quarry on McKinley Avenue.  This recommendation
is made on the basis of the following assumptions:

     1.  Dublin Road Water Plant producing three (3) tons of
         dry solids per mg of water processed.
     2.  Morse Road Water Plant producing one and one half (1%)
         tons of dry solids per mg.
     3.  Parsons Avenue (SWF Plant) producing same amount of dry
         solids as Morse Road Plant.   (Page IV-28 & IV-29)

The E.I.S. questions the useful life of the quarry.  The City has
estimated 60 years on the basis of disposing Dublin Road Plant
sludge only and assuming a 30% compaction of solids   The E.I.S.
suggests 75 years may be more likely.   (Page IV-30)

We have reviewed this matter in some detail with our chief chemist,
Mr. Mair  (See Appendix).  It is his feeling that due to nature of
quarry and lack of decanting facilities sludge will only compact
to 20%.

Also we are presently preparing plans  to dispose of sludge from the
Morse Road Plant via a pressure pipe.line.  This project should be
on line in 1979.
                               IV-171

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                                                                  -5-
D. D.  Robbins, P.E.                       March 14, 1978
Page 5


The E.l.S.  assumption concerning Parsons Avenue (SWF) solids  is
in great error.   Solids production at this plant will be four
(4) tons/mg.

Using  average day processing rates between now and the year 2000
we estimate that the three water plants will exhaust the capacity
of the quarry by the year 2000.

We are therefore much concerned about any plans to dump other
materials into this  location.

We are very much interested in the E.l.S. recommendation con-
cerning mixing water plant sludge with secondary solids from
your plants for land disposal in surface mine reclamation projects
and suggest this be  pursued with the appropriate agencies in  the
very near future.

5.  WATER RATES

A rather minor item, but on page 11-54 a statement is made con-
cerning the discontinuing of suburban surcharges being in 1978.
The context of the statement implies it refers to both water
and sewer surcharges.  This of course is not true.

6.  WATER REUSE

This was referred to early but we feel deserves special mention.
Page IV-13 emphasizes that there should be no need to consider
reuse of waste water plant to a point suitable for potable reuse.

We wholeheartedly agree.  Recent developments in the field of
water quality analysis have shown the presence of many substances
heretofore unknown to be present.  This is going to  have a very
decided impact in treatment process, technology and  cost.  It  is
doubtful we have even come close to  identifying all  the con-
taminates in  raw water supplies.

This brings up another somewhat unrelated point.  As a result  of
the discovery of certain synthetic organics  in the various raw
water supplies the Federal EPA  is modifying  the Safe Drinking
Water Regulations to require source  monitoring.   It  would, with
the benefit of hindsight, have  been  helpful  if the discharge
permits being issued under the  Clean Water Act had included  this
information.

It might be worthwhile to suggest EPA consider revising the  infor-
mation required  to be obtained  under this permit system to include
these  new parameters.
                              IV-172

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                                                                -6-
D.  D.  Rotbins,  P.E.                       March 14, 1978
Page  6
Should you  have  questions  concerning  any of the above, please
contact  myself or  Mr.  Francis.
.JAH:JLF:kk

cc:  R.  C. Parkinson
     0.  L. Francis
     J.  R. Doutt  tx-"
     File
                            IV-173

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HUBERT C PARKINSON. P.E.     PITY  07  P II I  IT HI R II
 D.«CIO«t Of PUBLIC tc.vlCE     llljll  U 1  &J U ll IJ IVl £1 U
                                                                       —7 —
    TOM MOOtW
      MAYOR                        -- ~~ --- T =_-r^r                       SUPCNINTCMOINT
 D.«CIO«t Of PUBLIC tc.vlCE

                                  OHIO

                             DIVISION OF WATER
                              9O W. BROAD STREET
                             COLUMBUS. OHIO 43215



                             March  20, 1978
    To:     Mr. D. D. Robbins , Superintendent
            Division of Sewers and Drains

    From:   Jack A. Holt, P.E. ,
            Superintendent
    Subject:  Columbus - E./L«§^ /Additional Comments
                                  -
    Reference is made to our submittal to you of March 14, 1978.
    Upon further review of the E.I.S., it appears some additional
    comments are in order.

    Adequacy of Water Supply.

    On Page 2 of our memo we make reference to recent analysis of
    future water demand and potentail developable resources.  The
    results of this analysis showed a year 2020 need of an addi-
    tional 100 mgd with resources of 120 to 180 mgd.

    The footnote at the bottom of Page II-U2 of the E.I.S. implies
    that Upper Darby may not be able to be developed due to adverse
    environmental considerations and that if such were the case, it
    would have an adverse effect on the region's water supply capa-
    bility - to the extent growth and industrial development would
    be seriously impaired.

    First of all, we point out that the analysis showed other re-
    sources as available to meet water needs even if Upper Darby
    cannot be built.   Secondly, we have completed an indepth
    environmental assessment of the Upper Darby Project which iden-
    tifies adverse impacts and suggests methods to eliminate or
    reduce them.
                               1.
                  QUAUITY WATER -            - REASONABLE COST

                                    IV-174

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                                                                  -8-
Since the Upper Darby Project is the only future alternative
that has been studied in great detail and the only one with a
"proven" yield at this point - in time it obviously plays a
major role in our future planning.  It would be in error to
conclude that the area growth and economy will depend on
this one project.   We feel our average daily demand projec-
tions include sufficient allowance for industrial growth or
expansion through the Year 2000.

The decision to limit industrial users need not be made on
the basis of inadequate water supplies.   It is, or should be,
entirely a local option.

Hoover Reservoir.

There is no mention in the E.I.S. of the effect of the
Galena-Sunbury waste discharges into Hoover Reservoir.  It
would seem that at least one regional solution to be consider-
ed would be interception of these wastes by a Columbus trunk
instead of "treated" discharges directly to the Reservoir.

JAH:bc
cc:     Director Parkinson
        J. L. Francis
        J. R. Doutt
        File
                            IV-175

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4.2       City of Columbus/ Division of Water


4.2.1     Comment;  The discussion of safe water yields and
water supply needs in the Columbus area need modification.

          Response;  The discussion and references to safe-
water yields and supply needs has been modified where recom-
mended.
4.2.2     Comment;  The safe water yields from ground and
surface waters on page 11-11 need clarification.

          Response;  The figures have been modified.
4.2.3     Comment:  We are very concerned that the Hoover
Reservoir area be closely monitored to detect deterioration
in the water quality due to malfunctioning septic tanks,
poorly operated package plants and development exceeding
environmentally compatible levels.

          Response;  Monitoring water quality in Hoover
Reservoir is a prudent step to take which should be accompa-
nied by the "monitoring" of growth allowed to occur in the
area and improved regulation of onsite disposal systems in
the area.  The pressures to develop can be balanced by pres-
sures not to develop in order to protect the water supply.
4.2.4     Comment;  The EIS assumption concerning Parsons
Avenue  (SWF) is in great error.  Solids production will be
4 tons/mg.  We are much concerned about any plans to develop
other materials into the quarry.

          Response;  The EIS did not intend to call into
question work done by the Division of Water in regard to
the amount of solids produced at the present and proposed
water treatment plants or the useful life of the quarry.
Our only purpose in discussing the wastewater ash-water
sludge codisposal alternative was to point out a system
which would seem to be worthy of consideration by the City
in terms of both implementability and ease of future op-
eration.  If the life of the quarry is indeed only 20 years
when receiving all present and future water sludges, the
                           IV-176

-------
City is free to explore alternate means of ultimate ash
disposal - an option which was intended to be left open
in the EIS regardless of the actual projected quarry  life.
                             iv-177

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4.3  City of Reynoldsburg

-------
4.3
   ICHARD J. DAUGHERTY
         Mayor
                                                          CITY  OF

                                                    REYNOLDSBURC
                                                         7232  Main Street
                                                   REYNOLDSBURG,  OHIO 43068
                                                            866-6391
     A NOI93N 'Vd3
S3I1IAM3VP
  r
                                  May 24,
                                      FRANK T. BALDY
                                       Service Director
       United States Environmental Protection Agency
       E. I. S. Section
       230 South Dearborn Street
       Chicago, Illinois   60604

       Attention:  Mr. Eugene Wojcik

                       Re:
                            (4.3.1)

                            (4.3.2)

                            (4.3.3)
Columbus, Ohio
Environmental Impact Statement
Blacklick Creek - Reynoldsburg Area
       ijear Sir:
            This office has been advised by our City Engineer that Dale
       Luecht has requested from Malcolm Pirnie, Inc., certain information
       in regard to locating a force main in the Livingston Avenue right-
       of-way which would serve the Blacklick drainage area, particularly
       Reynoldsburg, Ohio.

            Again this office has conferred with our City Engineer, Evans,
       Mechwart, Hambleton & Tilton, Inc., and wishes to emphatically
       express the following information which, in our opinion, should be
       addressed in this alternate routing of the force main.

            (1)  Livingston Avenue is a main east-west traffic artery
                 which will be expanded to a 48-foot pavement width,
                 as is a portion of the existing pavement.  The
                 existing 60-foot right-of-way will have to be expanded
                 to 80 feet at that time.  If a force main or force
                 mains of the sizes necessary for the present flows are
                 constructed along this route, we would suggest at least
                 a 90-foot right-of-way to accommodate these force mains,
                 existing and proposed utilities and sidewalks.  Nowhere
                 along the existing route do we have 90-foot right-of-ways,
                 It would take at least one year to procure the necessary
                 right-of-ways without court action.  However, with court
                 action, at least two years would be necessary.
                                        IV-178

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                                                                     — 2 —

United States Environmental Protection Agency    -2-    May 24, 1978
     (2)  There is a highly congested and commercialized area
          of Livingston Avenue east and west of Brice Road which
          is very similar to the Main Street area.  The force
          main would have to be constructed in the pavem._nt in
          this area which, needless to say, would involve premium
          backfill, temporary and permanent repaving, together
          with the inconvenience to the abutting business properties
          and, in general, the traveling public.  In other words,
          the same negative conditions would be subject to this
          routing as that outlined in our report on the Main Street
          alternative.

     (3)  The topography along Livingston Avenue is quite different
          from Main Street, and either of two alternatives would
          have to be used to eliminate deep sewers near 1-270.
          The first would be to continue the force main to or
          across 1-270 and perhaps all the way to the Big Walnut
          Interceptor.  This, of course, would be quite expensive
          and would not allow any flexibility in future planning.
          The second alternative would be to install a second pump
          station at the low point east of 1-270 west of Brice Road.
          This is totally unrealistic due to power consumption and
          additional maintenance in a second pumping system.  The
          City of Reynoldsburg has been in a concentrated effort to
          eliminate all existing pump stations, primarily due to
          the high cost of operation and maintenance and, of course,
          reliability factors.

     (4)  The area along S.R. 256 north of 1-70 and south of
          Livingston Avenue could not be served by gravity for the
          existing or future developments.  Cost of this additional
          expense should be included in any comparison contemplated.

     (5)  The area adjacent to Palmer Road and the Cobblestone
          Subdivision east of Graham Road would not be served by
          gravity and still another pump station would be required,
          which cost would have to be included in a comparison.

     (6)  This alternative would not eliminate existing plant
          discharge south of Tussing Road, where approximately
          1?000 homes are under construction and scheduled for
          development in Fairfield County.

     (7)  There will still be extensive tunneling of 1-270 with
          this route, even though there is not an interchange at
          Livingston Avenue.
                                  IV-179

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                                                                    -3-

United States Environmental Protection Agency    -3-    May 24, 1978
     In summary, the City of Reynoldsburg together with the City
Engineer, who has been in business in this area for 51 years and
City Engineer of Reynoldsburg for 18 years, are certainly more
knowledeable of the existing features in this area, together with
access to all records and the familiarity of the future plans of
this City and the surrounding areas.

     Mr. Luecht, upon on-site observation of the Main Street routing,
certainly agreed with this office and our City Engineer that the
Main Street routing was in error.  We can only hope that detailed
study; and, in our opinion, should not be less than a detailed study,
will certainly point out that the Livingston Avenue force main
routing would be a severe error in judgment.

     Again,, we should point out the error in the long term of in-
stalling a pump station system where a gravity route exists; from
maintenance, energy consumption, operating costs and reliability.
As pointed out above, it decreases the flexibility for future
planning.


                         Very truly yours,

                         CITY OF REYNOLDSBURG, OHIO
                          rank T. Baldy
                         Service Director
FTB:js

cc:  The Honorable John Glenn
     The Honorable Samuel Devine
     The Honorable Tom Moody, Mayor, Columbus, Ohio
     The Honorable Richard Daugherty, Mayor, Reynoldsburg, Ohio
     Mr. Robert Parkinson, Director of Public Service,
         Columbus, Ohio
     Mr. Dayton Robbins, Superintendent, Division of Sewerage
         and Drainage, Columbus, Ohio
     Mr. Roger D. Willis, Division of Sewerage and Drainage,
         Columbus, Ohio
     Mr. Jim Nottingham, Ohio E.P.A., Central District Office
     Mr. Greg Smith, Ohio E.P.A., Planning Section
     Malcolm Pirnie, Inc., Attention:  Mr. Mike Macy
     Evans, Mechwart, Hambleton & Tilton, Inc.,
         Attention:  A. W. Maier, P.E.
                              IV-180

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4.3       City of Reynoldsburg


4.3.1     Comment:  We believe that several of the alternate
routings for the Blacklick Creek-Reynoldsburg area did not
consider a number of factors affecting costs.

          Response;  See revised Chapter III appended to
this volume and Interceptor discussion in Volume I.
4.3.2     Comment;   The Livingston Avenue force main routing
would be a severe error in judgment.

          Response;  See revised Chapter III appended to
this volume and Interceptor discussion in Volume I.


4.3.3     Comment:   We should point out the error in the
long term of installing a pump station system where a gravity
route exists; from maintenance, energy consumption, opera-
ting costs and reliability factors.  It also decreases the
flexibility for future planning.

          Response;  See revised Chapter III appended to
this volume and Interceptor discussion in Volume I.
                            iv-181

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4.4  Delaware County

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4.4
                                          SO CHANNING STREET

                                         DELAWARE. OHIO 4301S

                                          TBUPHONE 814-389-8781
      GARY W GILBERT. P E.

                                                   April  7,  1978
              U.S.  Environmental  Protection  Agency
              230  South  Dearborn  Street
              Chicago,  Illinois   60604

              Attention:   Planning  Branch  -  EIS  Preparation  Section
                                                   Re:   Comments:  Draft  EIS
                                                        Wastewater Treatment  Facilities
                                                        for the  Metropolitan  Area
                                                        Columbus,  Ohio.
              Gentlemen:
                        We  have  reviewed  the  above  referenced  document  and  we  have  been
              unable to  determine from that document  the  real  need  of the treatment
              portions of the system.   Knowing what problems presently  exist is  adequate
              to  justify in my mind  the need  for the  system.   However,  someone not  so
              closely related with the problems would have  difficulty in  assembling the
              scattered  (throughout  the document) data and  information  into a  justifiable
              conclusion.   We therefore suggest that  a summary of present water  quality
              problems and  their extent be  developed  in the Final EIS.    ,4 . ,,

                        We  have  also found  inconsistencies  concerning statements in regard
              to  planning areas, West Scioto  Interceptor  alternatives and Big  Walnut
              Interceptor alternatives.

                        The statement on  page III-4 and III-5  item  (6)  regarding the
              Sunbury-Galena area may mislead readers regarding the area  to be studied by
              Sunbury, Galena, and Delaware County.  The  study area as  officially
              designated (by Ohio E.P.A.) for the Sunbury-Galena and Delaware  County area
              includes all  of the Duncan  Run  drainage area  to  the divide  between Duncan
              Run and Rocky Fork drainage areas, except for a  small  portion on the  east
              side at Hoover reservoir between the  mouth  of Duncan  Run  and  the
              Delaware-Franklin  County line.   Therefore,  the Sunbury-Galena County  planning
              area includes all  of the area designated as (6)  and a majority of  the area
              within Delaware County noted  as area  (7).   This  needs to  be well defined in
              the Final  EIS in order to clarify those boundaries.        (4.4.2)

                        We  take  exception to  the statement  in  item  (7)  page III-5 that
              "Due to the physical layout of  this  ((Big Walnut Creek, sub  area))  and the
              following  two sub  areas (Rocky  Fork and Blacklick Creek), a regionalization
              decision made for  one  must  be implemented in  all  three."  We  have  looked at
              the proposed  alternative layouts and  find no  physical  constraints  that would
              support the above  quoted statements.  It appears to be a  conclusion of the
              writer without adequate evaluation.           (4.4.3)


                                             IV-182

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                                                                                -2-
                              Big Walnut Area

          The alternative layout of interceptor sewers in alternatives A,
B, D and Sub B on Figures 111-8,9,11 and 12 respectively would appear to
require extreme depths of cut in order to provide gravity sewer service
to the Duncan Run drainage basin in Delaware County.  Are these depths of
cut reflected in the cost analysis, or are you assuming that the service
to this Duncan Run area is by pump station force-main?   (4.4.4)

          The alternative layout of service areas in Alternate C, Figure
111-10 would appear to provide more gravity service to all  areas, and
therefore be a more desirable configuration.

          The statement that Alternative D is recommended because of
flexibility in future decision making processes is commendable.  However,
we are unaware of the reasoning by which the statement "Ultimately, the
total service option proposed in Alternative A will be implemented for
Alternative D."(Page 111-20)   Why not Alternative C or one of the others?
The Final EIS should address the reasoning behind the writers conclusory
remark.  Furthermore, that statement pre-judges the recommendations of the
Sunbury-Galena, Delaware County facilities planning yet to be performed.

          Again on page 111-35 it is assumed that regional ization of the
Sunbury-Galena, Delaware County area with Columbus has been determined.
Not so!                                                    (4.4.5)


                             Scioto River Basin


          The statement on page II I -14 regarding the Delaware County EIS
is at best misleading.  The statement implies that the Delaware County EIS
concluded that the upper reaches of the Scioto River within Delaware County
would contribute flow to the City of Columbus sewer system.  That was not
the conclusion reached in the Delaware County EIS.  The statement was:
"The remainder of the Scioto Basin in the Delaware County Planning area
may be served either by Columbus or by Delaware County.  This will be
determined through additional facilities planning performed- by Delaware
County.

          We also question the overall evaluation in the EIS of the proposal
submitted in the Facilities Plan.  The planning area does not coincide with the
Ohio E.P.A. approved boundary.                        (4.4.6)

          Thank you for the opportunity to comment on the Draft EIS.


                                     Youns truly,
                                    XGARY ^"GILBERT, ?.E.
                                     DELAWARE COUNTY SANITARY ENGINEER
cc:  Delaware County Commissioners
     Tom Elliott - Regional  Planning
                                     IV-183

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4.4       Delaware County Sanitary Engineer
4.4.1     Comment:   The presentation of water quality prob-
lems is scattered throughout the EIS and makes it difficult
to see the justification for the proposed treatment portions
of the system.

          Response:   Appendix B characterizes the Scioto
River below Columbus.  Chapter II discusses, in general,
regional surface and groundwater guality problems.

4.4.2     Comment:   Better definition needs to be given to
the planning area boundaries covered by the Delaware County-
Sunbury-Galena 201 program as opposed to the Columbus 201 plan
and EIS.

          Response:   Please see response to Comment 4 .1. 3 .

4.4.3     Comment:   We have looked at the proposed alterna-
tive layouts and find no "physical constraints" that would
support the EIS statement on Page III-5, Item 7.

          Response:   "Physical constraints" as stated, was
not written in the EIS or intended.  The terms used were
"physical layout: meaning the interdependency of total re-
gionalization of the three subareas using only one intercep-
tor as in Alternative C, three different interceptors, one
for each area as in Alternative A or D or something in be-
tween as in Alternatives B or Sub B.  Because of this inter-
dependence or "physical layout" it was decided to evalute
these three areas together, in order to obtain a true com-
parison of alternatives.

4.4.4     Comment;   The alternative layout of interceptor
sewers in Alternatives A, B, D and Sub B on Figures III-8,
9, 11, and 12 respectively would appear to require extreme
depths of cut in order to provide gravity sewer service
to the Duncan Run drainage basin in Delaware County.  Are
these depths of cut reflected in the cost analysis, or are
you assuming that the service to this Duncan Run area is
by pump station force-main?

          Response:   The cost analyses presented in the EIS
are for the proposed interceptors and do reflect the topo-
graphy of the route.  The EIS cost analyses do not include
any costs for subtrunks or collector systems for an area.
                           IV-184

-------
4.4.5     Comment;   We are unaware of the reasoning by which
the statement "Ultimately, the total service option proposed
in Alternative A will be implemented for Alternative D."
(Page 111-20)  The final EIS should address the reasoning
behind the writers conclusory remark.  Furthermore, that
statement pre-judges the recommendations of the Sunbury-
Galena, Delaware County facilities planning yet to be per-
formed.

          Again on page 111-35 it is assumed that regionali-
zation of the Sunbury-Galena, Delaware County area with
Columbus has been determined.  Not so!

          Response: The statement mentioned above has been
deleted to avoid any further confusion.  In response to the
comment concerning Page III-35 see response to comment 3.1.3
4.4.6     Comment;   We also question the overall evaluating
in the EIS of the proposal submitted in the Facilities
Plan.  The planning area does not coincide with the Ohio
E.P.A. approved boundary.

          Response;  Please see the response to Comment4.1.3.
                             IV-185

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4.5  Fairfield County

-------
4.5
                    FAIRFIELD COUNTY REGIONAL PLANNING COMMISSION
                           COURTHOUSE, LANCASTER, OHIO  43130 £WWfi°«WEN
        March 29,  1978
        U. S. Environmental Protection Agency
        Region V                                        (4.5.1)
        230 South Dearborn Street
        Chicago, IL  60604
        ATTN:  Planning Branch - EIS Preparation Section

        Dear Sirs:

        This correspondence concerns our review of the recently released
        draft Environmental Impact Statement for Wastewater Treatment
        Facilities for the MetropolitanArea — Columbus, Ohio.  Although
        the character of the complete Columbus system may impose future
        external effects upon the entire Fairfield County planning
        region, our comments are limited to the proposals made for the
        Blacklick Creek subarea (Section 3.2.5, pp. 111-20 - 111-35).
        The southern portion of this subarea contains a significant
        portion of Violet Township, Fairfield County.  (see Map I).

        The assumption upon which the accepted Alternative D was chosen
        was that the population within the subarea was not of major
        consequence, with the exception of Reynoldsburg (which is
        erroneously termed a "village", despite a present estimated
        population of almost 19,000).

             The present population within the subarea is
             estimated at 27,700.  This is projected to
             increase to 30,300 by 1985 and 41,900 by the
             year 2000.  The major center of population
             is the Village of Reynoldsburg, which is
             presently served by an overloaded contact
             stabilization treatment facility.  (p. 111-24).

        The acceptance of this assumption renders credible the proposal
        in Alternative D - the serving of Reynoldsburg by a force main,
        but dependence in the subarea south of Reynoldsburg on
        individual package treatment facilities until "a time beyond
        the planning period".
                                        iv-186

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USEPA                                                              2
March 29, 1978
_age Two


The a ~ea In question, however, has experienced major population
growth in the past, and, by all indications, will continue to
do so.  In 1970, there were less than 180 dwelling units in the
area of Violet Township within the EPA designated boundary.  In
December, 1977, there were over 620 dwelling units in the area -
an increase of 244%.  At the present time, there are over 480
additional lots which are in the platting process.  In addition,
there are approximately 300 lots in the platting process which
are outside the designated watershed boundary, but will nonetheless
be served from a package treatment facility on the Blacklick Creek
near Tussing Road.  It is anticipated that all of these lots will
be developed by the year 1985.  Moreover, most of the land north
of Refugee Road and west of S. R. 256 is owned by one developer,
who has presented plans to local officials for developing the
tract in PUD fashion, at densities in excess of what has been
experienced in the Township until this time.  Although it is not
possible to predict at this time when development will occur, it
is plausible to assume that some residential construction will
occur on this tract prior to 1985.

According to the 1970 Census, the persons-per-dwelling-unit in
Enumeration Districts 16B and 17 (which comprise the total area
of Violet Township north of Refugee Road) was 3.23.  If this
factor is applied only to those lots in the platting process,
a projected increase in population of 2520 for the Fairfield
County portion of the Blacklick subarea is obtained.  The EPA
Planning Division, in the EIS, has projected that by 1985, the
population of the entire subarea will increase by 2600 persons!

Map II illustrates present and proposed development in the
Fairfield County portion of the subarea.  In view of these
population findings, it is felt that the EPA projection for
the subarea should be reassessed.  It is anticipated that
such a reassessment will affect the viability of the
selected alternative.

Respectfully submitted,
  lilip'Nf'Boy/e, director
Fairfield County Regional Planning Commission

i?NB/mjm

Enclosures

cc:  Robert Parkinson
     Fairfield County Commissioners
                               IV-187

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                                                                     -3-
MALCOLM
    PIRNIE.
       INC.
COLUMBUS  METROPOLITAN
         AREA
   FACILITIES   PLAN
BIG  WALNUT  CREEK
  SERVICE AREA
   ALTERNATE  D	
FIGURE
 m-u
                             IV-188

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IV-189

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                                                                   -5-
                           LEGEND


H  existing sewage treatment facilities


1.  Eastwood Village - 79 lots - in platting process.

2.  Summerfield I & II - 163 units - platted and developed.

3.  Summerfield of Hunter's Run - 404 lots - in platting process.

4.  Hunter's Run - under .one control:  as yet unplatted, but
                   zoned PUD.  Some development predicted by 1985,

5,  Woodsfield - 303 lots - in platting process - within service
                 area of package plant on Tussing Road.

6.  Eastchester - 70 dwelling units - developed in 1966-68.
                  On site sewage disposal.

7.  Chevington Woods - 160 dwelling units - developed in 1966-68.
                       On site sewage disposal.

    Chevington Woods North - 226 dwelling units - developed in
                             1973-76.

9.  New England Acres 1-73 dwelling units - developed in
                          1973-76.  That portion of New England
                          Acres within EPA boundary is on-site
                          sewage disposal.
                              IV-190

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4.5       Fairfield County Regional Planning Commission
4.5.1     Comment:  The assumption upon which the accepted
Alternative D was chosen was that the population within
the subarea was not of major consequence, with the excep-
tion of Reynoldsburg.  The area in question, however, has
experienced major population growth in the past, and, by
all indications, will continue to do so...  In view of
these population findings, it is felt that the EPA projec-
tion for the subarea should be reassessed, as the reassess-
ment could affect the viability of the selected alternative.

          Response:  The EIS did not mean to imply that the
subarea population was of no major consequence.  Certainly
in an area that has a small population base, an increase
of 2600 people over a five year period can be significant.
Furthermore, consideration of several factors is necessary
in order to assess the relevance of the population increases,
recent and projected, to decisions regarding sewer system
expansion.  These factors include:  household size, density,
net development rate, and onsite system performance.

               Household size - From all indications, the
               population increases are primarily charac-
               terized by families rather than individuals
               and all adult households.  The residential
               building which is or will be occurring to
               meet these household needs is predominantly
               single-family low density housing.

               Density - Development in the area is occur-
               ring at fairly low density.  Thus the cost
               to sewer is very high resulting from the
               increased ratio of length of pipe to number
               of units served.  Additionally local collec-
               tion systems are not eligible for federal
               funding and must be financed entirely by the
               local jurisdiction.

               Net development rate - While a local juris-
               diction may process subdivisions, the actual
               build out rate for all land subdivided or
               platted may be as low as 50 percent.  How-
               ever, few jurisdictions keep records in such
                              IV-191

-------
               "retarded subdivisions" can be quantified
               and a net development rate expressed to give
               more precision to popultation projections.
               The extent to which subdivisions are not
               fully developed further increases the per
               unit cost for sewering.

               On-Site system performance - A critical and
               often deciding factor is the extent of poor
               performance from existing onsite sewage dis-
               posal systems in an area.  If the occurence
               of malfunctioning or failed systems is wide-
               spread and has been documented, then ther.e
               may be strong justification to sewer.  System
               repairs coupled with regular maintenance and
               improved regulation are frequently the cost-
               effective solution to the abatement of pollu-
               tion from poor onsite system performance.
               If the soils in various areas are simply not
               suitable for onsite systems, then legal mea-
               sures should be instituted to constrain any
               further development that will generate sew-
               age and additional wastewater.  The prevalence
               or proliferation of onsite systems should not
               be thought of as an automatic precondition
               for sewers.

All of the above factors were considered and played a part
in the recommendations regarding the Blacklick-Reynoldsburg
area.
                             iv-192

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4.6  Genoa Township

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4.6



    GENOA TOWNSHIP BOARD OF TRUSTEES

                       Delaware County,  Ohio
                                                                   .} ^r^\\!^\
                                   April 6,  1973                    tv *- N- ~ - " -


                                                                      APR 1 0 1978

        Mr.  Valdas V. Adaiakus                                               ocriOW ^
        Deputy Regional Administrator               (4.6.1)              EPA^ REGIUS 3
        U.S. Environmental  Protection Agency                            ^^MINIST^OP
        Region V
        230 South Dearborn  Street
        Chicago, IL  60604

                                         Re:  Columbus,  Ohio Facilities Plan
                                             EPA-5-OH-FRANKLIN-COLUMBUS-WWTP &  INT-77

        Dear Mr. Adamkus:

             I have reviewed the draft SIS for  the Oclumbus Facilities Plan in respect
        to regionalization  alternatives due to  conflict between the Columbus Facilities
        Plan,  delineated as area 6 on figure III-1, and the Sunbury-Galena-Delaware
        County Planning Area, which involves the greater portion of our  township.

             As you are aware, much time, money and effort  has been, and will continue
        to be, invested by  the citizens of Delaware County  to properly solve wastewater
        collection and  treatment problems throughout the more populated  areas, particu-
        larly in southern Delaware County, where the problem is most severe.

             Your approach  to the problem of the conflict  between the two entities  has
        my general support, for the problems of Sunbury-Galena and the contiguous
        Delaware County area need a thorough, in depth study of the problems and alter-
        native solutions particularly in light  of PRM 77-8  and the subsequent directive
        from Region V dated October 18, 1977 discussing implementation.

             The Columbus Facilities Plan does  not contain  an in depth study of this
        particular area, which is reasonable for Columbus,  as it has many more pressing
        problems with which to contend with its collection  systems and treatment
        processes.

             Sunbury-Galena-Delaware County area also has  pressing wastewater collection
        and  treatment problems which need solutions now so  that orderly  planning may  be
        accomplished throughout the area.

             This area  is preparing its own study, as it has the expertise available  for
        Facilities Planning, and Delaware County and its Cities, Villages and Townships
        have overall planning'goals for their urban, suburban and rural  areas which are
        sufficiently different from Columbus/Franklin. County that any planning, whether
        it Facilities Planning, or any other systems planning, for Delaware County  and
        its  subentities should not be done by the Columbus/Franklin County area.

      Water/
                                          IV-193

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                                                      ColLK'iDus,'  Ohio  Facilities ?Ia:
                                                      2PA-r,-GH-FRANKLIN~
                                                      COLUHBUS-WWTP 4 INT-77 '

                                                      Aoril  6,  1978
     I have also reviewer! the Executive Summary,  in  D-V :.; •;'. lar  oarer,  5-10,
and wi'.'h to offer some discussion concerning soveral point,:;  from  my view-
point as a rr. :ilT.h, a oublic official, and C:v.l  Engir. -T who  has beer:
actively involves in pr^parin^ and eorrr.entin?; or.  I'aeiliti-j..;  Plan?, since
United States Environmental Protection Agency's inception.

     In our particular area of Genoa Township, the conversion from rural to
suburban has been occurring rapidly over  the past  seven vears,  evnn with
restrictive zoning.   This means that waterway contamination  has increased
due to the large increase of on-site disposal systems on  one acre lots in
soils that are unsuitable for on-site disposal.   Also,  the topography and
surface drainage systems are poor, further contributing to the  problem.

     The statement ''partial service to the Big Walnut Subarea may be  neces-
sary by 1985'' (page 10) is incorrect, which causes me concern as  all  factors
in the area strongly indicate conditions  in the area must b° addressed
specifically now, not ip 1Q85.

     As part of the study of regionalization required for any facilities
plan the Sunbury-Galena-Delaware County Facilities Plan will certainly
address interconnection with the Columbus system.  This locally prepared
Facilities Plan would certainly be more realistic  concerning such an  inter-
connection should such a regionalization  concept  be  feasible both from a
cost-effective and an environmental standpoint.
                                    Yours very  truly,
                                     'atrick E. Blayney<  P.E.
                                    Genoa Township-Trustee
PEB/alh
cc:  Delaware County Commissioners
     Robert Parkinson, Service Director, City of Columbus
     Gary Gilbert, Delaware County Sanitary Engineer
                                     IV-194

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4.6       Genoa Township/ Delaware County
4.6.1     Comment;  The statement "partial service to the
Big Walnut Subarea may be necessary by 1985" is incorrect,
which causes us concern as all factors in the area strongly
indicate conditions in the area must be addressed specifi-
cally now, not in 1985.

          Response:  The analysis showed that the population
density was insufficient to warrant the construction of
major interceptors at this time.  If existing onsite disposal
systems are the source of pollution in the area, abatement
approaches other than sewering could be implemented immedi-
ately or on an interim basis until sewer construction be-
comes cost-effective for the subarea.
                            IV-195

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4.7  Hamilton Township

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4.7
                          P      c i> "  •.- ">''„-  .. • < -t fi. ..''•
                                   BO:- '.?:>-RGUTc 3
                                   ^DOi'^f.T:, OHIO-'3137

    T-I 10cr~                                                               CL£RK
    IKUSl tf;o

    GARYL,:AHN                      >lj9rJJ  29,  J975                        ALVETAEO^M
   CLYDE A. CAMPBELL                                                             49I-39C3
                                                    (4.7.1)
           UNITED STATES
           Environmental Proteoiion Agency
                   Region  7
           230 South Dearborn  St.
           Chicago, Illinois   60604

                                         Re:Wastewater Treatment
                                            Columbusj Ohio

           Attention: George 8.  Alexander,  Jr.

           Dear Sir:

           The Board of Trustees of Hamilton Township appreciate
           the opportunity to  get  information to local persons
           relative to the above,  as we all suffer much  discomfort
           from the unbearable Oder from, the Columbus Southerly
           Sewage Treatment Plant.

           We do not understand why the environmental protection agency
           would permit such a nuisance and deplorable conditions to
           continue as they have with the City of Columbus.

           We would like to go on  record asking that your  agency
           do whatever is  permissible and do this before the  Evniron-
           mental Impact Statement (EIS) is finished*  The persons
           in this rural township  should be able to cleaner,  fresher,
           air and without impurities that they now have.

           Any consideration  or corrections in this matter will be
           greatly appreciated by this Board of Trustees.
                                         HAMILTON TOWNSHIP TRUSTEES
                                        IV-196

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4.7       Hamilton Township
4.7.1     Comment;  We do not understand why the Environ-
mental Protection Agency would permit such a nuisance and
deplorable conditions to continue as they have with the
City of Columbus.

          Response:  As the EIS demonstrates, the planning
and construction of a complex sewage treatment facilities
system is subject to considerable review by local, state,
and federal governments, not only because of their respec-
tive financial investments in the system, but also because
of their continuing responsibilities to regulate and operate
the system under applicable laws.  The planning process is
also subject to public scrutiny and controversy which may
result from judgments made in regard to engineering and
planning aspects of the system.  Consensus is needed before
such major public projects can proceed, and reaching that
consensus always takes longer than anticipated.
                         IV-197

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4.8  Mid-Ohio Health Planning Division

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  ' -  / --.. X
V     " V
                   4.8
            Mid Ohio Health Fianning Federation
            hoa'lh Systems Agency r» I l^u^n Service Afcu Nun ib«< o                  May 8, 1978
            United States Environmental
               Prelection Agency                                              k
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                                                                                   -2-
                                 Comments on

               DRAFT ENVIRONMENTAL IMPACT STATEMENT

                                       for

                   WASTEWATER TREATMENT FACILITIES
                  METROPOLITAN AREA, COLUMBUS, OHIO

                                       by

                        Environmental Health Subcommittee
                 Franklin County Health Planning Advisory Committee
                    MID-OHIO HEALTH PLANNING FEDERATION
                        P.O. Box ?239  Columbus, Ohio  43216

                              Adopted: May 4, 1978

                                   SUMMARY

The Draft EIS should state clearly that the  preferred interceptor alternatives were selected so
that they would not induce suburban sprawl and will protect unique and prime farmlands. In fur-
therance of this acknowledgment, UGEPA should slate unequivocally that it will use its authori-
ty under P.L. 92-500 to pievent the deterioration of water quality in the unsewered areas. The
problems of community services and facilities, runoff, and atmospheric conditions need to be
discussed from the bases of greater and more thorough quantification.

Wo are concerned that the EIS's proposed  design for ilie Jackson Pike and Southerly Sewage
Treatment Plants is not conservative, especially since these plants represent applications of
technology for which we do not have substantial operating experience.

We are concerned that this non-conservative design will not permit the treatment plants to meet
their effluent permits and that, in fact, they will violate their permits much of the time.
cc: Ohio Environmental Protection Agency, Mid Ohio Keaional Planning Commission, City of
    Columbus, other franklin County municipalities, and Anhcunni-Busch Brewery, Inc.
                                     IV-199

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                                                                                           — 3 —

                                       COMMENTS

While the overall quality of the Draft  FJS  is fair, there are a number of inadequacies that we
will  cornniont upon.  Our comments aro  divided into two  parts, those  dealing  with  the in-
terceptor  alternatives  and those  dealing  with tho  treatment  plants  including  water  quality
modeling.

I.    INTERCEPTORS

     (a)   The initial weakness in this part of the Draft EIG's discussion is its failure to make clear
         which ot the various alternatives were the preferred ones in the Facilities Plan. This denies
         the reviewer the opportunity to weigh the two preferred options, the City's ^iid U.S. EPA's.
                                                                          (4.8.1)
     (b)   It is obvious to us from the study of the Draft f-'S that U.S. EPA in its selection of intercep-
         tor alternatives is imposing land use controls on Columbus and the involved mettopolitan
         areas without making the clear statement that it is doing so. We find this duplicitous.
                                                                          (4.8.2)
         It is clear, with respect to these analyses of interceptor alternatives, that the Draft EIS is
         following U.S. EPA policy based on the July, 1974  study, Interceptor Sewers and Suburban
         Sprawl The Impact  of Construction Grants on Residential Land Use, prepared by Urban
         Systems Research and Engineering, Inc., for the  President's Council on Environmental
         Quality (CEQ). That  policy calls for planning interceptors so  that they do not induco
         growth. However, tiie Draft EIS only implies this (its methodology follows that, in most in-
         stances, sot forth in the study); cont-oquently, the  analyses suffer from the failure  to state
         this policy explicitly. Fairness to the City calls for U.S. EPA to ;itate that it considers the
         Facilities  Plan's interceptor choices as sprawl-inducive so that Columbus' citizens and
         their officials know "the rules of the game" and can thus  make their future plans for expen-
         ditures accordingly.

     (c)   Another policy implicit in the Draft EIS is CEQ's admonition to Federal agencies to act to
         protect unique and  prime  farmland  when planning arid  funding projects. Again,  we fee!
         that  the Draft EIS should  state this policy explicitly, then follow through by giving the
         acreages and locations in each interceptor planning area of unique and/or prime farmland.
                                                                         (4.8.3)
     (d)   The Draft EIS in several instances cites the ne^d for constraints on package plants and in-
         dividual residential systems in those areas which will not be served by interceptors, but
         ducks  responsibility for any control by saying control is  a local matter. (See, for example,
         sections 7.2-7.2.1, pp VII-6 - Vil 8.) This conveniently ignores U.S. EPA's authority  to exer-
         cise veto action over state administration as-set forth in P.L 92-500; i.e., NPDF.S permits,
         208 plans, 303 plans, 305 reports, waste load allocations,  etc. Wo  feel that U.S. EPA should,
         if it insists on pursuing the implicit policy stated in'1 (a)  abovu, accept its responsibilities
         for insuring the proper adininistiauon ot that polio/ and acknowledge its intention to carry
         them out.                                                        (4.8.4)

     (e)   Section 7.3.3 "Community Facilities and  Services" suggests that (here will  be increased
         costs to various local governments in meeting the  subject growth induced  needs, but
         doais with the subject only in generalities. We feel that a best  effort should be made to
         quantify these costs so that present taxpayers will be able to make a reasonable judgment
         of the  interceptor benefits.                                        ,. B  c\
                                                                          ( 4 . O . 3 I

     (f)   Section 7.4.1 states, in part, "However, a significant increase in  development may lead to
         incieased rates and  volumes  cf runoff."  and ".  . .new development  may possibly con
         laminate the water in the area's major potenlL;! aquifers." Those  are two soiious problems
         and should have been discussed in greater detail and with quantification. What is "signifi-
         cant development?" Not only can  aquifers be polluted, so can surface waters.  Whut
         volumes can be expacted and what would bo ihoir flood poientials; their effects on stiaam
         ecology? What kinds and quantifier, of pollutant.* can be projected? The recent end current
         literature is  too laroe for this subject to bo dismissed with spucuiation.
                                           IV-200                           (4.8.6)

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                                                                                       -4-
    (g)   Section 7.4.2 discussos atmospheric characteristics under two headings: (1) air quality, (2)
         climate. We find these discussions inadequate from a (idfa base, inconsistent in logic, and
         unjustifiably conclusory. The air quality section only  discusses total suspended par-
         ticulates (ISP) and ignores the oihet iemulated pollutants, yet section 2.1.2 (2)'s discussion
         says that NOX and Photochemical Oxicianis levels must ba limited to avoid exceeding stato
         standards. In dealing with TSP, the Draft E!S notes that the data are based on two samples
         taken in 1976 which ore then extrapolated to the year 1995 after "assuming" that there
         were no differences in TSP ceometric means between 1975 and 1976. Faith, then, requires
         the reader.lo accept that by 1895 TSP geometric mean will be 86%  of the standard. Having
         reached  that shaky  figure  for only one air  pollutant parameter,  the  Draft EIS says,  in
         discussing  climate,  that ". .  .population growth and development are not expected  to
         result in a violation of ambient air quality standards. .." then goes on to tax credulity fur-
         ther by adding  likelihood to unfounded expectation in concluding, ". . .it is unlikely that
         growth will  contribute to changes in the area's overall climate."

         What is the definition of "overall climate?" As an example, January's precipitation could
         double and  September's fall by half and, overall,  the climate would not change, but the ef-
         fects in those two months could be severe.

         What are the- correlations between regulated air  pollutants and climate?

         What correlations are there between non-regulated,  artificially generated pollutants and
         climate?

         What ?re the effects of artificial thermal  components on climate?

         There may be no information available to provide answers to these questions, or informa-
         tion may be inadequate to provide predictive answers, if so, the Diufi EIS should slate that
         it cannot  answer the question: "What climatic changes will occur?" Current studies in-
         dicate important climatic changes are being  caused by increased  urbanization.

         In predicting air quality for the year 2000, all parameters  of regulated pollutants should be
         included, not just one. Assumptions upon which predictions are based should be explain-
         ed-                                                            (4.8.7)

II.   TREATMENT AND WATER QUALITY

    (a)   Data in Appendices I and K,  indicate that if the brewery pretreatment is adopted, both
         Southerly and Jackson Pike will experience essentially the same hydraulic and c>ganic
         loads, and must produce the same effluent quality. The authors of the EIS should explain
         why different treatment schemes are proposed for the two plants.   (4.8.8)

    (b)   Within the  treatment plants, virtually all  processes are  sized at the upper end  of the
         allowable range of loadings (App. K) so that the  design is not conservative. It is probable
         this design will not  satisfy NPDES consistently, although a high quality effluent  will be
         produced.                                                      (4.8.9)

         Particular problems occur in the tank loadings which are all too high. (For examples, See
         Table 1.) The authors of the EIS apparently rely on sand filters to make up deficiencies in
         the settlers, but the loading on the filters (IC-12: JP at 2 8 gpm/ft2,  S  at 2.2 gpm/ft2) h alao
         high. (See R.L Gulp and G.L. Gulp, "Advanced Water Treatment," Van Nostrand-Roinhold,
         p. 107.)
                                        IV-201

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                                                                                        -5-
Table 1. Comparison of Scttlin
Settling Tank
Primary
Intermediate
EIS Loading
gal/day/ft2
710 (S)
880 (JP)
1360(JP)
g Tank Loading
"10- states"
loading
gal/day/ft2
600
1000
           Final
1090 (JP)
800
                        (4.8.10)
(c)  The Water Quality Modeling summarized in Appendix B is so grossly deficient as to be ir-
    relevant to this EIS. Major technical eirors include:

    (1)   Failure to verify the model.

    (2)   Use of an incorrect stream flow.  The data at  the Columbus  guage includes  the
         Jackson Pike effluent flow so Oiat  the stream flows used in the EIS actually double
         count the Jackson Pike effluent and lead to an erroneously high stream flow.

    (3)   Use of  incorrect reaction rates. The reaction rates utilized in the CIS represent reac-
         tion tales found in srnail turbulent siieams and are very much higher than reaction
         rates found in larger, sluggish streams liko the Scioto Rivor.

    (4)   Assumption  of simultaneous  exertion  of  nitrogenous  and  carbonaceous  BOD.
         Laboratory and field data indicate that carbonaceous BOD is exerted before , and prior
         to, nitrogenous BOD.

    (5)   Incorrect Mathematical equations.  The equations presented in  the Appendix of the
         EIS are the integrated form of the Streeter-Pheips equations assuming constant value
         of K^ and K2, whereas the EIS clearly states they havs variable values of K, and K2-

                                                                      (4.8.11)
                                       IV-202

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4.8       Mid Ohio Health Planning Federation


4.8.1     Comment;  One initial weakness of the draft EIS
is its failure to make clear which of the various alterna-
tives were the preferred ones in the Facilities Plan.  This
denies the reviewer the opportunity to weigh the two pre-
ferred options, the City's and U.S. EPA's.

          Response;  Alternatives  are compared on
 Table  III-ll  in  Volume III.
4.8.2     Comment;  The EIS through its selection of inter-
ceptors is imposing land use controls on Columbus and the
involved metropolitan areas without making the clear state-
ment it is doing so.

          Response;  U.S. EPA, by law, can only fund the
construction of interceptors to abate   documented needs
As several of the interceptors proposed in the Facilities
Plan would serve largely unpopulated areas, these intercep-
tors cannot reasonably be funded with federal dollars.  The
City of Columbus and other metropolitan jurisdictions are
free to fund the construction of these interceptors from
local sources if so desired.  The EIS in no way is imposing
land use controls on the local jurisdictions.
4.8.3     Comment;  The EIS should state the policy regard-
ing prime and unique farm lands and follow through by giving
acreages and locations in each interceptor planning area.

          Response;  It is not required under NEPA to dupli-
cate within any draft EIS all of the federal policies which
must be considered in analyzing environmental impacts of
major federal actions.  The SCS survey data of prime and
unique farmlands for Franklin County had not been completed
in form or detail for inclusion in this EIS.
4.8.4     Comment;  The EIS in several instances cites the
need for constraints on package plants and individual sys-
tems.  U.S. EPA should accept its responsibilities for ensur-
ing proper administration of such programs.
                             IV-203

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          Response;  The Clean Water Act now  allows  201
funds to be used to construct and manage onsite  systems
which serve small residential units.  U.S. EPA is  also con-
cerned with Ohio EPA's administration of the  water program
and has recently reached agreement on necessary  program  im-
provements and financial requirements.  The regulation of
onsite systems is a state and local responsibility.


4.8.5     Comment;  We feel that a best effort should be
made to quantify these costs  (community services)  so that
present taxpayers will be able to make a reasonable  judg-
ment of the interceptor benefits.

          Response;  The effort required to quantify the
costs of extending community services and  facilities to  new
areas, essentially a fiscal impact study,  is  one which can
and should be done by the local jurisdiction  and incorpora-
ted into the decision making and capital budgeting processes,
It is an effort that exceeds the resources made  available
to prepare the EIS.  Given the limited resources on  this
particular project a "best guess" on costs for various ser-
vices and facilities would not only be inappropriate for
inclusion in the EIS, but rightly subject  to  criticism.
4.8.6     Comment;  Increased  rates  and  volumes  of  runoff
resulting from development referenced  in the  EIS should be
calculated and quantified for  pollution  effect.

          Response;  To calculate runoff from future  develop-
ment is a waste of time and resources  unless  it  can be
site specific and fairly specific assumptions regarding
density, land planning, buildup and  development  practices
and material employed, environmental controls, and  landscap-
ing can be determined.  Such information may  be  more  appro-
priately developed by local planning agencies and the 208
planning program.
4.8.7     Comment;  The air quality and climatic  impact dis-
cussions are inadequate.


          Response:  The discussion of air quality has been
 substantially modified.  See Appendix FF for more detail.
                             IV-204

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4.8.8     Comment:   Data in Appendices I and K, indicate
that if the brewery pretreatment is adopted, both Southerly
and Jackson Pike will experience essentially the same hydrau-
lic and organic loads, and must produce the same effluent
quality.  The authors of the EIS should explain why differ-
ent treatment schemes are proposed for the two plants.

          Response:  This comment has been addressed in one
form or another in our responses to OEPA and the City of
Columbus.  In brief, we offer the following response:

          (1)  Reviewer is wrong in saying organic and
               hydraulic loads are "essentially the same".
               They are similar only in terms of total in-
               fluent BOD mass and significantly different
               in terms of flow, suspended solids mass and
               form, and organic (soluble vs. particulate)
               load distribution.

          (2)  The reviewer's second point, "must produce
               the same effluent quality", is a given, and
               does  not follow from his opening premise.


          (3')  Differences in treatment schemes can be
               attributed to flow considerations (used in
               designing solids-liquid separation system);
               form, mass, and concentration differences
               in suspended solids, organics and nitrogen
               (used in designing reactors); the clear
               identification of a dominant industrial
               waste influencing process design at one
               plant; and the existing inventory of treat-
               ment capability found at each plant.


4.8.9     Comment:   Within the treatment plants, virtually
all processes are sized at the upper end of the allowable
range of loadings (App. K) so that the design is not con-
servative.  It is probable this design will not satisfy
NPDES consistently, although a high quality effluent will
be produced.

          Response:  Please see applicable responses to the
OEPA and the City of Columbus comments.

4.8.10    Comment:   Particular problems occur in the tank
loadings which are all too high.   (For example, see Table 1.)
The authors of the EIS apparently rely on sand filters to
                            IV-205

-------
make up deficiencies in the settlers, but the loading on the
filters (K-12:  JP at 2.8 gpm/ft2, S at 2.2 gpm/ft2) is also
high.  (See R. L. Gulp and G. L. Gulp, "Advanced Water Treat-
ment," Van Nostrand-Reinhold, p. 107.)

     Table 1.       Comparison of Settling Tank Loading
     Settling Tank


     Primary

     Intermediate

     Final
EIS Loadinc
gal/day/ft'

710(S)

1360(JP)

1090(JP)
"10 states"
gal/day/ft2

600

1000

800
          Response:  The reviewer is incorrect in assuming
that the suggested settler design is deficient because it
doesn't agree with the ten State Standards  (See previous
responses to OEPA and the City of Columbus, particularly
response 4.1.72, 4.1.73, and 4.1.74).  We find nothing
of substance on page 107 of Gulp and Gulp regarding the
effluent filtration facility proposed for consideration
in the draft EIS.

4.8.11    Comment;  The Water Quality Modeling summarized
in Appendix B is so grossly deficient as to be irrelevant
to this EIS.  Major technical errors include:

          (1)  Failure to verify the model.

          (2)  Use of an incorrect stream flow.  The data
               at the Columbus gauge includes the Jackson
               Pike effluent flow so that the stream flows
               used in the EIS actually double count the
               Jackson Pike effluent and lead to an erron-
               eously high stream flow.

          (3)  Use of incorrect reaction rates.  The reac-
               tion rates utilized in the EIS represent
               reaction rates found in small turbulent
               streams and are very much higher than reac-
               tion rates found in larger, sluggish streams
               like the Scioto River.

          (4)  Assumption of simultaneous exertion of nitro-
               genous and carbonaceous BOD.  Laboratory
               and field data indicate that carbonaceous
               BOD is exerted before, and prior to, nitro-
               genous BOD.
                           IV-206

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          (5)  Incorrect Mathematical equations.  The equa-
               tions presented in the Appendix of the EIS
               are the integrated form of the Streeter-Phelps
               equations assuming constant value of K^ and
               K2f whereas the EIS clearly state they have
               variable values of Kj and K2-

          Response;  Please see responses to similar com-
ments made by the City of Columbus in Section 4.1 of this
Chapter and responses to the OEPA in Chapter 3.
                            IV-207

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V.  COMMENTS FROM PRIVATE CONCERNS
          AND INDIVIDUALS

-------
5.1  Anheuser-Busch Inc.

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                               ST. LOUJS,.M.O., U.S.A.. 63118


                                    April 6, 19T8
Mr. Gene Wojcik
Chief EIS Preparation Section
Planning Branch
U.S. Environmental Protection Agency
Region V
230 South Dearborn Street
Chicago, Illinois  6o6ok

Dear Mr. Wojcik:

     We are submitting these comments in response to your Office's
Notice of Public Hearing, dated February 2k, 1978, concerning
public comment on the draft Environmental Impact Statement ("EIS")
for Wastewater Treatment Facilities for the Metropolitan Area of
Columbus, Ohio?   I personally made an oral presentation and
submitted a prepared statement for the record at the public
hearing held in Columbus on March 30, 1978, a copy of which (the
"Oral Statement") is enclosed and incorporated herein by reference.
The comments in this letter are supplemental to those made by me
at the public hearing, and we request that both statements be
entered as part of the public record and receive due consideration
from your Office prior to preparation and issuance of the Final
Environmental Impact Statement.

     First, we are seriously concerned about the safety and      \  •  •   >
environmental consequences which could ensue from implementation
of the pretreatment scenario recommended, by the draft EIS (scenario
2, summarized at page 12 of the Executive Summary of the draft EIS),
and by the failure of the draft EIS to evaluate these consequences.
I described the unexplored safety and environmental issues associated
with pretreatment scenario 2 in my Oral Statement at page 1.

     The principal, substantive conclusion of the draft EIS was
that the industrial release of the Columbus Anheuser-Busch brewery
"presented the opportunity to derive significant changes in the
proposed project plan through implementation of an industrial
pretreatment requirement.  (page 12 of Executive Summary)."  The
legal basis by which the EPA purports to impose an "industrial
pretreatment requirement" on the Columbus Anheuser-Busch brewery
is not addressed in the draft EIS, which is not surprising because
no legal basis exists.  Anheuser-Busch discharges compatible wastes
into the Southerly treatment works, which is not disputed by the
                              V-l

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Mr. Gene Wojcik                 -2-                  April 6, 1978
EIS.  Applicable law does not require pretreatment of compatible
vastes, and Anheuser-Busch strongly objects to any arbitrary
attempt to impose an ad hoc pretreatment standard on one Anheuser-
Busch plant.                                (5.1.2)

   The basic legislation which establishes national policy and
governs the federal regulatory framework in this subject area, the
Federal Water Pollution Control Act of 1972, as amended, (the
FWPCA"), requires the pretreatment of incompatible wastes, but
not compatible wastes.  The FWPCA reads in pertinent part at
section 307(b):

          Pretreatment standards under this subsection .
          . . shall be established to prevent the discharge
          of any pollutant through treatment works . . ,
         • which are publicly owned, which pollutant inter-
          feres with, passes through, or otherwise is
          incompatible with such works.

In discussing the application of this section of the FWPCA, the House
and Senate conferees expressly cited breweries as an example of an
industry whose normal effluent was compatible with municipal waste
treatment systems, making the pretreatment of such waste unnecessary:

          Pretreatment of biological waste that is compatible
          with treatment provided by publicly owned waste
          treatment plants into which such waste is introduced
          may not be necessary.  Examples of such biological
          waste may be 'the normal effluent of a brewery and
          of food processing plants where the composition
          and proportion of such effluent is compatible with
          the municipal waste treatment system.  In no
          event is it intended that pretreatment facilities
          be required for compatible wastes as a substitute
          for adequate municipal waste treatment  works.
          Conference Report on Federal Water Pollution
          Control Act Amendments of 1972, S. Rep. No. 92-1236,
          92nd Cong., 2d Sess., Sept. 28, 1972, p. 313.

     Pursuant to its S 307(b) authority, the EPA issued pretreatment
standards at *tO C.F.R. Part 128, which establishes three situations
in which pretreatment of industrial wastes discharged into a publicly
owned treatment works are required by law.  Pretreatment is required
for industrial waste which would cause a state or municipality to
be in violation of the effluent limitations in a NPDES permit (S
128.110), for incompatible wastes (S 128.133), and for waste which
is deemed to interfere with the operation of a treatment works
(S 128.131).  This regulation also states expressly, as a matter
of federal policy, that pretreatment for removal of compatible
pollutants is not required (S 128.132).

                                V-2

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Mr. Gene Wojcik                 -3-                  April 6, 1978
     The draft EIS does not contend, nor could it sustain a contention,
that the actual or anticipated discharge from the Columbus brewery
falls within any of the three referenced wastewater discharge
categories which require pretreatment.  The brewery is not in viola-
tion of any state or local pretreatment ordinances pursuant to
S 128.110.  With respect to the second condition under which
pretreatment is required, the brewery discharge is composed.
of pollutants which are specifically enumerated, as 'compatible
pollutants" under S 128.121.  Since the Southerly treatment works
expansion alternatives in the Columbus Metropolitan Area Facilities
Plan (the "Facilities Plan") have been designed to treat the
anticipated effluent of the Anheuser-Busch brewery, by the definition
of a compatible pollutant set forth in S 128.121, the wastes dis-
charged from the brewery are compatible.

     Nor does the draft EIS take the position that the Anheuser-Busch
discharge falls within one or more of the four types of prohibited
wastes set forth in S 128.131, which are deemed to interfere with
the operation of a publicly owned treatment works, and which therefore
require pretreatment whether or not they fall within the definition
of compatible wastes.  The four types of wastes which are deemed to
interfere with the operation of a treatment works are:

          (a)  Wastes which create a fire or explosion
               hazard in the publicly owned treatment
               works.

          (b)  Wastes which will cause corrosive
               structural damage to treatment works . , .

          (c)  Solid or viscous wastes in amounts which
               would cause obstruction to the flow in
               sewers, or other interference with the
               proper operation of the publicly owned
               treatment works.

          (d)  Wastes at a flow rate and/or pollutant
               discharge rate which is excessive over
               relatively short time periods so that
               there is a treatment process upset and
               subsequent loss of treatment efficiency.

     The draft EIS at page IV-3 makes the assertion that "the brewery
waste impacts the Southerly wastewater treatment plant" for various
reasons.  It is clear that waste which "impacts" a treatment works
falls substantially short of the legal threshold of "interference
                                V-3

-------
Mr. Gene Wojcik                 -4-                  April 6, 1978
vith" a treatment works that triggers a federal pretreatment
obligation.  On the factual question of how and to what extent
brewery waste "impacts" the treatment works, as long as Anheuser-
Busch is performing within normal anticipated ranges, and can
avoid accidental discharges, which admittedly could violate the
"slug loading prescription of (d) above, Anheuser-Busch's discharge
and flow rate generally are not of such short-term variability as
to cause a problem under (d).  Nor does the existing or anticipated
Anheuser-Busch effluent cause a problem under (a), (b), or (c)
above.  On the other hand, if the EIS recommendation were adopted,
there is the possibility, as discussed in the Oral Statement, of
the production of methane gas in violation of (a); there is also
the possibility that effluent suspended solids generated by the
pretreatment of BOD could cause corrosive damage to, and accumula-
tions in, the sewage collection system in violation of (b) and (c).

     The EPA had another opportunity to review the question of
federal pretreatment standards for brewery and other compatible
wastes in the development of its "Guidelines for Pretreatment of
Pollutants Introduced into Publicly Owned Treatment Works,"
October, 1973.  Appendix D of the Guidelines sets forth all the
information available to the EPA concerning wastewater characteristics
for sixteen industrial groups.  With respect to the Beverages
Industry, (Annex 12), the EPA cites a study prepared for it by
Aware, Inc. of Nashville, Tennessee entitled "Industrial Wastes
Survey of the Malt Industry" (unpublished), from which the EPA
drew the following conclusion:

          {Study) results suggest that in a well designed
           and well operated joint treatment works, the
           beverages industrial wastes are similar to
           domestic wastes, and that the ratio of indus-
           trial wastes to domestic wastes does not
           significantly influence the treatability
           characteristics of the combined waste.

We ,find no evidence in the draft EIS to suggest that the Facilities
Plan contemplates other than a "well designed . . . joint treatment
works" in which brewery wastes are similar to and compatible with
domestic wastes.  Absent a change in the applicable law, i.e., the
federal pretreatment standards contained in UO C.F.R. Part 128,
there is no lawful basis for the EPA to impose an ad hoc pretreatment
standard on Anheuser-Busch's Columbus brewery.  If the EPA believes
it has a basis for modifying federal pretreatment standards in UO
C.F.R. Part 128, it should do so in a manner which is procedurally
fair and sufficient for a federal rulemaking, and -'hich adopts and
                               V-4

-------
Mr, Gene Wojcik                 -5-                  April 6, 1978
appliec a uniform standard for an entire industry class on a
nationwide basis.

     We also take issue with the raising of the pretreatment
alternatives ab initio in the draft EIS.  Under the statutory scheme
and the EPA's implementing regulations and procedures thereunder,
the appropriate mechanism for development and evaluation of pre-
treatment- design alternatives is the Facilities Plan, and not the
EIS, which by law and by practice is the mechanism established to
assess the environmental impact of a metropolitan treatment works
yhich is to receive federal funding.            (5.1.3)

     Congress gave primary responsibility in S 201(g) of the FWPCA
to the construction grant applicant to develop a facility plan which
included wastewater treatment alternatives that satisfied the
analytical and informational requirements of S 20l(g),  EPA regula-
tions (^0 C.F.R, S 35.917) provide that the facility plan is the
instrument for the development and the sys-tematic evaluation of
feasible treatment alternatives, including the cost-effectiveness
of those alternatives (S 35.917-1),  There is no finding in the
draft EIS that the applicant failed to comply with the requirements
levied by section 201 (g) or its implementing regulations at kQ
C,F,E, S 35, which might serve as a justification for the EPA's
disapproval in the draft EIS of the recommended treatment alternative
of the Facilities Plan.  Even if the EPA had made such a finding in
the EIS, it would have been more appropriate under applicable law
and under Congress' unambiguous delegation of this responsibility
to the local level, for the EPA to have recommended to the City
during the drafting and preliminary review process that it evaluate
pretreatment alternatives in the Facilities Plan.  There have been
numerous points during the lengthy Step 1 construction grant process
at which the EPA could have requested the City's evaluation of
pretreatment alternatives in the context of the developing Facilities
Plan.

     The EPA has published two handbooks for use by construction
grant applicants in the preparation of facility plans.  These hand-
books explain how to satisfy the requirements of applicable law,
set forth the criteria by which the EPA will review and approve the
facility plan, and describe in considerable detail the informational
and analytical prerequisites of the plan.  The handbooks are the
EPA Handbook of Procedures, January 1977, (Chapter IV, Step 1 Grant
Processing), and the EPA Guidelines for Preparing a Facility Plan,
May 1975.  The EPA has not alleged that the Facilities Plan is
deficient _in content, information, or format as prescribed by
these handbooks.  Indeed, if anything, these handbooks underscore
that the proper place for consideration of the pretreatment alter-
natives is in the Facilities Plan, and that if the EIS pretreatment
recommendations were simply transposed.to the Facilities Plan, they
                                V-5

-------
Mr. Gene Wojcik                 -6-                  April 6, 19J8
would not satisfy the EPA's own review criteria.   The EPA in these
handbooks insists upon evaluation of treatment alternatives on the
basis of a number of criteria other than the cost-effectiveness
criterion on which the EIS recommendation relies  entirely.   For
example, section 10.7 of the Facility Plan Preparation Handbook
advises construction grant applicants that the SPA will review
their facility plans in light of eleven criteria, only one of
which relates to cost-effectiveness, and that their plans will be
considered to have met the requirements of the FWPCA only when it
is specifically determined that these eleven criteria have been
satisfied.

     Thus there is no basis under the FWPCA, in its implementing
regulations, or under the EPA's'own procedural guidelines to take
evaluation of pretreatment alternatives out of the context of the
Facilities Plan and consider the issue in the first instance in the
EIS.  From another perspective, there is no basis under the enabling
legislation pursuant to which the EPA issues this EIS for the
original evaluation in the EIS of pretreatment alternatives on a
cost-effectiveness rationale.  Authority for the  EPA to issue the
EIS arises out of S 102(c) of the National Environmental Policy
Act ("NEPA") and out of the regulations issued by the Council on
Environmental Quality at UO C.F.R. Part 1500.  These two sources
of authority are unambiguous in their delineation of the purpose,
the scope and the specific content of an EIS, which is to assess
the effects of major federal actions on the quality of the human
environment and to explore alternative actions that will avoid or
minimize adverse environmental impacts,  The regulations make clear
that the "alternatives" required to be evaluated by the EIS
pursuant to S 102(c)(iii) of NEPA are not those from a cost-
effectiveness standpoint, but alternatives with different environmental
impacts, or, as stated in Uo C.F.R. S 1500.8(a)(U) a. "rigorous
exploration and objective evaluation of the environmental impacts of
all reasonable alternative actions, particularly those that might
enhance environmental quality or avoid some or all of the adverse
environmental effects."                 (5.1.4)

     Pursuant to the authority of NEPA and Part 1500, the EPA has
promulgated its own regulations on EIS preparation at Uo C.F.R, S 6
which remain consistent with NEPA's statutory purpose and scheme.
These regulations state at S 6.30k;

          The EIS shall serve as a means for the responsible
          official and the public to assess the environmental
          impacts of a proposed EPA action.

Section 6.30U goes on to enumerate the content requirements for an
EIS prepared by the EPA.  It lists and« describes seven major
                                V-6

-------
Mr. Gene Wojcik                 -7-                  April 6, 1978
categories of information and analysis of which an EIS should be
comprised.  All seven categories relate to environmental considera-
tions; none of them as a category deals with cost-effectiveness
questions.  In light of this regulatory and procedural framework,
it is difficult to ascertain on what legal basis the draft EIS
proposes treatment alternatives justified solely in terms of
purported-cost-effectiveness, and without regard to their
environmental impact.

     Leaving aside for a moment the question of whether or not the
EIS is an appropriate mechanism for raising and evaluating the pre-
treatment issue, the EIS in its discussion of the four pretreatment
alternatives materially fails to comport with the EPA's own
regulations and procedures for the preparation of environmental
impact statements.  The general analytical, approach dictated by
the EPA Manual for Preparation of Environmental Impact Statements,
Chapter III B(2), calls for the evaluation'of structural and non-
structural subsystems, the screening of subsystem alternatives to
combine compatible subsystems into system alternatives, and the
selection of a preferred system on the basis of a detailed compara-
tive analysis, the final step in which process, referred to as the
"Final Detailed Systems Screening," is the point at which comparative
costs are factored into the evaluation.  Even at this stage, com-
parative costs are only one of four criteria for evaluation, the
others being the system's contribution to water quality goals and
objectives, operability, reliability and flexibility of each
alternative, and significant environmental effects of each alter-
native.  Once again, the EPA's own internal procedures serve to
underscore the total absence of any environmental impact analysis
of the proposed pretreatment alternative in the draft EIS.  The
materiality of the omission is evidenced by the substantial
environmental concerns raised by the EIS's recommended pretreatment
alternative which we reviewed in our Oral Statement (page 1).

     In addition to the draft EIS's failure to assess the potential
environmental hazards of their recommended pretreatment alternative,
the cost-effectiveness analysis as well as the process design of
the pretreatment facilities contain several unfounded assumptions
and factual errors and reaches an erroneous conclusion as a result
of these errors.  These errors are discussed in detail in our Oral
Statement at pages k and 5-  The points discussed in our Oral
Statement provided evidence to show that the capital costs at the
Southerly Plant were underestimated when pretreatment was assumed
at the brewery.  In addition, the cost of the pretreatment plant
at the brewery would be significantly greater than that reported
in the Impact Statement.  We are enclosing design and cost estimate
                                V-7

-------
Mr, Gene Wojcik                 -8-                  April 6, 1978
information submitted to us by McWhorter & Associates, Inc.  of
Savannah, Georgia, consulting engineers retained by Anheuser-Busch.
This information reveals that the capital and operating costs which
vould be incurred by Anheuser-Busch as a result of the adoption of
pretreatment scenario 2 as recommended by the draft EIS are  seriously
understated.  An additional analysis is also attached to show the
financial impact that the implementation of the recommended  plan
would have on Anheuser-Busch.  This financial analysis reveals that
the recommended plan at the present discharge level from the
brewery would yield a return on investment to Anheuser-Busch of
1.97 percent and 2.63 percent under the expanded brewery assumptions.
Further analysis of the recommended plan at the present loading
condition reveals that if this plan were implemented, it would
cause Anheuser-Busch to incur a present value loss of $ 2,828,330.
In all probability, this would represent a very conservative
estimate of the loss that Anheuser-Busch wodid incur since the analysis
assumes that even though Anheuser-Busch would remove a large portion
of the load from the Southerly Plant, the sewer use rates  would
remain unchanged.  However, in reality, pretreatment 'by Anheuser-Busch
would result in a significant loss of revenue to the City of
Columbus and this loss of revenue would result in higher sewer use
charges for the users of the system.  This severe revenue drain on
the City and the significant increase in sewer use charges to users
of the Columbus system were not taken into account in the evaluation
of the various scenarios in the draft EIS.

Another factor not in-eluded in the evaluation of the scenarios is the
fact that the treatment of a combined brewery-municipal wastewater
aids in the removal of phosphorus.  The EIS acknowledges that brewery
wastes help to remove phosphorus but in the evaluation of the
scenarios, no additional cost was assumed at the Southerly Plant for
this additional treatment requirement when pretreatment was  assumed
at the brewery.                                     (5.1.5)

     One of the major assumptions made in the draft EIS was  that the
treatment of the brewery waste at the Southerly Plant was the cause
of the bulking sludge which currently hinders the operation  of the
plant.  The draft EIS even assumed that if the brewery wastewater
was pretreated, the need for further investigation of this problem
would be eliminated.  However, after extensive tests, the City of
Columbus has stated that they do not feel that the bulking problem
is caused by the treatment of brewery wastes.  Their analysis has
shown that their bulking problem is due to the presence of a blue-
green algae and not from the presence of filamentous bacteria, such
as Sphaerotilus Natans, or fungi which are usually associated with
bulking related to the treatment of a carbohydrate waste.  Therefore,
we think the assumption made in the EIS that the brewery waste is
the cause of the "bulking problem is unfounded and also feel  that
the elimination of a pilot plant at the Southerly Plant to determine
                                 V-8

-------
Mr. Gene Wojcik                 -9-      '            April 6,  1978
cause of the bulking problem is unwise.        (5.1.6)

     In conclusion, let me reiterate the conclusions which ve have
previously enunciated in the Oral Statement.   We are firmly
committed to the development of a reasonably  priced and environ-
mentally sound wastewater treatment facility  which will serve the
needs of all residential and industrial users in the Columbus
Metropolitan Area in compliance with all applicable local, state,
and federal laws.   We have worked closely with the City and with
state and federal environmental officials in  the development of
the treatment alternatives considered in the  Facilities Plan, and
we believe that the proper focus for the draft EIS should be the
environmental impact and cost-effectiveness of those treatment
alternatives described in the Facilities Plan.  We do not believe
that the EIS has put forward convincing environmental or cost
arguments to justify proposing new treatment  alternatives in the
draft EIS which it did not request appropriate local officials to
evaluate in the context of the Facilities Plan.  We can state with
assurance that the pretreatment scenario recommended by the draft
EIS will involve substantially increased costs to ourselves and to
all other local users.  We strongly object to the imposition on our
Company of a pretreatment standard that is not required by applicable
law or regulations and that it is not applied on a uniform basis to
other industries similarly situated.  In addition to the legal and
procedural deficiencies in the draft EIS, we  find its recommended
alternative to be environmentally questionable and considerably
more costly than the draft EIS suggests.

     Please let us know if there is further information which we
can provide.
                                Sincerely yours,

                                ANHEUSER-BUSCH, INC.

                                CL^L/r-* •/^~.~
                                //       *~
                                John L. Stein, Manager
att,                          ^Environmental Engineering Planning

JLS:de
cc:  Mr. Gordon Arbuckle
     PATTON, BOGGS & Blow
     1200 Seventeenth Street, NW
     Washington, DC
                                V-9

-------
                                                                        -10-
                                                          Scenario 2




                                              60,000 #/day          100.000 #/day
1)  Capital Costs




      Per McWhorter & Associates,  Inc.         $6,916,000             $ 7,361,000




2)  Operating Costs




      Per McWhorter & Associates,  Inc.         $329,000/year         $386,000/year




3).  Cost of Discharge to City Sewer System




      A)  Unit Costs




          Flov      $0.817 per 1,000 gal




          BOD       $0.109 per Ib  over 250 mg/1




          SS        $0.078 per Ib  over 300 mg/1




      B)  Savings in Sewer Charges




          a)  Cost Under Scenario  1




              Flow        $ 2,2"1<7  per day




              BOD         $ 5,915  per day




              SS          $   633  per day




              Total       $ 8,795  per day






          b)  Cost Under Scenario  2




              Flow        $ 2,2U7  per day




              BOD         $ 2,6^5  per day




              SS          $ 2^193  per day




              Total       $ 7,085  per day
                                      V-10

-------
                                                                        -11-
        c)  Savings ($5,795 - ->7,C°5) 365 days/year = ?62U,150 per year

    C)  Savings in Sewer Charges -"? 100,000 #/day

        a)  Cost Under Scenario 1

            Flov          $3,760 per day

            BOD           $9,850 per day

            SS            $1,050 per day

            Total        $1U.660 per day

        b)  Cost Under Scenario 2

            Flov         $ 3,760 per day

            BOD          $ 5,500 per day

            SS           $ 3,^00 per day

            Total        $12,660 per day

        c)  Savings = ($lU,66o - $12,660) 365 days/year = $730,000 per year

U)  Yearly earnings from installation of pretreatment system.   Assume both
    Sever Use Charges and 0 & M Costs increase at 5* per year  for 10 years;
    and then renain constant for next 10 years.
                      60,000 #/day
10,000 if/day
Year

1
2
"V
--*
k
5
6
7
8
9
10
11 )
thru )
20 )
Sever
Savings
$62U,150
655,350
688,100
722,600
758,700
796,600
836,1*00
878,200
922,000
968,300

968,300

0 & M
Costs
329,000
3^5,1*50
362,700
380,900
399,900
1*19,900
1*1*0,900
1*62,900
1*86,000
510, UOO

510, UOO

Earnings

295,150
309,900
325,^00
3^1,700
358,800
376,700
395,500
^15,300
U36,000
1*57,900

1*57,900

Sewer
Savings
730,000
766,500
80H,800
81*5,000
887,300
931,700
978,300
1,027,200
1,078,500
1,132,500

1,132,500

0 & M
Costs
386,000
1*05,300
1*25,500
1*1*6,800
1*69,200
1*92,700
517,200
51*3,200
570,300
598,900

598,900

Earnings

3l*l*tOOO
361,200
379,300
398,200
1*18,100
139,000
U60,100
U8U,000
508,200
533,600

533,600

                                     V-ll

-------
                                                                     -12-
5)  Rate of Return Analysis

    a)  60,000 #/day loading


        Total investment  = £6,916,000

        Maximum economic  life =  20 years

        Effective tax rate = 50.Q%


        Sum of years digits* depreciation


        10 year depreciation with 105» investment  tax credit
    Year
      1
      2
      3
      k
      5
      6
      7
      8
      9
     10
     11
     12
     13
     ll*
     15
     16
     17
     I8
     19
     20

    DCFROI equals 1.97 percent for a 20 year life
    b)  100,000 #/day loading

        Total investment = $7,361,000




                                 V-12
Depreciation

1,131,708
1,018,538
905,367
792,196
679,025
565,855
U52,68U
339,513
226, 3U2
113,171
0
0
0
0
0
0
0
0
0
0
Salvage

5,092,690
U, 07**, 152
3,168,785
2,376,539
1,697,56U
1,131,709
679,026
339,51'*
113,172

1
1
1
1
1
1
1
1
1
1
Earnings

1,678,350
309,900
325,1*00
3U1.700
358,800
376,700
395,500
1*15,300
1*36,000
1*57,900
U57, 900
!»57,900
1*57,900
1*57,900
1*57,900
^57,900
!*57,900
U57.900
^57,900
U57.900
Cash
Flow
1,1*05,029
66U ,219
615,383
566,91*8
518,912
1*71,277
1*21*, 092
377,1*06
331,171
285,536
228,950
228,950
228,950
228,950
228,950
228,950
228,950
228,950
228,950
228,950
Earnings
Rate
-6.05
-6.1*5
-6.61*
-6.72
-6.73
-6.62
-6.38
-5.95
-5.30
-l*.l*l
-3.38
-2.1*6
-1.6U
-0.92
-0.29
0.29
0.78
1.22
1.62
1.97

-------
        Year   Depreciation
Salvage
                      Earnings
                                  Cash Flow
 -13-
Earnings
  Rate
1
2
3
1*
5
6
7
8
9
10
11
12
13
1U
15
16
IT
18
19
20
l,20l+,526
1,081*. 07^
963,622
8143,169
722,717
602,261+
l+8l,8ll
361,359
21+0,906
120,1*53
0
0
0
0
0
0
0
0
0
0
5,1^20.3^2
It, 336, 293
3,372,676
2,529,507
1,806,790
1,2014,526
722,716
361,358
120,1*52
-0
-0
-0
-0
-0
-0
-0
-0
-0
-0
-0
1,816,200
361,200
379,300
393,200
1+18,100
1+ 39, 000
1*60,100
i+8i+,oao
508,200
533,600
533,600
533,600
533,600
533,600
533,600
533,600
533,600
533,600
533,600
533,600
1,510,363
722,637
671,1+61
620,63U
570,1+03,
520-,f32
-;•..;*? s.
• •''«&?'• ;,sf£
3 f ,"*«.'V*5|
*— -**.* **?
"'" -Y^f
26v^tff
26o,SOO
266,000
266,800
266,800
266 ,800
266,800
266,800
266,800
266,800
-5.35
-6.21
-6.36
-6.40
-6.35
-6.19
r5.38
r;.38
-14.67
-3.71+
-2.68
-1.75
-0.93
-0.21
O.U3
0.99
1.1+8
1.91
2.29
2.63
        DCFROI equals 2.63 percent for a 20 year life


6)  Present value* estimate at 60,000 #/day loading

    Year
      1
      2
      3
      1*
      5
      6
      7
      8
      9
     10
     11
     12
     13
     1U
     15
     16
     17
     18
     19
     20
1,1+05,029**
  664,219
  615,383
518,912
1*71,277
l+2l+,092
377,1+06
331,171
285,536
228,950
228,950
228,950
228,950
228,950
228,950
228,950
228,950
228,950
228,950
                Present
                Factor

                 0.8929
                 0.792$
                 0.7US
                 0.635?
                 o. 5671*
                 0.5066
                 0.1+523
                 0.1+039
                 0.3606
                 0,3220
                 0.2875
                 0.2567.
                 0.2292
                 0.1827
                 0.1631
                 0.11*56
                 0.1300
                 0.1161
                 0.1037
      *  Anheuser-Busch cost of capital assumed  3 12*  Total  =

     **  Includes 10? investment tax credit

     Present Value Loss = $6,916,000-- 1+,037,670 =  $2,823,330
                                    V-13
                                                 Present
                                                 ^Value
                                                 ..
                                                 ;36o,295
                                                 '2914,1+30
                                                  238,750
                                                  191,816
                                                  152,1+31+
                                                  119,1+20
                                                   65,820
                                                   58,770
                                                  '52.1+75
                                                   1+6,81+0
                                                   1+1,830
                                                   37,31+0
                                                   33,335
                                                   29,760
                                                   26,530
                                                   23,71+0
                                       t+, 087.670

-------
                                                                    -14-
                                Appendix
                                TABLE 1
                      100,000 IBS/DAY SCENARIO 2
                            DESIGN CONCEPT
DESIGN WASTEWATER LOAD
     Hydraulic Flow
          Normal Daily Flew at Full Production =6.5 MGD
          Maximum Daily Flow =7.8 MGD
          Peak Flow Rate = 9.3 MOD
     Biochemical Oxygen Demand
          Mean BOD = 100,000 Ibs/day
          Standard Deviation/Mean (Jan - April 1977) =0.34
          Normal Maximum BOD = 100,000 -r 1.34 = 134,000 Ibs/day
     Suspended Solids
          Design Suspended Solids = 25,000 Ibs/day

DESIGN EFFLUENT IJMITATICNS
     Hydraulic Flow
          Limitation = no limit
     Biochemical Oxygen Demand
          30 Day Average Limitation = 60,000 Ibs/day
     Suspended Solids
          Limitation =  no limit
     Nitrogen
          Limitation = no limit
     Phosphorus
          Limitation * no limit

RAW WASTE PUMPING STATION
     Peak Flow Rate = 9.8 MGD = 6,800 gpm
     Provide Four Pumps including One Standby
     Pump Capacity = 3,400 gpm each
     Pump Head Estimated at 40 feet TDK
     Pump Power = 50 HP

COARSE BAR SCREENS
     One Unit
     Manually Cleaned
     Bar Spacing = 2 inch clear opening
     Design Velocity at Average Flow =2.0 fps
     Design Velocity at Peak Flow =3.0 fps
     Inclined Angle from Horizontal = 30 degrees

METERING FLUME
     Metering Range
          Minimum Flow = 600 gpm
          Maximum Flow = 6,000 gpm
                                 V-14

-------
                                                                    -15-
             TANK
     Equalization of Hydraulic and Waste Loads
     Variable Storage Required = 100,000 gallons to eliminate flow peaks
     Total Storage Capacity = Provide maximum without risk of septicity
     Allowable Storage Tire = 6 hours maximum without septicity
     Total Storage Volume =6.5 MGD x 6 hours = 1,625,000 gallons
     Number Equalization Tanks = Two Units
     Volume Each Tank = 312,500 gallons
     Tank Size = 80 feet diameter x 21.5 feet SWD
     Mixer = Low speed top entry turbine
     Mixer Pumping Rate = 6.5 .MGD x 20 = 90,000 gpm minimum
     Mixer Power = 20 HP
     Minimum Water Depth for Mixer Operation
          Center Tank =5.5 feet
          Side Wan = 9
     Detention at Minimum Level with Normal Flow =0.5 hours with two tanks
     Detention at Maximum Level with Normal Flow = 6 hours with two tanks
     Effluent Pumps = Two variable speed units
     Pump Capacity =6.5 MGD = 4,500 gpm each

FINE SCREENS
     Equalized Flow = 4,500 gpm maximum
     Type = Stationary Wedge Wire
     Opening = 0.020 inches
     Material = 316 SST
     Length Screen Required * 4,500 gpm t 100 gpm/ft = 45 ft
     Provide 5 back to back 72 inch screens
     Screen Length with one unit down = 48 feet
     Provide Conveyors for Screenings
     Discharge Screenings into Dumpsters
     Haul Screenings to Sanitary Landfill
     Screenings Quantity varies with brewery operation
     Estimated Screenings
          Minimum day = 1 cubic yard
          Maximum day = 12 cubic yards (spent grain spill)
     BCD Removal = none

NEUTRALIZATION TANK
     Retention = 5 minutes at Average Flow
     Volume = 4,500 gpm x 5 min = 22,500 gals
     Mixer = low speed top entry turbine
     Mixer Pumping Rate = 4,500 gpm x 5 = 22,000 gpm
     Mixer Power = 2 HP
     Provide Acid and Caustic Feed Capability
     Provide 5,000 gals Storage for 95% H2S04
     Provide 5,000 gals Storage for 50% NaOH
                               V-15

-------
                                                                     -16-
NUTRIENT ADDITION
     Nitrogen
          Base Nitrogen Required on N/BOD removed ratio ='1/25
          BOD Removed = 134,000 Ibs/day - 50,000 Ibs/day = 84,000 Ibs/day
          Nitrogen Required = 84,000 Ibs/day x 1/25 = 3,360 Ibs/day
          Estimated Raw Waste Nitrogen = 560 Ibs/day
          Nitrogen Feed Required = 2,800 Ibs/day
          Provide Two Anhydrous Ammonia Storage Tanks
                (one tank on line and one reserve)
          Provide One 2,300 Ibs/day Evaporator
          Provide One 2,800 Ibs/day Feeder
          Feed Proportional to Monitored TOD Load
     Phosphoric Acid
          Base Phosphorus Required on P/BOD removed ratio = 1/125
          Phosphorus Required = 84,000 Ibs/day x 1/125 = 670 Ibs/day
          Estimated Raw Waste Phosphorus = 400 Ibs/day
          Feed Required = 270 Ibs/day
          Use H3P04 @ 75%
          Feed Rate =	270	     = 85 gpd
                      32% x 75% :< 8.34 x 1.58

          Provide Storage for Tank Truck Load plus 50%
          Provide 5,000 gals Storage
          Feed Proportional to Monitored TOD Load

BIOLOGICAL TOWER
     Design BOD5 Loading = 100,000 Ibs/day
     Soluble BOD Removal Required =  (80,000 - 35,000)/80,000 » 56%
     .Base Design on Following Formula;

          Le/Li =

          Where Li - Influent BODs
                Le = Settled Effluent BQDs
                K - Treatability Constant
                D = Media Depth
                q = Hydraulic Loading per Unit Area
                n = Media Constant
     n = 0.5 for BF Goodrich Vinyl Core Media

     Actual operation of a biological tower system pretreating brewing waste
     at one brewery, a pilot tower operated at another brewery, and a series
     of pilot laboratory studies on brewing waste indicate that two stage •
     filter performance predicted with a !<2o value of 0.01 is achievable with
     reasonable reliability for influent BOD concentrations averaging 2,000
     to 2,500 mg/1 and removals of 40 to 60 percent based on settled effluent
     BOD.

     Suspended  solids generated on the biological towers are estimated at 50% of
     soluble BOD removal.  The BODs of suspended solids biomass generated on
     the biological tower systems are estimated to be 20% of BODS removed.
                                 V-16

-------
                                                                    -17-
K is temperature dependent and varies as follows:

     KT = K20(1.035)T-20

Estimated temperature extremes in the biological towers
     Sunnier, All Stages = 27 degrees C
     Winter, First Stage = 20 degrees C
             Second Stage = 13 degrees C
Temperature corrected K values:

     Surmer K = .01(1. 035) 27~20 = 0.013
     Winter K will change with each filter stage as heat loss reduces tare.
             1st Stage K = .010
             2nd Stage K = .01(1. 035) 13~20 = 0.0079

Height is limited by structural capacity of media
     Maximum practical height = 32 feet
Provide three stage biological system
     Make each stage same size for interchangeability
     Assume K remains constant for each stage
     Fraction BOD remaining after each stage =  (1 - 0.56)-^ = 0.66
First Stage Design
     Rearrange equation to calculate q and use average winter K to
     calculate media required.
                 (.010 -i-  .0079)/2 * 0.889
          q =  [-HD/2n(LB/Ci]Vn

          q =  (-.0089 x 32/ln  .66)2

          q =  0.47 gpm/ft2

     Area = Q/q = 6.5 M3D/0.47 gpm/sf = 9,604 ft2

     Diameter  =  (9,604 x 4/rr) -5  =110 feet

     Media Volume = 110' J2T x 32 ft * 304,000 ft3 each filter

     Volume Loading

          First Stage = 100,000 Ibs BOD/304,000 ft3 = 329 3bs BOD/1COO cf

          Overall = 404 -? 2 stages = 164 BODAOOO cf
                               V-17

-------
                                                                   -18-
Perfonnance Each Stage - Winter Condition
     First Stage Performance

          LeAi = e~-01 x 32/.47*5 = 0.627
     Second Stage Performance

          Le/Li = e"*0079 x 32/.4T'5 = .692

Overall Performance
     BCD Removed based on settled effluent sample
                   (LeAi) ^ stage x (LeAi) j^ stage x  (Le/Li) 3rd stage
                  0.627 x 0.692 = 0.434 fraction remaining
          Fraction Removed = 1.0 - 0.434 = 0.566
          Soluble BOD Removed - 80,000 x .566 = 45,289 Ibs/day
     Suspended BOD Removed = 20,000 x est 21% = 4,200 Ibs/day
     BOD removed based on whole effluent sample
          BOD Removed » 45,289 - 20% + 4,200 = 40,424 Ibs/day
Recirculation
     Raw Waste Hydraulic Loading:
          Maximum day flow =0.56 gpm/sf
          Average day flow =0.47 gpm/sf
     Min. hydraulic Loading Required to provide adequate wetting =  .75 gpm/s:
     Desirable hydraulic loading to provide hydraulic sluffing of
          bionass under projected organic loading =1.5 gpm/sf
     Provide 2 recirculation pumps each stage for constant flow over filter
          capacity = 110 ft dia x .75 gpm/sf = 7,100 gpm
         . Head = +_ 50 ft TEH

Ventilation
     Max. air required when summer temperatures increase reaction rates
     Assumed maximum tower temperature = 27 degrees F .

     First Stage BOD removal at 27 degrees F

          Removal = 80,000  (1 - e--013 x 32/.47'-5) = 36,392 Ibs/day
     Oxygen required per Ib BOD removed =0.67 Ibs
     Total oxygen required = 36,392 x 0.67 = 2 4, 3 82" Ibs/day
     Oxygen transfer efficiency = 2%
     Percent Oxygen in air = 23% by weight
     Density of 27 degrees C air = 0.0735 Ibs/cf
     Air flow required:

        24,382 lbs/02/day       '           =  50,000 cfm
     2% x 23% x 0.0735 Ibs 02/cf Air

     Provide 50% excess air capacity
     Air capacity » 75,000 cfm/tower
     Provide 2 blowers each tower
     Blower -capacity 37,500 cfm @ 1" VC
                                v-18

-------
                                                                      -19-
               Neutralization - Biological Towers
                    Significant pH drop can occur on the biological towers
                    requiring neutralization between stages.

                    Provide pH monitoring and control at recirculation wet
                    well of second stage biological tower.

SPENT GRAIN PRESS LIQUOR STORAGE
     Purpose = Provide waste source during production shutdown
     Wastes Quantity = 3 days @ 15,000 Ibs/day BOD
     Concentration = 20,000 rag/1

     Storage Volume =      15,000 Ibs/day x 3 days             = 270,000 gallons
                        20,000 rag/1 x 8.34 Ibs/gal

LAND AREA REQUIRED
     Allow 50 feet from treatment units to property line
     Minimum land requirement = 320 ft x 360 ft
     Minimum Land Area =2.6 acres
     Maximum Building Height above Ground = 40 feet
     Maximum Excavation below Ground = 20 feet
POWER
     Connected Load = 800 KVA
     Running Load = 600 KVA
     Largest Motors = Four @ 125 HP
                                  v-19

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                     Appendix
                      TABLE 3
            100,000 LBS/DAY SCENARIO 2
            CONSTRUCTION COST BREAKDOWN
               -20-
Raw Waste Pumping Station
     Site Work
     Structural
     Mechanical
     Force Main
Coarse Bar Screen
     Site Work
     Structural
     Mechanical
Metering Flume
     Site Work
     Structural
     Mechanical
Equalization Tank
     Site Work
     Structural
     Equipment
     Mechanical
     Miscellaneous
Fine Screens
     Site Work
     Building
     Equipment
     Mechanical
     Miscellaneous
Neutralization Tank
     Site Work
     Structural
     Equipment
     Mechanical
     Miscellaneous
Biological Towers
     Site Work
     Structural - Concrete
     Structural - Steel
     Structural - Media Support
     Media
     Equipment
     Mechanical
     Miscellaneous
                       V-20
  $  4,000
    38,000
    92,000
   105,000
  $239,000
$
$
$


$
1,700
5,700
1,600
9,000
1,700
5,500
1,800
9,000
  $  8,000
   499,000
    48,000
    31,000
    25,000
  $611,000
  $  1,000
    57,000
    86,000
    26,000
    10,000
  $179,000
  $  1,000
    25,000
     6,000
     3,000
     4,000
  $ 39,000
  $  4,000
   982,000
    18,000
   133,000
 1,674,000
   147,000
    29,000
   138,000
$3,125,000

-------
Construction Cost Breakdown - continued              -21-
Dome and Odor Control
     Structural                         $252,000
     Equipment                           188,000
                                        $440,000

Control and Pumping Building
     Site Work                          $  8,000
     Structure                           210,000
     Equipment
          Equalization Pumps              26,000
          VFD                             35,000
          Recirculation Pumps             75,000
     Mechanical                           97,000
     Miscellaneous                         8,000
                                        $459,000

Chemical Storage
     Site Work                          $  1,000
     Foundations                           9,000
     Steel Tanks, Two                     28,000
     FRP Tanks, Three                     15,000
     Mechanical                           13,000
     Miscellaneous                         2,000
                                        $ 68,000

Spent Grain Liquor Storage Tank
     Tank FRP                           $133,000
     Foundation                           15,000
     Mechanical                           18,000
                                        $166,000

Instrumentation and Control Systems
     Equipment
          Instrumentation Package       $ 34,000
          Neutralization System           28,000
          TOD                             15,000
          Samplers                        10,000
     Installation                         43,000
                                        $130,000

Electrical
     Equipment
          Air Switch                    $ 16,000
          Transformer                     24,000
          MCC                             40,000
     Main Service                         38,000
     Motor Wiring                        125,000
     Building Electrical                  25,000
     Area. Lighting and Miscellaneous       8,000
                                        $276,000
                      V-21

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Construction Cost Breakdown - continued              -22-
Site Work
     Grading                            $ 12,000
     Paving                               26,000
     Fencing                              10,000
     Landscaping                          28,000
     Walks                                 3,000
                                        ? 79,000

Yard Piping
     Process Piping                     $140,000
     Utilities                             7,000
     Drainage                              8,000
                                        $155,000

Repiping Sanitary Sewage
     Sewers                             $100,000
                                        $100,000
                      V-22

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                               Appendix                             -23-
                                TABLET2
                       60,000 IBS/DAY SO,
                            DESIGN ca-:T;:*
DESIGN WASTEWATER LOAD
     Hydraulic Flow
          Normal Daily Flow at Full Produce!
          Maximum Daily Flow = 4.7 MGD
          Peak Flow Rats = 5.9 MGD
     Biochemical Oxygen Demand
          Mean BOD = 60,000 Ibs/day
          Standard Deviation/Wean (Jan - April 1977) = 0.34
          Normal Maximum BOD = 60,000 -r 1.34 = 80,400 Ibs/day
     Suspended Solids
          Design Suspended Solids = 15,000 Ibs/day

DESIGN EFFLUENT LIMITATIONS
     Hydraulic Flow
          Limitation = no limit
     Biochemical Oxygen Demand
          30 Day Average Limitation = 30,000 Ibs/day
     Suspended Solids
          Limitation =  no limit
     Nitrogen
          Limitation = no limit
     Phosphorus
          Limitation = no limit

RAW WASTE PUMPING STATION
     Peak Flow Rate = 5.9 MGD = 4,100 gpm
     Provide Three Pumps including One Standby
     Pump Capacity = 2,050 gpm each
     Pump Head Estimated at 40 feet TDH
     Pump Power = 30 HP

COARSE BAR SCREENS
     One Unit
     Manually Cleaned
     Bar Spacing = 2 inch clear opening
     Design Velocity at Average Flow =2.0 fps
     Design Velocity at Peak Flow =3.0 fps
     Inclined Angle from Horizontal = 30 degrees

METERING FLUME
     Metering Range
          Minimum Flow = 400 gpm
          Maximum Flow = 4,000 gpm
                                 V-23

-------
                                                                    -24-
EQUALIZATICN TANK
     Equalization of Hydraulic and Waste Loads
     Variable Storage Pequired = 100,000 gallons to eliminate flow peaks
     Total Storage Capacity = Provide maximum without risk of septicity
     Allowable Storage Tire = 6 hours maximum without septicity
     Total Storage Volume =3.9 MGD x 6 hours = 975,000 gallons
     Number Equalization Tanks = Two Units
     Volume Each Tank = 487,500 gallons
     Tank Size = 60 feet diameter x 23 feet SWD
     Mixer = lew speed top entry turbine
     Mixer Pumping Bate =3.9 MGD x 20 = 54,000 gpra minimum
     Mixer Power = 15 HP
     Minimum Water Depth for Mixer Operation
          Center Tank =5.5 feet
          Side Wall = 9
     Detention at Minimum Level with Normal Flow =0.5 hours with two tanks
     Detention at Maximum Level with Normal Flow = 6 hours with two tanks
     Effluent Pumps = Two variable speed units
     Pump Capacity = 4.7 MGD = 3,300 gpm each

FINE SCREENS
     Equalized Flew = 3,300 gpm maximum
     Type = Stationary Wedge Wire
     Cpening - 0.020 inches
     Material = 316 SST
     Length Screen Required = 3,300 gpm t 100 gpm/ft = 33 ft
     Provide 4 back to back 72 inch screens
     Screen Length with one unit down = 36 feet
     Provide Conveyors for Screenings
     Discharge Screenings into Dumpsters
     Haul Screenings to Sanitary Landfill
     Screenings Quantity varies with brewery operation
     Estimated Screenings
          Minimum day = 1 cubic yard
          Maximum day = 10 cubic yards (spent grain spill)
     BCD Removal = none

NEUTRALIZATION TANK
     Retention = 5 minutes at Average Flow
     Volume = 2,700 gpm x 5 min = 13,000 gals
     Mixer = lew speed top entry turbine
     Mixer Pumping Rate = 2,700 gp% x 10 = 27,000 gpm
     Mixer Power = 2 HP
     Provide Acid and Caustic Feed Capability
     Provide 5,000 gals Storage for 95% H2S04
     Provide 5,000 gals Storage for 50% NaCH
                                 V-24

-------
                                                                     -25-
NUTKEEOT
     Nitrogen
          Base Nitrogen Required on N/BOD removed ratio = 1/25
          BOD Removed = 60,000 Ibs/day - 30,000 Ibs/day = 30,000 Ibs/day
          Nitrogen Required = 30,000 Ibs/day x 1/25 = 1,200 Ibs/day
          Estimated Raw Waste Nitrogen = 400 Ibs/day
          Nitrogen Feed Required = 800 Ibs/day
          Provide Two Anhydrous Armenia Storage Tanks
                (one tank on line and one reserve)
          Provide One 1,600 Ibs/day Evaporator
          Provide One 1,600 Ibs/day Feeder
          Feed Proportional to Monitored TOD Load
     Phosphoric Acid
          Base Phosphorus Required on P/BOD removed ratio = 1/125
          Phosphorus Required = 30,000 Ibs/day x 1/125 = 240 Ibs/day
          Estimated Raw Waste Phosphorus = 100 Ibs/day
          Feed Required = 140 Ibs/day
          Use H3?O4 @ 75%
          Feed Rate =  	140	     * 44 gpd
                      32% x 75% x 8.34 x 1.58

          Provide Storage for Tank Truck Load plus 50%
          Provide 5,000 gals Storage
          Feed Proportional to Monitored TOD Load

           TOWER
     Design BODs Loading = 60,000 Ibs/day Total and 50-000 Ibs/day Soluble
     Soluble BCD Removal Required =  (50,000 - 15,000)/50,000 = 70%
     Base Design on Following Formula:

          Le/LL

          Where Li - Influent BODs
                Le = Settled Effluent BODs
                K = Treatability Constant
                D «= Madia Depth
                q = Hydraulic Loading per Unit Area
                n = Media Constant
     n =  0.5 for BF Goodrich Vinyl Core iMedia

     Actual operation of a biological tower system pretreating brewing waste
     at one brewery, a pilot tower operated at another brewery, and a series
     of pilot laboratory studies on brewing waste indicate that two stage
     filter performance predicted with a K20 value of 0.01 is achievable with
     reasonable reliability for influent BOD concentrations averaging 2,000
     to 2,500 mg/1 and removals of 40 to 60 percent based on settled effl'-aent
     BOD.

     Suspended solids generated on the biological towers are estimated a- 50%
     of soluble BOD removed.  The BOD5 of suspended solids biomass generated
     on the biological tower systems are estimated to be 20% of BOD5 rencved.
                                V-25

-------
                                                                          -26-
    K is temperature dependent and varies as follows:

          KT » K20(1.035)T-20

    Estimated temperature extremes in the biological towers
          Summer, All Stages = 27 degrees C
          Winter, First Stage = 20 degrees C
                  Second Stage = 13 degrees C
                  Third Stage = 8 degrees C
    Temperature corrected K values:

          Summer K = .OK1.035)27"20 = 0.013
          Winter K will change with each filter, stage as heat loss reduces teen.
                  1st Stage K = .010
                  2nd Stage K = .01 (1.035) l3"20 ='0.0079

                  3rd Stage K = .01(1. 035) 8~20 = 0.0066

    Height is limited by structural capacity of media
          Maxiinum practical height = 32 feet
    Provide three stage biological system
          Make each stage same size for interchangeability
          Assume K remains constant for each stage*
          Fraction BOD remaining after each stage = (1  - O.TO)1'3 = 0.67
    First Stage Design
          Rearrange equation to calculate q and use average winter K to
          calculate media required.
                      (.010 + .0079 + .0066} /3 = .0082
               q* [-KD/lnCLe/Li)]1/11

               q * (-.0082 x 32/ln .67)2

               q * 0.43 gpn/ft2
                           •
          Area * Q/q = 3.9 MGD/.43 gpn/sf = 6,298 ft2

          Diameter = (6,298 x 4/ir) -5 = 90 feet

          ttedia Volume = 90' ? x 32 ft * 200,000 ft3 each filter

          Volume loading

               First Stage = 60,000 Ibs Total BOD/200,000 ft3 = 300 Its Total
               BOD/1000 cf

               Overall = 300 t 3 stages = 100 Total BOD/1000 cf


* K-rate was derived from 2 stage system performance with 40 to 60% removal.
For this report, the K-rate is assumed to remain valid for 3-stage system at
70% removal.  This assumption should be verified by pilot testing before
proceed ing with the project-
                                   V-26

-------
                                                                       -27-
Performance Each Stage - Winter Condition
     First Stage Performance

          Le/Li = e--01 x 32/.4S-5 = 0.614
     Second Stage Pert ormance

          Le/Li = e"'0079 x 32/.43'5 =  .680
     •Hurd Stage Performance

          Le/Li = e'-0066 x 32/.43-5 =  .725

Overall Performance
     BCD Removed based on settled effluent sample
          Le/Li =  (Le/U) 1st stage *  (LeA*i) 2nd stage x  (Wli) 3rd ^ge

          Le/Li = 0.614 x 0.680 x .725 = 0.303 fraction remaining
          Fraction Removed = 1.0 - .303 = .697
          Soluble BOD Removed = 50,000 x .697 = 34,850 Ibs/day
     Suspended BOD Removed = 10,000 x est 21% =-2,100 Ibs/day
     BCD removed based on whole effluent sample
          BOD Removed = 34,850 - 20% +2,100 = 29,980 Ibs/day

Recirculation
     Raw Waste Hydraulic Loading:
          Maximum day flow =0.52 gpm/sf
          Average day flow =0.43 gpm/sf
     Min. hydraulic Loading Required to provide adequate wetting = .75 gpm/sf
     Desirable hydraulic loading-to provide hydraulic sluffing of
          biomass under projected organic loading =1,5 gpm/sf
     Provide 2 recirculaticn pumps each stage for constant flow over filter
          capacity = 90 ft dia x .75 gpm/sf = 4,770 gpm
          Head = + 50 ft TDH

Ventilation
     Max. air required when summer temperatures increase reaction rates
     Assumed maximum tower temperature = 27 degrees F

     First Stage BCD removal at 27 degrees F

          Removal = 50,000  (1 - e--013 x 32/.43'5) = 23,487 Ibs/day
     Oxygen required per Ib BOD removed =0.67 Ibs
     Total oxygen  required = 23,487 x 0.67 = 15,736 Ibs/day
     Oxygen transfer efficiency = 2%
     Percent Oxygen in air = 23% by weight
     Density of 27 degrees C air = 0.0735 Ibs/cf
     Air flow required:

        15,736 lbs/02/day	   = 32,300 cfm
     2% x 23% x 0.0735 Ibs 02/cf Air

     Provide 50% excess air capacity
     Air capacity  = 48,000 cfm/tcwer
     Provide 2 blowers each tower
     Blower capacity 24,000 cfm @ 1" WC

                                 V-27

-------
                                                                        -28-


               Neutralizaticn - Biological Towers
                    Significant pH drop can occur on the biological towers
                    requiring neutralization between stages.

                    Provide pH monitoring and control at,recirculation wet.
                    well of second stage biological tower.

SPENT GRAIN PRESS LIQUOR STORAGE
     Purpose = Provide waste source during production shutdown
     Wastes Quantity = 3 days (§ 9,000 Ibs/day BOD
     Concentration = 20,000 mg/1

     Storage Volume =      9,000 Ibs/day x 3 davs	        = 160,000 callers
                        20,000 rag/1 x 8".34 Ibs/gal

LAND AREA REQUIRED
     Allow 50 feet from treatment units to property line
     Minimum land requirement = 300 ft x 425 ft
     Minimum Land Area =2.2 acres
     Maximum Building Height above Ground = 40 feet
     Maximum Excavation below Ground = 20 feet

POWER REQUIREMENT
     Connected Load = 600 KVA
     Running Load = 450 KVA.
     Largest Motors = 75 HP
                               V-28

-------
                     Appendix
                      TABLE 4
             60,000 LBS/DAY SCENARIO 2
            CONSTRUCTION COST BREAKDOWN
                 -29-
Raw Waste Pumping Station
     Site Work
     Structural
     Mechanical
     Force Main
  $   4,000
    35,000
    70,000
  105,000
  $214,000
Coarse Bar Screen
     Site Work
     Structural
     Mechanical
Metering Flume
     Site Work
     Structural
     Mechanical
Equalization Tank
     Site Work
     Structural
     Equipment
     Mechanical
     Miscellaneous
$
$
$


$
1,700
4,900
1,400
8,000
1,700
5,500
1,800
9,000
  $   8,000
  299,000
    29,000
    19,000
    17,000
  $372,000
Fine Screens
     Site Work
     Building
     Equipment
     Mechanical
     Miscellaneous
Neutralization Tank
     Site Work
     Structural
     Equipment
     Mechanical
     Miscellaneous
Biological Towers
     Site Work
     Structural - Concrete
     Structural - Steel
     Structural - Media Support
     Media
     Equipment
     Mechanical
     Miscellaneous

                       V-29
  $  1,000
    51,000
    69,000
    21,000
    10,000
  $152,000
  $  1,000
    21,000
     6,000
     3,000
     4,000
  $ 35,000
  $  6,000
   979,000
    18,000
   133,000
 1,666,000
   155,000
    43,000
   118,000
$3,118,000

-------
Construction Cost Breakdown - continued               -30-
Dome and Odor Control
     Structural                         $231,000
     Equipment                           175,000
                                        $406,000

Control and Pumping Building
     Site Work                          $  8,000
     Structure                           225,000
     Equipment
          Equalization Pumps              19,000
          VFD                             28,000
          Recirculation Pumps             95,000
     Mechanical                          120,000
     Miscellaneous                         8,000
                                        $503,000

Chemical Storage
     Site Work                          $  1,000
     Foundati ons                           9,000
     Steel Tanks, Two                     28,000
     FRP Tanks, Three                     15,000
     Mechanical                           13,000
     Miscellaneous                         2,000
                                        $ 68,000

Spent Grain Liquor Storage Tank
     Tank FRP                           $106,000
     Foundation                           12,000
     Mechanical                           18,000
                                        $136,000

Instrumentation and Control Systems
     Equipment
          Instrumentation Package       .5 34,000
          Neutralization System           28,000
          TOD                             15,000
          Samplers                        10,000
     Installation                         43/000
                                        $130,000

Electrical
     Ecruipment
          Air Switch                    $ 12,000
          Transformer                     18,000
          MCC                             34,000
     Main Service                         36,000
     Motor Wiring                        101,000
     Building Electrical                  25,000
     Area Lighting and Miscellaneous       8,000
                                        $234,000
                       V-30

-------
                                                       -31-
Construction Cost Breakdown - continued
Site Work
     Grading                            $ 12,000
     Paving                               26,000
     Fencing                              11,000
     Landscaping                          28,000
     Walks                                 3,000
                                        $ 80,000

Yard Piping
     Process Piping                     $135,000
     Utilities                             7,000
     Drainage                              8,000
                                        $150,000

Repiping Sanitary Sewage
     Sewers                             $100,000
                                        $100,000
                      V-31

-------
                                                              -32-
                      60,000 LBS/DAY SCENARIO 2
                 ESTIMATED CONSTRUCTION COST
            (Based on June 1977 Construction Cost)
     Item                               Cost

Raw Waste Pumping Station               $214,000
Coarse Bar Screen                       $   8,000
Metering Flume                              9,000
Equalization Tank                        372,000
Fine Screens                             152,000
Neutralization Tank                        35,000
Biological Towers                       3,118,000
Dome and Odor Control                    406,000
Control & Pumping Building               503,000
Chemical Storage Tanks                     68,000
Spent Grain Liquor Storage Tank          136,000
.Instrumentation * Control Systems        130,000
Electrical                               234,000
Site Work                                  80,000
Yard Piping                              150,000
Repiping Sanitary Sewers                 100,000
 Subtotal                              $5,715,000
Construction Contingencies @  10%         572,000

Estimated Fixed Price Construction
     Contract                           6,287,000
Engineering & Administration  @ 10%       629 ,000

Estimated Total Construction  Cost     $ 6,916,000


 (Estimated total construction cost does not include  land  cost  o:
project contingencies and is  based on unit sizes  identified  in
the design concept)
                            V-32

-------
                                                             -33-
                 100,000 L3S/DAY SCENARIO 2
                 ESTIMATED CONSTRUCTION COST
           (Based or. June 197? Construction Cost)
     Item                               Cost

Raw Waste Pumping Station               $239,000
Coarse Bar Screen                       $  9,000
Metering Flume                             9,000
Equalization Tank                        611,000
Fine Screens                             179,000
Neutralization Tank                       39,000
Biological Towers                      3,125,000
Dome and Odor Control                    440,000
Control & Pumping Building               459,000
Chemical Storage Tanks                    68,000
Spent Grain Liquor Storage Tank          166,000
Instrumentation & Control Systems        130,000
Electrical                               276,000
Site Work                                 79,000
Yard Piping                              155,000
Repiping Sanitary Sewers                 100,000
 Subtotal                             $6,084,000
Construction Contingencies 9 10%         608,000

Estimated Fixed Price Construction
     Contract                          6,692,000
Engineering & Administration 8 10%       669 ,000

Estimated Total Construction Cost    $ 7,361,000


(Estimated total construction cost does not include land cost or
project contingencies and is based on unit sizes identified in
the design concept)

                Operating  and Maintenance Cost

                                    100,000  Ibs /day  60,000  Its  i

Labor  3.6  people  $  25,000            $   90,000      $   90,300

Chemicals  and supplies                   45,000          35,000

Power  * 3C/KVA                         158,000         113,000

Maintenance                             93,000          86.00:

                                      $  386,000      $  329,CCC
                             V-33

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                                                                      -34-
                           ST. LOUIS,M.O., U.S.A. 63118


                                   May 15, 1978
Mr. Dale Luecht
Water Division
US EPA
Region V
230 S. Dearborn
Chicago, 111.  6o6oU
Dear Mr. Luecht:
Mr. George Walkenshaw of the City of Columbus has informed
me that you and Mr. Sutfin of your office are interested
in obtaining information on the potential hazards of
discharging active biomass into a sanitary sever system
as discussed in our written comments to your office in
reference to the Columbus Draft EIS.  Although our
written comments did not specify an exact case history
relating to such a hazard, we were describing an incident
that happened on July lU, 1973 in Allentown, Pa.  This
incident involved the death of two individuals who were
apparently overcome by methane gas in an interceptor
station while they were obtaining wastewater samples.
Information regarding this incident is difficult to obtain
but we have found an account of the incident as printed
in a local newspaper.  A copy of these articles are
attached for your review.

A brewery wastewater pretreatment plant was discharging
an active biomass into the sewer system upstream from the
point where the individuals were killed.  This pretreatment
plant was very similar to the system that the Columbus
Draft EIS recommended for installation by Anheuser-Busch
to pretreat the wastewater from our Columbus Brewery.
                             V-34                           *•'"
                                                           America

-------
                                                                   -35-
Mr. Dale Luecht               -2-                  May 15,  1978
Because of the potential hazards of the pretreatment system
recommended in the Columbus EIS, we believe the EPA should
carefully reconsider the environmental impact of this
recommendation.  We are available to discuss this aspect
of the Columbus EIS or any other aspect of the EIS with
you at your convenience.
                            Very truly yours ,

                            ANHEUSER-BUSCH, INC.
                            C, E. Briscoe, Jr.
                            Environmental Engineer
CEB: de
cc:  Mr. Charles Sutfin
     Planning Division
     US EPA - Region V
     230 S. Dearborn
     Chicago, Illinois  6o6oU

     Mr. George Walkenshaw
     City of Columbus
     Division of Sewerage & Drainage
     90 West Broad Street
     Room U06 - City Hall
     Columbus, Ohio   U3215
                             V-35

-------
                          .WUX  JUL151973
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                                      f-,/ *"'*'",*$ i- 'rv^-^rf^*" ^J^jt." V/ i^,^" v-' "\""'. ~  ^.f," f''" j; 7 '- >.j
      ^--- J    '/)-?<•             By STAN SCHAFFER
  Two youths 'died when they were  apparently overcome  by sewage fumes and  a third
person was seriously injured  in a  rescue attempt at a sewer  interceptor station  yester-
day morning along the Little  Lehigh Creek in southwest Allentown.

  The dead were identified as Wayne  A. Nagle, 17,  a son of Mr. and Mrs. Robert A.
Nagle of New Tripoli R.I,  and Thomas R. English, 20, a son of Mr. and Mrs. Richard B.
English of Coplay R.I.

  John S. Nevins Jr., 35, of Allentown R.2, a city water department employe,  was  injured
and apparently overcome by the gas when he attempted to  rescue the  two  youths. The
Nevins residence is about 100 yards east of the station.

  NevL-.s was admitted to the Intensive care unit at Allentown Hospital, where his condi-
tion wis reported critical.
      Fireman Admitted
  An  Allentown  fireman,  Mi-
chael Gr:m, 26, was also admit-
tecj to  Allentown  Hospital. He
was rc-pcrted in good  condition.
He re;rr:«ily becarr.e fatigued
and e.vr.zusted  while  trying to
rescue Nevins.

  Charles Alley, 19 of 235 N. 8th
St., Allentown, discovered the
bodies c: :he bottom of a pit in
the  sta::on  when  he  reported
there for  work at  3 a.m. Alley
ran to the Nevins residence for
help.
  The dsid men as weil as Alley
 were e=c.;Dyed by the Kelly La-
 bor Div:;::n, 201 N.  7th St., Al-
 lentown.. for the Lehigh County
 Author::-,- 
-------
          Inhaled Gas
  By the time he got out of the
building, he had inhaled some nl
the sewer gas and was fatigued
a/id exhausted, said Mel Keyscr,
Allentown fire department  shift
deputy.
  Assisting in the  rescue  with
Grim  were   District   Deputy
Chief Dale Werkheiser of the Al-
lentown  Fire  Department  and
Ernmaus  Fire Chief Robert R.
Reiss.
  .Hoping to pull  the bodies cut
with a rope, one at a time, were
Keyser and Allentown  Fireman
Harold Newhard.
  Rciss, who was the first on the
*cene with an air pack, said he
couldn't get Nevins up by him-
self because of his size. He de-
scribed him as boinu >i lug man,
  "lie  was
couldn't do it alone," Reiss said.
         Otbtrs Assist
  He was then assisted by Grim.
Both firemen then went into the
pit I" got NPV.II>> (ml  Tlwv wen-
.-iiiU-d  by   .WiKluiil  KiiiiiKiiit.
Kire Chief  John Shafer, assis-
tant loreman Terry Oswald and
firemen Gary Fritch and Ken-
neth Kemmcr.
  Firemen had  difficulty pulling
Nevins through  the  top of  the
hole, located at floor level in the
building, because it's only  about
2'zfeet square.
  Keyser  said that  Nevins was
unconscious when they  brought
him out.  "Another  minute  or
two  and he would  have  been
dead," Keyser said. He said the
injured  man  was   mumbling
something before he became un-
conscious. Firemen put a resus-
citator  on: Nevins  before  they
got him out, Keyser said.
  There is a sign posted at the
entrance to the pit which states:
'•.Vever enter the sump pit  un-
less  the blower  has  been  oper-
ating for at  least five minutes."
It is  believed that  the blower
was in operation at the time of
the_accident.

        Thomas English
  Born  in  Allentown,  English
was  a  graduate of  Parkland
High School and attended Mora-
vian College for two years.
  He had been employed as an
Apple Hill ski lift operator and
in the  Cedar  Brook  Nursing
Hume.
  He was  a  member of Faith
United Church of Chris', Allen-
town.
  Surviving  besides his  parents
are a brother James at home,
two. .sisters, Elizabeth,  wife  of
Jclfery J.  Hcwit of  Chester,
X.J., and Alice,  wtt'e of Barry
KUxerof RoyerMuid, Montgom-
ery  County, and his maternal
grandmother,    Mrs.   Alerta
RtMiialey of Allentown.
         Wayne Naglc
  N'agle was "a son of Robert A.
and Gloria M. (Yeager) Nagle.
His father is director of the Le-
high' County  Area  Vocational-
Technical School.
  The youth was born in Allen-
town and was a 1973 graduate ol
Freedom High School. He was a
member of First Presbyterian
Church, Bethlehem.
  Surviving in  addition to his
parents  are  three  brothers,
Keith,  Scott  and Mark, ali at
home;   his paternal  grandpar-
ents,   Mr. and  Mrs.  Charles
\agle, and his maternal grand-
parents, Mr.  and Mrs, Wilbur
Meager Sr., aU of Allentown.
  A memorial service  will be
held   in  First   Presbyterian
'•hurch, Bethlehem,  at the ton-
 »-nirnr<< ol  Hi'1  liiimlv Tlirrr
 will liu mi calling liuiira  'lliv •) •>
 Burkholder Funeral  Home is in
charge of arrangements.
                   -37-
  •-   - "A'   r>        - "••  -   •-•---- - " -•;-- -• -..-.

                                                                                  -      -    -
  GETTING  IDENTIFICATION  —  Dr.  Carl  A.
  Warmkessel, executive director  of  the authority,
  back to camera, talks with John Bliss of  Kelly
Labor, center. Chester S. Dutt:r..
man, is on the far riRht. Stanc:r
town police on-the right us Coron--
                                                        V-37

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                                                                                             -38-
FATAL ACCIDENT — Lehigh County Coroner Robert C.   • lentown yesterday. Allentown Detective Ronald Niemeyer
Weir (secc^i from left) checks scene of accident fatal to    (with clipboard) assisted in the investigation. Body of one
two workers at sewage interceptor plant in Southwest Al-    victim Is in foreground, the other in back near the plant.
                                                    Scene
Effluent
     Li.  »JUUl| 8^        ~"~	^^V\    •>
     ay Have Exceeded Limits
icsiiug ««is ^iiuei way ai uiei.taiu raui r. rkunsie, aaminis-
sewage station in Southwest Al-|trative assistant of A.L. Wiesen-
lentown when two youths wereibergcr Associates, Allentown.
("Mtiid dead Saturday In dolor-! VVicsenlwrpor is the consulting
mine whether the effluent con-iuiiginw for the authority.
tent met requirements, it was! "There's a possibility the lim-
rcported last r.ight.
The victims. Wayne A. Xagle,
17, of New Tripoli R.I and
Thomas R. English, 20, of Cop-
lay U.I. were1 participating in
the sampling on behulf of the
Lehigh County Authority (LCA).
The metenrsg station, near
where Keystone Avenue crosses
its might be exceeded, and
that's why there was testing,"
he said.
The extracting of specimens
from a pit in (he ncwtige station
ix'Kun Thursday, according to
Kwikle. . .. _
N.igle and English were em-
ployed bv Kelly Labor of Allen-
the Little Lehigh River at | town. The LCA had hired the
Keek's Bridge, measures the:. youths.
amount of s^^age enter w? the' ,\ third Kelly Labor youth.
Allentown system from Western , Charles Alley, 19. of 235 N. 8th
LehighCoun'.y. 'St.. .AllcnUmn. discovered the
"There is l inlrrreplnr station about 8 a.m.i
Ihp riHiKMil br xvilhin Imils," Sariirrliiv.
 sewage and to deposit it in a
 cooled container.
  Both Jordan and Kunkel said
 they believe Nagle  apparently
| was  overcome about midnight
 Friday.
  Their theory is based on the
 volume of sampies taken and on
 a graph recording the amount of
 sewage flow .through the inter-
 ceptor.
  Kunkel said the graph, on the
 main floor of the station, showed
 • drastic fluctuation  about mid-
 night. A float tank  in the  pit
 area, which is  wired  to th«
 graph, may hnv? been bumped
 about this time, he said.
  English, who arrived at work
 at midnight Friday, was over-
 come when he went to Nagle's
 assistance, col ice said.
                                              V-38

-------
•  Jordan said  he  knew  of no
I regulations that would have re-
 quired that the youths wear pro-
jtective  masks or clothing when
j they went into the pit.

'  But he said that he "insisted"
I yesterday  that men venturing
j inlo the pit wear air packs. And
i another worker equipped  with a
 safely  line will remain on the
'main floor of the station when
i another employe is below, Jor-
i dan said.                  |>

,  The sampling of  the effluent!
i resumed  yesterday, he  said.j:
 from a surface manhole nearp
 the station.                j.1

  The  precise  circumstances
 leading to the youth's deaths re-
 mained unknown yesterday.
                                                                                                   -39-
   •Hie  &ah oratppec/Black
  Eddy woman was rutea a sui-
  cide yesterday by pt. Stanley
  Goodwin, Bucks Chanty coroner.
   Dr. Goodwin made the ruling
  after an shjtojsy was performed
  yesterday morning on Mary E.
  Sollner, 20/\
   MissyffillneKwas  discovered
  hanging in the attic of her River
  Road residence about 5 p.m.
  Monday.
Child's Body
Is  Found
In Monro
^ of a child believed to /be 2-4
 years old was found layst night
 in a secluded area along Cher-
 ry l-«ine in Analomink, Stroud
 Towiiship.
   Corbner  DanieJ' G. Warner
 of Mosroe  Coufcty scid  the
 body had beet/in the  heavy
 brush foi an/unknown period
 of time.  \/
   He said if\will be not known
 until an autopsy is performed
 today whaLaoay have caused
 the
   Warner saidine body was
 found by a man who was look-
 ing  over his  property line
 along Cherry Lanexjbout 7:30
 p.m.
   Strocid Township polta- and
 state  police at  Stroud&burg
'arc investigating.
                                .lull)  14 Occident

                                     Diving Injuries Are  Fatal
                                      To  Catasauqua Youth,  17
                                            \                      ^    CALL/JUL 2« B73
                                                             Douglas A.  Hod^rmajK  17, of 848  Bethlehem
                                                         Road, Catasauqua, died Monday in Aller.town Ho&pi-
                                                         tal of injuries received Jiily 14 in a divine  .scr.jdeitt at
                                                         a private lake near B}(ie Heron, Pike County.
                                                         \.  L-ehigh County/Coroner Robert C. Weir attributed
                                                         dealhto severe/Spinal and head injuries. The youth
                                                         was pulled froin  Little Mud Pond  after apparently
                                                         striking his^iead on a submerged log or rock.

                                                             Hoder'manXj18 a student at the Catasauqua Area
                                                         Senior -High SchocSi, where he would have entered his
                                                         juniof year in the falK
                                                          /' Born in Allentown, He was a son of  Andrew and
                                                         Jean P. (DeWalt) HodermS
                                                             He was a member of ChrisXUCC, Shoer.ersville.
                                                             Surviving besides his parentKare a  sister Jac-
                                                         queline D., at home, and the  paternMgrandpareiits,
                                                         Mr. and Mrs. John Hoderman  of Allentown.
                                                             Services will be at  1:30  p.m.  Thursday  in the
                                                         Thomas A. Burkholder Funeral Home. 3rd  and Wal-
                                                         nut streets, Catasauqua.  Calling hours will be 7-8:30
                                                         p.m. Wednesday.
                                   DOUGLAS A. HODERMAN
                              Agencies PushP^be
                              Investigations are  contin-
                             uing into the  cause  of the
                             deaths of two young men at a
                             Lehigh County  Authority sew-
                             age station in Southwest Allen-
                             town July 14.
                              Dr. Carl Warmkessel, au-
                             thority   executive  director,
                             said it may take two weeks
                             until the cause is Known.
                              He said the authority  ts
                             awaiting an analysis  of the
                             sewage as well as a final au-
                             topsy report.
                              Wayne A. Nagle, 17, of New
                             Tripoli  n.l, and Thomas R.
                             English,  20, of Coplay R.I,
                             were killed in the sewage sta-
                             tion — apparently by  sewer
                             fumes.
                              Tests of the sewage are un-
                             der way to determine whether
                             the effluent content was ex-
                             ccssibe or met requirements.
                              The two young men were en-
                             gaged in taking samples to de-
                             termine the amount of sewage
                             entering the Allentown system
                             from Western Lehigh County.
                             They were employed by Kelly
                             Services of Alleniown in be-
                             half of the authority.
                              ,I«hn S. Nevins Jr., 35. -of A!-
 ^ ;>1*'-*O  •
lentown R.2, who attempted to
rescue the two at the station,
was listed in serious condition
in Allentown Hospital last
night.  A city water depart-
ment employe, Nrvins was
overcome by fumes  in the res-
cue attempt.
  Warmkessel said  Nafile and
English did not  wear pro-
tective masks when they en-
tered the pit at the metering
station.
  "ft had  always  been  stan-
dard practice  not to,"  he
added. "We often sampled un-
der  the same conditions, the
same way."
  Warmkessel pointed out that
after the incident "we put m
very stringent safety rules so
that  it will- never  happen
again."
  He said the sampling pro-
pram ceased last Wednesday.
He noted that it was a tem-
porary project  conducted  as
part of a study of a  consulting
engineering firm to  remedy
problems at the  authority's
pretreatment plant  near Tiex-
lertown. The firm is Malcolm
                                                                                 Warmkcsicl also said he ex-
                                                                               pects ii will take  two  more
                                                                               weeks until the authority gets
                                                                               the reports on the analysis of
                                                                               the  sewage at the  metering
                                                                               station and the final autopsy.
                                                                                 When the reports are made,
                                                                               he explained,  the  authority
                                                                               will isiue  a statement -'as to
                                                                               what the cause of death was."
                                                                                 He added that the authority-
                                                                               is "extremely upset" by the
                                                                               whole matter
                                                                                 Warmkesscl said ;he L'.S. Ki-
                                                                               riclity i Guaranty Insurance
                                                                               Co. is aivestiRatm:: the dcit'is
                                                                               in behaif of tfie authority; rep-
                                                                               resentatives 01  the State Bu-
                                                                               reau  o: Occupational and In-
                                                                               dustrial Salety, in behalf of the
                                                                               Kelly service, and the .stale at-
                                                                               torney  general's  cince also
                                                                               had an investigator checking
                                                                               the samples.
                                                                                 No reports ha\e been made
                                                                               by any of the ir.Nestigatoi'S,
                                                                               Warmkessel ucclared.
                                                                                 Palmer   Tow;;sr..p  supcr-
                                                                               visors yesterda\  adopterf  a
                                                                               resolution  settins  s-:'ety ilan-
                                                                               dards for  township  err.plo-.es
                                                                               working in se'Aer  manholes
                                                                               and a'j'iP.ouzed  spenamg up io
                                                                               $500  lor a device Co mc.-isuie
                                                                               oxygen and other  gases  in
                                                                               sewer J.nes. T/'e  >^ptrvivors
                                                                               did  not sa\ 'Afits1.  pio
                                                                               their actions.
                                                   V-39

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                                                                                                                     -40-
       Lehigh  County   Dist.  Ally.,of criminal negligence," the dis-
     George J. Joseph said yesterday
     no criminal cnarges will be filed
     by his  office against  anyone  in
     the July 14 deaths of two young
     men doing  sewage testing work
     for the Lehish County Authority
     (LCA).
       The incident  also resulted  in
     serious injury to John  S. Nevins,
    la  Cit
             of  Alicntown  employe
     who  lives near the scene  of a
     sewage-metering  station  along
     the Little  Lehigh Creek  near
     Keek's   Bridge   in   Salisbury
     Township  where  the   tragedy
     happened.  Nevins tried  to res-
    | cue Wavne A. Nagle, 17, of New
     Tripoli R. 1 and Thomas R. Eng-
     lish, 20, of  Ccplay R. 1, the two
     workers who died.
trict attorney said.
  He  said he  has so informed
the State Department  of Envi-
ronmental Resources by  letter
to Atty. William  M.  Eichbaum,
DER  general counsel and depu-
ty secretary.
  DER charged the  county au-
thority with violating four safety
regulations in  its investigation
of the double fatality.
  The complaints were  filed in
late August before Justice of the
Peace William H.  Burdette of
Salisbury Township by Frank C.
Scntz Jr.,  industrial hygienist
working  out of DER's Reading
office.
  Each of the  counts carries  a
maximum fine of $50. Violating
a  DER rule  is a summary of-
       Joseph stated that after an in- j fense  A11 of ^e charges involve
     dependent  investigation  by his
     office, which included a  review
     of findings by Alientown police,
     that the evidence does not sup-
                                                                    Nagle and English  were em-  continued at fr.e stale's request.
                                                                  ployes of  Kelly  Labor Division
                                                                                                   State offices were closed ves-
                                                                   F A *t  ,        A                  wi*-ifcW \7iJll. ^.-7 n v » V. Wi\/t3i»u > \,Jf~
                                                                  of Alientown, a temporary man-  terd    ^     cf the Armis\ice

                                                                                                 Day or Veteran Day holiday.

                                                                                                   But Atty. Robert H. Jordan of
                                                                                                 Alientown, solicitor to the ccun-
                                                                  signed the young rnen to LCA to
                                                                  collect data for one of the au-
                                                                  thority's  technical  studies  re-
                                                                  lated  to recent sewerage prob-i^ authority, has filed a petition
                                                                  }ems                           to quash the complaints of safe-
                                                                    The two  victims wen* appar-
                                                                  ently overcome by fumes in the
                                                                  sump area of the metering sta-hcarmg  cou,.  Qct  3Q  DR
                                                                  uon-
                                                                    The  results of  detailed
                                                                                                 aiked lor a continuance. Jordan
                                                                                            tox- 1 said,  and he  did not  oppose a
icolorical tests to determine the! new hearing dite of Nov. 27 be-
medical cause in the  death of;cause he agreed  the state had-
Nagle  and  English  have  notj net had adequate  time to review
twen  officially  announced  to j his petition.
date by Lehigh County Coroner!   ,    .  „    .    .....     .
Robert Weir                   !   Ir°nical!y. t.-e petition charg-
       '   ."   ...  ,  .  , .  .,  !es DER has v:;lated the consti-
  Mrs. Weir said last  night theltutional righls of the defendant
                               jr. not engag:r.i in timely, efi'ec-
                                                                  completed  autopsy reports ar-
                                    Chapter 20i of DER's rules and j rived within  the past few  days' t'j"ve
                                    regulations covering occupation- L * '    '   u    J '     ..».._,
                                    al health and safety.
                                     A DER spokesman said those
     port the filir; of charges,  such | regulations specify  precautions
    I as manslaughter,  against  any
     one.
       "There is no basis in the facts
                                         must  be taken  whenever
                                    workmen enter confined spaces
                                                                  but her husband has not  had a,
                                                                  chance to examine  them  and   In layman i ;erms the state .is
                                                                  will  not be  available  for  com-
                                                                  ment until later today.
                                                                    Burdette said yesterday he is;   In the mearume if a hearing
                                                                  still  awaiting  word  from  DER ion  the  DER  cnarges is sched-
                                                              accused of dr^rging its feet to
                                                              the prejudice c: the defense.
                                    such as the sump of the county's j for a  new  hearing  date since :ulcd, Jordan said  as  authority
                                                                                            were i solicitor he will be there
     as we know them for allegations
                                                                Purr is'topetul'lhe deans and
                                                              studej)?councils will find  a way
                                                              to Remind students each year
                                                brothers thaf
                                                Mitch Fisnkint
                                                              that when they are  involved in
                                                              horseplay, the consequences can
    CALL   DECS
    There were r.o  violations  oo 'The university's findings cou-
  Lehigh   University's   studer.  urred with those of the North-
  cooe oi conduct in events sui arnptortsCounty  district  attor-
  rounding the accidental death ol   ,    v     u  t
  a sophomore  fr^rnity  brother11^8  ofhpe   about
  this  fall,  a  university  reporiamong ft
  finds.                         led to the
    The report, given Monday to°f  Flemington  R>2,
  the  Lehigh Fonira  by Pre.tonSept  '13. As a resuttx-  J—,view  toward  possible
  Parr, vice president-student af-ms    and   "immature^ judg-j mendatlon^  to  the
  fairs, calls on ail students, how- me nt,"  Fishxin apparentlyj commiUee an^ the  facu,t-
  ever, to "see  the issues clearly jumped fro««2c^driv«iOy^,amendments ,,hjg     rt
 and  t: -.e corrective  action' loj''aternit.y  brotner,  ami  struck]	
                                "lis  head  on  the  roadv^av  oni
                                                                                     recom-
                                                                                        for
 sensitize  ourselves  and  future
 generations of Lohi^h people in I South Mountain Drive above
 the  hope  of  avoiding  further j Lehigh campus.
 tragedies of this kind."
   Parr said  he has asked  sev-
.eral  deans   and  living-group
                                  "But," said Parr,  "that does
                                not begin tu dispose cf the mat-
, councils "to establish education-! tor>lor an accident thai resulted
(al programs that v,ill deal more! in a student's  death  arose m a
                                                                                   can
(effectively witii l'--e  problems of  context of student behavior that
i possible dangerous  tehavior in1 Inu-st ^ of «rave and continuing
i th« lituJcnt commumty."        , concern to all of us."
                                                              remedy
                                                                "Ail of
                                                                                    behavior,
                                                                              clear,  realistic
                                                                                   ppropriate
                                                                                ihey seek to
                                                                        us have  a  moral re-
                                                              sponsibility lo brinj to beur our
                                                              btot thought in devising correct-
                                                                         that  will OL' cffec-
                                                              ive actions
                                                              tiVf> "
                                                         V-40

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5.1       Anheuser-Busch,  Inc.
          Anheuser-Busch,  Inc.  submitted several written
statements with  comments  regarding the draft EIS in addi-
tion to giving verbal  testimony at the public hearing.
As their comments  concern highly controversial aspects
of the proposed  wastewater treatment system, responses
are provided to  both the  written submissions as well as
the verbal testimony.   The verbal testimony has not been
reprinted in this  volume,  rather it is contained in the
official transcript.   However,  the comments numbered 5.1.7
through 5.1.16 have been  taken  from points made in the ver-
bal testimony of Mr. John L.  Stein, Manager, Environmental
Engineering Planning for  Anheuser-Busch, Inc., St. Louis,
Missouri.
5.1.1     Comment:   We  are seriously concerned about the
safety and environmental  consequences which could ensue
from implementation  of  the pretreatment scenario  (recom-
mended by the EIS) and  the failure of the draft EIS to
evaluate these  consequence.

        Response:  Please see additional  analysis regarding safety
questions which have been addressed by Energy and Environmental Analysis
incorporated independent analysis.  Appendix AA.

5.1.2     Comment;   The legal basis by which the EPA pur-
ports to impose an "industrial pretreatment requirement"
on the Columbus Anheuser-Busch brewery is not addressed
in the draft EIS, which is not surprising, because no
legal basis  exists.

          Response:  Please  see the response to comment 4.1.52 and
 Volume I Chapter  3.
5.1.3     Comment:   The  appropriate mechanism for develop-
ment and evaluation  of pretreatment design alternatives is
the Facilities  Plan,  and not the EIS.

          Response:   The EIS does not propose to require a
specific pretreatment design be implemented but uses a typi-
cal design  in the  analysis in order to evaluate alternative
system removal  efficiencies and costs.
                            V-41

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5.1.4     Comment;   Cost-effectiveness cannot be the  only
criterion used  for  selection of a treatment alternative
according to U.S. EPA's  own regulations and guidelines.
Fully ten other criteria must be considered and satisfied.

          Response:   Cost-effectiveness includes other factors
 such as environmental and socioeconomic impacts.
5.1.5     Comment :   The  cost-effectiveness analysis  as  well
as the process design  of the pretreatment facilities  con-
tain several unfounded assumptions and factual errors,
and reaches an erroneous conclusion as a result of these
errors.  These errors  relate primarily to capital cost
estimates used both  for  the brewery and for Southerly.
Analyses enclosed detail the costs Anheuser-Busch would be
expected to incur if pretreatment scenario 2 were imple-
mented.

          Response   The  preliminary design and cost  esti-
mate, as prepared by McWhorter and Associates of Savannah
and enclosed by  the  brewery suggests that the EIS efforts
have seriously understated the capital and operating costs
of Scenario 2 for the brewery.  To address this comment we will highlight
the design differences and, where applicable, note questionable or inconsistent
concepts. The following is directed to that end:


               The brewery's design flow is higher than
               that  used in the EIS

                                  Average Day Flow, mgd
                  BOD,. Release     EIS      . Brewery
                                              _——__—_
                   60,000 Ibs/day    3           3.9
                   100,000 Ibs/day   3           6.5

                (These differences should increase the
                cost of any facilities prior to  the  trick-
                ling filter.)

                The brewery uses a three stage design with
                intermediate pumping and an overall  BODj-
                loading of about 100 pounds/100  CF.day;
                the overall BOD5 removal efficiences were
                estimated as follows:
                            V-42

-------
   Total effluent basis = 50 to 55%

   Soluble effluent basis = 55 to 60%

Note:  Corrections were made during this
       review in the 100,000 Ibs/day alter-
       native to reflect failure to use all
       three stages.

The EIS used a single stage design with an
overall BOD^ loading of about 180 pounds/
1,000 CF.day; the overall BOD5 removal
efficiencies were estimated as follows:

   Total effluent basis = 40 to 45%

   Soluble effluent basis = 67%

(These differences should increase the cost
of the filters as well as add a new recir-
culation pumping cost, which we note is not
included for all three stages.)

The design equation used by the consultant
is given and defined below:
   _ /T .     -KD/q
   Le/Li = e   ' ^
                 n
   Where Li = Influent BOD5
         Le = Settled Effluent BOD5
         K = Treatability Constant
         D = Media Depth
         q = Hydraulic Loading per Unit Area
         n = Media Constant
   n = 0.5 for BF Goodrich Vinyl Core Media

Here, the key is that the consultant applies
this equation only to the soluble fraction
(influent and effluent)  through all three
stages, even though its theoretical appli-
cability is in terms of total influent and
settled effluent.  If used in its normal
manner for the consultant's design, the
predicted overall BOD5 removal efficiency
after settling would be nearly 70 percent.
Further, since this equation is based upon
             V-43

-------
               a  settled  effluent BOD,-,  which contains some
               particulate  BOD,-,  it is obvious that on a
               "total  BOD-  in minus a soluble BOD^ out"
               basis,  the BOD^ removal efficiency must be
               greater than 70 percent.   We have problems
               with this  equation and.its derivation, since
               there is no  way to define the impact or un-
               known credit achieved through solids-liquid
               separation.   Thus, when using this equation
               and  interpreting published data, it is im-
               portant to qualify it by the sedimentation
               system which follows the trickling filter.

                    This  is not to claim that the technique
               used in the  Draft EIS is any better  (see the at-
               tached Flocor curve, which we used in conjunction
               with the assumptions defined in our letter
               of March 29,  1978), but only to point out
               that the Consultant's use of the equation
               is clearly inconsistent with its intended
               use  and that precise conclusions are thereby
               questionable.   Indeed, it further suggests
               that if the  consultant would have used the
               equation as  it was intended, he would have
               predicted  an overall BOD,, removal efficiency
               on a soluble effluent basis in excess of
               70 percent,  as compared to the 67 percent
               efficiency used in the EIS.

                    The next question is, "Did the consul-
               tant err in  any other assumptions?"  Although
               this cannot  be answered conclusively, some
               study of the treatability constant used is
               warranted.  Originally, the brewery's con-
               sultant took this constant as 0.01, and
               subsequently adjusted it downward to 0.0082
               to reflect winter conditions through all
               three stages (Note here, the EIS cited per-
               formance is  only for average annual condi-
               tions while  the consultant's performance is
               for  winter conditions.).  In reviewing a
               publication by McWhorter on a brewery
               waste design (.1), we note from the informa-
               tion given that he may have used a treat-
               ability constant of 0.016 in the past with
               the  same equation, as shown below:
(1)  McWhorter, T.R. and Zielinski, R.J., "Waste Treatment for the
    Pabst Brewery at Perry, Georgia".   26th Annual Purdue Waste
    Conference (May, 1971),
                            V-44

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V-45

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   Removal efficiency = 45% for a BOD- load-
     ing of 300 Ibs./lOOO CF.day

   Q = 1.3 mgd

   Two filters @ 41 SF diameter and 22 feet
     of depth

   (Superficial hydraulic load =


        _JU300,OOOJ4)
        1,440(41)^(2) (TT)
                            n _.     .
                          = 0.34 gpm/SF
     0.55 = e-22K/(0.34)°-5;  R= Q^

We also not from page 11 of this same publi-
cation, that McWhorther states:

     "In the design a 45% BOD removal was
     allowed for the filters.  Normally a
     much higher removal would be expected
     for a soluble carbohydrate waste of
     this nature, however, the extreme vari-
     ations of BOD loading and pH were ex-
     pected to adversely affect the filter
     efficiency."

     We do not understand this new conser-
vatism, especially since it is our under-
standing that the Columbus brewery was to
restrict its maximum daily BOD- release to
no more than 25 percent over tne average
day value and the pH swings are fairly easy
to control.  It is interesting to note that
if the treatability constant of 0.016 is
used in the Columbus situation with the
Consultant's equation, the predicted overall
treatment efficiency now goes to nearly 90
percent (adjusting this constant for winter
temperature influences yields an overall
BOD,, removal efficiency of about 82 percent) ,
Conversely, resubstitution of this treat-
ability yields the following hydraulic load-
ing rate to the first stage filter, as shown
below:
             V-46

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No temperature  adjustment,  K = 0.016

     q =  (-.016 x  32/ln.67)2 = 1.6 gpm/SF

With temperature adjustment, K = 0.0123

     q =  (-.0123 x 32/ln.67)2 = 1.0 gpm/SF

These hydraulic loading rates to a three
stage system yield an  overall BODj. loading
rate of 370 and 310 Ibs of  BODp per 1000
cf.day at  1.6 and  1.0  gpm/SE, respectively,
These values are well  in excess of the 180
lbs/100 cf.day  BODs loadings used in th.e EIS
     The preceeding  discussion,  even with
the assumption  that  the  equation is valid
for the manner  that  it was used, suggests
that the brewery's consultant may be some-
what conservative in his definition of sys-
tem needs .

The consultant's cost estimates  are summarized
in Table 1.  As can  be seen,  the 60,000 Ib./day
condition is only 6% cheaper  in  first cost
and 15% cheaper in operating  costs than the
100,000 Ib/day  option.   It can also be noted
that in seven instances  the 60,000 Ib./day
condition has the same or higher facility
costs.  The seven areas  amount to some 70
percent of the  entire cost prior to the intro-
duction of any  contingency or administration
and engineering costs.   Superficially, one
would not expect such a  lack  of  influent
load sensitivity, especially  in  terms of
biological towers and the control and pump-
ing building.   As shown  in Table 2, the de-
tailed breakout for  the  biological towers
and the control and  pumping systems also
shows that either one or both of the condi-
tions was improperly designed or costed.

Although the precedina raises questions of
credibility in the brewery's  statements concerning
the content of the EIS,  the proposed designs  and
costs show little  disagreement with those found in the
EIS, as shown in the following comparison:
             V-47

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                         TABLE 1

                       SCENARIO 2
       ESTIMATED CONSTRUCTION AND OPERATING COSTS
         (Based on June 1977 Construction Cost)
        Item

Raw Waste Pumping
 Station
Coarse Bar Screen
Metering Flume
Equalization Tank
Fine Screens
Neutralization Tank
Biological Towers
Dome and Odor Control
Control £ Pumping
 Building
Chemical Storage
 Tanks
Spent Grain Liquor
 Storage Tank
Instrumentation £
 Control Systems
Electrical
Site Work
Yard Piping
Repiping Sanitary
 Sewers

     Subtotal

Construction and
 Contingencies 3 10%

Estimated Fixed Price
 Construction Contract
Engineering £ Admin-
 istration 3 10%

Estimated Total Con-
 struction Cost
Q , 6.5 mgd
BODC 100,000 Ibs/day
3 — '
$ 239,000
9,000
9,000
611,000
179,000
39,000
3,125,000
440,000
459,000
68,000
166,000
130,000
276,000
79,000
155,000
100,000
$6,084,000
3 . 9 mgd
60,000 Ibs/day
$ 214,000
8,000
9,000
372,000
152,000
35,000
3,118,000
406,000
503,000
68,000
136,000
130,000
234,000
80,000
150,000
100,000
$5,715,000
*
0.90
0.89
1.00
0.61
0.85
0.90
1.00
0.92
1.10
1.00
0.82
1.00
0.85
1.01
0.97
1.00
0.94
   608,000


 6,692,000

   669,000


$7,361,000
   572,000


 6,287,000

   629,000


$6,916,000   0.94
 (Estimated total construction does not include land cost or
project contingencies and is based on unit sizes indentified
in the design concept.)
                            V-48

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                  TABLE 1 - (Continued)


             Operating and Maintenance Cost

                            100,000 Ibs/day   60,000 Ibs/day
* 60,000 Lb./day
 100,000 Lb./day
Labor 3.6 people
 S) 25,000                     $   68,000         $   68,000   1.00

Chemicals and
 supplies 3 1.5                   30,000             23,000   0.78

Power a 3[/KVA
 a 1.2                            79,000             56,500   0.74

Maintenance a 1.25                74,000             69,000   0.92
                              $  251,000         $  329,000   0.85
                            V-49

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                    TABLE 2

 DETAILED COST BREAKDOWN OF BIOLOGICAL TOWERS
       AND CONTROL AND PUMPING BUILDING
                              BOD  Lbs/Day

                         100,000"         60,000

Biological Towers
  Site Work             $    4,000   $    6,000
  Structural -
    Concrete               982,000      979,000
    Steel                   18,000       18,000
    Media Support          133,000      133,000
  Media                  1,674,000    1,666,000
  Equipment                147,000      155,000
  Mechanical                29,000       43,000
  Miscellaneous            138,000      118,000

                        $3,125,000   $3,118,000

Control and Pumping Building
  Site Work             $    8,000   $    8,000
  Structure                210,000      225,000
  Equipment
    Equalization Pumps      26,000       19,000
    VFD                     35,000       28,000
    Recirculation Pumps     75,000       95,000
  Mechanical                97,000      120,000
  Miscellaneous         	8,000   	8,000

                        $  459,000   $  503,000

     A similar conclusion appears to apply for the
     overall capital cost estimate.
                       V-50

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   BOD  , Ibs/day           100,000              60,000
                       1977    1974/1975    1977    1974/1975

  Capital Costs -
   Million $             7.4       5.9      6.9       5.5
     (divide by 1.25)
  Operating Cost -
   $l,000/yr.
     Labor
       (divide by 1.33)   90        68       90       68
     Chemicals
       (divide by 1.5)    45        30       35       23
     Power
       (divide by 2)      158        79      118       56
     Maintenance
       (divide by 1.25)   93        74       86       69

                         386       251      329       216

  Present Worth Equivalent,
   Million $                        87

  Present Worth with
   Southerly, Million $           111                104

  EIS Statement for
   Scenario 2 Present Worth
   with Southerly, Million $      110                102

  (% Difference)                   <1                <2

            From the above, it can be concluded that
       there is no difference  in the relative ranking of
       each scenario if  the values suggested by the
       brewery are used  in Table IV-2 of the EIS.
5.1.6     Comment;  The City of Columbus has stated that
they do not feel that the bulking problem is caused by
the treatment of brewery wastes.  Their analysis has
shown that their bulking problem is due to the presence
of a blue-green algae and not from the presence of fila-
mentous bacteria.  The assumption made in the EIS about
the bulking problem is unfounded.
                           V-51

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          Response:  Please see Appendix AA for a detailed discussion
of the bulking problem.

5.1.7     Comment;  The Impact Statement assumed the cost of
additional facilities at Southerly under the expanded Brewery
condition to be $66.4 million.  However, in developing their
cost of additional facilities at Southerly under present load-
ing conditions from the Brewery, the same cost was assumed.
Although the load to the Southerly plant decreased by approx-
imately 16 percent, no reduction in cost was assumed.

          Response:  The EIS did not assume the $66.4 million
cost for additional facilities at Southerly; it was taken di-
rectly from the Facilities Plan.  The Facilities Plan did not
directly address the brewery or its load.

     As explained in Appendix I, the EIS review of the Facili-
ties Plan's influent characteristics with a 60,000 Ib/day BODs
load from the brewery indicated that the concentration values
were adequately stated but that on a mass basis, the higher
flows of the Facilities Plan resulted in about 30 percent more
BODs and SS.  Changing the brewery's BOD5 load to 100,000 lb/
day gave agreement with the Facilities Plan's BOD5 mass but
maintained the previously cited differences in SS mass and
flow.  The review of the Facilities Plan for Southerly suggested
that some facilities might have to be expanded, while others
could be reduced or eliminated  (see Table 1-20).

     In recognition of the potential arguability of some of
the EIS recommendations for first cost savings as well as
additional capital improvement expenditures, it was decided
to develop Table IV-2 by considering the cost changes only
associated with the brewery and its various load and pretreat-
ment options.  This decision primarily impacts the trickling
filter.  Whether or not the brewery releases a nonpretreated
load of 60,000 Ib/day or 100,000 Ib/day causes a trickling
filter loading difference of about 15 or 25 percent on a total
or soluble BOD5 basis.  At these loading rates we would expect
a 5 percent change in the soluble BOD removal efficiency of
the trickling filter.  In our view, this change is insignifi-
cant, and we left the sizing of the trickling filters unchanged.
Alternately, we could have started from the 100,000 Ib/day
BODs brewery discharge condition, which most closely approxi-
mates the influent BODs mass found in the facilities plan, and
reduced the trickling filter's sizing in strict proportion to
the applied soluble BODj.  A 25 percent reduction in the filter
sizing would have resulted in a 15 to 25 percent savings in the
$3.0 million cost of the trickling filter or about $0.4 to $0.8
million.  This savings, associated with the 60,000 Ib/day 6005
release from the brewery is about 1 percent of the cost of the
Facilities Plan and, in our view, too insignificant to include
in Table IV-2.
                           V-52

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5.1.8     Comment;  Under Scenario 2, and an expanded Brewery
condition, the cost at Southerly was estimated to be $48.1
million.  The total load to the Southerly Plant under this
alternative was assumed to be 205,000 pounds BOD per day,
and 205,000 pounds of suspended solids per day.  Under the
present Brewery condition and Scenario 1, the load at
Southerly was assumed to be 205,000 pounds of BOD per day
and 165,000 pounds of suspended solids per day; the cost
of the facilities at the Southerly Plant was estimated at
$66.9 million.  Therefore, it was assumed in the cost
analysis that it would cost $18.3 million more to construct
a facility that would handle the same amount of BOD but
only 80 percent of the suspended solids load.  This assump-
tion was based at least partly on the fact that the Impact
Statement assumed that if pretreatment were implemented at
Anheuser-Busch the biologica-l filters at the Southerly Plant
could be eliminated.  Anheuser-Busch agrees with Ohio EPA
and the City of Columbus that this is an erroneous state-
ment.

          Response;  As shown in Table IV-1, Scenario 2
results in 16 percent less total BOD5, 36 percent less
soluble BOD5/ and 17 percent more suspended solids, in com-
parison to Scenario 1.  The reviewer has confused the
60,000 Ib./day BOD5 brewery load of Scenario 1 with the
100,000 Ib./day BODV brewery load of Scenario 2.
5.1.9     Comment;  The original Facility Plan estimated
the operating cost of the Southerly Plant to be $5.5 million
per year if the Southerly Plant accepted the total load
from the expanded Brewery.  However, the EIS assumed that
if the Brewery was operated at the present size, the oper-
ating cost would only be reduced by $100,000 per year.
This means that although the load to the Southerly Plant
would be approximately 16 percent less, the operating cost
would only be reduced by approximately 1.8 percent.

          Response;  The reviewer is correct in his inter-
pretation.  Personnel and chemical costs would show no
significant change, the power savings by eliminating the
pumping for the trickling filter and some solids handling
systems would be fractionally compensated for by the addi-
tional aeration horsepower requirement of the activated
sludge system, a slight maintenance savings will be derived
via the eliminated unit processes.
                            V-53

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5.1.10    Comment;  The EIS made no mention of the reduction
of performance of the trickling filter under cold weather
conditions.  In many installations, it has been found that
the performance of the trickling filter can be reduced by
as much as 60 percent under cold weather conditions similar
to those present in the Columbus area.  This error caused
the facility requirements of the Southerly Plant to be
underestimated when pretreatment is assumed at the Brewery.

           Response;  Why is trickling  filter failure more
likely at  the brewery than at Southerly?  Especially  (in
contrast to present practice) with the brewery providing
equalization and  neutralization facilities under the EIS
 analysis.
5.1.11    Comment;  The EIS made no mention of the fact that
the trickling filter is frequently subject to treatment
upsets.  Under such an upset condition, the efficiency of
the trickling filter could be reduced to zero for an ex-
tended period of time.  The EIS does not address the fact
that, under such an upset condition, the Southerly Plant
would be accepting the entire untreated effluent from the
Brewery which would cause a severe shock load on the
Southerly treatment system.  This error caused the facility
requirements at the Southerly Plant to be underestimated
when pretreatment is assumed at the Brewery.  However, it
should be noted that if the trickling filter was installed
at the Southerly Plant for treatment of combined brewery
and municipal wastewater, it would significantly reduce
the chance of upset.

          Response:  Data should be provided to support
the contention.  Please see previous responses to comments
on pretreatment design and Appendix AA.


5.1.12    Comment:  In addition to assuming that the trick-
ling filter would continously operate at a prescribed per-
formance level, the EIS also assumed the.t the solids pro-
duced from the trickling filter could be removed in the
primary clarifier at the Southerly Plant.  However, experi-
ence has shown that when the trickling filter is operated
in a pretreatment mode, a very low efficiency is obtained
from conventional sedimentation.  This error has caused
the facilities requirement at the Southerly Plant to be
underestimated when pretreatment is assumed at the Brewery.
                            V-54

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          Response:  The proposed sedimentation tank has a
design surface overflow rate of 500 to 600 gpd/SF and an
assumed effluent suspended solids of 100 to 200 mg/1 due
to poor settling characteristics.  We do not believe this
to be optimistic or impossible to achieve.  The reviewer
makes the mistake of blindly looking at percentage numbers;
he is reminded that an activated sludge system with 2,000
mg/1 MLSS will routinely achieve a suspended solids re-
moval efficiency of 98 to in excess of 99 percent.
5.1.13    Comment;  Under Scenario 3, the EIS assumed
approximately 95 percent efficiency of the conventional
settling basin at the Brewery for removing the suspended
solids produced from the trickling filter.  However, as
noted above, this is impossible to obtain under actual
operating conditions.  This error has caused the facility
requirement at the Southerly Plant to be underestimated
when pretreatment is assumed at the Brewery.

          Response;  Please see previous responses to com-
ments on pretreatment design.
5.1.14    Comment:  In the estimation of costs for the
pretreatment facility, the EIS did not include the cost
of odor control equipment.  Based on experience in other
locations, it would be impossible to operate a pretreat-
ment facility in a residential area similar to that around
the Brewery unless extensive odor control was provided.
This omission resulted in a severe underestimation of the
cost of the pretreatment facility at the Brewery.

          Response:  The estimates did include a cost credit
for odor control, see  EIS Table IV-1 and Appendix AA.
5.1.15    Comment;  The EIS assumed that a considerable
savings in capital and operating costs could be realized
at the Southerly Plant if flow equalization is provided
at the Anheuser-Busch Brewery ahead of the proposed pre-
treatment facility.  The EIS assumed that if the equaliza-
tion tanks were "of sufficient capacity and operated in a
manner that will cause the Brewery's ultimate pollutant
release to conform to the reverse image of the normal
domestic pattern of wastewater generation.  Operation in
this manner, i.e., release of two-thirds of the pollutant
                            V-55

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load in the 6:00 p.m. to 6:00 a.m.  time  period,  will dampen
the pollutant mass peaks experienced  at  the  Southerly treat-
ment works and yield a more  stable  operation."   On the sur-
face, this recommendation appears to  have  a  great deal of
merit.  However, several factors need to be  considered.
In order to design a system  to  release two-thirds of the
Brewery wastes in a 12-hour  period, it would be  necessary
to design the system one of  two ways.  The subsequent
analysis in the EIS goes on  to  state  that  the equalization
of wastes at the Brewery would  reduce the  peak energy
requirements at the Southerly Plant and  allow the Southerly
Plant to treat the Brewery wastes at  night when  the elec-
trical rates were assumed to be lower.   However,  since the
travel time in sewer system  from the  Brewery to  the Southerly
Plant is approximately 12 to 14 hours, this  would cause
Anheuser-Busch to treat its  wastewater during the peak
energy demand period.  Therefore, any power  cost savings
realized at the Southerly Plant would be offset  by in-
creased power costs at the Brewery.
         Response:  Flow equalization benefits all  scenarios.  For
the 60,000 Ib./day BOD5 brewery release under Scenario 2, using the
brewery's cost values, a 30 percent increase in the equalization tank
would cost no more than  $110,000  (1.6% of  the  total esti-
mated cost) and  effluent equalization  of storage tank
would cost no more than  $372,000  (5.4% of  the  total esti-
mated cost) - Conclusion:  not  significant,  odor control
can be  achieved  if it  is a design goal.  Potential alter-
native, go to Scenario 3, which is within  10 percent of
the total present  worth  of Scenario  2.

          As to  power  charges,  we recognize  the problem
but it  is incumbent upon the EIS  to  point  out  potential
mechanisms for operating savings  for a public  facility.
It appears that  equalization is far  easier to  achieve at
the brewery than at Southerly.   We might also  point out
that there seems to be some confusion  regarding the travel
time in the sewer.  In attempting to discredit the power
savings of the EIS, the  brewery cites  a time of 12 hours.
However, in their  comments regarding septicity, the City
of Columbus assigns a  23 hour travel time  from the Brewery
to Southerly.
                            V-56

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5.1.16    Comment;  According to some of the foremost
authorities.on brewery waste treatment, experience with
the pretreatment of brewery wastes with a trickling fil-
ter has not been proven to eliminate a bulking sludge
problem if one does exist.  For these reasons we believe
that it would be extremely unwise to delete the pilot
treatment plant program at the Southerly Plant.

          Response;  The reviewer should identify the
foremost authorities by name and association before cre-
ditability can be attached to this statement and so the
context of their remarks can be delineated.
                            V-57

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5.2  Columbus Industrial Association

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    5.2
       COLUMBUS   INDUSTRIAL  ASSOCIATION
            1515 WEST LANE AVENUE • COLUMBUS. OHIO 43221 • TELEPHONE 4B6-S741


                                                      April 13, 1978


                                                         (5.2.1-5.2.4)
Planning Branch - EIS Preparation Section
U. S. Environmental Protection Agency,  Region V
230 South Dearborn Street
Chicago, IL  60604

Dear Sirs:

     Our Association has reviewed the EIS respecting  "Wastewater Treatment
Facilities for the Metropolitan Area of Columbus, Ohio" and the comments of
our Association members present at the  Public Hearing on March 30.

     Here is the position of our Association, adopted by our Board of Directors
at their Board Meeting on April 12,  1978,  respecting  this Draft EIS.

     We have very serious reservations  respecting the legality and advisability
ot EPA requiring pretreatment of compatible wastes.   This requirement seems to
be contrary to the Water Pollution Control Act.

     The EIS does not appear to contain adverse comment respecting the Facilities
Plan developed by the City of Columbus  and for which  approval has been sought.
Consequently, the promotion of alternate methodology  is puzzling.

     The EIS does not address the environmental impacts of either the City's
Facilities Plan or the alternate methodology proposed by EPA.  Should not
environmental impacts be the main theme of an EIS?

     It is very disturbing to find that the EIS apparently was prepared without
seeking any input from or cooperation with appropriate personnel in the City of
Columbus.  Assuming that one of the  principal goals of EPA is to' benefit the
general welfare by seeking appropriate  participation  in the planning process, we
cannot comprehend the reason for this glaring omission.

     We find disturbing indeed the recommendations in the EIS implying federal
control of municipal area geographic and economic growth by dictating sewer
location and specifications.   We feel strongly that our municipal area must be
granted the widest latitude possible to determine its own future growth charac-
teristics.


                                        (Continued  	 )


                                       V-58

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Planning Branch - EIS 'Preparation SEction
Page 2
Ar '1 13, 1978
     We recommend that EPA accept the City of Columbus' Facilities Plan and
give EPA's approval to implement that plan without further delay.

                                        Sincerely,

                                        COLUMBUS INDUSTRIAL ASSOCIATION
                                        Newton A. Brokaw
                                        Executive Director
pmp
cc:  Senator John Glenn
     Senator Howard Metzenbaum
     Representative Sam Devine
     Representative Chalmers Wylie
     Mayor Tom Moody
     Public Service Director Robert C. Parkinson
     EPA, Washington, DC
                                       V-59

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5.2       Columbus Industrial Association
5.2.1     Comment;  We have serious reservations respecting
the legality and advisability of U.S. EPA requiring pre-
treatment of compatible wastes.  This requirement seems
to be contrary to the water pollution control act.

         Response:  Please see response to Comment 4.1.52 and Volume
 I Chapter 3.


5.2.2     Comment:  The EIS does not address the environ-
mental impacts of either the City's Facilities Plan or the
alternate methodology proposed by U.S. EPA,

          Response;  The discussion of environmental im-
pacts has been expanded in several areas, particularly in
regard to air quality, sludge disposal and pretreatment
alternatives.  See Volume I and Appendices Volume II.


5.2.3     Comment;  The EIS apparently was prepared without
seeking our input from or cooperation with appropriate
personnel in the City of Columbus.

          Response;  During the preparation of the EIS,
numerous meetings were held with City personnel.  The staff
from the Division of Sewage conducted tours through the
existing treatment facilities and provided considerable
information and assistance to the authors of the EIS.
5.2.4     Comment;  Our municipal area must be granted the
widest latitude possible to determine its own future  char-
acteristics.  Federal control of municipal area geographic
and economic growth by dictating sewer location and speci-
fications is a disturbing implication in the EIS.

          Response:  The U.S. Environmental Protection Agency
is not out to block community growth..  Our policy  is  to  ensure
that facilities are built with  adequate reserve capacity and
to preclude the funding of excess reserve capacity.   The large
backlog of needs  for wastewater treatment facilities  across
the United States means that EPA must allocate its resources
primarily to correct existing pollution problems.

     The draft EIS for Columbus found that most gravity  sewers
would be cost-effective if designed to flow half full when
serving the year  2000 projected population.  Such  a design
is equivalent to  providing sewer capacity for about forty
years.  We believe this provides ample flexibility for growth
in the Columbus area.

                            V-60

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5.3  Development Committee for
       Greater Columbus

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     5.3
                                                                             •so
           TWO  HUNDRED  EAST TOWN STREET   COLUMBUS-,  OHIO  13215  614/221-7871
             eE j
Charles W. Fullerton
   Chairman

Dr. Edward O. Mou'iton
   Chairman-Elect

Robert H. Potts
   Treasurer

JoiidC. Gallucci
   Secretary
Ralph H. Anderson, S.'.
William H. Anderson
Lou J. Bn'ggs
A.Chailos Brooks
A r -Cocfiian
V'   .hurCiillman
Waiter R. Dryden
MarkG. Femknopf
Stephen!. Guthrie
Jerome J. Hackman
Charles G. Hammond
Will Hellerman
Geoige W. Hockaden
H. James Holroyd
Joseph P. Jester
Haiold Jett
Richard E. Luecht
John G. McCoy
David R. Patterson
James Petropoulos
James W Phillips
Samual H. Porter
Hjrley E. Rouda
Arthur J.Scott
Fredric L. Smith
H.Clifford Taylor
Phillip W.Tefft
Richard L. Tully
'Charles G. Vath
Edward F. Wagner
Willis C.Welch
Ralph R. Widner
                           April  25,  1978

Mr.  Valdas  V.  Adamkus
Deputy  Regional  Administrator, Region V
United  States  Environmental  Protection
  Agency
230  South Dearborn  Street
Chicago, Illinois   60604

Attn:   Mr.  Gene  Wojcik
        E!S  Preparation Section
        Planning  Branch
Dear  Sir;
                                  Re:   Draft Environmental
                                        Impact  Statement  for
                                        Wastewater Treatment
                                        Facilities for  the
                                        Metropolitan Area  of
                                        Columbus,  Ohio
      This organization has  since its  inception been  deeply
involved in  capital  improvement programs in  Franklin  County
and,  of course,  the  Sewer Program  is  one that has  been ex-
tremely important to  the growth of  our area.

      Our Water Management Committee  has recommended  to our
Steering Committee and received its  approval  to submit a
position statement on  the above document.
      A  copy  of our
ate  having it  made
record.
comments is  enclosed.
a part  of the  official
We would appreci
public  hearing
                            Sincerely,
                                    -remean
                                 utive  Directo
                 WJC/lb
                 Ends.
                                               EI-'A
                                                                           5
                                      V-61

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                                                   -2-
      ENVIKONMENTAL IMPACT STATEMENT



                   ON



     WASTEWATER TREATMENT FACILITIES



                FOR THE



       METROPOLITAN AREA OF COLUMBUS
                Comments  By





DEVELOPMENT COMMITTEE FOR GREATER COLUMBUS



              April  25, 1978
                   V-62

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                                                      Apri1,  1978
                                                                    -3-
            Statement on the Draft Environmental  Impact Statement
                 Development Committee for Greater Columbus
The Development Committee for Greater Columbus is a privately sponsored,
non-governmental funded.organization, which was formed in 1957 to encourage
and promote sound planning of programs which would best serve people of
this area.  We have consulted with individuals and agencies  of civic and
governmental bodies to prepare master plans for the anticipated long range
needs of Franklin County's future residents, also helping work out problems
which had to be resolved in order that those programs could  be implemented.
Enclosed is some material which better illustrates our activities and pro-
grams .
if
Since our very inception the Water Management Committee has been one
the most involved and active parts of DCGC.   Its members included numerous
professional persons in engineering, planning, economics, conservation,
real estate and many other fields.  Over the last 20 years we have devoted
thousands of man-hours to review and analysis of the Sanitary Sewer pro-
gram in all its aspects.
It might be repetitive for us to discuss the technical issues in the EIS  '
since tney have been thoroughly analyzed by experts in the public agencies
involved in the Facilities Plan development and other interested organiza-
tions so we will not discuss many of them even though we have strong feel-
ings.  But some of them do have a direct and tremendous impact on major
decisions so we feel justified in ta.king a very firm position on some of
the most important basic issues.

POPULATION PROJECTIONS
Population projections have been questioned.  Historically, our rate of
                                  v-63

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Szacogent on the Draft Environmental  Impact                     -4-
Sta tenant
Development Committee for Greater Columbus
Page No.  Two
growth and population distribution have never followed the pattern of
other urban areas in Ohio and certainly they never conformed to national
averages.   Due to an aggressive annexation program plus tho City of
Columbus contracting with all other municipalities to provide water and
sewer service the growth pattern is flexible and has been healthy in
spite of some urban sprawl.
This issue has been a matter of extensive discussion in the past several
months.  Representatives of Mid-Ohio Regional Planning Commission, City of
Columbus Department of Development, Columbus Area Chamber of Commerce,
Ohio State University, Battelle Memorial Institute, Ohio Department of
Transportation, Ohio Department of Development and DCGC have participated
in analyses of all available data to determine projected trends in popula-
tion growth rates and distribution.  Certainly conclusions by the person-
nel with great expertise in these organizations who work with this type
of study all the time, should have more validity than figures developed
by persons unfamiliar with the area (and who we assume must be using
national average figures for urban areas).     (5.3.1)

JESIGN CONCEPT
                                                                 • f
The concept of using force mains instead of a gravity system violates the
principle on which our entire program has been developed1.  Several projects
were constructed in the past years for the express purpose of eliminating
such sections which were constant operational problems and created very
objectionable odor conditions at the pumping stations.  The Columbus sys-
tem, which is planned for ultimately serving the entire Franklin County
                                  v-64

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                                                                -5-
Sta tei.ient on the Draft Environmental  Impact
S ta ceil!en t
Oevelopment Committee for Greater Columbus
Page No. Three
area,  has always been based on being  with gravity flow.  Introduction
of force mains is considered retrogressive and the results totally un-
acceptable.  Force mains will create  operating problems, nuisance  from
odors  and are considered hazardous to public health.  Their permanent
energy demand requirements are cause  for concern because of electrical
power  system reliability and the concept is in direct violation of Presi-
dent Carter's philosophy for energy conservation.
We suspect that one reason for the EIS recommending force mains to serve
pockets of land not now adequately served by a public sewerage system,
coupled with elimination (or indefinite postponement) of several  major
trunk  lines, is effort by EPA to restrict or completely control growth.
We submit this is an erroneous conclusion and is an impossible means of
accomplishing their suspected objective.  Delimiting areas to be  served
by adequate public systems will  not result in all new growth only  taking
place  there.  From years of actual experience we know that new private
and commercial buildings will be constructed on lots with their own pri-
vate system, or else a package plant  will be constructed by a developer
under  County or Public Utilities Commission permit, to enable development
to proceed.  Cost of water and sewer, although always one of the  first
                                                                 'i
considerations, is not a major determining factor on whether land  is to
De developed or not.
Ha re-emphasize, however, that growth  areas can not be narrowly and speci-
fical.ly defined.  Therefore, if  we expect to continue planning and develo
ing a  good sewer system to serve the  entire area (which has been  the goal
                                 v-65

-------
 . tatcwent on the Draft Envi ronmenta'i  Impact
Statement
Development Committee for Greater Columbus

Page No.  Four


from its  Master Plan stage in 1953)  restrictions  and limitations re-

sulting from the EIS recommendations  would  result in an  inadequate,

fragmented set of private or package  systems  throughout  the county -

a condition which should not be permitted,  could  not be  tolerated and

one which we are continually working  to eliminate.


A second  reason for the recommendations apparently  is to reduce cost of

the program since original cost estimates have been exceeded.   Mostly

this increase has been due to the delays caused by  Federal  agencies  im-

pounding  appropriated funds  and the  extensive, complicated  frustrating

federal approval process.  In view of the fact that inadequate systems

or facilities could result in heavy  fines levied  on the  local  community

which operates the system it seems more proper to develop the  system on

accepted, safe criteria and  concept.       (5.3.2)


DESIGN CRITERIA

Obviously, a substantial part of the  theoretical  cost savings  is a major

reduction in design criteria.


The EIS Interceptor Alternatives is  based on  population  projections  for

a 20 year design period with the sewer flowing half full.  This has  no

direct relationship with design of the interceptor sewers on an ultimate

population basis (the design used by the City of Columbus)  since there is

nothing to prevent population projections in  the  next 20 years  from xripl-

ing, quadrupling,or more , leaving the original installation  substantially

undersized.  We have experienced some major problems where  the  density of

area when  it developed  exceeded the estimated load and .correct!vc action.
                                   V-66

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Statement on the Draft Environmental  Impact

Statement

Development Committee for Greater Columbus


Page No. Five




was expensive and involved extensive  damage in built up areas.   The En-


vironmental Impact of a parallel relief interceptor that v/ill  then be


needed would be much more severe than those where the original  inter-


ceptor was properly sized initially.   Very frankly, we do not  feel that


designing for only 20 years is worth  taking the risk.  The design of


trunk sewers and interceptors used by the City of Columbus has  proven


so successful in the past in providing adequate service the City would


be ill advised to depart from their present criteria.   (5.3.3)




ANHCUSER-.BUSCH BREWERY


At the least you can say our people were shocked to discover that pre-


treatment, using a trickling filter process, was recommended to handle e.


fluent at the Anheuser-Busch brewery  north of S.R.  161.  Certain conclu-


sions from reviewing that item were quite disturbing.


           1.  It appeared obvious that application of a trickling


               filter recommendation  for these conditions had  not


               been tested out in sufficient detail to provide  con-


               vincing documentation  that it would  accomplish  its


               objective.  Only one such identical  purpose installa-


               tion is known and it has not proven  to be capable of
                                                                 • f

               meeting all the anticipated results  EPA has assumed.


               Therefore, it does not seem logical  or justified to


               install it here, then  try to make it work.




           2.  The economic conclusions bused on this recommendation


               are seriously questioned when the figures show in one

                                 v-67

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Statement: on the Draft Environ in en toil Impact
•it a tern en t
De ve 1 opiiiC-Ti t Committee for Greater Columbus
Page No. Six
             instance that for the Southerly Sewage Treatment
             Plant it would cost $18.3 million more to construct
             a facility that would handle the same amount of BOD
             bjjt only 80% of the suspended solids load from the
             brewery by eliminating trickling filters at the plant.
             In another instance, in discussing brewery load at
             present \/ol ume with a pre- treatment process there, the-
             EIS indicated a possible $1 0 . 4 . mi 1 1 ion dollar reduc-
             tion in Facility Plan solid handling equipment, and
             only a $4.2 million dollar reduction in solid handl-
             ing equipment i f the brewery 1 oad we re expanded .

         3.  If the theoretical and unproven assumptions about per-
             formance of trickling filters at the brewery failed
             it would lead to catastrophic conditions at the bre-
             wery, in the sewer lines and at the sewage treatment
             plant.  This is certainly not a good place to experi-
             ment .

         4.  If the City is unable. to force Anheuser-Busch to in-
             stall trickling filters we are at an impasse and we
             understand they will violently resist such a plan.
             If the filters were installed, and if they did not
             meet  the theoretical design concept objectives, tho
             City would be faced with a horrendous problem of cor-
             recting the situation (which the Federal government
                                 v-68

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                                                                  -9-
Stateiv.ent on the Draft Environmental Impact

" tti teii.en t
development Committee for Creator Colu,,',bus


Page Mo. Seven




            would probably refuse to participate in) and an un-


            bearable fine (we are informed could be as much as


            $20,000 per day).  The thought is frightening unless


            the Federal government assumes the full responsibility


            for the decision.




Basically, the thought of trying to introduce such an unproven installa-


tion in the middle of a highly developed, heavily populated section of ot


area is frightening and seems diametrically opposed to the concept of cor


cern for environmental impact.  Our conclusion is overwhelming objection


to this recommendation by EPA.  Such a concept should have'been a part o1


a  Facilities Plan Study of Alternatives rather than an Environmental Im-


pact Statement.              (5.3.4)


TREATMENT PLANTS


Most of the disagreements between the draft EIS and the Columbus Facilit'


Plan for the wastewater treatment plants fall into four major areas:


            1.  Pretreatment of brewery wastes and accompanying


                reductions of influent loads and required facili-


                ties at the  Southerly Plant;




            2.  Reduced influent loads at the Jackson Pike Plant;''




            3.  Criteria used for design of individual treatment


                units; and,




            4.  The environmental compatibility of additional


                sludge reduction incinerators.

                                 V-69

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 '.atement on the Draft Environmental  Impact
 .;atement                                                         -ID-
Development Committee for Greater Columbus
Page No.' Eight
1.   Brewery Pretreatment
    The EIS calculates that brewery pretreatment  will  eliminate  a large
    portion of the solids handling facilities  and the  entire first stage
    biological treatment section at the  Southerly Plant.   This  economic
    analysis would appear to be  inaccurate.   First,  pretreatment and dis-
    charge to Southerly  should  generate the  same quantity of solids in
    the system as.complete treatment  at  Southerly.   Therefore,  brewery
    pretreatment cannot take credit for  elimination  of any solids handl-
    ing and disposal  facilities  at the Southerly  Plant.   Second, the pro-
    posed brewery pretreatment scenario  only  reduces the  brewery fraction
    of the total influent BOD5" load to Southerly  from  approximately 3Q%
    to 20%.  This reduced brewery load will  still be a significant percent-
    age of the total  influent load.  We  fail  to understand how  a 10% reduc-
    tion in total BOD5 can negate the need  for the first  stage  section
    when the EIS recommends a two stage  system at the  Jackson Pike Plant
    to meet an identical effluent standard.
2.   Jackson Pike Plant Influent  Loads
    The EIS methodology for the  determination  of  influent wastewater
    characteristics appears to be significantly in error  and results in re-
    duced treatment and disposal facilities  at the plant.  According to the
    City of Columbus  comments, the error was  introduced as a result of an
    assumption of heat-treatment recycle strengths.
    The EIS should re-evaluate this assumption and adjust the recommendation;
    accordingly.  If  the influent strength  cannot be accurately determined,
                                   v-70

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^tatoment or. the Draft Environmental Impact
 cater.icnt
Development Committee for Greater Columbus
Page No. Nine
    the methodology and assumptions used should be on the conservative
    side to insure adequate facilities to meet the stringent effluent
    limits i in posed.

3.  Treatment Unit Design Criteria
    With the exception of the first stage biological treatment at the
    Southerly Plant and what to do with the in-plant recycles, the EIS
    agrees with the Facilities Plan selection of the treatment processes
    to be utilized at both plants.  However, -the EIS has taken  .the liberty
    to redesign individual unit processes using criteria that results in a
    significant seale-down of facilities.
    Many of the members of the DCGC are engineering consultants with con-
    siderable experience in the wastewater treatment field.  Their experi-
    ence would indicate that these design criteria are not'in confcrmance
    with recognized engineering practice.  A review of the City of Columbus
    and Ohio EPA comments supports this viewpoint.  In addition, both the
    OEPA and the City of Columbus hase stated that many of the design cri-
    teria are not approvable by the regulatory agencies and they both have
    suggested, and we concur, that facilities designed on this basis will
    not meet the strict effluent limitations imposed on the plants and will
    result in serious adverse environmental impacts.

    'We would agree witri the City of Columbus that the design of treatment
    plants of this magnitude cannot deviate from normal practice unless
    sufficient data supported by adequate in-plant pilot testing is a vail-
    aDle on which to base such a design.  K'e further agre.e that utilization
                                   v-71

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statement on the Draft Environmental  Impact Statement            -12-
 
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  ;ater,ient on the Draft tnvi ronmental Impact                        -13-
S taternent
Development Committee for Greater Columbus
Page No. Eleven
Summary
We find many inconsistencies in the EIS and there are basic issues on
which we wholly disagree with the EPA recommended alternatives.

The Facilities Plan prepared by the City of Columbus represents what the
Development Committee for Greater Columbus is firmly convinced represents
a most logical, well supported, adequate and cost effective plan.
Alternatives suggested by EPA are not acceptable and we strongly support
the City's plan.  We urge its approval by EPA.
                                                 (5.3.5)
                                  V-73

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5.3       Development Committee For Greater Columbus
5.3.1     Comment;  Certainly conclusions regarding popu-
lation projections by personnel with great expertise should
have more validity than figures developed by persons un-
familiar with the area (and who we assume must be using
national average figures for urban areas).

          Response:   The authors of the EIS worked closely
with local planners and demographers regarding the popula-
tion projections.  National average figures for urban areas
were not utilized in any manner.
5.3.2     Comment:  The concept of using force mains in-
stead of a gravity system violates the principle on which
our entire program has been developed.  Force mains pre-
sent operational problems, odors at the pump stations, and
is an effort by U.S. EPA to restrict or completely control
growth.

          Response:  Please see responses related to this
issue (4.1.19, 24, 27, 5.2.4, and others).


5.3.3     Comment;  The EIS Interceptor Alternatives is
based on population projections for a 20 year design
period with the sewer flowing half full.  This has no
direct relationship with design of the interceptor sewers
on an ultimate population basis (the design used by the
City of Columbus)  since there is nothing to prevent popula-
tion projections in the next 20 years from tripling, quad-
rupling, or more,  leaving the original installation sub-
stantially undersized.

          Response:  Please see the response to Comment
4.1.19.
5.3.4     Comment:  At the least you can say our people
were shocked to discover that pretreatment, using a trick-
ling filter process, was recommended to handle effluent
at the Anheuser-Busch brewery north of S.R. 161.  Certain
conclusions from reviewing that item were quite disturbing.
                            V-74

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          Response:  The points  raised  by  the  Development
Committee for Greater Columbus regarding pretreatment of
the brewery waste have already been  covered in responses
to comments made by Anheuser-Busch and  the City of
Columbus.  See also Volume I  Chapter 3.


5.3.5     Comment:  Most of  the  disagreements  between the
draft EIS and the Columbus Facilities Plan for the waste-
water treatment plants fall  into four major areas:

          1.   Pretreatment  of brewery  wastes  and accompying
               reductions of influent loads and required
               facilities at the Southerly Plant;

          2.   Reduced influent  loads at the Jackson Pike
               Plant;

          3.   Criteria used for design of individual
               treatment units;  and,

          4.   The environmental compatibility of additional
               sludge reduction  incinerators.

          The Facilities Plan prepared  by  the  City of Columbus
represents what the Development  Committee  for  Greater Columbus
is firmly convinced represents a most logical,  well supported,
adequate and cost effective  plan.  Alternatives suggested by
EPA are not acceptable and we strongly  support the City's
plan.

          Response;  The specific points raised within the
four areas of disagreement have  already been discussed in
previous responses to comments made  by  Anheuser-Busch,
the City of Columbus, and Ohio EPA and our findings are summarized  in
Volume I.
                            V-75

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                  APPENDIX  AA

EVALUATION OF THE WASTEWATER TREATMENT PROCESSES
  PROPOSED FOR COLUMBUS, OHIO IN THE DRAFT EIS

     ENERGY AND ENVIRONMENTAL ANALYSIS,  INC.

-------
           EVALUATION OF THE
    WASTEWATER TREATMENT PROCESSES
      PROPOSED FOR COLUMBUS, OHIO
           IN THE DRAFT EIS
                  by
             John Stamberg
             July 21, 1978
Energy and Environmental Analysis, Inc.
        1111 North 19th Street
       Arlington, Virginia 22209

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                     TABLE OF CONTENTS
                                                           Page
Section I     Introduction and Purpose ..........     1
Section II    Technical Assessment of Proposed
              Southerly Scenarios .............     3
              A.  Background ...............     3
              B.  Assessment of the Need for
                  Brewery Waste Flow Control .......     4
              C.  Evaluation of Potential
                  Fungus Problems .............     5
              D.  Evaluation of Potential
                  Filamentous Growth Problems .......     7
              E.  Assessment of Proposed
                  Pretreatment Systems ..........    11
              F.  Assessment of Solids Handling
                  Needs .................  .    13
Section III   Technical Assessment of the Proposed
              Jackson Pike System .............    15
Section IV    Evaluation of Environmental Issues .....    17
              A.  Evaluation of Potential Odor at Proposed
                  Pretreatment Site ............    17
              B.  Evaluation of Potential Odor and Cor-
                  rosion in the Sewers Resulting from
                  the Proposed Brewery Pretreatment.  ...    18
              C.  Evaluation §f Increased Sewer Explosion
                  Risk Resulting from the Proposed
                  Brewery Pretreatment- ..........    19
Section V     Evaluation of the Findings on the Cost-
              Effectiveness Analysis ...........    20

-------
                TABLE OF CONTENTS  (Continued)






                                                            Page



Section VI   Findings and Recommendations  	    24



Appendix A   Calculations 	    26-



Sppendix B   Bibliography 	    39

-------
                          SECTION I
                  INTRODUCTION AND PURPOSE
     The "Draft Environmental Impact Stateraent-Wastewater Treat-
ment Facilities for Metropolitan Area-Columbus, Ohio" dated
February, 1978 evaluated four potential treatment scenarios
to find the most cost-effective and environmentally sound
approach to meet the required NPDES effluent limitations for
the Southerly plant.  In addition, the Draft EIS evaluated
one scenario for the Jackson Pike plant.  The four scenarios
for the Southerly plant involved ever-increasing degrees of
pretreatment of brewery waste from no pretreatment to separate
treatment.  These scenarios are:

     1. Brewery wastes without pretreatment as recommended
        by the "Cost-Effective Analysis-Columbus Metropolitan
        Area Facilities Plan".

     2. Pretreatment of the brewery waste to a point that
        the soluble oxygen demand is largely removed (a
        roughing filter at Anheuser-Busch).

     3. Pretreatment of the brewery waste to remove and handle
        the majority of the oxygen demand and suspended solids.

     4. Total brewery waste treatment to levels equivalent
        to Southerly NPDES effluent restrictions (separate
        municipal and industrial waste treatment).

     Primary treatment, intermediate roughing trickling filters,
activated sludge and filtration without industrial pretreatment
was the system recommended for both the Jackson Pike treatment
plant and Southerly treatment plant in the facilities plan.   In
                              -1-

-------
the facilities plan, five alternative systems were evaluated
for each plant, none of which involved pretreatment of brewery
wastes.  The last three scenarios above were not evaluated
in the facilities plan's cost-effectiveness analysis.

     The purpose of this report is (1)  to assess the suitability
and reliability of the four proposed scenarios for the Southerly
plant and the one for the Jackson Pike plant; (2) to evaluate
the environmental issues of the proposed treatment scenarios;
and (3) to evaluate the impact of these findings on the cost-
effectiveness analysis.

     This report uses engineering and microbiological princi-
ples to evaluate the proposed systems.   The calculations of
biological buildup, sludge production and effluent quality
have been based on meeting the NPDES requirements stated in
the Draft EIS, and the assumptions and methodology are -consis-
tantly applied to all the Southerly scenarios and the Jackson
Pike scenario.  The calculations reflect the necessity to nitrify
the ammonia nitrogen to 1 mg/1 (30-day average)/I.5 mg/1 (7-day
average)  for the period July-October and 2.5 mg/1 (30-day
average)/5.0 mg/1 (7-day average) for the period November-
December.
                             -2-

-------
                         SECTION II

    TECHNICAL ASSESSMENT OF PROPOSED SOUTHERLY SCENARIOS


A.   Background

     Brewery waste from the Anheuser-Busch plant is presently
discharged to Columbus, Ohio's Southerly treatment facilities.
The BOD,, load of the brewery waste was estimated to be between
99,000 to 107,000 Ib/day in 1976.  This is 55 percent to 59 per-
cent of the 180,000 Ib/day total BOD5 load received at the plant
(per DEIS page 1-31) .   Now the BOD,- load to the treatment plant
is to average 60,000 Ib/day with daily maximums of 75,000 Ib/day.
However, the brewery waste flow is estimated to be only about
3 MGD of 60 MGD flow at the plant.  The brewery waste is highly
concentrated (approximately 4000 mg/1 of BOD5), is highly soluble
BODg, and is low in nutrients (nitrogen and phosphorus).  It is
unlike domestic or non-brewery wastewater, which has a lower
concentration of BOD,-  (around 200 mg/1) and a higher proportion
of suspended or colloidal BOD_ as well as a surplus of the
nutrients (nitrogen and phosphorus) needed for bacterial growth.
Because of the brewery waste, peak BOD5 concentrations reach
1000 mg/1 at Southerly (per DEIS, p. A-28).

     The brewery waste contains high concentrations of soluble
carbohydrate waste.  This type of waste can induce growth of
fungus or filamentous  growth.  If either of these types of
growth become prevalent or dominant in an activated sludge
system, a bulking sludge can result.  Bulking results in poor
settling in clarification and the activated sludge can over-
flow the weirs.  This  results in an effluent with high sus-
pended solids and BOD,- levels.  Also, the settled sludge is
less concentrated and often more difficult to process.
                             -3-

-------
     Thereforet the joint treatment of brewery wastes and domes-
tic non-brewery wastes must be designed and operated differently
than a plant treating strict domestic wastes.

B.   Assessment of the Need for Brewery Waste Flow Control

     If BODj. levels of 1000 mg/1 are received at an activated
sludge plant, conventional activated sludge aeration equipment
cannot easily maintain desired dissolved oxygen levels in the
aeration tanks.  Also, most conventional trickling filters
cannot maintain aerobic conditions under these conditions.
Septic conditions and odor can result from these shock loadings
of BOD5-

     First, the rate of discharge of brewery waste should be
managed to prevent BOD_ loading in excess of 400 to 600 mg/1.
This is common to all scenarios.  Schroeder and Tchobanoglous
have recently found that BOD,- of 500 to 600 mg/1 may cause the
mass transfer rate of oxygen to become limiting in a plastic
media trickling filter (JWPCF, 48, pp. 1275-1276) .  Similarly,
in activated sludge, shock BOD5 loadings require increased
aeration, especially with a high biodegradable waste such as
brewery waste.  Increased aeration equipment needs to be pro-
vided.  However, increased aeration and agitation of the acti-
vated sludge may result in shearing of the bacterial floe par-
ticles and result in poor settling.  Therefore, the rate of
release should be managed to insure that BOD5 concentrations
at the plant remain less than 400 to 600 mg/1 to prevent treat-
ment process upset and/or loss of plant efficiency.

     If the non-brewery waste contains approximately 200 mg/1
BODc, the brewery waste must be contributing up to approximately
800 mg/1 BOD,- to cause the 1000 mg/1 BOD5 measured at Southerly.
If the maximum load on the secondary process is to be limited
                             -4-

-------
to 600 rag/1 or less of BOD5, then the brewery waste contribution
must be approximately 400 mg/1 or less when averaged over the
total flow to the Southerly plant.  Thus, for Scenario #1,
the maximum untreated brewery waste discharge rate must be re-
duced to about half of the existing rate to prevent shock
loadings.  Under the brewery waste load assumptions stated in
the DEIS, the proposed flow neutralization tanks have a maximum
pumping capacity of 9.4 MGD for the 60,000 Ib/day of BODj.
assumption and 13.0 MGD for the 100,000 Ib/day BOD5 assumption
and result in the waste being discharged at a minimum of a 10-
hour and a 12-hour period, respectively.  For an 85 MGD plant
at Southerly, at a 60,000 Ib/day BOD5 load rate over 10 hours,
excess BOD5 is not expected unless the flow to Southerly is less
than 43.2 MGD.  At 100,000 Ib/day BOD5 load rate over 13 hours,
excess BODc is not(expected unless the flow to Southerly is
less than 55.3 MGD.

     In the period prior to this, the pumps' capacity could be
estimated and limited as below:
(Daily BOD5  of Brewery)  #/day
  (Daily  Brewery  Volume)  MG
     (Pump Rate)  MGD	
     J8.34 x (600-200)1
                                              minimum hourly flow
                                              (in) MGD at
                                                   Southerly
C.   Evaluation of Potential Fungus Problems

     The generic formula for aerobic bacterial cells can be
expressed as CcH-^CUN.  Nitrogen is 12.4  percent by weight of
the bacterial mass.  Also, the phosphorus level is approximately
20 percent of the nitrogen level or 2.5 percent by weight of
the bacterial mass.  Based on secondary biomass production fig-
ures (approximate)  which I calculated for Southerly in the

-------
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period 1995-2000 for the 60,000 Ib/day of brewery waste, the
Southerly plant should not have a fungus problem as shown in
Table 1 for any scenarios.  However, the brewery pretreatment
facility in Scenarios #2, #3, and #4 may get into a fungus
problem unless the nitrogen and phosphorus additions are double
those levels of the McWhorter and Associates design.

D.   Evaluation of Potential Filamentous Growth Problems

     Filamentous growth  (wire-like bacterial growth) of one type
or another has a metabolic advantage in soluble wastes because
of their high surface area to volume ratio compared to zooqloeal
mass growth (ball shaped clusters of bacteria).  Also this high
surface area to volume characteristic gives filamentous growth
the metabolic advantage in activated sludge systems with low
dissolved oxygen.  Filamentous bacteria are more competitive in
utilizing the scarce oxygen for metabolism.  Also, if filamentous
bacteria occur in the influent in activated sludge unit, they
can seed, thereby encouraging filamentous growth.
     Filamentous growth does presently exist at Southerly.  This
growth has been identified morphologically (visually)  as a blue-
green algae phormidium or schizothrix (per Sykes; Drouet; and
Taft)  in the activated sludge.   Anheuser-Busch,  Inc. believes
that its waste could not be the cause of a blue-green growth.
Sykes work, however, shows that the filamentous growth believed
to be blue-green algae does respond to brewery wastes.  Anheuser-
Busch, Inc. would have a point if the filamentous growth was
algae.  However, after review of Sykes results and of Southerly
data,  I believe the filamentous growth is a filamentous photo-
synthetic bacteria.  These organisms can be very much like non-
photosynthetic bacteria except they use photosynthetic energy
for metabolism instead of chemisynthetic energy.  Photosynthetic
bacteria can grow anaerobically and can metabolize H2S or organic
                             -7-

-------
residues.  Unlike algae, once exposed to the light, they can
proceed with metabolism in the dark.  In an aeration basin with a
dissolved oxygen level of a few tenths of a milligram per liter, as
observed at Southerly, these photosynthetic filamentous bacteria
could easily thrive on H2S and soluble organic residue from the
brewery waste. This further explains why Sykes was unable to culture
what he thought to be blue-green algae on "Chu No. 10 medium" for
blue-green algae.  His culture efforts were successful when
sewage extract, soil extract, and acetic acid were used with Bold's
Busal medium.  This observation is consistent with my theory that
the filamentous organism is probably a photosynthetic bacteria.
Also, Sykes observed that the filamentous organisms did not thrive
in high dissolved oxygen.  Again conventional bacteria would
metab.olically overtake photosynthetic bacteria, in a case where
dissolved oxygen is not limited.

     Eliminating the confusion about blue-green algae, and,
assuming that all the activated sludge systems can maintain
adequate dissolved oxygen levels, I calculated the amount of
suspended or colloidal BODc vs. the soluble BOD,- and the amount
of normal colloidal suspended solids vs.  the amount of potentially
filamentous solids that could seed the activated sludge.  These
calculations were used to determine which systems would be sub-
ject to filamentous problems.

     Trickling filters tend normally to have filamentous type
growth and high soluble organic levels further encourage this
tendency.  Also, high loading rates and little control of ven-
tilation results in poor dissolved oxygen profiles in the trick-
ling filter slime.  Further, the colloidal organic matter could
also become contaminated with filamentous growth.

     As shown in Table 2, Scenario #1 could have between 48.5
and 100 percent of the solids seed from biological growth
                             -8-

-------
created from metabolism of soluble organics in the roughing
filter as filamentous growth.  Thus, this system is highly
susceptible to filamentous growth.

     As seen in Table 2, the mixed liquor (MLSS) in the second
stage activated sludge process in Scenario #1 is more diluted
and would favor filamentous organisms.  Also, total waste sludge
solids are low in comparison to the incoming filamentous orga-
nisms.  Filamentous organisms are less likely to be purged from
the system.  Scenarios #2 and #3, though having higher percen-
tages of soluble BODc, have much lower potential for filamen-
tous seed, higher average mixed liquors, and larger total waste
activated sludge quantities.

     It is my opinion that at Southerly, Scenario fl would be sub-
ject to troublesome filamentous growth and Scenarios #2,  #3,  and #4
would not.  Also, Scenario #1 is similar to existing conditions.
The Southerly plant has operated without detrimental filamentous
growth,  as in February and March of 1976,  and has operated with
severe filamentous growth in other months.   The major change from
existing conditions is the aeration equipment that would be able
to maintain higher dissolved oxygen levels.   The changes are mar-
ginal and no design safety factor exists. Also, nitrification did
not occur when filamentous growth was in control.  Thus,  increased
aeration may help improve operation, but will not improve the
system's reliability as much as in Scenarios #2, #3, or #4.
Also,  the existing Southerly plant should be able to meet sec-
ondary treatment criteria as defined by EPA by implementing
any one of the pretreatment systems invisioned for Scenario #2,
#3,  or #4.

     Nitrification of the ammonia nitrogen is needed to comply
with the NPDES requirements stated in the Draft EIS.  The ammo-
nia nitrogen must be reduced to 1.0 mg/1 (30-day average)/I.5 mg/1
                             -9-

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 (7-day average) for the period July-October and 2.5 mg/1  (30-day
average) /5.0 mg/1  (7-day average) for the period November-December,
For the period January-June no requirements exist.  To achieve
the required level of nitrification, the sludge age  (or sludge
retention time [SET] ) must be high (at least an SRT of 12.5 days) .
This requirement can make an activated sludge system susceptible
to filamentous growth because, D there is an added demand
for oxygen for the nitrifying bacteria which may prevent main-
tenance of high dissolved oxygen in aeration, and 2) high SRT
sludges are subject to filamentous growth and you cannot waste
out the filamentous growth quickly to purge it from the system
without loss of the slower growing nitrifying bacteria.

E.   Assessment of Proposed Pretreatment System

     The performance of a roughing filter without clarification
is difficult to predict.  However, since some estimates can be
made, the 70 percent removal of soluble BODc is a reasonable pre-
diction at 100 Ibs BOD5/1000 ft  loading rate.  This is 'consistent
with Havens and Emerson's use of Eluor data and the equation
used by McWhorter and Associates.  It is difficult to predict
solids generation or the BOD5 level  of the solids.  However,  at
these high loading rates there is little chance for endogenous
respiration or solids stabilization.  Rather soluble BOD5
will simply be converted to bacterial and fungal solids.   Using
Mccarty's equation:
                              (SRT)
                         1+b  (SRT)
          AM
          — =   volatile solids produced/day
          At
                            -11-

-------
          a = 0.46 (per McCarty)

          b = specific maintenance rate
            = 0.18 (1.047)T~28  in  °C
        SRT = solids retention time or equivalent
         A T?
         — = BOD5/day x BODg
         At              0.68 BOD5

Assuming 20°C and a low SRT (above wash out, say 3-4 days), the
solids generated from the 35,000 Ib soluble BOD5/day removal in
approximately equal to 50 percent of the soluble BOD5 removed or
17,500 Ib/day of solids generated.  This level, assumed by
McWhorter and Associates, is reasonable.
     However, the assumption by McWhorter and Associates, Inc.
that the BOD5 level of the suspended solids is equal to 20 percent
of the BOD removal is unreasonably low.  Suspended solids generated
in low SRT systems are approximately equal to BOD5-  Also, some
of the suspended BOD_ may be captured and metabolized.   I used
an estimate of 50 percent capture of suspended solids and a
50 percent BOD5 reduction of those solids.  McWhorter estimated
that 29,980 Ib/day of BOD5 is removed (34,850 Ib/day for soluble
BOD5 less 6,970 Ib/day for BOD5 of generated solids, plus 2100
Ib/day of BOD5).   I estimated that 20,000 Ib/day of BODg would
be removed (35,000 Ib/day for soluble BOD5 less 17,500  Ib/day
for BOD5 of generated solids, plus 2500 Ib/day for removal of
suspended BOD_).

     Of the two design concepts,  the McWhorter and Associates,
Inc. is more conservative than that of Havens and Emerson, both
in trickling filter loading (100 Ib BODt- 1000/ft  vs.  180 Ib BODc
       -5                               *>                        D
1000 ft ) and assumed flow (3.9 MGD vs. 3.0 MGD).   McWhorter's
design uses three stages, which will have fewer short-circuiting
problems, a better ventilation system, which gives better control
of aeration.   Cutting corners on the pretreatment design could
                            -12-

-------
result in less efficient removals and odor.  The more conserva-
tive design by McWhorter is a useful approach to serve as a
basis for the upper limit of pretreatment cost.

F.   Assessment of Solids Handling Needs

     My calculations for Scenario #1 indicate that there will be
less sludge than estimated in the Draft EIS as shown in Table 3.
Also, I estimate slightly greater quantities of primary sludge
and significantly lower production of secondary solids.

     For a 60,000 Ib/day brewery waste load, Scenario #2 has
17 percent less solids than Scenario #1, and Scenario #3 has
26 percent less solids than Scenario #1.

     The question is whether any further reduction in solids
handling can result at Southerly as a result of this reduction.
The Draft EIS for Scenario #1 assumes the use of existing sec-
ondary digesters as thickeners and use of existing thermal con-
ditioning units.  No saving can be gained in these areas for
Scenarios #2 or #3 because no new facilities will be eliminated.
However, opportunity exists to reduce centrifugation and incin-
eration capacity at Southerly for Scenario #2 and Scenario 13.
One centrifuge can be eliminated for Scenario 12, and possibly
two for Scenario #3 at a 60,000 Ib/day brewery waste load assump-
tion.  Also, at the lower brewery loading, one incinerator could
be dropped in capacity from 200 wet tons/day to 170 wet tons/day
for Scenario #2, and two incinerators could be dropped in capac-
ity from 200 wet tons/day to 170 wet tons/day for Scenario 12,
and two incinerators could be dropped in capacity from 200 wet
tons/day to 170 wet tons/day for Scenario #3.

-------
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-------
                           SECTION III

              TECHNICAL ASSESSMENT OF THE PROPOSED
                       JACKSON PIKE SYSTEM
     The main issue at Jackson Pike is to determine if the inter-
mediate trickling filter and intermediate clarifier are needed.
Facilities with and without intermediate trickling filter systems
at Jackson Pike can be designed to reliably meet NPDES require-
ments as stated in the Draft EIS.  The use of the intermediate
trickling filter system would result in a lower BOD5 loading
to the existing system.  This would allow the system to operate
at a lower mixed liquor suspended solids level.  The overall
solids production could, however, be decreased if the intermediate
trickling filter system is eleminated and the aeration tanks and
final clarifiers expanded in their place.

     With the intermediate trickling filter system, my calcula-
tions indicate that the average mixed liquor needs to be 2185
mg/1 based on 25.9 million gallons of aeration, or 1797 mg/1
based on 31.5 million gallons of aeration.  The Draft EIS ref-
erences both sizes.  Using the same tankage, without this inter-
mediate system, the existing mixed liquor would have to be 4090
mg/1 based on 25.9 million gallons of aeration, or 3364 mg/1
based on 31.5 million gallons of aeration.  This increase in
solids may require an expanded activated sludge system with
more blower capacity, aeration tankage,  and clarifier surface
area.  An increase of 5-10 MG of aeration capacity and a 50 per-
cent increase in clarifier overflow rate may be desirable.

     The secondary sludge production would increase with the
intermediate trickling filter system.  My calculations show that
the secondary sludge, which is the most difficult to handle,
would be increased to 87,108 Ib/day with the intermediate trick-
ling filter from 61,529 Ib/day without the intermediate trickling
                              -15-

-------
filter, approximately 40 percent more.   The total sludge would
be approximately 11 percent more with sludge productions of
257,108 Ib/day with the intermediate trickling filter and
231,529 Ib/day without it.

     Therefore, if the advantages of a lower sludge production
are more desirable, then the other factors such as the increased
cost of construction and operation of aeration equipment and
tankage and of additional clarification, then elimination of
the intermediate trickling filter has merit.  This is based on
the proposed loading stated in the Draft EIS and the fact that no
new major wastes high in soluble BOD are to be received in the
future.
                              -16-

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                          SECTION IV

              EVALUATION OF ENVIRONMENTAL ISSUES

A.   Evaluation of Potential Odor at Proposed Brewery
     Pretreatment Site
     The BODs levels of the brewery waste vary widely and average
approximately 4000 mg/1.  If a plastic media roughing filter is
used, excessive odor is highly likely due to I^S.  Theoreti-
cally, Schroeder and Tchobanoglous determined the limits of
oxygen transfer on plastic media trickling filters.  They con-
cluded, "When the BOD concentrations in excess of 500 to 600
mg/1 are applied (to a plastic media trickling filter), the mass
transfer rate of oxygen may become limiting.  The probability of
odor production will also increase under these conditions."  Also,
Bell and Tsumpes report experience in the operation of the Sewer
District No. 2 plant in Jacksonville, Florida, which receives
almost entirely brewery wastes from a similar Anheuser-Busch, Inc.
plant that has odor problem^.  The Jacksonville plant does not
control pH.  With an uncontrolled pH, this practical experience
substantiates the Schroeder and Tchobanoglous determinations.
The odor will probably be predominantly hydrogen sulfide which,
if the pH is increased to a pH of 8, can be mitigated.
     Covering of the trickling filter as proposed by McWhorter
and Associates, Inc. is a necessity.  Also, ozonation of vented
air and pH adjustment to pH 8 are recommended to mitigate
the odor problem.  Experience in Jacksonville shows the necessity
for use of corrosion-resistant material in the trickling filter
distribution system, the dome, and wall construction.  The cause
of this corrosion is probably the bacterial oxidation of hy-
drogen sulfide to sulfuric acid.  The bacteria, thiobacillus,
are aerobic and metabolize the hydrogen sulfide in condensed
moisture to sulfuric acid.  The acid, in turn, corrodes the
materials.
                            -17-

-------
     Elevation of the pH. to 8 forces most of the hydrogen sulfide
gas into soluble ions (HS  or S=).   Since the proposed plant
has neutralization facilities, pH levels can be elevated with
extra chemical addition.
B.   Evaluation of Potential Odor and Corrosion in the Sewers
     Resulting from Proposed Brewery Pretreatment
     Hydrogen sulfide is biologically produced in sewers when
oxygen and nitrate are unavailable as electron acceptors.  The
sulfate in the water serves as the electron acceptor for certain
bacteria and hydrogen sulfide is produced. . The bacteria, desul-
favibrio desulfuricans, dehydrogenate organic compounds.  How-
ever, the roughing filter converts easily dehydrogenated soluble
organics into bacteria or fungus solids, these solids contain more
complex molecules.  Thus, the roughing filter will not have any
worse odor than the existing conditions and some mitigation of
hydrogen sulfide production in the sewers may result.  If adjust-
ment to the pH is made in the roughing filters, further alleviation
of existing odors is likely.
     Corrosion results if condensed moisture builds up on the
top of the sewer, and thiobacilli grow and metabolize the
hydrogen sulfide gas to sulfuric acid.  Since there will be no
more or even less hydrogen sulfide gas, corrosion will also be
no more and perhaps even less than current conditions.   It  is
desirable to surge the  line periodically to wash out or  prevent
any buildup of thiobacillus-laden moisture on the top of the
sewer.  Some flow variation in the intermediate discharge sewers
for the Anheuser-Busch plant  can be beneficial in this matter.
Surging of immediate discharge sewers  for the Anheuser-Busch
plant should not be done with high strength wastes as this  surge
of high strength waste may result in  shock loadings to Southerly.
                             -18-

-------
C.   Evaluation of Increased Explosion Risk Resulting from
     Proposed Brewery Pretreatment
     There should be no increase in the explosion risk over
existing conditions with the implementation of pretreatment.
The pretreatment may even mitigate any explosion risk that may
exist.  Methane-producing bacteria can only produce methane from
acetic acid, propionic acid and/or other highly soluble volatile
acids.  These volatile acids or their precursor forms in the
brewery waste are also the most likely forms of soluble BOD-
to be converted into bacterial cells in the pretreatment system.
Therefore, there is less substrate for such organism to metab-
olize.  The produced bacterial cells would have to die and then
be metabolized anaerobically to volatile acid forms before
methane production can occur.
     Also, methane bacteria are slow growing and extremely sensi-
tive to low pH, oxygen, and heavy metals such as copper.  To get
methane production, long periods of stagnant conditions are
needed.  First, the bacteria must convert the soluble or solid
substance to volatile acids and then the bacteria producing the
methane need to be free from pH change, oxygen and heavy metals.
Such conditions are rare in sewers, especially those with small
diameters.  Most sewers are designed to flush out solids with
a specific gravity of 2.7.  The solids produced in the pretreat-
ment unit will have a specific gravity of 1.002 to 1.005.
     The Allentown case submitted by Anhueser-Busch, Inc. to
prove methane gas occurrence in a similar situation is irrelavent.
The two deaths were from asphyxiation.  This merely proved that
the sewer system had no oxygen in it.  This is the norm in sewers.
No proof or evidence of methane gas is presented.
                             -19-

-------
                           SECTION V

              EVALUATION OF THE FINDINGS ON THE
                COSTr-EFFECTIVENESS ANALYSIS

     The cost for the pretreatment of brewery waste should be
based on McWhorter and Associates, Inc. figures.  The numbers
should reflect the following changes.  The chemical cost should
be double for additional nutrient and pH control.  The power cost
should increase roughly 15% for ozone  (exact ozone need uncertain)
The capital cost could increase .up to 15% for ozone equipment and
corrosion resistant materials.
     The 1974/1975 operating cost would be adjusted as below:
     Labor
     Chemicals
     Power
     Maintenance
                          100,000 #/day
                            60,000  ft/day
     Used in Draft EIS
     Adjust Scenario #2
McWhorter
$68,000
30,000
79,000
74,000
$251,000/
year

Adjusted
$68,000
60,000
91,000
74,000
$293,000/
year
$300,0007
year
McWhorter
$68,000
23,000
56,000
69,000
$216,0007
year

Adjusted
$68,000
46,000
64,400
69,000
$247,4007
year
$200,0007
year
               -0-
                    $50,000
     The 1974/1975 capital cost would be as below:
       100,000 Ib/day                   60,000 Ib/day
       McWhorter
      $5.9 million
      Used in Draft
       EIS
      Adjust Scen-
       ario #2,
       #3, & 14
Adjusted
$6.8 million

$4.2 million

$2.6 million
 McWhorter    Adjusted
$5.5 million  $6.3 million

              $2.9 million
              $3.4 million
                             -20-

-------
     My technical analysis shows that solids handling costs in
Scenario #2 and #3 should be reduced.  The solids handling
reductions have been accounted for in Table 4 (p. 13 of the
Draft EIS) for Scenarios 12 and #3.  Perhaps for Scenario #3,
an additional $1.0 million savings in capital cost are pos-
sible from the elimination of an additional centrifuge and
reduction of incineration capacity.
     Appendix K of Draft EIS "Design Quantities and Unit Process
Sizing for the Recommended Treatment Facilities" was reviewed
for other items that may impact the cost-effectiveness analysis.
The review is summarized in Table 4.  If the intermediate
trickling filter and intermediate clarifiers are eliminated
at Jackson Pike and replaced with increased activated sludge
aeration capacity and increased final clarification, it was
assumed in this report that the cost of the eliminated systems
and the cost of the added facilities were roughly equal.

     As can be seen in Table 5, after all the above adjustments
were made, the relative order of the four Scenarios in the
Draft EIS is the same.  However, the differences in cost-
effectiveness are smaller.
                            -21-

-------
                                  TABLE  4


                  COMMENTS  ON APPENDIX F OF DRAFT EIS
          'DESIGN QUANTITIES AND  UNIT PROCESS  SIZING FOR THE

                    RECOMMENDED TREATMENT FACILITIES"
                                               Jackson  Pike
                                Jackson Pike   Without
                                with Inter-    Intermediate
                                mediate Trick- Trickling
                                ling Filter    Filter
                  Southerly
               System
System
Remarks
Pretreatment &
Primary Sedimen-
tation

First Stage Bio-
logical Treat-
ment
OK as stated   OK  as stated   OK as stated  None
Second Stage
Biological
Treatment
Secondary
Clarification
Elimination    OK as  stated
of roughing
filter is OK
as stated.
OK as stated   OK as stated
OK as stated   OK as  stated
Additional
elimination
of roughing
filter is
possible.
5-10 MG of
aeration
capacity may
be desirable.
Sludge savings at
Jackson Pike is a
benefit; however,
a larger activated
sludge system is
needed.

In lieu of roughing
filter, additional
aeration capacity
could be beneficial.
50% increase  In lieu of inter-
in secondary  mediate clarifica-
clarification tion,  additional
may be desir- final  clarifica-
able.         tion could be  bene-
              ficial.
Final Effluent
Filtration
OK as stated   OK as  stated   OK as stated  None
                                    -22-

-------
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-------
                        SECTION VI
               FINDINGS AND RECOMMENDATIONS
1.  Scenario #2,  #3,  and #4 for Southerly should operate
    reliably to comply with the NPDES requirements stated
    in the Draft  EIS.
2.  Scenario #1 for Southerly co.uld have filamentous growth
    problems that jeopardize reliable operations and compliance
    with the NPDES requirements stated in the Draft EIS.
3.  At Southerly, pretreatment of brewery waste should reduce
    the sludge quantities from 235,993 Ib/day for Scenario #1
    to 194,808 for Scenario #2 and to 177,818 for Scenario #3.
4.  Brewery waste pretreatment is subject to hydrogen sulfide
    production, which should be controlled by covering the units,
    adjusting pH  upwards, and perhaps ozone treatment of vented
    air.
5.  Odors and risk of sewer explosions will be mitigated, not
    created, by pretreatment of brewery waste.
6.  The regulation of brewery waste discharge rate is needed
    and can be simply handled by limiting the capacity of dis-
    charge pumps  from the equalization tanks at the brewery
    as calculated using the formula on page 5 of this report.
7.  The above findings do not affect the cost-effective ranking
    of Scenarios  at Southerly, but the difference in present
    worth is somewhat less than that in the Draft EIS.
8.  Pretreatment  of brewery waste should permit the existing
    Southerly plant to meet secondary treatment standards as
    defined by EPA.
                           -24-

-------
 9.   At Jackson Pike,  the use of  the  intermediate trickling
     filter (instead of an activated sludge system) increases the
     secondary sludge  by 40 percent,  from 61,529 Ib/day to
     87,108 Ib/day and increases  the overall sludge by 11 per-
     cent,  from 231,529 Ib/day to 257,108 Ib/day.
10.   Barring overriding institutional or implementation con-
     straints, Scenario #2 at Southerly is technically and
     cost-effectively  preferable.
11.   If Scenario #1 at Southerly  is chosen, pilot plant studies
     are needed for Scenario #1 to determine exact design and
     operational parameters required for reliable compliance
     with the NPDES limits.
                              -•as-

-------
                         APPENDIX A
                   BASIS FOR CALCULATIONS
A.   Influent Load

        Non-Brewery Wastes for 1995-2000
          SS-Draft EIS p. IV-5 for Southerly
                       p. 1-34 for Jackson Pike
          Suspended BOD5 p. 1-35 for Southerly
          Soluble BODc p. 1-34 for Jackson Pike

        Brewery Waste for 1995-2000
          ss-
          Suspended BODc        Draft EIS p. 1-35
          Soluble BOD5

        Sludge Handling for 1995-2000
          Estimated assuming treatment of thermal conditioning
          and other recycle streams.
        Existing Conditions at Southerly p. 1-31

B.   Pretreatment of Brewery Waste

        Scenario #2 Effluent
                         — KD
          Use • Le/_ .  = 3   /qn ' @ SRT equivalent of 3-4 days
                   c of produced biomass = SS

          SS = 0.50 soluble BOD^-removed + 0.75 initial
               suspended solids
          BODc - 0.30 soluble 8005 + 0.75 initial suspended
                 BOD5 +0.75 soluble BOD5 removed

        Scenario #3 Effluent
          As above with 80% SS removal in clarification.
                            -26-

-------
C.   Primary Effluent

        SS = 0.4 suspended solids
        BOD5 =0.4 suspended BOD5 +1.0 soluble BOD5
               (60% removal in primary clarification)

D.   Intermediate Trickling Filter Effluent

                       — KD
        Use • Le/_ . •= e   /qn @ SRT equivalent of 3-4 days
                 Lil

            • BOD_ of produced biomass = SS

        SS = 0.73 (1-0 suspended solids + 0.5 soluble BOD removed)
                  (based on 40 mg/1 SS in clarified effluent)
        BODj- = 0.75 suspended BOD5 + 0.20 soluble BODe

E.   Activated Sludge
        AM = 0<46  AF   f"1_ 0.8(b) (SRT) "I

        At         At   I   1+b  (SRT)  J
       	 = mass of solids produced/day
        At
n x 4 . 6
       J
       --  = BOD ultimate x      + Nitroge
        At                  Lo.68


         b = 0.18  (1.047)T~28 (§ 10°C


       SRT = sludge retention time @ 12.5 days


        SS = 10 mg/1


      BOD5 = 6 mg/1


     Results of calculations are on the following charts
                            -27-

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FEED SOLIDS
  28,350 Ib/day
              0 - 14,600 Ib/day
                  Coliodal SS
           28,350  - 13,750 Ib/day
               Potential Filamentous
ACTIVATED
SLUDGE
UNIT
479,150  Ib MLSS
                                         T
                                   38,332 Ib/day
                                      Waste
                                                        7089 Ib/day
                                                        Effluent Suspended
                                                        Solids
WASTE SOLIDS
                       31,243 Ib/day
                           Waste
                     Suspended  Solids
        Southerly Scenario  #1 or  1995-2000
          at  60,000  Ib/day- brewery  waste
                       -29-

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         Southerly Scenario #2 for 1975-200
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FEED SOLIDS
39,040  Ib/day
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-o
3 1~l
r5 "1
CO ^
rt II
4->
O CO
f-i CO

-------
FEED SOLIDS
92,800  Ib/day
                     92,800 Ib/day
                      Coliodal SS
                        0  Ib/day
                Potential  Filamentous
ACTIVATED
SLUDGE
UNIT
883787 lb  MLSS
                                             f
                                       70703 Ib/day
                                          Waste
WASTE SOLIDS
                       9174  Ib/day
                       Effluent
                       Suspended  Solids
                           61,529  Ib/day
                               Waste
                         Suspended Solids
                      Jackson  Pike  for  1995-2000
                       without Trickling Filter
                             -38-

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                         APPENDIX B


                        BIBLIOGRAPHY
A.   Background Documents


     1.  Columbus, Ohio Facilities Plans

     2.  Columbus, Ohio Draft Environmental Impact Statement

     3.  Review of Draft EIS by Columbus,  Ohio

     4.  Anheuser Busch Comments on Draft EIS

     5.  OEPA comments on Draft EIS

     6.  Southerly Influent Flow-Anheuser Busch Effluent Flor
         from January 1977 to March 1978

     7.  Preliminary Report on Elimination of Filamentary
         Blue-Green Algae at the Southerly Wastewater Treat-
         ment Plant

     8.  Enforcement Case Analysis Merrimack Treatment Facility
         July 14, 1975

     9.  Background Information on Hampton Roads Sanitation
         District's Williamsburg Sewage Treatment Plant,
         Williamsburg, Virginia

    10.  Correspondence on Anheuser Busch Brewery in Columbus

    11.  Havens and Emerson's response to comments on Draft EIS

    12.  Columbus, Ohio USER CHARGE/INDUSTRIAL Cost Recovery
         System

B.   General References

     1.  Schoeder, E.D. and Tchobanoglous, G., "Mass Transfer
         Limitations on Trickling Filter Design".   Journal Water
         Pollution Control Federation, Vol. 48, p. 771,  1976.

     2.  Beel, B.A., and Tsumpes, R.V., "Brewery Waste Treat-
         ment — Trials and Tribulations", Flood and Associates,
         Inc.  P.O. Box 8868, Jacksonville, FL, 1975.
                            -39-

-------
McCarty, P.L., "Water Resources Microbiology — CE 274",
Stanford University, 1967.

Sawyer, C.N. and McCarty, P.L., Chemistry for Sanitary
Engineers, 2nd Ed., McGraw-Hill Book Company, New York.

Frobisher, M., Hinsdill, R.D., Crabtree,  K.T., and
Goodhart, C.R., Fundamentals of Microbiology - 9th Ed.,
W.B. Saunders Company, Philadelphia.
                    -40-

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     TOM MOODY            ** •. n. -,r   «. •«    nn-rvT-nv-nwrn          D. D. ROBBINS
       MAY°"              CITY
ROBERT C. PARKINSON. P.E.
 DIRECTOR or PUBLIC SCRVICC
                            DIVISION OF SEWERAGE AND DRAINAGE
                                         CITY HAUL
                                    COLUMBUS. OHIO 43215
                                              October 25, 1978
       Mr. Charles Sutfin
       Division of Water
       U.S. Environmental Protection Agency
       230 South Dearborn
       Chicago, Illinois 6060*»

                                              Re:  Columbus EIS

       Dear Mr. Sutfin:

            The main points presented by U.S.E.P.A. at the September  13,  1978
       meeting can be summarized as follows:

            1.  Wastewater Treatment Plant Process Evaluation Report  -
                U.S.E.P.A. hired Mr. John Stamberg of Energy and Environmental
                Analysis, Inc., to prepare a report entitled "Evaluation  of
                the Wastewater Treatment Processes Proposed for Columbus, Ohio
                in the Draft EIS."  Basically, Mr. Stamberg's report  arrives at
                the same conclusions as presented in the Draft EIS for wet
                stream processes at Southerly and pretreatment at the brewery.
                U.S.E.P.A. said the report would be made a part of the Final EIS.

            2.  Sludge Disposal Alternatives - U.S.E.P.A. will allow  the  City
                to build one new incinerator and rebuild one existing incinerator.
                U.S.E.P.A. stated that  incineration would be considered only a
                short term solution and that the City should investigate  other
                forms of solids disposal for long term solutions.

            3.  Interceptors - USEPA has Towered their design population
                presented in the Draft  EIS from 1.11 million to 1.025 million.
                U.S.E.P.A. was still reviewing data for Reynoldsburg  and  New Albany
                so they did not discuss the interceptor alternatives  for  these
                areas.  However, the other interceptor alternatives for the
                final EIS will not change from that presented in the  Draft EIS.
                Also, the design criteria for sizing sewers will not  change  in
                the final EIS.

-------
Mr. Charles Sutfin
U.S. Environmental Protection Agency
October 25, 1978
Page 2
     Other meetings have taken place with U.S.E.P.A. and the City on
September 22, 1978 and October 10, 1978.   The meetings did not result in
any formal agreements.

     fn response to Mr. Stamberg's report, we feel  Professor Sykes'  letter,
a copy of which is attached, leaves little doubt that the report and subsequent
recommendations regarding process design  at Southerly are invalid.

     In regards to the sludge disposal  alternatives* the City was told by
U.S.E.P.A. to develop other methods of disposal  such as composting.   At the
time of the meeting, no cost-effective analysis  or final air modeling studies
had been presented to support this directive.  The City cannot develop other
forms of disposal  if the E1S dictates design of  other parts of the solids
handling processes.  For instance, the EIS recommends thermal conditioning
of waste activated sludge solids.  The City's experience shows that  thermal
conditioning of sludge is very helpful  to produce an autogeneous sludge cake
for final disposal by incineration.  However, thermally conditioned  sludge
has very little BTU and plant nutritional value  and is not suitable  for
composting.  Therefore, if the U.S.E.P.A. intends to limit the use of incin-
erators to a short term or standby method of disposal, and intends to promote
composting and land application, then it  must recognize that other unit processes
and design criteria for solids handling must be  reevaluated.  At both plants,
the City refuses to accept the EIS recommendation of anaerobic digestion of
Zimpro wastes since this is an unproven process.  The City expects the
opportunity to consider other processes as a means of treating the Zimpro
wastes.  Also, as  discussed before for both plants, the EIS recommendations
for incineration are unrealistic if proper solids disposal is to be  provided
on a continuous basis.

     In regards to wet stream facilities, neither the City nor their
consultants know of any wastewater treatment plants of comparable size that
have been designed and operated using the Draft  EIS criteria and still meet
30 day NPDES limitations of '', mg/1 for BOD and SS and 1 mg/l ammonia, year
round.  Furthermore, the Draft EIS design criteria does not meet Ten States
Standards or OEPA standards.  Therefore,  U.S.E.P.A. must prove to O.E.P.A.
and the City that the proposed design criteria will meet NPDES limitations.
We suggest that U.S.E.F.A. ask Havens and Emerson to locate at least five
wastewater plants they have designed, using the  design criteria in the Draft
EIS.  The City refuses to accept the EIS  recommendations on the basis that
NPDES effluent limitations would be unattainable and that EIS cost effectiveness
analysis did not  include enough money for rehabilitation of facilities,
particularly at Jackson Pike.

     U.S.E.P.A. has suggested that design criteria will be omitted from the
Final EIS.  However, unit process sizes and the  cost effective analysis would
still be in the EIS.  If this is done,  then the  design criteria has  not been

-------
Mr. Charles Sutfin
U.S. Environmental Protection Agency
October 25, 1973
Page 3
omitted from the Final EIS at all.  If U.S.E.P.A. insists on printing
mandatory unit process sizes or design criteria in the Final EIS, then the
City wants one of the following statements placed in the Final  EIS:

     1.  U.S.E.P.A. will guarantee NPDES effluent limitations will be
         met at all times at both facilities.

     2.  If the City of Columbus cannot successfully operate the facilities
         proposed in the EIS and meet NPDES effluent limitations, then
         U.S.E.P.A. will assume responsibility for operation of the
         fac i1i ties.

     3.  Use of design criteria in this final EIS is used only for
         comparing alternatives in the EIS and does not dictate the final
         design and unit process sizing.  Selection of final design
         criteria shall be determined by the City and their designers
         with approval by Ohio E.P.A.

     The City has yet to see a full cost-effective analysis of alternatives
for the Scioto West Interceptor.  Specifically, the EIS does not compare the
cost of the proposed pump station with the cost of extending' the Scioto West
Interceptor from Manhole 3 to Manhole 2.  Apparently, the EIS feels the
population density is not great enough in this area to warrant sewer facilities
and construction of such sewers would cause induced growth.  However, a more
realistic approach would be to build the one mile stretch between manholes 2
and 3 and eliminate a troublesome pump station.  In our opinion, the reliability
of the gravity sewer alternate is more important that the induced growth issue
in this case.

     The City has learned that the design criteria for interceptor sizing used
in the Draft EIS is not consistent with large interceptor criteria used by
other municipalities  in Region 5.  For instance, the Cuyahoga Valley Interceptor
in Cleveland,  which was subjected to an EIS, used an EPA approved design
criteria based on a forty year design, a wastewater flow based on water
consumption of 150-160 gpcd, infiltration based on 375 gpd per acre, and a
peaking factor of 2.0 for average flows over 11 mgd.  The City of Cincinnati
presently uses 100 gpcd flow and 1000 gpd per acre for infiltration which has
very recently been approved by U.S.E.P.A.  Therefore, the design criteria used
in the Draft EIS, aside from being unrealistic, is inconsistent with the
criteria being approved for other major cities in Ohio.

     One of the major concerns with the design criteria is the infiltration
allowance of 10 gpcd which was based on an approximate relation to 200 gpd/in.-mi
The figure of 200 mgd/in.-mi. is fine for a construction specification, but not
appropriate for infiltration flows that will enter the sewer during its lifetime.

-------
Mr. Charles Sutfin
U.S. Environmental Protection Agency
October 25, 1978
Page 4
     Consider a 30 inch interceptor that has ten 18 inch trunk sewer
connections.  Assume the interceptor and each trunk are one mile long.  The
allowable infiltration for each trunk is 18 x 200 x 1  or 3600 gpd.   The
allowable infiltration for the interceptor is 30 x 200 x 1  or 6000  gpd.
However, the total infiltration in the interceptor would be 10 x 3600 + 6000
or 42,000 gpd.  For this interceptor, the design infiltration should be
42,000/30 x 1 or 1400 gpd/in.-mi.

     By the time all of the laterals and service connections are considered,
the amount of infiltration that would result in the above example could be
much higher.  Our experience has shown that the infiltration through the
joints of Interceptors is normally within 200 gpd/in.-mi.,  but infiltration
flow increases significantly as connections are made to the interceptor.

     It was also noted at the September 22 meeting that parallel sewer
construction through Reynoldsburg in the future would  be difficult  and
expensive.  It would be more economical to build the ultimate size  sewer through
Reynoldsburg now.  This same concept should apply to the E1S recommendation for
the construction of the Rocky Fork Interceptor through Gahanna ?n 1995-
The Rocky Fork area through Gahanna is just as developed as Reynoldsburg,
and construction through the area would be extremely difficult and  expensive.
A more open route would be available as shown in Alternate B.  If the EIS
insists on eventual implementation of Alternate A, then the section through
Gahanna should be built immediately.

     Mr. Frank Baldy, Service Director for Reynoldsburg, identified several
factors not included with U.S.E.P.A.'s proposal of a force main along
Livingston Avenue  in letters dated May 24, 1978 and September 20, 1978.
U.S.E.P.A. has copies of both letters.  A revised cost estimate has been prepared
that includes all  these factors and is shown on the attached table  to be
about $5-2 million.  U.S.E.P.A.'s proposal of a force  main to serve Reynoldsburg
was apparently initiated to avoid induced growth south of Reynoldsburg.  With
the Information provided by the Fairfield County Regional Planning  Commission,
induced growth is  no longer an issue since there will  be a population density
of  1.7 persons per acre or more by the time an interceptor is built.

     The City has estimated costs for the Blacklick Interceptor from Brice Road
to  Broad Street.  Costs were estimated assuming connections to populations in
Violet Township were made and assuming the ultimate size of interceptor was
constructed through Reynoldsburg.   Using the Draft EIS criteria of  90 gpcd
average flow and 10 gpcd infiltration resulted In an estimated cost of $5,020,000,
below that of a force main alternate in Livingston Avenue.

     A $6,100,000 cost is estimated using a design criteria of 100 gpcd
average flow and 600 gpd  per acre infiltration, which would be consistent

-------
Mr. Charles Sutfin
U.S. Environmental Protection Agency
October 25, 1973
Page 5
with design criteria used in other major cities in Ohio.  There was a
difference of no more than two pipe sizes between the two alternates.

     The City has met with U.S.E.P.A. in Chicago twice since the September 13, 1978
meeting in the hopes of reaching a compromise.  However, we are not sure how
the statements made by U.S.E.P.A. af those meetings will be incorporated into
the Final  EIS.

     In order to eliminate confusion, we feel U.S.E.P.A. should clarify their
position relative to design criteria, unit process sizing and the cost
effectiveness analysis for both the interceptors and treatment plants.  We also
would like U.S.E.P.A. to reevaluate the alternatives for Scioto West, Rocky Fork,
and Blacklick Creek in view of our comments above and on a consistent basis
with other major cities in Ohio.

                                       Very truly yours,
                                       D. D. ROBBINS, P.E.
                                       Superintendent
DDRrMPI:jms

Enc.

cc:  R. C. Parkinson
     D. D. Robbins
     G. B. Walkenshaw
     R. Willis
     R. Smith
     F. Baldy  (City of Reynoldsburg)
     M. Macy  (Malcolm Pirnie,  Inc.)
     G. Elmaraghy  (O.E.P.A.)
     File

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              CONSTRUCTION COST FOR FORCE MAIN
                   ALONG LIVINGSTON AVENUE
a.)   Gravity Sewer along Livingston               $1,500,000

b.)   Force main along Livingston                     700,000

c.)   Pump Station at WWTP                            540,000

d.)   Additional small Pump Stations and
       force mains as described in
       Frank Baldy's letter                          570,000

e.)   Additional Major Pump Station                   540,000

                              Sub-Total           $3,850,000

             Engineering, Contingencies            1,350,000

                                  TOTAL           $5,200,000

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  Oiu
   ^«*™.^ ^M.**^ ••*.-»
The Ohio ' ate University            Civil Engineering
                              470 Hitchcock Hall
                              2070 Neil Avenue
                              Columbus, Ohio 43210
                              Phone 614 422-2771

        September  |8,  1978
Mr. George 8. Walkenshaw
Assistant Superintendent
Division of Sewerage and Drainage
90 West Broad Street
Columbus, Ohio ^3215

Dear Mr. Walkenshaw:

     I  have read the report entitled "Evaluation of the Wastewater Treatment
Processes Proposed for Columbus, Ohio, in the Draft EIS" written by
Mr, John Stamberg of Energy and Environmental Analysis, Inc.,  and dated
July 21, 1978.  My comments on this report follows.  Parenthetical references
to page numbers in this report are included where needed.

     (1)  Identification of Filaments.  The filaments are green and consist
of cylindrical cells without terminal differentiation; growth is heterotrophic
and occurs at low DO, but not under anoxia.  They were identified as the blue-
green alga Schizothr ix (alias Phormid ium) by Drs. Clarence Taft, of Ohio State
University, and Francis Drouet, of the Academy of Natural Sciences, Philadelphia.
These gentlemen are  internationally recognized authorities on microbial taxonomy.
They made their identification after  independent, first-hand examinations of
mixed liquor samples from Southerly.  On the other hand, Mr. Stamberg  is not
a microbiolog ist (Note his misspel1 ing of Schizothrix and Phormidium on page 7-),
and he has not had access to mixed liquor samples from Southerly.  His
identification of the filaments as a  photosynthetic bacterium is totally untenable.
A careful reading of Sergey's Manual  (Buchanan and Gibbons, 197*0 shows that no
species of photosynthetic bacteria  fits the filaments' description.  The only
green forms  (Rhodopseudomonas and various genera of the Chlorob iaceae) are
nonfilamentous; furthermore, the Chlorobiaceae are strictly anaerobic and
obligately phototrophic.  Confusion of photosynthetic bacteria with blue-green
algae or v.v.  is virtually  impossible, even  for a novice.  The Taft-Drouet
identification of the filaments as Sch? zothrix  (alias Phormid ium)  is,  therefore,
indisputable.   (it  should be noted that  Mr. Wei lings, Southerly's Chemist,
has  successfully isolated the alga using enrichment cultures growing aerobically
on minimal medium.   This disposes of  Mr. Stamberg's objection to our own failure
to  isolate the alga, but it  is  not necessary to  the identification.)

      (2)  Causes of  Filamentous Bulking.  There  is no basis whatever  in either
theory  or  in  fact for Table  2,  nor for the conclusions allegedly  drawn from  it.
First,  the majority  of the organisms  in  trickling filters are zoogloeal not

-------
Mr. George B. Walkenshaw
Division of Sewerage and Drainage
September 18, 1978
Page 2


filamentous  (Hawkes, 1963).  Second, Mr. Stamberg implies that the suspended
solids in an activated sludge mixed liquor are merely an accumulation of the
influent suspended solids  (pages 8 to 9)•   Fifty years ago, this position was
sometimes maintained, but  it is now known  that MLSS consist of those microbes
whose growth is favored by the mixed liquor conditions.  Consequently, the
composition of the MLSS is radically different from the composition of the
influent suspended solids.  Thus, even  if  substantial numbers of filaments
occurred in the influent  (which is unproved and unlikely) they would not
dominate the MLSS unless conditions favored their growth.  Third, Mr. Stamberg
states (page 11) that activated sludge  systems with long SRTs (incorrectly
identified as sludge [SIC] retention time) are subject to filamentous growths.
This statement flatly contradicts the well-established observation that
filamentous bulking  is associated with  short SRT's, or high F/Ms, since the
two are reciprocally related.  Furthermore, if Mr. Stamberg's assertion were
true, filamentous bulking  would be  the  bane of nitrifying activated sludges.
However, this is so  rare a problem  that the U.S.E.P.A.'s own manual on nitrogen
control  (Parker et al., 1975) does  not  even discuss  it.  Fourth, the occurrence
of  low DO's  in systems  intended for nitrification is the result of either a
design error or of an attempt to save money by cutting corners;  it simply does
not happen  in systems that are properly designed, constructed and operated.
Thus nitrification systems should not be  liable to filamentous bulking because
of oxygen transfer deficiencies, at least, not  if the U.S.E.P.A.'s plan review
process actually works.

      (3)  Selection  of Alternative  Plan.  The scenarios considered by Mr. Stamberg
consist of  a two-stage  biological system  consisting of trickling filters
followed  by activated  sludge  (page 1).   He asserts  that a  trickling  filter
located at  Southerly will  induce filamentous bulking  in  the activated sludge
process, whereas  if  the filter  is moved to the  brewery  it will not  induce
bulking.  A reason  for  this  rather  striking prediction  is not given,  perhaps
because none exists.   It  appears to contradict  his own  (fallacious)  seeding
theory of bulking.   First, on his principles, a  trickling  filter at  the brewery
should produce more  filaments  than  one  at Southerly,  because  the  soluble  BOD
would  be higher  (see pages 3,  8  6 9).   Moreover,  the  long  time-of-travel  in
 the sewer  between  the  brewery  and Southerly would  tend  to  fragment  the  trickling
fi1ter-sol ids.  Thus more filaments would escape  removal  in  primary  treatment
and seed  the activated  sludge.   Actually, there should  be  no  difference among
 the alternatives  as  regards  bulking.

      (*»)   Brewery V/aste and  Filament  Growth.   Mr.  Stamberg  has  misrepresented
our results regarding  the effect of brewery waste on filamentous bulking
 (see page  1).   To repeat, under  continuously high  DO  conditions  in  plug-flow
 reactors fresh  brewery waste never  caused filamentous bulking regardless  of the
 proportion of  brewery waste in the  sewage feed.  Under continuously low DO
 conditions in  plug-flow reactors,  fresh brewery waste induced Begg iafoa bulking.

-------
Mr. George B. Walkenshaw
Division of Sewerage and Drainage
September 18, 1978.
Page 3
However, continuously low DO does not occur at Southerly, and Beggiatoa bulking
is not Southerly1 s problem.

     In summary, I disagree strongly with virtually all of Mr. Stamberg's
biological statements.  His reasonings are usually baseless and sometimes
self-contradictory.  He has misrepresented our own research.  His cavalier
dismissal of the work of Taft and Drouet is simply outrageous.

                                      Respectful ly yours,
                                      ROBERT M. SYKES, Ph.D.
                                      Associate Professor

RMS:jms

Literature Cited:

 (1)  Buchanan, R.E. and Gibbons, N.E. et. al.  [ed.], Bergey's Manual of
     Determinative Bacteriology, 8th Ed., The Williams & Wilkins Co.,
     Baltimore  (1974) .

 (2)  Hawkes, H.A., The Ecology of Waste Water Treatment, The Macmillan Co.,
     New York  (1963TT~

 (3)  Parker, D.S.; Stone,  R.W. and Stenguist,  R.J., Process Design Manual
     for Nitrogen Control , Tech. Transfer, U.S. E.P.A., Washington  (1975).

 (*0  Stamberg, J., Evaluation of the Wastewater Treatment Processes Proposed
     for Columbus, Oh io,  in  the Draft El S, Energy and Environmental Analysis
     Inc., Arlington  (1978).

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        ENERGY AND  ENVIRONMENTAL ANALYSIS, INC.
                                        January 4,  1979
Division of Water
EPA Region V
230 S. Dearborn
Chicago, Illinois  60604
1111 North 19th Street
Arlington. Virginia 22209
(703) 528-1900
Dear Mr. Luecht:
In Mr. D.D. Robbins1 letter of October 25,  1978,  the City of Columbus
stated that they refuse to accept the wet process streams proposed  in
the draft EIS.  This was based on the fact that "the NPDES effluent
limitations would be unattainable."  The foundations for their con-
clusion are not supported by any scientific or engineering theory,
analysis or testing of the proposed wet process streams.   Their argu-
ments rely on the following points:

1.  Robbins and his consultants know of no wastewater plants of
    comparable size that have been designed and operated using the
    criteria in the Draft EIS and still meet the NPDES limitations
    proposed in the Draft EIS year round.

2.  The criteria in the Draft EIS do not meet "Ten States Standards"
    or OEPA standards.

3.  Based on criticism from Dr. Robert Sykes, my report and subsequent
    recommendations concerning the Columbus plant were judged invalid.

The first factor simply shows a reluctance to use or rely on existing
scientific and engineering knowledge in evaluating the problem.  Given
the restrictions of size, loading, NPDES standards, etc., it would  be
near impossible to find an exact parallel to the situation in Columbus.
This type of statement could be made for about any design of a large
treatment facility, even those in their 201 plan.  Therefore, it is in
these situations that scientific and engineering expertise is required.

The second factor implies that conformance with "Ten States Standards"
and/or OEPA standards insures compliance with,the proposed limitations
NPDES for Columbus.  In fact, a major survey   of municipal wastewater
treatment plants conforming to "Ten States Standards" showed the vast
majority did not comply with NPDES permit limitations.  Paradoxically,
the City of Columbus accepts these standards as appropriate to the
                             Economics / Enoineerino

-------
1/4/79
page 2
Division of Water, EPA Region V


situation of Columbus independent of their knowledge of a facility of
comparable size, loading rate, NPDES standards, etc., which has been
design and operated for a year in compliance with the limitations.  In any
case, the simple conformance or non-conformance of the criteria in the
Draft EIS to the above standards does not prove that the system in the
EIS could not attain the proposed NPDES requirements.

Finally, the dismissal of my report on the basis of Dr. Sykes1 criticism
is absurd.  Dr. Sykes1 comments generally ranged from trivial (e.g., his
spelling corrections) to misleading (e.g., his assertions regarding the
effect of brewery waste on bulking growths).

An example of one area of conflict between Dr. Sykes and myself is the
problem of identification of the bulking organism.  Certainly,
Drs. Taft and Drouet are authorities of the highest repute.  However,
it is probable that neither examined the bulking organisms under a
microscope where the genera Schizothrix and Phormidium would be readily
distinguishable to the trained eye.^/Their identification was likely
based upon un-aided visual examination only and hence must be considered
tenuous.  On this basis, we cannot discard the theory that the bulking
organisms are filamentous bacteria which have been observed to morpho-
logically closely resemble some types of blue-green algae.3/

Of considerably more importance is the determination of the cause of
Southerly"s bulking problem.  The bench studies done by Dr. Sykes
showed replication of bulking activity under conditions of low or
variable D.O. on reactors fed "fresh brewery waste" and/or settled in-
fluent sewage plus addition acetate.  Dr. Sykes viewed the insufficiency
of fresh brewery waste alone to induce bulking under simulated plant
conditions as proof that the brewery waste was not a cause of the bulk-
ing.  He instead concluded that acetate was the probable cause of the
Southerly bulking.

Although Dr. Sykes1 data are somewhat useful, it is apparent that his
conclusions are misleading.  Dr. Sykes gives the impression that his one
shot batch type bench studies accurately duplicate equilibrium conditions
of Southerly's treatment processes.  However, the anaerobic or microaerobic
conditions in the sewers and in the activated sludge tanks are omitted
from Dr. Sykes treatment.  In the treatment plant under these conditions
much anaerobic metabolism occurs, which can transform brewery wastes into
volatile acid metabolities such as acetic and propionic acid. '  These
metabolities, microaerobic conditions and high soluble BOD concentrations
(from the brewery waste) in the activated sludge tanks form an ideal en-
vironment for filamentous bulking organisms.

-------
1/4/79
page 3
Division of Water, EPA Region V
This hypothesis explains why the addition of acetate was seen to induce
bulking in Dr. Sykes1 studies.  Hence, Dr. Sykes1 conclusion incorrectly
implies that brewery wastes play little part in either the formation of
acetate or of conditions favoring bulking.  Also, Dr. Sykes1 analysis
fails to answer the crucial question of how chemicals such as acetate
and low D.O. are generated at the Southerly plant.  Again, these condi-
tions can be caused by anaerobic raicrobial metabolism in response to
high soluble BOD loadings from the brewery wastes.  Certainly, the
satisfactory performance of the Jackson Pike plant in contrast with that
of the Southerly plant only reinforces the conclusion that the brewery
wastes both directly and indirectly (via anaerobic breakdown into low
molecular weight metabolities) cause Southerly's bulking growth.

In summary, the City of Columbus uses nothing but specious rationale
to render the wet process design criteria in Draft EIS unacceptable.
                                      Sincerely,
                                      John Stamberg

Note:  References attached.

-------
                            References
1.  Stamberg, J.S., et al, "Evaluation of Municipal Wastewater Treatment
    Plant Operations under the NPDES Permit/Enforcement Program"
    (Prepared for EPA, 1978).

2.  Smith, G.M., Fresh Water Algae of the United States, McGraw Hill Book
    Co. New York (1933).

3.  Eikelboom, D.H., "Filamentous Organisms Observed in Activated Sludge",
    Water Research 9:  365-388 (1974).

4.  McCarty, P.L., Jeris, J.J. and Murdoch, W., "Individual Volatile
    Acids in Anaerobic Treatment", JWPCF 35:  1501-1516 (1963).

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               APPENDIX  BB



   REVIEW OF COLUMBUS, OHIO DRAFT EIS



                    BY



MUNICIPAL ENVIRONMENTAL RESEARCH LABORATORY



         U.S. EPA CINCINNATI, OHIO

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                   UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                                   CINCINNATI, OHIO 45268

   DATE: April 19, 1979

SUBJECT: Review of Columbus, Ohio Draft Environmental Impact  Statement
        (dated February, 1978)
FROM:  Edwin F> earth, Chief
      Biological Treatment Section,  TPDB, WRD, MERE,

  T0:  Stephen P. Poloncsik, Chief
      Technology Division (5WEE)
      U.S.  EPA Region V
      Chicago, Illinois 60604
                                                                           _,
                                                                          en
        THRU:  Robert L. Bunch,
               Treatment Process Development Brancn, WRD
        THRU:  John J. Convery, Direc-cor^CL,
               Wastewater Research Division
        I. Background

             In accordance with the understanding among Messrs F. Mayo, J. Convery,
        S. Poloncsik, G. Williams, J. Roesler and E. Earth, the subject document
        was reviewed to evaluate the process design for the Southerly Treatment
        Plant in relation to pretreatment Scenario #2.

             In preparing for this, the following documents were reviewed:

             1) Environmental Impact Statement, "Wastewater Treatment Facilities
                for the Metropolitan Area Columbus, Ohio"  (February 1978).

             2) "Evaluation of the Wastewater Treatment Processes Proposed for
                Columbus, Ohio."  Energy and Environmental Analysis, Inc., J.
                Stamberg (July 21, 1978).

             3) Responses to subject EIS; A collection of letters and prepared
                responses to comments (unbound and undated).

             4) Cost Effective Analysis; "Columbus Metropolitan Area Facilities
                Plan," Malcolm Pirnie, Inc. (Volume One of One, and Volume Two
                of Two, July 1976).

             5) "Preliminary Report on Elimination of Filamentous Treatment
                Plant," Robert Sykes, Ohio State University, Columbus, Ohio
                (April 1978).

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                               -2-

     This review does not address the need, desirability or regulatory
aspect of pretreatment of brewery waste before discharge to the Southerly
plant.  It concerns only the compatibility of process selection and unit
sizing for Scenario #2 in relation to the discharge permit for the Southerly
plant.

     These discharge requirements are tabulated in the draft EIS as
follows:

                                    Average Permissible Value
      Parameter                    30 Day               7 Day

      BOD5, mg/1                     8                   12

      SS, mg/1                       8                   12

      Fecal coliform, #/100 ml      200                 400

      NH4-N, mg/1:
         July-October               1.0                 1.5
         November-December          2.5                 5.0

      P, mg/1                       1.0                 1.5

      DO, mg/1                      6.0

      pH, units                    6 to 9              6 to 9

     It should be noted that the draft EIS and the Facilities Plan
work with different volumes of flow to Southerly and the EIS is not
consistent in regard to flow between text and appendix pages.  Also,
the EIS does not completely finalize the sludge handling options at
Southerly.  Since the design is mainly in the conceptual stage at this
time these points should not materially effect the evaluation.

II. Review

     1. Filamentous and/or Bulking Sludge at Southerly

     Section IV, pages 3 and 4 indicate soluble carbohydrate induces
a bulking activated sludge at Southerly.  The Sykes report describes
bulking in pilot reactors caused by Sphaerotilus, Beggiato and Schizothrix
under different operating and feed regimes.  Stamberg dismisses the Sykes
work and ascribes the causative organism to a class of filamentous photo-
synthetic bacteria.  Mr. Rodgers of the Columbus staff, has isolated and
corelated the blue-green algae Schizothrix, with bulking conditions at
Southerly.

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                               -3-
     Dr. R. Safferman, EMSL-Cincinnati, has observed a mixed liquor sample
from Southerly, provided by Mr. Rodgers, and reviewed the Sykes report.
From gross observation, Dr. Safferman was not able to confirm the presence
of Schizothrix in that particular sample.  Dr. Safferman's review of the
Sykes report brought forth many questions on the adequacy of the work
in regard to controls and cultural conditions.  It is Dr. Safferman's
judgement that to resolve the problem of association of the bulking
condition at Southerly with a specific organism would require at least
a man year of effort under carefully controlled conditions.

     It is WRD's position that resolution of the causative organism is
not a central feature of process selection for Southerly.  The main
consideration should be that historically, bulking has been observed
at Southerly and any design modification should provide the flexibility
of operational control to manage a bulking situation.

     2. General Comments on Process Design, Irrespective of Scenario #2

     a) Aeration Configuration

        The conceptual layout of the aeration system shown on Table IV-18,
page IV-77 is considered quite appropriate for the Southerly situation.
This configuration would provide operation flexibility to meet the inter-
mittent nitrification requirements, provide energy savings during the non-
nitrification season, assist in controlling solids flux to the clarifiers,
and provide control of bulking sludges.

     The total aeration volume at Southerly, after the addition of 5.2
million gallons of tankage recommended in the facilities plan, will be
26-s-3 million gallons.  This would provide 7.4 hours of detention time
based on 85 mgd of flow.  If the 5.2 million gallon capacity were used
for reaeration as indicated in Section K-9 of the EIS, this would provide
5.9 hours of detention time.  At the process peak flow the respective
detention times would be 4.8 and 3.9 hours.

     Since nitrification kinetic rate is based on 10  C and the Southerly
nitrification requirement is most stringent during warm weather, no difficulty
in achieving nitrification at these detention times with a CRT of 15 days
is anticipated.

     In the responses to the EIS it was noted that a step aeration
process such as shown on Table IV-18 was not considered suitable for
nitrification.  This is true if detention times are very short; however,
as noted above, this is not the case with Southerly; the reactor can be
managed to provide full detention time or increased mixed liquor solids
and yet limit solids flux to the clarifier.  This point also relates to

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                               -4-
a response comment regarding clarifier overflow rates higher than the
"Ten State Standards."  At process design flow of 85 ragd, the Southerly
final clarifiers will have a surface overflow rate of 626 gallons per
day per square foot.  The EIS properly indicates that in addition to
surface overflow rates the solids flux to clarifiers should be controlled.
The flux of a maximum of 25 pounds per square foot per day indicated for
Southerly is adequate.

     The provision for reaeration of the return sludge should not only
assist in maintaining a high CRT, but materially assist in minimizing
the occurrence of bulking sludge at Southerly.  Aeration of the mixed
liquor in the absence of substrate shifts the metabolism toward an
endogenous stage and improves settleability.

     b) Efficient Oxygen Transfer

     The EIS recommends a change to an oxygenation system which is more
efficient than the present sock diffusers at Southerly.  This is considered
vital to success of nitrification and improvement of the sludge bulking
as well as a necessary step to increase energy utilization.  Recent testing
of jet aerators by the Los Angeles County Sanitation District under WRD
sponsorship has shown these devices not to be as efficient as the EIS
indicates.  However other fine bubble devices showed efficiencies in the
neighborhood of 5 to 7 pounds of oxygen transferred per horsepower hour
(wire).  As indicated in MERL's June 5, 1978 memo to Dale Luecht, we would
reemphasize the desirability of a Step 1 engineering feasibility study
of aeration devices for the Southerly plant.  MERL could assist in this
study in any manner your Division thinks necessary.

     c) Design Flexibility

     Review of the EIS shows a good deal of effort in regard to process
flexibility.  Aside from the aforementioned aeration concept, the provision
for routing flow around the plastic first stage filters and capability
of directing return sludge to these filters is sound practice.  This
will allow energy savings and process control to meet the seasonal
discharge requirements at the Jackson Pike plant.

     Provision for mating aeration bays with respective final clarifiers
will allow maintenance without major deterioration of effluent quality.

     The interconnecting piping between Southerly and Jackson Pike should
help ease peak loading for both main stream flow and sludge handling
operations.

     Provision of multiple metal dosing points for phosphorus control is
desirable practice to allow efficient use of precipitant and process control
with changing wastewater characteristics.

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                              -5-
     3. Scenario #2

     Scenario #2 process design as given in the EIS differs from the
facilities plan for Southerly in that the recommended first stage plastic
filter and intermediate clarifier have been deleted.  To compensate for
this deletion, pretreatment of the brewery waste by plastic media filters
will be provided upstream of the Southerly plant, and the filter under
drain discharged directly into the sewer system leading to Southerly.

     Section V-12 of the EIS indicates that the existing pretreatment
and primary sedimentation facilities at Southerly will not be expanded.
This is the most severe reservation we have in regard to Scenario #2.
The sloughed solids from the brewery plastic media filters will have
to be caputured by the existing primary tankage.  In addition, a portion
of the phosphorus will be precipitated in the primaries which will
increase the solids load.  Also, aside from normal primary solids, solids
from phosphorus control and sloughed brewery pretreatment solids, recycle
solids will enter the primary tanks.  These recycle loads will be tertiary
polish filter backwash, air flotation subnatant, thermal conditioning
recycle, digester supernatant, and vacuum filter filtrate (or centrifuge
centrate).  Appendix J outlines these recycles.

     Section A-19 of the EIS states that historically Southerly operation
has been plagued with solids handling problems.  Coupled with this is the
statement in Section IV-64 (4.42) and Appendix J (J.6) that an intermediate
clarifier is considered essential for the reliability of the Jackson Pike
plant.  Since the sloughed solids from the upstream brewery plastic filter
will be transported to Southerly via the sewer, efficient solids capture
will be necessary to protect the single stage nitrification process from
excessive sludge wasting and consequent loss of CRT control.

     Conceptually we see nothing wrong with Scenario #2, but express
concern over implementing good solids control, with the above considerations
in relation to Southerly operation, when the primary tankage receives
incremental solids.

     4. Environmental Effects of Sloughed Solids

     Several of the responses to the EIS stated concern over the fate and
effects of sloughed plastic media trickling filter solids during transport
in the sewer to Southerly.  A newspaper account of two fatalities occurring
under conditions of similar circumstances cannot be related directly to
sloughed solids.  Extreme safety measures must always be followed when
entering any enclosed area conveying wastewater, whether or not sloughed
trickling filter solids are present.

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                               -6-

     Several proposals have been put forth to use sewer travel time as
a part of complete treatment by aeration or oxygen injection at selected
sewer sites (Boon, A. C.,  et al., "The Use of Oxygen to Treat Sewage
in a Rising Main," Water Pollution Control, Volume 76, pages 98-112,
1977).

     Inherently sewers are devoid of oxygen to an extent that depends
on character of the waste being conveyed, flow characteristics and
geometry.  Whether or not the introduction of some quantity of actively
respiring organisms would lead to a deleterious condition would have to
be based on site specific evaluation.

     Los Angeles County Sanitation Districts'  have evolved over the years
the concept of satellite treatment facilities that handle constant flow
and a centralized sludge handling facility.  The satellite plants discharge
primary and waste secondary solids directly to sewers leading to the
central sludge processing plant.  WRD suggests that historical data on
this practice could help resolve the deliberations on the environmental
effects of the brewery filter solids discharged to the sewer leading to
Southerly.
cc: F. T. Mayo
    Dr. R. Safferman

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             HAVESTS
                                               EMERSON
OLEN H.ABPLANALP
STANLEY H. BUTTON

GEORGE O.SIMPSON
VINCENT A. IAOAVAIA

GARY M. SI EG EL
JUNIUS W. STEPHENSON

SOL KOPVOWITZ
ROBERT L. KAERCHER

MICHAEL C. MULBARGER
RICHARD N. SPADEMAN
                         IXCORPORATED

                   CONSULTING ENGINEERS
CLEVELAND OFFICE:
       BOND COURT BUILDING
       I3OO EAST 9TH STREET
       CLEVELAND, OHIO
           2I6/62I-24O7


             May 9, 1979
                                              ENVIRONMENTAL
                                              ENGINEERING
                                                               WATER RESOURCES
                                                               POLLUTION CONTROL
                                                               SEWERAOE-O RAINAOE
                                                               WASTEWATER TREATMENT
                                                               INDUSTRIAL WASTES
                                                               SOLID WASTES DISPOSAL
                                                               AIR POLLUTION CONTROL
                                                               RATE INVESTIGATIONS
                                                               SANITARY LABORATORIES
                                                               AREAWIDE PLANNING
Mr. Dale Luecht
Water Division
U. S. Environmental
Region V
230 S. Dearborn
Chicago, Illinois

Dear Mr. Luecht:
                               Protection Agency
                               60604
                In response to  your  request,  we are pleased to document the
          conversation between Mr.  E.  F.  Barth and myself in USEPA's Chicago
          office on May  8th  regarding  his April 19, 1979 memorandum, "Review
          of Columbus, Ohio  Draft Environmental Impact Statement".

                Page 2, Paragraph 5,  Sentence 1

                    The  inconsistencies mentioned only reflect a 10 mgd
                credit for.recycle flows  (filter backwash, etc.) on the
                average daily flow received at the plants.  Mr. Barth
                acknowledged  the point  and indicated that he had no further
                problem in understanding.

                Page 3, Paragraph 3,  Sentence 1

                    Mr.  Barth  was advised that the final volume is 31.5
                million gallons, inclusive of the 5.2 million gallon expan-
                sion which can  be used  for return sludge aeration during the
                winter to satisfy biomass  cell residence time considerations
                (see Table K-4). Mr. Barth acknowledged the misunderstanding.

                Page 5, Paragraph 2,  Sentence 5

                    Mr.  Barth  was advised that the filter backwash at Jackson
               •Pike is to be preferentially returned to the intermediate
                settler;  at Southerly the  process stream is to be returned
                to .the head of  the final settler (see Figure V-l).  At Jackson
                Pike, the potential  return of filter backwash to the final .
                clarifier is  also shown.   We also indicated that return
                of this flow  to the  primaries at both plants was also viable
                as an alternate point of introduction and should be provided
                if possible.  Mr. Barth acknowledged the misunderstanding.

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Mr. Dale Luecht
U. S. Environmental Protection Agency
May 9, 1979
Page 2
     Page 5, Paragraph 2, Sentence 5 - Continued

          Further, although not discussed with Mr. Barth, for
     calculation convenience and a worst case statement, we
     assumed that the other recycles were applied directly to
     the primary effluent (see Table K-l).  Thus, at Southerly,
     the primary routinely sees only raw wastewater, sloughed
     brewery pretreatment solids, and the additional solids mass
     derived from phosphorus control by metal salt addition.

     We believe that the foregoing adequately described our conversa-
tion and adds clarity where Mr. Earth's review comments inadvertently
conflicted with statements in the Draft EIS.  By copy of this letter,
we are informing Mr. Barth of our response to your request.  If either
he or you are in disagreement, we request that you inform us by
May 21, 1979.  Otherwise, we will assume that there is no need for
further discussion and that the comments are correctly stated.

                                  Very truly yours,

                                  HAVENS AND EMERSON,' INC.
                                  Michael C. Mulbarger

MCM:fch



cc:  Mr. E. F. Barth

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               APPENDIX  CC

           REVISED CHAPTER III:
SERVICE AREA AND SEWER SYSTEM ALTERNATIVES

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               CHAPTER  III




             (REVISED MAY  1979)




SERVICE AREA AND SEWER  SYSTEM  ALTERNATIVES




      (WITH ASSOCIATED  CORRESPONDENCE)

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       III.  SERVICE AND SEWER SYSTEM ALTERNATIVES
3.1  REGIONALIZATION

     This Section discusses the possibility of regionalization
of various divisions of the planning area.  Each subarea is first
defined and described, as are the regionalization alternatives
proposed for each in the Facilities Plan and by subsequent review
of the Plan.  A final section examines the cost sensitivity of
the chosen plan to various design philosophies.
3.1.1  Description of Planning Area

     Figure III-l shows the planning area and subareas.  All
of Franklin County except the extreme southeast and southwest
corners is included, along with areas to the northwest as far
as Sunbury in Delaware County.  Also included is a small area
of Delaware County west of the 0'Shaughnessy Reservoir and small
portions of Licking, Fairfield, and Pickaway Counties.


3.1.2  Existing Service Area

     The existing service areas for the two wastewater treat-
ment facilities serving the City of Columbus are also shown on
Figure III-l.  These two plants, Jackson Pike and Southerly,
presently serve the City of Columbus as well as the communities
of Bexley, Worthington, Westerville, White Hall, Upper Arlington,
Marble Cliff, Grandview Heights, portions of Gahanna, Hilliard,
and small unincorporated areas surrounding the City of Columbus.

     A 42-inch gravity sewer designed to service the areas along
the eastern edge of Griggs Reservoir and the upper Scioto River
as well as the Dublin area west of the Reservoir is presently
nearing completion.  The latter area will contribute its flow
via a force main across the Reservoir south of State Route 161.
This main will continue to be used until an interceptor along
the western edge of Griggs Reservoir is constructed.  All
intercepted flow will be transported to the Jackson Pike Plant
for treatment.

     Also nearing completion is the interconnecting sewer
between the Jackson Pike and Southerly service areas.  This
line, which varies from 150 to 156 inches in diameter
throughout the gravity portions of its length, currently
                            III-l

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               LEGEND
                                                                  Figure IE-1
                                                             Planning Area For
                                                          Metropolitan Columbus
I.  WEST SCIOTO
2.  BIG RUN
3.  DARBY CREEK
4.  GROVE CITY
5.  MINERVA PARK
6  SUNBURY-GALENA
7.  BIG WALNUT CREEK
8.  ROCKY FORK
9  BLACKLICK CREEK
10. GROVEPORT
II.  RICKENBACKER A.F.B.
••EXISTING SERVICE AREAS

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transports flow from Grove City to the Southerly Plant.  Presently,
the City of Columbus has a construction contract (City Auditors
Engineer Contract Reference Number 2032) which would tie the
interconnecting sewer to the Big Run and Frank Road Interceptors
and divert these flows to the Southerly WWTP.  Appendix I to
this report proposes that the interconnecting sewer be used to
transport excessive Jackson Pike flows (greater than 200 mgd)
to Southerly to avoid a 25 to 50 mgd expansion at Jackson Pike
and to utilize the full hydraulic capacity of both treatment
plants.  In order to fully tie the two plants together, it is
proposed that the interceptor be extended from the Big Run and
Frank Road connections some two to three thousand feet to con-
nect to the Jackson Pike influent sewers.  The estimated cost
for this extension is $1.2 million.

     Approximately 12,000 acres, or 12 percent of the areas
tributary to the wastewater treatment facilities, are served
by combined sewers.  Twenty-five hundred acres of this total
contribute flow to Southerly while the remainder are influent
to Jackson Pike.  At the present time, there are at least three
major combined overflow points in the Southerly system, and 30
major overflows to the Scioto River in the Jackson Pike system.
OEPA reports that there are some 80-90 additional overflow
points in both systems.  Present plans for the combined system
are somewhat undefined, with an ongoing sewer system evaluation
survey being conducted and plans being laid for the separation
of some key areas.  Therefore, a detailed analysis and recom-
mendations of and for the combined areas are inappropriate
for this Impact Statement at this time.

     However, in the interest of completeness, a preliminary
analysis and mathematical modeling of the combined sewer over-
flows was done to determine if any tentative conclusions could
be drawn.  Appendix H presents the inputs and results of this
work.  The major conclusions of the Appendix are:

          Degradation of Alum Creek is primarily dependent
          upon the quality of the combined sewer overflow,
          indicating treatment may be a viable alternative.

          Degradation of the Scioto River below the combined
          overflows is severe even at relatively good quality
          loadings (6005 < 10 mg/1) in conjunction with
          all quantities of overflow modeled, indicating
          the need for improvements within the sewer system
          before attempting to treat at overflow points.
                           III-2

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3.1.3  Subarea Description

     This Section describes and discusses each of the 11 subareas
shown in Figure III-l,  and considers the feasibility of the in-
clusion of each in a regionalized system.

     (1)  West Scioto

          This 24,300 acre unit is located in the northwestern
     part of Franklin County,  and is bordered on the east by
     the Scioto River and on the south by the Cities of Billiard
     and Upper Arlington.  Also included are the Muirwoods Vil-
     lage and Shawnee Hills areas of southern Delaware County.

          The present population of the West Scioto area is
     estimated to be 13,500 "people, and is projected to in-
     crease to 31,800 by 1985,  and to 42,600 by the year 2000.

     (2)  Big Run

          The Big Run service  area is also located in western
     Franklin County just south of the West Scioto subarea, and
     is comprised of the drainage to Hellbranch Run upstream of
     U.S. Route 40.  This 12,900 acre subarea is estimated to
     presently contain 1,500 people, and is expected to increase
     to 4,600 by 1985 and 10,400 by the year 2000.  The area is
     presently unsewered.

     (3)  Darby Creek

          The Darby Creek area encompasses the remaining 28,500
     acres in the western portion of the planning area.  The
     present population is estimated at 4,500.  The largest
     population center, 750 people, is the Village of Darbydale.
     The population projections for this area envision 11,100
     people by 1985 and 17,000 by the year 2000.

          There are presently no sewers in the Darby Creek
     subarea.  The projected population density is only slightly
     more than onehalf person per acre.  The combination of
     such a low density and the need for either pumping of
     sewage into the Columbus  service area or construction
     of deeply laid sewers precludes further consideration
     of this subarea as a portion of a regional plan.

     (4)  Grove City

          The Grove City subarea is bounded on the south by
     the Franklin-Pickaway County line, on the east by the
                             III-3

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Scioto River, on the north by areas presently served by
the City of Columbus sewer system, and on the west by
the Darby Creek subarea.  Relatively heavy development
has taken place in and around both Grove City itself and
the Village of Urbancrest.  These two municipalities have
a present total estimated population of 19,000,  a value
which is expected to increase to 20,900 by 1985  and to
26,200 by the year 2000.  Recently, wastewater flows
from Grove City and Urbancrest have been diverted to
the Southerly-Jackson Pike interconnecting sewer, making
further regionalization considerations academic.

     Rural areas predominate south of Grove City, and
consist of approximately 16,100 acres with expected
1985 and 2000 populations of 6,100 and 12,300 respect-
ively.  Due to this sparse population, the rural areas
of this subunit will not be considered further for
regionalization.

(5)  Minerva Park

     The Minerva Park subarea consists of 750 acres
located in the north-central portion of Franklin County.
Sewer service is presently provided by the Southerly
WWTP for the areas to the north, south, and west of
Minerva Park, with the 72-inch Alum Creek Interceptor
bounding the eastern side.  Wastewater from the  area is
presently collected and conveyed to the Minerva  Park
WWTP, which dicharges to Minerva Lake Creek.  The
existing plant is a 0.17 mgd extended aeration facility
which serves a contributory population of approximately
1,500 people.  Projected populations for the total sub-
area are 3,400 by 1985 and 3,500 by the year 2000.

(6)  Sunbury-Galena

     The 45,000 acre Sunbury-Galena subarea is located
in Delaware and Licking Counties.  It is bounded on
the north by an imaginary line just north of Sunbury,
on the east by the Hoover Reservoir watershed divide,
on the south by a line just above the Duncan Run drain-
age area, and on the west by a line one to two miles
west of Hoover Reservoir.

     Homes in the area primarily use septic tanks and
leachfields for sewage disposal.  The exception  to this
is the Village of Sunbury, which is sewered and  uses a
treatment facility which discharges to a tributary of
                       III-4

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Big Walnut Creek.  Proposals to study sewerage alterna-
tives in a facilities plan for the area have been sub-
mitted.  The lead entity in this endeavor is the Village
of Sunbury, with the Village of Galena and Delaware County
also participating.

     The facilities plan will consider the possibility
of regionalization into the Columbus system as one
alternative for Sunbury-Galena.  If regionalization is
deemed best, flow from the area would be treated at the
Columbus Southerly facility.

(7)  Big Walnut Creek

     The 24,300 acre Big Walnut Creek subarea is located
in northeastern Franklin County and southeast Delaware
County.  It includes all the drainage to Big Walnut
Creek from Duncan Run south to the existing 84-inch
interceptor at State Route 161.

     Projected populations for this area are 14,100 by
1985 and 21,300 by the year 2000.  The portion of the
subarea located in Delaware County is to be included in
the facilities planning activities discussed for Sunbury-
Galena.  This area was also included in the Columbus
Facilities Plan and was, therefore, retained for review
in this Environmental Impact Statement.  Due to the
physical layout of this and the following two subareas
(Rocky Fork and Blacklick Creek), a regionalization
decision made for one must be implemented in all three.

(8)  Rocky Fork

     The Rocky Fork subarea consists of some 11,400 acres,
all of which is tributary to Rocky Fork.  The Big Walnut
Creek and Blacklick Creek units form the boundaries to
the northeast and west, respectively.  The Rocky Fork
subarea presently has 4,300 people, and is expected to
grow to 9,100 by 1985 and 17,800 by the year 2000.  The
largest centers of population are the Villages of Gahanna
and New Albany (which is presently unsewered).

(9)  Blacklick Creek

     This subarea consists of 32,700 acres of the Black-
lick Creek drainage basin, and extends from the Creek's
headwaters to the existing 96-inch interceptor at Brice
Road.  Portions of both Franklin and Licking Counties
are included.
                       Ill-5

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          The estimated present population of the area is 27,700,
     The population is projected to be 30,300 by 1985, and
     41,900 by the year 2000.   The heaviest population concen-
     tration is found in Reynoldsburg, which had a 1970 total
     of about 13,900 people.  The City of Reynoldsburg operates
     a contact stabilization wastewater treatment plant with
     a 2.25 mgd design capacity.  Present operation of this
     facility reportedly requires occasional bypassing of
     untreated sewage directly to Blacklick Creek.

     (10) Groveport

          The 5,000 acre Groveport subarea consists of the
     Village of Groveport and surrounding unincorporated areas.
     In 1970, Groveport had approximately 2,500 people.  Most
     of the present population contributes wastewater to a
     0.30 mgd trickling filter facility.  The Franklin County
     Commissioners currently own and operate the treatment
     plant for the Village of Groveport.  The plant and sewer
     system will be turned over to the Village when the bonds
     are retired in the near future.  The discharge from this
     plant is to Little Walnut Creek.  An expanded sewer sys-
     tem could collect flow from the entire area and transport
     them by gravity into the existing 96-inch Blacklick Creek
     and 108-inch Big Walnut Creek Interceptors; a total ser-
     vice option which is not possible with the location of
     the present treatment plant.

     (11) Rickenbacker Air Force Base

          The Rickenbacker Air Force Base consists of some
     4,200 acres.  The Base is currently being served by a
     1.25 mgd trickling filter plant which discharges to Walnut
     Creek.  In 1970, there were approximately 5,600 persons
     at the Base.  However, the Department of Defense has
     decided to deactivate the air base making regionaliza-
     tion academic.
3.1.4  Summary

     The following subareas were chosen from those discussed
above as suitable for possible inclusion in a regionalized
system:

          West Scioto

          Big Run
                            III-6

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          Minerva Park

          Big Walnut

          Rocky Fork

          Blacklick Creek

          Groveport

          Rickenbacker Air Force Base(l)

Selection of a final total regional area from among these sub-
areas is dependent upon the cost-effectiveness of the inclusion
of each, as analyzed and discussed in the following section.


3.2  ALTERNATIVE COMPARISON

     This section will contain a description of alternatives
within each planning subarea and a discussion of the primary
impacts and costs associated with each.  Ultimately, a final
recommended plan is selected and described.  (Secondary impacts
are discussed for each subarea in Chapter VII of Volume III.)


3.2.1  General

     The Brookside Estates area, which was considered in the
Columbus Facilities Plan, will not be evaluated in this Impact
Statement, since its construction has been approved and com-
pleted.  Construction consisted of the installation of a 30-inch
sewer that connects to the Olentangy Interceptor Sewer a few
hundred feet north of State Route 161.  This plan was that
recommended by the Brookside Estates Mini-Facilities Plan.

      The East Scioto area has a newly constructed 42-inch
extension of the existing 42-inch East Scioto Interceptor
from Case to Martin Roads parallel to Riverside Drive.  This
system will serve the east side of the Scioto River as well as
the portion of the City of Dublin which is located on the
western side of the River.  Service to the western side is
provided by a completed pump station and force main crossing
the River on the south side of Route 161.  Servicing of the
western side is to continue until another means of disposal
is provided or the eastern side grows in population and



(^Reasons for including Rickenbacker Air Force Base in the
   analysis are given in Section 3.2.7.
                            III-7

-------
requires the extra capacity of the East Scioto Sewer extension
for its sanitary flow.  Because of this sewer construction, the
East Scioto area will not be considered further in  this Environ-
mental Impact Statement.

     Sewers for the areas to be regionalized were designed in
the Facilities plan based on ultimate population.   Guidelines
proposed since the preparation of the Facilaities Plan have
recommended the use of year 2000 populations for sewer design.
Accordingly, the sewer sizes developed in the following sections
have used the slopes and peaking factors listed in the Facili-
ties Plan (with a 0.013 Manning's n)  in conjunction with year
2000 population projections.  Sewers specified are assumed to
flow at or near half capacity at the end of the planning period
Size and cost sensitivities to designs predicated on ultimate
populations, half capacity at year 2000, and full capacity at
year 2000 are provided in a later section of this chapter.

     The quantity of dry weather sewage flow was calculated
to be approximately  90 gpcd.  This flow was developed after
analyzing the Infiltration/Inflow data available for the City
of Columbus (!) .

     The overall gaged infiltration from 19 existing service
areas discussed in the I/I report can be expressed in two ways:
3,580 gallons per inch-diameter mile per day, or 173 gallons per
capita per day.  For ease of design computation, an allowance
for infiltration expressed in gallons per capita is desirable.
Using 200 gallons per inch-diameter mile as an allowable infil-
tration number which can be achieved in new sewers, and
assuming the ratio of 3,580 gallons per inch-diameter mile to
173 gallons per capita to hold true  (20:1), a value of 10 gal-
lons per capita per day results for infiltration into newly
constructed sewers.
     Having established a total estimate of 100 gallons per
capita per day (gpcd) for infiltration and sanitary flow,
the total design flow was calculated using the following
equation:

          Design Flow = P2000 x 10° 9Pcd x P-F-

              P2000 = Population in the year 2000

              P.P.    = Columbus Peaking Factor
(1)"infiltration/Inflow Analysis, Columbus Metropolitan Area
   Facilities Plan" by Malcolm Pirnie, Inc., 1975.
                            III-8

-------
The flow calculated by this equation was then divided by 0.51,
a factor which will provide the capacity for a sewer which
will flow half full in the year 2000 d).  The relationship
of average daily flow to the peaking factors selected for use in
the equation is shown in Figure III-2 (2).

     Interceptor costs used in the following sections were
based on recent bids for sewer construction in the Columbus
area. Capital costs for lateral sewers and house connections are
not included in alternative comparisons, since Federal funding
for their construction will not be available except in scattered
cases meeting the requirements of Appendix G (3).  other
capital costs for items such as pump stations and treatment
plants were estimated based on past experience with the struc-
tures under consideration.  Operation and maintenance (O&M)
expenses were computed using actual current plant costs and
estimates of costs that will be incurred through the year 2000.
Annual O&M costs for interceptors were assumed to be equal to
0.25 percent of the initial construction cost.  Any computations
involving interest used an annual rate of 6-3/8% over the period
starting in 1980 and ending in the year 2000.  Service lives of
interceptors and wastewater treatment plants were assumed to be
50 and 35 years, respectively.

     A study of the New Albany area, which presently experiences
water quality problems due to overutilization of septic tanks,
provided a basis for establishing a threshold for maximum
population densities allowable before interceptor construction
should be considered.  New Albany currently has an estimated
population of 600 contained in an area of 400 acres.  Thus, it
was assumed that when other areas with soil suitabilities for
septic tank usage similar to those in New Albany reach a
density of 1.5-2.0 people per acre, the provision of centralized
sewage treatment or interception systems should be examined in
light of the pollution problems encountered.  This density
criterion was used throughout the planning area, as the great
majority of soil associations present are considered to be
marginally suitable, at best, for heavy septic tank and leach-
field usage.
(l)Appendix F provides design tables for each alternative
   investigated.

(2)xaken from "Cost-Effective Analysis, Vol. One", Malcolm
   Pirnie, Inc., 1975.

(3)pRM 77-8, "Funding of Sewage Collection System Projects",
   U.S. EPA, June, 1977.
                            III-9

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     In the sub-areas that are projected to have 2.0 people/acre
or more within the planning period prior to construction of the
recommended intercepting sewers, it will be necessary that local-
ized facilities planning be conducted.  The Village of Minerva
Park, the City of Reynoldsburg, and the Village of New Albany  are
exceptions to this having already established their needs.  The
localized facilities planning will determine the specific needs
for wastewater treatment facilities as well as evaluate alterna-
tive methods of wastewater treatment.   The localized facilities
planning can be conducted by either the City of Columbus or
the appropriate municipality.  During the above additional
localized facilities planning, the Ohio Environmental Protection
Agency's "Procedures for Archaeological and Historic Preserva--
tion" must be followed prior to the design and construction of
any recommended wastewater treatment facilities.

     It should be noted that the sizes of all interceptors,
force mains, and pump stations mentioned in the following
sections are based on half-full flow in the year 2000.  As
detailed design data become available, small changes in
alignment and/or sizing may be necessary.  It should also be
noted that EIS statements as to interceptor sizing over a
given length may ultimately be designed more practically by
starting with a smaller diameter sewer with increases in size
up to or slightly over that specified  in this document.


3.2.2 West Scioto(1)

     The West Scioto subarea will contribute flow to the
Jackson Pike Wastewater Treatment Plant if tied into the
Columbus sewerage system.  For the most part, this area is
presently unsewered.  The exceptions are the Dublin and
Muirfield Village areas to the north which presently have
sewers and plan to tie-in temporarily to the interceptor
constructed along the east side to the Scioto.  The present
population of the total area is estimated to be 13,500 people,
and is expected to increase to 31,800  people by 1985 and to
42,600 by the year 2000.

     (1)  Alternative Description

          There are two gravity sewer  alternatives under con-
     sideration for servicing this area, as shown in Figures
(i)Figures depicting the routes for all subareas which were
   considered in the Columbus Facilities Plan prepared by
   Malcolm Pirnie, Inc. have been reproduced for this
   Environmental Impact Statement with only minor changes.
                          111-10

-------
III-3 and III-4 .   The first, known as the Low Level
Alternative, consists of an interceptor that travels along
the edge of Griggs Reservoir from the existing 72-inch
stub of the Scioto Interceptor to Indian Run Creek near
Dublin.  The interceptor is 33,300 feet long, and ranges
from 36 to 48 inches in diameter.

     The second,  or High Level Alternative,  connects the
same two points as the Low Level option.  It differs from
the Low Level Alternative north of Tudor Ditch.   At this
point, the interceptor crosses over open and residential
area to the intersection of Dublin and Schirtzinger Roads.
From this intersection northward, the interceptor follows
Dublin Road to Rings Road.  After traveling  west on Rings
Road for about one-quarter of a mile, the route turns north
through more open land until finally reaching Indian Run
Creek.  The length of the interceptor in the High Level
Alternative is 33,800 feet, with a diameter  that varies
from 36 to 48 inches.

     A No Action Alternative was not considered viable,
since increasing pollutant loads upon the area's Crosby-
Brookston and Milton-Ritchey-Miamian soil associations
through continued use of septic tank and leach field
systems could result in contamination of Griggs Reservoir,
which is presently used as a potable water supply.

(2)  Primary Impacts

     Short-term primary impacts of the Low Level Alterna-
tive would largely be due to the erosion caused by the close
proximity of interceptor construction to Griggs Reservoir
and the crossing of ten streams or ditches.   Levels of
suspended solids and turbidity can be expected to tempor-
arily increase in these watercourses.  The Low Level
Alternative also traverses 22,700 feet of steep slopes
and 1,600 feet of the James Thomas Park.  Because of the
type of land use close to the Resrvoir, this Alternative
also traverses 21,900 feet of wooded area.

     The long-term effects of the Low Level  Alternative
are associated with the purchase of easements through
private yards and the removal of large trees.  Most of
the interceptor route is within a flood plain, and is
frequently across stream and ditch outlets.   These con-
ditions will require raised manholes along with 5,400
feet of aerial sewer, creating a permanently adverse
aesthetic appearance.
                       III-ll

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                           EXISTING
                           EAST SCIOTO
                           INTERCEPTOR
MALCOLM
    PIRNIE,
        INC
COLUMBUS  METROPOLITAN
          AREA
    FACILITIES   PLAN
    SCIOTO   RIVER
    SERVICE  AREA
LOW   LEVEL  ALTERNATE
FIGURE
 m-3

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                                          EXISTING

                                          EAST SCIOTO

                                          INTERCEPTOR
 MALCOLM
 Tti PIRNIE,
 LJfl    INC.
COLUMBUS  METROPOLITAN

          AREA

    FACILITIES   PLAN
    SCIOTO   RIVER

    SERVICE  AREA

HIGH  LEVEL  ALTERNATE
FIGURE
 m-4
DEFIANCE

-------
     The High Level Alternative, which calls for 16,500
feet of sewer along Dublin Road, would create a short-
term adverse impact by disruption of traffic.  Dublin
Road is used by commuters going to and from the City of
Columbus, and presently has two schools and several
churches and residential areas located along it.  Another
short-term adverse impact is involved in the construction
of the proposed interceptor through 6,400 feet of steep
slopes with 12 stream and ditch crossings.  This alter-
native route also crosses the same 1,600 feet of the
James Thomas Park as that in the Low Level Alternative.

     The main long-term impact resulting from the High
Level Alternative is the 1,300 feet of interceptor which
must be aerial and will create an adverse impact upon
the aesthetics of the area.

     Both alternatives have local short-term adverse
impacts due to construction, such as noise, air quality,
and temporary aesthetic degradation.  Both alternatives
have the beneficial impact of the elimination of most
septic tank systems which could possibly contaminate
ground water if continued and increased usage was permitted,
The High Level Alternative would require most of the homes
on the east side of Dublin Road to tie into the intercep-
tor by pumping, with some continuing to use individual
septic tank systems.  The Low Level Alternative would
collect all sewage flow from this area.

(3)  Phasing

     Figure III-5 shows population densities for the West
Scioto subarea for both High and Low Level Alternatives.
All interceptor sections below Manhole 3 may be needed
by 1980 due to both the densities indicated in the Figure
and the need to protect Griggs Reservoir from possible
contamination.  Additional facilities planning will assess
the situation of the sub-area and determine the need for
the interceptor sections.  Between Manholes 2 and 3, the
density is low, indicating no immediate need for construc-
tion.  The City of Dublin lies above Manhole 2, and cur-
rently pumps sewage over Griggs Reservoir into the East
Scioto Interceptor.

(4)  Costs

     Phasing considerations point toward the cost-
effectiveness on a present worth basis of constructing
a permanent pump station and parallel 12-inch force main
                        111-12

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  6.0
                                            FIGURE m-5
                                      DENSITY TRENDS FOR THE
                                WEST SCIOTO AND BIG RUN SUBAREAS
                           Manholes         Code
                           Beginning to#2     O
                           #2  to  #3       x
                           #3  to  #4       A
                           #4  to  #5       *
                           #5  to  #6       D
               1985
1990
1995
2000
              SCIOTO RIVER  INTERCEPTOR
          (HIGH a LOW LEVEL  ALTERNATIVE)
  6
  5
2 3
o>
Q.
£ 2 0
M
c
o
                           Manholes         Code
                           Beginning to #2     O
                           #2  to  #3        X
                           #3  to  #4        A
                           *4  to  #5        *
                           #5  to  #6        D
               1985
 1990
 1995
2000
                BIG  RUN   INTERCEPTOR

-------
  across Griggs Reservoir, since the interceptor sections
  above Manhole 3 will not be required until after the
  planning period.

       The capital cost of the pumping station and additional
  force main is about $413,000 with an equivalent annual O&M
  cost of $28,800.  This cost is common to both alternatives.
  The remaining capital cost of the Low Level ($2,825,000) is
  associated with the gravity interceptor.  The capital cost
  of the High Level Alternative serving the same area is only
  $2,206,000.  On a present worth basis (including salvage),
  the Low Level Alternative amounts to $3,227,000, a value
  some 20% above the $2,697,000 attributable to the High
  Level Alternative.

  (5)  Summary and Further Considerations

       A summary of West Scioto data and cost results is
  provided in Table III-l.

       The costs and primary impacts for the West Scioto
  area regionalization favor the High Level Alternative.
  Because of the large difference in costs and the less
  serious nature of the associated primary impacts, the High
  Level Alternative is the selected plan for the West Scioto
  area.

       The Environmental Impact Statement for the Delaware
  County area (1) presented a plan which called for the
  upper reaches of the Scioto River basin within Delaware
  County to contribute flow to the City of Columbus' sewer
  system, a plan which would increase the year 2000 popula-
  tion projections by about 15,000 people.  To allow for this
  option without the need to parallel interceptors and
  undergo dual construction impacts, a larger interceptor
  than that proposed for the High Level Alternative would be
  required.  The  increased sizes and costs  for this modifica-
  tion are compared to the original alternative in Table
  III-2.
"Final Environmental Impact Statement, Olentangy Environ-
mental Control Center and Interceptor System", for the
Delaware County, Ohio Board of Commissioners, Prepared by
the U.S. EPA, Region V, July 1976.
                       111-13

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                      Table III-l
    Alternative Summary for the West Scioto Subarea

                                      Alternatives
     Item                      Low Level     High Level

  Length of Sewers (feet)        33,300         33,800

  Type of Land Traversed (feet)
   Woodland                     21,900         12,200
   Open Space (rural)               100          4,600
   Stream Corridor               6,400          4,100
   Steep Slopes                 22,600          6,400
   Parks and Recreation          1,600          1,600
   Reservoir Shoreline          26,900          6,400
   Residential                   3,700          4,300
   Highway Right-of-Way          3,000         16,500

  Stream Crossings                  10             12
  Highway Crossings                  4             24

  Costs (Thousands of Dollars)
   Capital (1980)               $ 3,238        $ 2,619
   Capital (2000)                 1,550          1,421
   Annual O&M (1980-2000)          (1)             (2)
   Present Worth               $ 3,227        $ 2,697
    varies from $24,200 in 1980 to $55,100 in the year
2000.
    varies from $22,600 in 1980 to $53,500 in the year
2000.  Does not include O&M for pumpage of flows from
homes unable to reach the interceptor by gravity.
                        111-14

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                          Table III-2
     Proposed Modification to the High Level Alternative
                  for the West Scioto Subarea
                                   Original             Modified
Length of Sewer (feet)              Size                  size

      7,100                          36"                   42"
      6,600                          36"                   42"
      9,800                          36"                   42"
      3.900                          36"                   42"
      6,400                          48"                   48"

Pumping Station (Peaked Flow)      4.5 mgd               9.0 mgd

Cost  (Thousands of Dollars)

     Capital (1980)                $2,619                 $2,981
     O&M (2000)                     1,421                  2,173,
     Present Worth                  2,697(1)               3,139^
 (!)0&M varies from $22,600 to $53,500 in 1980 to 2000.

 (2)0&M varies from $38,200 to $100,000 in 1980 to 2000,



                          111-15

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          Thus, for an 18 percent ($446,000) increase in present
     worth cost, the option of serving the Scioto River area
     within Delaware County can be maintained.  An annual equiv-
     alent cost of $21 per person per year would result for
     this plan using the present population, a figure which
     reduces to $7 per person per year for the year 2000
     population.  Prior to implementation of the recommended
     alternative, localized facilities planning must be com-
     pleted in the Delaware County, Scioto Basin to determine
     the needs for the planning period.


3.2.3  Big Run

     The 12,900 acre Big Run subarea is located in western
Franklin County, and is comprised of the Hellbranch Run drain-
age basin upstream of U.S. Route 40.  The flow from this area
will be transported to the Jackson Pike WWTP if connection is
made to the City of Columbus' sewer system.  The present popu-
lation is estimated at 1,500, and is expected to increase to
4,600 by 1985 and 10,400 by the year 2000.

     (1)  Alternative Description

          The general soil association within the region is
     the Crosby-Brookston-Lewisburg.  This association is
     characterized by a high seasonal groundwater table and
     low permeability.  These conditions prohibit heavy use
     of septic tank systems, indicating that as population
     increases, sewer service should be provided.  The type
     of soil present does not permit a viable No Action
     Alternative.

          Alternative A calls for areawide regionalization.
     As shown on Figure III-6, this system requires 33,000
     feet of interceptor construction along Hamilton Ditch,
     starting approximately one mile north of the Roberts Road
     crossing and ending with a connection to the existing
     54-inch Big Run Interceptor at Galloway Road.  The pro-
     posed interceptor would vary in diameter from 18 to 27
     inches.  This is the only regionalization alternative
     deemed viable for this area.

     (2)  Primary Impacts

          The alignment of the interceptor will result in
     two stream crossings and five highway crossings.  The
     type of land which will be affected is mainly open or
     grassland.  Adverse short-term impacts may result due
                           111-16

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MALCOLM
    PIRNIE,
       INC.
COLUMBUS  METROPOLITAN

         AREA

   FACILITIES   PLAN
  BIG  RUN       FIGURE

INTERCEPTOR      Dl-6

-------
 to the close proximity of the interceptor route to Big
 Run for some 25,000 feet.  Short-term impacts resulting
 from noise, air pollution, and aesthetics are not judged
 to be severe due to the open space and grasslands which
 will generally separate construction activities from
 heavily populated areas.

 (3)  Phasing

      The population density increases shown on Figure
 III-5 for the Big Run area illustrate that most of the
 interceptor sections should not be built during the
 planning period.  The exception to this is the section
 between manholes 4 and 5, which may be needed by 1995.

 (4)  Costs

      The capital cost of Alternative A is $2,200,000,
 with an associated annual O&M cost of $2,500  (between
 1995 and 2000).  These values, along with salvage and
 phasing considerations, represent a present worth of
 only $140,000.

 (5)  Summary

      Table III-3 provides a summary of alternative data
 and costs for the Big Run subarea.

                      Table III-3
    Alternative Summary for the Big Run Subarea(1)

           I tern

 Length of Sewers (feet)                     33,000

 Type of Land Traversed (feet)
  Open Space (rural)                         33,000
  Stream Corridor                            25,000
  Residential                                  0

 Stream Crossings                              2
 Highway Crossings                             5

 Costs (Thousands of Dollars)(!)
  Capital (1995)                            $ 1,008
          (2000)                            $ 1,192
  Annual O&M (1995-2000)                          3
  Present Worth                             $   140

Does not include the individual treatment unit costs
necessary under a phased construction plan.


                      111-17

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          Population projections point toward a fairly heavy
     growth in areas surrounding Interstate 70 close to the
     City of Columbus.  A more detailed analysis of this area
     suggests that sewer service may be needed by 1985.  There-
     fore, a modification to the Big Run alternative proposed
     in the Facilities Plan is recommended.

          This modification entails providing sewer service
     to a 1,350 acre area with a population projected to be
     4,100 by the year 2000.  This area can be served by two
     trunk sewers tying into the existing Columbus system,
     one along Feder Road and one along Renner Road, in order
     to serve areas south and north of 1-70, respectively.
     The primary impacts of these trunk sewers are minor,
     since they travel along .highway right-of-ways or through
     open farmland and lightly residential areas.  The total
     capital cost for the construction of 7,200 feet of 18-
     inch diameter sewer along Renner Road and 7,900 feet of
     15-inch diameter sewer along Feder Road is about $770,000,
     It should be noted that these sewers can only serve the
     two areas described, and cannot be extended, using a
     gravity system, any further west within the Big Run
     subarea.  This modification results in an annual cost
     of $17 per person per year, for the year 2000 popula-
     tions.  Figure III-6 has included the routes of these
     proposed extensions.

          Prior to implementation of the recommended alterna-
     tive, localized facilities planning must be completed
     to determine the needs of this segment of the Big Run
     subarea.
3.2.4  Minerva Park

     The Minerva Park subarea is located in the north-central
portion of Franklin County.  Wastewater treatment is presently
provided by the Columbus Southerly WWTP for the areas to the
north, south, and west of Minerva Park.  The Alum Creek Inter-
ceptor forms the eastern boundary.  Minerva Park's present
wastewater treatment plant, which discharges to Minerva Lake
Creek, is a 0.17 mgd extended aeration facility.  The present
estimated population is 1,500 people.  The projected popula-
tions for this area by the years 1985 and 2000 are 3,400 and
3,500 respectively.
                          111-18

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(1)  Alternative Description

     Two alternatives were considered for serving the
Minerva Park subarea.  The Interceptor Alternative shown
in Figure III-7 is one in which an interceptor would be
constructed from the Minerva Park WWTP in an easterly
direction to a point on the 72-inch portion of the existing
Alum Creek Interceptor.  The flow would be treated at the
Southerly WWTP.  The proposed interceptor will be about
3,900 feet long, and will vary from 12 to 15 inches in
diameter.  An extension will continue upstream of Minerva
Lake Creek with approximately 900 feet of 12-inch sewer.
A 20-foot permanent right-of-way has been purchased and
the design of the interceptor has been completed as per
the recommendations of the Facilities Plan.  Plans have
progressed to such an extent that a portion of the inter-
ceptor crossing Westerville Road has already been installed
as part of a highway reconstruction project.

     The second, or Plant Alternative, proposes expansion
and improvement of the existing treatment plant.  By the
year 2000, a 0.6 mgd plant will be necessary.  Required
additions will be built adjacent to the old plant on land
presently used for farming.  Effluent requirements for a
0.6 mgd plant at this location will probably be quite
stringent.  Costs summarized at the end of this section
have assumed design release levels of 8 mg/1 8005, 8 mg/1
SS, 1.0 mg/1 ammonia nitrogen (summer), and a minimum of
5.0 mg/1 of dissolved oxygen at all times.  Due to the
large population increase projected by 1985, the plant
should be built by 1980 with full capacity installed for
the wastewater flow in the year 2000.

     It has been reported that the effluent from the WWTP
adds nutrients to and depletes oxygen from the relatively
small flow in Minerva Lake Creek.  .It was estimated that
the present flow from the WWTP is about one-third of the
creek's dry weather flow.  These existing conditions do not
permit consideration of a No Action Alternative.

(2)  Primary Impacts

     The short-term impacts due to construction of the
Interceptor Alternative would be the degradation of surface
water quality from increases in turbidity due to construc-
tion activities along 4,200 feet of stream banks and at
three stream crossings.  Aquatic biology would be hampered
by the increase in turbidity and by the area destruction
caused by work activities in or near the stream.  Woody
                       111-19

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   SCALE IN FEET
0   1000  2000 3000
MALCOLM
    PIRNIE,
       INC.
          COLUMBUS METROPOLITAN

                   AREA

              FACILITIES   PLAN
MINERVA  PARK

  INTERCEPTOR
  ALTERNATE
FIGURE

 ffl-7

-------
vegetation is sparse along the proposed route, thereby
minimizing the effect of any removal required.  The inter-
ceptor mainly traverses open fields and farmland, with no
structures occurring along the proposed route.  This
situation will reduce adverse noise, aesthetic, and air
quality impacts.  Traffic disruption and public inconveni-
ence is expected to be minimal, since no nouses occur along
the route and only one road, which already has a portion of
the interceptor constructed beneath it, would be crossed.
A short section of proposed interceptor will pass beneath
railroad tracks.  The 900-foot branch in the Interceptor
Alternative requires some 350 feet of construction through
steep slopes, a situation which will cause adverse short-
term impacts.

     Long-term beneficial impacts will mainly be found in
the improvement of water quality in the Minerva Lake Creek
due to the elimination of the Minerva Creek Plant.  The
elimination of the plant will have further beneficial
impacts by improving local aesthetics, decreasing manpower
costs, energy commitment, and land requirements.

     Long-term adverse impacts resulting from retention
of the treatment plant are the commitment of more manpower,
energy, and land due to the needed expansion by 1980.  The
retention of the WWTP close to growing residential communi-
ties could increase impacts from odor, noise and aesthetics,

(3)  Phasing

     Phasing through the use of projected densities was
not necessary for this subarea since the combination of the
large population growth expected by 1985 and the probable
stringent permit release levels for a WWTP in the area
require interceptor or treatment plant construction by
1980.

(4)  Costs

     The capital cost for the Interceptor Alternative is
$380,000, with an associated annual operation and main-
tenance cost of $1,000.  For a true comparison, the O&M
should include the cost of treating the 0.6 mgd from the
Minerva Park area at the Columbus Southerly plant.  When
this consideration is included, (along with salvage value)
a total present worth for the Interceptor Alternative of
$542,000 is derived.
                       111-20

-------
          The capital cost for the Plant Alternative (excluding
     land costs)  is estimated to be $2,070,000.  The costs for
     operation and maintenance of the proposed 0.6 mgd plant are
     estimated as approximately $400/mg.  Total present worth of
     the Plant Alternative is then $2,325,000, assuming construc-
     tion takes place by 1980.

     (5)  Summary

          A tabular summary of data and costs for Minerva Park
     is provided in Table III-4.  The selected plan for this
     subarea is the Interceptor Alternative.  This selection was
     made primarily to minimize the long term impacts associated
     with operating and maintaining a local treatment plant and
     because of the large difference in capital and O&M costs
     between the Plant and interceptor Alternatives.  Construc-
     tion impacts of the Interceptor Alternative may be somewhat
     severe, but they will be short-term and will occur only
     once.  A cost of $32 per person per year results using
     present population, whereas using the year 2000 population
     results in a cost of $14 per person per year for the
     Interceptor Alternative.

          Localized facilities planning need not be completed
     prior to implementation of this alternative since the needs
     have been adequately identified and evaluated.


3.2.5  Big Walnut Creek, Rocky Fork, Blacklick Creek

     The three individual subareas (Big Walnut Creek, Rocky Fork,
Blacklick Creek)  that are described in the following sections
must be taken as a single unit in any regionalization alternative
analysis.  Three possible regionalization systems, designated as
A, B and C,  were proposed in the Columbus Facilities Plan.  These
will be reviewed in the following paragraphs along with another
alternative (D) which proposes only partial regionalization of
the three subareas during the planning period.  Figures III-8
through 12 show the routes of the five alternatives investigated.

     (1)  Alternative Description

          1.   Big Walnut Creek

               The Big Walnut Creek subarea is located in north-
          eastern Franklin County and southeastern Delaware
          County.  This area presently has an estimated popula-
          tion of 6,000.  The population is expected to increase
                          111-21

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                    Table III-4
   Alternative Summary for Minerva Park Subarea

                                 Alternatives
       Item               Interceptor     Plant

Length of Sewers (feet)       4,800          0

Type of Land Traversed (feet)
 Woodland                     1,500          0
 Open Space (rural)           3,300          0
 Stream Corridor              4,200          0
 Steep Slopes                   350          0
 Agricultural                   0          5 acres

Stream Crossings                3            0
Highway Crossings            Already Constructed

Costs (Thousands of Dollars)
 Capital (1980)              $  380       $ 2,070
 Annual O&M                     (1)          (2)
 Present Worth               $  542       $ 2,325
        varies from $24,300/year in 1980 to
    $32,300/year in 2000.
 (2)
 v 'O&M varies from $32,300/year in 1980 to
    $51,100/year in 2000.
                     111-22

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                       •(ROCKY FORK
                       I INTERCEPTOF
 MALCOLM
      PIRNIE,
         INC
COLUMBUS  METROPOLITAN

          AREA

    FACILITIES    PLAN
BIG   WALNUT  CREEK
  SERVICE  AREA

   ALTERNATE A
FIGURE
 m-8
DEFIANCE

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                      I ROCKY FORK
                       INTERCEPTOR
MALCOLM
    PIRNIE,
       INC.
COLUMBUS  METROPOLITAN

          AREA

    FACILITIES    PLAN
BIG  WALNUT  CREEK

   SERVICE  AREA

   ALTERNATE  B
FIGURE
 m-9

-------
 MALCOLM
     PIRNIE,
        INC.
COLUMBUS  METROPOLITAN
         AREA
   FACILITIES   PLAN
BIG  WALNUT CREEK
  SERVICE  AREA
   ALTERNATE C
FIGURE
 m-io
DEFIANCE

-------
 MALCOLM
     PIRNIE,
        INC
COLUMBUS  METROPOLITAN

         AREA

   FACILITIES   PLAN
BIG  WALNUT  CREEK

  SERVICE AREA
   ALTERNATE  D
FIGURE
DEFIANCE

-------
MALCOLM
7KI PIRNIE,
Jfl    INC.
COLUMBUS  METROPOLITAN

         AREA

   FACILITIES   PLAN
BIG  WALNUT CREEK

  SERVICE  AREA
 ALTERNATE SUB B
FIGURE
 DI-12

-------
to almost 14,100 by 1985 and 21,300 by the year 2000.
If regionalized into the Columbus sewerage system,
flow from this subarea will be treated at the Southerly
WWTP.

     One of the major concerns within the Walnut Creek
area is the protection of Hoover Reservoir, which is
used as a potable water supply.  If population growth
is as predicted, heavy use of septic tanks and leach-
fields will occur if sewers are not provided.  The
local soils are mainly of the Bennington-Pewamo
Association, and are unacceptable for septic tank
systems.

     Alternatives A and D would involve the construc-
tion of a 36-inch interceptor over 28,000 feet.  The
proposed interceptor route parallels the eastern edge
of Hoover Reservoir and Walnut Creek.  Service would
be instituted from the existing 84-inch interceptor at
State Route 161 northward to the Lake of the Woods
area.

     Alternative B envisions an interceptor which
begins at Duncan Run and follows Rocky Fork to Central
College Road.  The interceptor route then runs west-
ward to Walnut Creek where it turns to the south to
ultimately connect to an existing 84-inch interceptor,
which transports the flow to the Southerly WWTP.  The
proposed interceptor varies in size from 18 to 36
inches over a length of 40,000 feet.

     Alternative C will involve the construction of
an interceptor which is the same length and follows
the same route as that in Alternative A but which
would serve a smaller area.  Due to this decrease in
service area, the diameter of the proposed interceptor
is reduced, and will vary from 30 to 36 inches.  In
this Alternative, some of the subarea will be served
by an extended Rocky Fork Interceptor, as discussed
in the next section.

2.   Rocky Fork

     The Rocky Fork subarea is located in the north-
eastern portion of Franklin County, encompassing some
11,400 acres.  The present population for this sub-
area is about 4,300 people, and is expected to
increase to 9,100 by 1985 and to 17,800 by the
year 2000.
                  111-23

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     At the present time, the surface waters in and
around the Village of New Albany are heavily polluted
during low flows.  Specifically, Rose Run,  Sugar Run,
and Rocky Fork are heavily impacted by point and non-
point releases from individual septic tanks and leach-
fields.  This situation again eliminates consideration
of a No Action Alternative.

     Alternative A consists  of an interceptor running
parallel to Rocky Fork for some 33,700 feet.  The
diameter of this proposed interceptor varies from
24 to 36 inches.  Service will be provided  to the
Rocky Fork drainage area from just south of Granville
Road to the Village of Gahanna, which presently is
included in the City of Columbus' sewer system.  The
proposed Rocky Fork Interceptor will tie into the
existing 84-inch Walnut Creek Interceptor near the
confluence of Walnut Creek and Rocky Fork.

     Alternative B consists  of an interceptor which
varies in diameter from 24 to 36 inches as  it traverses
some 36,800 feet along Rocky Fork to a point just
north of Havens Corners Road.  The route then turns
southeast running across country until reaching the
proposed 36-inch Blacklick Creek Interceptor.  The
point of connection to the Blacklick Creek  Interceptor
is approximately one-quarter mile south of  the inter-
section of Taylor and Reynoldsburg-New Albany Roads.

     Alternative C for the Rocky Fork subarea consists
of an interceptor 46,100 feet long which varies in
diameter from 18 to 36 inches.  This proposed inter-
ceptor would begin near the  Rocky Fork, approximately
one-quarter mile south of the Franklin-Delaware County
line.  The route would parallel Rocky Fork  on the
eastern side until reaching  the same location north
of Havens Corners Road proposed in Alternative B.
The Alternative B route is followed from this point
on to the proposed 36-inch Blacklick Creek  Interceptor.

     Alternative D utilizes  8,000 feet of 8-inch
force-main and 10,500 feet of 12-inch gravity sewer.
This sewerage system is designed to collect flows
only from the New Albany area and transport them to
the existing Big Walnut Creek Interceptor.   The
remainder of the Rocky Fork  area will not be included
in a regional system until at least 1995.
                  111-24

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     The cost of building a treatment plant in the
New Albany area was also investigated using a base
population of approximately 20,000 people, and is
summarized in Table III-5 along with the pump station
and force main costs involved in Alternative D.  The
pump station-force main system is shown to be half
as expensive as the treatment plant option.

     A modification to the lower section of the
interceptor proposed for the Walnut Creek subarea
may be necessary.  The portion of this unit which
is in Delaware County will be included in a Facili-
ties Plan to be undertaken shortly by entities
within Delaware County.  It is suggested that the
final design size for this interceptor be deter-
mined by the Facilities Plan.

     During the comment period, the City of Columbus
expressed concern of the Draft EIS's Alternative D
for the Rocky Fork Basin for not utilizing a section
of sewer already constructed below Morse Road.  The
Final EIS considered the City's proposed alternative
as shown in Figure 111-13.  The alternative would
utilize the existing 15 to 21-inch sewer with an
extension of approximately 1,000 feet of 12-inch
gravity sewer connecting to an 8,000 foot 8-inch force
main.  The pump station would be located near the
intersection of Route 62 and Morse Road.  An 18-inch
interceptor follows Route 62 northward into the
Village of New Albany comprising an estimated length
of 12,000 feet.

     A table comparing sizes, lengths, and costs of
the original Alternative D for the Rocky Fork area
and the alternative proposed by the City for ser-
vicing the same area is presented in Table III-6.

     As shown by the table, the original Alternative
D for the Rocky Fork area is some 14% less expensive
than the alternative proposed by the City.

     The primary impacts associated with each alter-
native are relatively small in difference, in that
they both utilize a pump station and 8,000 feet
of force main.  The City's alternative, however,
is some 6,000 feet shorter when everything is con-
structed .
                111-25

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                     Table III-5
        Treatment Plant Costs vs.  Pump Station
             Costs in the New Albany Area
                         Treatment Plant   Pump Station

Capital Cost
 Treatment Plant           $2,070,000
 Pump Station                   -            $  170,000
 Interceptor                    -               710,000

   Total                   $2,070,000        $  880,000

Present Worth
 Treatment Plant
   (capital)               $1,810,000
   (O&M)                   $  990,000
 Pump Station (capital)          -            $  170,000
              (O&M)              -               110,000
 Interceptor  (capital)          -               590,000
              (O&M)              -                20,000
 Southerly Treatment
  Plant (O&M)                   -               420,000

   Total                   $2,800,000        $1,310,000
                          111-26

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MALCOLM
    PIRNIE,
       INC.
COLUMBUS  METROPOLITAN

         AREA

   FACILITIES   PLAN
BIG  WALNUT  CREEK    FIGURE

  SERVICE AREA       m-13
   ALTERNATE D-H

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                         Table III-6
          City vs. Draft EIS Rocky Fork Alternative
Proposed City Alternative
Facilities

Pump Station
1-8-inch Force Main
1-12-inch Interceptor
1-18-inch Interceptor
New Construction(l)
  Time
 of Con-
struction

   1980
   1980
   1980
   1980
   1980
     TOTAL

     PRESENT WORTH = $1,465,000
Length
 (ft)
 8,000
 1,000
12,000
25,200(2)

46,200
 Construc-
 tion Cost

  $105,000
   156,000
    75,000
   508,000
   660,000

$3,504,000
($/yr)

26,500
   400
   200
 1,300
 6,700
Original Draft EIS Alternative
Facilities

Pump Station
1-8-inch Force Main
1-12-inch Interceptor
New Construction^9)
  Time
 of Con-
struction

   1980
   1980
   1980
   1980
     TOTAL

     PRESENT WORTH = $1,290,000
Length
 (ft)
 8,000
10,500
33,700

52,200
 Construc-
 tion Cost

  $105,000
   156,000
   480,000
 3,360,000

$4,101,000
($/yr)

26,500
   400
 1,200
 8,400
(1) New Construction is gravity sewer as proposed in Alterna-
    tive A for the Rocky Fork area.

(2) Sections 1-2 and 2-3 of the sewer proposed under the original
    Alternative D are not considered to be necessary since a nearby
    gravity section was already constructed in 1980.
                          111-27

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     The secondary impacts are also considered to be
similar except that the City's alternative constructs
more length of gravity sewer at an earlier period in
time, possibly inducing earlier growth into the area.

     Therefore, the alternative for the Rocky Fork
area as proposed by the City was disregarded from
further consideration.  This was determined on the
basis that the impacts were considered to be similar
and the costs favored the original Alternative D as
proposed in the Draft EIS.

3.   Blacklick Creek

     The proposed Blacklick Creek Interceptor will
extend 47,700 feet from just south of the Penn
Central Railroad Bridge crossing of Blacklick Creek
to Brice Road where it will connect to an existing
96-inch interceptor.  This length and route are the
same for all alternatives.  The only difference
between alternatives is in the proposed pipe size
due to the varying wastewater flows intercepted
from the areas to the north of the Blacklick Creek
subarea.  The Blacklick Creek Interceptor route in
all but Alternative D includes approximately 4,600
feet of spur line which will continue upstream along
Blacklick Creek.  Service will be provided by this
spur line to a relatively small area on the east
side of the Creek.

     Alternative D calls for 11,100 feet of 24-inch
gravity sewer and 5,700 feet of a 16-inch force main.
This system is designed to collect the sanitary flow
from the Reynoldsburg area and transport it to the
existing Big Walnut Creek Interceptor by way of
Route 256 and Livingston Avenue.  The remainder of
the Blacklick Creek area is to be served by indi-
vidual treatment units.  Interceptor construction
will be necessary by 1990 for sections #3 to #5,
as shown on Figure III-8 in Alt. A.

     The present population within the subarea is
estimated at 27,700.  This is projected to increase
to 30,300 by 1985 and 36,200 by the year 2000.  The
major center of population is the City of Reynolds-
burg, which is presently served by an overloaded
contact stabilization treatment facility.  Since
                   111-28

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      expansion of this plant is site-limited and its
      continued operation unattractive economically(1),
      all alternatives considered have included Reynolds-
      burg's flow in the Blacklick Creek Interceptor.

      Table III-7 lists the different interceptor lengths
 and sizes for each alternative for the Big Walnut, Rocky
 Fork and Blacklick Creek subareas.  Also provided in this
 table is the proposed construction date for each system.

      The lower section of the Big Walnut Creek interceptor
 will be required by 1980, since most of the future growth
 is projected to occur in this area.  The remaining section
 or sections for all the Big Walnut Creek alternatives will
 be constructed up to twenty years later.

      Due to the need for providing sewer service to the
 New Albany area, all alternatives call for providing sewer
 service to New Albany.  The 18-inch line proposed in the
 Facilities Plan for Alternative C was found to not be
 required during the planning period.  Populations in the
 lower portion of the subarea are not projected to increase
 rapidly, and early construction of an interceptor may cause
 secondary growth impacts.  Therefore, a cost comparison
 is presented later in Table III-8  (as Sub-alternative B)
 to determine whether an interceptor should be built
 through this area by 1980 or if service to the upper
 portion of the subarea should be provided by means of a
 12-inch force main.  The force main would be constructed
 from the proposed interceptor westward along Morse Road
 to an existing 15-inch sewer.  The pump station and
 force main would be constructed immediately, and would
 remain in service until the capacity of the existing
 15-inch sewer is reached.  At such a time (assumed to
 be 1985 in this analysis), the remaining 28,300 feet of
 36-inch interceptor will be constructed.

 (2)  Primary Impacts

      1.   Big Walnut Creek

           The Big Walnut Creek subarea will suffer the
      same environmental impacts with Alternative A, C,
      or D.  The short-term primary impacts are traffic
Blacklick Creek Area Mini-Facilities Plan, Columbus
Metropolitan Area Facilities Plan by Malcolm Pirnie, Inc
Page 46.
                       111-29

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                         Table III-7
   Interceptor Lengths and Sizes for the Big Walnut Creek,
           Rocky Fork, and Blacklick Creek Subareas
       Subarea

Alternative A
 Big Walnut Creek
 Rocky Fork
 Blacklick Creek
Alternative B
 Big Walnut Creek
 Rocky Fork
 Blacklick Creek
Subalternative B
  Rocky Fork
                 (1)
Length
(feet)
                             19,000
                              9,000
                             28,000
                              3,500
                              5,000
                             25,200
                             33,700
                              7,700
                              5,000
                             35,000
                             47,700
                              3,000
                             30,000
                              7,000
                             40,000
                              3,500
                              5,000
                             28,300
                             36,800
                             47,700
                               3,500
                               5,000
                               6,200
                              28,300
                              43,000
  Size
(inches)
             36
             36
             24
             27
             36
             21
             27
             36
             18
             27
             36
             24
             27
             36
4,600
3,100
11,000
29,000
18
30
36
42
Construction
    Date
   (Year)
              2000
              1985
              1980
              1980
              1980
              2000
              2000
              1980
             24
             27
             12 F.M.
             36
              2000
              2000
              1985
              1980
              1980
              1980
                                                      2000
                                                      1980
                                                      1980
                                                      1980
              1980
              1980
              1980
              1985
                           111-30

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                Table III-7 - Continued
   Interceptor Lengths and Sizes for the Big Walnut Creek,
           Rocky Fork and Blacklick Creek Subareas
        Subarea

Alternative C
 Big Walnut Creek
  Rocky Fork
  Blacklick Creek
(1)
Length
(feet)
                             19,000
                              9,000
                             28,000
                             19,300
                              8,500
                             28,300
                             56,100
                              4,600
                              3,100
                              5,000
                             16,000
                             19,000
                             47,700
                             19,000
                              9,000
                             28,000
                              8,000
                             10,500
                              3,500
                              5,000
                             25,200
                             52,200
                              9,600
                             11,200
                              7,700
                              5,000
                             35,000
                             64,500
   These values replace those in Alternative B for Rocky
   Fork
   P.M. = Force Main
Alternative D
  Big Walnut Creek
  Rocky Fork
  Blacklick Creek
Construction
Size Date
(inches) (Year)
30
36
18
27
36
18
30
36
42
42
36
36
8 FM
12
24
27
36
16 FM
18
21
27
36
2000
1985
2000
1980
1980
2000
1980
1980
1980
1980
2000
1985
1980
1980
1995
1995
1995
1980
1980
2000
2000
2000
                           111-31

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disruption and the effects of construction in residen-
tial areas.  The proposed route will traverse several
thousand feet of steep slopes and wooded areas which
may cause both short- and long-term adverse impacts.
Due to construction near streams and Hoover Reservoir,
including three major stream crossings, temporarily
severe erosion and siltation of these waters may
result.  Another long-term adverse aesthetic impact
of these alternatives will be caused by the need for
approximately 500 feet of aerial sewer in order to
cross a ravine south of the Lake of the Woods area.

     Alternative B for Big Walnut retains the lower
portion of the interceptor proposed in Alternatives
A and C.  This 7,000 foot length includes the steep
slopes and wooded area mentioned above.  Above this
portion, the interceptor route is along Central
College Road, parallel to the western side of Rocky
Fork.  This area is mainly open grassy or cultivated
land, with most wooded areas occurring within 20 to
50 feet of the stream.

     The long-term benefit derived in all alterna-
tives will be the protection of surface and ground
water quality from degradation caused by continued use
of inadequate individual and centralized wastewater
treatment systems.

2.   Rocky Fork

     Short-term impacts to the Rocky Fork subarea in
Alternative A are primarily due to erosion and tur-
bidity caused by the close proximity of construction
to the stream and the several creek crossings required,
including one across Walnut Creek.  Destruction of
trees and vegetation will occur at stream crossings,
through a wooded area south of Morse Road, and in an
area above Sugar Run.  Most of the remaining land
traversed is agricultural, with residential areas
disturbed only within the City of Gahanna.  Traffic
disruption is expected to occur since the interceptor
route crosses several roadways.  A public park, which
consists mostly of cleared grassland, is along the
route of the Rocky Fork interceptor in Alternative A.
The interceptor would also cross through a few areas
near Rocky Fork which have steep slopes.
                   111-32

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     The long-term beneficial impact of all alter-
natives for the Rocky Fork subarea is the central
collection of sewage, thereby avoiding use of indi-
vidual disposal systems which release to the generally
nonreceptive area soils.  (The septic tank and leach-
field systems presently in use around New Albany are
reported to already contribute to surface water
pollution.)

     In Alternative B, the Rocky Fork subarea is to
be served by extending the interceptor to the proposed
36-inch Blacklick Interceptor.  This new section
eliminates Alternative A route problems such as the
crossing of Walnut Creek, most of the affected resi-
dential area, and the park.   The bulk of the different
construction route for Alternative B is through
agrarian areas.

     The primary impacts associated with the construc-
tion of the pump station and force main required for
Subalternative B focus on the commitment of energy,
materials, and manpower required for construction
that will be phased out fairly early in the planning
period.  The force main will "be constructed along
S.R. 161, and will cause some minor traffic disrup-
tion.  The construction of this 6,200 feet of 12-inch
main will add two more road  crossings and three more
stream crossings.  The main  reason for acceptance of
this section of the alternative is the delayed con-
struction of some 28,300 feet of 36-inch interceptor
in the southern portion of the Rocky Fork subarea.

     Alternative C for the Rocky Fork area is an
extension of Alternative B.   The basic route is the
same, but instead of ending  below Sate Route 161, the
interceptor continues northward to approximately one-
quarter mile of the Franklin-Delaware County line.
Primary environmental impacts will be the same as
with Alternative B, with the addition of four highway
crossings, two pipeline crossings, and the construc-
tion of some 19,300 feet of  interceptor through open
and cultivated areas.

     The major primary impacts associated with
Alternative D  (apart from the ongoing localized
impacts from construction of individual treatment
systems) are caused by construction of the 18,500
feet of sewer and force main for the interception
                  111-33

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       of the New Albany waste flow.  The force main (8,000')
       is completely within highway right-of-ways near open
       farmland and lightly residential areas, a situation
       which will cause some traffic disruption.  The route
       is through some 900 feet of wooded area and 600 feet
       of steep slopes.  The route involves three stream
       crossings and four highway crossings.  Erosion could
       result from construction at the stream crossings.
       Final construction in 1995 will result in the same
       impacts as those noted for similar sections proposed
       in Alternative A.

       3.   Blacklick Creek

            The primary impacts to the Blacklick Creek sub-
       area are the same for Alternatives A, B, and C, since
       only the sewer size varies.  The proposed interceptor
       route would cross the eastern side of Blacklick Woods
       Metropolitan Park.  The Park contains a 55 acre State
       Nature Preserve, which should be protected from any
       construction damage.  The proposed interceptor route
       through the Park is about a quarter mile from the
       Nature Preserve, but care should be taken during
       construction so as not to disturb the Preserve in any
       way.  Contact and permission must also be obtained
       from the proper agencies in regards to crossing the
       Blacklick Metropolitan Park.

            In a letter from ODNR^), the Park was identi-
       fied as having been developed with Land and Water
       Conservation Fund Act money.  This funding restricts
       the future use of the Land under Section 6(f) of the
       Act.  It has been established by ODNR that:  "Granting
       control or partial control of land within the Park for
       a sewer line would constitute a Section 6(f)  conflict.
       Any requrest for a conversion of land use must first
       be submitted by the Park District to this Department
       (ODNR) for review and approval.  The conversion request
       must also be reviewed by the Heritage Conservation &
       Recreation Service and meet the prerequisite for
       approval of a Section 6(f) conversion request before
       final approval by the Secretary of the Interior."
       Additional facilities planning is required to address
       the Section 6(f) conflict and to evaluate gravity
       sewer and force main alternatives which bypass the
       Park.
(1)   See attachments to this Appendix.

                        111-34

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     The principal long-term beneficial impact of the three
alternatives is in the improvement of water quality in
Blacklick Creek which will result from the elimination of
the Reynoldsburg WWTP and several other inadequate smaller
treatment plants.

     During the planning period, Alternative D collects
flow only from the Reynoldsburg area through a 20,200
foot gravity sewer and force main system.   The route
crosses Blacklick and Big Walnut Creeks once each along
with 17 highway crossings (including Interstate 270).
The type of land traversed is mainly residential with
the exception of 800 feet of open grassy areas which have
about 400 feet of steep slopes.  The route will be entirely
within the highway right-of-way.  Primary impacts expected
are due to the short-term surface water quality degrada-
tion from construction activities beneath or near the
two creeks, the possible erosion caused by construction
on steep slopes, and traffic disruption, primarily on
Livingston Avenue.  The construction of Sections #3 and
#5 shown on Figure III-8 should begin in 1990, and the
impacts noted for Alternative A will again be applicable.

(3)  Phasing

     1.   Big Walnut Creek

          Figure 111-14 illustrates the population densi-
     ties for the Big Walnut Creek alternatives.  In all
     cases, the projected population densities (apart from
     the section just below the Hoover Reservoir) are below
     1.0 person/acre during the planning period.  The sec-
     tion below the Reservoir may require construction by
     1985 if the population growth occurs as predicted.

     2.   Rocky Fork

          Figure 111-15 indicates that no interceptors for
     this subarea should be constructed until 1995, with
     the far upstream sections of each probably not required
     during the planning period.  However, Alternatives A,
     B, and C must have all sections from manhole 2 to the
     connection with the existing interceptor constructed
     by 1980 due to the immediate need of transporting
     sewage away from the New Albany Area.  The provision
     of the force main in Alternative D delays the need for
     interceptor construction below New Albany until 1995.
                       111-35

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   6.0
                                           FIGURE m-ti-
                                       DENSITY TRENDS  FOR THE
                                        BIG WALNUT SUBAREA
                                                   Manholes
                                                   Beginning to#2
                                                   #2  to  #3
                                          Code
                                            O
                                            X
               1985
1990
1995
2000
      BIG WALNUT  INTERCEPTOR   (ALTERNATIVES A a C)
  6.0
 § 5.0
S. 4.0
o
n 3 o
0
Q
  1.0
                          Manholes         Code
                          Beginning to #2     O
                          #2  to  #3        X
                          #3  to  #4        £
               1985       1990       1995      2000

      BIG WALNUT INTERCEPTOR    (ALTERNATE B)

-------
                                          FIGURE  ffl-15
  6.0
  5.0
 _ 4.
 £
  2
^^ ™ '
>
                                    DENSITY  TRENDS  FOR THE
                                      ROCKY  FORK  SUBAREA
                          Manholes        Code
                          Beginning to #2      O
                          #2  to  #3        X
                          #3  to  #4        A
              1985
1990
1995
2000
    ROCKY  FORK  INTERCEPTOR  ( ALTERNATIVES A 8 B)
  6.0
§ 5.0
a. 4.0
w
c
o
Sao
a.
£20
c
e
                         Manholes        Code
                         Beginning to #2    O
                         #2  to  #3       X
                         #3  to  #4       A
                         #4  to  #5       *
               1985
 1990
 1995
2000
       ROCKY  FORK  INTERCEPTOR   (ALTERNATE C)

-------
     3.   Blacklick Creek

          Figure 111-16 illustrates that the only portion
     of the Blacklick Creek Interceptor which must be
     built immediately is that which collects and trans-
     ports the waste flow from the Reynoldsburg area to
     the Southerly treatment plant.  Additional facilities
     planning to address the Section 6(f)  conflict and to
     evaluate force main and gravity sewer alternatives in
     the Blacklick Creek subarea is required before a final
     decision can be made.

(4)  Costs

     The costs presented in Table III-8 show the total
capital costs for each subarea alternative broken into the
proper time frame.

     Table III-8 shows that Alternative A, at $15,710,000
has the lowest capital cost; while Alternative D has the
highest, $19,510,000.  The cost of the force main variation
of Alternative B is higher than the nonforce main Alterna-
tive by $320,000.  This is due to an increase of $170,000
for the force main construction and $150,000 for the con-
struction of a prefabricated pumping station with an assumed
life of 20 years.  However, it should be noted that this
cost difference is reversed on a present worth basis due
to the delaying of portions of the interceptor construction.

(5)  Summary

     Table III-9 provides a summary of each alternative
in regards to primary impacts and cost.

     Alternative D is shown to be the most cost-effective
on a present worth basis, followed by Alternative A, which
is 28 percent higher.  Since Alternatives B, Sub. B, and C
are all much greater in present worth than Alternative D,
they were considered as not cost-effective.  Alternatives
A and D both provide service to the Big Walnut Creek,
Rocky Fork, and Blacklick Creek areas by independent sewer
systems.  In other words, the cost-effective alternative
will involve service to each basin separately (something
Alternatives B, Sub B and C cannot do).  For this reason,
a detailed present worth cost analysis was performed for
Alternatives A and D for each individual service area as
follows:
                     111-36

-------
  6
                  FIGURE  HI-16
              DENSITY TRENDS FOR  THE
                 BLACKLICK SUBAREA
                           Manholes         Code
                           Beginning to#2     O
                           #2  to  #3        X
                           #3  to  #4        A
                           #4  to  #5        it
               1985
1990
1995
2000
    BLACKLICK   INTERCEPTOR   (ALTERNATIVES  A8C)
  6.0
5 5.0
  4.0
o
0.
  3 0
*2 0
                          Manholes         Code
                          Beginning to #3     O
                          #3  to  #4        X
                              to  #5        A
               1985
 1990
 1995
2000
      BLACKLICK  INTERCEPTOR  ( ALTERNATE  B)

-------
                       Table III-8
      Interceptor Costs for the Big Walnut Creek,
       Rocky Fork, and Blacklick Creek Subareas
    Subarea

Alternative A
  Big Walnut Creek
  Rocky Fork
  Blacklick Creek

    TOTAL

Alternative B
  Big Walnut Creek
  Rocky Fork
  Blacklick Creek

    TOTAL

Subalternative B
  Big Walnut Creek
  Rocky Fork
  Blacklick Creek

    TOTAL

Alternative C
  Big Walnut Creek
  Rocky Fork
  Blacklick Creek

    TOTAL

Alternative D
  Big Walnut Creek
  Rocky Fork
  Blacklick Creek
    TOTAL
                            Construction Costs, $1,000
1980
$
3
4
$8
$
4
6
$10
$

4,
$5,
$
4
5
$ 9
$
2
0
,360
,920
,280
0
,280
,160
,440
0
970
720
690
0
,350
,140
,490
740(1)
,660
1985
$1,
$1,
$1,


$1,
$1,
3,
1,
$6,
$1,


$1,
$1,
3,
4,
720
0
0
720
330
0
0
330
330
630
440
400
720
0
0
720
720(2)
360 ii\
920 (4)
2000
$3,
2,
$5,
$5,


$5,
$5,


$5,
$3,
1,

$5,
$3,
2,
670
0
130
800
510
0
230
740
510
0
230
740
960
790
230
980
670
0
040
Total
$5
3
7
$15
$


S
4
6
$17
$


6
4
6
$17
$


5
6
5
$17
$

5
4
9
,390
,360
,050
,800
,840
,280
,390
,510
,840
,600
,390
,830
,680
,140
,370
,190
,390
,100
,620
                       $ 3,400
$10,000
                                                (3)
$5,710 $19,110
(1)

(2)

(3)

(4)
Includes capital cost of pump station(s).

Construction in 1995.

Construction in 1985 and 1995.

Construction in 1990.
                            111-37

-------
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-------
     Alternative A

                              Capital        Present Worth
                             ($1,000)          ($1,000)

     Big Walnut Creek          5,390               985
     Rocky Fork                3,360             2,847
     Blacklick Creek           6,960             4,199

          TOTAL                                  8,051


     Alternative D

                              Capital        Present Worth
                             ($1,000)          ($1,000)

     Big Walnut Creek          5,390               985
     Rocky Fork                4,100             1,290
     Blacklick Creek           9,620             4,034

          TOTAL                                  6,309
          On a present worth basis, the least costly alternative
     would be a mixture of Alternatives A and D for Blacklick
     Creek and Rocky Fork (Big Walnut Creek is the same in both
     alternatives).  Alternative D is slightly higher in capital
     cost for the Rocky Fork service area, but is significantly
     less than Alternative A on a present worth basis.  This
     present worth difference along with its allowance for
     flexibility in future decision-making and lessening of
     possible secondary impacts makes Alternative D the recom-
     mended plan for the Rocky Fork Area.

          In the Blacklick Creek Area, Alternative A was thought
     to be the recommended plan, since it is less than Alterna-
     tive D in capital costs and close on a present worth basis.
     The implementability of a force-main alternative has been
     characterized as extremely difficult by local agencies and
     officials in the Blacklick area, and would not allow the
     abandonment of several  package plants which will be picked
     up by the gravity interceptor of Alternative A.  Yet, the
     new Section 6(f)  conflict requires a rethinking of all
     alternatives for Blacklick during localized facilities
     planning.  The force main may yet be the alternative of
     choice for reasons of feasibility or cost when the Park
     issue is resolved.(D
(1)   An Assessment of costs  of going through the park was
     made bv Metro Parks and is attached to this Appendix.

                            111-39

-------
3.2.6  Groyeport

     The Groveport subarea consists of approximately 5000 acres.
Route 33 near Blacklick Creek makes up most of the unit's northern
boundary, while the eastern edge lies just east of George Creek.
Walnut Creek and Swisher and Saltzgaber Roads form the southern
and western boundaries, respectively.  The only existing sani-
tary sewer system serves the City of Groveport.  Sewage is
treated at a 0.30 mgd trickling filter installation which cur-
rently discharges to Little Walnut Creek.

     (1)  Alternative Description

          The Groveport area population is presently estimated
     at about 4,000, and is expected to increase to 6,500 by
     1985 and to 11,600 by the year 2000.  This projected in-
     crease in population, coupled with the varying suitability
     of the local soils to septic tank and leachfield treatment
     systems, precludes further analysis of a No Action Alter-
     native for this subarea.

          Service to the developing portions of the Groveport
     area cannot be entirely provided by a gravity system while
     totally utilizing the existing wastewater treatment plant.
     Since it discharges to Little Walnut Creek near the Rick-
     enbacker Air Force Base, it was assumed that eventually
     both releases will have the same effluent limitations.
     The proposed 30 day average release levels for the Air
     Force Base are 8 mg/1 BOD5, 8 mg/1 suspended solids,
     1 mg/1 ammonia nitrogen (summer), and 1 mg/1 of total
     phosphorus.

          Three regionalization alternatives will be con-
     sidered for this subarea:  a plant alternative and two
     interceptor alternatives (shown in Figures 111-17 and
     18).  The treatment plant alternative would upgrade and
     expand the existing facility to 1.7 mgd.  This alterna-
     tive will also require the construction of a gravity
     sewer to handle the 1.2 mgd average flow coming from
     the area northeast of the plant near Route 33.

          The two interceptor alternatives also utilize a
     "northeast interceptor" which will parallel Route 33 for
     some 5,000 feet to provide service to the northern portion
     of Groveport.  This 15-inch interceptor will connect to a
     96-inch section of the existing Blacklick Creek Interceptor
     on the eastern bank of Blacklick Creek near Route 33.
                           111-40

-------

*~              '                            '

-------


-------
     Interceptor Alternative A differs from Alternative
B in the manner of interception of flows from the
southern portion of the area.  Alternative A includes
an interceptor branch which starts at Rager Road and
travels westward along the Chesapeake and Ohio Railroad
to a point just south of the 90 degree turn in Ebright
Road.  Here the interceptor crosses to the north, and
follows Ebright Road into the main interceptor at
Hendron Road.  This 14,100 foot branch will be 24 inches
in diameter.

     The main interceptor in Alternative A collects
flow from the area near the wastewater treatment plant.
From this point, the route crosses a few streets within
the City, turns in a northwestern direction, and follows
an intermittent stream to Big Walnut Creek.  After
crossing Big Walnut Creek, the interceptor will tie
into a 108-inch section of the existing Big Walnut
Creek Interceptor.  The proposed line is some 17,500
feet in length, and ranges in diameter from 18 to 27
inches.

     The main interceptor in Alternative B traverses
the same route as that in Alternative A, but ranges in
size from 18 to 30 inches.  Alternative B differs by
the inclusion of two branch interceptors.  The East
Branch connects to the main at Hendron Road as in
Alternative A, but is only 15 inches in diameter and
5,600 feet long, running parallel to Ebiight Road.  The
other  (Canal) branch starts near Rager Road and initially
runs westward along the Chesapeake and Ohio Railroad.
It then turns south, following the old Ohio Canal route
until connecting to the main interceptor close to the
intersection of Hamilton and Rohr Roads.  The Canal
Branch Interceptor will be 24 inches in diameter for
its entire length of 11,800 feet.

(2)  Primary Impacts

     The Plant Alternative will involve long-term
adverse impacts due to the ongoing commitment of man-
power, materials, land, and energy required for the
upgrading and expansion of the Groveport WWTP.  The
retention of the WWTP close to growing residential
areas could result in adverse impacts due to odor,
noise, and aesthetic degradation.
                      111-41

-------
     The northeast interceptor parallel to U. S. Route
33 is common to all three alternatives.  It will be
constructed through either cleared land or farmland,
with little adverse primary impacts expected.  The
route of the main branch of the Groveport Interceptor
is also common to Alternatives A and B.  Most of the
11,000 feet of the main interceptor travels through
open farmland, occasionally crossing some residential
backyards.  Four road crossings, including a proposed
tunnel under Route 665, will occur along this section
of the interceptor.  Crossing of Big Walnut Creek will
result in short-term surface water degradation due to
erosion and turbidity.  The remainder of the interceptor
length will involve about 1,000 feet of roadway construc-
tion along Lambert Avenue and the crossing of Rohr Road
in order to intercept flow from the present wastewater
treatment plant.

     All road crossings (except the proposed tunneling
under Route 665) are expected to cause unpleasant
short-term impacts in regard to noise, air quality, and
aesthetics.

     The interceptor proposed in Alternative A for the
southern portion of the subarea will collect flow from
an elementary and a junior high school.  Most of the
interceptor route traverses open farmlands, with the
exception of the school property and the single crossing
of Ebright Road, which may cause some temporary traffic
disruption.

     Alternative B includes the East Branch and Canal
Branch Interceptors.  The East Branch traverses the
same route as the southern interceptor of Alternative
A, but is only 5,600 feet long, terminating prior to a
crossing of Ebright Road.  Again, little impact is
expected from construction through the school property
and the cleared farmland.  The Canal Branch starts at
the existing treatment plant and proceeds along Rohr
and Wirt Roads, eventually crossing Groveport Road to
meet the main interceptor.  This is the only construction
in or along a roadway, with the exception of the cros-
sing of Rager Road at the uppermost end of the inter-
ceptor.  Traffic disruption and inconvenience is expected
to occur in these areas for short periods of time.
                     111-42

-------
     Construction along Wirt Road passes the Groveport
Log House, which is listed on the National Register of
Historic Places.  No other historic place is known to
be in the area.

     After crossing Groveport Road, the interceptor
route follows the old Ohio Canal right-of-way until
reaching the Chesapeake and Ohio Railroad.  A number of
homes and large trees exist along the Canal.  Many of
these trees will have to be moved, and construction in
this area will negatively impact local residents in
terms of noise, air pollution, and aesthetic degrada-
tion.

     At the intersection of the Chesapeake and Ohio
Railroad, the interceptor route follows the southern
side of the railroad tracks, traversing open farmland
and cleared land until crossing the tracks at Rager
Road by means of a tunnel.  Little adverse primary
impacts are expected to occur as a result of this last
section of interceptor construction.

(3)  Phasing

     Figure 111-19 shows the population densities
served by the two interceptor alternatives for the
Groveport subarea.  These Figures indicate that the
northeast interceptor need not be constructed until
about 1995, but that the main branch of the interceptor
should be constructed by 1980.  Besides the heavy
densities served, another reason for construction of
the main interceptor by 1980 is to intercept and transport
flows from the present Groveport treatment plant site.

     The East Branch in Alternatives A and B may be
be required by 1990, and  the Canal Interceptor in
Alternative B  may be needed by 1985.

(4)  Costs

     The capital cost for an upgraded and expanded
plant for the City of Groveport which is able to meet
average summer month release standards of 8 mg/1 BOD, 8
mg/1 SS and 1 mg/1 ammonia nitrogen, is estimated to be
approximately $3,680,000.  The capital cost for the
northeast interceptor is $180,000, bringing the total
capital cost of the Plant Alternative to $3,860,000.
The operation and maintenance cost for the plant is
estimated at $350/mg, while the annual 0 & M for the
northeast interceptor is $440.
                      111-43

-------
                                             FIGURE  m-19
                                       DENSITY  TRENDS  FOR THE
                                         GROVEPORT  SUBAREA
  6.0
^ 4.0
M
5 3.0
o
0
t 2.0
>>
                                                     Manholes         Coda
                                                     East Branch         O
                                                     Main Branch         X
                                                     Northeast Branch     A
               1985       1990        1995       2000

      GROVEPORT  INTERCEPTOR  (ALTERNATE A)
                1985        1990        1995       2000

      GROVEPORT  INTERCEPTOR  (  ALTERNATE  B )
                                                    Manholes         Code
                                                    East Branch         O
                                                    Canal  Branch         X
                                                     Main  Branch        A
                                                     Northeast  Branch     *

-------
          Capital costs for Interceptor Alternatives A and B
     are estimated as $2,260,000 and $2,050,000,  respectively.
     The O&M costs are $5,600 per year for Alternative A,  and
     $5,100 per year for Alternative B.  Treatment costs at the
     Southerly plant have been included in Alternatives A and B
     for comparison purposes.

     (5)  Summary

          A summary of interceptor lengths, primary impacts,
     costs, and present worths for the three alternatives are
     provided in Table 111-10.

          The selected plan for the Groveport subarea is Alter-
     native A.  This option costs more than Alternative B on
     a capital basis, but, due to phasing of sections of inter-
     ceptors, the present worth of A is far less.  Alternative A
     calls for less interceptor length and involves fewer envi-
     ronmental impacts than Alternative B.  The Plant Alternative
     is higher than either interceptor plan in terms of capital
     costs, O&M costs, and present worth, and commits more
     long-term resources.  Alternative A involves a dollar
     per person per year cost of $41 using the present popula-
     tion, or $14 per person per year using the projected 2000
     population.

          Localized facilities planning should be conducted,
     including an infiltration/inflow analysis, to determine
     needs prior to implementation of the recommended alter-
     native.
3.2.7  Rickenbacker Air Force Base

     The Rickenbacker Air Force Base encompasses some 4,200
acres, and is served by an existing 1.25 mgd trickling filter
installation.  Currently, this facility receives only sanitary
wastewater, and discharges effluent to Little Walnut Creek via
an outfall sewer.  There are two other small treatment plants
on the Base which serve a golf course and a trailer park.  Plans
call for the abandoning of both small facilities in the near
future.

     The Department of Defense has decided to deactivate the
airbase.  Prior to the deactivation decision, an engineering
firm had completed the design of a 14-inch force main that
follows Alum Creek Drive.  This force main would tie into the
Big Walnut Interceptor at MH No. 40 instead of MH No. 30.
                          111-44

-------
                         Table 111-10
         Alternative Summary for the Rickenbacker
                 Air Force Base Subarea

                                      Alternatives
                                              Interceptor
         Item                 Plant           A          B
Length of Sewers (feet)           0       18,200       19,200

Type of Land Traversed
   (feet)
   Woodland                       0          300            0
   Open Space (Rural)             0       15,200       15,900
   Residential                    0        2,700        3,300
   Highway R.O.W.                 0       18,200       16,400

Stream Crossings                  033
Highway Crossings                 056

Costs (Thousands of Dollars)
   Capital (1980)            $1,500       $1,318       $1,140
   Annual 0 & M  (1980-2000)    100.8         52.3         51.8
   Present Worth             $2,435       $1,670       $1,517
                              111-45

-------
     The following analysis, although completed on alternatives
different from the designed alternative, is included in the EIS
for the following reasons:

          To show that the designed alternative is similar
          to Alternative A, and that the designed alternative
          has environmental impacts that have been evaluated
          with other alternatives.

          To allow immediate construction of the designed
          alternative if the base reactivates and Federal funds
          are requested for the construction.

     (1)  Alternative Description

          The Waste Allocation Report for the Scioto River Basin
     suggests that the summertime average monthly effluent
     limitations imposed on the Rickenbacker treatment plant
     should be 8 mg/1 BOD, 8 mg/1 SS, 1 mg/1 ammonia nitrogen,
     and 1 mg/1 total phosphorus.  Since these proposed limita-
     tions are not presently being achieved, the No Action
     Alternative was not considered to be viable.

          Three alternatives were analyzed for this subarea,
     including the retention and upgrading of the treatment
     plant and two gravity interceptor alternatives.  The
     interceptor alternatives are shown in Figures 111-20 and
     111-21.

          The route of Interceptor Alternative A, similar to
     the designed alternative, does not actually enter the Air
     Force Base, initiating at a point just above the Base where
     Route 665 turns to the northeast.  At this tie-in point,
     the interceptor will be some 12 feet deep, enabling easy
     connection from almost any part of the Air Force Base.  The
     interceptor initially travels westward along Route 665 to
     Alum Creek Drive.  The proposed route then follows Alum
     Creek Drive northward to Bixby Road, at which point it
     continues along Bixby to Reese Road near Walnut Creek.
     The interceptor will then tie into the Big Walnut Creek
     Interceptor at Manhole 30.  The proposed sewer is to be 24
     inches in diameter throughout its entire length of 18,200
     feet.

          The interceptor route of Alternative B begins at the
     same point as Alternative A.  However, the interceptor
     proposed in this Alternative continues along Route 665
     until it reaches Lockbourne Road.  At this point it travels
                           111-46

-------

-------

-------
northward along Lockbourne for some 2,000 feet, and then
runs eastward until tying into manhole 16 of the existing
108-inch Big Walnut Creek Interceptor.  The proposed inter-
ceptor is again 245 inches in diameter for its entire
length of 19,200 feet.

     The above sizing took into consideration the fact that
the Air Force Base will be the only area served by this
interceptor.  Therefore, its design assumed full flow in
the year 2000, using the Air Force estimated average flow
of 0.8 mgd over the entire planning period.

(2)  Primary Impacts

     The primary impacts associated with the Plant Alterna-
tive are the future commitments of manpower, material, and
energy required for the upgrading and operation of the
facility.

     The most significant primary impact of Alternative A
is the disruption of the small residential area included
in the interceptor route along Route 665.  Along Alum
Creek Drive, the route is mainly through open farmland, and
interceptor construction can be accomplished with minimal
traffic disruption.  The interceptor will travel along the
southern side of Bixby Road in order to avoid the heavily
wooded areas to the north.  The agricultural land on the
south side of Bixby Road continues for the remainder of the
route until the existing 108-inch Big Walnut Creek Inter-
ceptor is reached.  Tunneling will be required within this
final portion in order to cross the Norfolk and Western and
Chesapeake and Ohio Railroads.

     The primary impacts of the route proposed in Alterna-
tive B are associated with the disruption of the residential
area near Route 665 where the interceptor begins-, and with
the required construction through wooded areas along Lock-
bourne Road and Big Walnut Creek.  Most of the remainder
of the affected area is open farmland.  A tunnel is also
required for this alternative for crossing the same two
railroads mentioned in Alternative A.

(3)  Phasing

     No density plot is provided for this subarea since no
growth is expected to occur during the planning period.  Due
to the need for abandoning or improving the present treat-
ment plant to meet stringent effluent discharge requirements,
                      111-47

-------
the interceptors for either regionalization alternative
considered should be constructed by 1980.

(4)  Costs

     The costs associated with the Plant Alternative are
for construction ($1,500,000), and operation and main-
tenance ($350/mg).   The total present worth of this plan,
including salvage values, is $2,435,000.

     Alternatives A and B require capital  expenditures of
$1,318,000 and $1,140,000, respectively.  Annual operation
and maintenance costs are $3,300 for Alternative A, and
$2,900 for Alternative B.  The operation and maintenance
expenses incurred at the Southerly treatment plant due to
the flow from the Base must also be included for a true
comparison of the plant and interceptor alternatives on a
present worth basis.  Construction on the  Base and routing
of flows to the tie-in point of each Alternative is re-
garded as an internal matter, and costs have not been
included in this analysis.

(5)  Summary

     Table III-ll gives a summary of the primary impacts
and costs for the three alternatives.

     Alternatives A and B entail more primary impacts
than does the Plant Alternative.  The Plant Alternative
does involve a long-term commitment of resources and will
require double the O&M cost of either interceptor alterna-
tive.  This cost-effective analysis performed using a
24-inch interceptor illustrates that a regionalization
alternative, whether it be A or B, is the  preferred method
of handling flow from the Air Force Base.

     The Base has prepared its own preliminary economic
analysis and conveyed the information in a letter dated
October 21, 1977.  The salient comments are present below.

          Currently, an engineering firm is designing the
          sewage connection system.  The preliminary design
          calls for a 14-inch force main (route shown on
          Figure 111-20) ro a 21-inch gravity line (route
          shown on Figure 111-21).  The exact size of the
          line will be decided upon after  further analysis.
                     111-48

-------
                         Table III-ll

         Alternative Summary for the Rickenbacker
                 Air Force Base Subarea

                                      Alternatives
                                              Interceptor
         Item                 Plant           A          B
Length of Sewers (feet)           0       18,200       19,200

Type of Land Traversed
   (feet)
   Woodland                       0          300            0
   Open Space (Rural)             0       15,200       15,900
   Residential                    0        2,700        3,300
   Highway R.O.W.                 0       18,200       16,400

Stream Crossings                  033
Highway Crossings                 056

Costs (Thousands of Dollars)
   Capital (1980)            $1,500       $1,318       $1,140
   Annual O & M  (1980-2000)   100.8         52.3         51.8
   Present Worth             $2,435       $1,670       $1,517
                              111-49

-------
               The economic analysis comparing the upgrading and
               operating of the on-base plant to the construction
               of a connection line to the City of Columbus has
               been revised using the new proposed user rates.
               Results of this analysis showed the present worth
               of a plant alternative to be $7.8 million dollars;
               while the cost of a force main alternative was
               $5.4 million.  (These costs assumed an annual
               inflationary rate of 8 percent.  Ignoring infla-
               tion, the costs are reduced to $5.9 million and
               $3.2 million, respectively.)  The analysis shows
               that the connection to the city system is more
               economical.

               The environmental assessment concerning the
               connection to the City of Columbus, forwarded by
               our letter of 18 August 1977,  is applicable to
               either a gravity line or to a force main.  Either
               system, if selected, would be designed and  con-
               structed with a capacity to serve the base only,
               and would be routed along the right-of-way of an
               existing roadway.

               The City of Columbus has agreed to accept the base's
               wastewater as noted in their letter to U.S. EPA on
               1 March 1977.

          Two additional comments should be made concerning the
     regionalization of the AFB.  The first is that, as shown on
     Figures 111-20 and 111-21, the routes proposed by the Air
     Force are similar to those proposed by the EIS and therefore,
     similar primary impacts would be expected to result.  The
     exception to this is the portion of the route proposed by
     the AFB for the gravity alternative which crosses Blacklick
     Creek, a crossing not found in the EIS alternative.

          The second comment concerns the fact that no secondary
     impacts are anticipated to result from any regionalization
     scheme since the interceptor line would carry only flows from
     the Rickenbacker AFB.


3.2.8     Sensitivity Analysis

     Analyses were performed to show the size and cost differences
between designs based on ultimate population, on interceptors
flowing half full in the year 2000, and on interceptors flowing
full in the year 2000.  Table 111-12 shows the slopes, sizes,
                           111-50

-------
























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-------
and costs of the chosen alternatives for each subarea as well as
the sensitivity of the design concept of sizing each interceptor
at half capacity in the year 2000.


     The cost difference between designs using half full by 2000
and full by 2000 vary from 3% to 24%, with the average and
median variation around 18%.  This  demonstrates that, on the
average, an 18% increase in cost will permit twice as much
intercepted flow at design conditions.

     Table 111-13 shows the comparison of ultimate density versus
the projected design density for the year 2000.  The table shows
that most of the areas are at or less than 25% of their ultimate
density by the year 2000, making designs based on an ultimate
population concept uneconomical for the Columbus area.
                            111-53

-------
                    Table 111-13
   Year 2000  vs.  Ultimate Densities Per Subarea
(1)
Subarea

West Scioto
Big Run
Minerva Park
Big Walnut Creek
Rocky Fork
Blacklick Creek
Groveport
Rickenbacker A.F.B.


Subarea not in Facility Plan
                                       Population Density
                                     EIS          Facility Plan
                                  Year 2000           Ultimate
                                     2.0
                                     0.9
                                     5.3
                                     1.
                                     1,
     0
     8
   1.1
   2.6
1.0 - 1.3
10-20
 4-4.6
 7-24
  4
  8
 6-10
 7.4
 (1)
                        111-54

-------
COLD; "'i
                 }•;:)' .S  J.'Ky^
                  POI'DL/Vi ION
TRAFFIC
ZONE



2423
2422
2421
2420
2419
2418
2501
3402
3403
3404
3405
3406
3407
3408
3409
3410
3411
3412*
3413
3414*
3415
3416
3417*
3418
3502*
3505*
3507*
4409
TOTAL COUNTY
1.250 M
MORl'C 10/76
PROJECTIONS
TOTAL
TRAFFIC
ZONE

527
432
994
636
1413
2082
1962
85
2927
2283
1187
7069
2730
0
1130
4944
5533
3952
633
2922
2731
1863
3798
4167
4042
3974
883
4200
SERVED
IN
TRAFFIC
ZONE
527
432
994
636
141
645
784
85
2927
2283
1187
2121
2730
0
1130
4944
5533
3952
633
2601
0
0
1785
1083
3597
1590
530
966
TOTAL COUNT/
1. 130 J-!
• — ~ — - —
HIS 2/73
PROJECTIONS
TOTAL
TRAFFIC
ZONE

465
381
877'
561
1-246
1836
1727
75
2582
2014
1047
6235
2408
0
997
4361
4880
3486
558
2577
2409
1643
3350
3675
3557
3497
777
3704
SERVED
IN
TRAFFIC,
ZONE
465
381
877
561
124
569
690
75
2582
2014
1047
1871
2408
0
997
4361
4880
•_ 3486
5*58
; 22C.M
0
0
]574
955
3165

1309
4 66 |
852
""" " '" 	 "A~ /
TOTAL COUNTY
1.025 K
MORPC.S/2.V7Q
PROJECTIONS
TOTAL
TRAFFIC
ZONE

266
203
360
201
525
740
1727
53
479
920
202
5140
2133
0
479
3864
2261
3622
500
3137
2420
905
3964
2641
4857
5447
! 3469
990
SERVED
IN
TRAFFIC
ZONE
266
203
360
201
52
229
690
53
479
920
202
1542
2133
0
479
3864
2261
3672 !i
500 I
2792
0
0
1063
687
4.122 fi

2179
20M2 J
228
Traffic  zones" showinq irxcrcxascr- in population under
revise,!  projections.

-------
               Ohio Department of Nature  Resources
                          OFFICE OF OUTDOOR RECREATION SERVICES
                           Fountain Square ; Columbus, Ohio 43224 • (614) 466-4974

                                                              RECEIVED


         Mr. John McGuire,  Administrator                            APR 2 31979
         U.S. Environmental  Protection Agency
         Region V                                                  ^^ REGION 5
         230 South Dearborn Street                                  OFFICE of REGIONAI
         Chicago, Illinois   60604                                    ADMINISTRAT-'

         RE:  Wastewater Treatment Facilities for the Metropolitan  Area, Columbus,
             Ohio; Proposed Blacklick Creek Interceptor

         Dear Mr. McGuire:

             An inquiry has been made by your Ohio  Facilities Planning Staff as to
         whether construction of the above cited  interceptor sewer  through  Blacklick
         Woods Metropark, Rey'noldsburg, Ohio, would  result in a Section 6(f) conflict
         of the Land and Water Conservation Fund  Act.

             Under two separate projects, Blacklick Woods Metropark  has been developed
         with Land and Water Conservation Fund monies.  Granting control or partial
         control of land within the park for a sewer line would constitute  a Section
         6(f) conflict.

             Any request for a conversion of land use must first be  submitted by the
         Park District to this Department for review and approval.  The conversion
         request must also  be reviewed by the Heritage Conservation & Recreation Ser-
         vice and meet the  prerequisite for approval of a Section 6(f) conversion
         request (see attached) before final approval by the Secretary of the Interior.

             If you have any questions or need any  additional information  please do
         not hesitate to contact my office.
                                          /     ,
                                         £ana>r G: Olson, Chiel
                                          Office of Outdoor Recreation Services
         DGO:sjd
         Attachment
         cc:  Frank D.  Jones, HCRS
   >          Edward F.  Hutchins, Metro Parks
su.)sjft.^     Dayton Robbins, City of Columbus
  /,.  , t.      Gene Wojcik,  U.S. EPA
             Greg Smith, Ohio EPA
                JAMES A. RHODES, Governor  •  ROBLRT W TEATER, Director • DONALD G OLSON, Chief

-------
As prerequisites for approval of any 6-f conversion request, it
should be determined that:

     1.  JLL1 practical alternatives to the conversion have
         been evaluated and rejected on sound bases.

     2.  The fair market value of the property to be converted
         has been established and that the property proposed for
         substitution is of at least equal fair market value.

           a.  Generally this will necessitate a review of
               appraisals prepared in accord with Part 675.2.5
               for both the property proposed to be converted
               and that recommended for substitution.  However,
               at the discretion of the Regional Director, a
               State certification that appraisals of both
               properties are acceptable and reveal that the
               replacement property is of at least equal fair
               market value as that of the property to be
               converted can be accepted.  Exercising this
               authority should be consistent with the State's
               review responsibilities with respect to donation
               appraisals.

           b.  Property improvements will be excluded from all
               fair market value consideration for properties
               to be substituted.  Exceptions are allowable
               only in those cases where property proposed for
               substitution contains improvements which directly
               enhance its outdoor recreation utility.

     3..  The property proposed for replacement is of reasonably
         equivalent usefulness and location as that being converted.
         Dependent upon the situation and at the discretion of the
         Regional Director, the replacement property need not provide
         identical recreation experiences or be located at the same
         site provided it is in a reasonably equivalent location.
         It must, however, be administered by the same political
         jurisdiction as the converted property.

     4.  The property proposed for substitution meets the eligibility
         requirements for fund-assisted acquisition in the Manual.
         The replacement property must constitute or be part of a
         viable recreation area.  It should be also noted that public
         land may not be used for substitution unless it meets the
         acquisition criteria of Manual Part 670.1.8K.

     5.  All necessary coordination with other Federal agencies has
         been satisfactorily accomplished.

-------
6.   The guidelines for environmental evaluation enumerated
    in Manual Part 650 have been satisfactorily completed
    and considered by the Service during its review of the
    proposed 6{f) (3)  action.  In cases where the proposed
    conversion arises from another Federal action, final
    review of the State's proposal shall not occur until
    the Region is assured that all environmental review
    requirements related to that other action have been
    met.

7.   Clearinghouse review procedures set forth in Manual
    Part 660.1.ID have been adhered to if the proposed
    conversion and substitution constitute significant
    changes to the original Land and Water Conservation
    Fund project.

8.   The proposed conversion and substitution are in accord
    with the SCORP.

9.   Staff consideration of the above points reveals'no
    reason for disapproval and the project files are so
    documented.

-------
                               Metro  Parks
              999 Park Road • P.O. Box 29169 • Columbus, .Ohio 43229 • 614/891-0700
Board of Park Commissioners                                                          Director-Secretary
  Michael B. Karr                                                                  Edward F. Hutchins
  Everett H. Krueger                                                               Deputy Director
  Robert M. Zollinger, M.D.                                                            John A. Metzker


                                                 February 5, 1979    •:_-•    '^
                                                                      **''    ~~n
  Mr. Dale Leucht                                                    ~I1'    "~    : j
  Water Quality Planning Branch                                       -'--            J
  USEPA Region V                                                           -^     -.
  230 South Dearborn Street                                           *-     ^    	
  Chicago, Illinois  60604                                              .     ^    <

  Dear Mr. Leucht:                                                    ;     ~      '
                                                                      C      _=    :~
  I am writing to you about the impacts of the Blacklick interceptor sewer'.'line, alf pro-
  posed in the  Columbus Metropolitan Area Facilities' Plan, on Blacklick Woods Metro-
  politan Parh.  While I realize that it is late in  the decision-making process for  this. !
  must point out that we were only made aware'in mid-December of 1978 of what  the ap-
  proved route might be.  On December  19, Mr. John Metzker, Deputy Director  of the
  Metropolitan Park District accompanied Messrs Gregory Smith and Robert Monsarrat of
  the Planning Division of  Ohio  EPA on a tour of those  areas of the Park through which
  the pipeline would pass.  In bringing these impacts to your attention it is  not  our
  intention to cause further delay to the already protracted planning for this needed
  correction of the Reynoldsburg area's  water pollution problems; however,  the im-
  pacts on Blacklick Woods Metropolitan Park  will be  extensive and, consequently will
  have serious  detrimental effects on the recreational activities of the 565,000 people
  who use the Park throughout  the year and the 65,000 people who use the Golf Course
  during its seven- to eight-month season.  We  feel,  regardless of the time factor,
  serious consideration must be given to mitigating, if  not avoiding,  these impacts.

  The pipeline will cross two major portions of Blacklick Park, the Golf Course,  as
  alluded to above, and a natural area.  We do not consider the impacts to one to be
  greater or less than to the other.  The Golf Course is, in actuality, two courses, an
  18-hole par-72 course and an  18-hole par-59 course.  As the pipeline enters the Park
  it will divide  the greens  and fairways 13, 14,  15 from the par-59 course  and then will
  drop south across the par-72  course crossing eight fairways and probably two greens,
  thus eliminating eight holes from it and separating  fairways 12 and 15 from the un-
  damaged remaining  eight holes. There is the  additional matter of disruption of the
  complex sprinkler system and the effects of digging on two 26-inch wells.  The impact
  may be analyzed in  three ways: damage to  the course, loss of revenues, disruption
  of recreation.

  Our landscape staff and  the course professional estimate that it will take a minimum
  of two years for the damaged  fairways and  greens to  be restored to their pre-
  construction state.   Our best  estimate  of the costs  for repairing the direct damages
  is  $15,000 per damaged hole, or a total of $400,000.  However, the greatest monetary
  losses will result from the lost greens fees,  currently running $351,000 per year.
  We have been  advised that  the time the Park's impacted  areas will be unavailable for
  use will be the better part of  a year, since  the construction company will have to
  use the pipeline right-of-way  as its major access between Livingston Avenue, the
  Park's northern boundary, and Interstate 70, its southern boundary.


            BLACKLICK WOODS     HIGHBANKS   f^T^]    BLENDON WOODS   SHARON WOODS
              SLATE RUN  CHESTNUT RIDGE     ViS2§/        BATTELLE (DARBY CREEK)
                 INN1SWOOD GARDENS        \^:.,c
-------
If the course is unplayable for one season,  it will take three years for the number of
players, 65,000, who last played the course over the season to reach that number
again.   However, whether the course can be returned to playability with only one
season's loss is dependent on when the construction begins and how long the area is
used for construction, so two season's loss  is not improbable.  Two seasons' loss
would require five years for return of the original number of players,  thus, without
taking inflationary factors into consideration, income losses to the Park District would
run between 1  million and 1.5 million dollars.  Added to  this figure would be the costs
of maintenance of those portions  of the course not directly impacted by the construc-
tion during that period and full maintenance after construction.  Those costs are
$273,000 per year.  If the courses are out of  commission for two  seasons, the im-
mediate add-on to the loss of fees would be $546,000, with a pro-rata  add-on for
every year until the greens fees offset these  costs.  The effect of the  lost net gain
shown  between a year's income from greens fees over course maintenance costs would
be felt throughout the Park System  since it is used to cover maintenance costs in other
areas because tax-generated funds are inadequate for these purposes.

The recreational loss from construction on the Golf Courses is not limited to golf.  During
the winter,  a complete winter sports program of skiing,  sledding and  skating is con-
ducted here and with the access  lost from Livingston Avenue, that program also would
be lost to the public.

South of the Golf Course the pipeline will cross a natural area which was just opened
to the public last year.  It had been closed for over  20 years, after being cleared
of former farm  buildings, so that it  could recover vegetation ally  and be reoccupied by
wildlife.   It is  appropriate to point out  here that the  primary function of the Metro-
politan Parks is to provide non-consumptive,  no-harvest, natural area recreation
365 days a year which, translated into operations, requires the careful nurture of
balanced ecosystems.  The opening of this natural area followed  the completion in the
fall of  1978, at a cost of $90,000, of combined jogging and bicycle trail which can also
be used for Nordic skiing in winter.  The pipeline will bisect the lower loop of this
trail, but more damaging to the area will be the impact on the 20-year recovery of
vegetation and wildlife habitat.  The construction alone will undo 20 years of slow
natural recovery, but that will be compounded by the prolonged  use of the right-of-
way.  The effects of machinery noise and concentrated human activity  will be dis-
ruptive to the  wildlife both in this area and in a more delicate and critical area im-
mediately to the west.

The natural area complex based on this delicate ecosystem -was dedicated as a preserve
under Ohio's Natural Area Preservation statutes.  The central feature  of this complex
is a mature eirn-ash-swamp forest association.  A pond was constructed to increase
habitat diversity; a nature interpretation center,  whose primary feature is concealed
viewing of wildlife through one-way glass walls, was  constructed, together with a
nature trail and boardwalk through  the swamp.  The  total cost was $230,712.  The
natural diurnal and periodic  migration of wildlife—deer,  foxes, and birds—into this
area is dependent on  their freedom of circulation between this area and that through
which the pipeline and right-of-way will pass.  It is that circulation and migration
upon which  the nature center and trail system depend for their attraction to and  use
by park visitors.  There is no doubt, in our judgment, that the  disruption of the area
to the east of this dedicated  natural area  will  have a major and moderately long-term
negative effect on the natural area and its recreational use.

While the monetary impacts to the Park's Golf Courses and natural  areas will be

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substantial, the greatest losses will be in the disruption of carefully nurtured natural
areas and wildlife habitat and the deprivation of recreational opportunities for sub-
stantial numbers of people.  In light of these impacts, which are far from being short-
range, on Blacklick Woods Metropolitan Park, we would encourage you to give definitive
consideration to using the alternate route for the pipeline which lies to the east of the
Park and Blacklick Creek along State Route 256 or to one that would proceed  west
along Livingston Avenue beyond the western boundary of the Park.

                                               Sincerely,
                                               Edward F.  Hutchins
                                               Director-Secretary
EFH:akw
cc: Regional Director, Heritage Conservation
      and Recreation Service
    Chief, Division of Recreational Services, ODNR
    Chief, Natural Area Preservation Section, ODNR
    Director, Region  V, USEPA

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           APPENDIX  DD

        REVISED APPENDIX B:
MATHEMATICAL CHARACTERIZATION OF THE
    SCIOTO RIVER BELOW COLUMBUS

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            APPENDIX B
   MATHEMATICAL CHARACTERIZATION
OF THE SCIOTO RIVER BELOW COLUMBUS

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                         APPENDIX B
                MATHEMATICAL CHARACTERIZATION
             OF THE  SCIOTO RIVER BELOW COLUMBUS
B.I  INTRODUCTION

     The computer is  a valuable tool in the systems  analysis
approach to comprehensive  studies involving stream modeling
and alternative evaluation in the development, use,  and
management of water resources.  This study has used  a basic
dissolved oxygen water quality model to define the impact of
point wastewater releases  from the Jackson Pike and  Southerly
wastewater treatment  facilities upon the oxygen resources of
the Scioto River under a variety of low flow regimes.
Effluent loadings were adjusted so as to establish a final .
load allocation for any modeled pollutant such that  a viola-
tion of the applicable water quality standard is avoided.
Ideally, this provides an  optimum situation because  the
receiving stream can  now be used as a final treatment device
to the extent that its capability is not taxed to the detri-
ment of the natural environment and indigenous aquatic
species.

     Obviously, any attempt at future prediction is  fraught
with difficulty and plagued with controversy.  Indeed, the
capability for mathematical sophistication via the computer
far exceeds the fundamental knowledge needed to establish
reasonably correct input parameters.  The reader should
remember that a mathematical model gives only correct
relative results with constant input parameters.  Specific,
finite results are a desired goal but are rarely achievable.
B.2  DISSOLVED OXYGEN MODEL

     Detailed mathematical analysis of the Scioto River
revolves around a simplified dissolved oxygen profile.  The
basic program was produced by the Texas Water Development
Board and titled "DOSAG"(U.  This water quality model was
then modified by the Georgia Environmental Protection Division
to allow the incorporation of a different method of calculating
reaeration and to drop flow augmentation considerations.
    Simulation of Water Quality in Streams and Canals
    DOSAG-1, Texas Water Development Board (1970).

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      The mathematical model was  further refined to incor-
 porate  instream sheet oxygen demands  and assets and reaction
 rate  attenuation as  a function of  dissolved oxygen concentra-
 tion  or attainment of a  set background  ultimate carbonaceous
 oxygen  demand.   The  final  form of  the dissolved oxygen model
 is  given below.
      D =

     where DQ = Initial dissolved oxygen deficit  (mg/1)
           LQ = Initial ultimate carbonaceous oxygen demand
                   (mg/1)
           No = Initial ultimate nitrogenous oxygen demand
                   (mg/1)
           D  = Dissolved oxygen deficit  (DO saturation - DO
                  stream) at any time t  (mg/1)
           KI = Carbonaceous decay coefficient  (days'1)
           K2 = Reaeration coefficient  (days"1)
           K3 = Nitrogenous decay coefficient  (days"1)
           t  = travel time, days
           BD = Sum of in-stream sheet demands and assets
                   (mg/day/SF)
           d  = stream depth (ft. )
          28.3 = Liters/cubic feet
The following sections describe the development and background
thinking that went into the establishment of the input
parameters for the model and the waste load allocation
activities.
B.3  TEMPERATURE CONSIDERATIONS

     The temperature adjustments for
given below:

      Kir K3 and BD at any T/ °C = 1
                                         K2 , K3 and BD are
                                          and BD at 20°C (1.05)T~20
         K2 at any T,  °C = K2 at 20°C (1.02)T"2°

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 These  adjustments  are well documented  in the literature and
 represent no deviation  from  the  current state of the art.

     Temperatures  under low  flow conditions  in the Scioto
 will likely be relatively high due  to  the three cooling
 water  releases in  and below  the  City of Columbus.   Two of
 these,  Ohio State  (not  presently operating)  and the Columbus
 Division  of Electricity plant, are  above Jackson Pike,  while
 the third,  Columbus  and Southern Ohio  Electric Company,  is
 below  Southerly.   This  bracketing of the facilities being
 modeled pointed toward  use of the maximum permissible stream
 temperature stated in the Ohio Water Quality Standards,  32°C.

     The  use of this high a  temperature will probably remain
 valid  even after the closing of  the present  City Division of
 Electricity plant.   Plans currently call for the replacement
 of this facility with another coal  and refuse-fired production
 unit just below Jackson Pike (pending  voter  approval),  a
 move which will likely  continue  to  produce elevated stream
 temperatures.

     Winter model  runs  were  also conducted for the same
 segment of the Scioto River.  The stream temperature utilized
 in this effort was 12°C, a value which again reflects  conditions
 resulting from releases <5f cooling  water.
B.4  INSTREAM OXYGEN DEMANDS AND ASSETS

     The BD term in the dissolved oxygen model represents
the cumulative effect of algal photosynthesis, algal decay,
and the oxygen demand associated with any benthic deposits.
The first would represent a stream asset, and the other two
would be demands.

     Algal photosynthesis is, first of all, nutrient depen-
dent.  After that, a favorable habitat for algal replication
is needed.  Algal replication and, in turn, photosynthetic
oxygenation, are dependent upon sunlight as an energy source.
Where algal photosynthesis occurs algal decay is an inevitable
corollary.  A field sampling program will usually measure a
stream condition exhibiting the maximum net influence of
algal photosynthesis since it is most often conducted in the
daylight hours.  Only those samples taken near dawn will
measure the maximum net impact of algal decay on the oxygen
resources of the stream.  Quantitatively, it is not known if
the net 24 hour impact of photosynthesis and decay is
positive or negative.   Therefore, it was assumed in this
study to be self-canceling.

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     The  benthic  oxygen demand  is highly variable,  since  it
 reflects  the  accumulation of  both natural organic debris
 (such  as  leaves in the fall), organic  settleable solids
 discharged  from point wastewater sources, and the naturally
 developed sediment load from  nonpoint  sources.  The cumula-
 tive impact of these considerations is further reduced to
 the intangible by storm frequency and  intensity as  well as
 stream velocity.

     For  the  purposes of the  modeling  effort, it was assumed
 that both of  the  dischargers  were achieving a minimum of
 secondary treatment equivalency with no settleable  solids in
 their  effluent.   It was further assumed that the seven
 consecutive day,  ten year low flow regime would precede the
 fall season and its attendant leaf litter in the streams.
 These  assumptions allowed the use of a zero or insignificant
 benthic demand in all modeling runs.
B.5  REACTION COEFFICIENTS

B.5.1  Reaeration Coefficient  (K2)

     The escape coefficient concept established by Tsivoglou
and his co-workers is gaining wide acceptance in stream
modeling work for a definition of the reaeration coefficient.
The reported relationship is of the form:


                  Ah               i
          K2 = C  —r  (base e, days"1)

               where:  C = escape coefficient, ft."1
                      Ah = change in stream bed height, ft.
                       t = time of travel, days.
Historic convention had been to use a constant C of 0.05
throughout the entire flow range with an upward adjustment
for clean streams  (up to 0.07) and a downward adjustment for
grossly polluted streams (down to 0.02).  However, a later
publication by Tsivoglou and Neal^1' has further refined
this relationship to reflect changing values of C with
stream flow.   This study recommends using an escape coef-
ficient (at 20°C) of 0.05 when stream flows are in excess of
25 cfs.  This value was used in all simulation runs.
(1)  Tsivoglou, E.G., and Neal, L.A., Tracer Measurement
    of Stream Reaeration - III.  Predicting the Reaeration
    Capacity of Inland Streams, 48th Annual WPCF Conference,
    Miami Beach, Florida (1975).

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     In this modeling effort, the Ah value was established
using 7.5 minute USGS quadrangles and establishing a repre-
sentative stream slope through a measured distance and
reported contour lines.  The change in elevation was then
calculated from the slope over the stream reach.  Slope on
the Scioto from Columbus to Circleville is fairly uniform,
with values ranging from 2.1 to 2.3 feet per mile.

B.5.2  Carbonaceous and Nitrogenous Decay Coefficients
             and K3)
     The establishment of correct KI and 1(3 inputs for
mathematical characterization of a receiving stream is one
of the most controversial aspects of river modeling and
waste load allocation.   Most historic modeling efforts have
incorporated K^ and K3 rates corresponding to those observed
in a standard laboratory BOD determination.  Studies by
Havens and Emerson (!) (2> incorporating field derived K rates
have indicated that laboratory values may significantly
underquantify actual instream deoxygenation characteristics
due to the static nature of the BOD test itself.  The values
selected as input parameters for the mathematical analysis
in this study represent a composite of the rates measured by
Havens and Emerson in streams carrying elevated concentra-
tions of oxygen demanding materials.  These rates, as shown
below, are adjusted as a function of velocity in a very
rough approximation of the in-situ measurements.  (It is
probable that they truly vary as a function of both stream
depth and velocity, i.e., a total mixing function.)
            Velocity                KI             K3
             (fps)                 (days-1, base e, 20°C)

             <0.6                   0.6             0.3
             >1.0                   6.0             3.0
           >0.6 to  1.0          straight line transition
(1)  Water Quality Assessment and Basin Modeling - Rocky
    River and Tinkers Creek, prepared for the Three Rivers
    Watershed District by Havens and Emerson, Ltd. (1974) .

(2)  Water Quality Assessment and Low Flow Analysis -
    Muskingum Watershed,  prepared for the Ohio EPA by
    Havens and Emerson,  Ltd. (1976) .
                              5

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The critical velocities are  those where  instream settling
 (<0.6 fps) and instream scour  (>JL.O) are believed to dominate,

     Laboratory rates are,  generally speaking,  approximately
an order of magnitude less  than the  corresponding field
rates found in the above referenced  studies.  As  a general
rule, it can be safely stated that a laboratory rate  will be
the lower limit of field rates experienced  under  any  stream
condition(1).   Accordingly,  modeling runs were  conducted at
rates one tenth and one-half the above  tabulated  values in
order to "envelope" probable stream  conditions  and to demon-
strate model rate sensitivity.   Rate coefficients of  one-
half of the above tabulated values are  considered to  be the
most probable for the river under the design  conditions.


B.6  REACTION RATE ATTENUATION

B.6.1  Dissolved Oxygen

     The dissolved oxygen model is only  intended to  char-
acterize the stream's reaction under aerobic conditions.  In
recognition of this situation and the fact that  aerobic
organism activity will become attenuated under low dissolved
oxygen conditions, it was necessary to reduce  the deoxygena-
tion coefficients associated with carbonaceous and nitro-
genous stabilization.  A review of several readily available
references,(2)(3)(4)indicated that carbonaceous  stabilization
rates begin to slow at dissolved oxygen  levels on the order
of 0.5 mg/1.  Similarly, nitrogenous or  nitrification rates
begin to slow at a dissolved oxygen concentration of about
1.5 mg/1.
(1)"DO Workshop",  Federal EPA sponsored Symposium: Rate
    Constants for Surface Water Modeling, San Francisco,
    California, April, 1977.

(2) Eckenfelder, W.W., and O'Connor, D.J., Biological
    Waste Treatment, Pergamon Press, New York, N.Y.  (1961).

(3) Process Design Manual for Nitrogen Control, U.S. EPA
    Technology Transfer  (1975).

(4) Hopwood, A.P.,  and Downing, A.L., Factors Affecting
    the Rate of Production and Properties of Activated
    Sludge in Plants Treating Domestic Sewage,Institute
    of Sewage Purification, 5, 3 (1961) .

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     Figure B-l  shows the rate attenuation  employed in the
water quality model.  The model utilizes  the calculated
dissolved oxygen at the end of each  subreach  (each reach is
divided into ten equal subrcaches) to  set the appropriate
attentuation factor/ if applicable,  for Kj^  and K^ in the
subsequent subreach.

     This adjustment alone would make  the dissolved oxygen
model limited to aerobic waste stabilization.  The predicted
rate shutdown upon calculation of zero dissolved oxygen
means that the oxygen demanding load will now start to
accumulate as new downstream loads are introduced into the
stream.  Since this load accumulation will  act to further
suppress modeled stream recovery, any predicted recovery can
be totally eliminated when the input is large.  In recogni-
tion of this fact, a further refinement of  the model in-
corporated a velocity dependent anaerobic decay function of
the carbonaceous load when extremely low  (<0.1 mg/1) levels
of dissolved oxygen are anticipated.  Figure B-2 provides a
comparison of this anaerobic adjustment with the usual
aerobic equation.

B.6.2  Background Carbonaceous Load

     A background carbonaceous load attenuation consider-
ation is based upon the observation that  some fraction of
the ultimate carbonaceous load (Lo)  is not readily bio-
degradable, and  thus is stabilized at a much lower rate.
The computer handles this by using a reaction rate one-
hundredth of the normal value when a preset background
ultimate carbonaceous load is calculated  at the end of each
subreach.   A background LO of 3 mg/1 was utilized in all
modeling runs.
B.7  PHYSICAL STREAM CHARACTERISTICS

B.7.1  Flow Relationships

     Many models of streams start with Manning's equation
for velocity of liquids in open channels:

          1.5 p2/3ql/2
      V ~ ~N~ R   S

               where  N = Mannings n
                      R = hydraulic radius, ft.
                      S = slope, ft./ft.

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                       ore.
                       -fto
                   Vor VC^
      N— CAR BONACEOUS
      -NITROGENOUS (K3)
K,)
                               2.0
DISSOLVED OXYGEN, mg/jj.

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6.0
4.0
2.0
            0.2
                           AEROBIC
                                         •ANAEROBIC
0.6           J.O




   Velocity, fps
1.4

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 This  equation can  be  solved by  trial and error in the
 computer for a  satisfying depth and velocity with a known
 flow.  The major difficulty of  using this technique is that
 it  is dependent upon  correct Manning's n and stream width
 assumptions for the flow regime under consideration.  Since
 the detailed measurements and observations necessary to
 properly define these parameters were not possible in this
 study, it was thought to be preferable to attempt to define
 only  the stream velocity of the Scioto River in the modeled
 segments.  Characterization of  the velocity bypasses inter-
 mediate estimates  of  physical parameters associated with a
 stream, since velocity is the result of a given physical
 stream reach experiencing a given flow at a calculated
 slope.  Several methods  were employed to estimate reasonable
 instream velocities for  this study.

      The first  technique employed for velocity estimation
 was a -statistical  correlation of stage discharge relation-
 ships provided  by  the United States Geological Survey for
 gaging stations within the study area.  Equations of the
 form  y = aQb can be developed from this data, with y equal
 to velocity, width, or depth such that the expression for
 hydraulic continuity  (Q  = VA)  is satisfied.   Data obtained
 in this manner  in  the study area is, to a large extent, site
 specific, since many  stations experience upstream flow
 regulation;  a phenomena  which precludes the application of
 coefficients and exponents derived to other stream points
 which are similar  physically but nonregulated.

     Only three stations on the Scioto were within the
 modeled portion of the River:    the USGS gage at Columbus (RM
 27.0), a point between Shadeville and Southerly (RM 16.5),
 and at U.S.  Route  22  in  Circleville (RM 0.0).  Coefficients
 relating stream flow  to  velocity at these points are 0.381,
 0.009, and 0.055,  respectively.   Exponents on flow were
 found to be  0.232, 0.646, and  0.379, respectively.

     Estimates of  stream velocities in the Scioto River have
 also been made by  the Ohio Environmental Protection Agency
 as a part of their 303e waste  load allocation responsi-
bilities.  Values were obtained through a mathematical
 technique which adjusted a measured set of cross sectional
data to predicted  low  flow cross sections and their at-
 tendant stream velocities.

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      Cross sectional measurements  were also taken by con-
 sultants to the State  of  Ohio in 1962 as a part of a flood
 plain study for the Columbus  area.   Using the mean daily
 flow at the USGS Scioto River at Columbus gage on the dates
 of each measurement, a rough  approximation to the stream
 velocity can be made.  Table  B-l lists both the Ohio EPA  and
 the 1962 velocity estimates as a function of Scioto River
 mile along with the predicted velocity at stream points
 where the coefficient  and exponent method is applicable.
 The flow input  for the treatment plants under the OEPA and
 gaged approximations cause overall flow in the stream to  be
 near that noted in 1962,  which was at somewhat higher back-
 ground values with a lower plant input.

      Table B-l  reveals a  consistent  velocity trend - a
 relatively slow stretch below Jackson Pike after which the
 River speeds up and gradually tapers off to a fairly steady
 velocity.   A visual survey of USGS maps and the Scioto
 itself indicated likely points for these general velocity
 regimes to exert themselves due to either natural or arti-
 ficial considerations  acting  upon  channel geometry and side
 conditions.   Again, in an effort to  envelope actual future
 conditions,  model  sensitivity runs were conducted at velocities
 +33  percent of  the predicted  values.


 B,8   FLOW INPUTS

      Effluent flows from  the  two Columbus wastewater treat-
 ment facilities  were assigned  the  (1995)  dry weather values
 attributed  to them in  the  Environmental Assessment  of  the
 Columbus Metropolitan  Area Facilities Plan.   Jackson Pike
 was  modeled  at  100 million gallons per  day  (mgd), while
 Southerly was modeled  at  85 mgd.  Other present  wastewater
 releases  in  the  planning area were not  modeled,  since  they
 will most  likely be contributory to  one of  the  larger  plants
 by the design year.  The proposed Delaware  County plant on
 the  Olentangy River is the exception to  this, and is assumed
 to contribute its design flow to the stream above the  study
 area.  Cooling releases to the Scioto River  are  assumed to
 be an intake and once  through arrangement,  with  no net
 stream flow addition or subtraction.

     Background  stream flows are unusually  hard  to define
 for the study area due to the regulated nature of many of
the streams.  The Scioto River is especially affected by
regulation and withdrawals for water  supply.
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     At least three  low  flow  regimes on  the  Scioto  below
 Columbus are possible  and  can be  supported by  some  form of
 documentation.  One  flow assumption would be that the Scioto
 River above the Olentangy  actually goes  dry  due  to  the
 withdrawals experienced, and  that the Olentangy  flows are
 those dictated by the  low  flow release schedule  from the
 Corps of Engineers dam at  Delaware Lake, as  follows:

              Period           Discharge, cfs

          July 1-10                 10
          July 11-20                25
          July 21-31                35
          August 1-20               40
          August 21-31              35
          Sept. 1-Oct. 31           20
          Minimum Release            5

 Communications with the  USGS  have indicated  that  a  flow
 regime which incorporates  the minimum release  from.Delaware
 Lake in conjunction with a zero flow in  the  Scioto  above the
 Olentangy is in fact far more severe statistically  than the
 usually modeled low flow that persists for 7 days with a ten
 year recurrence (7-10)(!).

     Another possible  low  flow regime is that  which was used
 by the OEPA in arriving  at their  waste load  allocations for
 the Columbus treatment facilities.  This value, 18.2  cfs,
 attempted to strike a balance between the minimum permissible
 reservoir release and the  normal  low flow discharge schedule.

     The USGS also maintains  a computerized  file for  each  of
 their stream gaging stations  which will permit the  calculation
 of a 7-10 (or any other  statistically significant)  flow.
 Since upstream regulation was instituted, the  7-10  flow
 reported to exist just above  the  Jackson Pike  facility is
 122 cfs.   This value seems  high,  and model sensitivity runs
were made to show whether or  not  such a flow would  cause a
 significant difference in  load allocation conclusions.

     Flows from streams tributary to the Scioto were  input
on the basis of a USGS - specified 7-10 low flow or on  a
cfs/square mile transfer of those flows to similar  streams
on a direct drainage area ratio basis.
(1)Personal Communication, Richard Swisshelm, Ohio District,
   USGS.

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      Wintertime  flows were  arrived  at by analyzing seven
 consecutive  day  cold weather  low  flows which have  actually
 been recorded  at the Scioto River at Columbus USGS gage  over
 the past ten years.  A value  of 222 cfs, which was observed
 in January,  1971, was selected as representative of a low
 wintertime flow  regime.  This is  not to be  confused with a
 cold weather statistically  correct  7-10 low flow - it is
 merely intended  to provide  an approximation to such a value.

      Table B-2 provides a summary of significant inputs  to
 the stream model in terms of  river  mile. The velocities and
 deoxygenation  coefficients  tabulated are those at  the median
 and probable field conditions, respectively.   Deoxygenation
 rates are base e at 20°C.   The listed reaeration rate is
 that which results from a median  velocity consideration.
B.9  WASTE LOAD ALLOCATION

     National Pollutant Discharge Elimination System  (NPDES)
permits have been issued to both of the Columbus wastewater
treatment plants.  Limitations significant to a simplified
stream modeling effort are those on dissolved oxygen  (6.0
mg/1 average), BODs  (8 mg/1 monthly average), and NH3~N  (1.0
mg/1 summer and 2.5 mg/1 winter monthly averages).  These
values correspond to the Ohio EPA definition of BACTEA  (Best
Available Control Technology Economically Achievable).
Since DOSAG operates on the basis of ultimate BOD  (Lo) and
ultimate nitrogenous demand  (No), an adjustment to the NPDES
permit values was required.  In accordance with past Ohio
EPA practice, Lo was defined as 1.5 x 6005 and No as 4.0 x
NH3-N.  These release levels, along with an effluent DO of
6.0 mg/1, were used as a starting point for all model runs.

     Table B-3 provides a summary of stream response to
effluent loadings from Jackson Pike and Southerly at NPDES
permit release levels.  Model sensitivity to upstream flow,
stream velocity, and deoxygenation coefficients is tabulated;
as is the seasonal variation in the stream response to the
applied load.  Figures B-3 and 4 provide a visual representa-
tion of the DO profile in the Scioto River for the various
sensitivity runs in summer and winter, respectively.

     Two striking facts may be observed from a perusal of
the Table and Figures.  The first of these regards the
"tightness", or lack of significant variation exhibited by
the DO profiles under the various sensitivity runs.  Such a
phenomena indicates that many of the uncertainties associated

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with the prediction of the parameters which were allowed  to
vary are relatively insignificant.  Even the parameter which
showed the greatest sensitivity, deoxygenation rates, produces
a summer minimum DO below Jackson Pike which is still slightly
below 5.0 mg/1 at the lowest rate investigated.

     The second consistent output from all modeled runs at
NPDES release levels is the small variance of stream DO at
the end of each run at Circleville  (6.02 mg/1 - 6.53 mg/1
summer).  Since Circleville is the next significant discharger
of wastewater in the Scioto River basin, such a reduced
upstream DO and instream pollutant load  (in relation to
current conditions) will allow allocation requirements at
this facility to be established without regard to stream  sag
problems caused by the Columbus releases.

     Overall, the output obtained for summer conditions
would indicate that the decision is proper to require the
Columbus facilities to upgrade to their final NPDES levels
rather than to levels which are predicted to maintain present
water quality standards.  Despite probable continued dissolved
oxygen violations below each release, conditions in the
Scioto will improve immensely.  Evidence has indicated a
slowing of deoxygenation rates in streams that undergo
substantial load reductions - a fact which points to the
need for detailed observation and sampling of improved
stream conditions before passing judgement on any water
quality maintenance release levels.

     Winter stream response upon receipt of NPDES allowable
loads were modeled to determine the impact of the higher
nitrogen releases allowed under nitrogenous stabilization
rate limiting conditions resulting from colder temperatures.
Again,  violations or near violations of instream DO levels
were shown on four of the six sensitivity runs,  with only
greatly reduced deoxygenation rates allowing the stream to
carry the release loads without noticeable impact.   Instream
oxygen levels at Circleville are uniformly high under all
modeled winter conditions.

     Although the decision to require the present NPDES
release levels from the Columbus plants appears  to be sound,
some indication of probable allocations to achieve water
quality standards is also in order.   Table B-4 presents
the allocated values for the various sensitivity runs in
both summer and winter for the Jackson Pike facility.   Table
B-5 provides the same information for Southerly.

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     Summertime modeling  runs  for Jackson  Pike indicate  the
high degree of treatment  required at this  facility  under all
conditions.   Releases of  nitrogenous oxygen  demand  are
reduced to zero under all but  the least  stringent  (10%)  rate
condition.  Such an effluent limitation  would  require substan-
tial additional processes at the facility, such as  a break-
point chlorination and dechlorination capability.   Equally
significant costs would be involved in reducing the carbona-
ceous load to the levels  tabulated, which  approach  background
stream concentrations.

     Winter conditions at Jackson Pike indicate that it  is
possible to release levels of  nitrogenous  demand equal to or
greater than that specified by the cold weather permit
requirement in all runs.  Carbonaceous levels  are more
variable, with two runs indicating the need  for more stringent
control than the NPDES limits, and one allowing release  up
to a secondary treatment  equivalency. Differences in allowable DO
release levels tabulated  are intended to take  advantage  of
higher oxygen solubility  at lower temperatures,  with effluent
DO values of 6.0 mg/1 indicating no need for post-aeration
at the plant.

     Summertime allocations for the Southerly  treatment
facility (Table B-5) are  less  stringent than those  for
Jackson Pike under all modeled conditions.   Nitrogenous
releases are never required to be less than  permit  values,
while carbonaceous levels vary from 6 to 12  mg/1 for eight
of the ten conditions investigated.

     Winter conditions allow nitrogenous releases to increase
substantially from Southerly, with two of  the  five  modeled
runs limited by instream  ammonia toxicity  rather than oxygen
demand and sag.  Instream nitrogen levels  were assumed to be
toxic in accordance with  the 1972 EPA Water  Quality Criteria
which sets an upper limit for  un-ionized ammonia of 0.02
mg/1.  The total ammonia  exhibiting this un-ionized fraction
will vary depending upon  temperature and pH  conditions.   If
one assumes a wintertime  pH of 7.5 and a stream temperature
of 12°C, toxic conditions will exist when  the  total nitrogen
demand exceeds 14 mg/1.   Carbonaceous winter allocations are
always equal to or less stringent than NPDES requirements,
with reduced deoxygenation rates again allowing higher
release levels.

-------
     A few modeling runs, which are not tabulated, were also
done to see whether or not it would be advantageous to treat
a portion  (50%) of the Jackson Pike flow at Southerly.
Results consistently indicated little, if any change, in
release requirements at Jackson Pike, while forcing Southerly
to obtain more stringent effluent levels due to the combination
of higher process flow and lower upstream dilution.  It was
concluded that such a treatment and release scheme would offer
no overall benefits in terms of either environmental quality
or cost savings.

     The results of the modeling indicate that the following
release levels are appropriate for maintenance of stream quality
below the Columbus wastewater releases:
                          Table B-6
               Required Release Levels  (mg/1)

                              DO
          Summer:
            Jackson Pike     6.0      4      0
            Southerly        6.0      9      4

          Winter:
            Jackson Pike     8.8     12     14
            Southerly        6.0     30     40
Facilities design activities summarized elsewhere in this
Impact Statement were predicated on these effluent levels.
                                28

-------
                                              Jl
          United States Department of the Ertt^
                       GEOLOGICAL SURVEY     f _£:rs— —-*"*~. _
                     Water  Resources  Division	MCM—"-,,:!?	__
                       975  West  Third Avenue1	CT— ^s^.^
                       Columbus, Ohio  43212           '-^

                                               May 10, 1978


                     ID]
Mr. David  L.  KlunzingJ
Havens  and Emerson,  li
Bond  Court Building
1300  East  9th Street
Cleveland,  Ohio    "11^^ & EMERSON, INC.

Dear  Mr. Klunzinger:       CLEVELAND

'This  is in response  to your letter  of April  26,  1978. Hope-
fully,  we  can clarify some  of the apparent confusion  regard-
ing the flow  at  Station  03227500, Scioto  River at Columbus,
Ohio.

The flow measured  and published  at  most U.S.G.S.  gaging
stations including Station  03227500,  is the  water flowing
past  the actual  gage control.  The  low-water  control  for
a  gage  is  always somewhat downstream  from the gage structure.
If the  amount of water flowing past the gage  control  can
be accurately measured,  the gage record is considered good.
That  flow  record is  then utilized in  any  flow frequency
analysis which is  conducted for  that  station.  Please note
that  the frequency analysis is not  dependent  upon the source
of water passing the gage control.  It is important,  however,
that  the record  be homogeneous.  As an example,  for a regulated
stream  only record collected  after  regulation was initiated
should  be  used rather than  using record collected both before
and after  regulation was initiated.

An adjustment of any. flow characteristic  for the  effects
of frequency  characteristics  of  inflows or diversions can
be quite difficult.  This is  especially true  for  low-flow
characteristics.  The inflow  or  diversion record  must be
available  and must be subjected  to  a  frequency analysis
if it is to be accurately used as an  adjustment  to the low-
flow  characteristic  derived from the  regular  flow record
Only  flow  values of  identical recurrence  interval should
be added or subtracted.  If as an example, the 7-day, 10-
year  low-flow of a station  was 200  cfs and the 7-day, 10-
year  low-flow of an  inflow  upstream from  that station was
50 cfs, the adjusted low-flow could be calculated to  be
150 cfs.   If, however, the  50 cfs was an  estimated mean
inflow  rather than a 10-year  recurrence interval  value, it
should  not be utilized with much confidence  as an adjustment
factor.

-------
 The primary reason for the lack of confidence is that the
inflows or diversions would probably be at their greatest
difference or deviation during a significant period of drought,

It is my understanding that the flow at the Scioto River
at Columbus gage station does include flow from the Frank
Road Treatment Plant but does not include the flow from
the Shadeville Treatment Plant.  A discharge measurement
was made on the Scioto River above the influence of the Frank
Road Treatment Plant and another discharge measurement was
made on the same day at the control for the gage, which
is below the influence of the sewage effluent from the Frank
Road Treatment Plant.  Those two measurements were made
on July 22r 1978.  The flow above the influence of the Frank
Road Treatment Plant was 57 cfs.  The flow downstream from
the Plant effluent at the gage was 213 cfs.

We hope that this clarifies the flow statistics at the Scioto
River at Columbus gage.  If you have any further questions,
please do not hesitate to contact us.

                    Sincerely yours,
                    Arthur 0. Wgstfall
                    Acting District Chief
FVS/jw

-------
    APPENDIX  EE

COLUMBUS METROPOLITAN
AREA GROWTH POTENTIAL
      1977-1985

-------
           DEVELOPMENT COMMITTEE FOR GREATER COLUMBUS
           TWO  HUNDRED EAST TOWN  STREET   COLUMBUS, OHIO  43215   614/221-7871
                                           September 7,  1978
STEERING COMMITTEE
Dr. Edward Q. Moulton
    Chairman

Arthur J. Scott
Chairman-Elect

Robert H. Potts
  Treasurer

John C. Gallucci
   Secretary
Ralph H. Anderson, Sr.
William H. Anderson
Richard Bere
Lou Briggs
A. Charles Brooks
A. G. Cochran
David S. Cook
W. Arthur Cullman
Mark G. Feinknopf
Charles VJ. Fullerton
Jerome J. Hackman
Charles G. Hammond
Will He-Herman
George W. Hockaden
H. James Holroyd
Joseph P. Jester
Harold Jett
Richard Luecht
John G. McCoy
David R. Patterson
James W. Phillips
Samuel Porter
Harley Rouda
Fredfic L. Smith
H. Clifford Taylor
Phillip W. Tefft
Richard L. Tu'lly
Charles G. Vath
Edward F. Wagner
Willis C. Welch
Ralph R. Widner

Wairon J. Ciemean
       Director
 original:  Water-
SEP^"

£PA REGION. 5
OFFICE OF REGIONA'
           '
Mr.  Valdas Adamkus
Acting  Regional  Administrator
 Region V
United  s'tates  Environmental Protection
 Agency.
230  South Dearborn Street
Chicago, Illinois  60604

Dear Mr. Adamkus:
      I appreciated receiving a  copy of your letter of
August 29, 1978  to Mayor Moody  concerning  the Environ-
mental Impact  Statement  for the  Columbus Sewer System
Plan .

      We Vvt-re very pleaded that  Mr.  Wojcik  could  spend
some  time on August 23rd with us and discuss further
the  concern which was  generated  by  the document  en-
titled Columbus  Metropolitan Growth Potential, 1977-
1985.   I't did  appear  that there  was some conflict  be-
tween points made in  our presentation on August  8, 1978
at our meeting in Chicago and the projections -indicated
in the Growth  Potential  document.

      I think interpretation of  the  Growth  Potential docu-
ment  has been  unfortunate.  It  represents  some planner's
concept of what  will  happen in  a time span which is rela-
tively short as  related  to years of service for  our area-
wide  sewer system and, "importantly, it reflects  opinions
of City of Columbus planners, not those who do the plan-
ning  for suburban communities.   It  would only be natural
for  the City of  Columbus to want all new development to
take  place inside its  boundaries and such  a document as
we are considering would reflect that.

      During our  meeting  with Mr. WojciK it was suggested
that  in other  Federal  programs  there has been a  precedent
here  in Ohio for over  25 years  when there  is a difference
of opinion on  typo and/or sfize  of facilities built for
local communities on  Federal projects.  Whenever,  the
local community  felt  it  was justified to build a larger
size  or different type of facility  than -the Federal a^oncy
would approve, an estimate was  made for both plans and
Federal participation  limited to that amount which wou.o
have  been eligible under their  criteria.   This has boon
done  many times  in many  projects throughout tho  '•»••»*.«» l>
Ohio  and seems to be  completely  rational;   tho 1

-------
Mr. Valdas Adamkus
Acting Regional Administrator
 Region V
United States Environmental  Protection
 Agency
September 7, 1978

Page No. Two

agency does not participate  financially beyond that which
they feel is justified  and  the  local community has the
freedom of decision on  what  they believe will be needed
for the future.

     If City officials  are  so  confident they are right
and are willing to bear the  additional cost this, indeed,
seems to be a. reasonable and equitable arrangement.

     We are fully aware of  the  limitations a Federal agency
has in applying criteria and standards for a wide range
of conditions which exist in different states and in differ-
ent systems.  We realize the reluctance of Federal agencies
to deviate from standard procedures but we feel strongly
tlxat application of their programs should permit flexibility
when local governments  demonstrate local conditions differ
from other areas.

     If we can furnish  any  other information.or assist in
resolving this issue  we would  be glad to do so.  Thank you
for your consideration  of our  position.

                            Sincerely,
                               J.  Cremean
                                .utive Director
WJC/lb
cc:  Dr. Edward Q.  Moulton
     A. G. Cochran
     Mayor Tom Moody
     Robert Parkinson
     Jack N. Huddle
     Dayton Robbiris
     William Habig

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Mayor Tom Moody
Department of Development

LeVeque Tower
50 West Broad Street
Suite 401
Columbus, Ohio 43215
                                                                             Director N. Jack Huddle

                                                                             614-222-7763
            October, 1978

            To The Citizens of Columbus

            The Department of Development respectfully submits the second annual Growth
            Statement for the City of Columbus.

            This planning report is not a no-growth statement nor does it state where growth
            should or should  not occur.  Rather, it is an appraisal of where and to what extent
            growth is most likely to occur and discusses those factors that affect growth or may
            alter growth in the future.  The value of the growth statement is that  it attempts
            to define the total impact of various aspects of growth rather than discuss each
            factor individually.  The statement brings together Federal policies, national growth
            trends and local  decisions or peculiar  practices which will shape  future metropolitan
            growth.

            The purpose of this report is twofold.  First, it is an attempt to identify and discuss
            issues that may affect the future growth of the Columbus Metropolitan Area.  The
            statement provides long term projections of  population changes and household
            formations and an inventory of underdeveloped land. These facts along with the
            characteristics of growth will provide  an information base for functional planning
            activities such as sewer, water, parks, and  transportation planning.  Secondly, the
            growth statement provides a framework for preparing and processing the Capital
            Improvements Program. This program is a schedule of public  physical  improvements
            for the City of Columbus over a six year period.  The schedule of programs is based
            on need, priorities, and the City's financial standing.  The growth statement will
            identify the long term needs and thereby influence priorities  for funding projects.

            Because this report is associated with the Capital Improvements Program, it is
            updated and published annually. The  constant updating will provide a current
            barometer reading of changing conditions and their potential long term implica-
            tions.  If you have questions or comments regarding this report, please contact
            Lin Carver at 222-8172.

            Very truly yours,
            N.  JACK HUDDLE, DIRECTOR
            DEPARTMENT OF DEVELOPMENT
\

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COLUMBUS METROPOLITAN AREA

GROWTH POTENTIAL

1978 - 1985
October, 1978
The preparation of this report was financed in
part through a Comprehensive Planning Grant
from the Federal Department of Housing and
Urban Development, under the provisions of
Section 701 of the Housing Act of 1954, as
amended.

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 TABLE OF CONTENTS
 I.   INTRODUCTION

     Local Policies Determine Distribution of Growth	    2
     Columbus Growth Has Been Unique	    3

 II.   GROWTH POTENTIAL OF COLUMBUS METROPOLITAN AREA

     Geographical Limits	    5
     Capacity of Existing Development Area.	    7
     Capacity of Expanded Planning Area	    9
     Population and Household Projections	   13
     Annexation Activity	   19
     Accommodating Growth	   19

III.   "UNKNOWNS"  AFFECTING GROWTH

     School Desegregation	   22
     Future Energy Supply Is Uncertain	   22
     Dangerous Precedent Being Set By U.S.E.P.A	   23

IV.   GROWTH PROJECTIONS

     Active Growth Areas	   25
     Limited Growth Areas	    30

 V.   SUMMARY STATEMENT

     Regional Goals	   33
     Opportunities	    33
     Summary of Recommendations	   36

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INTRODUCTION

The essence jf the first growth statement of the City of Columbus, Columbus Metropolitan
Area Growth Potential 1977-1985, was that current growth characteristics are significantly
different from those generally experienced during the previous twenty-five years and that
the City of Columbus, as well as other communities, may have to make adjustments in order
to accommodate these changes.  The conclusion of the first growth statement was that the
anticipated  lull in growth at least for the next few years provides an opportunity for the
City of Columbus to concentrate on improving  the quality of existing development.

The primary objective of the second annual growth statement is to update information provided
in the first statement with particular  emphasis on the geographical distribution of population
and household growth for the year 2000; unfortunately, similar figures are not available for
1985.  This document is to provide a framework for the preparation of the 1979-1984 Capital
Improvements Program.  The projections and growth characteristics ideally should be for 1985.
However, because of the low growth rates anticipated through 2000 and the fact that many
functional planning activities require a planning period of ten to twenty years prior  to con-
struction, the year 2000 geographical projections should provide a reliable  indication of
future development needs.  Because this.report is the prelude to the annual  Capital Improve-
ments Program,  it will be updated and published annually.  In anticipation  of bond issues to
finance future capital improvements being submitted to the voters of Columbus in November
of 1979 or 1980, a comprehensive growth statement will be issued prior to July 1979.

It was stated in the first growth statement that  one of the most significant factors that could
alter Columbus' future growth characteristics was the impact of federal policies, particularly
those of the U.S. Environmental Protection Agency relative to the City's sanitary sewer system.
In early 1978, the U.S.E.P.A. published  its Environmental Impact Statement (E.I.S.) on the
City's Metropolitan Facilities Plan   and the worst of the City's fears were realized.  The
U.S.E.P.A., prompted by the fact that it finances 75% of major sewer projects at the local
level,  is not only dictating many aspects of  the upgrading and development of the sewer
system, but is also using the expansion of the sewer system as a means of directing local
growth.  While this action has proven to be  highly provocative and is obviously a dangerous
precedent, much of the problem has been a lack of public understanding of  development
objectives and policies for the metropolitan area.  This void must be considered as partially
the cause for the U.S.E.P.A.  in going as  far as  it did in superimposing its own development
objective on the E.I.S.

It is the intent of these growth statements to clarify the position of the City of Columbus and
provide a vehicle by which the City  will  not only identify its future growth characteristics,
but also propose policies the City should pursue in order to accommodate changes in growth.
An underlying assumption of these statements is that the best way to counter and minimize
unnecessary federal influence is to publicly  state on a regular basis the City's development
objectives.  This approach should provide  a  consistent and current basis for evaluating all
growth and development related programs, thereby providing a much stronger basis to influence
federal decisions which affect  local development.
   The Columbus Metropolitan Facilities Plan is a twenty year capital improvements
   program for upgrading and expanding the city's sewer system.

                                          1

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The publication of Hie E.I.S. highlighted some general misunderstandings about growth at
the local  bvel and the means by which local growth can or cannot be manipulated.  The
following discussion of the nature of Columbus' growth should provide a better understanding
of how functional  planning can impact on or accommodate growth.

Local Policies  Determine Distribution of Growth

There is a distinction that must be made concerning growth.  First, there is the overall
growth, or growth potential/ of the metropolitan area (Mid-Ohio Region).  This growth
refers to the overall change in population or economic growth over time.  This overall
growth is primarily determined by national and regional (east north central economic
region) trends.  The components of change, whether it be net natural increases or net
migration resulting in population  changes or unemployment changes reflecting overall
economic growth,  are primarily subject to national and regional trends.  In the case of
population, for example, it is highly unlikely that Columbus, regardless of how attractive
it is as an individual community, can continue to grow  substantially if the region as a whole
is in a decline. Therefore, generally speaking, the trends at the national  and regional
levels will have the greatest impact on overall growth.

The second aspect of growth to be considered is the distribution of local growth within the
metropolitan area. While it is true that there are several factors that contribute  to urban
growth patterns including such abstractions as "area attractiveness" and quality of schools
which are based on individual value judgements, it is virtually impossible for an  area to
urbanize without the availability of sewer,  water  and transportation facilities.  Local
officials  cannot control natural amenities of an area nor an individual's value judgements;
but, they can  and do determine which area  gets what facilities and when.  In fact, most
factors that a potential urban dweller would evaluate when considering an  area of a
community in which to live are the direct result of the availability of an urban service
provided by local  government and comes about as  a result of  the availability of the
traditional "growth shapers", transportation, water and  sewer facilities (the relative
importance of  these three is discussed on page 5).  Therefore, local attitudes concerning
the geographical distribution of growth and  local policies concerning the availability of
these basic facilities is of prime importance in the distribution of growth.   The importance
of local decisions  is obvious from the  fact that the success of Columbus' growth,  as compared
to other central cities, during the past twenty years is directly attributable to the city's
geographical expansion through annexations.  This expansion was  the result of local policies
on annexation and utility line extensions that were discussed  extensively in the last year's
growth statement.  ^
 n
  The U.S. Census Bureau has divided the country into economic divisions and regions.
  Columbus is located in the east division of the North Central  Region.  The North Central
  and Northeast Regions are often referred to jointly because of their similar economic
  problems relative to competition with the "Sunbelt" states.

 3
  Department of Development, City of Columbus, Columbus Metropolitan Area  Growth
  Potential,  T977-1985, November,  1977, p. 1.

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Columbus' Growth Has Been Unique

Columbus has received considerable attention during the past few years at the state and national
levels concerning its recent evidence of growth.  Columbus has been identified as "the healthiest
of all Ohio's major urban areas and healthier than most of the nation's 85 largest cities. ^
Most recently,  Columbus has been singled out as "bucking" a statewide  trend of population
decline as well  as "leading the Pack" among 13 major midwest cities in terms of growth.**
Equally significant is Columbus' absence from lists of "cities in trouble."  Columbus is not
identified as a  city in trouble by at least six different sets of  criteria summarized in an article
published by the Academy For Contemporary Problems. °

In terms of the  socioeconomic well being of cities, Columbus has fared even better when compared
to other large metropolitan areas across the nation and is consistently better off than any of the
north-central and northeastern cities.  This point is emphasized by a research exercise conducted by
the National Planning Association which categorized the 40 largest cities as either (1) declining
and vulnerable, (2) declining but basically healthy, and (3) growing. '    Columbus was the only
city within the  northeast and northcentral  economic regions that was listed as a growing city.

The basis for these reports vary considerably. However, they are generally  related to the fiscal
well being of the city or they are an analysis of census related population figures that apply to
the entire Standard Metropolitan Statistical Area  (SMSA).  For example, the comments referring
to Columbus bucking the statewide trend of population decline is a survey of growth from 1970-
1976 of 13 SMSA's in the Midwest with population over 750,000; this survey is based on the
latest U.S. Census figures issued in December,  1977.  It should be noted that although the
Columbus S.M.S.A. (which contains the five counties of Delaware,  Fairfield, Franklin, Madison,
and Pickaway)  experienced the highest net growth in population during this  time period,  it also
experienced a loss of 3,400 residents as a  result of migration; Franklin County alone suffered a
loss of 22,200 residents as a result of migration.  Previous estimates by the Census Bureau shows
Columbus experiencing significant losses through migration which exceed natural  gains due to
favorable birth  to death rates.  The accuracy of these figures depicting losses due to migration
are considered  highly questionable by local officials.  As a result of this concern, local agencies
have jointly developed their  own estimates which are discussed on page  14 of this report.  These
local estimates  also show losses due to migration since  1974,  however, it is  not as extensive as
that shown by census information.  Regardless of the figures used, there  does appear to be a
leveling off of  local growth as a direct result of regional  and national trends, the difference  in
figures lies in the estimate as to when the growth began to  level off.
4
  Curtin,  Michael, "City Healthiest of 7 in Ohio,  Study Reveals".  The Columbus
  Dispatch, February 22,  1977.

~* Staff Writer, "Columbus Bucking Ohio Trend of Shrinking Metropolitan Areas."
  The Columbus Citizen Journal, January 1,  1978

6 Stanley, David I., "Cities in Trouble," Academy for Contemporary Problems,
  December, 1976.

7 Ibid p. 4.

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When compared to the balance of the S.M.S.A., Columbus as a central city begins to show
some weaknesses.  A "hardship index" prepared by the Brooking's Institute, for the purpose of
comparing cities based on "long  term  socioeconomic decline," indicates that Columbus is not
much better off than most other central cities in its ability to compete with its suburban areas.
It also ranks relatively high in average annual operating expenditures (for the years 1973-
1974) and in the number of local government employees per 1,000 residents,  two criteria  that
are characteristics of declining central cities with fiscal problems.  While it is highly debatable
that these criteria are meaningful measures of a city's fiscal well  being, they do serve to  high-
light the fact that Columbus' potential growth problems may be directly related to intraregional
movement and thereby associated more with local policy decisions.

These qualifications are being made in order to place Columbus' future growth potential in
perspective,  which is a primary focus of this report.  The fact that local policies are instru-
mental in the distribution of local growth makes it necessary that we understand the significance
of where growth is occurring locally.  Hence, the clarification of Columbus' growth versus
growth of the S.M.S.A.  Equally significant is an understanding that Columbus' growth has
been an exception to the rule. It apparently has not conformed to the growth patterns of  the
north-central and northeast economic regions.  While this is encouraging, it also raises the
issue as to how long Columbus can continue to "buck these trends."  It is the conclusion of this
report  that Columbus can anticipate a positive growth rate over the next twenty years although
it will  be significantly lower than that experienced during the fifties, sixties, and early
seventies.  This lower growth rate occurring in combination with a georgraphical area several
times larger than  the area in question in the early 1950's, will result in development charac-
teristics significantly different than those encountered  in the previous twenty years. These
chainging characteristics must be considered in decisions concerning future capital  improve-
ments and fiscal policies.

Several policy decisions will be  made in the near future concerning such issues as the region-
alization of the sewer system, annexations, bond issues for financing future capital investments,
changes in utility rates and energy conservation. Many of these factors can, as in  the past,
work as disincentives to the redevelopment of Columbus' innercity.  Given the fact that the
future growth of Columbus  is somewhat at the whim of national trends and a declining regional
economy, it is imperative that Columbus exercise considerable caution in these future decisions
which affect the distribution of local growth.

Columbus' greatest challenge, as the  central city of a  large metropolitan area, is to maintain
a positive growth rate and  remain fiscally healthy in an otherwise statewide declining economy.
The ma|or emphasis of  this  report is on the physical growth and development of the City of
Columbus.   However, it is becoming more and more evident that the nature and extent of
urban growth has  its greatest impact on the fiscal well  being of the city and thereby the quality
of life it can provide its residents.  Therefore, much of the discussion of the implications  of
physical growth will, out of necessity, be in terms of fiscal impacts.  Whereas this statement
concerns itself more with the geographical  distribution of growth and the ability of the city to
physically accommodate this growth, future statements, in anticipation  of capital improvements
bond issues, must address the fiscal implications and the city's ability to afford growth.
o
  Growth for the purpose of this report refers to residential growth and, therefore,  the physical
  expansion of the Columbus Metropolitan Area to accommodate population increases (increases
  in households).  The use of the terms "growth and development" refer to development of an
  urban character: residential subdivisions of a density in excess of one dwelling unit per acre.

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GROWTH POTENTIAL OF THE COLUMBUS METROPOLITAN AREA
Traditionally, there have been three factors that promote or allow development to occur
on an urban scale: transportation, water, and sewer facilities.  The freeway system within
the Columbus Metropolitan Area is for all practical purposes complete and, therefore, will
have little additional impact on development distribution over the next twenty-five years.
The two remaining freeway proposals, SR 315 and IR 670, are the result of existing develop-
ment or anticipated growth that will  occur for the most part regardless of the availability
of these facilities.  Arterials, within the surface street system, are generally not constructed
or upgraded until development is well underway and the resulting traffic justifies their need.
Consequently, the role of transportation (accessibility) in determining the location and
intensity of future growth is somewhat limited.

The water system also plays a  lesser role in determining growth because of the City's policy
to relate it to the availability of sewers. ?    The supply of water will not limit growth through
the year 2000.  However, the cost of providing water will have an impact on growth although
the impact will probably not be felt until after  1985.

Hence, for the purpose of this statement, an initial discussion of the growth potential of
Franklin County can be accomplished through an analysis of the existing and proposed service
areas of the City's sewer system.
Geographical Limits

There are no major physical barriers limiting the geographical expansion of the Columbus
Metropolitan Area. There are, however, practical limits that should be used in discussing
the potential for the future development of Columbus.  These limits are defined by the
drainage areas (watersheds) of six major streams that approximate the boundaries of Franklin
County.  These boundaries, the expanded planning area delineated in Figure  1, are  also
the designated planning area  for the Columbus Metropolitan  Facilities Plan (201 Facilities
Plan), a  twenty year capital  improvements program for updating and expanding the City's
sewer system, prepared for the U.S.E.P.A. in. accordance with  P.L.  92500.  The U.S.E.P.
A. finances 75% of the major sewer projects at the local level;  future projects will be
financed in accordance with  the final 201  Facilities Plan.

These boundaries reflect the two major constraints to  Columbus'  geographical  expansion:
economic realities and political considerations.  The designated planning area recognizes
the infeasibility of expanding to the east beyond the  Blacklick Creek watershed and  to the
west beyond the Hellbranch-Darby Creek watershed.  The cost of building pumping stations
or additional treatment facilities as part of the Columbus system cannot be justified at this
time.
   Department of Development, The City of Columbus, Development Policies Statement,
   December, 1973, p. 6.

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The fact that the northern boundary of the planning area basically follows the county line
recognizes the limited potential of annexing into another county; it is also an acknowledge-
ment of the 201 facilities planning program  in southern  Delaware County.  In the south-
eastern portion of Franklin County, there is a third 201  facilities planning effort (Canal
Winchester - Pickerington Facilities Plan) that complicates the possibilities of expanding
political jurisdictions beyond the Franklin County line.

The planning area of the Columbus 201 Facilities Plan,  therefore, defines practical geo-
graphical limits within which to discuss the  potential growth of the Columbus Metropolitan
Area.

Once the planning area is designated, it is  possible to determine the  capacity of the area
to accommodate future growth.  In order to  place Columbus' growth potential in perspective,
the approach herein is to consider the present potential  for accommodating growth based on
existing utilities, in the ground or otherwise committed, referred to as the existing develop-
ment area and then project a reasonable growth potential for the expanded planning area
shown  on Figure 1.
Capacity of Existing Development Area

The existing development area consists of those areas where sewers are existing or committed
through a legally binding agreement, if and when such service  is needed.  The existing
development area is delineated in Figure 2 and consists of the serviced and unserviced
portions of the City of Columbus and the incorporated suburban  municipalities under contract
with Columbus and the unincorporated areas that lie within these contract areas.  The
twenty suburban municipalities identified in Table 1 have contracted with the City of
Columbus which has agreed to accept and treat the  flow of sewage generated within these
contract areas.  The serviced portion of Columbus and suburban municipalities is that defined
by the Infiltration/Inflow Analysis Report which is part of the Columbus Metropolitan Area
Facilities Plan.  '"  The  remaining incorporated area of all municipalities is assumed to be
underdeveloped with the capacity for intense development of an urban character.  The
remainder of the development area,  the unincorporated portions of the sewer  contract areas,
is guaranteed sewer services upon annexation to a municipality.  It is assumed that these
areas are undeveloped.
   Malcom Pirnie, Inc., Infiltration/Inflow Analysis, Columbus Metropolitan Area
   Facilities Plan, July, 1975, Plate I.

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THIS ANALYSIS ASSUMES THAT THE EXISTING DEVELOPMENT AREA IS PRESENTLY
GUARANTEED THE NECESSARY FACILITIES THAT WOULD ALLOW, AND INDEED
PROMOTE, MORE INTENSE DEVELOPMENT THAN WOULD BE POSSIBLE  IN AN
UNINCORPORATED,  NONCONTRACT AREA.

Tables 1 and 2 provide a breakdown of the developed and underdeveloped acreage within
each of these sub areas.  The resulting figures are conservative estimates and an accurate
representation of the degree of development that exists as of April, 1976.  The results
indicate the availability of 187.5 square miles of underdeveloped land  in our defined
existing development area of the Columbus sewer system.  Seventy-eight (78.1) square
miles of underdeveloped  land exist within the City limits of Columbus; approximately
31 .25 square miles are within the serviced area defined by the Infiltration/Inflow Analysis
report.  Thirty-nine (39.1) square miles remained undeveloped within the suburban corpo-
ration limits, and  there are an additional 70 square miles within the sewer contract areas
that are yet to be incorporated.

There are several observations that can be made concerning this undeveloped land.  First,
with the exception of Westerville, all suburban municipalities, not already surrounded
by Columbus, have sufficient land  in the contract areas to at least double their present
size.  The fact that Westerville has "urbanized" approximately 80% of  its incorporated area
is indicative of its rapid  growth rate over the past decade. Secondly, there is an even distri-
bution  of undeveloped land throughout the analysis area (development area).  Of the incorpo-
rated undeveloped land,  approximately one-third is within Columbus' serviced area, one-third
is in the recently annexed areas, and one-third exists within the  suburban incorporated areas
which for the most part has been recently annexed. Third, in the unincorporated areas,
the contract areas (acreage) vary in size in proportion to the current size of the particular
communiiy:  the bigger the municipality, the bigger the contract area for expansion
purposes.

IN SUMMARY,  FROM THE STANDPOINT OF AVAILABLE LAND,  THERE APPEAR TO BE NO
RESTRICTIONS OR LIMITATION ON  ANY PARTICULAR MUNICIPALITY OR  GEOGRAPHICAL
AREAS AS FAR AS FUTURE EXPANSION POSSIBILITIES WITHIN THE EXISTING  DEVELOPMENT
AREA.
Capacity of Expanded Planning Area

The expanded planning area, as defined earlier, approximates the boundaries and area of
Franklin County.  The area within which the Columbus Metropolitan Area can reasonably
expect to expand, then,  is in the vicinity of 500 square miles.  This expanded planning
area is an increase of about 234 square miles (180%) over the previously discussed develop-
ment area. Table 3 breaks this land area down on a sewer interceptor basis which reflects
possible extensions of the sewer system as proposed by the facilities plan.  There is some
overlap between the existing contract areas and the proposed expansion areas as shown by
Figure 3.  Therefore, Table 3 distinguishes between those portions of the watershed (expansion
area)  that fcil within contract areas and the remaining land in the designated area.

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                           Table 2
                      Undeveloped Land By
                     Subareas of Urban Area
Subarea                                               Square Miles

Columbus                                                        78.1
  Serviced                                         31 .2
  Unserviced                                       46.9

Suburban Municipalities                                           39.1
  Serviced
  Unserviced

Contract Areas                                                   70.3
  Unincorporated

  Totals                                                        187.5
Source: Update and expansion of undeveloped land data presented in the
        appendicies of the Infiltration/Inflow Analysis/ Columbus Metropolitan
        Area Facilities Plan through an analysis of 1976 Aerial Photographs of
        Franklin County.
                             11

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In addition, there is a significant amount of unincorporated land that does not fall within
these interceptor areas.  This land is available for rural development or subject to annex-
ation to Columbus and thereby available for urban development. Either way it will accom-
modate some degree of development.  The figure in Table 3 represents the land necessary to
account for the remainder of the acreage within the 550 square mile expanded planning area.

AGAIN THE MAJOR OBSERVATION THAT CAN BE MADE IS THAT THE EXPANDED
PLANNING AREA IN NO WAY RESTRICTS OR FAVORS ONE AREA OF THE COUNTY
OVER ANOTHER.
                                       Table 3
                                    Square Miles In
                                Expanded Planning Area
    Interceptor
    Service Area

    Big Walnut
    Rocky Fork
    Blacklick North
    Blacklick South
    Groveport
    Southwest
    Big Run
    Scioto West
    Scioto East
    Brookside

    Subtotals

    Remaining
    Unincorporated Area
 Total Square
 Miles

 32.81
 17.86
 25.00
 26.16
  8.20
 44.74
 20.20
 38.02
  7.42
  3.90

224.31
Square Miles Within
Existing Contract
Areas

    2.34
    8.48

    10.54
    8.20
   31.25
    7.42
    2.34

   70.57
                  Total Area
Square Miles Beyond
Contract Areas

     30.47
      9.38
     25.00
     15.62

     44.74
     20.20
      6.77

      1.56

    153.74

     78.13
                                                 231.88
    Source:  Environmental Assessment,  Columbus Metropolitan Area Facilities Plan.
            Table 40, Population and Area Data, Page 169, July 1976.

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POPULATION, HOUSEHOLDS AND HOUSING
The Year 1974 Was A Critical Point In Local Growth

Some progress has been made during the past six months in clarifying the population picture
in the Mid-Ohio region.  The major problems associated with projecting future population were
the lack of understanding of what has happened at the local level since the 1970 census and
the need for a  reliable estimate of the current population. To remedy this situation, a task
force composed of representatives of the Mid-Ohio Regional  Planning Commission, the Columbus
Area Chamber  of Commerce,  the O.S.U. City and Regional  Planning Department, the City
of Columbus, and the Ohio Department of Transportation  was formed to  develop a methodology
for estimating local population.  The findings of this Population Task Force suggest that dramatic
changes in  the demography of Columbus and Franklin County have occurred since  1970.

As Table 4  below illustrates,  the population of Columbus  in January 1978 was 581,664 and the
population  of Franklin County was 904,175.  Although these figures indicate a 7.8 percent
and a 8.5 percent increase since the 1970 census in Columbus and Franklin County, respec-
tively,  an examination of the yearly changes in population demonstrates that most of these
increases occurred between April  1970 and January 1974.
Table 4  Population and Household Estimates,  1970-1978
         City of Columbus and Franklin County
                       City of Columbus
                                            Franklin County
 Date of
 Estimate

 April  1960

 April  1970
 Jan. 1971
 Jan. 1972
 Jan. 1973
 Jan. 1974

 Jan. 1975
 Jan. 1976
 Jan. 1977
 Jan. 1978
Population

471,316

539,677
540,601
551,289
558,669
573,252

575,100
576,935
578,338
581,664
Households

142,378

173,056
174,949
181,663
186,820
195,395

198,909
202,522
206,082
209,641
Population

682,962

833,249
846,308
861,811
878,885
896,850

899,975
897,058
901,640
904,175
Households

200,763

259,321
265,662
275,007
284,123
295,376

300,811
304,347
309,765
315,182
 Source:  Franklin County 1975 Population Estimates and Methodology, prepared by a
         joint committee composed of representatives from the Columbus Department
         of Development, the Mid-Ohio Regional  Planning Commission, the Columbus
         Area Chamber of Commerce, the C.S.U. City and Regional Planning Depart-
         ment, and the Ohio Department of Transportation, Revised November 21, 1977.
                                          13

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The City of Columbus grew by 33,575 people between April of 1970 and January 1974
(average: 8,953 people per year) and by only 8,412 people between  1974 and 1978
(average: 2,103 people per year).  Similiarly, Franklin County increased by 63,601
people between April 1970 and January 1974 (average:  16,960 people per year) and by
only 7,325 people between 1974 and 1978 (average: 1,831 people per year).  The  dramatic
change in local growth patterns is further illustrated in Figure 3 which charts annual
changes in growth indicators for all of Franklin County.
     10- -
     0
  Numbers.
  in 1000*.

     -3-i
                                                           Population Chanoe

                                                           Household Chame

                                                           Bui IH inn Perm!ts:
                                                           units authorized
          119701  119711 |1972|  |1973|  11974 | 119751  119761  119771

  Figure 3  Indicators of Growth    Franklin County 1970-1977

  Source:  Franklin County 1975 Population Estimates and Methodology, November 1977.
Thus, 80 percent of the growth in Columbus and 90 percent of the growth in Franklin County
between 1970 and  1978 occurred in the first half of this period.  Only 20 percent and 10 percent
of this increase in Columbus and Franklin County, respectively occurred after  1974.  It is obvious,
then, that 1974 was a critical point in local population change.  An examination of  the compo-
nents of population change (births, deaths,  and migration) shows that net migration was the deter-
mining factor of the area's net growth as the net natural increase has been stable since 1970.
Prior to 1974 both Columbus and Franklin County experienced a net inmigration, but after 1974
both experienced a net outmigration resulting  in a similar pattern for net population change
(Figure 4).

It is also evident from these figures that Columbus has, at a minimum, kept pace with county
growth and has even increased when county population showed an absolute decline.  Between
1975 and 1976, for example,  Franklin County had an absolute decrease of 2,917 people while
the City of Columbus grew by 1,835 people.

                                           14

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                                                          4 Net Natural Increase

                                                            Net Population Change
                                                            Net Migration
 numbers 1970
 in 1000't
1971
1972    1973    1974    1975    1976    1977
 Figure 4 Components Of Population Change, Franklin County 1970-1977

 Source:  Franklin County 1975 Population Estimates and Methodology, November 1977.


Household Growth Has Not Leveled Off As Sharply

Population increases in both the City of Columbus and Franklin County declined after 1974.
Household increases,  although following a similar trend,  did not level off as sharply. While
the population of Columbus increased by an average of 2, 103 persons per year between 1974
and 1978, households increased at an average of 3,562 households per year during this same
period.  The high rate of household growth in  relation to population growth is  primarily a
reflection of changing living patterns as indicated by a declining average household size.
Declining household size, a characteristic of national as well  as local trends,  is partially a
function of the falling birth rate, reflected in the decreasing average numbers of persons under
18 years old in households and the increasing proportion of one and two person households as
reflected by the increasing numbers of people  who choose to live alone, the increasing numbers
of people who have postponed marriage, the increasing numbers of divorced people and the
increasing proportion of persons over age 65.
Local Forecasts Show Area Growth

The significance of these demographic changes in Columbus and Franklin County lies in the
implications which may be drawn for both long and short-term growth projections.

In the long-run, even under optimistic assumptions about the  growth of local employment,
declining fertility rates, as reflected in the U.S. Census series II forecasts, will somewhat
limit the potential of population and household growth in the Columbus  and Franklin County
area. Although recent projections by Battelle Memorial Institute suggest that Franklin

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County's population will remain relatively stable over the next 22 years, the Population Task
Force has established a more optimistic, interim forecast of 1,025,800 people in Franklin
County by the year 2000 (Figure 5).  This interim forecast assumes an average annual  rate of
growth of 0.57 percent, a substantial increase over the 0.20 percent average annual rate  of
growth experienced in the County between 1974 and 1978.  If both birth and death rates
follow recent trends, the 0.57 percent average annual growth rate implies continued out-
migration, but at a rate below that experienced during the 1974-1978 period.  In fact,  the
forecast would imply an average increase  in Franklin County's population of 5,528 people
per year for the  next 22 years.
    1100
    10001
                         1970    1974    1978
  Figure 5 Population Trends And Year 2000 Forecast

  Source:  City of Columbus, Department of Development
In the short-run, through 1985, the increases in total households relative to a stabilized
population, reflected in a declining household size, should continue the demand for new
construction and rehabilitation of housing units.  The demand for new housing units in the
City during this period should be accompanied by an equal demand for utility hook-ups such
as sewer,  water, gas and/or electricity and telephone.  Consumption of these services, how-
ever, can be expected to decline slightly as the number oT people per household declines.

A straight line breakdown of the household forecast by five year increments, based on the
year 2000 control totals of 396,500 and 264,200 for the county and city, are shown in
Table 5 and Table 6.  These forecasts indicate a reduced, but steady rate of household
growth which will continue the demand for new housing construction in Columbus and Franklin
County.

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Table 5        Population and Household Forecast,  1978-2000
              City of Columbus, Ohio
Year

1978

1980
1985
1990
1995
2000
Total         Household
Households   Size

209,641      2.64
214,600
227,000
239,400
251,800
264,200
2.59
2.46
2.40
2.39
2.38
             Population in
             Households

              553,452

              555,814
              558,420
              574,560
              601,802
              628,600
                 Population in
                 Group Quarters

                   28,212

                   28,300
                   28,800
                   30,000
                   30,000
                   30,000
                  Total
                  Population

                  581,664

                  584,114
                  587,220
                  604,560
                  631,802
                  658,600
Table 6
Year

1978

1980
1985
1990
1995
2000
Population and Household Forecast,  1978-2000
Franklin County, Ohio
Total         Household
Households   Size
315,172

322,574
341,054
359,534
378,014
396,500
2.76

2.71
2.58
2.52
2.51
2.50
Population in
Households

 869,875

 874,176
 878,919
 906,026
 948,815
 990,800
Population in
Group Quarters

   34,300

   35,000
   35,000
   35,000
   35,000
   35,000
  Total
  Population

  904,175

  909,176
  914,919
  941,026
  983,815
1,025,800
Household Growth Creates a Demand for New Housing
Net household growth between 1978 and 1985 is forecast to average 2480 and 3696 house-
holds per year for Columbus and Franklin County respectfully.  The net demand for housing
is estimated to be 2,730 new units in Columbus and 4,071 new units in Franklin County as
a whole each year for the next seven years (Table 7).
                                      ?7

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Table 7       Basic Factors in New Housing Production, 1978-1985
              Columbus and Franklin County,  Ohio

                          City of Columbus                   Franklin County
Total
Units
17,360
17,360
1,747
19,107
Single-
Family
7,482
818
8,300
Multi-
Family

9,878
929
10,807
Total
Units
25,872
25,872
2,625
28,497
Single
Family
14, 178
1,412
15,590
Multi-
Family
11,694
1,213
12,907
A. Household Growth

B. Tenure Split 1
                     2
C. Replacement Factor

D. Net Demand

E. Average Annual
    Demand                2,730  1,186     1,544           4,071     2,227     1,844

  Based on 1974-1978 new construction averages
f\
  Based on normal losses of 0.1% per year

The impact of changing demographic conditions in Columbus and Franklin County can be seen
in the related forecast of new housing  demand. If the assumptions guiding the forecast are
realized, the average annual demand for new housing construction will be below that experienced
between 1970 and 1973 and even below that experienced between 1974 and 1977 (see Table 8), the
period  of low construction activity.


Table 8       Units Authorized by Permit and Demand Forecast
              Columbus and Franklin County, Ohio
                          City of Columbus                  Franklin County
                          1970--73    1974-'77  1978--85     1970--73   1974--77   1978-'8i
Total Permits
 Avg. Annual

Demand Forecast
 Avg. Annual
35,476
8,869

12,846
3,212


19,107
2,730
48, 149
12,037

19,067
4,767


28,497
4,071
                                     18

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Annexations Increase City's Size By 5 Square Miles


Through the first half of 1978, the City of Columbus has increased its geographical area
one and a half (1 1/2) square miles, from 174.5 to 176.1 square miles.  An additional
4.7 square miles (3000+ acres) has been approved for annexation to Columbus by the County
Commissioners and it is anticipated that these annexations will be accepted by City Council.
Thus, by the end of the third quarter of 1978,  the geographical area of the City of Columbus
will  be in excess of  180 square miles.

These figures represent a significant upswing in the number of annexation applications as
well as number of acres over the previous two years.  This increase in activity probably
reflects the recovery from the economic recession experienced from 1974 through 1976.

One of the largest annexations in several years, the  Hartman Farms,  is located in south central
Franklin County, an area  that was previously defined as a relatively inactive growth area.
This annexation is  the culmination of many months of preparation and ground work with little
significance associated with the  timing.  It is not anticipated that the area will pick up
significantly in development activity through 1985 as a result of this annexation or any
other activity  in the area.

The most interesting and significant development relative to annexations occurred in the north-
eastern portion of the city and county, an area previously defined as an active growth area.
The annexation activity in the northeast, which included two relatively large annexations in
the vicinity of 500 acres each, does not reflect a sudden development potential in Columbus;
rather  they are reactions to an attempt to contain urban  expansion in this area.  Residents of
Plain Township initiated a referendum, which appeared on the June ballot, that would permit
the City of New Albany to pursue the annexation of  the remaining unincorporated area within
Plain Township. The referendum was narrowly defeated. This effort and  its near success
indicate a desire by many residents in the vicinity of New Albany not to  take on an urban
character.  Therefore, the probability of the entire sewer contract area of New Albany
experiencing urban development through the year 2000,  as  previously thought, is somewhat
remote.  Figure 6, defining active growth areas, has been revised to reflect that annexation
potential through 1985, and development potential through the year 2000 will be limited to
west of New Albany Road.

Accommodating Growth

The ability of  the existing and anticipated city limits to accommodate growth  is extensive.
Based on the methodology utilized by the MORPC report entitled "Potential Residential
Development:  Columbus and 20 Adjacent Municipalities," and updating the information to
reflect the  Columbus corporate limits of 180 square miles (refer to the previous section) and
the enclosed population projections, it can be shown that there is now sufficient residential
acreage available  to accommodate growth through the year 2030.  Similarly,  on a metro-
politan basis the updated information presented in this report indicates that the existing
development area could accommodate projected growth through the year 2025.  The existing
development area is therefore, capable of accommodating over 50 years of anticipated growth.
                                        19

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Considering the expanded planning area as the future metropolitan or urban area and applying
the above methodology, there could be in excess of 164 square miles (105,000 acres) that
would develop residentially.  This acreage would accommodate  conservatively 1,500,000 people.
It is difficult at this point in time, based on current growth patterns,  to perceive when, if
ever, Franklin County will reach a population of 1,500,000.
                                         21

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"UNKNOWNS" AFFECTING  GROWTH


There are three other major factors that may have a substantial impact on the future growth and
development patterns of the City of Columbus:  the Columbus school desegregation suit, the
"energy crisis",  and federal policies.  The full impact of these issues is unknown at this
point. However, it is the purpose of this report to anticipate and account for any impacts
that may occur to the greatest extent possible.


School Desegregation

There will be some impact on the City's growth potential within the first five years of the
implementation of the school desegregation  plan. The possible impacts consist of:  a more
pronounced outmigration from the inner city; less new development (filling-in) of the
inner  city; and a lessening of property values of the inner city.  Therefore, we should anti-
cipate a temporary increased outmigration from the inner city. This migration should be
tempered by the increased costs of housing  in suburban areas, thereby further reducing the
mobility and housing opportunities of middle income families, reinforcing a trend that
already exists. The temporariness of this shift is also due to the initial uncertainty of the
desegregation  plan. Within a reasonable period of time the situation should stabilize at
which time this issue will have a minimal impact on demographic trends in Franklin County.
THEREFORE, THE DURATION AND INTENSITY OF THE IMPACT OF THE DESEGREGATION
PLAN WILL BE TEMPORARY AND LIMITED.
Future Energy Supply Is Uncertain

The most confusing factor continues to be the potential impact of the "energy crisis" on
growth of the Columbus Metropolitan Area.  One certainity, however, that can now be
anticipated, is the heavy involvement of federal and state government.  The City of Columbus
recently submitted an application for a federal  grant in order to,  among other things, define
the nature of the energy crisis in Central Ohio and to determine what, if any, action can be
taken by local governments to adjust to potential energy impacts.

 The Columbus Metropolitan /rea has encountered various energy related problems during the
 past few years.  In addition to the effects of the international oil embargo,  this area has
 witnessed shortages and interruptions in  the supply of natural gas and electricity.  The
 results have varied from inconveniences to residential homes to permanent loss of jobs and
 future employment opportunities.   It is assumed that such interruptions and shortages will
 continue to be experienced in the future.  It is further assumed that these "energy crises"
 have a lasting impact on the  region's economy. A recent study published by the Academy
 for Contemporary Problems concluded that the  loss of manufacturing and associated employ-
 ment opportunities was primarily due to  a high death rate of firms and the inability to replace
 these firms, rather than an actual migration of firms to the "sunbelt." ^  It appears that the
    Jusenius, Carol L. and Ledebur, Larry, The Migration of Firms and Workers in Ohio,
    1970-1975, Academy of Contemporary Problems, p. 14
                                          22

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shortages and interruptions in the supply of natural gas and electricity over the past few
years has been instrumental in an excessive death rate of industries.  The availability and
cost of energy may be a major factor in the lack of establishing new industries. The energy
crisis, then, appears to have an existing impact on economic growth and employment
opportunites.

Therefore,  energy, its availability, accessibility,  and cost, is a key factor in local growth.
On a regional basis, the supply is the major energy problem as the overall growth of the
metropolitan area  is dependent upon national and regional trends.  Within the metropolitan
area cost is very significant in the spatial distribution of development which in turn has
tremendous implications on requirements for capital improvements and city services.

It is anticipated that the cost of energy will continue to rise.  This increased  cost will,
within five to ten  years, have significant impacts on  the pattern of development in the
metropolitan area. First, the shortage will continue  to limit the growth potential for the
Mid-Oh'o region resulting in a continuation of the lower growth rates through the year
2000.  Second, the increased costs  of transportation  (automobile) will discourage  continued
wide spread low density residential  patterns while encouraging "filling-in" of the existing
urban area. Third, the  increased cost of utilities will make it substantially more expensive
to maintain a residence  in the rural  areas of the  county.
 Dangerous Precedent Being Set By U.S.E.P.A.

 The policies of the Federal government continue to be the one element that could have
 the most significant impact on local growth, at least in the immediate future.  Federal
 policy is the one factor that can have a  significant impact on both national trends that
 influence local growth potential and the distribution of growth at the local level.  The
 publication of the U.S.E.P.A.'s Environmental Impact Statement (E.I.S.) emphasized the
 potential level of involvement that could be expected of the Federal government.  The
 U.S.E.P.A. has obviously chosen to use the fact that it pays for 75% of the major sewer
 projects in the Columbus Metropolitan Area to attempt to manipulate local development
 and growth.  This is not only a dangerous precedent, but it is based on a highly question-
 able study.

 Generally, the summary of secondary impacts of the E.I.S. reflect the characteristics of
 Central Ohio's existing and anticipated growth.  The most significant point is the final
 assumption which states that,  "The ability of the area's economy to support additional
 popularion and the adequacy of water supplies may be more significant determinants of
 population growth and development patterns than availability of public sewer services."  '
 The fact is that the sewer system as well  as  the water distribution system will  have little
 if any impact on the region's growth potential.  It could,  however, significantly affect
 the distribution of future growth.  With this recognition, the E.I.S.  proceeds to use the
  U.S.E.P.A., Region V, Draft Environmental Impact Statement, Wastewoter Treatment
  Facilities for rhe Metropolitan Area, Columbus, Ohio, February,  1978, p. VII-2.
                                         23

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expansion of the sewer system as a means of manipulating local growth.  This is being
done with a minimal understanding of the local area's economy (economic growth potential)
and with very selective and arbitrary concerns about why growth should or should not
occur in any particular subarea.

The population and area densities are the most serious shortcomings of the E.l.S. relative
to the secondary impact analysis.  The population control figure of 1.11 million is acceptable
as being "within the range" of population control figures being used by this statement
for the Columbus Metropolitan Area. However, the breakdown of this control number by
the eleven subareas is highly questionable.  First, there is no documentation as to how
they accomplish this breakdown.  It is apparently, at best, a guess. Secondly, these
subarea estimates are inconsistent with the disaggregation of population presented in this
document.  The most obvious area of concern  is  in the Blacklick watershed subarea. The
E.l.S. relates to the entire watershed whereas the Facilities Plan basically programmed a
sewer for only the southern half.  It is important to realize that there is a significant
difference between the northern half and southern half of the watershed relative to  growth
potential.  The year 2000 population projection of 41,800 presented in the E.l.S. is
comparable with the allocation used by this document.  However, over 90%  of the
projected population falls within the southern portion of the Blacklick watershed, from
Reynoldsburg on downstream.  The resulting densities for the lower  half, then would be
in excess of 2 persons per acre which appears  to be a critical criterion used in the E.l.S.
to justify a sewer line.  This report identifies  southeast Columbus as a major growth area
over the next twenty years, particularly that portion of the Blacklick watershed downstream
of Reynoldsburg.   It is  the conclusion of this report that the best alternative for providing
immediate relief for Reynoldsburg is a continuation of the Blacklick interceptor as proposed
in the Facilities Plan; this approach will also  address the long-term needs of  southeast
Columbus.

The most significant point that should be made is that the  City of Columbus is in a position
to make the best determination as to the potential and location of its future growth.  The
local concern is for as  comprehensive an understanding and anlysis as possible.   Specifically,
at the local level, Columbus must consider the concerns of various other Federal programs
from HUD, Department of Energy,  Department of Transportation,  etc.  In addition, there
are several additional local forces and issues that must be considered, the least of which are
the impacts of a school desegregation suit and the long term fiscal implications of providing
a wide spectrum of services in addition to the  sewer system. The U.S.E.P.A. through this
E.l.S. has expressed a  concern for only a few aspects of growth,  some of which are questionable
such as the urbanization of agricultural  land.  It is also highly questionable that the heavy
reliance upon a centralized sewer system at very low densities (2 persons/acre)  is consistent
with energy conservation and growth management objectives.

In conclusion, there appears to be considerable doubt as to the reliability of the E.l.S.
secondary impact analysis.  Based on this concern, the tone of the E.l.S. that a Facilities
Plan should be used by  a Federal agency to manage local growth is  highly suspect and
inherently dangerous.  The City of Columbus is far more capable of determining and dealing
with its own growth potential. Considerable thought should be given to the implications of
this very fundamental relationship between the Federal Government and local jurisdictions.
                                         24

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GROWTH PROJECTIONS
The intent of this section is to identify where growth is presently occuring and likely to
continue through  1985 in order that the City can properly plan its capital improvements.
The projections and recommendations pertain only to the City of Columbus and areas
within which it is likely to experience annexation pressures.

Active Growth Areas

THE GROWTH AREAS OF THE COLUMBUS  METROPOLITAN AREA THROUGH  1985
WILL  CONTINUE TO BE IN THE NORTHERN PORTIONS OF THE COUNTY AND
SOUTHEAST COLUMBUS.

Development in the northwest and southeast will primarily occur within the Columbus city
limits (Refer to Figure 7).  Northeast development will center around Westerville and
northeast Columbus.  By 1985, development will shift almost entirely to the City of Columbus.
Westerville, with no apparent intent to expand its city limits,  is rapidly utilizing its
developable land. This fact in combination with the "anti-urban development"  atmosphere
of Plain Township necessitates that urban development occur within the City of Columbus.
It  is anticipated,  therefore, that significant annexation pressure will continue in the area
between S.R.  161 and Central College  Road west of  New Albany. The City recently
rezoned 100 acres of land in the vicinity of S.R.  161 and Hamilton Road to accommodate
a future regional shopping center.  This was an effort to establish similar zoning previously
held in  the county thereby protecting the area's future  commercial development  potential.
Development of this regional facility is not  anticipated for several years until sufficient
residential growth warrants such a facility.  Extensive residential growth within  Columbus'
city limits beyond the outerbelt (1-270) is not anticipated before the mid 1980's.

The key to actual development of land within the Columbus City limits is the availability
of sewers.  The anticipated growth in the area can be easily accommodated by the first
phase of the Rocky Fork interceptor as proposed by the  Columbus Metropolitan Facilities
Plan.  This phase would also accommodate anticipated  annexations in  the area as well.

The southeast continues to show a great deal of promise for developmert activity in the
future.  Major rezoning activity  is occuring in the area which will support development
for several years into the future.  Initial development will primarily consist of single
family units. The area, with extensive flood plain areas resulting in permanent open space
and excellent accessibility via the freeway  system and  major arterials, lends itself to
multi-family, medium density development.  The major question relative to future multi-
family development is the area's  location relative to downtown and other employment
centers.
                                       25

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Table 9 presents a summary of population and dwelling unit '* growth for the year 2000 on
a planning area basis which in turn are grouped by quadrants.  The figures shown are only
for those portions of the planning areas that fall within the Columbus city boundaries
anticipated for the year 2000 (Figure 8).  A characteristic of these figures that is immediately
apparent is the impact of the reduced household size.  While every planning area shows
growth or maintains the existing number of dwelling units, nearly a third of the planning
areas (eight) reflect an actual loss in population.  Thus,  many of the developed areas of
the inner city, while not experiencing an overall loss in total dwelling units will experience
substantial losses in population.  The hardest hit areas are the near north and near east
sides which are the most intensely developed.

There are some figures in Table 9 that are in conflict with other statements in this document.
Planning Areas 7 and 26 stand out as being exceptionally high and tend to distort the overall
growth picture at the quadrant and county  levels.  Presently, there is very little development
activity on the west side and particularly in these two planning areas.  It is the contention
of this statement that the west and particularly the southwest portions of the city will  remain
relatively inactive through 1985 and probably through the year 2000.  One explanation for
these high figures is that the control totals for the county and city (1,025,000 and 658,600
respectively) may be excessive

The combination of the above two factors also distorts the relative growth potential on a
quadrant basis.  The southwest quadrant is shown gaining a substantially higher percentage
of new growth than the southeast quadrant. This is due to the excessively high rate of
growth in Planning Area 26 as well as the relatively high population loss (15,000) in the
inner city portions of the southeast quadrant.

The most appropriate step for overcoming these discrepancies would be to determine a more
acceptable control total and to make the necessary adjustments to redistribute the population
more accurately.  However,  the present commitment to the county total of 1,025,000 and
the lack of opportunity to rerun  the distribution of the population necessitates that, for the
purpose of this report,  the available figures be used and  qualified where necessary.

Table 9, therefore, should be qualified such that Planning Areas 7 and 26  (within the
Columbus city limits) show a gain of only 8,500 and 5,000 respectively.  The results would
show the northwest and northeast gaining nearly equal amounts of future growth and the
southwest quadrant receiving the least amount of new growth.  This change would also
result in Planning Areas 25, 6, 2 and 12 gaining the greatest amount of new growth.  These
distribution figures would more accurately  represent the anticipated future growth picture.
  Dwelling units (equivalent to the housing stock) include both occupied housing units
  (equivaU"* to households) and vacant housing units (assumed to be 4.0 percent of the
  housing srock).
                                         27

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Table 9     Population and Dwelling Unit  Distribution
               City of Columbus
                                               Population
                                                   Dwelling Units
Northeast Quadrant

Planning Area
3
4
6
11
12
14
Total
Northwest Quadrant

Planning Area
2
5
7
8
9
10
13
Total
Southwest Quadrant

Planning Area
15
16
17
26
Total
Southeast Quadrant
Downtown
Area Totals

Planning Area
19
20
21
22
23
24
25
27
Total
Planning Area
18
Total
Less
Unincorporated *
1974
892
2,254
44,672
65,240
11,280
34,329
158,667
1974
4,661
12,697
1,673
4,426
24,700
38,476
81,264
167,897
1974
67,585
16,293
10,356
3,821
98,055
1974
40,434
58,711
9,033
58,491
15,083
8,966
15,755
621
207,094
1974
6,787
6,787
638,500
80,069
2000
5,075
10,791
57,507
59,188
23,769
30,886
187,216
2000
17,350
17,350
20,330
14,364
27,759
33,905
78,973
210,031
2000
69,571
14,844
12,811
18,927
116,153
2000
37, 105
52,104
12,053
53,938
17,139
10,678
28,839
5,989
217,845
2000
11,464
11,464
742,709
84,109
Change
4,183
8,537
12,835
-6,052
12,489
-3,443
28,549
Grange
12,689
4,653
18,657
9,938
3,059
-4,571
-2,291
42,134
Change
1,986
-1,449
2,455
15,106
18,098
Change
-3,329
-6,607
3,020
-4,553
2,056
1,712
13,084
5,368
'0,751
Change
4,677
4,677
104,209
4,040
•\ of Total
4.0
8.2
12.3
12 0
27.4
'- of Total
12.2
4.5
17.9
9.5
2.9
40.5
°- of Total
1.9
2.4
14.5
17.4
-: of Total
2.9
2.0
1.6
12.6
5.2
10.3
s- of Total
4.5
4.5
1974
355
861
14,135
22.306
3,365
12,040
53,562
1974
1,319
4,818
554
1,529
10,256
13,471
33,793
65,740
1974
22,161
5,941
3,595
1,253
32,950
1974
16,275
19,763
3,331
21,978
4,828
2,975
5,700
210
75,060
1974
3,570
3,570
230,882
27,346
:ooo
2.060
4,674
22,952
23,260
9.381
12,311
74,638
2000
6,729
7.548
8,128
5,854
11,772
13.471
34,655
88,157
2000
27,352
6,259
5,218
7,637
46,466
2000
16,275
20,159
5,060
21,978
6,394
4,137
12,524
2,411
88,938
2000
5.740
5.740
303,939
28.730
Change
1,705
3,813
8,817
954
5,516
271
21,076
Change
5,410
2,730
7,574
4.325
1,516
0
862
22,417
Change
5,191
318
1,623
6,384
13,516
Change
0
396
1,729
0
1,566
1,162
6,824
2,201
13,878
Change
2,170
',170
73,057
1.384
°, of Total
2.4
5.2
12.1
1.3
7.6
0.4
28.8
°c of Total
7.4
3.7
10.4
5.9
2.1
0
1.2
30.7
°~ of Total
7.1
0.4
2.2
8.7
18.5
cc of Total
0
0.5
2.4'
0
2.1
1.6
9.3
3.0
19.0,
3- ot Total
3.0
3.0
City Total
                                 558,431   658,600  100,169
                                                                                          203,536   275,109  71,673
            •Includes:
             Perry Township - Planning Areas 2 4, 5
             Sharon Township - Planning Area 3
             Clinton Township - Planning Areas 9 4 11
MtFFlin Township - Planning Area 12
Franklin Township - Planning Areas 15 & 17
 Source:   Deportment of Develooment; Adopted From MCRPC's Tnp Generation Vonobles  For The Year 2000, May 1978.

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Limited Growth Areas

More significant perhaps are the areas that will experience little urban development or that
should not be developed in  the near future. It is important to identify those areas where
there is minimal growth potential overall in order to prevent piecemeal commitments that
could in the long run commit the City to costly and widespread capital  improvements and
urban services.

THE MOST OBVIOUS AREA THAT SHOULD BE DISCOURAGED FROM DEVELOPING IN
AN  URBAN CHARACTER IS THE BIG DARBY-HELLBRANCH WATERSHED IN THE FAR
WESTERN PORTION OF THE COUNTY.  Extensive development of this area will eventually
require costly pumping facilities in order to tie the area into the Columbus system or a sepa-
rate collection system and treatment facility.  Secondly, the area has extensive drainage
problems that must be resolved  before development occurs.  Finally, the western half of the
county  is presently the least active growth area overall.  There already exists sufficient
incorporated area to accommodate projected growth.  Therefore, there is no justification for
any  municipality in the  foreseeable future to annex into this drainage basin and thereby
encourage urban development.  Development should be limited to sparsely  settled patterns
where drainage, water quality, and water supply can  be handled on an individual  basis.

TWO ADDITIONAL AREAS THAT  SHOULD NOT BE ENCOURAGED TO DEVELOP TO AN
URBAN CHARACTER ARE THE BIG WALNUT AND NORTH BLACKLICK AREAS IN THE
EXTREME NORTHEAST PORTIONS OF THE COUNTY.  The growth potential  for these areas
is not great in the near future and the availability of sewers would probably not change the
character and type of growth significantly.  The following reasons are given for this conclu-
sion:

     (1)  These areas are somewhat removed from the existing urban area with half of the
         area lying outside  of Franklin County;

     (2) Annexation to either Westerville or New Albany is unlikely.  Westerville's eastern
        boundary for "annexable area" is Big Walnut Creek; New Albany's expansion will
        be  accommodated within the Rocky Fork  drainage area;

     (3)  They are the least accessible of all the expansion areas being considered herein;

     (4)  There is a great deal of undeveloped land in the adjacent and "closer-in" urban
        areas of Columbus, Gahanna, and Westerville; and,

     (5)  With the availability of sewers in south-central  Delaware  County,  it is unlikely
        that portions of Big Walnut and Blacklick areas that lie within Delaware County
        will develop as  extensively or as rapidly.

Urban development would necessitate the extension of the Big Walnut and Blacklick inter-
ceptors.  Based on the above factors this investment cannot  be justified through the year
2000.  Therefore, piecemeal and scattered  urban development and annexations should be
discouraged.
                                        30

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 The publication of the E.I.S. by the U.S.E.P.A.  did serve to highlight a potential need for
 a sanitary sewer.  The E.I.S. proposed delaying the construction of the Big Walnut Interceptor
 Sewer along the east side of the Hoover Reservoir, a recommendation made in the first growth
 statement.  In response to the E.I.S.,  the City Division of Sewerage and Drainage noted that,
 "This decision seriously endangers the  City's present and future drinking water supply by in-
 creasing the probability of contamination by untreated sewage." 14  A review of the area
 ind'cates that there may be as many as 700 septic tanks and eight package treatment plants
 operating in inadequate soil  conditions. The area, however, is not anticipated to grow
 significantly.  There  is, therefore, a question raised as to the need for a central sanitary
 sewer for purposes of  water quality rather than to serve anticipated urban development.  The
 iss-je raises several questions. On the  one hand, will the availability of a sewer tend to
 increase growth in the area  (thereby attracting it from another "sewered area") resulting in
 a continuation of metropolitan wide sprawl at low densities.  On the other hand,  if growth
 does not occur, as predicted, who will pay for the installation of the sewer?  And finally,
 is it even possible to  force existing area residents on to the system in  order to resolve the
 ground water contamination problem?

 There appear to be no answers to these  questions at this point in time. Before a  decision is
 made to build or not build the Big  Walnut Interceptor extension,  a  comprehensive study should
 be made to  include: an analysis of the  ability of the proposed sewer to solve the existing
 problem; the costs to  specific groups of tax payers;  and, secondary  impacts on growth distri-
 bution.


 In addition  to the availability of utilities a major indicator of the likelihood of growth in
 a particular area can  be its ownership pattern.  The ownership pattern of two areas within
 the existing development area,  the extreme northwest,  west of 1-270  between Dublin and
 Milliard, and  the area immediately east of Gahanna, stands out because it indicates no
 evidence of growth pressures. Unlike the southeast and New Albany areas where the anti-
 cipation of a sanitary sewer  interceptor has encouraged major developers to purchase land
 thereby enhancing its development potential, the above areas have not  experienced similar
 activity.  BECAUSE OF THESE FACTORS, THE UNAVAILABILITY OF SEWERS (OR OTHER
 UTILITIES) AND THE  ABSENCEOF DEVELOPMENT PRESSURE AS THE RESULT OF LAND
 INVESTMENTS, THESE TWO AREAS WILL NOT EXPERIENCE URBAN DEVELOPMENT
THROUGH THE YEAR 1985.  If sewers  were  constructed, it is likely that  interest and
 investment in the area would follow. Therefore, sewer construction should not be considered
through 1985 and it is likely that the need for sewers cannot be justified through the year
2000.

Finally, it should be noted that within  the existing  urban area that  is  serviced (within
incorporated boundaries), the western and southern  portions will continue to exhibit a mini-
mum amount of development  activity similar to what has been experienced over the past few
years.  Although a great deal of residential platting and zoning activity has occured, it is
not anticipated that actual development will  pick up  significantly.
   Department of Public Service, City of Columbus, Review of U.S.E.P.A.  Region V,
   Draft Environmental  Impact Statement, Wastewater Treatment Facilities for the
   Metropolitan, Area Columbus, Ohio, March 1978, p. 3.


                                         31

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In summary it should be reemphasized that these growth projections are primarily for the
purpose of assisting  capital  improvements programming through 1985.  References to the year
2000 are made where the short term trend is expected to continue.  Obviously, a reevalua-
tion of needs for 1985 through 2000 should be made in the early 80's that would consider 1980
census information and the current  economic growth potential.
                                          32

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  SUMMARY STATEMENT

  Regional Goals
  It is the intent of this report that the policy recommendations for Columbus be developed
  within a regional context.

  Since 1965 seventeen publications have been prepared in an attempt to establish goals
  directing the future growth and development of the Mid-Ohio region. The vast majority
  of these attempts at goal  identification were the result of staff efforts at MORPC and DOD.
  There was however, a significant effort in 1965 to obtain citizen input through the County's
  "Blue Plan";  "^   there have also been two recent efforts to update and pursue additional
  citizen input, MORPC's Year 2000 Goals and Objectives and Columbus' Overall Economic
  Development Plan.  A comparison of these efforts over a ten year period provides rather
  interesting results.  First, there is a great deal of consistency over  the ten year  period.
  And second, these efforts have done very  little to provide direction (state  priorities) for the
  establishment of policies  and programs.  One reason contributing to both of these factors is
  that a goal is merely a generalized statement of a desired end.  It is seldon specific enough
  to provide direction or comparison. Furthermore, the primary concern for  widespread citi-
  zen  participation forces a product that runs  the gamut of general ideas.  It is obvious, how-
  ever,  that over a period of time peoples' ideas do  not change significantly.  It is for these
  reasons that the policies  identified in  this report are felt to be reflective of citizens general
  desires at  the regional level.
  Opportunities
  The various efforts at goal identification do appear to have an underlying theme:

      To achieve a better way of life for all people living  in the region, assuring
      access to opportunities for personal development and for participation in
      community affairs.  '
   Franklin County Regional Planning Commission, Summary of Columbus Seminars for the
   Blue Plan, July, 1965.

^ Franklin County Regional Planning Commission, Summary of Columbus Seminars for the
   Blue Plan, July, 1965, p. 8.
                                          33

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If in fact the overriding goal of the citizenry of this region is to improve the quality of
life, the major conclusion of this report is that THE NEXT TEN TO TWENTY YEARS OFFERS
AN EXCELLENT OPPORTUNITY TO IMPROVE THE QUALITY OF WHAT EXISTS.  There will
be no tremendous pressures or demands on the existing sewer,  water and transportation
systems.  Growth potential is limited:  the looming energy crisis will probably further limit
and at least  concentrate future development.  Given these expectations, the following recommen-
dations reflect the need to reaffirm those policies of the past  and  to articulate new policies that
direct the City's efforts toward improving what we have and encouraging future growth to occur
within reasonable and manageable urban boundaries.

To this end,  it is necessary to define reasonable boundaries for accommodating growth through
1985.  Figure-9 delineates the  area that should approximate the service limits of the  Columbus
Metropolitan Area: the area within which urban development through  1985 should be encouraged
and will most likely occur. The dashed boundaries indicate that annexation and urban develop-
ment beyond these areas is appropriate only if it can be accomplished without the eventual
construction or extension of an interceptor or subtrunk sewer.  Piecemeal development should be
permitted only if it doesn't commit the City to substantial capital improvements and costly urban
services.  It is further assumed  that within this boundary the entire area (including and
specifically  the contract areas  in the southern portion of the County) can be serviced without
further expansion of interceptors and subtrunks beyond those identified in the 1979-1984 Capital
Improvements Program.
                                          34

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SUMMARY OF RECOMMENDATIONS

I.   All development of an urban nature should occur within an incorporated municipality
     that is within the defined 1985 Urban Area.  The concept of a "sewer freeze" should be
     continued whereby Columbus requires annexation of a parcel of land to the City or a
     municipality under contract to the City as a prerequisite for access to the sewer and water
     system.

II.   Future urban development should not be encouraged outside of the 1985 urban area.

     A.  Utility lines (sewer and water) should definitely not be extended into the following
         drainage areas at least through 1985:

            (1) The Hellbranch - Big Darby Watershed;
            (2) The Blacklick Watershed north of the Penn Central  Railroad.

     B.   No parcel of land  should be annexed nor any suburban sewer contract written that
         would necessitate the extension of sewer interceptors except for the following:

            (1) The Blacklick interceptor from Brice Road to Reynoldsburg; and
            (2) The first phase of the Rocky Fork interceptor.

     C.  The Scioto West  and Rocky Fork (second phase) interceptors will not be needed at
         least through 1985. b

     D.  Water lines should be programmed for construction in coordination with anticipated
         needs for future sewers.

III.  Within  the 1985 urban area, Columbus should strive for a healthy balance between
     redevelopment and continued expansion.

     A.  Columbus should  give increased attention to improving, revitalizing and conserving
         development within the existing city limits.

     B.   Columbus should  continue to accept land for annexation within the 1985 urban
         area that is likely  to develop to an urban character.

IV.  Columbus should  consider the total impact of various sewer related issues on its ability
     to maintain its share of future metropolitan growth.  These issues include:

            (1) Equitable  surcharges for suburban municipalities;
            (2) Metropolitanization of the sewer system;
            (3) The removal of the prerequisite for annexation to an incorporated municipality
               prior to gaining access to the sewer and water system,  and
            (4) The potential of  two additional sewer facility plans within the area influenced
               by Columbus' growth.
a A substantial ground water pollution problem may already exist, threatening Hoover Reservoir
  a major source of drinking water.  Therefore,  a sewer may be necessary to alleviate the
  existing pollution problem.  The necessity of such a sewer should be based on a detailed study
  of the primary and secondary impacts of the construction of a sewer in the area.

 A description of the first and second phases for servicing the Rocky Fork Watershed
  is available on page 115 of the Cost Effectiveness Analysis, Columbus Metropolitan
 Area Facilities Plan.

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    APPENDIX  FF

SECONDARY AIR IMPACT
      ANALYSIS

-------
               SECONDARY  AIR IMPACT ANALYSIS
                   FOR  COLUMBUS,  OHIO
     The Environmental  Protection Agency, Region V, has ex-
pressed concern  that  the  Federal action of awarding sewage
system construction grants  might contribute to community
growth which in  turn  could  adversely affect air quality in
the so-called non-attainment areas.   This report is an analy-
sis of the effects of expanding the  present sewage treatment
facility of Columbus, Ohio  on the total emission of hydro-
carbons and particulates  in Franklin County, Ohio in the
year 2000.

     The two primary  objectives of this study are to:

          Determine differences in emissions of Total Sus-
          pended Particulates (TSP)  and non-methane hydro-
          carbons  (HC)  corresponding to two population growth
          patterns for  the  year 2000 in Franklin County,
          Ohio.

          Determine the effect of the emissions on the attain-
          ment strategies.

This report is organized  in the following five parts:

          Population  distribution
          Vehicle miles travelled (VMT)
          Hydrocarbon emissions
          Particulates  emissions
          Effect on attainment strategies.

Each of the above parts is  described below.


1.   POPULATION DISTRIBUTION

     A population projection for Franklin County, Ohio of
1.025 million people  by the year 2000 was analyzed for two
population distributions:

          Urban sprawl
          Infill
      "Infill" refers to the concentration of new development upon vacant
      land remaining within the urban area, as opposed to new development
      in virgin or relatively undeveloped suburban or rural areas.
                             — 1 —

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The urban sprawl population distribution pattern   by traffic
district within Franklin County is shown in  Figure 1 as  a
percentage change in growth from 1974.  The  percentage change
in population for the infill  pattern by traffic district is
shown in Figure 2.  These two population distribution patterns
form the basis of the analysis of air quality  of  Franklin
County, Ohio in the year 2000 under two different growth
patterns.

     The urban sprawl population distribution  is  assumed to
be consistent with the City of Columbus'   sewer plan. The
infill population distribution is assumed  to be consistent
with the sewer plan proposed by the U.S. EPA and  represents
controlled growth.  In the remainder of the  report the two
population distributions will be distinguished by the terms
"sprawl option" and "infill option."
2.   VEHICLE MILES TRAVELLED  (VMT)
     Hydrocarbon emissions result primarily  from motor ve-
hicles; therefore, the first step in analyzing  emissions for
Franklin County involves an analysis of  vehicle miles trav-
elled  (VMT) under each population growth pattern.

     Several methods for calculating VMT were analyzed in
developing a method best suited to the data  that were avail-
able .   These  methods  are summarized  below.*

          Method A—Estimating VMT using "broad-brush"
          statistics pertaining to roadway mileage,  automo-
          bile ownership and average VMT per vehicle.  This
          method was not used since it is not sensitive to
          population distribution.

          Method B—Allocating county-wide VMT  to subareas
          within the county by utilizing county or state
          highway traffic flow maps and  roadway inventory
          data.  Insufficient data were  available to use
          this method.

          Method C—Calculating VMT based on land use and
          demographic characteristics of the county.  This
          method is a simplification of  the  comprehensive
          transportation planning process and involves es-
          tablishing trip generation and attraction rates;
          volume of travel between subcounty areas,  between
          these areas and external locations; and the average
      Booz, Allen & Hamilton, "Methodologies for the Analysis of Secondary
      Air Quality Impacts of Wastewater Treatment Projects Located in Air
      Quality Maintenance Areas," prepared for U.S. EPA, Region II,
      March 1976.

                             -2-

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                                        FIGURE 1
                        Projected Population Distribution by
                       Traffic District for the Sprawl Growth
                       Pattern in 2000 in Franklin County, Ohio
                                                     J
Legend:
     Heavy lines indicate proposed sewer lines
     Shaded area denotes loss in population
     The numbers within the traffic district show traffic
     district number and percent increase in population over
     1974.
                            — 3 —

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                                         FIGURE 2
                         Projected Population Distribution by
                        Traffic District for the Infill Growth
                        Pattern in 2000 in Franklin County, Ohio
Legend:
     Heavy lines indicate proposed sewer lines
     Shaded area denotes loss in population
     The numbers within the traffic district show traffic
     district number and percent increase in population over
     1974.
                            -4-

-------
          trip length.  MORPC*has calculated VMT by traffic
          district for the base year 1974 using the Gravity
          Model, which uses this type of analysis.  The re-
          sults of the Gravity Model approach were used in
          this study.

     VMT in Franklin County were calculated for the year
2000 under the sprawl and infill options by the analysis of
the number and length of motor vehicle trips using both his-
toric and projected data.

     The first step was to determine the number of vehicle
trips for each year, 1964, 1974, and 2000.  Since the total
population was the same under the year 2000 sprawl and infill
options, the total number of vehicle trips was assumed to be
the same for each of the two projected population distribu-
tions.  Two assumptions were made in determining the number
of vehicle trips for each year:

          The auto occupancy factor for 1974 was applied to
          the 1964 and 2000 data.  The factor was 1.528
          persons, per car.

          Two percent of the vehicle trips were attributed
          to mass transit.

The vehicle trips by trip type

          Internal auto
          Internal truck
          Internal taxi
          Internal/external auto
          Internal/external truck

are shown in Column 4 in Table 1.  It can be seen that the
number of vehicle trips increase with population.

     The next step in calculating VMT involves determining
average trip length (in minutes) by trip type for each year
under analysis.  Trip lengths for 1964, 1974, and 2000  (in-
fill) were obtained from the trip generation data provided
to us by the Mid-Ohio Regional Planning Commission (MORPC).
The trip length for the sprawl option was determined by
linearly extrapolating the 1964 and 1974 average trip lengths,
assuming that the sprawl option represented a continuation of
the population growth pattern between 1964 and 1974 to 2000.
Average trip lengths in minutes for each year under analysis,
by trip type, are shown in Column 6  of Table 1.  These data
show that the average trip length for internal-external trips
has increased under the 2000 sprawl option when compared to
the 2000 infill option.
     Mid-Ohio Regional Planning Commission.
                            -5-

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     Average trip length for internal/external trips, on the
contrary, has decreased under the 2000 sprawl option when
compared to the 2000 infill option.  This is attributed to
businesses moving into suburban areas and more shopping malls
in suburban areas.

     The average trip length in minutes was then converted
to trip length in miles, as shown in Column 7  in Table 1 by
assuming an average speed of 36.3 mph based on the data ob-
tained from MORPC.

     We then calculated average daily VMT by trip type as
shown in Column 8  in Table 1.  A comparison of the estimated
VMT under the two growth patterns in 2000 is shown in Table 2.

     Internally generated VMT increase under the sprawl op-
tion by 2.27 percent compared to the 2000 infill option.
This results from longer trip lengths for internal trips
as the population is spread over a larger area.

     The VMT generated by internal/external trips, on the
contrary, decrease under the sprawl growth pattern,  compared
to the infill growth pattern.  This may be attributed to
shorter trip lengths resulting from businesses, including
shopping malls, moving out to the suburban areas.

     Because of the greater reduction in the internal/ex-
ternal VMT under the sprawl option compared to the reduction
in the internal VMT under the infill option, the total VMT
is seen to be slightly greater under the infill option than
that under the sprawl option.

     One must be cautious, however, in drawing conclusions
from these results since the percentage differences  in VMT
between the two population projections is less than  the ex-
pected error in the data.


3.   HYDROCARBON EMISSIONS

     Hydrocarbon emissions are calculated by multiplying
appropriate emission factors by VMT.

     U.S. EPA has developed a method for determining emis-
sions of various pollutants from six vehicle classes and all
modes of vehicles in grams per mile.  The methodology is
described in detail in "Mobile Source Emission Factors."*
Emission factors can be calculated from tables based on national
    U.S.  EPA, "Mobile Source Emission Factors," Final Document, EPA-
    400/9-78-006, March 1978.
                            -7-

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data or from a computer program developed by  EPA called
MOBILE-1.  In this study, emission  factors  for  non-methane
hydrocarbons were determined by the MOBILE-1  computer  program.
The inputs specific to the. study  area  required  to run  the
program are:

          Average annual temperature,  which was 52°F  for
          Columbus, Ohio

          Average speed, which was  36.3  mph for Columbus,
          Ohio

          Calendar years.

     Total non-methane hydrocarbon  emissions  were calculated
by multiplying emission factors generated from  the MOBILE-1
computer program by the VMT determined in this  study.  They
are shown in Table 3.  As seen from the  results presented  in
this table, the hydrocarbon emissions  will  be reduced  signifi-
cantly from 1974 to 2000 under both the  sprawl  and the infill
growth patterns because of the reduction in the emission fac-
tor.  The difference  in the emissions  between the two  growth
patterns resulting from the difference in VMT under the  two
growth patterns is within the range of error  expected  in the
available data.
 4.   PARTICULATE  EMISSIONS

     The objective  of  this  subtask was to estimate existing
 and  future  emissions of  total suspended particulates (TSP)
 from residential  space heating in Franklin County.  TSP
 emissions from residential  space heating result from onsite
 fuel combustion,  and in  the case of electrically heated
 homes,  they result  from  fuel combustion at the electrical
 power generating  station.   The quantity of county-wide TSP
 emissions depends upon the  number and type of dwelling units
 and  the type of fuel used  for space heating.   Since these
 factors are not likely to vary significantly  under the two
 growth  patterns,  the county-wide TSP emissions would be the
 same under  the different growth patterns.  The estimates of
 TSP  emission given  here, therefore, apply to  both the infill
 and  sprawl  growth patterns.   The TSP emissions from onsite
 and  offsite fuel  combustion are described separately below.
      (1)  Onsite  TSP  Emissions  from Residential Space
          Heating

          The  onsite  TS?  emissions  from residential space
      heating in Franklin  County in  1975 were obtained from
      the  PEDCo report*  and  were projected to the year 2000
     PEDCo Environmental Specialists, Inc., "Impact of Future Develop-
     ment upon Particulate Air Quality in Franklin County, Ohio,"
     November 1975.
                             -9-

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by using data from the same report.  The method for
estimating the onsite TSP emissions consisted of es-
timating the number of dwelling units using different
types of fuels for space heating in Franklin County,
determining the fuel usage, and multiplying the fuel
usage by the appropriate TSP emission factors.

     Four types of fuels are used for residential space
heating in Franklin County:  bituminous coal, fuel oil,
natural gas, and LPG.  Based on the census data for
1960 and 1970 for Franklin County, the use of coal for
residential space heating is declining rapidly and the
use of fuel oil and LPG is declining slowly, whereas
the use of natural gas is increasing slowly.  Assuming
that the decline or growth in the number of dwelling
units using the four types of fuels is logarithmic, the
historic trend was extrapolated to determine the number
of dwelling units using these fuels in 1975 and 2000.
The following logarithmic relationship was used:
                 (DU)x + n =


where     (DU)  = Camber of dwelling units in the base
                  year
       (DU)      = number of dwelling units in x + n year
          x   r = rate of change in dwelling units per
                  year

     Based on the census aata for 1960 and 1970, the
value of r was found to be -0.197 for coal, -0.. 00035
for fuel oil, -0.00735 for LPG, and +0,00087 for natural
gas.  The estimated number of dwelling units based on
the above equation is shown in Columns 2 and 3 in
Tab le 4 .

     The amount of the four types of fuels used for
residential space heating in Franklin County was cal-
culated by multiplying the number of dwelling units by
the average fuel usage per dwelling unit per year.  The
latter was calculated by using the following data:

          Number of degree days in 1975  in Franklin
          County:  5153

          Heating requirement factor per dwelling unit
          per degree day:  0.0012 ton coal, 0.18 gal.
          fuel oil, 26.18 cubic foot natural gas, and
          0.2935 gal. LPG.
                       -11-

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The estimated  fuel  usage  is  shown in Columns 4 and 5
in Table 4.

     The TSP emission  factors  were obtained from AP-42*
and are shown  in  Column 6 of Table 4.  The estimated
TSP emissions  for 1975 and 2000 are shown in the last
two columns of Table 4.
 (2)  Offsite  TSP  Emissions  from Residential Space
     Heating

     The offsite  TSP  emissions  from residential space
heating in Franklin County  were estimated by assuming
that the electrically heated homes in the county would
be supplied electricity  from a  coal-fired power plant.
The number of electrically  heated homes in Franklin
County is increasing  as  most new homes are built with
electrical heating systems.  Using the data on the
total number  of dwelling units  in Franklin County in
1975 and 2000 obtained from MORPC and subtracting the
number of dwelling units using  onsite fuel combustion
for space heating given  in  Table 4 from the total, the
number of electrically heated dwelling units was es-
timated to be 23,425  in  1975 and 115,591 in 2000.

     Assuming that an average dwelling unit in Franklin
County requires 26,000 BTU  of heat per degree day**
the annual heating requirement  per dwelling unit in
Franklin County,  which had  5153 degree days in 1975,
is estimated  to be 13.4  x 10 BTU.  Further, assuming
that the overall  energy  conversion, generation, trans-
mission, and  distribution efficiency of a coal-fired
power plant is approximately 30 percent, the annual
heat input requirement per  dwelling unit at the power
plant is estimated to be 44.86  x 10 BTU.  Finally,
assuming that the coal-fired power plant is equipped
to control the TSP emissions to meet the New Source
Performance Standard  of  0.1 Ib  per 10 BTU heat input,
U.S. Environmental Protection Agency, "Compilation of Air Pollutant
Emission Factors," Publication No.  AP-42,  April 1975.

Based on the heating requirement factor for onsite fuel combustion,
discussed earlier.
                       -13-

-------
     the TSP emissions attributable to supplying electricity
     for residential space heating in Franklin County in
     1975 and 2000 are estimated to be 52.55 tons and 259.00
     tons respectively.
     Thus, based on the  above  analysis,  the TSP emissions
from onsite fuel combustion  for  residential space heating
in Franklin County are expected  to reduce from 305.33 tons
in 1975 to 259.80 tons in  2000,  whereas  those from a coal-
fired power plant supplying  electricity  for space heating
in Franklin County are expected  to increase from 52.55 tons
in 1975 to 259.00 tons in  2000.
5.   EFFECT ON ATTAINMENT  STRATEGIES

     The hydrocarbon emissions  from motor vehicles in Franklin
County were projected to the  year 1982* and 1987*by linearly
scaling the VMT between 1974  and  2000  and multiplying the
VMT by the emission factors calculated by using the MOBILE-1
program.  The results of these  calculations, shown in Table
5, indicate that the difference in the emissions under the
two growth patterns is less than  1.23  percent in 1982 and
2.1 percent in 1987, well  within  the  range of expected error
in the available data.  Thus, the effect of one growth pat-
tern relative to the other on the attainment of ambient air
quality standards  for photochemical oxidants in the metro-
politan Columbus area would not differ significantly.

     The TSP emissions from onsite residential space heating
in 1982 and 1987 were estimated using  the method discussed
earlier and are shown in Table  6.  Since the total number
of dwelling units  under the two growth patterns would be the
same, the residential space heating requirement and hence the
resulting emissions of total  suspended particulates under the
two growth patterns would  not differ  significantly.  Thus,
the effect of one  growth pattern  relative to the other on
the attainment of  ambient  TSP standard would not differ sig-
nificantlv.
      According to the Clean Air Act Amendments of 1977, those areas
      that failed to attain the national ambient air quality standards
      by July 1977 must attain these standards by December 31, 1982.
      A five year extension to 1987 may be obtained for attaining the
      photochemical oxidants and carbon monoxide standards, if certain
      conditions are met.
                            -14-

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                    TABLE 5
       Estimated Hydrocarbon Emissions*
          in Franklin County, Ohio
Year
1982
Infill
Sprawl
1987
Infill
Sprawl
Average
Daily VMT

18,923,796
18,693,196

20,427,974
19,995,599
Composite
Emission
Factor
(gm/mile)

3.288
3.288

1.722
1.722
Emissions
(tons/year)

25,034
24,729

14,153
13,853
*From motor vehicles
                      -15-

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                    TABLE 6
           Estimated TSP Emissions*
          in Franklin County,  Ohio

Fuel

Bituminous Coal
Fuel Oil
Natural Gas
LPG
Total
TSP Emissions (tons/year)

1982
12.37
67.26
186.71
2.92
269.26
1987
4.64
66.84
187.53
2.81
261.82
*From residential space heating by onsite fuel combustion
                       -16-

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               APPENDIX  GG

     EFFECTS OF PARA-DICHLOROBENZENE
AND ORTHO-DICHLOROBENZENE ON GERMINATION
      AND EARLY SEEDLING DEVELOPMENT
           OF CORN AND SOYBEANS

                U.S. EPA
        PLANT BIOLOGY LABORATORY
             BELTSVILLE, MD

-------
 r.',-'t-=   August 25, -1978


K i i- T "l :   s 1 11 ri n o finalwcic*
1	"  •   *./siy'-uvjVJ (i[|t-*tjr«»i*-r»
        Robert L. Jasper j/3tt\s±iwstj  Section Head
        Safety & Biological  Section,  CBIB (TS-768)
  TOr
        Dale Luecht,  Project Officer
        Water Division, Region  V
THRU:   Coleman H. Hall
        Acting Branch Chief
        Chemical & Biological  Investigations Branch {TS-768)

THRU:/  William S. Murray,
    ffl Director
    /   Benefits & Field  Studies  Division (TS-768)
        Attached  is  the  report on effects of ortho- and para-dichlorobenzene.
        on corn and  soybean  germination and radicle growth.  You have
        received  the earlier reports.

        Uptake studies will  get under way shortly.  Details or questions  should
        be discussed with Dr.  Bernard Schneider, Radioisotope Laboratory.

        Please call  Bill  Audia on 344-2833 if you have questions regarding  the
        attached  report.
        Attachment
    EPA FORM 1320-6 (REV. 3-76)

-------
                   UiMil ED STATES tiMVIKUK.,'^ i ^L 
-------
      EFFECTS' OF PARA-DICHLOROBENZENE AND ORT.HU-i>iChLO.rOBENZEIiE ON




     GERMINATION MHD  EARLY SZiDLINGr r'EViCLOrMEI^T Or' C'UKi< ANL' GOiBiiAES



                              Introduction



Para-Bichlorobenzene  (PDB) and Ortho-Dichlorobenzene  (ODB) are manufactured




in large quantities in the United States and abroad.  They are widely dis-



persed in the environment.  PDB is used extensively as a household moth




-control agent and as  ei deodorant (McKinney 1970).  It has beer, used in




animal repellents, as a fungicide for control of blue mold in tobacco




seed beds (Berg 1977), and as a miticide in mycological cultures  (Elliot




19^8; Crowell 19^1).



ODB is used in cleaning solvents, heat transfer media, degreasing agents,




and for odor control  in sewage treatment-plants.  Generally, the  benzene




compounds are toxic and are known to be mitotic poisons. (EPA-5-OH-1978).






Samples of Ohio sludge were sent to the Plant Biology Laboratory  after




chemical analysis had shown varying amounts of PDB and ODB (Appendix  A).



Processed sludge is being considered for use as fertilizer or as  a ferti-




lizer base for agronomic crops.  A review of the literature showed limited



data on the response  of higher plants to PDB and ODB.  Data are also  lack-



ing on uptake and metabolish of these chemicals by higher plants.  If



processed sludge is to be used as fertilizer or a fertilizer base and



PDB and ODB are components therein, it is imperative that their effects




.upon plant life be known.  The purpose of this research is to determine




the effects of PDB and ODB on germination and early seedling development




of corn (Zea mays L.  'SS727') and. soybeans  (Glycine max (L.)  'Beeson  FW-7').

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                                  - 2 -
                          I/A rptn>T A T C1 A T-m
                              Experiment 1



Germination Study.  (Environmental chamber).  Ten seeds each of corn and




soybeans were placed in 15 x 90 mm glass petri dishes lined with two




cheets of 9-cm Whatman No. 2 filter paper.  Twenty-five ml of PDB or ODB




-at 1, 5-, 10, -L5, and 20 ppm were added separately .to -each petri dish.




These solutions constituted the PDB and ODB standards to which the sludge



treatments are compared.  PDB and ODB were dissolved in acetone.  An ace-




tone check was prepared by mixing 0.37 ml of acetone in 100 ml of dis-



tilled water.  Twenty-five ml of this solution was applied to 10 corn



or soybean seeds.  Twenty-five-ml aliquots of sludge diluted with dis-




tilled water to give concentrations of 50$ or 66^ (l to.l or 2 to l)




from each liquid sample were added to petri dishes containing 10 corn or



soybean seeds.  Dry sludge (cake) samples were leached through 1*00 x




1*5 ora glass columns using distilled water as the solvent.  The leachate



was filtered through Whatman No. 2 filter paper at the bottom of each



column, collected in a beaker, and diluted as above.  Twenty-five ml of



diluted sludge leachate were applied to petri dishes containing corn or



soybean seeds as above.  Dishes to which only distilled water was added



served as controls.  All dishes were incubated in an environmental cham-



ber in the dark at 23 C and 6k% relative humidity for six days.  At the



end of the incubation period, the number of seeds that had germinated




was recorded.  Seeds were counted as germinated if radicle (root portion




of germinating seed) length was at least 5 mm long.   As a measure of




seed vigor, radicle length was recorded also.

-------
                                  „ "5 _




Combinations of PDB/OD3 and sludge dilutions  were  prepared by  mixing




each with distilled water 50$ (l to l) or 66$ (2 to  l).   Standard con-




centrations of the PDB and ODE were maintained (l, 5,  10, 15,  ?nd 20




ppm).  Germination and radicle length of all  treatments were recorded




8ix days after incubation.  All treatments were replicated five  times




and arranged in a completely randomized  design. Treatment means were




separated by the Duncan's Multiple Range Test at the 1% level  of signi-




ficance (Steel and Torrie 1960).






                              Experiment 2



paper containers, 150 mm high and 175 am in diameter,  with holes punched



in the bottom for drainage, were filled  with  3.^ kg  of white sand. These



containers served as planting beds for the specimen  plants, corn and  soy-



beans-  Ten seeds each of corn and soybeans were planted" in separate




pots at a depth of 2.5^ cm, and sand was brought to  field capacity by



sprinkling with a fog nozzle.  Standard  solutions  of PDB  and ODB at 1,



5, 10, 15, and 20 ppm were prepared in half-strength Hewitt's  medium



(Steward 1963).  Suspensions of 5$ sludge were prepared by diluting the



sludge samples with an appropriate quantity of distilled  water.   The  PDP



and ODB standards and the 5$ sludge suspensions were applied separately



to corn and soybeans in 200-ml portions  10 times during the test period.




An acetone check was prepared as in Experiment 1,  and  a 200-ml portion




was applied as.above.  A nutrient check  was prepared by diluting Hewitt's




medium 50$ with distilled water.  Pots treated as  above with half-strength




Hewitt's medium and distilled water served as controls.   In order to

-------
                                  ., ii -



maintain an adequate moisture level between treatments, 200-ml portions



of distilled water were added to all pots as often as necessary.  The



liquid rate of application for the PDB/ODB standards and the 5$ sludge



was 23,5^5 gallons per acre (17k.2 kl per hectare)..  Treatments were ar-



ranged in a randomized complete block with five replications.  Plant



height measurements were taken weekly during the experimental period.



All plants were cut at the sand surface, and fresh weights were recorded.



Then plants were dried at 80 C for 72 hours to determine the dry weight.



Means were separated as in Experiment 1.





                                 RESULTS



                              Experiment 1



PDB and ODB did not significantly reduce the germination of corn seeds



(Table l).  However, some PDB treatments showed lower soybean germina-



tion than controls.  Combinations of PDB/ODB did not adversely affect



the germination of corn or soybean's.  The acetone check had no effect



on the germination.



Some sludge treatments (Table 2) adversely affected germination of corn



and soybeans.  Sludge treatment L had the lowest mean germination for



corn, while soybeans appeared more tolerant when diluted 2 to 1 with



distilled water.



Generally, PDB or ODB alone or in combination did not adversely affect



the radicle length (Table 3).  Depression of soybean radicle length by



PDB was not evident at the higher concentrations.  Sludge treatments D



(1:1) and L (l:l) significantly decreased radicle length in germinating



corn and soybeans.  Also, sludge treatment C was detrimental to radicle



growth in soybeans.

-------
                              Experiment 2



PDB, ODB, or 5$ sludge treatments did not adversely affect germination



of corn or soybeans  (Table 5).  PDB and ODB did not adversely affect




the height, fresh or dry weight or corn or soybeans.  However, some



-sludge, treatments adversely affected fresh and dry weight of corn and




soybeans  (Tables 6-8).  The height of corn was significantly reduced by




sludge treatments A, E, G, L, and distilled water lh days after treat-




ment.  Treatments A, E, J, and distilled water significantly reduced




height 20 days after treatment.  Treatments A, C, D, E, F, G, J, L, and




distilled water reduced height of corn 29 days after treatment (Table 6)



The height of soybeans was significantly reduced when treated with sludge




treatments C, D, G, H, J, and distilled water lU days after treatment;



also by treatments C, D, G, and distilled water 20 days after treatment,




and by treatments A, C, D, .G, H, and distilled water 29 days after



treatment (Table 6).




Distilled water and all sludge treatments, except H and K, significantly



reduced the fresh weight of soybeans.  The same was true for corn except



that treatment K did not significantly reduce the fresh weight of corn



when compared with the nutrient control (Table 7).  All sludge treatments



and distilled water significantly reduced the dry.weight of corn, and




all'sludge treatments, except K, significantly reduced the dry weight



of soybeans when compared with the nutrient control (Table 8).






                               CONCLUSIONS



Corn and  soybeans planted from'seed and treated 10 times over a period




of 30 days with PDB and ODB 1, 5, 10, 15, and 20 ppm appeared normal and

-------
                                  - 6 -



a& healthy as the nutrient controls.  These data suggest that PDB or ODB




alone, or in combination up to 20 ppm does not adversely affect germina-



tion or early seedling development of corn and soybeans.  The results of




this -'nvestigation, however, cannot be conclusive until the uptake and




fate of PDB and ODB in corn and soybeans are known.  Radioisotope studies



are -planned to supply information on this phenoncaien.




Sludge diluted to 5$ solid matter did not adversely affect germination




of corn or soybeans in the greenhouse.  However, certain sludge treat-




ments did adversely affect germination in the environmental chamber (Ex-




p^riment l).  The concentration of the sludge in environmental chambers




(50$ and 33$) along with light and humidity factors perhaps accounts for




the difference.  Most sludge treatments did adversely affect the fresh




and dry weight of both corn and soybeans (Tables 7 and 8).  Also, most



sludge treatments caused stunting of corn and soybeans 29 days after




treatment (Table 6).  These data strongly suggest that Metropolitan



Columbus, Ohio sludge contains growth-inhibiting agents, that do not



appear to be PDB or ODB, which may be detrimental to the normal growth



and development of corn and soybeans.

-------
Tnble 1.  Effect oC PDD/ODB alone and in combination.on r
          of corn and soybean seeds  (envi.ron.T.qntal chamber).


Treatment ppm
PDB
PDB
PDB
PDB
PDB
ODB
ODB
ODB
ODB
ODB
PDB/ODB
PDB/ODB
PDB/ODB
PDB/ODB
PDB/ODB
PDB/ODB
PDB/ODB
PDB/ODB
PDB/ODB
PDB/ODB
PDB/ODB
PDB/ODB
PDB/ODB
PDB/ODB
PDB/ODB
Control
Acetone
1
5
10
15
20
Jl
5
10
15
20
1
5
10
15
20
1
5
10
15
20
1
5
10
15
20
(Distilled HgO)
Check
Ratio
PDB/ODB
. ...
	
—
- —
.—
-««-»
	
-__
...
---,
1«1
.1:1
1:1
1:1
1:1
a.-i
2:1
2:1
2:1
0:1
1:2
1:2
1:2
1:2
1:2
—
—
Corn
Germination "£
96 a
92 a
88 a
88 a
78 a
90 a
96 a
90 a
90 a
70 a
72 a
Ok a
88 a
9U a
73 a
88 a
92 a
90 a
88 a
78 a
76 a.
88 a
86 a
76 a
76 a
92 a
90 a
Soybean ^
Germination %
68 a-d
56 ab
68 a-d
52 a
52 a
8U bed
8U bed
78. a-d
7k a-d
66 abc
9U cd
86 cd
8U cd
76 a-d
7k a-d
88 cd
92 cd
86 cd
80 a-d
88 cd
88 cd
86 cd
88 cd
96 d
7k a-d
92 cd
9!* cd
j£
 Means within columns followed by the seme letter are not significantly
 different at the 1$ level according to Duncan's Multiple Range Test.

-------
                                 -. 8 -


Table 2.  Effect of sludge treatments on corn and soybean seed germin-
          ation (environrv^nta 1 chamber).
Sludge
Ratio
Treatment HpO/Sludge
A .
A
B
B
C
C
D
D
E
E
F
F
G
G
H
H
I
I
J
J
K
K
L
L
Control
Acetone
Itt
2:1
1:1
25l
1:1
2:1
1:1
2:1
1:1
2:1
1:1
2:1
1:1
2:1
1:1
2:1
1:1
2:1
1:1
2:1
1:1
2:1
1:1
2:1
(Distilled H20)
Check .
Corn ^
Germination %
28 a-d
50 def
1*0 c-f
40 c-f
11* ab
30 a-e
li* ab
.20 abc
68 fg
58 f
52 def
1*3 'def
38 c-f
52 def
32 b-e
51* def
1*2 c-f
56 cf
1*8 def
56 ef
1*8 def
1*0 c-f
6 a
12 ab
92 g
90 g
Soybean
Germination %*
.16 a
1*8 c-g
52 d-h
56 e-j
26 a-d
3k a-f
22 a-f
1*6 b-g
92 k
80 i-k
78 h-k
62 f-i
1*1* b-h
5k d-i
18 ab
61* hij
38 a-g
82 jk
5!* d-i
32 a-d
92 k
82 jk
1*0 a-g
80 ijk
92 k
9!* k
*
.Means within columns followed by the same letter are not significantly
 different at the 1% level according to Duncan's Multiple Range Test.

-------
                                 - 9 -

Table 3.  Effect of PDB and ODB alone or  in combination on the  radicle
          length of germinating corn and  soybean seeds  (Environmental
          chamber).
Ratio
Treatment ppm PDB/ODB
PDB
PDB
PDB
PDB
PDB
0DB
ODB
ODB
ODB
ODB
PDB/ODB
PDB/ODB
PDB/ODB
PDB/ODB
PDB/ODB
PDB/ODB
PDB/ODB
PDB/ODB
PDB/ODB
PDB/ODB
PDB/ODB
PDB/ODB
PDB/ODB
PDB/ODB
PDB/ODB
Control
Acetone
1
5
10
15
20
1
5
10
15
20
1
5
10
15
20
1
5
10
15
20
1
5
10
15
20
(Distilled HgO)
Check
. — _
— _
' — — -
...
	
WWW
.._
--_
._.
...
1:1
1:1
1:1
1:1
1:1
2:1
2:1
2:1
2:1
2:1
1:2
1:2
1:2
1:2
1:2
—
_-.
Corn - Radicle
Length (mm)
109 f
109 f
111 f
98 ef
98 ef
88 c-f
96 def
80 b-f
62' a-e
36a
54 abc
52 abc
56 abc
59 a-d
52 abc
52 abc
61 a-d
kh ab
52 abc
50 abc
no f
59 a-d
55 abc
56 abc
60 a-d
77 b-f
8U b-f
Soybean - Radicle
Length (naa)
27 abc
20 a
16 a
13 a
13 a
kl abc
kO abc
2U ab
2k ab
18 a
52 c .
25 abc
25 abc
30 abc
3O abc
U8 be
51 c
3U abc
. 33 abc
36 abc
36 abc
38 abc
h2 abc
U2 abc
28 abc
37 abc
39 abc
 Means, within columns followed by the  same  letter are  not  significantly
 different at the 1$ level according to  Duncan.'s Multiple  Range  Test.

-------
                                - 10 -
           Effect of sludge treatments on corn and soybean radicle
                 (mm) (environmental chamber).
L 1. II 	
,-.;ut,:fl
7r"*t=>
A
A
B
B
C
C
D
D
E
E
r
p
c
c
H
H
I
I
J
J
K
K
L
L
Ace'tone
Control
*U*»~~- .
.. , 	 	 	 ' 	 ' — ' 	
Ratio
*nt Ho O/ Sludge
1:1
2:1
1:1
2*1
1:1
2:1
1:1
2:1
1:1
2:1
1:1
2:1
1:1
2:1
1:1
2:1
1:1
2:1
1:1
2:1
1:1
2:1
1:1
2:1
Check ---
(Distilled H20)
.J 1.1-.! _ - - 1 	 	
Corn - Radicle
Length (mm)*
20 ab
63 c-h
58 e-h
k8 b-g
8 a
23 abc
3 a
8 ab
90 h
80 f gh
1*1 a-f
U3 b-f
lU ab
26 abc
37 a-e
71 e-h
kk b-f
80 f gh
26 abc
30 a-d
66 d-h
62 c-h
2 a
8 a
654 d-h
8k gh
Soybean - Radicle
Length (mm)
8 abc
30 a-e
3^ c-f
32 b-e
5 ab
5 ab
3 a
8 abc
89 h
59 f g
29 a-e
12 a-d
7 abc
10 abc
6 ab
37 def
12 a-d
60 f g
8 abc
5 ab
77 gh
5k efg
6 ab
22 a-d
37 def
39 def
different at the 1% level
    by the same letter are not significantly
according to Duncan's Multiple Range Test.

-------
                               -. 11 -

   ••  '   "ffcct of PDB. ODB,  and 57? sludge on the germination of corn
         nr.d soybeans, 10 days after treatment (greenhouse).
• 	 	 	 " "
fr-atrwnt
• 13 1 .PP°
:?? 5 PPO
K? 10 ppa
it a 20 ppa
. : -v 1 ppa
: •> 5 PP^

criv 15 ppa
cry 20 ppm
sludge A
0 1 utl^e B
ulud^.e . C
Sludge D
5 iucJp.e 2
Sludge F
Sludge G
Sludge H
Sludge I
Sludge J
Sludge K
Sludge L
Control (Distilled H20)
Acetone Check
Nutrient Control
G e r m i
Corn
100 a
100 a
98 a
98 a
100 .a
100 a
100 a
96 a
98 a
100 a .
92 a
98 a
100 a
98 a
98 a
100 a
98 a
98 a
98 a
100 a
100 a
100 a
100 a
98a
100 a
nation %
Soybean
98 a
96 a
98 a
98 a
..100 a
100 a
100 a
98 a
100 a
98 a
98 a
92 a
98 a
fl?l Q
^T CL
9k a
100 a
90 a
"98 a
98 a
96 a
98 a
96a
98 a
100 a
100 a
Means within columns followed by the same letter are not significantly
different at the 1$ level according to Puncan's Multiple Range Test.

-------
-able 6.   Effect of PDB,  ODD,  and 5$ sludge  on the  height  of  corn and soy
          beans  (greenhouse).'
Corn Height (rran)
Treatment

PDB 1
PDB 5
PDB 10
PDB 15
PDB 20
ODB 1
ODB 5
ODB 10
. ODB 15
ODB 20
Sludge
Sludge
Sludge
Sludge
Sludge
Sludge
Sludge
Sludge
Sludge
Sludge
Sludge
Sludge
Control
tilled
Acetone

ppm
ppm
ppm
ppm
ppm
ppm
ppm
ppm
ppm
ppm
A
B
C
D
E
F
G
H
I
J
K
L
(Dis-
H20)
Check
Nutrient Con-
trol

Days after
1U
131 e
130 e
136 e
129 e
132 e
131 e
135 e
133 e
138 e
132 e
76 ab
115 de
118 de
100 cd
82 abc
101 cd
87 abc
127 e
128 e
78 abc
122 de
89 be
61* a

117 de
132 e

*
Soybean Height (ran)*
Treatment
20
181*
181
185
183
182
183
178
170
1B3
17U
113
1*5
11*3
130
107
122
11*9
11*1*
153
115
163
115
101*

159
179

fg
efg
fg
efg
efg
efg
efg
d-g
fg
efg
ab
a-f
a-f
a-d
a
abc
b-g

b-g
ab
c-g
a
a

c-g
efg

29
256
265
280
2U7
25U
270
2Ul
255
276
21*1
11*9
180
11*7
151*
150
137
139
171*
189
ll*7
208
ll*6
112

219
25U

fgh
fgh
h
fgh
fgh
gh
e-h
fgh'
gh
e-h
ab
bed
ab
abc
ab
ab
ab
bed
b-e
'ab
c-f
ab
a

d-g
fgh

Days after
11*
156
-151
160
182
156
169
187
168
161
156
137
139
121*
113
151
137
125
119
11*9
125
11*2
11*2
107

177
173

c-g
c-f
d-g
fg
c-g
d-g
g
d-g
d-g
c-g
a-d
a-e
abc
a
b-f
a-d
abc
ab
b-f
abc
a-e
a-e
a

fg
efg

Treatment
20 29
278
301
301
325
311
322
325
255
316
300
231
217
191*
181
253
228
205
220
255
235
253
235
180

310
280

c-g
d-g
d-g
g
efg
fg
g
b-g
efg
d-g
a-d
abc
ab
a
b-f
abc
ab
abc
b-g
a-d
b-f
a-d
a

efg
c-g

519 c-h
530 d-h
1*92 e-g
606 fgh
608 fgh
558 d-h
569 e-h
535 d-h
61*1* h
631 gh
377 abc
1*25 a-e
307 a
316 a
1*65 b-f
1*11* a-d
335 ab
371* abc
1*25 a-e
1*10 a-d
1*65 b-f
1*13 a-d
337 ab

561 e-h
531* d-h

Means, within columns followed by the  same letter are not significantly
different at the 1$ level according to' Duncan's Multiple Range Test.

-------
                                - 13 -

Table 7.   Effect of PDB,. ODB,  and 5$ sludge on the fresh weight (aerial
          parts) of corn and soybeans,  31 days after treatment (green-
          hous'e).

Treatment
PDB 1 ppm
PDB 5 ppni
4>DB 1Q ppm .
PDB 15 ppm
PDB 20 ppm
ODB 1 ppa
ODB 5 ppm
ODB 10 ppm
ODB 15 ppm
ODB 20 ppm
Sludge A
Sludge B
Sludge C
Sludge D .
Sludge E
Sludge F
Sludge G
Sludge H
Sludge I
Sludge J
Sludge K
Sludge L
Control (Distilled H20
Acetone Check
Nutrient Control
Fresh
Corn
82.2 gh
82.6 gh
76.8 gh
69.7 efg
. 63.1 def
85. U h
75.3 fgh
73.0 e-h
79-5 gh
70.2 efg
19.8 ab
U3.2 c .
17.0 ab
18.6 ab
16.6 ab
16.1 ab
20.9 ab
U3.7 c
U7.8 c
13.1 ab
51.7 cd
23. U b
8.8 a
79.1 gh
61.3 de
weight (g)*'
Soybean
1+04.1 fgh
39. 1f fgh
37.3 efg
1*0.6 Tgh
U0.7 fgh
U7.6 h
U3. 6 gh
39.5 fgh
Ul.3 fgh
36.7 efg
18.1 ab
2U.8 be
12.9 a
03.5 g
18.1 ab
lU.U a
1^.9 a
26.5 c.d
2U.5 be
1U.9 a
30.2 cde
15.8 a
13.0 a
38.7 fg
33.1 def
 Means within columns followed by the same letter are not significantly
 different at the 1% level according to Duncan's Multiple Range Test.

-------
         rrf- - ,. r*j*^ . JL  _ r* Tir*"'"*
         jur; £x j. =•_ v  G- i i.'->


         parts) of corn and soybeans, 31 days after treatment (green-


         house).

Treatment
PDB 1 ppm
PDB 5 ppm
PDB 10 ppm
PDB 15 ppm
PDB 20 ppm
ODB 1 ppm
ODB 5 ppm
ODB 10 ppm
ODB 15 ppm
ODB 20 ppm
Sludge A
Sludge B
Sludge C
Sludge D
Sludge E
Sludge F
Sludge G
Sludge H
Sludge I
Sludge J
Sludge K
Sludge L
Control (Distilled H20)
Acetone Check
Nutrient Control
Dry w e i g
Corn
10.6 hi
10.6 hi
9.7 f-i
8.9 efg
7.9 de
10.5 ghi
9.9 f-d
9.1 e-h
10.1 i
9.^ e-i
2.5 ab
5.2 c
2.6 ab
2.8 b
1.8 ab
2.2 ab
3,5 ab
5.3 c
5.U c
1.9 ab
6.5 cd
3.0 b
.1.1 a
9.6 f-i
8.3 ef
: h t (g)*
Soybean
6.8 jk
6.8 jk
6.5 d
6.U id
6A ij
7.5 k
6.1 ij
6.5 d
6.U ij
6.2 ij
3.5 cde
U.3 ef
2.U ab
2.3 a
3.2 bed
2.U ab
2.5 ab
U.5 fg
U.O def
2.7 abc
5.2 gh
3.9 def
2.3 a
6.2 ij
5.6 hi
Means within columns  followed by the same letter are not significantly

different at the 1$ level according to Duncan's Multiple Range Test.

-------
                                 - 15 -





                              REFERENCES



1.  Berg, G.L. (ed).  (1977) Farm Chemicals Handbook.  Meister Publishing



    Company, Willoughby, Ohio.  0-197.



2.  Crowell, I.H. (19^1)  Use of Dichlorocides in the confciol of scavenger



    mites in tube cultures.  Mycologia 33:137.



3.  Elliot,. E.W. (19^8)  The effect of PDCB on fungi.  Proceedings of Iowa



    Academy of Science 55:99-107.



U.  Environmental impact statement (Draft) (1978)  Wastewater treatment



    facilities for the Metropolitan Area of Columbus Ohio. P IV 2U.



5.  MeKinney, J.D. and L. Fishbein. (1970)  The electron-capture gas chromo-



    tography of para-Dichlorobenzene metabolites or as a means of exposure.



    Bulletin of Environmental Contamination and Toxicology 5:35^-361.



6.  Steel, R.G.D., and J.H. Torrie.  (i960)  Principles and procedures of



    Statistics.  McGraw Hill Book Company, Inc. New York.  ^8l.



7.  Steward, F.C.  (19^3)  Plant Physiology.  Academic Press, New York.

-------
                                 - 16 -

                              APPENDIX A
                                                                #
Beltsville Laboratory Chemical Analysis of Columbus,  Ohio Sludge

Se-T.ple Code    .     Description               Dichlorobenzene content (ppra)
 • "  ~                                            Para          Ortho

    A               Lagoon HLIN                   2.66           4.13

    B               Southerly Zimpro process       ND             HD

    C               Southerly special condition   0.65            M)

    D               Southerly special condition   0.69            ND

    E               Southerly Lagoon              0.37           0.28

    F               Southerly special sample      0.25           O.05
                                     (cake)

    G               Southerly special condition   0.91            ND

    H               Southerly special sample       ND            0.13
                                       process

    I               Southerly special sample      0.01            ND
                               Zimpro process

    J               Jackson Pile Zimpro (cake)    2.25           2.17

    K               Jackson Pike D-U               ND            0.03

    L               Jackson Pike 2-sludge         0.13           0.28
 Analysis by EPA, BFSD, Analytical Chemistry Section, Residues & Special
Projects Labaratory, Bldg. 306, ARC-E, Belts ville, Maryland  20705


ND = none detected.

-------
          APPENDIX  HH

 EPA POLICY STATEMENT CONCERNING
   THE RELATIONSHIP AMONG EPA,
ITS CONTRACTORS, SUBCONTRACTORS,
    GRANTEES, AND THE PUBLIC

-------
          1.  RELATIONSHIP OF EPA WITH CONTRACTORS AND SUB-
              CONTRACTORS IN THE EIS PREPARATION PROCESS;'.

              And

          2.  REQUIREMENT THAT OPINIONS AND CONCLUSIONS OF EIS
              CONTRACTORS AND SUBCONTRACTORS BE SUBMITTED TO
              EPA FOR REVIEW BEFORE PUBLIC DISCLOSURE BY EPA.
To Environmental Protection Agency (EPA) Contractors and Subcontractors

Performing Environmental Impact Statement (EIS) Preparation Work:


     EPA policy pursuant to 40 C.F.R. Part 6 regulations (esp. Sections 6.104,
6.208, and 6.304) which implement the 1969 National Environmental Policy Act
(NEPA) and applicable court decisions require ongoing EPA participation with
its assisting contractors and ultimate EPA evaluation in the EIS preparation
process.  As part of the evaluation, final decision-making on the contents of
the draft and final documents with regard to Title II wastewater treatment
grant matters (P.L. 92-500, as amended) remains EPA's responsibility, to be
exercised by the Regional Administrator (RA) of each EPA region, including
Region V.

     Therefore, our joint EIS functions (EPA and contractors) commence with
the central inventory-gathering of information pertinent to the proposed
project, Including feasible alternatives, and then proceed to the evaluation
of this information and the reaching of preliminary conclusions by the
involved contractors and EPA staff.  This, in turn, is followed by a
reworking and reanalysis of certain elements of the work product until
EPA staff, with the assistance of its contractors, has evolved, with
.and for the RA, the Draft EIS.  As a formal document, the Draft EIS should
embody conclusions that are tentatively final; thus, it serves (at that
refined stage) to remove most of the evolving, "moving target" character
of prior preliminary and interim elements of the process.  It is at .
this obvious juncture th.at EPA would most frequently seek out maximum
public participation in the EIS process, since its involvement then would
have its most meaningful content and impact.

     Further, the overall EIS preparation process concurrently involves
a coordinated input from various governmental and private sources.  This
is accomplished with an eye toward compliance with various Federal, State
and local requirements, including and in addition to NEPA.  Among other

-------
additional matters, the EIS process must consider whether the project
is consistent with the provisions of the Federal Water Pollution Control
Act, the Federal Clean Air Act, the National Historic Preservation Act,
and applicable State and local laws, e.g., scenic rivers acts and emission
control ordinances.  Furthermore, it must utilize disciplines pertinently
required to be applied in the particular case.  The ultimate responsibility
for the integration of these activities resides with EPA.

     In addition to the foregoing EPA and contractor assisted activities,
(as alluded to above) EPA has a responsibility to appropriately accommodate
the public's input and participation in the EIS process.  Indeed, applicable
EPA regulations [(40 C.F.R. § 6.206(a)(2) and (b)] prescribe publication  of
a notice of intent to prepare an EIS and the solicitation of "[governmental]
agency and public input to a draft EIS"-.  Significantly, such involvement
must neither mislead these parties nor detract from the consummation of
the total process by EPA itself.  In certain instances, EPA may determine
to formalize the involvement of the public at large in the various stages
of the process, from its inception.  That approach entails establishing
citizen advisory committees to review and discuss preliminary and interim
EIS work products.  In other situations, a more informal approach is
utilized to attain public input.  Where EPA decides to utilize an informal
approach, caution must be shown against inappropriate or premature dis-
closure by EPA or its assisting contractors and subcontractors of
evolving and, therefore, changing opinions and conclusions circumscribing
the. EIS process.  Such disclosure could not only mislead and confuse the
public but consume substantial amounts of EPA staff time (and funds) in
clarifying its full significance.  As a result, EPA (not its assisting
contractors) has the responsibility of determining at what point or
points, in addition to the time commencing at and about the publication
of the Draft EIS, public disclosure of EIS conclusions may be timely
and appropriate.

     Therefore, EPA requires that opinions and conclusions reached by its
assisting contractors and subcontractors in'connection with their EIS
contract work be first submitted to EPA for review before any disclosure
by EPA to others.
                               /John McGuire
                               I   Regional Administrator

Dated:  QEC 1   1978

-------
          APPENDIX II




COLUMBUS EIS PROJECT PARTICIPANTS

-------
             COLUMBUS EIS PROJECT PARTICIPANTS


U.S. EPA REGION V


DALE LUECHT, EIS Project Officer

          B.S. Chemistry, M.S. Natural Sciences

          Preparation of EIS's on Wastewater treatment
          facilities in the states of Illinois, Indiana,
          and Ohio since 1974.


DENNIS LONG, Environmental Engineer

          B.S. Civil Engineering

          Project review and construction grants program
          management for facilities planning in Ohio since
          August 1978.


THEODORE ROCKWELL, EIS Project Team Member

          B.A. Environmental Conservation

          EIS's on wastewater treatment facilities with
          EPA since October 1978.


THOMAS WILLIAMS, EIS Project Team Member

          B.S. Civil Engineering

          EIS's on wastewater treatment facilities with
          EPA since June 1978.
BOOZ • ALLEN & HAMILTON, INC.


DAVID W. WEISS,  Partner-in-Charge

          B.S. Mechanical Engineering

          25 years experience in systems analysis and environ-
          mental assessment.

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LAWRENCE B. CAHILL, Project Manager

          B.S. Mechanical Engineering, M.S. Environmental
          Engineering, M.A. in Public Administration

          6 years experience in environmental, institutional,
          and financial assessment of water pollution control
          and water quality management projects.
STEPHEN W. BAILEY, Wastewater Treatment Analyst

          B.S. Civil Engineering, M.Ehg. Environmental
          Engineering, registered Professional Engineer

          5 years experience in planning and design of
          municipal and industrial wastewater treatment
          facilities.
WILLIAM C. LAMB, Natural Environment Analyst

          B.A. Liberal Studies

          3 years experience in the environmental assess-
          ment of water, air, and noise pollution control
          programs.


SATISH B. SURYAWANSHI, Air Quality Impact Analyst

          B.S. Mechanical Engineering, M.S. Mechanical Engineering

          7 years experience in environmental impact analysis
          and air pollution control.


JOANNE S. WYMAN, Man-made Environment, Demographic, and
                 Secondary Impacts Analyst

          B.A. and M.A. Government and International
          Relations, Ph.D. Politcal Science.


KATHLEEN M. ZACHER, Secondary Impacts Analyst

          B.S. Urban Studies

          8 years experience in urban growth policy
          development and analysis.

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WANDA FRYE, Editor

          B.S. English and Journalism

          3 years experience editing and coordinating
          technical publications in environmental and
          defense-related project areas.
HAVENS AND EMERSON, INC.
MICHAEL C. MULBARGER, Partner-in-Charge

          B.S. Civil Engineering, M.S.  Civil Engineering,
          registered Professional Engineer

          14 years experience in sanitary engineering
          research and development, and process design
          and control.
N. EDWARD HOPSON, Project Manager

          B.S. Civil Engineering, M.S. Civil Engineering,
          Ph.D. Civil Engineering, registered Professional
          Engineer

          11 years experience including teaching environ-
          mental engineering, and facility and areawide
          wastewater management planning.


DAVID L. KLUNZINGER, Senior Wastewater Treatment Analyst

          B.S. Civil Engineering, M.S. Civil Engineering,
          registered Professional Engineer

          6 years experience in wastewater management
          facilities planning and river basis studies.
BEN C. WESTER, Senior Wastewater Collection and Service Area
               Regionalization Analyst

          B.S. Civil Engineering, registered Professional
          Engineer

          5 years experience in wastewater management
          facilities planning and sewerage systems design.

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APPENDIX JJ




BIBLIOGRAPHY

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                  BIBLIOGRAPHY


 FEDERAL LAWS

 1.    Clean Air Act,  as amended 42 U.S.C. Section 7409
      (Supp. 1977).

 2.    Clean Water Act of 1977,  P.L.95-217,  91 Stat.  1566,
      33 U.S.C. 1251  et jseg.  (Supp.  1978).

 .3.    Federal Water Pollution Control Act Amendments of
      1972, P.L. 92-500, 86 Stat.  816, 33 U.S.C.  1252(a)
      (Supp. 1978).

 4.    The National Environmental Policy Act of 1969, as
      amended, P.L.  91-190, 42 U.S.C. 4321-4347,  January 1,
      1970, as amended by P.L.  94-52, July 3, 1975,  and
      P.L. 94-83,- August 9, 1975.


 U.S.  EPA

 5.    U.S. EPA, "Air  Pollution Aspects of Sludge  Incineration,"
      prepared by Gulp, Wesner and Gulp, NTIS Number PB-259
      457, June 1975.

 6.    U.S. EPA, "Compilation of Air Pollutant Emission
      Factors," Third Edition,  AP-42, August 1977.

 7.    U.S. EPA, "Consideration of Secondary Environmental
      Effects in the  Construction Grants Process,"  Program
      Guidance Memo No. 50, June,  1975.

 8.    U.S. EPA, "Cost Effectiveness Analysis Guidelines,"
      40 CFR Part 35, Subpart E, Appendix A, September 10,
      1973.

 9.    U.S. EPA, "DO Workshop," EPA sponsored Symposium:
      Rate Constants  for Surface Water Modeling,  San
      Fransico, California, April, 1977.

10.    U.S. EPA, "EPA  Policy Statement Concerning  the Rela-
      tionship Among  EPA, Its Contractors,  Subcontractors,
      Grantees, and the Public," Dec. 1, 1978.

11.    U.S. EPA, "Evaluation of Storm Standby Tanks,  Columbus,
      Ohio," Water Pollution Control Research Series
      11020FAL 03/71, EPA Water Quality Office, 1971.
                           JJ-1

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12.   U.S. EPA, "Evaluation of the Wastewater Treatment
      Processes Proposed for Columbus, Ohio in the  Draft
      EIS," by John Stamberg of Energy and Environmental
      Analysis, Inc., July, 21, 1978.

13.   U.S. EPA, "Final Environmental Impact Statement,
      Olentangy Environmental Control Center and Interceptor
      System," for the Delaware County, Ohio Board of
      Commissioners, July, 1976.

14.   U.S. EPA, "Funding of Sewage Collection System Projects,"
      PRM 77-8, June, 1977.

15.   U.S. EPA, "The Helical Bend Combined Sewer Overflow
      Regulator," Environmental Protection Technology Series,
      Report EPA-600/2-75-062, December 1975.

16.   U.S. EPA, "Methodologies for the Analysis of Secondary
      Air Quality Impacts of Wastewater Treatment "Projects
      Located in Air Quality Maintenance Areas," prepared
      by Booz, Allen & Hamilton, Inc., March, 1976.

17.   U.S. EPA, "Mobile Source Emission Factors," Final
      Document, EPA 400/9-78-006, March, 1978.

18.   U.S. EPA, "Preparation of Environmental Impact State-
      ments," 40CFR Part 6, April 14, 1975.

19.   U.S. EPA, "Process Design Manual for Nitrogen Control,"
      Technology Transfer, 1975.

20.   U.S. EPA, "Secondary Impacts of Transportation and
      Wastewater Investments:  Research Results," Report
      No. EPA-600/5-75-013, July, 1975.

21.   U.S. EPA, "A Study of Pesticide Disposal in a Sewage
      Sludge Incinerator," EPA 68-01-1587, 1975.
OHIO EPA

22.   Ohio EPA, Untitled report on the air quality impacts
      of sludge incineration at the Jackson Pike and
      Southerly wastewater treatment plants, August 3, 1978.

23.   Ohio EPA, "Procedures for Archeological and Historical
      Preservation," undated.

24.   Ohio EPA, "Water Quality Standards," Ohio Administrative
      Code Regulations 3745-1 through 3745-1-.14, formerly
      EP-1-01 through EP-1-09, recodified January 31,  1977;
      Amended December 30, 1977, Effective February 14, 1978.


                           JJ-2

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.MID-OHIO REGIONAL PLANNING COMMISION (MORPC)

25.   Halig,  W.C.,  et.  al., "Water Supply Plan (Revised)
      for Columbus-Franklin County,  Ohio, Prepared for the
      Mid-Ohio Regional Planning Commission,  1972.

26.   MORPC,  "Public Services and Facilities  Profile:   Fire
      Protection Services in Franklin Countv," February 1977.

27.   MORPC,  "Potential Residential  Development:   Columbus
      and 20  Adjacent Municipalities," July 1975.

28.   MORPC,  "A Technical Report on Year 2000 Land Use and
      Trip Generation Variables," February 1977 (preliminary).
 CITY OF COLUMBUS

29.   Department of Development, "Development Policies
      Statement," City of Columbus,  December 1973.

30.   Department of Development, "Land Use Study,"  City of
      Columbus,  December, 1973.

31.   Department of Development, "Overall Economic  Develop-
      ment Plan," City of Columbus,  October 1976.

32.   Development Committee for  Greater Columbus,  "Columbus
      Metropolitan Growth Potential, 1977-1985," November
      1977.

33.   Ecol Science, Inc., "Environmental Assessment of Sludge
      Handling Facilities for the Columbus, Ohio Jackson
      Pike and Southerly Wastewater Treatment Plants," March
      31, 1975.

34.   Grant,  Brundage, Baker and Stauffer, Ltd., "Columbus
      Metropolitan Area, Facilities Plan Segment,  Solids
      Handling and Disposal." April 24, 1975.

35.   Malcolm Pirnie,  Inc., "Columbus Metropolitan  Facilities
      Plan:  Cost-Effectiveness  Analysis-, Environmental
      Assessment, Infiltration/Inflow Analysis,  Facilities
      Report," July, 1975 through October, 1976.

36.   PEDCo-Environmental Specialists, Inc., "Impact of
      Future Development upon Particulate Air Quality in
      Franklin County Ohio," prepared for Malcolm Pirnie, Inc.,
      Columbus,  Ohio,  November 1975.
                           JJ-3

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37.   A. E. Stilson and Assoc. Consulting Engineers, "Summary
      Report on Phase I-Feasibility of Refuse/Coal Fired
      Generating Facility," prepared for the Columbus Department
      of Public Service, December, 1975.

38.   Sykes, R. M., "Preliminary Report .on Elimination of
      Filamentous Blue-Green Algae at the Southerly Wastewater
      Treatment Plant," for the Division of Sewerage and
      Drainage, City of Columbus, Ohio, April, 1978.
 GENERAL

39.   Cavender, T. M.,  "Checklist of Fishes for the Big
      Walnut Creek Drainage," Ohio State University Museum of
      Zoology, Columbus,  Ohio, 1974.

40.   Council on Environmental Quality, "Preparation of
      Environmental Impact Statements," 40CFR Part 1500,
      August 1, 1973.

41.   Eckenfelder, W. W., and O'Connor, D.  J., Biological
      Waste Treatment,  Pergamon Press, New York,-N.Y.,  1961.

42.   Fennelly, P. F.,  "Primary and Secondary Particulates
      as Pollutants, A Literature Review,"  Journal of Air
      Pollution Control Association, July,  1975.

43.   Gordon, R. B., "The Natural Vegetation of Ohio in
      Pioneer Days," Bulletin Ohio Biological Survey,
      Volume III, No. 2,  1969.

44.   Havens and Emerson, Ltd., "Water Quality Assessment,
      and Basin Modeling '- Rocky River and Tinkers 'Creek,"
      prepared for the Three Rivers Watershed District, 1974.

45.   Havens and Emerson, Ltd., "Water Quality Assessment
      and Low Flow Analysis - Muskingum Watershed," prepared
      for the Ohio EPA, 1976.

46.   Hopwood, A. P., and A. L. Downing, "Factors Affecting
      the Rate of Production and Properties of Activated
      Sludge in Plants Treating Domestic Sewage," Institute
      of Sewage Purification, 5, 3, 1961.

47.   National Academy of Sciences, "Geochemistry and the
      Environment, The Relation of Selected Trace Elements
      to Health and Disease," Volume I, 1974.
                            JJ-4

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48.    The National Register of Historic Places,  1972; and
      Supplement,  1974.

49.    North Central Regional Research Publication 235,
      "Application of Sludges and Wastewaters on Agricultural
      Land:  A Planning  and Educational Guide,"  October, 1976.

50.    Olive, J. H., "A Study of Biological Communities in
      the Scioto River as Indices of Water Quality," U.S.
      Office of Water Resources Research,  U.S. Department
      of Interior, Washington, D.C., 1971.

51.    Phinney, G.  J., "An Ecological Comparison of Two
      Streams in Central Ohio," Ph.D. Dissertation, Ohio
      State University,  Columbus, Ohio, 1967.

52.    Pimentel, et. al., "Land Degradation:   Effects on Food
      and Energy Resources," Science, Volume 194, No. 4261,
      October 8, 1976.

53.    Real Estate Research 'Corporation, The Costs of Sprawl,
      prepared for the Council on Environmental Quality;
      Department of Housing and Urban Development; and
      Environmental Protection Agency, April, 1974.

54.    Stansbury, D. H.,  "The Naiad Ixiollusks of Alum Creek
      and Big Walnut Creek Between Alger Road Bridge and
      the Scioto River," The Ohio State University Museum
      of Zoology,  Columbus, Ohio, 1974.

55.    Stansbury, D. H.,  "An Evaluation of tne Naiad Mollusk
      Fauna of Big Darby Creek in Central Ohio," The Ohio
      State University Museum of Zoology,  Columbus, Ohio,
      1972.

56.    Texas Water Development Board, "Simulation of Water
      Quality in Streams and Canals:  DOSAG-1,"  1970.

57.    Trautman, M. B., The Fishes of Ohio, Ohio State Univer-
      sity Press,  Columbus, Ohio,1957.

58.    Tsivoglou, E. C.,  and Neal, L. A., "Tracer Measurement
      of Stream Reaeration - III.  Predicting the Reaeration
      Capacity of Inland Streams," 48th Annual WPCF Conference,
      Miami Beach, Florida, 1975.

59.    U.S. Army Engineer District, Huntington, W. V.,
      "Alum Creek Lake,  Alum Creek, Scioto River Basin, Ohio,"
      Final Environmental Statement, 1973.
                           JJ-5

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61.    Waldbott, George L.,  Health Effects of Environmental
      Pollutants,  The C.  V. Mosby Company, 1973.

62.    Young, David R., and  T.  C.  Heeser,  "Inputs  of
      Chlorinated  Benzenes," Annual Report for the Year
      Ended 30 June,  1976;  Southern California Coastal Water
      Research Project, El  Segundo, California.
                           JJ-6

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